Introduction

Shoreline Leisure Bray, Shoreline Leisure Greystones and Shoreline Leisure Sportspark are committed to protecting your privacy and to be completely transparent about what information we hold. We understand our obligations to you and wish to help you understand how and why we process your personal data. This privacy notice sets out the basis by which we collect, use and disclose the personal data of our members, as well as your rights in respect of such personal data. We may update this privacy notice from time to time. The version available online will always be the most up to date current version and notifications will be through the webpage. The above entities - (i) Bray Swimming Pool Sports & Leisure Centre Ltd T/A Shoreline Leisure Bray and (ii) Wicklow Recreation Services Ltd T/A Shoreline Leisure Greystones & Charlesland Sports & Recreation Park are joint data controllers. The designated joint controller representative is Shoreline Leisure Bray. Shoreline Leisure Bray is entitled to act on behalf of both the above organisations and is responsible for providing information to the data subjects in a compliant manner, and for processing and responding to requests submitted by any the individual, organisations by a data subject or authority.

Scope  
This Privacy Notice applies both to our online activities and to information collected offline or via channels other than this website.

How we collect your Personal Data

You will have provided all of the information we hold, when you complete either a physical or online membership application form and health commitment statement. After initially agreeing to this privacy policy, when you visit our website, we also automatically collect certain information about your device, including information about your web browser, operating system, IP address, time zone, and some of the cookies installed on your device. Additionally, as you browse our website, we collect information about the individual web pages or content that you view, what websites or search terms referred you to our website, and information about how you interact with our website.

“Cookies” are data files inserted on your device or computer and often include an anonymous unique identifier. Our website requires cookies in order to be able to function and access is not possible without you enabling these cookies.

“Log files” track actions occurring on our website, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.

Type of personal data we collect and process

When setting up a membership account, we will collect and gather the following categories of personal data,

• Identity data: Name, Date of Birth, Gender

• Contact details: Telephone number(s), Address, E-mail Address

In addition, when completing a fitness assessment / health screening, we may collect further medical information subject to your consent.

How we use your personal data

• To Verify your identity to enable membership of the organisation

• To correct and update information at your request.

• Comply with a legal or regulatory obligation.

• Dealing with issues of Health & Safety, processing possible insurance claims, and/or “In Case of Emergency Numbers'' whilst engaged in activities at Shoreline sites. Only approved Staff of Shoreline and/or authorised 3rd parties, will have access to this particular data.

• Communicating with you via email, phone or post in relation to matters relating to your membership or details of upcoming events and programmes. You have the right to withdraw your consent to communications at any time by using the tools within the website or contacting us via email at gdprbray@shorelineleisure.ie

• We also use Google Analytics to help us understand how you use our website.
  
  

 Legal basis for processing your personal data
The legal basis upon which we hold personal data is as follows:

• Our legitimate interests - we require this information about our members in order to fulfill our function providing services to our members.

• Legal Obligation: We have legal obligations, including for example, obligations to ensure the safety of our members and third parties pursuant to which it is necessary to hold the information retained.

• Performance of Contract: As a commercial organisation we are required to enter contractual arrangements with staff, members and third parties and information is required in order to complete the performance of such contractual obligation.

• Consent: Where none of the above bases apply, we will obtain and process personal data only with your consent, which you may withdraw at any time.

Children's Information
Another part of our priority is adding protection for children while using the internet. We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity. Shoreline Leisure does not knowingly collect any Personal Identifiable Information from children under the age of 16. If you think that your child provided this kind of information on our website, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records.

Existing Data Information with Shoreline Leisure
We will use our best endeavors to guarantee that all Personal Data that you have submitted to us is maintained and up to date. However, it is your responsibility to inform us of any changes to your data to ensure that it is up to date.

Marketing
If you are a member, we may with your consent pass information to you directly in relation to upcoming Shoreline Leisure events or programmes. We will not share your personal data with other external marketing services providers.

Sharing your data with others
We do not disclose to any third party personal data that we may collect or you provide to us with the exception of third parties expressly mentioned in this privacy policy.

• Personal data collected by us is shared as necessary to allow you to access and use multi-site facilities.

• Where necessary we may choose to use the services of 3rd party external IT or other services providers as data processors, as defined by and approved under the relevant GDPR legislation.

• Where you have provided consent by opting in, we will share your contact details with our internal marketing department for marketing and communications purposes.

• We may on occasion need to share information with professional advisors such as solicitors and insurers and other outside professional advisors (i.e. Health & Safety Consultants) relevant to the activity of Shoreline Leisure.

• We require that all third parties respect your personal data, and to treat it in accordance with the law. We do not allow our 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.

• Unless prevented by applicable law, we will notify you when it might be necessary to provide your personal data to third parties in ways other than explained above, and you may have the option to prevent such sharing at the time that we notify you.

• There may be other reasons where it is not possible or appropriate to gain your consent such as disclosures to the Gardaí for prevention or detection of crime, or to meet statutory obligations.

 Data Retention

Any person who creates either an on-line membership account or completed a onsite membership application and provides all their personal data but then chooses NOT to continue their membership after the expiry date of their membership contract will have all their data deleted after 36 months.

Rights

You have the following rights;

• Right to be informed:This privacy notice provides the information you are entitled to receive on how your data is collected, stored and processed. In a clear and accessible way.

• Right of access: Please contact us if you would like to request access to a copy of your data in electronic form.  There is no charge for us providing you with this data and it will usually be provided within one month of the request.  However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse your request in these circumstances. We may need specific information from you to help us confirm your identity and ensure your right to access.

• Right of correction/deletion: You may exercise your right to have your personal data erased in a number of circumstances e.g. if the data is no longer necessary in relation to the purpose for which it was created or you withdraw consent. If you have provided consent for the processing of your data, you have the right (in certain circumstances) to withdraw that consent at any time which will not affect the lawfulness of the processing, before your consent was withdrawn.

Security

The security of your personal data is very important to us.We will ensure that we have in place appropriate technical and organisational measures to prevent unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to personal data. We use a variety of security technologies and procedures to help protect your personal information from unauthorised access, use or disclosure.

Identity and contact details of controller and data protection officer:

Bray Swimming Pool Sports & Leisure Centre Ltd T/A Shoreline Leisure Bray is the designated controller and processor of data for the purposes of the Data Protection Act.

Additional information:

Log Files
Shoreline Leisure follows a standard procedure of using log files. These files log visitors when they visit websites. All hosting companies do this as part of hosting services' analytics. The information collected by log files include internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks. These are not linked to any information that is personally identifiable. The purpose of the information is for analysing trends, administering the site, tracking users' movement on the website, and gathering demographic information.

Cookies and Web Beacons

Like any other website, Shoreline Leisure uses "cookies". These cookies are used to store information including visitors' preferences, and the pages on the website that the visitor accessed or visited. The information is used to optimize the users' experience by customizing our web page content based on visitors' browser type and/or other information. Third-party ad servers or ad networks use technologies like cookies, JavaScript, or Web Beacons that are used in their respective advertisements and links that appear on Shoreline Leisure, which are sent directly to users' browsers. They automatically receive your IP address when this occurs. These technologies are used to measure the effectiveness of their advertising campaigns and/or to personalize the advertising content that you see on websites that you visit. Note that Shoreline Leisure has no access to or control over these cookies that are used by third-party advertisers.

Third Party Privacy Policies

Shoreline Leisure's Privacy Notice does not apply to other advertisers or websites. Thus, we are advising you to consult the respective Privacy Notices and Policies of these third-party ad servers for more detailed information. It may include their practices and instructions about how to opt-out of certain options. You can choose to disable cookies through your individual browser options. To know more detailed information about cookie management with specific web browsers, it can be found at the browsers' respective websites.