Privacy Policy for Activate UK

Who we are

We are Activate UK, a network of companies who operate under licence from Agility UK Ventures Ltd (a company registered in England and Wales with registered company number 15663011 whose registered office is at 3 Sheen Road, Richmond Upon Thames, England, TW9 1AD. Please contact us using the details below if you have any questions on these terms or the service that we provide. Where we refer to "us" or "we" in this statement we are referring to Agility UK Ventures Ltd and any Activate UK business in the network.

What information we hold about you

We collect personal information whenever you provide it to us. This personal information may include the following:

• name, date of birth and contact details
• demographic information including postcode, preferences and interests
• payment details
• various technical information which is collected automatically including your IP address, web browser type and version and operating system

How we use your data

We use your information for the purposes of contacting you regarding any enquiries you make and to exercise and carry out our rights and obligations arising from any orders for our products or services.

We will also use your information in order to enhance and develop our website, products and services. We aim to provide you with the best possible service and experience when using our website, as such we may use your data in order to continue to improve your experience when using our website.

We will also, where we have your consent to do so, use your contact details to keep you up-to-date with our products and services including offers and promotions from us. We may also contact you, with your consent, in order to conduct market research to enable us to customise and update our website.

We will not provide your information to third parties other than as set out below.

The basis on which we use your data

When we use your personal information we are required to have a legal basis for doing so. There are various different legal bases upon which we may rely, and these will depend on the personal information in question and the specific context in which we collect it.

The legal bases we may rely on include:

• consent: where you have given us clear consent for us to process your personal information for a specific purpose
  
• contract: where our use of your personal information is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract
  
• legal obligation: where our use of your personal information is necessary for us to comply with the law (not including contractual obligations)
  
• vital interests: where our use of your personal information is necessary to protect you or someone else's life
  
• public task: where our use of your personal information is necessary for us to perform a task in the public interest or for our official functions, and the task or function has a clear basis in law
  
• legitimate interests: where our use of your personal information is necessary for our legitimate interests (such as marketing) or the legitimate interests of a third party (unless there is a good reason to protect your personal information which overrides our legitimate interests)

We may also need, in some circumstances, to record and process personal information about you that might be interpreted as sensitive information, such as recording if you have an accident when using our facilities. Where we do this, we consider that the recording and use of that data is necessary for medical purposes and/or so that we can comply with employment law and/or establishing legal rights.

Who we may share your data with

We may use and share aggregated statistical data regarding usage of our service with third parties but will not provide such third parties with any personally identifiable information about you.

We may disclose or transfer your personal data to:

• our agents and service providers
  
• any of our corporate group companies
  
• any business within the Activate UK network
  
• a third party who acquires our business
  
• law enforcement and regulatory agencies in connection with any investigation to help prevent unlawful activity or as otherwise required by law
  

Keeping your data secure

We will use technical and organisational measures to safeguard your personal data, for example:

• we store your personal data on secure servers
  
• access to your personal data is limited to authenticated and approved staff

While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that are transferred from you or to you via the internet.

Promotional communications

We may use your personal information to send you updates (by email, text message, telephone or post) about products and services, including exclusive offers, promotions or new products and services from us and those within theActivate UK network.

We have a legitimate interest in processing your personal information for promotional purposes. This means we do not usually need your permission to send you promotional communications. However, where permission is needed, we will ask for this permission separately and clearly.

We will always treat your personal information with the utmost respect and never sell or share it with other organisations outside the Activate UK for marketing purposes.

You have the right to opt out of receiving promotional communications at any time by using the unsubscribe link in our communications or contacting us on the details below.

Transfer of data out of the EEA

The information that we collect from you may be transferred to, and stored at, a destination outside of the European Economic Area ("EEA"). It may also be processed by staff in destinations outside the EEA who work for us or for one of our third party service providers.

These destinations may not have the same legal protections for personal data as you enjoy under English law. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy statement and data protection legislation.

When we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

the countries we transfer your personal data to have been deemed to provide an adequate level of protection for personal data by the European Commission;

• we use contractual clauses approved by the European Commission which give personal data similar protection to that which it has in the EEA; or
  
• where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data that applies within the EEA.
  

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Your Rights

You have the right to request access to personal data that we may process about you, correct any inaccuracies in your data free of charge, and/or require us to erase personal data that we may process about you. If you wish to exercise this right, you should:

• put your request in writing
  
• include proof of your identity and address (eg a copy of your driving licence or passport, and a recent utility or credit card bill); and
  
• specify the personal data you want access to, including any account or reference numbers where applicable.

If you have any concerns or questions as to the way in which we process your information please do contact us. In addition you have a right to bring a complaint with the Information Commissioner's Office. More information on the Information Commissioner's Office and your rights is available at www.ico.org.uk.

Cookies

For our website to function properly we use cookies. To obtain your valid consent for the use and storage of cookies in the browser you use to access our website and to properly document this we use a consent management platform: Termly. This technology is provided by Termly 906 W 2ND AVE, STE 100 SPOKANE, WA 99201-4540, United States.

When you access our website, a connection is established with Termly’s server to give us the possibility to obtain valid consent from you to the use of certain cookies. Termly then stores a cookie in your browser in order to be able to activate only those cookies to which you have consented and to properly document this. The data processed is stored until the predefined storage period expires or you request to delete the data. Certain mandatory legal storage periods may apply notwithstanding the aforementioned.

Termly is used to obtain the legally required consent for the use of cookies. The legal basis for this is article 6(1)(c) of the General Data Protection Regulation (GDPR).

Data processing agreement

We have concluded a data processing agreement with Termly. This is a contract required by data protection law, which ensures that data of our website visitors is only processed in accordance with our instructions and in compliance with the GDPR.

Server log files

Our website and Termly automatically collect and store information in so-called server log files, which your browser automatically transmits to us. The following data is collected:

• Your consent status or the withdrawal of consent
  
• Your anonymised IP address
  
• Information about your Browser
  
• Information about your Device
  
• The date and time you have visited our website
  
• The webpage url where you saved or updated your consent preferences
  
• The approximate location of the user that saved their consent preference
  
• A universally unique identifier (UUID) of the website visitor that clicked the cookie banner
  

Retention of data

Most of the data which you provide to us will be retained for a period of up to 6 months following your last interaction with us. Where you sign up to receive our newsletter we shall retain your information for as long as we have your consent to provide you with our newsletter.

Some of your data will be retained for a period of up to 7 years from the date of your last interaction with us in line with our accounting obligations or longer in some cases where it is necessary to retain this information for insurance, licensing or other regulatory reasons.

Changes to this policy

We may change this policy from time to time. You should check this policy frequently to ensure you are aware of the most recent interact with us.

Contact Us

To contact us please use the following details:

3 Sheen Road, Richmond Upon Thames, England, TW9 1AD

info@playactivateuk.com