PRIVACY POLICY

PRIVACY POLICY

The Cheltenham Trust – Privacy Notice

Who we are and what we do

The Cheltenham Trust is a registered charity focused on developing Cheltenham’s culture and sport offer through community engagement, sustainable investment and social enterprise. The Trust engages audiences through the arts, heritage, performance, tourism, sport, play and wellbeing opportunities.

The Trust needs certain information to conduct business with you, provide services and enable access to goods and services. The Trust also requires personal data to progress applications to work and to fulfil our legal obligations as an employer for example.

The Trust is known as the ‘data owner’ of the personal data you provide to us.  We only collect the information from you that we are required to hold.

Any questions regarding our privacy practices should be sent to:

Data Protection Officer (DPO)

The Cheltenham Trust
The Wilson, Clarence Street, Cheltenham GL50 3JT

Email: dataprotection@cheltenhamtrust.org.uk

Tel: 01242 387497

Why we need your information and how we use it

The Cheltenham Trust keeps any personal information about you held confidentially in accordance with the current Data Protection regulations, whether it is held on computer or in secure manual filing systems. We will store your personal information only if you chose to provide us with it, for example by completion of an electronic form on this website. In these circumstances, any personal information supplied will only be used to provide the requested information or service.

We may ask you to consent to receive information about our goods and services or fundraising.

What type of information is collected from you

If you are using goods and services of the Trust, applying for a role with the Trust, providing services to or for the Trust, we would ask for your; name / contact name, company name, address, date of birth, contact details, National Insurance number (employment only), proof of identity (as applicable), professional registration and/or qualifications (as applicable), and bank account details (only if paying for goods and services or requiring payment for goods and services provided).

BIOMETRICS POLICY

 The reason for this policy is to enable the use of our kiosk and access control software that uses fingerprint scanning to speed up a member’s access into our facilities and increases greater security over their user identity.

The system does not store fingerprint images. The scanner sees the fingerprint and “samples” points of what it sees. Based on the pattern of lines and junctions in the samples, the scanner makes a number and sends the number to the computer; this is an algorithm. So the scanner sees fingerprints and uses them to make Reader Numbers. What the computer receives is a member card number, not a fingerprint. It may be hypothetically possible to make a machine that “reverse engineers” the member card number to re‐create the sample points. A schematic representation of patches of a fingerprint will be created, not a full or a detailed fingerprint.

We will collect consent from parents/guardians of young persons aged 13 years and under before allowing young persons to submit their fingerprint.

Who your information may be shared with (internally and externally)

We may share your information with selected third parties including:

  • Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you. This would always be subject to a strict data protection contract between the Cheltenham Trust and the third party eg our mailshot mail house for brochure distribution.
  • Social media sites for the purposes of data analytics and targeted advertising
  • Analytics and search engine providers that assist us in the improvement and optimization of our websites
  • Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into contract with you.

We may disclose your personal information to third parties:

  • In the event that the Cheltenham Trust or substantially all of its assets are acquired by a third party, in which case personal data held by it about its 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 obligation, or in order to enforce or apply terms to use or terms and conditions of supply and other agreements; or to protect the rights, property, or safety of The Cheltenham Trust, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
  • Please note that sensitive personal data will not be shared with third parties without your consent.

How long we keep your information (retention period)

The retention period depends on the context of the relationship.

If you are applying for a role and are unsuccessful, we will keep your data for 6 months, after which time it will be destroyed. If you become an employee of one of the partner Councils or clients, we will keep your data for a minimum of 6 years after the end of your employment after which time it will be destroyed.

How we protect your Information

  • We will not transfer your personal data to any other organisation.
  • We have implemented generally accepted standards of technology and operational security in order to protect personal data from loss, misuse, or unauthorised alteration or destruction.
  • Please note however that where you are transmitting information to us over the internet this can never be guaranteed to be 100% secure.
  • For any payments which we take from you online we will use a recognised online secure payment system.
  • We will notify you promptly in the event of any breach of your personal data which might expose you to serious risk.

Your rights 

You have rights under the Data Protection Legislations:

  • to access your personal data
  • to be provided with information about how your personal data is processed
  • to have your personal data corrected
  • to have your personal data erased in certain circumstances
  • to object to or restrict how your personal data is processed
  • to have your personal data transferred to yourself or to another business in certain circumstances.

 How you can access, update or correct your information

The Data Protection law gives you the right to apply for a copy of information about yourself. This is called a ‘Subject Access Request’.   The accuracy of your information is important to us to be able to provide relevant services more quickly. We are working to make our record keeping more efficient.

In the meantime, if you change your address or email address, or if any of your circumstances change or any of the other information we hold is inaccurate or out of date please email us or write to us at:

The Cheltenham Trust

Cheltenham Town Hall

1 Imperial Square

Cheltenham

Gloucestershire

GL50 1QA

Email: dataprotection@cheltenhamtrust.org.uk

Leisure: Tel: 01242 387435

Culture: Tel: 01242 387459

The Data Protection Legislation gives you the right to apply for a copy of information about yourself. This is called a Subject Access Request. Find out more on how to make a Subject Access Request

Website Cookie and analytics statement

The Cheltenham Trust keeps any personal information about you held confidentially in accordance with the current Data Protection regulations, whether it is held on computer or in secure manual filing systems. We will store your personal information only if you chose to provide us with it, for example by complete an electronic form on this website. In these circumstances, any personal information supplied will only be used to provide the requested information or service.

Google Ads

Google, as a third party vendor, uses cookies to serve ads. Google’s use of the DART cookie enables it to serve ads to visitors based on their visit to sites they visit on the Internet. Website visitors may opt out of the use of the DART cookie by visiting the Google ad and content network privacy policy

Use of re-targeting functions on the website

Activation of interest-related advertising using “re-targeting”

This website uses so-called “re-targeting Tags”. A “re-targeting tag” is a JavaScript element which is positioned in the website source code. When a user visits a page on this website which contains a “re-targeting tag”, the provider of the online advertising (e.g. Google) places a cookie on the user’s computer and organises the advertising in accordance with retargeting target group lists. This cookie is subsequently used to activate re-targeting campaigns (“Interest-related advertising “) on other websites. Studies have proven that integrating interest-related advertising is of greater interest for the Internet user than an advert which has no direct relation to the person’s interest and previously visited websites.

What is a cookie?

A cookie is a small amount of data that a website places on your computer.

Why do websites use cookies?

Web pages have no memory. If you are surfing from page to page within a website, you will not be recognised as the same user across pages. Cookies enable your browser to be recognised by the website. So cookies are mainly used to remember the choices you have made – choices such as the language you prefer and the currency you use. They will also make sure you are recognised when you return to a website.

Do all cookies do the same thing?

No, there are different types of cookies and different ways of using them. Cookies can be categorised according to their function, their lifespan and according to who places them on a website.

How does The Cheltenham Trust (Leisure at Cheltenham / The Wilson / Cheltenham Town Hall/ Pittville Pump Room/ Prince of Wales Stadium) use cookies?

Our websites use the following types of cookie:

  • Technical cookies: We try to give our visitors an advanced and user-friendly website that adapts automatically to their needs and wishes. To achieve this, we use technical cookies to show you our website, to make it function correctly. These technical cookies are absolutely necessary for our website to function properly.
  • Functional cookies: We also use functional cookies to remember your preferences and to help you to use our website efficiently and effectively, for example by remembering your preferred currency and language, your searches and the accommodation you viewed earlier. These functional cookies are not strictly necessary for the functioning of our website, but they add functionality for you and enhance your experience.
  • Analytics cookies: We use these cookies to gain insight into how our visitors use the website, to find out what works and what doesn’t, to optimise and improve our website and to ensure we continue to be interesting and relevant. The data we gather includes which web pages you have viewed, which referring/exit pages you have entered and left from, which platform type you have used, date and time stamp information and details such as the number of clicks you make on a given page, your mouse movements and scrolling activity, the search words you use and the text you type while using our website. We also make use of analytics cookies as part of our online advertising campaigns to learn how users interact with our website after they have been shown an online advertisement, which may include advertisements on third-party websites. We will not know who you are, and only obtain anonymous data.
  • Commercial cookies: We use these to show you Tregenna advertisements on other websites. This is called “retargeting” and it aims to be based on your browsing activities on our website, such as the destinations you have been searching for, the accommodation you have viewed and the prices you have been shown.

How long do The Cheltenham Trust (Leisure at Cheltenham / The Wilson / Cheltenham Town Hall/ Pittville Pump Room/ Prince of Wales Stadium) cookies stay active?

The cookies we use have varying lifespans. The maximum lifespan we set on some of them is five years from your last visit to our website. You can erase all cookies from your browser any time you want to.

How can you recognise our cookies?

You can find our cookies in your browser settings.

Does The Cheltenham Trust (Leisure at Cheltenham / The Wilson / Cheltenham Town Hall/ Pittville Pump Room) use third-party cookies?

Yes, the Trust uses the services of trusted and recognised online advertising and marketing companies. The Trust may also use third-party providers for analytical purposes. To enable their services, these companies need to place cookies.

The providers we use are committed to building consumer awareness and establishing responsible business and data management practices and standards.

When it comes to online advertising and marketing companies, we strive to only work with companies that are members of the Network Advertising Initiative (NAI) and/or the Interactive Advertising Bureau (IAB). Members of NAI and IAB adhere to industry standards and codes of conduct. NAI and IAB members allow you to opt out of the behavioural advertising. Visit www.networkadvertising.org andwww.youronlinechoices.com to identify the NAI members that may have placed an advertising cookie file on your computer. To opt out of an NAI or IAB member’s behavioural advertising programme, simply check the box that corresponds to the company from which you wish to opt out.

In order to control the collection of data for analytical purposes by Google Analytics, you may want to visit the following link: Google Analytics Opt-out Browser Add-on.

Who has access to The Cheltenham Trust (Leisure at Cheltenham / The Wilson / Cheltenham Town Hall/ Pittville Pump Room/ Prince of Wales Stadium) cookie data?

Only The Cheltenham Trust has access to The Cheltenham Trust cookies. Cookies placed by third parties can be accessed by these third parties.

How can you manage your cookie preferences?

Using your browser settings in, for example, Internet Explorer, Safari, Firefox or Chrome, you can set which cookies to accept and which to reject. Where you find these settings depends on which browser you use. Use the “Help” function in your browser to locate the settings you need.

 

If you choose not to accept certain cookies, you may not be able to use some functions on our website. And opting out of an online advertising network does not mean that you will no longer receive or be subject to online advertising or marketing analysis. It means that the network from which you opted out will no longer deliver ads tailored to your web preferences and browsing patterns.

Does The Cheltenham Trust (Leisure at Cheltenham / The Wilson / Cheltenham Town Hall/ Pittville Pump Room) use web beacons?

As well as using cookies, The Cheltenham Trust sometimes uses web beacons. A web beacon is a tiny graphic image of just one pixel that’s delivered to your computer either as part of a web page request or in an HTML email message. Either directly or through service providers, we use these pixels as part of our online advertisements either on our website or on third-party websites to learn whether a user who is being shown an online advertisement also makes a reservation; to track conversion with partner websites and to analyse the traffic patterns of users to optimise the services we bring to you.

 

Should you wish to know more about the GDPR, please visit the dedicated webpage on the ICO website.

TERMS OF USE

Use by you of this website establishes, and is strictly on the basis of, agreement in full by you, on your own behalf and on behalf of anyone you represent, to the following Terms and Conditions:

1. We reserve the right to amend these Terms & Conditions at any time by amendment to the version posted on the website, whereafter any subsequent use by you of the website will be taken as acceptance by you of the Terms & Conditions in their amended state.

2. You warrant that you are not in breach of any law or order of any court by using this service.

3. You agree that, in visiting and navigating around this website:

  •  you will not act in any way that amounts to a breach of any law and will fully indemnify and hold us harmless against all claims or demands or other consequences of any breach of this provision,
  • you will not upload onto any area of this website any images, graphics, text, hyperlinks, machine readable code or other content that amounts to a breach of the rights, including intellectual property rights, of others and/or which may breach reasonable standards of morality, decency and respect for the interests of others to be treated with civility and/or which may breach the rights in law of others not to be defamed and/or which may breach any right in law whatsoever and shall hold harmless ourselves against all claims and demands that may relate in any way to such content.
  • you will not upload onto any area of this website any information, whether as to your identity, the purpose of your visit or otherwise, that is not truthful and honest,
  • you will not upload to this website, or create or increase any risk of the uploading by others, or otherwise expose this website or any email address disclosed on it, to the risk of a visit or action by any virus, trojan, autobot or other form of malware of any description, and will keep us at all times fully indemnified against any loss or damage resulting from any such upload or risk,
  • we have full right to remove at any time, and without notice to you, any content uploaded by yourself to this website,
  • should you access any part of this website by personal login, you accept full responsibility for all actions taken on the website under your username, whether or not you were the person who took such action,
  • there is no liability on us for loss or damage resulting, directly or indirectly, from your visit to (including agreeing not to seek to hold us responsible, or accountable, for any action or lack of action by yourself as a result of information or advice appearing on), this website, or through access from this website, whether a website that is linked from this website, or any website that masquerades as our website or from data and information appearing through data sharing technologies, or from your use of less than the optimal encryption security, anti-virus or anti-spam protection or other similar procedures, including measures to protect your personal identity, in your browser or e-mail program, or otherwise the manner and procedures you adopt when browsing around the Web
  • that, whilst we will use our best endeavours at all times to ensure the continuity of the availability of the website on the Internet, given that the potential for disruption of connectivity extends well beyond technology and events over which we have any control, covering possible actions by many varied organisations who contribute to the functionality and connectivity of the Internet as well as the status of your own software and websites, there will be no liability on us for any loss or damage resulting, directly or indirectly, from any disruption of access or failure or variation of intended functionality that occurs for whatever reason,
  • that we reserve the right at any time to suspend or cancel your use of, or access to, this website,
  • that you recognise that we own all intellectual property rights in the content on this website, and that you will not, either by yourself directly or by assisting or permitting others so to do, do anything that breaches in any way such intellectual property rights of ourselves and, in particular, will not copy or reproduce any element of this website or its code or use it, or any part of it, to create any content, document, website, image or graphic. In addition you will not create, or permit or assist others in creating, any hyperlink to any part of this website save to the home page nor take any action that directly or indirectly prevents, in whole or in part, access to, or reduces the enjoyment by yourself or others of, this website,
  • that when seeking to purchase any goods or services on this website, that you will not do so save on the basis that our Terms and Conditions of Sale are accepted by you as regulating any such purchase you make.

4. In the event that any term is held to be invalid by a decision of a court of competent authority, the remainder of these Terms & Conditions shall remain valid and enforceable.

5. The laws of England and Wales shall be the only laws that apply to your use of this website and you agree to submit to the exclusive jurisdiction of the courts of England and Wales for the resolution of any claim or dispute arising.

6. All written notices to be given to us shall be sent by post to:
 Tommy Taylors Lane
Cheltenham 
GL50 4RN 
United Kingdom