PRIVACY POLICY.

1. Who are we?

This website ('Site') is operated by Caddi Group Limited, a company registered in England and Wales under registration number 13142645 ('Caddi Club', 'we', 'us' and/or 'our'). You can contact us as indicated under the 'Contact' section on our website.

The data controller responsible for your personal data is the Caddi Group Limited, with whom you contract as a customer, member, or membership applicant.

2. What is this privacy policy for?

This privacy policy ('Privacy Policy') applies to personal data that we collect from you as a user of this Site or as a membership applicant, member, or customer ('you' or 'your' being interpreted accordingly). It provides information on what personal data we collect, why we collect the personal data, how it is used and the lawful basis on which your personal data is processed, and what your rights are under the applicable data protection and privacy laws, including the General Data Protection Regulation ('GDPR') which became applicable to us, and you, as of 25 May 2018.

'Personal data' as used in this Privacy Policy means any information that relates to you from which you can be identified.

By using our Site or submitting your personal data you are taken to accept the terms of this Privacy Policy, so please read it carefully.

3. The personal data we collect.

We collect the following personal data about you:

Membership Application

The personal details you provide when submitting a membership application either online or in person through our hosting partner Glofox, and when you register through the Site. This includes your name, address, email address; business address and phone number; gender and date of birth; country; a picture of yourself; information about your work and other information that you elect to provide to support your application and other information that you elect to disclose in your user profile on the Site. We also collect information about your debit/credit card and bank account information provided by you to our payment service providers. We require this information for the purpose of recording and processing your membership application (and administering your membership). For further details, please also refer to the section below headed 'Payment information'.

Reservation Information

Guest information, such as your first and last name, email address, billing and payment information (for further details, please also refer to the section below headed 'Payment information'). Personal data collected in relation to reservations such as bay bookings will be processed in accordance with a privacy policy provided at the time of requesting a reservation. Please ensure that you read our privacy notice on the reservation website that we may provide to you when we collect, or process, your personal data.

Site and Caddi Club Third-Party Digital Channels e.g. Caddi Club App and Glofox.

We collect information regarding your use of the Site and our third party Digital Channels, e.g. how you engage with the Site and our Digital Channels, including how you interact with content we show to you, videos you watch, how you use and interact with our Caddi Club App, and what Caddi Club sites you visit. We also infer your preferences for the purpose of personalising content. We will also process your personal data in order to tell you about our existing Caddi Club services and opportunities and any new Caddi Club services and opportunities.

Location Information

We may also use GPS technology to determine your current location. Some of our location-enabled services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can enable or disable location services when you use our Site or Digital Channels at any time through your mobile device settings.

Capacity Planning and Tracing Information

We also collect information regarding your visits to our Caddi Club sites for capacity planning purposes and to comply with government guidelines, regulations and mandates.

Other Information

Personal details you choose to give when corresponding with us by phone or email; participating in user/customer/member surveys, or otherwise visiting and interacting with this Site or any other websites associated with this Site; and personal data that you provide to us when you visit one of our clubs or other premises. We can also combine personal data that you provide to us with other information we collect about you when you make a reservation through third-party services, such as online bay bookings necessary to process your requests.

4. Automatically collected personal data

Log data

When you visit our Site, our servers record information ('log data'), including information that your browser automatically sends whenever you visit the Site. This log data includes your Internet Protocol ('IP') address (from which we understand the country you are connecting from at the time you visit the Site), browser type and settings, the date and time of your request.

Our Site uses cookies (small text files placed on your device) and similar technologies to distinguish you from other users. This is to provide you with a good user experience when you browse our Site, and allows us to improve its features. For detailed information on the cookies and similar technologies we use, please see our Cookie Policy.

5. How we use your personal data

We use your personal data in the following ways:

To acknowledge, confirm and deal with your membership application (and where necessary put you on our waiting list). Such use of your data is necessary in order to implement your request to become a member.

Where you are a member, we use it to provide you with membership services, administer your membership account and contact you regarding your use of the services. Such use is necessary to respond to, or implement, your request, and for the performance of the contract between you and us.

To complete and fulfil your booking, to process your payment, and provide you with related customer service, including sending confirmations or pre-arrival messages, assist you with meetings, events or celebrations. Such use is necessary for the performance of the contract between you and us.

To contact you in connection with user/customer/member surveys and use any information you choose to submit in response (provided that you gave us your consent to being contacted in this way at the time you provided us with the personal data).

To personalise the content you receive and provide you with tailored content that will be of interest to you.

To communicate with you about your visit to our Site.

To notify you about changes to our service, provide you with user support and enforce our terms, conditions and policies.

Caddi Club may provide you, or permit selected third-party service providers to provide you, with information about goods or services, events and other promotions we feel may interest you as a member or membership applicant. We (or such third-party providers) will contact you by email only with your consent, which was given at the time you provided us with the personal data.

In order to comply with our legal obligations, we use your data to help us detect abuse, fraud and illegal activity on the Site.

As necessary for certain legitimate business interests, which include the following:

Where we are asked to deal with any enquiries or complaints you make.
To administer our Site, to better understand how visitors interact with our websites and ensure that our Site is presented in the most effective manner for you and for your computer/device.
To conduct analytics to inform our marketing strategy and that of our Caddi Club group and enable us to enhance and personalise the experience we offer to our members, customers and our communications. This includes creating customer or member profiles to enable personalised direct marketing communications.
To enable our Caddi Club App to function if you choose to use this function.
To improve, promote and develop the Site and promote popular conversations, programs and campaigns on the Site.
To provide postal communications which we think will be of interest to you.
If you ask us to delete your data or to be removed from our marketing lists and we are required to fulfil your request, to keep basic data to identify you and prevent further unwanted processing.
To share personal data among the Caddi Club group for administrative purposes; for providing membership services; and in relation to our sales and marketing activities.
We may anonymise, aggregate and de-identify the data that we collect and use such anonymised, aggregated and de-identified data for our own internal business purposes, including sharing it with our current and prospective members, business partners, agents and other third parties for commercial, statistical and market research purposes, for example to allow those parties to analyse patterns among groups of people, and conducting research on demographics, interests and behaviour.
For internal business/technical operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes and as part of our efforts to keep our Site, network and information systems secure.
To contact you in case you may have been in contact with a person who has or is displaying symptoms of COVID-19 and to comply with government guidelines, regulations and mandates.
To (a) comply with legal obligations, (b) respond to requests from competent authorities; (c) enforce Caddi Club rules; (d) protect our operations or those of any of the Caddi Club group; (e) protect our rights, safety or property, and/or that of the Caddi Club Group, you or others; and (f) enforcing or defending legal rights or preventing damage.

We may use your personal data for other purposes, which you consented to at the time of providing your data including but not limited to provide you with location-based services (where those services are available in your jurisdiction, and you choose to share your precise location with us).

As used in this Privacy Policy, 'legitimate interests' means the interests of Caddi Club in conducting and managing our organisation. When we process your personal data for our legitimate interests, we make sure to consider and balance any potential impact on you, and your rights under data protection laws. Our legitimate interests do not automatically override your interests. We will not use your personal data for activities where our interests are overridden by the impact on you, unless we have your consent, or those activities are otherwise required or permitted to by law. You have the right to object at any time to processing of your personal data that is based on our legitimate interests, on grounds relating to your situation (for more information on your rights, please see 'Your personal data protection rights' section below).

6. Disclosure of your information.

We share your personal data with third parties in the following situations:

Service providers: Caddi Club, like many businesses, sometimes hires selected third parties who act on its behalf to support its operations, such as (i) card processing or payment services (see the section below headed 'Payment Information'); (ii) credit reference agencies to protect against possible fraud; (iii) IT suppliers and contractors (e.g. data hosting providers or delivery partners) as necessary to provide IT support and enable us to provide membership services and other goods/services available on this Site or to members; (iv) web analytics providers; (v) providers of digital advertising services; and (vi) providers of CRM, marketing and sales software solutions. Pursuant to our instructions, these parties may access, process or store your personal data in the course of performing their duties to us and solely in order to perform the services we have hired them to provide.

Business transfers: if we sell our business or our company assets are acquired by a third party, personal data held by us about our members, membership applicants or customers may be one of the transferred assets.

Administrative and legal reasons: if we need to disclose your personal data (i) to comply with a legal obligation and/or judicial or regulatory proceedings, a court order or other legal process requirements from public health organisations, local councils and governmental, federal and state authorities. (ii) to enforce our Terms & Conditions, Caddi Club rules or other applicable contract terms that you are subject to or (iii) to protect us, our members, membership applicants, or contractors against loss or damage. This may include (without limit) exchanging information with the police, courts or law enforcement organisations.

7. Payment information.

Any credit/debit card payments and other payments you make through Caddi Club or whilst on Site will be processed by our third-party payment providers. The payment data you submit will be securely stored and encrypted by our payment service providers using up-to-date industry standards.

We may arrange that card or payment data you submit in support of a membership application or subscription fee is stored for the purpose of processing your application, initiating your membership and collecting your subscription fees if your initial application is successful. If you are put on to a membership waiting list, please note that this data may be stored for later use to initiate your membership and subscription.

We store and use this card or payment information for the purpose of processing any future

payments that you make as a member for additional goods and services. We will store this data in

accordance with our legal obligations under applicable law, and only for so long as legally permitted.

You may choose to opt-out of us holding your card or payment data, although this means that you will need to re-supply us with card/payment details to initiate your membership subscription fee, or for the purpose of making any future purchases.

8. Personal data transfers.

Your personal data will be transferred to, and stored in, countries other than the country in which the information was originally collected, including the United States and other destinations outside the European Economic Area ('EEA'), to our service providers.

Please note that the countries concerned may not provide the same legal standards for the protection of your personal data that you have in the United Kingdom or EEA. Where we transfer your personal data to countries outside of the EEA, we will take all steps to ensure that your personal data will continue to be protected. We will implement appropriate safeguards for the transfer of personal data to our service providers in accordance with the applicable law, such as relying on our service or implementing standard contractual clauses for data transfers. If you would like to receive more information on the safeguards that we implement, including copies of relevant data transfer contracts, please contact us as indicated below.

9. Security.

Where we have given you (or where you have chosen) a password or login that enables you to access certain restricted parts of our Site, you are responsible for doing everything you reasonably can to keep these details secret. You must not share your password or login details with anyone else.

Unfortunately, the transmission of information over the internet or public communications networks can never be completely secure. We will take appropriate technical and organisational security measures to protect the personal data that you submit to us against unauthorised/unlawful access or loss, destruction or damage, although we cannot 100 percent guarantee the security of personal data that you provide to us online.

10. Personal data retention.

We will keep your personal data only for as long as is reasonably necessary for the purposes outlined in this Privacy Policy, or for the duration required by any legal, regulatory, accounting or reporting requirements, whichever is longer. In particular, we retain membership records for six years after expiration or termination of your membership. We retain information submitted through the Site and the other websites we operate for two years following account closure or contact with you, as applicable. When you consent to receive marketing communications, we will keep your data until you unsubscribe.

To determine the appropriate retention period for your personal data, we consider the amount, nature, and sensitivity of the personal data, the purposes for which we process your personal data, applicable legal requirements or operational retention needs, and whether we can achieve those purposes through other means.

Upon expiry of the applicable retention period we will securely destroy your personal data in accordance with applicable laws and regulations. In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case it is no longer personal data.

11. Your personal data protection right.

Certain applicable data protection laws give you specific rights in relation to your personal data. In particular, if the processing of your personal data is subject to the GDPR, you have the following rights in relation to your personal data:

Right of access: If you ask us, we will confirm whether we are processing your personal data and, if so, provide you with a copy of that personal data along with certain other details such as the purpose of the data processing. If you require additional copies, we may need to charge a reasonable fee.

Right to rectification: If your personal data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we shared your personal data with others, we will tell them about the correction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal data so you can contact them directly.

Right to erasure: You may ask us to delete or remove your personal data, such as where our legal basis for the processing is your consent and you withdraw consent. If we shared your data with others, we will tell them about the erasure where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal data with so you can contact them directly. We may continue processing personal data where this is necessary for a legitimate interest in doing so, as described in this Privacy Policy.

Right to restrict processing: You may ask us to restrict or 'block' the processing of your personal data in certain circumstances, such as where you contest the accuracy of the personal data or object to us processing it. We will tell you before we lift any restriction on processing. If we shared your personal data with others, we will tell them about the restriction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal data so you can contact them directly.

Right to data portability: You have the right to obtain your personal data from us that you consented to give us or that was provided to us as necessary in connection with our contract with you. We will provide you with your personal data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.

Right to object: You may ask us at any time to stop processing your personal data, and we will do so if:

We are relying on a legitimate interest to process your personal data — unless we demonstrate compelling legitimate grounds for the processing.
We are processing your personal data for direct marketing.

Right to withdraw consent: If we rely on your consent to process your personal data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing of your data before we received notice that you wished to withdraw your consent.

Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we handled your personal data, you can report it to UK data protection authority, the Information Commissioner's Office (ICO), or, as the case may be, any other competent data protection authority of an EU member state that is authorised to hear those concerns. You may find EU Data Protection Authorities' contact information at https://edpb.europa.eu/about-edpb/board/members_en.