Privacy Policy

The Lakeland Climbing Centre Limited – Privacy Notice
The Lakeland Climbing Company Ltd [trading as Kendal Wall Climbing Centre, PrestonWall Climbing Centre, LancasterWall Climbing Centre, HarroWall Climbing Centre, VauxWest
Climbing Centre, VauxEast Climbing Centre, RavensWall Climbing Centre, CroyWall Climbing Centre,
CanaryWall Climbing Centre, BethWall Green Climbing Centre,] (the “Wall”, “we”, “us”) (registered company number [03006915]) is
committed to protecting your privacy. At all times we aim to respect any personal information you share
with us, or that we receive from others, and keep it safe. This Privacy Notice (“Notice”) sets out our
data processing practices and your rights and options regarding the ways in which your personal
information is used and collected (including through our websites – [www.kendalwall.co.uk, www.prestonwall.co.uk, www.lancasterwall.co.uk,
www.harrowall.co.uk, www.vauxwest.co.uk, www.vauxeast.co.uk, www.ravenswall.co.uk,
www.croywall.co.uk, www.canarywall.co.uk, www.bethwall.co.uk,]).
This Notice contains important information about your personal rights to privacy. Please read it
carefully to understand how we use your personal information.
The provision of your personal information to us is voluntary. However, without providing us
with your personal information, your use of our services or your interaction with us may be
impaired. For example, you may be unable to sign up as a member, or make an online booking.
Contents of this policy:
1. How we collect personal information about you
2. What personal information do we use?
3. How and why will we use your personal information?
4. Lawful bases
5. Communications for marketing/ fundraising
6. Children’s personal information
7. How long do we keep your personal information?
8. Will we share your personal information?
9. Security/ storage of and access to your personal information
10. International Data Transfers
11. Exercising your Rights
12. Changes to this Notice
13. Links and third parties
14. How to contact us
1. We collect personal information about you:
a. When you give it to us directly
For example, personal information that you submit through our website such as pre-registering
on our database; or by making a booking to use our facilities; or via our tablets at Wall reception;
or signing up for our email newsletter; or personal information that you give to us when you
communicate with us by email, phone or letter.
b. When we obtain it indirectly
For example, your personal information may be shared with us by third parties including, for
example, the Association of Climbing Walls (Britain) Limited (“ABC”), an organisation
established to promote safe management practices in climbing walls of which we are a member;
third party service providers; analytics providers and search information providers. To the extent
we have not done so already, we will notify you when we receive personal information about
you from them and tell you how and why we intend to use that personal information.
c. When it is available publicly
Your personal information may be available to us from external publicly available sources. For
example, depending on your privacy settings for social media services, we may access
information from those accounts or services (for example when you choose to interact with us
via Facebook, Instagram, Twitter and Google).
d. When you visit our website
When you visit our website, we automatically collect the following types of personal information:
(a) Technical information, including the internet protocol (IP) address used to connect your
device to the internet, browser type and version, time zone setting, browser plug-in types
and versions and operating systems and platforms.
(b) Information about your visit to the websites, including the uniform resource locator (URL)
clickstream to, through and from the website (including date and time), services you viewed
or searched for, page response times, download errors, length of visits to certain pages,
referral sources, page interaction information (such as scrolling and clicks) and methods
used to browse away from the page.
(c) We collect and use your personal information by using cookies on our website – please
see our Cookie Notice at any of our websites – www.kendalwall.co.uk,
www.harrowall.co.uk, www.vauxwest.co.uk, www.vauxeast.co.uk,
www.ravenswall.co.uk, www.croywall.co.uk, www.canarywall.co.uk,
www.bethwall.co.uk, and www.prestonwall.co.uk
(d) In general, we may combine your personal information from these different sources set out
in a-d above, for the purposes set out in this Notice.
2. What personal information do we use?
We may collect, store and otherwise process the following kinds of personal information:
a. your name and contact details including postal address, telephone number, email address,
emergency contact details and, where applicable, social media identity;
b. your date of birth and gender;
c. your financial information, such as bank details and/ or credit/ debit card details,
d. information about your computer/ mobile device and your visits to and use of this website,
including, for example, your IP address and geographical location;
e. personal descriptions and photographs;
f. details of your qualifications/ experience;
g. CCTV recordings;
h. Information relating to medical emergencies or accidents on our premises;
i. Medical information shared by you where you feel it is important for us to know about a
certain medical condition when you are using our centres
j. Photographs taken during climbing competitions within our centres
and/ or any other personal information which we obtain as per paragraph 1.
Do we process special categories of data?
The EU General Data Protection Regulation (“GDPR”) recognises certain categories of personal
information as sensitive and therefore requiring more protection, for example information about
your health, ethnicity and religious beliefs.
In certain situations, the Wall may collect and/or use these special categories of data (for example,
information on climbers’ medical conditions relevant to their use of our facilities). We will only
process these special categories of data if there is a valid reason for doing so and where the GDPR
allows us to do so.
3. How and why will we use your personal information?
Your personal information, however provided to us, will be used for the purposes specified in this
Notice. In particular, we may use your personal information:
a. to register you as a member of the Wall;
b. to allow you to make a booking to use our facilities;
c. to otherwise provide you with services, products or information you have requested;
d. to provide further information about our work, services or activities (where necessary, only
where you have provided your consent to receive such information);
e. to assist you with certification schemes, such as NICAS;
f. to answer your questions/ requests and communicate with you in general;
g. to allow you to apply for a job or volunteer role with us;
h. to manage relationships with our partners and service providers;
i. to analyse and improve our work, services, activities, products or information (including our
website), or for our internal records;
j. to keep our facilities safe and secure;
k. to run/administer the activities of the Wall, including our website, and ensure that content is
presented in the most effective manner for you and for your device;
l. to audit and/ or administer our accounts;
m. to satisfy legal obligations which are binding on us, for example in relation to regulatory,
government and/or law enforcement bodies with whom we may work (for example requirements
relating to the payment of tax or anti-money laundering);
n. for the prevention of fraud or misuse of services; and/or
o. for the establishment, defence and/ or enforcement of legal claims.
4. Lawful bases
The GDPR requires us to rely on one or more lawful bases to use your personal information. We
consider the grounds listed below to be relevant:
a. Where you have provided your consent for us to use your personal information in a certain
way (for example, we may ask for your consent to use your personal information to send you
email newsletters, or to collect special categories of your personal information. Special
categories of personal information are explained in paragraph 2 above).
b. Where necessary so that we can comply with a legal obligation to which we are subject (for
example, where we are obliged to share your personal information with regulatory bodies
which govern our work and services).
c. Where necessary for the performance of a contract to which you are a party or to take
steps at your request prior to entering a contract (for example, to provide you access to our
facilities in return for your booking fee).
d. Where it is in your/someone else’s vital interests (for example, in case of medical
emergency suffered by a climber).
e. Where there is a legitimate interest in us doing so.
The GDPR allows us to collect and process your personal information if it is reasonably
necessary to achieve our or others’ legitimate interests (as long as that processing is fair,
balanced and does not unduly impact your rights as an individual).
In broad terms, our “legitimate interests” means the interests of running of the Wall as a
commercial entity and ensuring the best possible user experience.
When we process your personal information to achieve such legitimate interests, we consider and
balance any potential impact on you (both positive and negative), and on your rights under data
protection laws. We will not use your personal information for activities where our interests are
overridden by the impact on you, for example where use would be excessively intrusive (unless,
for instance, we are otherwise required or permitted to by law).
5. Communications for marketing/promotional purposes
We may use your contact details to provide you with information about our work, events, services
and/or activities which we consider may be of interest to you (for example, about services you
previously used, or events involving our, or other walls’, facilities).
Where we do this via email, SMS or telephone (where you are registered with the Telephone
Preference Service), we will not do so without your prior consent (unless allowed to do so via
applicable law).
Where you have provided us with your consent previously but do not wish to be contacted by us
about our work, events, services and/or activities in the future, please let us know by email at
[email protected] You can opt out of receiving emails from the Wall at any time by clicking the
“unsubscribe” link at the bottom of our emails.
6. Children’s personal information
When we process children’s personal information, where required we will not do so without their
consent or, where required, the consent of a parent/ guardian. We will always have in place
appropriate safeguards to ensure that children’s personal information is handled with due care.
7. How long do we keep your personal information?
In general, unless still required in connection with the purpose(s) for which it was collected and/or
processed, we remove your personal information from our records six years after the date it was
collected; or six years after a junior (Under 18 years of age when registered) turns 18. However, if
before that date (i) your personal information is no longer required in connection with such
purpose(s), (ii) we are no longer lawfully entitled to process it or (iii) you validly exercise your right
of erasure (please see Section 11 below), we will remove it from our records at the relevant time.
If you request to receive no further contact from us, we may keep some basic information about
you on our suppression list in order to comply with your request and avoid sending you unwanted
materials in the future.
8. Will we share your personal information?
We do not share, sell or rent your personal information to third parties for marketing purposes.
However, in general we may disclose your personal information to selected third parties in order to
achieve the purposes set out in this Notice.
These parties may include (but are not limited to):
a. Climbing Centres owned and operated by the Lakeland Climbing Centre Ltd
b. the ABC and the ABC Training Trust;
c. local government agencies;
d. funding bodes such as Sport England and NGB;
e. awarding bodies such as Mountain Training;
f. other members of the ABC;
g. healthcare professionals;
h. providers of kit and equipment;
i. suppliers and sub-contractors for the performance of any contract we enter into with them, for
example IT service providers such as website hosts, payment providers or cloud storage
providers;
j. professional service providers such as accountants and lawyers;
k. parties assisting us with research to monitor the impact/effectiveness of our work, events,
services and activities; and
l. regulatory authorities, such as tax authorities;
In particular, we reserve the right to disclose your personal information to third parties:
 in the event that we sell or buy any business or assets, in which case we will disclose your
personal information to the (prospective) seller or buyer of such business or assets;
 if substantially all of our assets are acquired by a third party, personal information held by
us may be one of the transferred assets;
 if we are under any legal or regulatory duty to do so; and/or
 to protect the rights, property or safety of the Wall, its personnel, users, visitors or others.
9. Security/storage of and access to your personal information
The Wall is committed to keeping your personal information safe and secure and we have
appropriate and proportionate security policies and organisational and technical measures in place
to help protect your information.
Your personal information is only accessible by appropriately trained staff, volunteers and
contractors, and stored on secure servers which have features to prevent unauthorised access.
10. International Data Transfers
Given that we are a UK-based organisation we will normally only transfer your personal information
within the European Economic Area (“EEA”), where all countries have the same level of data
protection law as under the GDPR.
However, because we may sometimes use agencies and/or suppliers to process personal
information on our behalf, it is possible that personal information we collect from you will be
transferred to and stored in a location outside the EEA, for example the United States.
Please note that some countries outside of the EEA have a lower standard of protection for personal
information, including lower security requirements and fewer rights for individuals. Where your
personal information is transferred, stored and/or otherwise processed outside the EEA in a country
that does not offer an equivalent standard of protection to the EEA, we will take all reasonable steps
necessary to ensure that the recipient implements appropriate safeguards (such as by entering into
standard contractual clauses which have been approved by the European Commission) designed
to protect your personal information and to ensure that your personal information is treated securely
and in accordance with this Notice. If you have any questions about the transfer of your personal
information, please contact us using the details below.
Unfortunately, no transmission of your personal information over the internet can be guaranteed to
be 100% secure – however, once we have received your personal information, we will use strict
procedures and security features to try and prevent unauthorised access.
11. Exercising your Rights
7
Where we rely on your consent to use your personal information, you have the right to withdraw
that consent at any time. This includes the right to ask us to stop using your personal information
for marketing or fundraising purposes or to unsubscribe from our email list at any time. You also
have the following rights:
a. Right of access – you can write to us to ask for confirmation of what personal information we
hold on you and to request a copy of that personal information. Provided we are satisfied that
you are entitled to see the personal information requested and we have successfully confirmed
your identity, we will provide you with your personal information subject to any exemptions that
apply.
b. Right of erasure – at your request we will delete your personal information from our records
as far as we are required to do so. In many cases we would propose to suppress further
communications with you, rather than delete it.
c. Right of rectification – if you believe our records of your personal information are inaccurate,
you have the right to ask for those records to be updated. You can also ask us to check the
personal information we hold about you if you are unsure whether it is accurate/up to date.
d. Right to restrict processing – you have the right to ask for processing of your personal
information to be restricted if there is disagreement about its accuracy or legitimate usage.
e. Right to object – you have the right to object to processing where we are (i) processing your
personal information on the basis of the legitimate interests basis (see paragraph 4), (ii) using
your personal information for direct marketing or (iii) using your information for statistical
purposes.
f. Right to data portability – to the extent required by the GDPR, where we are processing your
personal information (that you have provided to us) either (i) by relying on your consent or (ii)
because such processing is necessary for the performance of a contract to which you are party
or to take steps at your request prior to entering into a contact, and in either case we are
processing using automated means (i.e. with no human involvement), you may ask us to
provide the personal information to you – or another service provider – in a machine-readable
format.
g. Rights related to automated decision-making – you have the right not to be subject to a
decision based solely on automated processing of your personal information which produces
legal or similarly significant effects on you, unless such a decision (i) is necessary to enter
into/perform a contract between you and us/another organisation; (ii) is authorised by EU or
Member State law to which the Wall is subject (as long as that law offers you sufficient
protection); or (iii) is based on your explicit consent.
Please note that some of these rights only apply in limited circumstances. For more information, we
suggest that you contact us using the details in paragraph 14 below.
We encourage you to raise any concerns or complaints you have about the way we use your
personal information by contacting us using the details provided in paragraph 14 below. You are
further entitled to make a complaint to the Information Commissioner’s Office – www.ico.org.uk For
further information on how to exercise this right, please contact us using the details below.
12. Changes to this Notice
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We may update this Notice from time to time. We will notify you of significant changes by contacting
you directly where reasonably possible for us to do so and by placing an update notice on our
website.
13. Links and third parties
We link our website directly to other sites. This Notice does not cover external websites and we
are not responsible for the privacy practices or content of those sites. We encourage you to read
the privacy policies of any external websites you visit via links on our website.
14. How to contact us
Please let us know if you have any questions or concerns about this Notice or about the way in
which the Wall processes your personal information by contacting us at the channels below. Please
ask for / mark messages for the attention of the LCC Data Protection Manager
Email: [email protected]
Telephone 020 7160 0248
Post:
LCC Data Protection Manager,
VauxWall West Centre
Arches 45b-47c
South Lambeth Road
London
SW8 1SR