Colchester Phoenix Amateur Swimming Club understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, https://www.phoenixswim.club/ (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with the General Data Protection Regulation (GDPR).

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is deemed to occur upon your first use of Our Site. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

“Cookie” – means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out below;

“Cookie Law” – means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;

“personal data” – means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and

“Us/Our” – means Colchester Phoenix Amateur Swimming Club.

Information About Colchester Phoenix Amateur Swimming Club

Our website address is: https://www.phoenixswim.club/

Our Site is owned and operated by Colchester Phoenix Amateur Swimming Club, a Registered Charity registered in England under charity number 1053511.

We are regulated by the Charity Commision.

We are a member of Swim England.

What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

What is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers (e.g. your IP Address).

What Are My Rights?

Under the GDPR, you have the following rights, which we will always work to uphold:

  1. The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details provided at the end of this Privacy Policy.
  2. The right to access the personal data we hold about you. This is known as a “subject access request”. Details of how you can request this information can be found below in this Privacy Policy.
  3. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details provided at the end of this Privacy Policy to find out more.
  4. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details provided at the end of this Privacy Policy to find out more.
  5. The right to restrict (i.e. prevent) the processing of your personal data.
  6. The right to object to us using your personal data for a particular purpose or purposes.
  7. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
  8. Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided at the end of this Privacy Policy.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

What Data Do We Collect Via Our Site?

Depending upon your use of Our Site, we may collect some or all of the following personal and non-personal data (please also see the How Do You Use Cookies? section in this Privacy Policy on our use of Cookies and similar technologies and our Cookie Policy):

  • Name;
  • Email address;
  • Telephone number;
  • IP address;
  • Web browser type and version;
  • Operating system;
  • A list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;

What Data Do We Collect When You Register With Colchester Phoenix Amateur Swimming Club?

The only data we hold is he data that you supply to us during registration. This can include your name, address and email address. As well as details of any disabilities or medical conditions.

How Do You Use My Personal Data?

Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for the following purposes:

  • Communicating with you. This may include responding to emails, calls or comments from you.
  • Supplying you with information by email OR post that you have opted-in to (you may unsubscribe or opt-out at any time. To opt-out of subscriptions to blog posts by email you can click the unsubscribe link. You will no longer receive letters or club information via emails from us if/when you decide to leave Colchester Phoenix Amateur Swimming Club).
  • Analysing your use of Our Site and gathering feedback to enable me to continually improve Our Site and your user experience.
  • Tracking Swimming progress.
  • Club Communications.

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email AND/OR post with information, news, and offers about Colchester Phoenix Amateur Swimming Club. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

Third Parties (including Jetpack, Akismet, iThemes Security and Wordfence Security) whose content appears on Our Site may use third-party Cookies, as detailed below in the How Do You Use Cookies? section in this Privacy Policy. Please refer to the How Can I Disable Cookies? section in this Privacy Policy for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.

Security Logs – The IP address of visitors, user ID of logged in users, and username of login attempts are conditionally logged to check for malicious activity and to protect the site from specific kinds of attacks. Examples of conditions when logging occurs include login attempts, log out requests, requests for suspicious URLs, changes to site content, and password updates. This information is retained for 14 days.

When Comments are Left On Our Site What Personal Data Is Collected?

When visitors leave comments on Our Site we collect the data shown in the comments form (name, email address, and website URL), and also the visitor’s IP address and browser user agent string to help spam detection. Spam detection is run by Akismet which is owned by Automattic.

An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here.

Comments, along with the visitor’s name and profile picture if you have one, are displayed publicly on the blog posts when approved. The comment submission data is stored in the database of Our Site. This data is also emailed directly to the Colchester Phoenix Amateur Swimming Club gmail account – communications.phoenixswim@gmail.com. This notification email will include the submitter’s IP address, timestamp, name, email address, website, and message. The Gmail Privacy Policy is available here.

When You Fill In The Contact Forms On Our Site What Personal Data Is Collected?

When visitors fill in the Contact Us, Volunteering or Sponsor Us contact forms on Our Site we collect the data shown in the contact form (name, email address, and phone number if provided). We use contact forms provided by NinjaForms and the contact submission data supplied to us is stored in the database of Our Site. This data is also emailed directly to the Colchester Phoenix Amateur Swimming Club gmail account – communications.phoenixswim@gmail.com. This notification email will include the submitter’s contact details supplied to us. The Gmail Privacy Policy is available here.

How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

  • business needs that require documentation to be retained
  • Database backups of Our Site that sent to the Colchester Phoenix Amateur Swimming Club gmail account

for the lifetime of this website.

  • iThemes Security logs are retained for 14 days.

How and Where Do You Store or Transfer My Personal Data?

I will only store or transfer your personal data in the UK. This means that it will be fully protected under the GDPR.

Your personal data is stored upon Our Site’s database. If you leave a comment it will be shared to the Colchester Phoenix Amateur Swimming Club gmail account – communications.phoenixswim@gmail.com. Visitor demographics will be shared with the Jetpack and Askimet plugins (owned by Automattic).

Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to one important exception.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are] involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

To protect Our Site from attacks this site is scanned for potential malware and vulnerabilities by Sucuri’s SiteCheck. We do not send personal information to Sucuri; however, Sucuri could find personal information posted publicly (such as in comments) during their scan. For more details, please see Sucuri’s privacy policy.

Where We Send Your Personal Data

Visitor comments are checked through an automated spam detection service (Akismet). Analytics are collected by Jetpack. Emails and database backups are sent to the Colchester Phoenix Amateur Swimming Club Gmail account, please see the Gmail Privacy Policy.

Our Site is part of a network of sites that protect against distributed brute force attacks. To enable this protection, the IP address of visitors attempting to log into the site is shared with a service provided by ithemes.com. For privacy policy details, please see the iThemes Privacy Policy.

How We Protect Your Personal Data

In order to keep your data as safe as possible, we use secure passwords to access any place your data may be stored. Any laptops and mobile phones used are password protected.

Within WordPress itself, we have security plugins installed (Wordfence and iThemes), which inform us of any potential risks to security, including any attempts to log into WordPress.

How Can I Control My Personal Data?

In addition to your rights under the GDPR, found in the What Are My Rights? Section of this Privacy Policy, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data.

You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

Can I Withhold Information?

You may access Our Site without providing any personal data at all.

You may restrict our use of Cookies. For more information, see the How Can I Disable Cookies? section in this Privacy Policy and my Cookie Policy.

How Can I Access My Personal Data/Make a Subject Access Request?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses using the details provided at the end of this Privacy Policy.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover my administrative costs in responding.

We will respond to your subject access request within one month and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of my progress.

How Do You Use Cookies?

Our Site Uses cookies in the following way:

Commenting – If you decide to leave a comment on Our Site you may opt-in to saving your name, email address and website. This information is held in the cookies. This is for your convenience so that you do not have to fill in your details again if you decide to leave another comment in the future.

Our Site also uses the following plugins and third-party systems:

  • Akismet (an anti-spam plugin provided by Automattic) for the purpose of automatically capturing spam comments.
  • Jetpack (an analytics service also provided by Automattic) for the purpose of user experience and gathering website analytics. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling us to better understand how Our Site is used. You can find out more in Jetpack’s Cookie Policy
  • Wordfence Security (a security service provided by Wordfence) for the purpose of checking Our Sites security. You can find the Wordfence Privacy Policy here.
  • iThemes Security (a security service provided by iThemes) for the purpose of checking Our Sites security. You can find the iThemes Privacy Policy here.

How Can I Disable Cookies?

Before Cookies are placed on your computer or device, you will be shown a pop-up requesting your consent to Enable All Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You will be given the option to Disable the Strictly Necessary Cookies and/or the 3rd Party Cookies. If you wish to disable the placing of Cookies certain features of Our Site may not function fully or as intended.

The analytics service(s) used by Our Site use(s) Cookies to gather the required information. You do not have to allow us to use these Cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable us to better understand how Our Site is used.

In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. If you do not wish for Our Site to place Cookies on your device we have provided links to tutorials for disabling Cookies on for major browsers below:

You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently.

Embedded content from other websites

Articles on Our Site may include embedded content (e.g. videos from YouTube, images, articles, etc.). Embedded content from other websites behave in the exact same way as if the visitor has visited the original website they are placed on. These websites (e.g. YouTube) may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracing your interaction with the embedded content if you have an account and are logged in to that website.

How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following:

Email address: communications.phoenixswim@gmail.com.

Changes to this Privacy Policy

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.

THIS PRIVACY POLICY WAS UPDATED ON THE 25TH OF MAY 2018