1. COLLECTION OF DATA
1.1. Important information and who we are
Our site is not intended for children, and we do not knowingly collect data relating to children.
For the purposes of the General Data Protection Regulation (EU) the data controller is S Adventure Cycling Ltd, NEO House, Riverside Drive, Aberdeen, Scotland, AB11 7LH. SA is made up of several different entities and brands. This privacy notice is issued on behalf of all of the entities and brands owned by S Adventure Cycling Ltd. If you have any questions about this privacy notice, including details of the entities and brands, or any requests to exercise your legal rights, please contact us using the details set out below.
Email address: info@ScottishAdventure.org
Postal address: S Adventure Cycling Ltd, NEO House, Riverside Drive, Aberdeen, Scotland, AB11 7LH.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues ( www.ico.org.uk ), or the equivalent regulatory authority in your country. However, we would like to deal with your concerns before you approach the ICO (or other regulator) so please contact us in the first instance.
1.4. Changes to the privacy notice and your duty to inform us of changes
1.5. Third-party links
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
1.6. Information we may collect from you
Personal data, or personal information, means any information from an individual can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
Identity Data includes first name, last name, username or similar identifier, title, date of birth and gender. We may collect your passport details if you book a Scottish Adventure Event which takes place outside of the UK.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.
Usage Data includes information about how you use our website, products, and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our carefully selected third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).The only exception to this is in relation to limited health data requested when booking a SAC Travel Trip, which are governed by separate terms and conditions available at www.ScottishAdventure.org . We do not collect any information about criminal convictions and offences.
1.7. If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
1.8. How is your personal data collected?
We use different methods to collect data from and about you including through:
1.8.1. Information you give us
You may give us your Identity, Contact and Financial Data by filling in forms on our site or on our social media pages or profiles, or by corresponding with us by phone, email, in app or otherwise. This includes personal data you provide when you:
Apply for our products or services.
Create an account on our website or by downloading the Spond application
Subscribe to our service or publications.
Request marketing to be sent to you.
Enter a competition, promotion, or survey.
Give us some feedback; or
When you apply for a job position.
1.8.2. Information we collect about you.
With regard to each of your visits to our site we may automatically collect the following information: technical information e.g. about your browser or the device you use to access the site etc., information about your visit such as browsing actions and patterns, e.g. which website you clicked through to reach ours and lengths of visits to pages.
1.8.3. Information we receive from other sources.
We may receive personal data about you from various third parties and public sources as set out below:
Technical Data from the analytics providers (such as Google based outside the EU).
Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
Identity and Contact Data from selected business partners, data brokers or aggregators.
1.8.4. Use of personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract, we are about to enter into or have entered into with you and to provide you with the information, products and services that you request from us.
To provide you with information about other goods or services we offer that are like those that you have already purchased or enquired about.
To provide you, or carefully selected third parties to provide you, with information about goods or services we feel may interest you. We will only contact you by electronic means (email or SMS or PUSH notifications) with information about goods and services like those which were the subject of a previous sale or negotiations of sale to you).
Where we or a third party have a legitimate interest and your interests and fundamental rights do not override those interests.
To comply with a legal or regulatory obligation, including exchanging information with other companies and organisations for the purposes of fraud protection.
To administer, operate and improve our site and ensure it is presented in the most effective manner; as part of our efforts to keep our site safe and secure; to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
We may combine information we receive from other sources with information you give to us and information we collect about you and use it for the purposes set out above.
Where you opt out of receiving marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
1.9. Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.
2. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table above.
Internal Third Parties as set out in the Glossary.
External Third Parties as set out in the Glossary.
In the event that we sell or buy (or plan to sell or buy) any business or assets or seek investment from a third-party investor, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets, or investor, as the case may be. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party 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.
3. INTERNATIONAL TRANSFERS
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA working for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services.
Whenever 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:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see the European Commission: Adequacy of the protection of personal data in non-EU countries.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Please contact us if you would like further information on the specific mechanism used by us when transferring your personal data out of the EEA.
4. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
5. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we must keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
6. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
6.1. Request access to your personal data (commonly known as a "data subject access request").
This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
6.2. Request correction of the personal data that we hold about you.
This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
6.3. Request erasure of your personal data.
This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
6.4. Object to processing of your personal data where we are relying on a legitimate interest
If there is something about your situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, such as where we are obliged by law, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. An example of this may be where we have obligations to process your financial data for the purposes of complying with our tax obligations. Please note that if you already have an account with SAC, but complete a purchase via the guest checkout, we will be unable to modify your marketing preferences as we will not have the relevant identity information or authority to do so. Your marketing preferences can be amended by you at any time via your account settings, or when you receive further email communication from us.
6.5. Request restriction of processing of your personal data.
This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
6.6. Request the transfer of your personal data to you or to a third party.
We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
For further information on your individual rights, please visit https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/ . If you wish to exercise any of the rights set out above, please contact us.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
6.7. What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
6.8. Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
7.1. LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
7.2. THIRD PARTIES
7.2.1. Internal Third Parties
Other entities or brands managed by SA acting as joint controllers or processors.
7.2.2. External Third Parties
Service providers acting as processors based in Europe, USA, Hong Kong, Australia, New Zealand.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the same countries listed above who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who re quire reporting of processing activities in certain circumstances.
Other carefully selected third parties who provide services to SAC including (but not limited to): website applications, order processing, warehouse systems, customer services, file storage, courier and other shipping partners, event management, payment processing, communication applications, EPOS applications, shipping applications, marketing communications campaign management (which includes email campaign management tools), analytic tools, mapping tools and social media.