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Privacy Policy

Culture and Leisure NL Ltd

Privacy Notice – COVID 19 Coronavirus Test and Protect Strategy

  • Who we are

CultureNL and NL Leisure are trading names of Culture and Leisure NL Ltd. Culture and Leisure NL Ltd is a registered Scottish charity, charity number SCO 43891. We are an Arms Length External Organisation (ALEO) of North Lanarkshire Council. Our head office is at Summerlee Museum Of Scottish Industrial Life, Heritage Way, Coatbridge, Lanarkshire, ML5 1QD. Culture and Leisure NL Ltd is the data controller and responsible for your personal information.

  • Information we are collecting about you

For the health and safety of the customers and staff in these premises, we are recording the name and contact details of everyone who enters to support NHS Scotland’s Test and Protect Strategy. This information will be used to enable NHS Scotland to contact you should you have been in these premises around the same time as someone who has tested positive for coronavirus. Contacting people who might have been exposed to the virus is an important step in stopping the spread.

  • Commitment to Privacy

We are committed to protecting the privacy and confidentiality of any personal information that we hold.  This privacy notice will tell you how we look after this information and tell you about your rights.

We will ensure that your personal information is kept secure, in line with the General Data Protection Regulation (“GDPR”) and the Data Protection Act 2018. We will only collect the minimum information necessary to fulfil this purpose; when we don't have a need to keep this information about you, it will be disposed of in a secure manner.

Information Commissioner’s Office

You have the right to make a complaint at any time to the Information Commissioner’s Office, the UK data protection regulator who can be contacted via the contact details below, however, we would welcome the opportunity to discuss your concerns with you before you do so:

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Phone: 0303 123 1113 (local rate) or 01625 545 745 or visit their website at

  • Data Protection Officer

We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, you can contact the DPO via the contact details below:

Data Protection OfficerEmail: informationrequests@culturenl.co.uk
Culture and Leisure NL LtdTelephone: 01698 274589

North Lanarkshire Heritage Centre

High Road

Motherwell

ML1 3HU

  • The personal information we are asking you to provide

Along with the date and time of your arrival and departure we will ask for your name and contact telephone number. If you do not have a telephone number, you have the option to provide a postal address or an email address. Customer health information will not be requested or stored.

  • How your personal information is collected?

We will ask you for this information when you attend these premises.

  • Purposes for which we will use your personal data

As described above, the purpose for which we are processing your personal data is to assist with NHS Scotland’s Test and Protect strategy in relation to the coronavirus public health epidemic. This will involve the gathering and, when necessary, the sharing of information with NHS Scotland as the responsible body for Test and Protect. We will only share this information with NHS Scotland in relation to the coronavirus public health epidemic. This data will not be used for any other purpose including any marketing purposes.

  • Lawful Basis for Collection and Sharing of this Information

We will use your personal information on the following basis:

Under data protection law, GDPR Article 6(1) (e ) we are allowed to collect and process personal information where necessary to perform a task carried out in the public interest or in the exercise of official authority vested in us. Collection of this information will assist us in providing services and carrying out official functions safely. It will help us to assist with NHS Scotland’s Test and Protect Strategy in relation to the coronavirus public health epidemic.

  • Sharing your personal information

We will share the personal information you provide only with NHS Scotland and only for the purposes described in this notice. In order to assist in the containment of the virus, we will only share your data when it is requested directly by NHS Scotland. This will only be in the unlikely event there is a cluster of coronavirus cases linked to the venue. Information will be transferred securely to NHS National Services Scotland who will use the data to contact trace those who were in the establishment at the same time as the positive case, and will provide guidance and support to those who may be advised to self-isolate. Read further information on the NHS Scotland Test and Protect strategy on the NHS website at: www.informationgovernance.scot.nhs.uk/use-of-your-data-for-track-trace-isolate-tti/

  • How long will we hold your information

Your personal data will be retained only for the purposes stated in this privacy notice and will be held by us for no more than 3 weeks (21 days). All personal data will be held and disposed of in a safe and secure manner.

  • Your Legal Rights

You have rights under data protection laws in relation to your personal information. You have the right to

  • Request access to your personal information (known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Not be subject to a decision based on solely automated processing if that produces a legal effect concerning you or similarly significantly affects you. Note that this right does not apply if the decision is (i) necessary for entering into, or performance of, a contract between us and you; (ii) authorised by law; or (ii) based on your explicit consent
  • If at any point within the 21 days after your visit you decide you’d like us to delete the personal data you provided, please advise us and we will delete the information which you have provided.

If you wish to exercise any of the rights set out above, please contact us on 01698 274589.

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

For information about how Culture and Leisure NL Ltd process wider personal information for other purposes please see our privacy notice at: https://culturenl.co.uk/privacy-statement/

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Download our privacy policy

Culture and Leisure NL Ltd ("we"; "us"; "our") respects your privacy and is committed to protecting your personal information at all times.

We are the data controllers in respect of the personal information which we hold about you. As data controllers, we are responsible for determining how we use the personal information which we hold about you.

In accordance with the General Data Protection Regulation ((EU) 2016/679) (the "GDPR"), this privacy notice sets out how we use your information in the course of operating our business and also sets out your legal rights in relation to the personal information we hold about you.

This privacy notice applies to our use of any personal information which we may collect from you through your use of this website or which we may otherwise collect from you as one of our customers or members (i.e. a member of NL Leisure). This includes any personal information which we may collect from you via face-to-face communication, post, phone, email, social media or any other means of communication. This privacy notice also applies to any information about you which we may collect from any third party in the course of running our business.

The information we collect about you

We may collect, use, store and transfer a number of different kinds of personal information about you which we have grouped together as follows:

  • Identity Data includes [name, title, date of birth and gender].
  • Contact Data includes [postal address, email address and phone numbers].
  • Financial and Transaction Data includes [bank account and payment card details, details about payments from you to us (e.g. membership payments) and details of any services / products you have purchased from us].
  • Technical Data includes [internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website].
  • Profile Data includes [details of your membership of NL Leisure; details of purchases or orders made by you; subscriptions by you to our newsletters / mailing lists or any other services / products we provide; details of any interests, preferences, survey responses, feedback or complaints which you have communicated to us; details which you have provided in relation to taking part in any competition or promotion sponsored by us; and details of any sensitive personal information which you have provided to us (e.g. details about any health conditions)].
  • Usage Data includes [information about how you use our website, services and products].
  • Marketing and Communications Data includes [your preferences in receiving marketing materials, promotions and/or newsletters from us and your communication preferences].

We may also be required to process additional information about you from time to time in the course of operating our business where this is necessary for the purposes of administering our business correctly and/or promoting our services / products effectively.

Where we need to collect personal information by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services / products). In this case, we may have to cancel a service or product you have ordered from us but we will notify you if this is the case at the time.

How your information is collected

We will mainly collect personal information about you through direct interactions with you. You may give us your personal information by filling in forms or by corresponding or engaging with us through our website or by face-to-face communication, post, phone, email, social media or any other means of communication. This includes personal information you provide when you: (i) purchase or use our services / products; (ii) register as a member of NL Leisure; (iii) subscribe to our newsletters / mailing list or any other services / products; (iv) request marketing materials to be sent to you; (v) enter a competition, promotion or survey; or (vi) provide us with any feedback or other communications.

As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal information by using cookies, server logs and other similar technologies.

We may also collect information about you from other entities in our group, from our business partners and from various other third party service providers, such as professional advisers, analytics providers, advertising networks, search information providers, fraud prevention and credit reference agencies and providers of IT / technical services, payment services and/or delivery services.

It is important that the personal information we hold about you is accurate and up to date. Please let us know if your personal information changes at any time during your relationship with us.

How we use your information

We will only use your personal information where we have a lawful basis for doing so. Most commonly, we will use your personal information in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for the purposes of our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those legitimate interests.
  • Where we need to comply with any legal obligation or regulatory requirement.

We may also use consent as a lawful basis for providing you with marketing communications in certain circumstances. For further details, please see the Marketing section below.

The table below sets out a description of the main ways we plan to use your personal information and which of the relevant lawful grounds for processing we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Please note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you require details about the specific lawful ground we are relying on to process your personal information where more than one lawful ground has been set out in the table below.

Purpose / Activity

Lawful grounds for processing

[Registering you as a member of NL Leisure or registering you as a customer of any other service / product provided by us.]

[Necessary for the performance of a contract with you.]

[Processing your orders / purchases as a customer and providing you with services / products in connection with any contract which you have entered into with us.]

[Necessary for the performance of a contract with you.]

[Communicating with you for the purposes of providing you with services / products which you have ordered / purchased from us.]

[Necessary for the performance of a contract with you.]

[Necessary for our legitimate interests in operating our business correctly and promoting our services / products effectively.]

[Managing our relationship with you, including reviewing and responding to any questions, feedback or other communications submitted by you.]

[Necessary for the performance of a contract with you.]

[Necessary to comply with our legal obligations.]

[Necessary for our legitimate interests in operating our business correctly, promoting our services / products effectively, developing and improving our services / products and our facilities and responding to queries or complaints effectively.]

[Managing and processing all payments, fees and/or charges and collecting and recovering any sums owed to us.]

[Necessary for the performance of a contract with you.]

[Necessary for our legitimate interests in processing payments made by our customers and members and recovering any debts due to us.]

[Providing you with the opportunity to take part in competitions or promotions.]

[Necessary for our legitimate interests in promoting our services / products effectively and developing and growing our business.]

[Providing you with the opportunity to complete surveys. Reviewing any survey responses or other communications from you in relation to your experience of our services / products and our facilities.]

[Necessary for our legitimate interests in studying how customers experience our services / products and facilities and developing and improving our services / products and facilities.]

[Administering and protecting our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).]

[Necessary to comply with our legal obligations.]

[Necessary for our legitimate interests in operating our business correctly, ensuring the provision of effective administration and IT services, maintaining network security and preventing fraud.]

[Delivering relevant website content and online advertisements to you and measuring and understanding the effectiveness of the advertising we serve to you.]

[Necessary for our legitimate interests in studying how customers use our services / products, developing and improving our services / products, keeping our website up to date and relevant, growing our business and informing our marketing strategies.]

[Using data analytics to improve our website, services / products, marketing, customer relationships and experiences.]

[Necessary for our legitimate interests in keeping our website up to date and relevant, developing and improving our services / products, growing our business and informing our marketing strategies.]

[Providing you with marketing materials, newsletters and promotions and also providing you with suggestions and recommendations about services / products that may be of interest to you.]

[Necessary for our legitimate interests in developing and promoting our services / products and growing our business.]

[In certain circumstances, we may use consent as a lawful basis for processing personal information for direct marketing purposes.]

Please note that we may also process sensitive personal information about you (e.g. information on physical and/or mental health) in circumstances where: (i) you have provided your explicit consent; (ii) the processing relates to information which has been manifestly made public by you; (iii) the processing is necessary for reasons of substantial public interest; (iv) the processing is necessary for the establishment, exercise or defence of legal claims; or (v) the processing is otherwise permitted in accordance with the GDPR and/or the Data Protection Act 2018.

Marketing

We may use your personal information to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services, products, promotions and/or offers may be relevant for you for the purposes of marketing.

You will receive marketing materials from us if you have requested this information from us. You may also receive marketing materials from us if you have purchased services or products from us (e.g. membership of NL leisure), or engaged in negotiations with us in connection with our services or products, or if you have provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving marketing materials. In these circumstances, we will provide you with marketing materials on the lawful basis that it is necessary for the purposes of our legitimate interests in developing and promoting our services and products and growing our business.

If you have provided us with your details and none of the above circumstances apply, you will only receive marketing materials, email newsletters or email promotions from us in circumstances where you have provided an opt-in consent which confirms that you want to receive such marketing from us. In these circumstances, you have the right to withdraw your consent at any time to the use of your personal information for marketing purposes.

Opting out of marketing

You have the right to object at any time to the processing of your personal information for direct marketing purposes. If you object to such processing, we will cease to process your personal information for direct marketing purposes.

You can ask us to stop sending you marketing materials at any time by: (i) following the opt-out links on any marketing communication, email message or email newsletter sent to you; or (ii) contacting us by email at info@nlleisure.com.

How long we retain your information

We will retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Disclosures of your information

We may need to share your information with various third parties which provide services to us or act on our behalf in connection with the operation of our business. In particular, your information may be disclosed to the following categories of third parties:

  • [Other entities in our corporate group.]
  • [Professional advisers (including legal advisers and financial advisers), auditors, insurers, bankers, and financial organisations.]
  • [Other third party service providers which provide services to us in connection with the operation of our business, including but not limited to: IT and system administration services and other technical services; data analytics services; marketing services; fraud prevention and credit reference services; logistics and delivery services; and payment processing services.]
  • [Trade associates and business partners.]
  • [Third parties with whom we may enter into negotiations in respect of a commercial agreement, e.g. joint business venture.]
  • [HM Revenue & Customs and/or any other public authority or regulatory authority in circumstances where we are required to disclose personal information by law.]

We require all third party service providers to respect the security of your personal information and to treat it in accordance with the law. We do not permit our third party service providers to use your personal information for their own purposes and only permit them to process your information for specified purposes and in accordance with our instructions.

International data transfers

Please note that there may be instances where it may be necessary for us to transfer your information outside the European Economic Area, e.g. if we use third party service providers from another country. In these circumstances we shall put in place suitable safeguards to ensure that your information is held securely. If you require further information about the safeguards put in place you can request it from us by contacting us by email at the email address set out below.

Your legal rights in relation your information

Under the GDPR, you have a number of legal rights in relation to the personal information which we hold about you. We respect your legal rights in relation to your information and aim to uphold your rights in everything we do. Your legal rights under the GDPR include the following:

  • Subject access right – You can ask us to provide you with a copy of the personal information which we hold about you and a description of how we use your information.
  • Right to rectification – If you believe any information we hold about you may be inaccurate or incomplete, you can require us to rectify these inaccuracies.
  • Right to erasure / Right to be forgotten – You can require us to erase your information in certain circumstances. However, please note that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Right to data portability – Where we process your information using automated means of processing on the basis of your consent or for the purposes of performing a contract with you, you can request that we supply such information to another party in a machine-readable format.
  • Right to restriction of processing – You can require us to restrict or suspend our processing of your information in certain limited circumstances.
  • Right to object to processing – Where we process your information on the lawful basis that such processing is necessary for the purposes of our legitimate interests, you have the right to object to us processing your information in certain circumstances.
  • Right to object to processing for direct marketing purposes – You have the right to object at any time to the processing of your information for direct marketing purposes. If you object to us processing your information for direct marketing purposes, we will no longer process your information for such purposes.
  • Right to withdraw consent – If we process your information on the basis of your consent, you have the right to withdraw your consent at any time to the processing of your information. However, please note that this will not affect the lawfulness of any processing of your information carried out before you withdraw your consent.

How to contact us

Please get in touch if you have any questions about how we use your information or you wish to contact us about your legal rights or if you have any complaints or feedback about our use of your information. Please contact us at any time by sending an email to us at info@nlleisure.com.

If you wish to submit a complaint or express any concerns about our use of your information, please contact us in the first instance. We will do our best to resolve your complaint or address your concerns to your satisfaction. However, if you feel that we have not resolved your complaint or addressed your concerns, please note that you have right to make a complaint at any time to the Information Commissioner's Office, the UK supervisory authority for data protection issues.

Please note that we may update this privacy notice at any time. Any changes to this privacy notice will be posted on our website, and where appropriate, notified to you by email.