Privacy Policy

Whiteadder Watersports Trust understands that your privacy is important to you and that you care about how your personal details are used and shared online. We respect and value the privacy of everyone who visits this website, www.whiteadderwatersports.co.uk (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our 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.

1. Definitions and Interpretation 

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

“Account”

means an account required to access and/or use certain areas and features of Our Site;

“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 in section 13, 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 Data Protection Act 1998 and EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and

2.          “We/Us/Our” means Whiteadder Watersports Trust, a Scottish Charity No. SC050575 whose registered address is 18/5 James Street, Portobello, Edinburgh. EH15 2DW and which operates from Whiteadder Watersports Centre, Whiteadder Reservoir

2.            Information About Us

2.1         Our Website is owned by Us and operated by Us in conjunction with Ionos Systems

2.3         Our Data Protection Officer is Ian Maxwell Blinkhorn and can be contacted by email at whiteadderad2022@gmail.com by telephone on 01361 610160, or by post at Whiteadder Whiteadder Watersports 18/5 James Street, Portobello, Edinburgh. EH15 2DW.

3.            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 such other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

4.            Your Rights

4.1         As a data subject of Ours, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:

4.1.1      The right to be informed about Our collection and use of personal data;

4.1.2      The right of access to the personal data We hold about you (see section 12);

4.1.3      The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14);

4.1.4      The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 14);

4.1.5      The right to restrict (i.e. prevent) the processing of your personal data;

4.1.6      The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);

4.1.7      The right to object to Us using your personal data for particular purposes; and

4.1.8      Rights with respect to automated decision-making and profiling.

4.2         If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to
lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.

4.3         For further information about your rights, please contact the Information Commissioner’s Office https://ico.org.uk or your local Citizens Advice Bureau.

5.            What Data Do We Collect?

Depending upon your use of Our Site, We may collect some or all of the following personal and non-personal data (please also see section 13 on Our use of Cookies and similar technologies and Our Cookie Policy):

5.1         name;

5.2         date of birth;

5.3         gender;

5.4         business/company/school name;

5.5         job title;

5.6         profession;

5.7         contact information such as email addresses and telephone numbers;

5.8         demographic information such as post code, preferences and interests;

5.9         financial information such as credit/debit card numbers.

5.10      Watersports experience

5.11      Medical information 

6.            How Do We Use Your Data?

6.1         All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the Data Protection Act 1998 and   
GDPR at all times. For more details on security see section 7, below.

6.2         Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it
is in Our legitimate interests. Specifically, We may use your data for the following purposes:

6.2.1      Providing and managing your Account/booking;

6.2.2      Providing and managing your access to Our Site;

6.2.3      Personalising and tailoring your experience on Our Site;

6.2.4      Supplying Our products or services to you (please note that We require your personal data in order to enter into a contract with you);

6.2.5      Personalising and tailoring Our products or services for you;

6.2.6      Replying to emails from you;

6.2.7      Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by emailing whiteadderad2022@gmail.com;

6.2.8      Market research and customer satisfaction purposes;

6.2.9      Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience.

6.3         With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email and/or telephone and/or post and/or text with information, news and offers on Our products
or services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the Data Protection Act 1998 and GDPR and
the Privacy and Electronic Communications (EC Directive) Regulations 2003, as applicable.

6.4         You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.

6.5         We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):

6.5.1      On successful completion of your course or stay with Us your name, certificate number details and the date of issue will be stored for up to 7 years as recommended by the RYA. This information allows Us to verify or replace certificates if required. If you do not wish your details to be stored neither We nor the RYA will be able to replace or verify your certificate in the future.

6.5.2      For those who have subscribed to receive marketing information We will keep your details unless or until you withdraw your permission. This can be done at any time by contacting whiteadderad2022@gmail.com

7.            How and Where Do We Store Your Data?

7.1         We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.

7.2         Your data will only be stored in the [UK] or [within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein).

7.3         Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.

7.4         Steps We take to secure and protect your data include: 

7.4.1      A secure online database and booking system; and

7.4.2      Secure online storage of course information.

7.4.3      Secure storage for archived information for up to 7 years.

8.            Do We Share Your Data?

8.1         Subject to section 8.2, We will not share any of your data with any third parties for any purposes, although in certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for
example, where We are involved in legal proceedings, where We are complying with legal obligations, a court order, or a governmental authority.

8.2         We may share your data with other companies in Our group for marketing and administrative purposes.

8.3         We may sometimes contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third
parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our
obligations, and the obligations of the third party under the law.

8.4         We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any
anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used
within the bounds of the law.

8.5         The third-party data processors used by Us and listed below are all within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where We transfer any personal data
outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the Data Protection Act 1998 or GDPR including:

8.5.1     We use Mailchimp to send e-newsletters on Our behalf, We gather statistics around the opening and clicks using industry standard technologies to Us to monitor and improve our e-newsletter updates.  More information can be found on
Mailchimp’s privacy notice;

8.5.2     On successful completion of your RYA Instructor training, Powerboat Level 2 or to register you for the RYA Safe and Fun Safeguarding course your name, contact details, date of birth, certificate number and date of issue will be shared with
the RYA through a secure web portal on www.rya.org.uk. The data will be stored on the RYA’s central database. This information allows the RYA to record your qualification, to update any records they may hold for you, and to verify or replace your certificate if required. For further information on how the RYA will deal with your data, please see the RYA’s privacy policy at www.rya.org.uk/go/privacy.

8.5.3     Our online booking system We use has been developed by EOLA and all information is held securely online.  For further information on how information is stored with EOLA, please see their privacy notice at www.eola.co.uk

8.6         In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court
              order, or a governmental authority.

9.            How Can You Control Your Data?

9.1         In addition to your rights under the GDPR, set out in section 4, when you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details and by managing your Account).

9.2         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 receive.

10.         Your Right to Withhold Information

10.1      You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.

10.2      You may restrict Our use of Cookies. For more information, see clause 12 of this policy or visit https://www.aboutcookies.org/

11.         How Can You Access Your Data?

You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and we will provide any and all information in response to your request free of charge. Please contact us for more details at whiteadderad2022@gmail.com, or using the contact details below in section 13. 

12.         Our Use of Cookies

12.1      Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to
provide and improve Our products and/or services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

12.2      All Cookies used by and on Our Site are used in accordance with current Cookie Law https://www.aboutcookies.org/

12.3      Before Cookies are placed on your computer or device, you will be shown a prompt e.g. “pop-up” requesting your consent to set those 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 may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended. [You will be given the opportunity to allow only first party Cookies and
block third-party Cookies.]

12.4      Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in clause 12 of this policy.5. Your consent will not be sought to place these Cookies, but
it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 13.9, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.

12.5      The following first party Cookies may be placed on your computer or device:

Name of Cookie           Purpose                                                                                    Strictly Necessary

PHPSESSID                 It's the identifier for your current session in PHP                      yes

exp_last_activity          Every time the state is updated (the page reloaded)                 yes
                                      the last activity is set to the current datetime. Used to
                                      determine expiry. This is essential for logged in users,
                                      but not for guests - it is set for both.

exp_last_visit                Sets the datetime that the user last visited the site and            yes
                                      is set for both guests and logged in users. If not set, is
                                      automatically set to 10 years ago. Affects guests and
                                      logged in users.

exp_tracker                  Tracks the last 5 pages viewed by the user, and is used           yes
                                      primarily for redirection after logging in etc. Affects
                                      guests and logged in users.

exp_sessionid                Used to associate a logged in user with their data.                  yes

exp_expiration              Used to logout a loggedin user if they haven't been active        yes
                                        for a certain amount of time.

exp_csrf_token              A security cookie used to identify the user and prevent             yes
                                        Cross-Site Request Forgery attacks.

user_cookie_consent     Tracks whether the user has dismissed the cookie consent popup           yes

12.6      Our Site uses analytics services provided by Google. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how Our Site is used. This, in turn, enables Us to

improve Our Site and the products and/or services offered through it. 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
continually improve Our Site, making it a better and more useful experience for you.

12.7      The analytics service(s) used by Our Site use(s) Cookies to gather the required information.

12.8      The analytics service(s) used by Our Site use(s) the following Cookies:

Name of Cookie              First / Third Party              Provider              Purpose

_ga                                       3rd                                  Google                 Used to distinguish users
_gat_UA-17228195-1                       analytics

_gid                                      3rd                                  Google                 Used to throttle request rate. 

If Google Analytics is deployed via Google Tag Manager, this cookie will be named _dc_gtm_<property-id>.
 

12.9      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. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

12.10   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 including, but not limited to, login and personalisation settings.

12.11   It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are
unsure about adjusting your privacy settings.

Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our products and/or services.

13.         Responding to a Personal Data Breach

We have the necessary processes in place should a breach accidentally occur.  These processes include;

13.1.      The breach will be reported to the ICO within 72 hours of Us becoming aware of it

13.2.      The case in such circumstances will be handled by Our Data Protection Officer, Ian Maxwell Blinkhorn

13.3.      We will inform the affected individual of the breach as soon as We become aware of it. We will notify them of;
              a)  the nature of the breach
              b)  details of Our Data Protection Officer
              c)  potential consequences of the data breach
              d)  appropriate measures taken to mitigate any possible adverse effects

13.4.     All breaches will be documented even if they don't need to be reported 

14.         Contacting Us

If you have any questions about Our Site or this Privacy Policy, please contact Us by email at www.whiteadderwatersports.co.uk, by telephone on 01361 610160 or by post at Whiteadder Watersports Trust, 18/5 James Street, Portobello, Edinburgh. EH15 2DW. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you.

15.         Changes to Our Privacy Policy

We may change this Privacy Policy from time to time (for example, if the law changes). 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.