Leisure United

Website Privacy Notice

May 2023

Leisure United respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or in other circumstances when we collect data from you (including via email) and tell you about your privacy rights and how the law protects you.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below:

1. Important information and who we are 1

2. The data we collect about you 3

3. How is your personal data collected? 5

4. How we use your personal data 6

5. Cookies 10

6. Disclosures of your personal data 11

7. International transfers 12

8. Data security 12

9. Data retention 13

10. Your legal rights 13

1. Important information and who we are

Leisure United is a charitable company limited by guarantee (company number 10076004 and registered charity number 1174371) operating football and fitness hubs across the UK. We are a wholly-owned charitable subsidiary of The National Football Trust (company number 11535526 and registered charity number 1184825) and are contracted by, and work in collaboration with, national delivery partners including:

· The Football Association;

· Sport England;

· Premier League;

· Football Foundation;

· the Department for Culture, Media and Sport; and

· local authorities / councils.

This privacy policy is issued on behalf of Leisure United only, so when we mention, "we", "us" or "our" in this privacy policy, we are referring to Leisure United as the controller and entity responsible for processing your data. We will let you know when we are acting as processor on behalf of another controller, for instance The National Football Trust. Our ICO registration number is ZA298766.

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us at gdpr@leisureunited.com or write to us at Leisure United, SGP Graves, Bochum Parkway, Sheffield S8 8JR.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

To register anyone under 16 years of age for our services, a parent or guardian will be required to complete the registration and the parent or guardian will be our primary contact in respect of that registration.

It is important that you read this privacy notice together with any other privacy notice or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements other notices and privacy policies and is not intended to override them.

Changes to the privacy notice and your duty to inform us of changes

We keep our privacy notice under regular review. This version was last updated on the date stated at the beginning of this privacy notice. Any changes we may make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by email.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). You give us your personal data when you:

· use our hubs;

· use our website;[LF1] [RH2]

· interact with our social media channels;

· create an account with us;

· contact us or communicate with us in any way;

· register to receive or download information, newsletters or other documentation;

· enter competitions; or

· make a donation.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data

title, first name and last name, date of birth, gender and photo identification.

Contact Data

email address, telephone number, postal address and next of kin contact information.

Profile Data

preferences, use of our hubs and feedback and survey responses. If you receive marketing from us, we may track any subsequent actions online.

Financial Data

bank account details.

Transaction Data

details about payments to and from you and other details of services you have purchased from us.

Marketing and Communications Data

preferences in receiving communication and marketing from us. We keep a record of the emails we send you. We may also track whether you or any social media accounts linked to your account receive or open them, so we can make sure we are sending you the most relevant information.[LF3] [RH4]

Health Data

medical history, current medical conditions or any medical conditions that arise throughout our engagement with you.

Criminal Conviction Data

data relating to criminal convictions and offences or related security measures and information that would be collected and reported by a DBS check.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature or to calculate the percentage of users previously involved in organised football. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice. We collect, use and share the following data as Aggregated Data only:

Technical Data

includes internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices used to access this website or our social media channels.[LF5] [RH6]

Usage Data

includes information about the use of our website, our social media channels and services, the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time), 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 contact number[LF7] [RH8] .

Special Category Personal Data

Special category personal data includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data.

We collect information about your health so we can provide a better service and make any necessary adjustments to our services. We may also collect data relating to racial or ethnic origin solely for the purposes of equal opportunities monitoring. We will not process special category personal data without first obtaining your prior consent[BE9] .

We collect information about criminal convictions and offences as far as is necessary under our Safeguarding Policy [BE10] [RH11] as amended from time to time and for the promotion of welfare of young people and vulnerable adults.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, for you to use our hubs). In this case, we may have to cancel your registration to use our hubs, but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you, including through:

Direct interactions with you

By filling in forms or by corresponding with us by post, phone, email or otherwise, you may give us your Identity, Contact, Profile and Marketing and Communications Data. This includes personal data you provide when you use our hubs (social media platforms including Facebook and Instagram), use our website, create an account with us[LF12] , contact us or communicate with us in any way, register to receive or download information, newsletters or other documentation, enter competitions or make a donation.

Automated technologies or interactions

As you interact with our website[LF13] and hubs, we will automatically collect Technical and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using the cookies described in the ‘Cookies’ section below, server logs and other similar technologies.

Third parties

When a member creates an account to use a football hub the FA will provide us with the individual’s FAN number for the monitoring of disciplinary matters, participation and safeguarding. If the details you provide do not match an existing FAN number then the FA will register a new FAN number and provide us with the newly registered number. It is necessary to have a FAN number to be able to use a football hub.

We may also receive information from you from our third-party marketing partners where you have provided your express consent for this information to be passed on to us.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

· where we need to perform a contract that we have entered into with you. This means processing your personal data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

· where it is necessary for our legitimate interests. This means our interests in conducting and managing our company to enable us to give you the best service. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

· where we need to comply with a legal obligation. This means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

· where we need to rely on consent. This means we will only process your personal data if we have received valid consent from you. We will get your consent before sending third-party direct marketing communications to you via email, telephone call or text message. You have the right to withdraw consent to marketing at any time by changing your account preferences online or contacting us through the contact hub.

Purposes[RH14] for which we will use your personal data

We have set out a description of all the ways we plan to use your personal data and which of the legal bases we rely on to do so in the table below. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

Please contact us if you need details about the specific legal ground(s) we are relying on to process your personal data where more than one ground has been set out in the table below:

Purpose or activity

Type of data

Lawful basis for processing, including basis of legitimate interest

To enable you to create an account with us and use our hub facilities

(a) Identity Data

(b) Contact Data

(d) Financial Data

(e) Transaction Data

(f) Marketing and Communications Data

(g) Health Data

(h) Criminal Conviction Data

(a) Performance of a contract with you.

(b) Necessary for our legitimate interests (to ensure we have an understanding of any health problems to accommodate for).

(d) Consent.

To respond to your enquiries

(a) Identity Data

(b) Contact Data

(a) Necessary for our legitimate interests (to communicate and maintain a relationship with you).

To keep you updated by email of important information regarding our services

(a) Identity Data

(b) Contact Data

(d) Marketing and Communications Data

(a) Performance of a contract with you

(b) Necessary for compliance with a legal obligation

To monitor participation levels with our services

(a) Identity Data

(b) Contact Data

(d) Technical Data

(e) Usage Data

(a) Necessary for our legitimate interests (to study how customers use our services)

(b) Necessary for compliance with a legal obligation

To receive and acknowledge donations

(a) Identity Data

(b) Contact Data

(d) Financial Data

(e) Transaction Data

Performance of a contract with you

For research purposes and to gather monitoring and evaluation information, including sharing this information with our partners

(a) Identity Data

(b) Contact Data

(d) Technical Data

(e) Usage Data

(f) Financial Data

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our services, to develop them and grow our organisation)

To enable you to take part in a competition or complete a survey

(a) Identity Data

(b) Contact Data

(d) Marketing and Communications Data

(e) Usage Data

(a) Performance of a contract with you

(b) Consent

To maintain safety and security at our facilities through the use of CCTV

(a) Identity Data

Necessary for our legitimate interests (to ensure Leisure United’s premises, both internally and externally, are kept secure).

To promote our business interests and commercial profile

(a) Identity Data

(b) Marketing and Communications Data

Consent

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system. Maintenance, support, reporting and hosting of data).

(a) Identity Data

(b) Contact Data

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise).

(b) Necessary to comply with a legal obligation.

Marketing and promotional information

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us and third parties sending marketing communications on our behalf if you have indicated that you are happy to receive them. You may receive marketing communications from us if you have communicated with us in any way and you have not opted out of receiving such marketing communications[LF15] [RH16] .

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third-party for marketing purposes.

Opting out

You can ask us to stop sending you marketing messages at any time by logging into your online account at https://app.leisureunited.org/Dashboard/Organisation/.

Where you opt-out of receiving these marketing messages, this will not apply to personal data provided to us when you use our hubs, use our website, create and account with us, contact us or communicate with us in any way, download information, newsletters or other documentation, enter competitions or make a donation.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Cookies

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.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

We use the following cookies:

· Strictly necessary cookies. These are cookies that are required for the operation of our website.

· Functionality cookies. These are used to recognise you when you return to our website and remember your preferences (for example, your choice of language or region).

· Analytical or performance cookies. These allow you to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

· Targeting cookies. These cookies record a user’s visit to our website, the pages they have visited and the links they have followed[LF17] [RH18]

A full list of the cookies that we use from time to time can be found at in our Cookies Policy:

https://leisureunited.com/cookie-policy/

Please note that the following third parties may also use cookies, over which we have no control. These named third parties may include, for example, advertising networks and providers of external services like web traffic analysis services. These third-party cookies are likely to be analytical cookies or performance cookies or targeting cookies:

· Instagram (Meta);

· Facebook Marketing[LF19] [RH20] (Meta); and

· Google Analytics.

To deactivate the use of third-party advertising cookies, you will need to amend your preferences for tracking on the host sites for these third-party advertising cookies manually or, you can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

6. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes for which we will use your personal data table above.

· Our delivery partners based in the UK, including The Football Association, Sport England, Premier League, Football Foundation, the Department for Culture, Media and Sport and local authorities / councils.

· Other third parties such as First Sports International (who host the Leisure United website and management software system), Hurrah Marketing (who undertake our marketing activity on our behalf), Google Analytics, Facebook, Instagram and MKT.

· Third parties to whom 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 or to protect the rights, property, or safety of you or others.

· Professional advisers such as lawyers, bankers, auditors and insurers based in the UK who provide consultancy, legal, banking, accounting and insurance services.

· HM Revenue & Customs, regulators and other authorities based in the UK who require reporting of processing activities in certain circumstances.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

7. International transfers

We do not transfer your personal data outside the UK.

8. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9. Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

We will retain full membership information of users of the football hubs for a period of 7 years following the last use of the account and full membership information of users of the gym facilities at the hubs for the duration of the gym membership. CCTV data will be retained for a period of 30 days from capture and then deleted, regardless of membership status at our centres. However, some personal information may be retained for longer periods based on the assessment criteria detailed in the paragraph above.

In some circumstances you can ask us to delete your data: see the section below called “Your legal rights” for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

10. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of the rights set out below, please contact us at gdpr@leisureunited.com or write to us at Leisure United, SGP Graves, Bochum Parkway, Sheffield S8 8JR. You have the right to:

· Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

· Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate personal data we hold about you corrected, though we may need to verify the accuracy of the new personal data you provide to us. You may also edit your personal data through the online member hub.

· Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your personal data unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

· Object to processing of your personal data where we are relying on a legitimate interest (or those of a third-party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your personal data which override your rights and freedoms.

· Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

o if you want us to establish the personal data's accuracy;

o where our use of the personal data is unlawful, but you do not want us to erase it;

o where you need us to hold the personal data even if we no longer require it as you need it to establish, exercise or defend legal claims; or

o you have objected to our use of your personal data, but we need to verify whether we have overriding legitimate grounds to use it.

· Request the transfer of your personal data to you or to a third-party. We will provide to you, or a third-party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated personal data which you initially provided consent for us to use or where we used the personal data to perform a contract with you.

· Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain events, products or services to you. We will advise you if this is the case at the time you withdraw your consent.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

[LF1]Interact upon social media channels?

[RH2]Following call on 20/01, Amanda will confirm with Linda what tracking occurs and where this information is held.

[LF3]How you interact to marketing and or social media channels

[RH4]As above.

[LF5]Social media channels and access

[RH6]Following call on 20/01, Amanda will confirm with Linda and First Sport System whether the data collected through social media is considered personal data or aggregated data.

[LF7]Do we not need to include a section here about online advertising - using data on google search, facebook interests etc etc

[RH8]As above.

[BE9]The new health declaration you are implementing should come into effect at the same time as this policy. The final paragraph in the declaration should be amended to state that by signing they are giving consent to processing the special category health data included in the declaration.

[BE10]Once both policies are in place insert a link here.

[RH11]Link has been added.

[LF12]Social media

[LF13]And social channels

[RH14]We’re cautious that this privacy notice has been amended several times since 2021. With that in mind, have all the processing purposes been captured in the table below or does this need updating?

[LF15]Do you need to say sometimes marketing and promotional information may be sent on behalf of LU from third party organisations acting on your behalf?

[RH16]This has been covered in line five of this clause.

[LF17]We also re-target people who have visited the website with google and FB advertsing

[RH18]This information is covered in the cookie policy so it doesn't need to be repeated. A link to the cookie policy has been included in this clause.

[LF19]I think these are officially logged and called Meta now (perhaps put FB and insta in brackets)

[RH20]We have bracketed Meta given the names 'Instagram' and 'Facebook' are more familiar terms than 'Meta'.

Privacy Policy