Byw’n Iach Cyf Privacy Notice
Byw’n Iach Cyf. is committed to protecting your privacy.
When deciding what personal information to collect, use and hold, we are committed to making sure that we will:
- Only collect, hold and use personal information where it is necessary and fair to do so.
- Keep your personal information secure and safe.
- Securely dispose of any personal information when it is no longer needed.
- Be open with you about how we use your information and who we share it with; and
- Adopt and maintain best practice high standards in handling any personal information.
This privacy notice explains how we use any personal information we collect about you when you use our services.
This Policy was last updated July 2020
What information do we collect about you?
We collect information about you when you register to join or book our facilities in the Byw’n Iach Cyf centres in order to gain access to our services. This information may include:
- Personal – Name, address, email, telephone numbers, date of birth, gender.
- Product or service – type of enquiry, products or services you have used or bought from us, how you heard about us, activities you are interested in, promotional offers you are interested in, membership categories of interest to you.
- Usage – activity usage and non- attendance.
- Image – if you participate in one of our activities or you become a member your photograph may be taken to allow our staff to verify your identity. Images may also be taken for marketing purposes, with your consent.
We will use this information to provide the services requested, maintain accurate records, and, if you agree, to send you marketing information about events or services we offer.
We also collect information when you voluntarily complete customer surveys, or provide feedback.
How will we use the information about you?
The information we collect about you is necessary for the performance of the contract between us.
It is used:
- For the purpose for which you provided the information, i.e. to become a member of Byw’n Iach Cyf;
- To enable us to communicate with you, and provide you information about Byw’n Iach Cyf;
- To enable us to effectively manage your customer account, and to ensure the collection of any charges that you may incur as a member of Byw’n Iach Cyf;
- To monitor our performance in providing services to you;
- To gather statistical information to allow us to plan future provision of services and to obtain your opinion about our services.
- To administer and provide products and services you request or have expressed an interest in.
- To enable us to administer any competitions or other offers/promotions which you enter into
- To communicate with you in the event that any products or services you have requested are unavailable.
- For fraud screening and prevention purposes.
- For record keeping purposes.
- To carry out market research so that we can improve the products and services we offer.
- To track your activity on our digital platforms.
- To create an individual profile for you so that we can understand and respect your preferences.
- To personalise and improve your experience on our digital platforms.
- To personalise and/ tailor any communications that we may send you.
- For profiling purposes to enable us to personalise and/or tailor any marketing communications that you may consent to receive from us.
- To a record of your fitness and swimming levels.
- To provide you with a membership subscription card to gain member access to facilities.
- To send subscription notices to you.
- To provide you with a membership.
- To retain your personal information on our membership database for the duration of your membership.
- To contact you with relevant correspondence.
- To provide you with specific marketing information based on your choices.
- To utilise images/ videos in marketing with your consent.
Keeping your personal data safe
Your personal information is kept securely on our Leisure Management System which is stored by Cyngor Gwynedd. Any personal information of those that have signed and consented to use PulseMove software will be stored on a database externally in Dublin by a company called Pulse Fitness.
Your data will only be used for the purposes of managing your centre use and is used in a way that protects your privacy.
Your data may also be accessible to the suppliers of our leisure management systems. These suppliers have committed to handling data in accordance with the requirements of the General Data Protection Regulation (GDPR), and will only do so to the extent that is required to maintain the library management systems.
Disclosing information to outside parties
We will only disclose your information to another 3rd party, when necessary and lawful.
Byw’n Iach is required by law to protect the public funds it administers and so may use any information you have provided for the prevention, detection and investigation of fraud and irregularity, for the performance of a contract, or, task carried out in the public interest, or to comply with a legal obligation. Part 6 of the Local Audit and Accountability Act 2014 and the Accounts and Audit (Wales) Regulations are the Legal basis.
We will not share your information for marketing purposes with companies outside Byw’n Iach Cyf.. Your information will not be transferred or shared with any organisation outside of the European Economic Area (EEA).
The information you provide may be used for research, historical or statistical purposes. Where this is the case the relevant data will be anonymised first to remove any identifying features.
If you consent to us collecting and sharing information about your ethnic background, your religious beliefs, or any disability that you may have we will only do so in order to meet our duties under the Equality Act 2010 and to ensure that the service that we provide to you is suitable for your needs.
When do we collect personal data about you?
We may collect personal data about you to provide the best experience possible when you:
- Visit one of our websites, online booking services or mobile app.
- When you buy or enquire about any of our services online or offline.
- When you talk to us on the phone.
- Register to be a customer with us or book to receive any of our services.
- Fill in a form or survey for us.
- Carry out a transaction on our website.
- Participate in a competition or promotion or other marketing activity.
- Contact us, for example by email, telephone or social media.
- Participate in interactive features on any of our websites.
How long we will hold your information
The information you supply will be kept for the minimum period necessary for our purposes. When we dispose of personal information, we will do so in a secure way.
We will only share your information with the NHS Test, Trace a Protect (TTP) should they contact us, we will not do anything unless they contact us.
Sharing of your information will be for Health & Safety reasons and legal duty of care to our staff and other attendees at our facilities.
Details of your attendance recorded at our facilities will be in-line with our current retention policy.
The law gives you a number of rights:
Asking for information about yourself
You have the right to ask for all the information that we have about you.
However, we cannot give you information if the record includes:
- Confidential information about other people; or
- Information that a professional believes would cause serious harm to the physical or mental welfare of yourself or someone else; or
- If providing the information would prevent us from preventing or solving a crime
Asking us to correct information that you believe is incorrect
You should inform us if you believe that information about you is incorrect.
It may be possible that we will be unable to change or delete the information on every occasion but we will correct anything that is factually incorrect.
Up to one month is allowed to respond to requests; however, this could be extended by up to a further two months if the application is bulky or complex.
Ask us to delete information (right to be forgotten)
You may ask us to delete your information where there is no good reason for us to continue to hold on to it, for example:
- Where your personal information is no longer needed
- Where you have withdrawn your consent
- Where your information has been used illegally
- Where there is a legal requirement to delete the information
- Where you have objected to the processing of your information
- Where data has been collected as part of an on-line service for children (uploading an app or social media)
We cannot delete your information where:
- The law states that we must keep it
- It is used for freedom of expression
- It is used for public health purposes in the public’s interest
- It is used for research or statistical purposes
- It is necessary for legal claims.
Asking us to restrict the use made of your personal information
You have the right to ask for this where:
- You have found that information about you is incorrect and you have informed us
- You have objected to processing and we need time to determine whether our basis outweigh the rights of the individual
- We do not have a legal right to use the information but you wish us to restrict the use rather than delete it completely
- We do not have any reason to retain it but you need it to establish, execute or defend a legal claim
- Up to one month is allowed to respond to requests; however, this could be extended by up to a further two months if the application is bulky or complex.
Asking us to move your information to another provider (data portability)
You have the right to ask for your personal information in a common format or for it to be given to another service provider.
However, this can only happen if:
- We use your information with your permission or through a contract
- The processing is done automatically (by a computer)
Objecting to the processing of information
You have the right to object under the following circumstances:
- We have processed your information on the basis of legal interests or an official public/authority task;
- Where there is public marketing;
- For processing due to research or statistics
We will comply with the request unless:
- There are strong, legal reasons for processing
- There is a need to establish, execute or defend legal claims.
Claims in relation to automated decisions and profiling
You have the right to ask for an explanation about any decisions made by a computer (i.e. decisions without any intervention by an individual).
You can query any decisions made by a computer about you, unless this needs to be done for a contract, there is a legal requirement, or you have given your permission for this to happen.
It is also possible for you to object to any ‘profiling’, namely when decisions are made about you that are based on your personal information, e.g. health condition.
We will inform you if we use your personal information to profile you.
How to contact us
Please contact us if you would like update your personal details, or you wish to cancel your Byw’n Iach membership:
Telephone: 01286 679679
Write to: DPO, Byw’n Iach Cyf. Plas Llanwnda,
Stryd y Castell, Carenarfon, Gwynedd. LL55 1SE