Privacy Notice for ClubManager

Last updated 18^th August 2021

Club Manager Limited takes security and privacy seriously. This Privacy Notice explains how we collect, store and use personal data when you browse www.clubmanagercentral.com (the "ClubManager website"), use the ClubManager application ("ClubManager") or otherwise provide your personal data to us. Please read this Privacy Notice carefully to understand how we will treat your personal data.

This Privacy Notice relates to ClubManager as a data controller. This means that it applies where we are responsible for deciding how we hold and use your personal information. We are required to provide you with the information contained in this privacy notice.

About us

ClubManager provides a transformative member management system for clubs, associations, charities and businesses that delivers tons of functionality without complexity. 

Using your personal data

If anyone can be identified by any information that we collect, this information is called ‘personal data’. Data protection law says that ClubManager must have a reason or ‘purpose’ for collecting and using personal data.

Our purposes are:

1. Providing ClubManager

2. Internal record keeping

3. Managing our relationship with you

4. Developing and improving our products and services

5. Contacting you for marketing purposes

6. Providing insights

How we ensure that what we do with your information is lawful

ClubManager can only collect and use your personal information if we have a lawful basis to do so. The bases we use to legitimise our processing are:

1. Providing ClubManager

• The processing is necessary - for the performance of a contract to which the data subject is a party, or for the taking of steps at the request of the data subject with a view to entering into a contract

• The data subject has given consent to the processing

ClubManager does not intentionally collect or process any special categories of data in the provision of ClubManager.

When we enter into a contract with you we are also a “data processor”. This means amongst other things that you as the Subscriber controls each Invited User’s level of access to the relevant organisation and Service at all times and can revoke or change an Invited User’s access, or level of access, at any time and for any reason. Where we are a data processor, we will process personal data only in accordance with the written instructions of the data controller, and as permitted by the UK GDPR and other relevant regulations. Where a client is based outside the European Economic Area it is the responsibility of that client to ensure that it complies with its domestic privacy laws.

2. Internal record keeping

• The processing is necessary for compliance with any legal obligations to which the data controller is subject, other than an obligation imposed by contract

3. Managing our relationship with you

• The processing is necessary for the purposes of legitimate interests pursued by the data controller or by the third party or parties to whom the data are disclosed, except where the processing is unwarranted in any particular case by reason of prejudice to the rights and freedoms or legitimate interests of the data subject.

We want to establish and improve trust in ClubManager. By developing relationships with our clients there is an expectation that both parties will benefit.

4. Developing and improving our products and services

• The processing is necessary for the purposes of legitimate interests pursued by the data controller or by the third party or parties to whom the data are disclosed, except where the processing is unwarranted in any particular case by reason of prejudice to the rights and freedoms or legitimate interests of the data subject.

We monitor patterns of usage, such as login dates and volumes of data, so we can understand how people are using ClubManager to develop and improve our products. To aid in monitoring patterns of usage, we log your IP address when you use the website. This is your computer's individual identification number that is assigned to your computer when connected to the Internet. We also monitor traffic information when you visit our site or read our emails, including things like page visits, email clicks, purchases, referring sites, and video viewings.

We use this information to improve our website, advertising, promotions, and to understand customer purchasing behaviour. Please see Section: Use of Cookies below regarding cookies.

5. Contacting you for marketing purposes

• The data subject has given consent to the processing

• The processing is necessary for the purposes of legitimate interests pursued by the data controller or by the third party or parties to whom the data are disclosed, except where the processing is unwarranted in any particular case by reason of prejudice to the rights and freedoms or legitimate interests of the data subject.

We may use your personal data to contact you by email, fax, post, SMS, social media and/or telephone to let you know about our other ClubManager and/or third party services, content, offers or product ranges which may be of interest to you. We may also use your membership data to enable us to tailor these notifications (in order to make sure what we are sending you is relevant). This is called profiling. If you would like us to stop providing you with such notifications or to stop us creating a profile of you, just contact us at privacy@clubmanagercentral.com.

Please note, this may take up to one working day to take effect.

You cannot stop service emails from ClubManager (for example, a reminder that your subscription is expiring) whilst an account is active, as this is part of your contract.

If you are signed up to marketing communications, cancelling your ClubManager account will not cancel your marketing preference.

We believe that marketing communicates the reasons why consumers should choose us, including the benefits, the price, and the unique features we offer. It also helps maintain relationships with our clients and creates engagement.

6. Providing insights

• The processing is necessary for the purposes of legitimate interests pursued by the data controller or by the third party or parties to whom the data are disclosed, except where the processing is unwarranted in any particular case by reason of prejudice to the rights and freedoms or legitimate interests of the data subject.

We monitor anonymous, aggregated information about account and membership data so that we can produce insights about small businesses finance. For example, based on an anonymous, aggregate data analysis, we may produce a white paper that reports how clubs run manage membership renewals. We may share these insights with customers, on our blog or other promotional material, use them internally to improve our product and communications, or share with other interested third parties. Just to be clear - we will never identify you or your business in such communications or white papers and will never report data in such a way that your business could be identified.

Consent

Where you have given consent to us using your personal data you have the right to withdraw your consent and we will then stop processing it. This will not affect the lawfulness of processing based on consent before its withdrawal. If withdrawal of consent may affect the way we can deliver our service/s to you we will tell you at the time. Please also see the ‘What are your rights?’ section below.

Information Others Provide to Us

We may receive information from others (e.g. your bank) that you have authorised that third party to provide to us. This could include the initial information to enable us to create your account (e.g. your full name, your email address and your business type) and also your bank transaction data.

Who do we share your information with?

We use third parties to assist us in providing ClubManager from time to time, and in those cases will disclose your personal and/or membership data to them. We only share your data with third parties that we trust, and where there are assurances in place as to how they will protect the data.

You may grant third party access to your personal or membership data by enabling the ClubManager API for that third party if you have a contract with us. At all times, this access is controlled by you.

We may contact you if the specific arrangement we have in place with a third party which impacts you is changing and / or coming to an end and to let you know what will take place next.

We may also share your personal and membership data with third parties:

• in the event that we, our business, or substantially all of its assets are acquired by a third party (in which case personal information about customers will be one of the transferred assets);

• if we are under a duty to disclose or share your personal or membership data in order to comply with any legal obligation; to cooperate with law enforcement officials in the investigation of unlawful activities of ClubManager website users or relating to ClubManager users; or in order to enforce or apply any contract with you; or to protect our rights, property, or safety of our employees, customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

We also utilise a number of carefully selected third parties to help provide our services to you. Examples of these functions include email, providing marketing assistance and data analysis, data management, handling credit card transactions and providing customer service. In choosing to work with any such third parties, we will always ensure that the security policies and confidentiality arrangements of those third parties adhere to the same requirements we ourselves impose and expect, as a minimum. No ownership rights to the data will be transferred to any third party.

For a full list of data processors and details of the adequate safeguards in place in respect of data transfers outside the EEA, please see here.

3rd party apps

In addition we share information and data with various 3rd party apps. These are data controllers in their own right. We list those apps here and advise that you read their privacy notices:

Google Inc. We use Google Analytics to help us understand the way people use ClubManager so we can make it better and communicate relevant information to users. To provide this Google collects anonymised statistical data about the use of our website and applications. Read Google Analytics’ Privacy Policy

SendGrid We use SendGrid for sending emails. To do this SendGrid stores user names, email addresses and analytical data on their usage of ClubManager. We use that data to ensure we only send emails relevant to the individual. https://www.twilio.com/legal/privacy

Zendesk Inc. Our customer support system and emails are provided by Zendesk. Customers email addresses will appear in Zendesk along with all discussion between the customer and ourselves. https://www.zendesk.co.uk/company/agreements-and-terms/privacy-policy//

Stripe. We process debit and credit card payments using Stripe Payments Europe Limited. a worldwide payments provider. The main capture is through their European subsidiary based in Ireland, but some of the data is passed to Stripe Inc. the parent company in the USA. For this transfer to be lawful they employ the European Commission’s Standard Contractual Clauses (“Model Clauses”) to allow for the lawful transfer of such data under the EU Data Directive. https://www.chargebee.com/privacy/

Spreedly. We process debit and credit card payments using Spreedly, Inc. a worldwide payments platform. The main capture is through their European subsidiary based in Ireland, but some of the data is passed to Stripe Inc. the parent company in the USA. For this transfer to be lawful they employ the European Commission’s Standard Contractual Clauses (“Model Clauses”) to allow for the lawful transfer of such data under the EU Data Directive. https://www.spreedly.com/privacy

GoCardless GoCardless. https://gocardless.com/privacy & https://support.gocardless.com/hc/en-gb/articles/360000281005

Debit Finance Collections Plc Debit Finance Collections Plc. https://www.debitfinance.co.uk/legal/

Harlands Services Ltd Harlands Services Ltd. https://www.harlandsgroup.co.uk/legal/

The Retention People The Retention People https://trpcem.com/privacy-policy/

SmartDebit SmartDebit https://www.smartdebit.co.uk/privacy/

IFTTT https://ifttt.com/trust

The data that we collect from you may be transferred to, and stored at, a destination outside the United Kingdom (UK). It may also be processed by staff operating outside the UK who work for us, one of our group companies or for one of our suppliers. Such staff may be engaged in, among other things, the processing of your payment details and the provision of support services. Where personal data is processed outside the UK this is likely to be a ‘restricted transfer’ and so we must ensure that a safeguard is in place that is recognised by the representative supervisory authority of the United Kingdom. This is the Information Commissioner's Office (ICO). The safeguard is most likely to be use of one of the ICO's standard contractual clauses.

Where our data processors are based in the EEA they must also comply with the original General Data Protection Regulation 2016/679 (GDPR).

Use of cookies

We may further use, or permit selected third parties to use your personal data to enable us to track and analyse ClubManager website traffic and visitor trends, improve your browsing experience and to personalise and enhance the content and advertising we display.

Cookies are small files saved to your device that track, save and store information as well as your interactions and usage of our services. The primary purpose for our use of cookies is to allow us to provide a smooth, efficient and personalised experience for our users both on and off our website through remembering your preferences, storing passwords if you request it and serving you more relevant advertising.

If you want to manage or disable cookies for the ClubManager website, you can do it by changing your browser settings. We suggest consulting the Help section of your browser or taking a look at the About Cookies website which offers guidance for all modern browsers.

How long do we store your data for?

When you cancel your account with ClubManager, you can either delete your data from the active system immediately, or we will automatically delete your data within 180 days.

However, to ensure the integrity of our systems and your data, we utilise various technologies to continually take secure, encrypted backups. Data remains archived within these backups and these are maintained according to our defined two-year data retention policy, after which they are removed.

Details of financial transactions will be kept for six years following the financial year in which the transaction took place

If you are signed up to marketing communications, we will delete your personal data two years after you cancel your account or after your last contact with us.

What are your rights?

1. Access to your personal data: You can ask us to confirm if we are processing your personal data and you may request a copy of your personal data by contacting our support team at privacy@clubmanagercentral.com.

2. Right to change or withdraw your consent: Where you have given us consent to make use of your personal data for any of the purposes outlined in this Privacy Notice, you may withdraw that consent by contacting us using the details given below.

3. Right to Rectification: You may ask us to update out of date or inaccurate information we hold about you. To do so, please log on to your ClubManager account and update your information or get in touch.

4. Right to Erasure: In certain circumstances you may ask us to erase your personal data. If you would like us to erase the personal data we hold about you, please get in touch.

5. Right to Data Portability: you can ask us to provide you with the personal data that we hold about you, which was supplied by you, in a structured, commonly used, machine readable form, or ask for us to send such personal data to another data controller. You can use the Export All Data functionality at any time to export your data or please get in touch.

6. Right to object: In certain circumstances you may object to our processing of your personal data. Please get in touch.

7. Right to restrict processing: You can ask us to restrict the processing of personal data we hold about you in certain circumstances. Please get in touch.

Changes to this Privacy Notice

We may modify or update this Privacy Notice from time to time to reflect the changes in our business and practices, and so you should review this page periodically. When we change the policy in a material manner we will let you know and update the ‘last updated’ header at the top of this page.

This Privacy Notice was last amended on 18^th August 2021.

Getting in touch

If you have any queries relating to this Privacy Notice or ClubManager’s use of your personal data, please contact our Head of Information Security via email through privacy@clubmanagercentral.com or our Support Team at support@clubmanagercentral.com or by writing to us at

Club Manager Limited, 195 St. Marys Lane, Upminster, England, RM14 3BU

How to complain

If you wish to complain about the way we handle your personal information please contact us in the first instance. If, when we have investigated and responded you are still unhappy, please contact the Information Commissioners Office on 0303 123 1113, email: dpo@ico.org.uk or visit: www.ico.org.uk