PRIVACY AND COOKIES POLICY
JUST FOR FUN
HOLIDAY CLUB LIMITED PRIVACY NOTICE FOR PARENTS
1 INTRODUCTION
1.1 We are
committed to protecting and respecting your and your child’s privacy. Just for
Fun Holiday Club runs children’s daytime activities camps across Wiltshire. In
this privacy notice, references to “we”, “us”, “our”, or “Just for Fun Holiday
Club” is a reference to Just for Fun Holiday Club Limited and the activity camp
which your child is attending, may be attending, or has attended.
1.2 This privacy
notice sets out the basis on which any personal data we collect from you or
your child, or that you provide to us, is handled by us. We also have a privacy
notice addressed to your child. This is available on our website.
1.3 Please read the
following carefully to understand our views and practices regarding your and
your child’s personal data and how we will treat it.
1.4 For the
purposes of the General Data Protection Regulation 2016/679 (“GDPR”), we are
the data controller and our trading address is 27-28 Commercial
Road, Swindon SN1 5NS.
1.5 If you are
reading this privacy notice online, we recommend that you print and retain a
copy for future reference.
2 INFORMATION WE COLLECT ABOUT YOU AND YOUR CHILD
Information you
give us
2.1 You may give us
personal data about you or your child, in several ways; these include:
2.1.1 using, visiting
or interacting with our website (such as filling out forms or registering on
our website);
2.1.2 visiting one
of our activity camps;
2.1.3 corresponding
with us by phone, e-mail or post; and
2.1.4 sending
information directly to us, for example when paying our fees, giving us medical
records or information about your child’s health, completing activity camp
registration forms, signing up to our terms and conditions or providing
information as requested by us and/or which is necessary from time to time.
2.2 The information
you give us may include the following information about you and / or your
child:
2.2.1 full name;
2.2.2 gender;
2.2.3 date of
birth;
2.2.4 contact
details (including home address, e-mail address, and mobile, home and/or work
phone number);
2.2.5 parent login
information (i.e. username and password) for the website;
2.2.6 financial and
credit card information;
2.2.7 education and
health records (including special education needs, medical or physical
conditions and/or accidents);
2.2.8 current
registered doctor’s surgery;
2.2.9 family
circumstances (including your relation to the child); and
2.2.10 which camp
site(s) your child visited.
Technical
information we collect about you when you visit our website.
2.3 With regard to
each of your visits to our website we may automatically collect the following
information:
2.3.1 technical
information, including the Internet Protocol (IP) address used to connect your
computer to the Internet, browser type and version, time zone setting, browser
plug-in types and versions, operating system, and platform; and
2.3.2 information
about your visit, including the full Uniform Resource Locators (URL)
clickstream to, through and from our website (including date and time); pages
you viewed or searched for; page response times, download errors, length of
visits to certain pages, page interaction information (such as scrolling,
clicks, and mouse-overs), and methods used to browse away from the page and any
phone number used to call our number.
2.4 Our website may
contain links to and from the websites of our partner networks, advertisers,
suppliers and affiliates. If you follow a link to any of these websites, please
note that these websites have their own privacy policies and that we do not accept
any responsibility or liability for these policies. Please check these policies
before you submit any personal data to these websites.
Information we
receive from other sources.
2.5 We may be
working closely with third parties (including, for example, your child’s
current school, medical practitioners, photographers, local authorities,
education authorities, business partners, payment and delivery services, debt
collectors, lawyers, and credit reference agencies) and may receive information
about you from them.
2.6 We may also use
CCTV footage to ensure the activity camp is safe. We may receive information
about you if you use any of the other websites we operate or the other services
we provide.
3 COOKIES POLICY
3.1 Our website
uses cookies to distinguish you from other users of our website. This helps us
to provide you with a good experience when you browse our website and also
allows us to improve our site. For detailed information on the cookies we use
and the purposes for which we use them, please see our cookie policy.
4 CONTACT US
4.1 Questions,
comments and requests regarding this privacy notice are welcomed and should be
addressed to the Just for Fun Holiday Club Data Protection Co-Ordinator at
info@justforfunholidayclub.co.uk or write to us at Just for Fun Holiday Club, 27-28 Commercial
Road, Swindon SN1 5NS.
5 USES MADE OF THE INFORMATION
Information you
give to us.
5.1 We will use the
information you give to us to pursue the following legitimate interests:
5.1.1 to provide
daytime activities for your child;
5.1.2 to protect
the welfare of your child and to promote the objects and interest of Just for
Fun Holiday Club and the Active Learning Group;
5.1.3 to store this
information on our chosen management information system;
5.1.4 to manage any
queries or disputes you or your child may have with us or that we have with you
or your child;
5.1.5 to enforce
our terms of use with you or any other contract we may have with you;
5.1.6 where your
child is attending or has attended one of our daytime activity camps, to
provide you with information about other similar services (for example, summer
camps) that we offer as part of extra-curricular experiences and overall
development of your child; and
5.1.7 to send out
surveys to you by email or SMS in order for you to provide feedback to us on
our daytime activity camps.
5.2 In order to
pursue the legitimate interests referred to in paragraph 5.1 we rely on
software applications and other technology to process personal data about you
and your children. This includes our management information system. The third
parties we use to deliver these applications are carefully chosen and vetted by
us to ensure that, among other things, your and your child’s personal data is
kept secure. For further information on the kind of technology we use, please
contact our Data Protection Co-Ordinator.
5.3 We will also
use the information you give to us as is necessary to carry out our obligations
arising from the contract (or potential contract) between you and us and to
provide you with the information and services that you request from us. For
example, we will provide daytime activity camps for your child and will use
personal data where necessary to deliver this service. We will also use your
personal information to invoice you for our services pursuant to the contract
between you and us. We will also require a certain amount of personal
information about you and your child at the registration stage.
5.4 Inevitably,
there will be an overlap between what we do that is necessary to (a) perform
our contract with you and (b) pursue a legitimate interest although we have
tried our best to demarcate these as set out above. If you have any questions
about these please contact our Data Protection Co-Ordinator.
Information we
collect about you from our website.
5.5 We will use
this information for the following legitimate interests:
5.5.1 to contact
you if you have made an enquiry to us directly or via our online enquiry form
and/or to inform you about available places at the camp in the future;
5.5.2 to administer
our website and for internal operations, including troubleshooting, data
analysis, testing, research, statistical and survey purposes;
5.5.3 to improve
our website to ensure that content is presented in the most effective manner,
and your online experience is as effective and appropriate as possible, for you
and for your computer; and
5.5.4 as part of
our efforts to keep our website safe and secure.
Information we
receive from other sources.
5.6 We may combine
this information with information you give to us and information we collect about
you. We may use this information and the combined information for one of the
purposes set out above (depending on the types of information we receive).
5.7 Also, health
practitioners may provide us with information (particularly sensitive personal
data) about your child which may need to be added to our medical, special
educational needs or child protection file. This kind of processing of
sensitive personal data may be necessary (a) for medical diagnosis or provision
of health care and/or (b) to protect the vital interests of your child or
another person taking into account the mental and physical capacity of your
child.
5.8 In order to
achieve the purposes described in paragraph 5.7, we may do the following:
5.8.1 keep a list
of your child’s allergies or medical requirements in case of emergency. It is
necessary for the camp to have a list readily available to our staff so that we
are able to look after your child promptly in the event of a medical emergency;
and
5.8.2 rely on
software applications and other technology to process medical information (such
as allergies, accident’s and injuries) about you and your children. For further
information on the kind of technology we use, particularly in the context of
processing sensitive personal data about your child, please contact our Data
Protection Co-Ordinator.
When we disclose
information
5.9 In order to
pursue one of the legitimate interests set out above, we may share your and
your child’s personal information with:
5.9.1 local
authorities, SEN co-ordinators, social services or the police where we have
reason to believe there are safeguarding concerns in respect of your child;
5.9.2 where your
child is not British, we may have to provide information about you or your
child to UK Visas and Immigration;
5.9.3 business
partners, professional advisors, debt collectors, suppliers and sub-contractors
for the performance of any contract we enter into with them or you; and
5.9.4 credit
reference agencies for the purpose of assessing your credit score where this is
a condition of us entering into a contract with you.
5.10 We may
disclose your personal information to third parties if we are under a duty to
disclose or share your personal data in order to comply with any legal
obligation, or in order to enforce or apply our terms of use and other
agreements. This includes exchanging information with other companies and
organisations for the purposes of fraud protection and credit risk reduction.
Where we need to
get your consent
5.11 We will not
market services to you (other than in accordance with paragraph 5.1.6 above)
without your consent and you have the right to ask us not to use your contact
details for marketing.
5.12 We will also
seek your permission if we decide to post any photographs of your child on any
of our marketing materials (including our prospectus, advertisement’s or
website).
5.13 You or your
child do not have to give us details about your child’s race, religion, or
ethnicity if you do not want to. If you do provide us with this information, we
only use these details to assist us with the day-to-day running of the daytime
activity camp (for example, if your child’s religion means that he or she has
particular dietary requirements then we will of course be much better informed
if we have this information to cater to your child’s requirements) and for
equal opportunities monitoring purposes.
Where you have
given consent to the above, you can withdraw this consent at any time.
6 TRANSMISSION OF PERSONAL INFORMATION OUTSIDE THE EEA
6.1 The data that
we process about you and your child may be transferred to, and stored at, a
destination outside the European Economic Area (“EEA”). We try to limit this
where possible, but it may be necessary where, for example, one of our
suppliers has a data centre outside the EEA. We will take all steps reasonably
necessary to ensure that your and your child’s data is treated securely and in
accordance with this privacy notice and that the appropriate legal safeguards
are in place prior to the transfer, for example particular ensuring that any
contracts between us and the recipient of the information have EU-approved
standard data protection clauses or are recognised as having adequate
protection for the transfer of personal data.
7 YOUR RIGHTS
7.1 Under the GDPR,
you and your child have the following rights:
7.1.1 Right to
correction. You have the right to have inaccurate personal data about you or
your child rectified.
7.1.2 The right to
erasure. You have the right to request that we delete your and your child’s
personal data where: (a) the personal data are no longer necessary in relation
to the purposes for which they were collected or processed; (b) you withdraw
your consent to processing for which we previously obtained your consent; (c)
you object to the processing and, as a result, we agree to cease that
processing (please see paragraph 7.1.5 for more details); (d) the personal data
has been unlawfully processed; and (e) we are required to erase the personal
data in order to comply with the law.
7.1.3 Right to
restriction. You have the right to obtain from us the restriction of processing
where: (a) you contest the accuracy of the personal data we hold about you; (b)
the personal data has been unlawfully processed; (c) we no longer need the
personal data but they are required in limited circumstances; and (d) you
object to the processing and, as a result, we agree to cease that processing
(please see paragraph 7.1.5 for more details).
7.1.4 Right to
request transfer. In certain circumstances, you have the right to receive
personal data from us in a structured, commonly used and machine-readable
format and the right to transmit it to a third party organisation.
7.1.5 Right to
object. You have the right to raise an objection to any of our processing in paragraphs
5.1 and 5.2. Please tell us if you object to any type of processing that we do
and we will work with you to address any concerns you may have.
7.1.6 Right to
object to marketing. If you do not want us to process your personal data for
direct marketing, please tell us and we will ensure that we no longer do this.
7.1.7 Right to
complain to the ICO. Whilst we would always prefer it if you approached us
first about any complaints or queries you may have, you always have the right
to lodge a complaint with the Information Commissioner’s Office.
7.1.8 Right to
request access. You have the right to access personal data we hold about you.
We encourage you to contact our Data Protection Co-Ordinator and request our
standard SAR form for you to complete in order to help us process your request.
8 HOW LONG WE KEEP PERSONAL INFORMATION
8.1 We will not
keep any personal data about you for any longer than is necessary for the
purposes for which the personal data are processed.
8.2 We follow a
personal data retention policy which determines how long we keep specific types
of personal information for. For further information about the criteria, we use
to determine what periods we keep specific information, please contact our Data
Protection Co-Ordinator. By way of summary, once a child in our records reaches
the age of 15, we will delete their records soon afterwards (unless we think
there is a good reason to keep them longer).
9 USE OF OUR WEBSITE
9.1 Where we have
given you (or where you have chosen) a password which enables you to access
certain parts of our website, you are responsible for keeping this password
confidential. We ask you not to share a password with anyone. Unfortunately,
the transmission of information via the internet is not completely secure.
Although we will do our best to protect your personal data, we cannot
guarantee the security of your data transmitted to our website; any
transmission is at your own risk. Once we have received your information, we
will use strict procedures and security features to try to prevent unauthorised
access.
10 CHANGES TO OUR PRIVACY NOTICE
10.1 Any changes we
make to this privacy notice in the future will be posted on our website and,
where appropriate, notified to you by e-mail. Please check back frequently to
see any updates or changes to our privacy notice.
Dated 26 Jan 2021