You entrust Getafix with your important information and we take our responsibilities seriously. We are committed to protecting and respecting your personal data, always treating you as we would want others to treat us.
- What is the purpose of this Privacy Statement?
This Privacy Statement explains how Getafix looks after your personal data when we provide our products and services, in accordance with legislation, including the General Data Protection Regulation. We also explain what your rights are.
By providing your personal data you acknowledge that we will only use it in accordance with this Privacy Statement.
When we refer to Getafix we mean any part of Getafix Ltd operations providing your products and/or services, including courses, expeditions, accommodation, kit sales or technical consultancy.
- How will we use your personal data?
Data protection laws require that the personal data we hold about you must be:
- used lawfully, fairly and in a transparent way;
- collected only for valid purposes that we have clearly explained to you, and not used in a way that is incompatible with those purposes;
- relevant to the purposes we have told you about and limited only to those purposes;
- accurate and kept up to date;
- kept secure and confidential;
- kept only as long as necessary for the purposes we told you about.
- How do we ensure the privacy of your personal data?
We have put in place appropriately secure 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, NGBs and other third parties who have a business need to use your data. They will only process your personal data on our instructions and are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
As part of our data security measures we ensure that we train our employees and have appropriate data protection policies in place to support our compliance.
- What kind of data may we hold on you?
Personal data means any information about an individual from which a person can be identified.
In order to provide our products and services we may collect the following types of personal data about you:
- contact details such as name, address(es), telephone number(s), email address(es), next of kin;
- any relevant medical information, including medications needed, mental health issues etc;
- identification information such as: signature, date of birth, passport number etc
- any information necessary to the trip, course or qualification you are undertaking
- images: photographs and videos taken while you are participating in a Getafix service.
- How may we collect your personal data?
We may collect personal data from you in a number of ways, including:
- information you give us: You may choose to provide us with your personal data: o by corresponding with us by telephone, email, letter or other means;
by booking yourself onto a Getafix service through our website;
by filling in booking or other forms provided by Getafix or our governing bodies; o by sharing photographs or film with us, or by members of the Getafix team taking photographs or film during courses.
- information we receive from other sources:
- We may receive information from third parties, such as your employer or National Governing Bodies.
- How will we use your personal data?
We only use your personal data when the law allows us to. Most commonly we will use your personal data to provide your product or service and to comply with our legal obligations. We set out the main reasons why we process your personal data and the applicable circumstances below:
- To perform the contract we have entered into with you, be it de facto or actual.
- To comply with a legal obligation, for example:
- where we are required to use your personal data and maintain records of our dealings with you;
- to respond to complaints and data subject requests (see section 11 below); and
- to investigate, prevent or detect crime.
- Where it is necessary for our legitimate interests (or those of a third party) provided your interests and fundamental rights do not override those interests, for example:
- to establish, exercise or defend our legal rights, where we are faced with any legal claims or where we want to pursue legal claims ourselves;
- to respond to and manage ad hoc enquiries and complaints; o to provide and improve customer support;
- for accounting, auditing purposes and corporate governance purposes; and
- to provide management information to enable us to monitor our performance and understand our business, to maintain our business records, to manage our financial position and business capability, to receive professional advice, to improve our products and services and for training purposes.
- Where we have obtained your explicit written consent to do so, for example: o to process your sensitive personal data;
to provide you with marketing services, including information about Getafix or its products and services, and related information, which may be provided by other Getafix group companies;
On rare occasions we may also use your personal data where we need to protect your interests (or someone else’s interests) or where it is needed in the public interest, for example for the investigation, detection and prevention of crime.
- How will we use sensitive personal data?
We may process special or sensitive personal data, for example medical information, only where it is needed for legitimate business purposes in the supply of Getafix services.
- If you choose not to provide or update personal data
If you do not provide certain information requested we may not be able to provide your Getafix product or services and we may not be able to comply with our legal obligations.
Please note that we may process your personal data without your knowledge or consent where this is required or permitted by the law.
- Who may we share your personal data with?
We may share your data with third parties where this is a necessary part of our contract with you, for example National Governing Bodies for the purposes of you obtaining a qualification. We will always require those third parties to respect the security of your data and to treat it in accordance with the law and only for the purpose for which we obtained it.
- How long will we use your information for?
We will keep your information for as long as you are a customer of Getafix, and for the purposes of processing of National Governing Body qualifications and suchlike. Thereafter we may keep your data for up to 5 years to enable us to respond to any questions or complaints and to maintain records, where we are required to do so. We may keep your data for longer than 5 years if we cannot delete it for legal, regulatory or technical reasons.
To determine the appropriate retention period we consider the type of contract you have with us, the quantity, 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, whether we can achieve those purposes through any other means and any applicable legal requirements to retain such personal data for prescribed periods. Where we retain your data we will make sure your privacy is protected and only use it for the purposes described above.
- Your rights in connection with personal data
You can ask us to do certain things with your personal data such as provide a copy of it, correct it or even delete it. There may be occasions where we cannot comply with a request and we will tell you if this is the case and our reasons. This will usually be for legal or regulatory reasons.
Under certain circumstances you have the right to:
- Request access to your personal data ("data subject access request”). This enables you to confirm whether we process your personal data and to receive a copy of the personal data we are processing and certain information about how we use your personal data.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request the erasure of your personal data. You can ask us to delete or remove personal data where the processing is no longer necessary for the original purpose or where you withdrew your consent, or the processing is unlawful or your personal data must be erased to comply with the law. However in some cases, if we have another legal basis or legitimate interest for processing your personal data, we may not be able to comply. We will tell you if this is the case.
- Request the restriction of processing of your personal data. You can ask us to restrict the processing of personal data where you think the personal data we hold is inaccurate until we can verify its accuracy, or you believe we no longer need to process your personal data (but you do not want it erased), or you wish processing to be restricted pending confirmation that our processing is based on our overriding legitimate interest.
- Object to the processing of your personal data. You have the right to object to us processing your personal data where we are doing so;
based on our legitimate interest (for the purposes described in this Privacy Statement) unless we can demonstrate compelling grounds as to why the processing should continue in accordance with Data Protection laws;
for direct marketing purposes.
Please note that by exercising this right it is possible that Getafix will no longer be able to continue to provide its products or services or administer its contract with you.
- Right to withdraw consent. If you have provided your consent to the processing of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. This would not affect the validity of the processing prior to such date. Once we have received notification that you havewithdrawn your consent, we will no longer process your information for the purpose(s) you originally agreed to, unless we have another legitimate basis for doing so in law.
Please note that by exercising this right it is possible that Getafix will no longer be able to continue to provide our products or services or administer our contract with you.
- How do you exercise your rights?
You can make a request by contacting Getafix via a number of ways set out below. However, we will always ask you to confirm your request in writing.
You will not usually have to pay a fee to exercise any of your rights. However, we may charge a reasonable administration fee, or not comply with the request, if a request is clearly unfounded, excessive or repetitive so as to be deemed vexatious.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
- What if you have questions about this Privacy Statement or the way Getafix uses your personal data?
If you wish to exercise any of your rights, or you have any questions about this Privacy Statement, how we handle your personal data or if you wish to make a complaint, please email firstname.lastname@example.org or write to Getafix Ltd, Tyn Yr Ardd, Carrog, Corwen, Denbighshire, LL21 9LB
- Right to complain
You also have the right to make a complaint at any time to the ICO (Information Commissioners Office), the UK supervisory authority for Data Protection issues. Contact details for the ICO can be found at https://ico.org.uk/.
- Changes to this Privacy Statement
We reserve the right to update this Privacy Statement at any time, and we will update the copy on our website whenever we do so.