Website Privacy notice
We are Bowls England operating under the brand name ‘PlayBowls’. We’re a company registered in England and Wales with company number 6297656, whose registered address is at Riverside House, Milverton Hill, Royal Leamington Spa, Warwickshire, CV32 5HZ. Accordingly we are subject to the laws of England and Wales, to include those which are referenced within this document. In this privacy notice we will refer to ourselves as ‘we’, ‘us’ or ‘our’.
We take the privacy, including the security, of personal information we hold about you seriously. This privacy notice is designed to inform you about how we collect personal information about you and how we use that personal information. You should read this privacy notice carefully so that you know and can understand why and how we use the personal information we collect and hold about you.
We have not appointed a Data Protection Officer to oversee our compliance with data protection laws, as we are not required to do so, but our Chief Executive, who also acts as Company Secretary, has overall responsibility for data protection compliance in our organisation.
Bowls England are offering PlayBowls as a platform for bowls clubs to list free rink space, and to enable users to book this space. The central system will adhere to the rules below with regard to your data, and we will endeavour to ensure that all clubs and users follow these guidelines.
1. Key Definitions
The key terms that we use throughout this privacy notice are defined below, for ease, and in compliance with the terms and requirements of The Data Protection Act 2018:
Data Controller: this is the organisation or person responsible for deciding how personal information is collected and stored and how it is used.
Data Processor: a Data Controller may appoint another organisation or person to carry out certain tasks in relation to the personal information on behalf of, and on the written instructions of, the Data Controller. (This might be the hosting of a site containing personal data, for example, or providing an email marketing service that facilitates mass distribution of marketing material to a Data Controller’s customer-base.)
Personal Information: in this privacy notice we refer to your personal data as ‘personal information’. ‘Personal information’ means any information from which a living individual can be identified. It does not apply to information which has been anonymised.
Special Information – specific personal information of an especially sensitive nature requires extra protection under data protection law. Sensitive data includes information relating to health, racial and ethnic origin, political opinions, religious and similar beliefs, trade union membership, sex life and sexual orientation and also includes genetic information and biometric information.
2. Details of personal information which we collect and hold about you
2.1 Set out below are the general categories and details of retention periods in relation to those categories (see section 8 below for more details about retention) and in each case the types of personal information which we collect, use and hold about you:
General Category Types of Personal Data in that category Retention Periods
Identity Information This is information relating to your identity such as your name (including any previous names and any titles which you use), gender, marital status and date of birth This will be kept for a maximum of six years, in line with Bowls England policy.
Contact Information This is information relating to your contact details such as e-mail address, addresses, telephone numbers This will be kept for a maximum of six years, in line with Bowls England policy.
Account Information This is information relating to your account with PlayBowls (including username and password This will be kept for a maximum of six years, in line with Bowls England policy.
Payment Information This is information relating to the methods by which you provide payment to us such as bank account details, credit or debit card details and details of any payments (including amounts and dates) which are made between us. This will be kept for a maximum of six years, in line with Bowls England policy.
Transaction Information This is information relating to transactions between us such as details of the goods, services and/or digital content provided to you and any returns details. This will be kept for a maximum of six years, in line with Bowls England policy.
Survey Information This is information which we have collected from you or which you have provided to us in respect of surveys and feedback. This will be kept for a maximum of six years, in line with Bowls England policy.
Marketing Information This is information relating to your marketing and communications preferences. This will be kept for a maximum of six years, in line with Bowls England policy.
Website, Device and Technical Information This is information about your use of our website and technical data which we collect (including your IP address, the type of browser you are using and the version, the operating system you are using, details about the time zone and location settings on the device and other information we receive about your device) This will be kept for a maximum of six years, in line with Bowls England policy.
2.2 The types of personal data we collect about you may differ from person to person, depending on who you are and the relationship between us.
3. Details of how and why we use personal information
3.1 We are only able to use your personal information for certain legal reasons set out in data protection law. There are legal reasons under data protection law other than those listed below, but in most cases, we will use your personal information for the following legal reasons:
(a) Contract Reason: this is in order to perform our obligations to you under a contract we have entered into with you;
(b) Legitimate Interests Reason: this is where the use of your personal information is necessary for our (or a third party’s) legitimate interests, as long as any such legitimate interests do not override your fundamental rights, freedoms or interests;
(c) Legal Obligation Reason: this is where we have to use your personal information in order to perform a legal obligation by which we are bound; and
(d) Consent Reason: this is where you have given us your consent to use your personal information for a specific reason or specific reasons.
3.2 As explained in section 1 above, there are more sensitive types of personal data which require higher levels of protection. Where we process such sensitive types of personal data we will do this in any one of the following circumstances:
(a) We have your explicit consent;
(b) Where it is necessary in relation to legal claims; or
(c) Where you have made the personal data public.
3.3 So that we are able to provide you with access to rink sessions at one of our clubs we will need your personal information. If you do not provide us with the required personal information, we may be prevented from supplying this service to you.
3.4 It is important that you keep your personal information up to date. If any of your personal information changes, please contact us as soon as possible to let us know. If you do not do this then we may be prevented from supplying the service to you. For example, if you change your email address and do not inform us, you may not receive essential booking information.
3.5 Where we rely on consent for a specific purpose as the legal reason for processing your personal information, you have the right under data protection law to withdraw your consent at any time. If you do wish to withdraw your consent, please contact us using the details set out at the beginning of this notice. If we receive a request from you withdrawing your consent to a specific purpose, we will stop processing your personal information for that purpose, unless we have another legal reason for processing your personal information, in which case, we will confirm that reason to you.
3.6 We have explained below the different purposes for which we use your personal information and, in each case, the legal reason(s) allowing us to use your personal information. Please also note the following:
(a) if we use the Legitimate Interests Reason as the legal reason for which we can use your personal information, we have also explained the basis of that legitimate interest; and
(b) for some of the purposes we may have listed more than one legal reason for which we can use your personal information, because the legal reason may vary depending on circumstances. If you need confirmation of the specific legal reason upon which we are relying to use your personal data for that purpose, please contact us on email@example.com.
Purpose Legal Reason(s) for using the personal information
To create your account on PlayBowls. This is necessary to enable us and the club(s) to properly manage and administer support to you.
To process your order on PlayBowls, which includes taking payment from you, advising you of any updates in relation to your order, or any enforcement action against you to recover payment. This is necessary for use of the site to purchase your rink space at the club(s).
To manage our contract with you and to notify you of any changes This is necessary to enable us to properly administer and perform any contract for the provision of merchandise, products or services
To comply with audit and accounting matters This is necessary to ensure that we are able to fulfil all associated legal obligations, to include those issued by official national bodies.
For record keeping, including in relation to any guarantees or warranties provided as part of the sale of goods, services and/or digital content We have a legitimate interest in retaining records whilst they may be required in relation to complaints or claims. We need to retain records in order to properly administer and manage your membership and in some cases, we may have legal or regulatory obligations to retain records.
We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above.
To improve the goods, services, and/or digital content which we supply In order to improve the goods, services, and/or digital content for future customers and to grow our business
To send you other marketing information we think you might find useful or which you have requested from us, including our newsletters, information about Membership, events, participation products and information about our commercial partners Where you have given us your explicit consent to do so, or we reasonably consider the sending of such information to be in your legitimate interests
To ensure the smooth running and correct operation of our website To ensure our website runs correctly
To understand how customers and visitors to our website use the website and interact with it via data analysis To improve and grow our business, including our website, and to understand our customer’s needs, desires and requirements
3.7 Sometimes we may anonymise personal information so that you can no longer be identified from it and use this for our own purposes. In addition, sometimes we may use some of your personal information together with the personal information of other individuals to give us statistical information for our own purposes. Because this is grouped together with other personal information, and you are not identifiable from that combined data, we are able to use this.
3.8 Under data protection laws we can only use your personal information for the purpose(s) we have told you about, unless we consider that the new purpose is compatible with the purpose(s) which we told you about. If we want to use your personal information for a different purpose which we do not think is compatible with the purpose(s) which we told you about then we will contact you to explain this and what legal reason is in place to allow us to do this.
4. Details of how we collect personal information and special information
4.1 We usually collect Identity Information, Contact Information, Payment Information, Transaction Information, Survey Information and Marketing Information directly from you when you create your account or purchase services. This includes the personal information which you provide to us when you subscribe to our mailing list or enter a competition or survey.
6.1 Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. This information is used to track visitor use of the website and to compile statistical reports on website activity.
6.2 For further information visit aboutcookies.org or www.allaboutcookies.org. You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.
6. Details about who Personal Information may be shared with
6.1 We may need to share your personal information with other organisations or people. These organisations include, but are not restricted to:
(a) Bowls Clubs, who will need access to your data in order to administer the service to you; and
(b) our email service platform, in order to send you account creation confirmation, booking confirmations, cancellation notices, and other messages covered under legitimate interests.
6.2 Depending on the circumstances, the organisations or people who we share your personal information with will be acting as either Data Processors or Data Controllers. Where we share your personal information with a Data Processor we will ensure that we have in place contracts, which set out the responsibilities and obligations of us and them, including in respect of security of personal information.
6.3 We do not sell or trade any of the personal information which you have provided to us.
7. Details about transfers to countries outside of the EEA
7.1 We do not transfer your personal information outside of the EEA. In the event that we intend to change this for any reason, we will first seek your direct consent.
8. Details about how long we will hold your personal information
8.1 We will only hold your personal data for as long as is necessary. How long is necessary will depend upon the purposes for which we collected the personal information (see section 4 above) and whether we are under any legal obligation to keep the personal information (such as in relation to accounting or auditing records or for tax reasons). We may also need to keep personal information in case of any legal claims, including in relation to any guarantees or warranties which we have provided.
8.2 We have set out above the details of our retention periods for different types of data. You can find them in in section 2 and also in section 3.
9. Automated decision making
9.1 ‘Automated decision making’ is where a decision is automatically made without any human involvement. Under data protection laws, this includes profiling. ‘Profiling’ is the automated processing of personal data to evaluate or analyse certain personal aspects of a person (such as their behaviour, characteristics, interests and preferences).
9.2 Data protection laws place restrictions upon us if we carry out automated decision making (including profiling) which produces a legal effect or similarly significant effect on you.
9.3 We do carry out automated decision making (including profiling) which produces a legal effect or similarly significant effect on you. If we do decide to do this then we will notify you and we will inform you of the legal reason we are able to do this.
10. YOUR RIGHTS UNDER DATA PROTECTION LAW
10.1 Under data protection laws you have certain rights in relation to your personal information, as follows:
(a) Right to request access: (this is often called ‘subject access’). This is the right to obtain from us a copy of the personal information which we hold about you. We must also provide you with certain other information in response to these requests to help you understand how your personal information is being used.
(b) Right to correction: this is the right to request that any incorrect personal data is corrected and that any incomplete personal data is completed.
(c) Right to erasure: (this is often called the “right to be forgotten”). This right only applies in certain circumstances. Where it does apply, you have the right to request us to erase all of your personal information.
(d) Right to restrict processing: this right only applies in certain circumstances. Where it does apply, you have the right to request us to restrict the processing of your personal information.
(e) Right to data portability: this right allows you to request us to transfer your personal information to someone else.
(f) Right to object: you have the right to object to us processing your personal information for direct marketing purposes. You also have the right to object to us processing personal information where our legal reason for doing so is the Legitimate Interests Reason (see section 4 above) and there is something about your particular situation which means that you want to object to us processing your personal information. In certain circumstances you have the right to object to processing where such processing consists of profiling (including profiling for direct marketing).
10.2 In addition to the rights set out in section 4, where we rely on consent as the legal reason for using your personal information, you have the right to withdraw your consent. Further details about this are set out in section 4.5.
10.3 If you want to exercise any of the above rights in relation to your personal information, please contact us using the details set out at the beginning of this notice. If you do make a request then please note:
(a) we may need certain information from you so that we can verify your identity;
(b) we do not charge a fee for exercising your rights unless your request is unfounded or excessive; and
(c) if your request is unfounded or excessive then we may refuse to deal with your request.
11.1 You may receive marketing from us about similar goods and services, where either you have consented to this, or we have another legal reason by which we can contact you for marketing purposes.
11.2 However, we will give you the opportunity to manage whether we market to you and, if so, the extent to which we do so. In any e-mail which we send to you, we provide a link to either unsubscribe or opt-out, or to change your marketing preferences. If you have an account with us, you can login to your account and manage your preferences there too. You can also opt-out of any marketing communications. You can also delete your PlayBowls Account, in which case Bowls England will not contact you again in direct connection with PlayBowls. To change your marketing preferences, and/or to request that we stop processing your personal information for marketing purposes, you can always contact us on the details set out at the beginning of this notice.
11.3 If you do request that we stop submitting marketing materials to you, this will not prevent us from sending communications to you which are not to do with marketing (for example in relation to rink bookings which you have purchased from us).
11.4 We do not pass your personal information on to any third parties for marketing purposes.
If you are unhappy about the way that we have handled or used your personal information, you have the right to complain to the UK supervisory authority for data protection, which is the Information Commissioner’s Office (ICO). Please do contact us in the first instance if you wish to raise any queries or make a complaint in respect of our handling or use of your personal information, so that we have the opportunity to discuss this with you and to take steps to resolve the position. You can contact us using the details set out at the beginning of this privacy notice.
13. Third Party Websites
Our website may contain links to third party websites. If you click and follow those links then each one will take you to the relevant third party website. Those third party websites may collect personal information from you and you will need to check their privacy notices to understand how your personal information is collected and used by them.