Caversham Park Village Association Privacy Policy

Overview
This Privacy Policy explains how we use any personal information you provide to the Association when you use our services in our Centre, our website and any contact you have with our Staff.
We respect your right to privacy and are committed to maintaining it. We only collect, store and process your personal information in accordance with the relevant laws and regulations.
By accessing, browsing or otherwise using our website you confirm that you have read and understood this Privacy Policy. Please ensure you have read it carefully, and particularly the section detailing your rights in relation to the personal information that we collect about you.

Definitions
“the Association” or “We” means Caversham Park Village Association or other subsidiaries or sections within the Association as appropriate. Sections are the groups which operate as part of the Association’s constitutional aims. Our registered address and the address for any correspondence is The Secretary, Caversham Park Village Association, The Milestone Centre, Northbrook Road, Caversham, Reading, RG4 6PF
“Staff” means any member of staff employed directly by the Association, any Trustee, any volunteer working for the Association or any member of a Section committee.

Personal information that we collect from you
This will depend upon the services you are using:
• Name and Title
• Home, Billing and Delivery Address(es)
• Email Address(es) (home, mobile, work – customer dependant)
• Phone Number(s) (home, mobile, work – customer dependant)
• Membership information
• Account Password and Login details
• Date of Birth
• Gender
• Details of your interactions with our Staff
• Your images on CCTV
• IP Address
• Device information
• Website / Browsing History, including location data

We collect personal information when you:
• Purchase membership over the phone or through our website
• Subscribe to our newsletters
• Engage with us via social media
• Register or use our Wi-FI
• Enter our competitions, prize draws or promotions
• Communicate with our Staff or contact us for any reason, e.g. membership queries, complaints, website issues via phone, email, in person and postal correspondence
• Complete a form, such as for a transaction or employment purpose or for accident or incidents in our premises or for other health and safety or security purposes
• Use our buildings which usually have CCTV systems operated for the security of our members, visitors and our Staff
• Browse the website
• Contact us using any contact form on our website

Personal information that we collect from Third Parties
If you link your Google, Facebook, Twitter, Instagram or LinkedIn accounts or any accounts from other third party services to the Association then we also receive information from those accounts to the extent you’ve agreed to this as part of your settings and that third party’s privacy policy.

How we use the information about you
We use your personal information in a number of different ways, depending on the type of information provided. You do not have to provide this personal information but if you don’t, you may not be able to purchase membership, goods or services from us, we may not be able to provide membership or certain services and you are unlikely to receive our optimal overall member experience.

Your name, contact details and date of birth
Used to administer your membership. This is to maintain an unambiguous register of members and ensuring that anyone who applies for membership (whether by new application or renewal) is entitled to any discounts in membership rates or other fees as set down by the eligibility rules of those discounts.
To sign you up to our email newsletters and marketing information. You consent to receive our email newsletters and other marketing information if you use our Wi-Fi service or express a wish to do so by ticking the relevant box on membership forms or other documents. You can opt out of these at any time by clicking the link at the bottom of any such communications or by contacting The Secretary by post or email.
In the detection and prevention of fraud or other crimes. The Association has legitimate interest in protecting itself from fraud.
To be able to return any lost items to you or record any incidents or accidents in our premises. You have legitimate interest in providing this information to enable the Association to manage such incidents.
To invite you to complete a survey where you have completed a transaction or otherwise interacted with the Association. We may use a third party to collect and transmit this information. The Association has a legitimate interest in selling membership, its products and improving our member and visitor experience. We don’t need your consent to send you these communications, but they will not include any promotional content unless you have opted-in to receive marketing from us. We use responses from surveys to monitor and improve the quality of our products and services and your overall customer experience for the future.
To send you marketing promotions, offers, competitions and events by email, post, phone and SMS for the Association’s membership, goods and services (subject to your preferences). We use a third party, Mailchimp, to help us manage and send out emails.
To process and manage your booking or appointment, for example an appointment to see a member of staff or hire of a room or provision of a service. We must do this to perform our contract with you as well as setting up the appointment or booking and arrange this with you.
To combine aggregated information about our members (that doesn’t identify those members) to help us track performance and improve the services we offer. The Association ha a legitimate interest in analysing this information to improve member and visitor experience.
To send you service emails or communications required by law to update you about any changes to our membership, goods and services and any information required by law relating to your membership or booking.
Your payment details
To fulfil your order (such as purchase of membership or other product or service, booking of a room hire), i.e. taking payment, updating you regarding status of your order and providing the product or service to you as well as managing any issue during fulfilment. We have to do this to perform our contact with you. We do not store payment details and use third party merchant service providers such as (but not limited to) Lloyds Cardnet and PayPal to process these transactions on our behalf.
Your login and password
To verify your identity when you access any account you hold with us. We have a legitimate interest in verifying you are who you say you are and to ensure that products, services and memberships are provided to the correct person.
Device information when using our Wi-Fi
We do this to allow you to use the Wi-Fi in our buildings and allow automatic reconnection upon your return. We use Wireless Social to provide our Wi-Fi. We have to do this to provide this service to you. We will also ask you to consent to receiving email marketing through this registration.
Your image on CCTV
To ensure the safety of our members, visitors and staff and the prevention and detection of anti-social or unlawful acts and recover any loss or damages caused by members, visitors, staff or perpetrators of unlawful acts. The Association has a legitimate interest in protecting itself from crime and providing a safe environment for its staff, members and visitors.
General
In some circumstances we also need to provide your information to enable us to comply with legal or regulatory requirements, such as criminal or whistleblowing investigations. We will do this where the Association has a legal obligation to provide such personal information to the authorities and regulators to comply with the law.
We may also use publicly available information (such as from the electoral register) to ensure that our database is kept accurate and relevant. The Association has a legitimate interest to ensure our database is kept up to date.

Personal information shared with Third Parties
In order to provide our services to you, we share your data with professional services providers who provide electronic systems to us such as general office administration, accounting, marketing, CCTV and membership administration systems.
The Association only transfers your personal information to those third parties where we can be sure that we can protect your privacy and your rights. We only transfer the information which is needed to provide membership, goods and services and if we stop using a third party, we require them to remove or anonymise your information. We do not, and will not, sell your personal data to any third party.

How long we store your information for
We will hold on to your information for as long as you have a relationship with the Association (such as membership) or as long as is needed for us to be able to provide membership or the relevant goods or services to you. The Association’s general retention policy is to retain information for 7 years.
In some circumstances, such as to meet our legal or regulatory obligations, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions, we may hold on to your personal information after we’ve finished providing services to you, or for longer than our general retention policy.

Your rights over your information
You have the right to access your data, request us to erase the data if you believe we no longer have the right to process it, or amend your data if it is incomplete or inaccurate, or restrict our processing of your data if you believe it to be inaccurate.
If you wish to request that we correct, delete or restrict processing of any personal information, you should write to The Secretary at our registered address or by email to secretary@cpva.org.uk. In all case, you must provide a copy of a valid photographic identification (such as a passport or driving licence) so that we can be sure of your identity and the information we hold about you.
If we agree that the information is inaccurate or that processing should be restricted, we will make the appropriate corrections, deletions or restrictions as soon as is practicable any in any case within one month. If we do not agree that the information is inaccurate, we will let you know.
If you are receiving marketing information by email which you no longer wish to receive, the easiest way to request us to stop this is to use the “unsubscribe” link at the bottom of the email and follow the instructions to cancel your subscription to that marketing information. Alternatively, you may write to The Secretary at our registered address or email secretary@cpva.org.uk.
If you wish to make a complaint about the use of your information, please write to The Secretary at our registered address or email secretary@cpva.org.uk. You also have the right to lodge a complaint with the UK data protection regulator, the Information Commissioner’s Office. For contact details, please refer to the Information Commissioner’s Office website.

Special categories of information
Some types of data fall within categories of data which have additional protection under the GDPR such as health, ethnic origin, racial or sexual orientation. We do not collect or store any such data. All types of data is detailed earlier in this Privacy Policy.

How to contact us
You can contact us by writing to The Secretary, Caversham Park Village Association, Milestone Centre, Northbrook Road, Caversham, Reading, RG4 6PF. Any email correspondence relating to this policy may be sent to secretary@cpva.org.uk.

Changes to this privacy policy
This privacy policy will be updated from time to time in line with changes to the way we handle and store your information.
This policy was last updated on 17 December 2019 to clarify the third party data processors.