We are Data Controller for the Personal Data you supply to us. Data Protection issues for Womenclimb are managed by the CEO. Contact details are set out in the “Contacting us” section at the end of this privacy notice.
The legal basis on which Womenclimb collects & stores your information
Womenclimb is required to state the basis on which it collects and stores your personal information, and three legal bases, as defined by the ICO, are applicable:
- Legitimate Interest
Becoming a member of Womenclimb and attending Womenclimb events, meetups or training are deemed to be a Contract. We collect and process your Personal Data to:
- Identify and communicate with you,
- Administer training safely,
- Collect subscriptions, training fees and other money due, and
- Process the affiliation fee with the British Mountaineering Council (BMC).
What Personal Data do we collect?
We collect Personal Data about you when you visit our Sites or use our Services, including the following:
- Registration and use information – When you register to use our Services by establishing an account, we will collect Personal Data as necessary to offer and fulfil the Services you request. Depending on the Services you choose, we may require you to provide us with your name, postal address, telephone number, email address and identification information to establish an Account. We may require you to provide us with additional Personal Data as you use our Services.
- Paid services: When you send or request money through the services, we collect Personal Data such as name, postal address, telephone number, email. The extent of Personal Data required about a participant may vary depending on the Services you are using to send or request money. We use Paypal and Eventbrite to manage payments from you to us and refunds from us to you. They have their own privacy policies which you can find on their websites.
- Other information we collect related to your use of our Sites or Services – We may collect additional information from or about you when you communicate with us, contact our customer support teams or respond to a survey.
Your image in photos or videos
The ICO has advised that GDPR does not apply to images of people taken in public places by amateur photographers. Although not a GDPR issue, we offer general advice below –
You do not usually have a legal right to object to being photographed in a public place. It is common courtesy for photographers to seek permission, however, you are not obliged to consent to being photographed.
From the date of issue of this document, if we have used an image or video of you on our website, in Womenclimb social media, or in any printed Womenclimb publications, from the date of issue of this document, we will only do so where the photographer assures us that you have consented. If you wish for any image or video of you to be removed from our website, or social media channels, you must notify both us and the photographer, in writing. On such notification, we will use reasonable endeavours to remove such images from our website or Womenclimb social media, but it is impractical for us to remove images of individuals from Womenclimb printed publications, and we are not able to offer this option. Note that we can only help where your image appears in Womenclimb media. Any issues you have with any other use of your image by the photographer, are between you and the photographer.
Why do we retain Personal Data?
We may retain your data for insurance purposes for a period of up to 6 years.
How do we process personal data?
We may process your Personal Data for a variety of reasons:
To operate our website and provide services, including to:
- Register & administer the membership system
- Run events, meetups, trips and training
- Help climbers improve skills, knowledge & understanding through online & offline means
- Provide blog posts on our website
- Enable access to online account
- Send information requested
- Help climbers find climbing partners
- Share competitions, discounts and benefits
- Communicate with you about any of the above
To manage our business needs, such as monitoring, analysing, and improving the Services and the Sites’ performance and functionality. For example, we analyse user behaviour and perform research about the way customers use our Services.
To manage risk and protect the website, social media channels, services, customers and staff from fraud by verifying your identity, and helping to detect and prevent fraud.
To comply with our obligations, to enforce the terms of our website, social media channels and services, to comply with all laws and regulations.
For our legitimate interests, including to:
- enforce the terms of our Sites and Services;
- manage our everyday business needs, such as monitoring, analysing; and
- anonymise Personal Data in order to provide aggregated statistical data to third parties, including other businesses and members of the public, about how, when, and why Users visit our Sites and use our Services.
With your consent, including to:
To market to you by delivering marketing materials about womenclimb products and services and the products and services of unaffiliated businesses.
To provide personalised services
To provide you with location-specific options, functionality or offers if you elect to share your Geolocation Information through the website, social media or services.
To make it easier for you to find and connect with others
To respond to your requests, for example to contact you about a question you submitted to Womenclimb crew.
You can withdraw your consent at any time.
If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.
If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.
If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.
For users that register on our website, we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can see and edit that same information.
Do we share your Personal Data?
We will always treat your information with great care. We will only share your data in limited circumstances. We may share your Personal Data or other information for the following reasons:
With other companies that provide services to us: We use third party service providers to perform services on our behalf. These providers each have their own privacy policies:
With other organisations that we have partnered with: We share Personal Data with other organisations and businesses with whom we have partnered to jointly create and offer a product. These organisations may only use this information in relation to the product you have purchased, unless you have given express consent for other uses.
With other third parties as permitted or required by law: We may share information about you with other parties for PayPal’s business purposes or as permitted or required by law, including:
- if we need to do so to comply with a law, legal process or regulations;
- to law enforcement authorities or other government officials, or other third parties pursuant to a subpoena, a court order or other legal process or requirement applicable to Womenclimb.
- if we believe, in our sole discretion, that the disclosure of Personal Data is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity;
- to protect the vital interests of a person;
- to protect our property, Services and legal rights;
- in connection with shipping and related services for purchases made using a Service;
- to help assess and manage risk and prevent fraud against us,
- to support our audit, compliance, and corporate governance functions.
We never share your Personal Data with third parties for their marketing purposes without your consent.
What privacy choices are available to you?
You have choice about what data you share, however this will limit the services we can provide to you.
- Personal Data. You may decline to provide Personal Data when it is requested by Womenclimb, but certain service may not be available to you.
- Location and other device-level information. Your device may collect information about you, including your geolocation and user usage data. To find out more about this, you can refer to your device handbook and settings.
- Tracking & Cookies. You may have options to manage cookie preferences, which you can access via your device settings or internet settings. You can learn more at: aboutcookies.org.
- Account. If you choose to set up a membership account with Womenclimb, you may review and edit the Personal Data within that account directly or by contacting us.
- Marketing. If you choose to join our mailing list, you may choose which information you submit, with the minimum being email address and name. If you would prefer not to submit this information or to withdraw this information, you may do so by clicking unsubscribe.
What are your rights?
Subject to limitations set out in EEA data protection laws, you have certain rights in respect of your Personal Data. In particular, you have a right of access, rectification, restriction, opposition, erasure and data portability. Please contact us if you wish to exercise these rights.
How do we protect your Personal Data?
We maintain technical, physical, and administrative security measures designed to provide reasonable protection for your Personal Data against loss, misuse, unauthorised access, disclosure, and alteration. The security measures include firewalls, data encryption, physical access controls to our data centres, and information access authorisation controls. While we are dedicated to securing our systems and Services, you are responsible for securing and maintaining the privacy of your password(s) and Account/profile registration information and verifying that the Personal Data we maintain about you is accurate and current.
Can children use our services?
The Sites and Services are for adults over the age of 18 and are not directed to children under the age of 18. We do not knowingly collect information, including Personal Data, from children or other individuals who are not legally able to use our website and services. If we obtain actual knowledge that we have collected Personal Data from a child under the age of 18, we will promptly delete it, unless we are legally obligated to retain such data. Contact us if you believe that we have mistakenly or unintentionally collected information from a child.
What else should you know?
For full information about your rights see the Information Commissioner’s Office. When we receive a request to amend or delete your Personal Data we will respond immediately. We recognise how important this is to you.
If you have any concerns about the Personal Data we hold about you please contact the Womenclimb CEO, Emily Pitts: firstname.lastname@example.org