Cookie & Privacy Policy

PRIVACY POLICY

PROTECTING YOUR DATA ON OUR WEBSITE

Last updated: 3rd August 2024

Above The Bay Limited, Registration number 06678201, is registered at 8Whittle Court, Knowlhill, Milton Keynes, MK5 8FT. We know that you carehow information about you is stored, used and shared and we appreciateyour trust in us to do that carefully and sensibly. This notice describes ourmeans of storing your data, using your data, and protecting your data. Ourprivacy policy forms part of, and should be read in conjunction with, ourwebsite terms and conditions (“Website Terms”).

By accepting our Website Terms, visiting Abovethebay.co.uk andabovethebay.co.uk (“websites”) registering to use our services via ourwebsite our booking software (“booking software”), or signing up to ouremail newsletters (“newsletters”), you are accepting and consenting to usprocessing your personal data in accordance with our Privacy and CookiePolicies. You may withdraw such consent at any time by letting us knowat operations@abovethebay.co.uk.

The Website, and booking software is brought to you by Above The BayLimited. Above The Bay Limited believes it is important to protect yourPersonal Data (as defined in the EU General Data Protection Regulation2016/679 (GDPR) and the Data Protection Act 1998) and we arecommitted to giving you a personalised service that meets your needs in away that also protects your data and privacy. This requires us to collectpersonal data from you. However, we want to put you in control of thatpersonal data. We want you to be aware at all times where and how yourpersonal data is being used. This is of paramount importance to us.

This policy will explain:

• What data we may collect about you
• How we collect your personal data
• What we do with your data
• Where we store your data
• How we keep your data secure
• Whether we share your data anywhere else
• The cookies we use and how you can reject these cookies
• Your rights in relation to your data

THE DATA WE MAY COLLECTINFORMATION YOU VOLUNTARILY PROVIDE

• If you contact us (by phone, email or through the Website) with an enquiry or in response to any communication from us, we may keep a record of that correspondence for three years in case we need to contact you in relation to the issue for which you contacted us, for operational performance improvement and/or nuisance caller management. We will not use it for marketing purposes.
• When you register to use our service or product, via the Website orBooking Software, in which case this may include your contact details, your child’s name, date of birth, and medical details, how you will pay for the product or service and your bank details.

We may also collect data from documents that are available to the public, such as the electoral register.

INFORMATION WE COLLECT ABOUT YOUR DEVICE

When you use the Website, Booking Software, Newsletters and interact with our Services, we may use technology such as that provided by GoogleAnalytics and Active Campaign to collect information about your visit to ourWebsite, Booking Software, and use of our Newsletters. In essence, these tools enable us to analyse how you and others interact with our Website, Booking Software, and Newsletters. The information we collect may include:

• your IP address;
• the type of browser you use (e.g. are you using the Chrome or Safari browser?);

• the number of sessions per browser on each device;
• the type of device (e.g. Apple) and operating system (e.g. iOS) you are using;

• timezone;
• if you opened our newsletters;
• user preferences;
• actions performed on our website; and
• which pages you visited.

WHAT WE DO WITH YOUR DATA

Personal Data about our customers is an important part of our business and we shall only use your Personal Data for the following purposes, and shall not keep such Personal Data longer than is necessary to fulfill these purposes:

• To help us to identify you when you contact us.
• To help us to identify accounts, services and/or products which you
• could have from us, or selected partners, from time to time. We may do this by automatic means using a scoring system, which uses thePersonal Data you have provided and/or any information we hold about you and Personal Data from third party agencies (including credit reference agencies).
• To help us to administer and to contact you about improved administration of any accounts, services, and products we provide.
• To allow us to carry out marketing analysis and customer profiling(including with transactional information), conduct research, including creating statistical and testing information.
• To help to prevent and detect fraud or loss.
• To provide you with marketing information about products and
• services, offered by the Pro shop, or services and events from,Above The Bay Limited / Falmouth Golf Club, and selected partners, unless you have previously asked us not to do so.
• To communicate with you about your use of our services viaWhatsApp
• We may monitor and record communications with you (including phone conversations and emails) for quality assurance and compliance.

Where you give us Personal Data on behalf of someone else, you confirm that you have provided them with the information set out in this PrivacyPolicy and that they have not objected to such use of their Personal Data.

In connection with any transaction which we enter into with you:

• We, and other companies in our group, may carry out credit and fraud prevention checks with one or more licensed credit reference and fraud prevention agencies. We, and they, may keep a record of the search. Information held about you by these agencies may be linked to records relating to other people living at the same address with whom you are financially linked. These records will also be taken into account in credit and fraud prevention checks. Information from your application and payment details of your account will be recorded with one or more of these agencies and may be shared with other organisations to help make credit and insurance decisions about you and members of your household with whom you are financially linked and for debt collection and fraud prevention. This includes those who have moved house and who have missed payments.
• If you provide false or inaccurate information to us and we suspect fraud, we will record this and may share it with other people and organisations. We, and other credit and insurance organisations, may also use technology to detect and prevent fraud.
• If you need details of those credit agencies and fraud prevention agencies from which we obtain and with which we record information about you, please write to our Data Protection Manager at Above TheBay Limited, Swanpool Road, Falmouth, Cornwall, TR11 5BQ.

You have the opportunity to withhold or withdraw your consent for the use of your personal data for purposes other than those listed above.

WHERE WE STORE YOUR DATA

We may store your information, when required, physically and electronically.

Physical Data:

• Your data may be stored physically in the forms of registers and mandate forms.
• We do not store your data physically without your knowledge.
• If we obtain your data physically, it will be destroyed after two weeks,
• or earlier at your request. We may occasionally request proof of identity before we disclose personal data to you.

Electronic Data:

• Your personal data will be stored in our Booking Software and ClubV1 software platform.
• You contact information (name and phone number) will be stored on our WhatsApp mobile phone.
• We destroy any personal data we have of you, in our BookingSoftware and Active Campaign, 5 years after your final use of our product or service. WhatsApp conversations will be deleted after the conversations have ended.

Some of our services and/or products require us to create an electronic spreadsheet with the personal data you provide through one of our third parties. This information is stored so we can gain a better understanding of you as the customer, and offer you a better user experience when using our service and/or product. We may keep the spreadsheet for two

months after you have used our service and/or product. Your information can be deleted at your request.

WHERE WE SHARE YOUR DATA

We may allow other people and organisations to use Personal data we hold about you in the following circumstances:

• If we, or substantially all of our assets, are acquired or are in the process of being acquired by a third party, in which case Personal data held by us, about our customers, will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request.
• We employ companies and individuals to perform functions on our behalf, and we may disclose your Personal Data to these parties to carry out our purposes stated in the What We Do With Your
  Data section, or, for example, for fulfilling orders, delivering packages, sending postal mail and email, removing repetitive information from customer lists, analysing data, providing marketing assistance, providing search results and links (including paid listings and links) and providing customer service. Those parties are bound by strict contractual provisions with us and only have access toPersonal data needed to perform their functions, and may not use it for other purposes.
• From time to time, the information that we collect from you may be processed outside the European Economic Area (EEA), but we have ensured that there is an adequate level of protection for such information.

WHO WE SHARE YOUR INFORMATION WITH

Your Personal Data is disclosed to our employees, on “a need to know”basis and we confirm that all such persons understand the importance of client confidentiality and privacy.

Your Personal Data may be used to contact you, to perform the fulfill mentor payment of any bookings made by you via our Booking Software.

Below is a non-exhaustive list of third parties we work with. We may work with third parties not listed below or stop working with the third parties listed below.

Name Why we work with them

GoogleAnalytics

To monitor Website performance and user experience.

Google Apps To process emails, create spreadsheets and word documents

Club V1 / Hub To monitor your sales journey with us and to provide youSpot with our Newsletters and improve the user experience.

Ticket Tailor To manage bookings for our services and/or products

WhatsApp

To send texts and communicate with you about your use of our services/products

HOW WE KEEP YOUR DATA SAFE

We do not store credit card details nor do we share customer details with any third parties, apart from the parties listed in the table above. We have strict security measures to protect Personal Data.

• We will not disclose your Personal Data to any third party except in accordance with this Privacy Policy.
• We work to protect the security of your information during transmission by using Secure Sockets Layer (SSL) software, which encrypts information you input.
• We reveal only the last five digits of your credit card numbers when confirming an order. Of course, we transmit the entire credit card number to the appropriate credit card company during order processing.
• WhatsApp messages are encrypted, so any information you share with us will not be read by others.

COOKIES AND PIXELS

‘Cookies’ are small pieces of data that are stored on your computer, mobile phone or other devices, to recognise your browser and record how you have used a website. Pixels are small blocks of code on web pages or emails that do things like allow another server to measure viewing of a webpage or email and are often used in connection with cookies.

We may use cookies to monitor how people use our site. This helps us to understand how our customers and potential customers use our website sowe can develop and improve the design, layout, and function of the sites.

You can normally alter the settings of your browser to prevent it from accepting cookies. If you do not want us to use cookies in your browser, you can set your browser to reject cookies or to tell you when a website tries to put a cookie on your computer. However, you may not be able to use some of the products or services on our website without cookies.

Please refer to your device’s help material to learn what controls you can use to remove or block cookies. Your device may have third-party add-ons that can add, disable or delete cookies. We are not responsible for these third-party add-ons, or the cookies they may place in your browser.

THIRD PARTY ADVERTISING

The Website may include third-party advertising and links to other websites. We do not provide any personally identifiable customer PersonalData to these advertisers or third-party websites.

These third-party websites and advertisers, or Internet advertising companies working on their behalf, sometimes use technology to send (or“serve”) the advertisements that appear on the Website directly to your browser. They automatically receive your IP address when this happens.They may also use cookies, JavaScript, web beacons (also known as action tags or single-pixel gifs), and other technologies to measure the effectiveness of their ads and to personalise advertising content. We do not have access to or control over cookies or other features that they may use, and the information practices of these advertisers and third-party websites are not covered by this Privacy Policy. Please contact them directly for more information about their privacy practices. In addition, the NetworkAdvertising Initiative offers useful information about Internet advertising companies (also called “ad networks” or “network advertisers”), including information about how to opt-out of their information collection.

We are not responsible for loss that you may incur when using these third party websites.

RECORDING AND PHOTOGRAPHINGEvents / Golf SESSIONS

At Above The Bay Limited, we may record and photograph our sessions for various important purposes, including marketing, security, data collection, marketing analysis, and training. These recordings and photographs help us in the following ways:

1. Marketing: We use images and video footage to showcase our coaching activities and achievements. This allows us to share the joy and success of our young footballers with the wider community, as well as potential future participants and their families.

2. Security: We may use recordings to enhance the safety and security of our sessions and facilities. It helps us monitor and address any potential issues promptly. We cannot guarantee that recording will always be maintained at all sessions.

3. Data Collection: Captured images and videos may contain valuable data for coaching and training purposes. These recordings assist us in assessing performance, improving coaching techniques, and tailoring our services to better meet the needs of our participants.

4. Marketing Analysis: We analyse recorded content to refine our marketing strategies, ensuring that our services are reaching the right audience effectively.

5. Training: Recordings are also used for training purposes. They help our coaching staff continuously improve their skills and better serve the needs of our participants.

Parental Adherence and Consent

We value the trust that parents place in our services and understand the importance of respecting individual privacy. Parents or legal guardians of children participating in our sessions are kindly requested to adhere to the following:

1. Consent: By allowing your child to participate in our sessions, you are providing consent for us to record and photograph the activities for the purposes mentioned above, including training and any future purposes aligned with our policies and values.

2. Communication: If you have any specific concerns or preferences regarding the recording and photographing of your child during sessions, please feel free to contact us. We respect individual choices and are open to addressing any concerns or special requests.

3. Respect for Privacy: While we may record and photograph sessions, we take your child's privacy seriously. We are committed to handling and storing this data securely and in compliance with data protection regulations. Images and videos will not be used inappropriately or without consent.

Thank you for your understanding and support in helping us provide a safe, enjoyable, and continuously improving experience for your child and all participants. If you have any questions or require further information about our recording and photographing practices, please do not hesitate to contact us. Your trust is invaluable to us, and we are dedicated to ensuring that your child's privacy is protected and respected.

YOUR RIGHTS

It is important to us that you are able to control your personal information.

You have the right to ask us not to process your personal information for marketing purposes, with the exception of customer communication such as welcome emails, weekly training guides, service and/or product feedback, registration reminders, booking confirmation and the like. You can exercise your right to prevent such processing at any time by contacting us at operations@abovethebay.co.uk

You can ask us for a copy of this Privacy Policy, and of any amendedPolicy, by writing to Above The Bay, Swanpool Road, Falmouth, Cornwall,TR11 5BQ or by emailing us at operations@abovethebay.co.uk. ThisPrivacy Policy applies to the handling and management of Personal Data we hold about individuals. It does not apply to information we hold about companies and other organisations.

You have the right to obtain a copy of the Personal Data that we hold about you. You can do this by emailing us at operations@abovethebay.co.uk or writing to the above postal address. There may be a nominal charge of £10to cover administrative costs.

We aim to keep the Personal Data we hold about you accurate and up to date. If you tell us that we are holding any inaccurate Personal Data about you, we will delete it or correct it promptly. Please email us
at operations@abovethebay.co.uk, or write to us at the postal address above, to update your Personal Data.

If you want to stop using the Website, Booking Software, Newsletters and our Services, you may do so. If you do, you may also want to remove any cookies that we have placed on any device used to access the Website, Booking Software, Newsletters and our Services.

CONSENT

By using the Website, Booking Software, and our Services, you consent to us using your Personal Data for the purposes explained and set out in thisPrivacy Policy.

Your consent is required for us to send you marketing communication. If you choose to remove your consent at a later time, you can do so anytime by clicking ‘unsubscribe’ at the bottom of the marketing email or
emailing operations@abovethebay.co.uk

CHANGES TO OUR POLICY

We reserve the right to change this policy at any time without notice, in which case, we will publish the amended version on this page. Where appropriate, we will notify you by email or Newsletter. You confirm that we shall not be liable to you or any third party for any change made to this Privacy Policy from time to time. It is your responsibility to check regularly to determine whether this Privacy Policy has changed.

COMPLAINTS

If You wish to make a complaint about the Website, Booking Software, ourServices, or any associated matter, you may contact us by telephone, email, or letter. Wherever possible, complaints will be dealt with promptly, and you will receive a response under 30 working days.

CONTACTING US

If you would like any more information or you have any comments about our Privacy Policy, please either write to us at Data Protection Manager,Above The Bay Limited, Swanpool Road, Falmouth, TR11 5BQ, or email us at operations@abovethebay.co.uk.

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