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THE QUEEN’S CLUB PRIVACY POLICY

QCL is registered in England under company number 23072 at The Queen’s Club, Palliser Road, London, W14 9EQ

1. PRIVACY POLICY INTRODUCTION

The Queen’s Club Limited takes the privacy of your personal data very seriously and complies with its obligations under the General Data Protection Regulation (GDPR). This Privacy Policy explains how we deal with any personal data held and outlines the rights you have regarding the data held.

Use of this website by you constitutes your confirmation that you are happy for your personal data to be used in the ways described in this privacy policy (“Privacy Policy”).  If you do not wish to accept this Privacy Policy, please leave this website immediately.

The Privacy Policy covers all visitors to the website and Members (“you”, “your”) of The Queen’s Club (“we”, “us”, “our”).

The Queen’s Club reserves the right to make any amendments to this Privacy Policy, as privacy laws and practices are constantly changing. Please check back here from time to time. We will publish a new Privacy Policy when we make any substantial updates.

2. HOW THIS WEBSITE COLLECTS DATA PERSONAL DATA

This website collects personal information in a number of ways, including:
1 Site visitation tracking:
- Internet protocol (IP) address used to connect your computer to the Internet
- your login information
- time zone setting
- platform you are using

2. Information you give us via:
- Members’ online secure portal
- Contact forms
- email links

3. Cookies information – through the use of both:
- session cookies
- persistent cookies

Site visitation tracking and collection of cookies is statistical data about your browsing actions and patterns and does not identify any individual. 

3. COOKIE POLICY

To find out more about the our Cookie Policy, please click here.

4. HOW WE USE YOUR DATA

The purposes for which we may use your personal data include:
1. the administration of this website:
- troubleshooting issues
- data analysis
- testing
- statistical

2. survey purposes

3. to allow you to participate in interactive features of our service, when you choose to do so (for example, court bookings, the Member search facility, competition sign-ups)

4. to notify you about changes to our service

5. as part of our efforts to keep the website safe and secure. See section 5. How personal data is held and data security below.

5. PROCESSING OF PERSONAL DATA

We may also process your personal data for one or more of the purposes set out below:
- It is necessary for the Club’s or a third party's legitimate interests. The Club’s "legitimate interests" include reasonable interest to carry out the Club’s business (except where such interest are overridden by the interest rights or freedoms of you the data subject)
- It is necessary for the establishment, exercise or defence of legal claims (for example, to protect and defend our rights or property);
- It is necessary for compliance with our legal obligations (for example, safeguarding and child protection; or for the prevention and detection of crime; and in order to assist with investigations - including criminal investigations - carried out by the police and other competent authorities).

We publish our Members’ names, email address, mobile number and other telephone numbers on our secure online portal. If you do not wish for your contact details to be listed, this can be through updating your preferences online.

In compliance with GDPR, where the Club relies on consent as the lawful basis for processing a child’s personal data, we will ensure that those aged 13 or over provide their own consent, and for those under the age of 13, we will collect consent from whoever holds parental responsibility for the child.<.p>

In these instances, the Club will ensure that the wording when collecting the consent for the personal data of the child is clear for both the child of 13 years or above and the parent(s) of the child under the age of 13.

Please note that as of 17/05/2018, this is the age proposed in the UK Data Protection Bill and is subject to Parliamentary approval.

6. SHARING AND TRANSFERRING PERSONAL INFORMATION

Your personal data will be treated as strictly confidential. We will only share your personal information with staff and third parties where required by law, where it is necessary to manage the Club’s Membership, or where we have another legitimate interest in doing so.

Some of the organisations to which we may disclose personal information may be situated outside of the UK and EU. In order to provide the benefits from any arrangements with sporting governing bodies, reciprocal clubs or clubs and venues which we have a special relationship with, we may need to transfer your personal information to these countries some of which do not have laws that protect privacy rights as extensively as in the UK. If we do transfer your personal information to other territories, we will take proper steps to ensure that the information is protected in accordance with this Privacy Policy.

In all other circumstances, we will only share or transfer your data with your consent.

7. DATA SECURITY AND HOW PERSONAL DATA IS HELD

Data stored on our website will be stored in a secure manner and we shall use reasonable endeavours to ensure that any such data cannot be accessed by unauthorised third parties. Access to personal information stored on the Club’s servers also restricted.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of the website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

8. LENGTH OF TIME INFORMATION IS HELD

We keep your personal data for no longer than is reasonably necessary. If you are no longer associated with the Club, your information will be kept for a reasonable period for the purposes of statutory record-keeping and dealing with any legal claims/disputes.

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, the applicable legal requirements and other factors that we consider relevant.

9. THIRD PARTY WEBSITES

The website contains links to other websites. We are not responsible for the Privacy Policies or practices of third party websites.

The same applies when you visit a page with content embedded from a third party website such as YouTube, for example.

10. YOUR RIGHTS AND PERSONAL DATA

With respect to your personal data, and subject to various conditions and exemptions, you have the right to:
- request access to your personal data (commonly known as a "subject access request")
- request that the Club corrects any personal data if it is found to be inaccurate or out of date
- ask us to delete or remove your personal data where you have exercised your right to object to processing (see below)
- object to the 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.
- request the restriction of processing of your personal data. You can also withdraw your consent, where this is the basis for our processing your information (without affecting the lawfulness of our previous processing carried out based on your consent)
- request the transfer of your personal data to another data controller
- lodge a complaint with the Information Commissioner

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 for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances

We may need to request specific information from you to help us confirm your identity and ensure your right to access the personal data (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

11. CONTACT AND COMPLAINT DETAILS

If you have any queries about this data Privacy Policy or how we process your personal data, or if you wish to exercise any of your rights, please use the following contact methods and details:
- by email: gdpr@queensclub.co.uk
- by telephone: 020 7386 3430 (Communications & Membership Manager)
- or by post to: GDPR, Membership Office, The Queen’s Club, Palliser Road, London, W14 9EQ

If you are not satisfied with how we are processing your personal data you can make a complaint to the Information Commissioner whose contact details are:
- by email: ico.org.uk
- by telephone: 030 3123 1113
- by post to: Information Commissioners Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

11. YOUR DUTY TO INFORM US OF CHANGES

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