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Privacy Policy

BACKGROUND:
Exercise Anywhere Ltd t/a Nordic Walking UK [“Exercise Anywhere”] understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, www.nordicwalking.co.uk “Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is deemed to occur upon your first use of Our Site. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:

“Account”
means an account required to access and/or use certain areas and features of Our Site;

“Cookie”
means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below; and

“Cookie Law”
means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;

2. Information About Us
Our Site is owned and operated by Exercise Anywhere, a limited company registered in England under company number 05273896.
Registered address: 23-25 Waterloo Place, Leamington Spa CV32 5LA
VAT number: 851 9434 11
Data Protection Officer: Gillian Stewart.
Email address: privacy@nordicwalking.co.uk
Telephone number: 0333 12345 40.
Postal Address: French Grass Works, Kingston Rd, Worth Matravers, Dorset, BH19 3JP

3. What Does This Policy Cover?
This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

4. What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

5. What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:

1. The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.
2. The right to access the personal data we hold about you. Part 13 will tell you how to do this.
3. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
4. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 15 to find out more.
5. The right to restrict (i.e. prevent) the processing of your personal data.
6. The right to object to us using your personal data for a particular purpose or purposes.
7. The right to data portability. This means that, if you have provided personal data to us directly, we am using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
8. Rights relating to automated decision-making and profiling.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

6. What Data Do We Collect?
Depending upon your use of Our Site, we may collect some or all of the following personal and non-personal data (please also see Part 14 on our use of Cookies and similar technologies and our Cookie Policy:

• Name;
• Date of birth;
• Gender;
• Address;
• Email address;
• Telephone number;
• Business name;
• Job title;
• Profession;
• Payment information; (Note: this information is NOT normally taken and our company normally uses third party financial institutions as listed in Part 10).
• Information about your preferences and interests;
• IP address;
• Web browser type and version;
• Details Next of Kin whilst using our booking system, events, activities and/or holidays;
• Details of Medical Contraindications whilst using our booking system, events, activities and/or holidays;
• Operating system;
• A list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;

7. How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for the following purposes:

• Providing and managing your Account;
• Providing and managing your access to Our Site;
• Personalising and tailoring your experience on Our Site;
• Supplying our products and services to you. Your personal details are required in order for us to enter into a contract with you.
• Personalising and tailoring our products and services for you.
• Communicating with you. This may include responding to emails or calls from you.
• Supplying you with information by email or post that you have opted-in to (you may unsubscribe or opt-out at any time by emailing us, ticking the opt-out button or writing to us).
• Analysing your use of Our Site and gathering feedback to enable us to continually improve Our Site and your user experience.

With your permission or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone, text message or post with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

Third Parties (including our instructor network and strategic partners) whose content appears on Our Site may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.

We use automated systems for carrying out certain kinds of decision-making. If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the GDPR gives you the right to do so. Please contact us to find out more using the details in Part 15.

8. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

• We will retain your personal data for a period of approximately 7 years. This time frame is based on the average number of years between first and most recent transaction dates and assumes contact between the customer and data controller is relevant to you, the customer.

9. How and Where Do You Store or Transfer My Personal Data?
We will only store or transfer your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the GDPR or to equivalent standards by law.

10. Do You Share My Personal Data?
We may share your personal data with other companies in our group for processing bookings and orders. This includes Nordic Walking UK Ltd and Sante Solutions Ltd OR our holding company and its subsidiaries.

We may sometimes contract with the following third parties to supply certain products and services such as our instructors or representatives local to you. These may also include payment processing, delivery, and marketing. In some cases, those third parties may require access to some or all of your personal data that we hold.

• Financial institutions including but not exhaustive such as Streamline, WorldPay, PayPal, Stripe, Harlands Direct Debit Services and others that may provide money collection services from time to time.
• Companies that act on our behalf to provide appropriate services to improve the delivery of our products and services such as courier companies or marketing profile companies.
• Instructor network and contracted representatives providing our contracted services and products

If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.

If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 9.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

11. How Can I Control My Personal Data?

11.1 In addition to your rights under the GDPR, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and at the point of providing your details and by managing your Account).

11.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

12. Can I Withhold Information?
You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.

You may restrict our use of Cookies. For more information, see Part 14

13. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

14. How Do You Use Cookies?
This site uses cookies to distinguish you from other users. Some of these cookies are essential to make this site work properly, to allow you to make your bookings or other purchases, and to enable Us to fulfil your purchase requests. Other types of cookies help us to provide you with a good experience when you browse our site, allow us to improve our site or the way we provide our service to customers, or are used to provide you with information or offers from Us and/or third parties that may be of interest to you.

You can view more information on cookies and a list of cookies that are used on this website by visiting our cookie page.

You can accept or decline cookies at any time by accessing the preference panels from your browser’s main menu (usually found under ‘Edit’, ‘Tools’ or ‘Options’). However, if you choose to remove cookies parts of the site may not work properly or your use of the site may be impaired.

In order to help us maintain and improve our service to you we also use 'cookies' to collect information about your use of the website. Cookies are a feature of web browser software that allows web servers to temporarily store information within your browser, which, in turn, allows us to recognise the computer used to access our site. Most browsers automatically accept cookies but you can delete existing cookies from your browser. You can also edit your browser options to choose not to receive cookies in future. We may use cookies to keep track of the transaction from one page to the next.

We use third-party application service providers to perform some tracking functions. These companies may use cookie-based information (not including your name, address email address or telephone number) about your visits to this and other websites in order to measure advertising effectiveness. We may also collect information about your visit to our website, based on your browsing (click stream) activities. This information may include the pages you browse and products and services viewed or booked for example. This helps us to better manage and develop our offers and to provide you with better products and services tailored to your individual interests and needs. We may use this information to measure the entry and exit points of visitors to the site and respective numbers of visitors to various pages and sections of the site and details of searches performed. We may also use this information to measure the usage of advertising banners, other click-throughs from the site. We may disclose information of this nature in aggregate form to third parties but personal information on individual visitors will not be passed on to any third party.

Please note:
If you choose to use this site without declining any non-essential cookies, then your use will constitute implied consent to the non-essential cookies that are set.

15. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details.

For the attention of Gill Stewart:
Email address: privacy@nordicwalking.co.uk.
Telephone number: 0333 12345 40.
Postal Address: French Grass Works, Kingston Rd, Worth Matravers, Dorset BH19 3JP.

16. Changes to this Privacy Policy
we may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. we recommend that you check this page regularly to keep up-to-date.

Updated: 24th May 2018