Privacy Policy

This Privacy Policy sets out how we, UK Skydiving Adventures Ltd, collect, store and use information about you when you use or interact with our website, www.ukskydivingadventures.comand where we otherwise obtain or collect information about you. This Privacy Policy is effective the 11thMay, 2018.

Contents

Summary

This section summarises how we obtain, store and use information about you. It is intended to provide a very general overview only. It is not complete in and of itself and it must be read in conjunction with the corresponding full sections of this Privacy Policy.

Data controller: UK Skydiving Adventures Ltd

How we collect or obtain information about you:

  • When you provide it to us by placing a booking online via our website, via a paper booking form by post or over the phone.
  • When you request more information from us by completing an enquiry form on our website or by sending us an email.
  • from your use of our website, using cookies
  • Occasionally, from third parties.

Information we collect: customer name, contact details, participant details, payment information e.g. your credit or debit card details, IP address, information from cookies, information about your computer or device (e.g. device and browser type), information about how you use our website (e.g. which pages you have viewed, the time when you view them and what you clicked on, the geographical location from which you accessed our website (based on your IP address), company name or business name (if applicable), VAT number (if applicable).

How we use your information:

  • The information you provide is used purely to process your booking to fulfil our contractual obligation.
  • For administrative and business purposes (particularly to contact you and process orders you place on our website and over the phone), to fulfil our contractual obligations, to advertise our goods and services, to analyse your use of our website, to improve our business and website in connection with our legal rights and obligations.

Disclosure of your information to third parties:

  • Only to the extent necessary to run our business, to fulfil any contracts we enter with you, and where required by law or to enforce our legal rights.
  • UK Skydiving Adventures will send your contact details and jump specific information to the skydiving centre you selected during the booking process, solely for the purpose of securing your place for your chosen skydiving experience.
  • If you are participating in a charity skydive, UK Skydiving Adventures will inform your chosen charity to enable them to help you with your fundraising efforts as well as to prevent fraud and financial crime. UK Skydiving Adventures will share a participant’s data with their chosen charity on the basis of legitimate interests and/or a contract with the participant for the purpose of the chosen charity contacting them about their fundraising. UK Skydiving Adventures will only share a participant’s data with their chosen charity for the purposes of direct marketing with explicit consent i.e. the participant will be given the option of ticking an OPT IN box if they would also like to hear more from their chosen charity via their stated contact preference about other fundraising events and marketing initiatives in the future. The participant can change their mind at any time by contacting their chosen charity directly. You can find your chosen charity’s privacy statement on their website.

We do not sell your information to third parties (other than in the course of a business sale or purchase or similar event.

How long we retain your information: for no longer than necessary, taking into account any legal obligations we have (e.g. to maintain records for tax purposes), any other legal basis we have for using your information (e.g. your consent, performance of a contract with you or our legitimate interests as a business) For specific retention periods in relation to certain information which we collect from you, please see the main section below entitled How long we retain your information.

How we secure your information: using appropriate technical and organisational measures such as storing your information on secure servers, encrypting transfers of data to or from our servers using Secure Sockets Layer (SSL) technology, encrypting payments you make on or via our website using Secure Sockets Layer (SSL) technology, only granting access to your information where necessary and the use ofencrypted emails.

Use of cookies: we use cookies in accordance to our cookie policy. For more information, please visit our cookies policy here: https://www.ukskydivingadventures.com/cookie-policy

Transfers of your information outside the European Economic Area In certain circumstances your information may be transferred outside of the European Economic Area, to the following countries: USA. We will ensure appropriate safeguards are in place, e.g. the third parties we use who transfer your information outside the European Economic Area have self-certified themselves as compliant with the EU-U.S. Privacy Shield.

Use of automated decision making and profiling: we do not use automated decision making however we do use profiling i.e. Google Analytics with the sole purpose of analysing website performance.

Your rights in relation to your information

  • to access your information and to receive information about its use
  • to have your information corrected and/or completed
  • to have your information deleted
  • to restrict the use of your information
  • to receive your information in a portable format
  • to object to the use of your information
  • to withdraw your consent to the use of your information
  • to complain to a supervisory authority
  • Sensitive personal information: we do not knowingly or intentionally collect what is commonly referred to as ‘sensitive personal information’. Please do not submit sensitive personal information about you to us. For more information, please see the main section below entitled Sensitive Personal Information.

Our details

The data controller in respect of our website is UK Skydiving Adventures Ltd, company registration number: 6708098 of PO Box 372, Bicester, Oxfordshire, OX27 0GA. You can contact the data controller by writing to UK Skydiving Adventures Ltd, PO Box 372, Bicester, Oxfordshire, OX27 0GA or sending an email to info@ukskydivingadventures.com.

If you have any questions about this Privacy Policy, please contact the data controller.

Information we collect when you visit our website

We collect and use information from website visitors in accordance with this section and the section entitled Disclosure and additional uses of your information.

Web server log information

We use a third-party server to host our website called Ready Design, the privacy policy of which is available here: https://www.ukskydivingadventures.com/cookie-policy Our website server automatically logs the IP address you use to access our website as well as other information about your visit such as the pages accessed, information requested, the date and time of the request, the source of your access to our website e.g. the website or URL (link) which referred you to our website, and your browser version and operating system.

Our server is located in the UK.

Use of website server log information for IT security purposes

Our third-party hosting provider collects and stores server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and other cyber-attacks, by detecting unusual or suspicious activity.

Unless we are investigating suspicious or potential criminal activity, we do not make, nor do we allow our hosting provider to make, any attempt to identify you from the information collected via server logs.

Legal basis for processing: compliance with a legal obligation to which we are subject (Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation: we have a legal obligation to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of our processing of information about individuals. Recording access to our website using server log files is such a measure.
Legal basis for processing: our and a third party’s legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: we and our third-party hosting provider have a legitimate interest in using your information for the purposes of ensuring network and information security.

Cookies

Cookies are data files which are sent from a website to a browser to record information about users for various purposes.

We use cookies on our website, including essential, functional, analytical and targeting cookies. For further information on how we use cookies, please see our cookies policy which is available here: https://www.ukskydivingadventures.com/cookie-policy

You can reject non-essential cookies by using our cookie control tool, but doing so can impair your ability to use our website or some or all of its features. For further information about cookies, including how to change your browser settings, please visit www.allaboutcookies.org or see our cookies policy https://www.ukskydivingadventures.com/cookie-policy

Information we collect when you contact us

We collect and use information from individuals who contact us in accordance with this section and the section entitled Disclosure and additional uses of your information.

Email

When you send an email to the email address displayed on our website, we collect your email address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in your email).

Legal basis for processing: ourlegitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so.

Transfer and storage of your information

We use a third-party email provider to store emails you send us. Our third-party email provider is Ready Design located in the UK. Their privacy policy is available here: https://readydesign.net/privacy-statement

Emails you send us will be stored within the European Economic Area on our third-party email provider’s servers in the UK.

Enquiry form

When you contact us using our enquiry form, we ask you to provide the following mandatory information: your name, email address, the type of skydiving experience you are interested in, your preferred skydiving location, the information packs you wish to receive and the preferred method for UK Skydiving Adventures Ltd to contact you. The following information we request for you to provide is optional: address, contact number and how you heard about us.

If you do not provide the mandatory information required by our contact form, you will not be able to submit the contact form and we will not receive your enquiry.

If you wish to be contacted by a different method to email, you need to ensure that you supply this optional piece of contact information.

Legal basis for processing: ourlegitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so.

Transfer and storage of your information

Messages you send us via our enquiry form will be stored within the European Economic Area on our third-party email provider’s servers in the UK.

Phone

When you contact us by phone, we collect your phone number and any information you provide to us during your conversation with us. We do not record phone calls.

Legal basis for processing: ourlegitimate interests (Article 6(1)(f) of the General Data Protection Regulation)
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so.

Transfer and storage of your information

Information about your call, such as your phone number and the date and time of your call, is processed by our third-party telephone service provider, Vonage Limitedwhich is located in The Bonhill Building, 15 Bonhill Street, London, EC2A 4DN. Their privacy policy is available here: https://www.vonage.co.uk/about/legal/privacy-policy/

On the occasions that you call when we are on the phone or out of the office, your call including information such as your phone number, the date and time of your call, and message will be directed to and processed by our 3rdparty reception team at Internet Communications Limited which trades as JAM, which is located at Unit 5, Borehamwood Enterprise Centre, Borehamwood, Hertfordshire, WD6 4RJ. Their privacy policy is available here: http://www.jam.co.uk/privacypolicy.aspx

Information about your phone call will be stored by our third-party telephone service provider within the European Economic Area.

Post

If you contact us by post, we will collect any information you provide to us in any postal communications you send us.

Legal basis for processing: ourlegitimate interests (Article 6(1)(f) of the General Data Protection Regulation)
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so.

Information we collect when you interact with our website

We collect and use information from individuals who interact with particular features of our website in accordance with this section and the section entitled Disclosure and additional uses of your information.

E-Newsletter

When you place a booking with us or when you complete an enquiry form on our website, you will be able to tick an OPT IN box confirming that you would like to receive news and details of any special offers by email. You can opt out of receiving this information at any time by contacting us directly.

Legal basis for processing: yourconsent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: you give your consent to us sending you our e-newsletter by signing up to receive it using the steps described above.

Transfer and storage of your information

Information you submit to subscribe for our e-newsletter will be stored within the European Economic Area on our secure database located on a server in the UK.

Information we collect when you place an order on our website.

We collect and use information from individuals who place an order on our website in accordance with this section and the section entitled Disclosure and additional uses of your information.

Information collected when you place an order

Mandatory information

When you place an order for goods or services on our website, we collect the name of the person placing the booking, phone number, email address, billing address, shipping address (if different from the billing address), company name (if applicable), as well the participant’s details, (i.e. name, age, height, weight and date of birth).

If you do not provide this information, you will not be able to purchase goods or services from us on our website or enter into a contract with us.

Legal basis for processing: necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: we need the mandatory information collected by our checkout form to establish who the contract is with and to contact you to fulfil our obligations under the contract, including sending you receipts and order confirmations.
Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation: we have a legal obligation to issue you with an invoice for the goods and services you purchase from us where you are VAT registered and we require the mandatory information collected by our checkout form for this purpose. We also have a legal obligation to keep accounting records, including records of transactions.

Optional information

We also collect optional information from you (non-personal), such as preferred date for experience, preferred time, whether you would like the skydive filmed. We also ask you if you would like to receive marketing communications from us. For further information, see ‘Marketing communications’ in this section below.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: the optional information requested is not necessary for UK Skydiving Adventures to be able to process your booking, as it can be provided at a later date when the customer is ready.

Processing your payment

After you place an order on our website you will need to make payment for the goods or services you have ordered. To process your payment, we use a third-party payment processor. Your payment will be processed by Pay Pal.

Pay Pal collects, uses and processes your information, including payment information, in accordance with their privacy policies. You can access Pay Pal’s privacy policy via the following link(s): https://www.paypal.com/uk/webapps/mpp/ua/privacy-full

Transfer and storage of your information

Pay Pal Europe is located in Luxembourg. Information relating to the processing of your payment is stored outside the European Economic Area on our third-party payment processor’s servers located in Scottsdale, Arizona and San Jose in California in the USA. We receive email notifications which are stored on our third-party email provider servers which are located in the UK.

For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

Legal basis for processing: necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: to fulfil your contractual obligation to pay for the goods or services you have ordered from us.

Marketing communications

At checkout you will have the option of receiving marketing communications from us.

Our goods and services

You can opt in to receiving marketing communications from us in relation to our goods and services by email, by ticking an OPT IN box indicating that you would like to receive such communications.

We will send you marketing communications in relation to our goods and services only if you opt-in to receive them. You can opt out of receiving this information at any time by contacting us directly.

Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: you give your consent to us sending you information about our goods and services by signing up to receive such information in accordance with the steps described above.

Transfer and storage of your information

Information you submit to subscribe for our e-newsletter will be stored within the European Economic Area on our servers in the UK.

Information we collect when you place an order via the telephone

We collect and use information from individuals who place an order over the phone in accordance with this section and the section entitled Disclosure and additional uses of your information.

Information collected when you place an order

Mandatory information

When you place an order for goods or services over the phone, we collect the name of the person placing the booking, phone number, email address, billing address, shipping address (if different from the billing address), company name (if applicable), as well the participant’s details, (i.e. name, age, height, weight and date of birth).

If you do not provide this information, you will not be able to purchase goods or services from us or enter into a contract with us.

Legal basis for processing: necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: we need the mandatory information collected by our checkout form to establish who the contract is with and to contact you to fulfil our obligations under the contract, including sending you receipts and order confirmations.
Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation: we have a legal obligation to issue you with an invoice for the goods and services you purchase from us where you are VAT registered and we require the mandatory information collected by our checkout form for this purpose. We also have a legal obligation to keep accounting records, including records of transactions.

Optional information

We also collect optional information from you (non-personal), such as preferred date for experience, preferred time, whether you would like the skydive filmed. We also ask you if you would like to receive marketing communications from us. For further information, see ‘Marketing communications’ in this section below.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: the optional information requested is not necessary for UK Skydiving Adventures to be able to process your booking, as it can be provided at a later date when the customer is ready.

Processing your payment

When you place an order over the phone you will need to make payment for the goods or services you have ordered. To process your payment, we use a third-party payment processor. Your payment will be processed by World Pay.

World Pay processes your information, including payment information, in accordance with their privacy policies. You can access World Pay’s privacy policy via the following link(s): https://www.worldpay.com/uk/privacy-policy

Transfer and storage of your information

World Pay is located in the UK. Information relating to the processing of your payment is stored within the European Economic Area on our third-party payment processor’s servers in the UK.

Legal basis for processing: necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: to fulfil your contractual obligation to pay for the goods or services you have ordered from us.

Marketing communications

You will be verbally asked whether you wish to opt in to receiving marketing communications from us in relation to our goods and services by email.

Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: you give your consent to us sending you information about our goods and services by signing up to receive such information in accordance with the steps described above.

Transfer and storage of your information

Information you submit to subscribe for our e-newsletter will be stored within the European Economic Area.

Our use of profiling

We use profiling on our website in the form of Google Analytics with the sole purpose of gaining an understanding of how our website is performing and how we can improve it as opposed to using the data to target individuals with advertising and marketing campaigns. We do not consider that this has any legal effect on you or similarly significantly affects you.

You have the right to object to our use of profiling described in this section. You can do that by opting-out of cookies and similar technologies in accordance with the method described in the relevant section below. If you do not want us to process your actual IP address (usually the IP address assigned to you by your Internet Service Provider) when you visit our website, you can use a Virtual Private Network (VPN) or a free service such as Tor.

You can find out more about our use of cookies and similar technologies (including the legal basis on which we use them) and how to opt out from them in our cookies policy, which is available here: https://www.ukskydivingadventures.com/cookie-policy

Profiling

Profiling is any form of automated processing of your information to evaluate personal aspects about you, to analyse or predict things like your performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

Use of profiling for web analytics

Our web analytics service, Google Analyticscollects information such as your location (based on your IP address) and your behaviour (based on cookies) when you access our website (such as the pages you visit, what you click on, how long you stay on the site). We will only process information from cookies if you have consented to us setting cookies on your computer in accordance with our cookies policy https://www.ukskydivingadventures.com/cookie-policy. Information collected about you, once collected is anonymised and stored on an aggregate basis.

Logic involved: by automatically analysing and categorising information such as the location (based on IP address) as well as the behaviour and devices of visitors to our website (using cookies), we are able to gain a better understanding of what our website visitors want (in terms of the content of our website and our products), how to improve our website.

Significance and envisaged consequences: cookies will be used to track and store information about your behaviour and device on our website (unless you have opted out from receiving such cookies by rejecting analytical cookies using our cookie control tool) and your location will be analysed based on your IP address. We will not use this information to retarget individuals with any form of advertising but instead use the information to help improve our website.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: to gain an understanding of how our website is being used and how we can improve our website.

Information we collect about you from third parties

This section sets out how we obtain or collect information about you from third parties.

Occasionally we receive information about you from third parties. These third parties will generally include companies, charities or individuals who are wanting to organize a group skydive.

It is also possible that third parties with whom we have had no prior contact may provide us with information about you.

Information we obtain from third parties will generally be your name and contact details, but will include any additional information about you which they provide to us such as age, height and weight which are necessary pieces of information for processing a skydive booking.

In certain circumstances (for example, to verify the information we hold about you or obtain missing information we require to provide you with a service) we will request and obtain information about you from the company, charity or individual who are wanting to organize a group skydive and who have already contacted UK Skydiving Adventures.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where a third party has passed on information about you to us (such as your name and email address) in order for us to provide services to you, we will process your information in order to take steps at your request to enter into a contract with you and perform a contract with you (as the case may be).
Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: where you have asked that a third party to share information about you with us and the purpose of sharing that information is not related to the performance of a contract or services by us to you, we will process your information on the basis of your consent, which you give by asking the third party in question to pass on your information to us.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: where a third party has shared information about you with us and you have not consented to the sharing of that information, we will have a legitimate interest in processing that information in certain circumstances.

For example, we would have a legitimate interest in processing your information to perform our obligations under a sub-contract with the third party, where the third party has the main contract with you. Our legitimate interest is the performance of our obligations under our sub-contract.

Similarly, third parties may pass on information about you to us if you have infringed or potentially infringed any of our legal rights. In this case, we will have a legitimate interest in processing that information to investigate and pursue any such potential infringement.

Where we receive information about you in error

If we receive information about you from a third party in error and/or we do not have a legal basis for processing that information, we will delete your information.

Disclosure and additional uses of your information

This section sets out the circumstances in which we will disclose information about you to third parties and any additional purposes for which we use your information.

Disclosure of your information to service providers

We use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business and who process your information for us on our behalf. Below we have listed the categories of the recipients and where applicable and possible the names of the recipients including links to their privacy policies:

Telephone provider(s):

Email provider: Ready Design: https://readydesign.net/privacy-statement

IT service provider: Ready Design: https://readydesign.net/privacy-statement

Web developer: Ready Design: https://readydesign.net/privacy-statement

Hosting provider: Ready Design: https://readydesign.net/privacy-statement

Customer Reviews Processor:

Payment processors:

Skydiving centres located in the UK

Charities located in the UK

Our third-party service providers are located in the UK apart from Pay Pal whose servers are located in Scottsdale, Arizona and San Jose in California in the USA.

Your information will be shared with these service providers where necessary to provide you with the service you have requested, whether that is accessing our website or ordering goods and services from us.

We do not display the identities of some of our service providers publicly by name for security and competitive reasons. If you would like further information about the identities of our service providers, however, please contact us directly [via our contact form] or [by email] and we will provide you with such information where you have a legitimate reason for requesting it (where we have shared your information with such service providers, for example).

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest relied on: where we share your information with these third parties in a context other than where is necessary to perform a contract (or take steps at your request to do so), we will share your information with such third parties to allow us to run and manage our business efficiently.
Legal basis for processing: necessary to perform a contract and/or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: we may need to share information with our service providers to enable us to perform our obligations under that contract or to take the steps you have requested before we enter into a contract with you.

Disclosure of your information to other third parties

We disclose your information to other third parties in specific circumstances, as set out below.

Providing information to third parties such as Google Inc. Google collects information through our use of Google Analytics on our website. Google uses this information, including IP addresses and information from cookies, for many purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and anonymised basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the following page: https://www.google.com/policies/privacy/partners/
Legal basis for processing: ourlegitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): meeting our contractual obligations to Google under our Google Analytics Terms of Service (https://www.google.com/analytics/terms/us.html)

You can opt out of Google Analytics by installing the browser plugin here: https://tools.google.com/dlpage/gaoptout

Transfer and storage of your information

Information collected by Google Analytics is stored outside the European Economic Area on Google’s servers in the United States of America.

For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.]

Sharing your information with third parties, which are either related to or associated with the running of our business, where it is necessary for us to do so. These third parties include our accountants, affiliates, business partners, independent contractors, and insurers. Further information on each of these third parties is set out below.

Legal basis for processing: ourlegitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: running and managing our business efficiently.

Accountants

We share information with our accountants for tax purposes. For example, we share invoices we issue and receive with our accountants for completing tax returns and our end of year accounts.

Our accountants are MHA MacIntyre Hudson (1 The Forum, Minerva Buesiness Park, Lynchwood, PE2 6FT) Their privacy policy is available here: https://www.macintyrehudson.co.uk/privacy-policy

Affiliates

Affiliates are individuals or entities we work with to promote our business by various means, including by advertising our services on their websites, for example. Our affiliates include the charities that we work with. Affiliates will share information with us and we will share information with them where you have expressed an interest in our products or services.

Our affiliates are various charities all of which are located in the UK.

Business partners

Business partners are businesses we work with which provide goods and services which are complementary to our own or which allow us to provide goods or services which we could not provide on our own. We share information with our business partners where you have requested services which they provide whether independently from, or in connection with or own services.

Our business partners are the British Parachute Association affiliated skydiving centres that we work with, all of whom are located in the UK.

Independent contractors

Occasionally, we use independent contractors in our business. Your information will be shared with independent contractors only where it is necessary for them to perform the function we have hired them perform in relation to our business.

Our independent contractors are GDPR compliant self-employed administrators located in England.

Insurers

We will share your information with our insurers where it is necessary to do so, for example in relation to a claim or potential claim we receive or make or under our general disclosure obligations under our insurance contract with them.

Our insurers are Coversure. Their privacy policy is available here: https://www.coversure.co.uk/privacy-policy

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: running and managing our business effectively.

AND

Legal basis for processing: necessary to perform a contract or to take steps at your request prior to entering into a contract(Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: we need to share your information with other companies in order to be able to meet our contractual obligations to you or to take steps at your request prior to entering a contract, for example because of the services or information you have requested.

We do not display the identities of all of the other third parties we may share information with by name for security and competitive reasons. If you would like further information about the identities of such third parties, however, please contact us directly [via our contact form] or [by email] and we will provide you with such information where you have a legitimate reason for requesting it (where we have shared your information with such third parties, for example).

Sharing your information with a prospective or actual purchaser or seller in the context of a business or asset sale or acquisition by us, a merger or similar business combination event, whether actual or potential.

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): sharing your information with a prospective purchaser, seller or similar person to allow such a transaction to take place.

Disclosure and use of your information for legal reasons

Indicating possible criminal acts or threats to public security to a competent authority

If we suspect that criminal or potential criminal conduct has been occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that we fraud or a cyber crime has been committed or if we receive threats or malicious communications towards us or third parties.

We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.

Legal basis for processing: ourlegitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: preventing crime or suspected criminal activity (such as fraud).

In connection with the enforcement or potential enforcement our legal rights

We will use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: enforcing our legal rights and taking steps to enforce our legal rights.

In connection with a legal or potential legal dispute or proceedings

We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): resolving disputes and potential disputes.

How long we retain your information

This section sets out how long we retain your information. We have set out specific retention periods where possible. Where that has not been possible, we have set out the criteria we use to determine the retention period.

Retention periods

Server log information: we retain information on our server logs for 1 month

Order information: when you place an order for goods and services, we retain that information for six years following the end of the financial year in which you place your order, in accordance with our legal obligation to keep records for tax purposes. Once you have completed your skydiving experience, you can however request to have your personal data erased from our system, leaving just the original customer order number, by emailing us at info@ukskydivingadventures.com

Correspondence and enquiries: when you make an enquiry, or correspond with us for any reason, whether by email, via our contact form or by phone, we will retain your information for as long as it takes to respond to and resolve your enquiry, and for 3 further month(s), after which point we will delete your information.

E-Newsletter: we retain the information you used to sign up for our e-newsletter for as long as you remain subscribed (i.e. you do not unsubscribe) or if we decide to cancel our e-newsletter service, whichever comes earlier.

Criteria for determining retention periods

In any other circumstances, we will retain your information for no longer than necessary, considering the following:

  • the purpose(s) and use of your information both now and in the future (such as whether it is necessary to continue to store that information to continue to perform our obligations under a contract with you or to contact you in the future);
  • whether we have any legal obligation to continue to process your information (such as any record-keeping obligations imposed by relevant law or regulation);
  • whether we have any legal basis to continue to process your information (such as your consent);
  • any relevant agreed industry practices on how long information should be retained;
  • the levels of risk, cost and liability involved with us continuing to hold the information;
  • any relevant surrounding circumstances (such as the nature and status of our relationship with you).

How we secure your information

We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:

  • only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible;
  • using secure servers to store your information
  • verifying the identity of any individual who requests access to information prior to granting them access to information;
  • using Secure Sockets Layer (SSL) software to encrypt any information you submit to us via any forms on our website and any payment transactions you make on or via our website
  • only transferring your information via closed system or encrypted data transfers

Transmission of information to us by email

Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.

We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.

Transfers of your information outside the European Economic Area

Most of your information (see exceptions stated below) is stored in the following European Economic Area (EEA) countries: England

Other than to comply with any legal obligations to which we are subject (compliance with a court order, for example), we do not intend to transfer your information outside the EEA or to an international organisation. In the unlikely event that we are required to transfer your information outside the EEA (or to an international organisation) for such a purpose, we will ensure appropriate safeguards and protections are in place.

This is with the exception to the following where your information will be transferred and stored outside the European Economic Area (EEA) in the circumstances set out below:

Google Analytics

Information collected by Google Analytics (your IP address and actions you take in relation to our website) is transferred outside the EEA and stored on Google’s servers. You can access Google’s privacy policy here: https://www.google.com/policies/privacy/

Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission.

Safeguard(s) used: Google has self-certified its compliance with the EU-U.S. Privacy Shield which is available here: https://www.privacyshield.gov/welcome. The EU-U.S. Privacy Shield is an approved certification mechanism under Article 42 of the General Data Protection Regulation, which is permitted under Article 46(2)(f) of the General Data Protection Regulation. You can access the European Commission decision on the adequacy of the EU-U.S. Privacy Shield here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm

Payment processors

Website bookings:

Information you submit to us when placing a booking via our website is transferred outside the EEA and stored on our payment processor servers. Our payment processor is: Pay Pal. You can access their privacy policy here: https://www.paypal.com/uk/webapps/mpp/ua/privacy-full

Country of storage: Scottsdale, Arizona and San Jose in California in the USA. This country is not subject to an adequacy decision by the European Commission.

Safeguard(s) used: details on how Pay Pal safeguard all information collected can be found here: https://www.paypal.com/us/webapps/mpp/ua/privacy-full

Your rights in relation to your information

Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by writing to UK Skydiving Adventures Ltd, PO Box 372, Bicester, Oxon, OX26 9FN or sending an email to info@ukskydivingadventures.com:

  • to request access to your information and information related to our use and processing of your information;
  • to request the correction or deletion of your information;
  • to request that we restrict our use of your information;
  • to receive information which you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file) and the right to have that information transferred to another data controller (including a third-party data controller);
  • to object to the processing of your information for certain purposes (for further information, see the section below entitled Your right to object to the processing of your information for certain purposes); and
  • to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.
  • In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation.

For the purposes of the UK, the supervisory authority is the Information Commissioner’s Office (ICO), the contact details of which are available here: https://ico.org.uk/global/contact-us/

Further information on your rights in relation to your personal data as an individual

The above rights are provided in summary form only and certain limitations apply to many of these rights. For further information about your rights in relation to your information, including any limitations which apply, please visit the following pages on the ICO’s website:

You can also find out further information about your rights, as well as information on any limitations which apply to those rights, by reading the underlying legislation contained in Articles 12 to 22 and 34 of the General Data Protection Regulation, which is available here: http://ec.europa.eu/justice/data-protection/reform/files/regulation_oj_en.pdf

Verifying your identity where you request access to your information

Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so.

These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.

How we verify your identity

Where we possess appropriate information about you on file, we will attempt to verify your identity using that information.

If it is not possible to identity you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation to be able to verify your identity before we are able to provide you with access to your information.

We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.

Your right to object to the processing of your information for certain purposes

You have the following rights in relation to your information, which you may exercise in the same way as you may exercise by writing UK Skydiving Adventures Ltd, PO Box 372, Bicester, Oxon, OX26 9FN or sending an email to info@ukskydivingadventures.com

  • to object to us using or processing your information where we use or process it to carry out a task in the public interestor for our legitimate interests, including ‘profiling’ (i.e. analysing or predicting your behaviour based on your information) based on any of these purposes; and
  • to object to us using or processing your information for direct marketing purposes (including any profiling we engage in that is related to such direct marketing).

You may also exercise your right to object to us using or processing your information for direct marketing purposes by:

  • clicking the unsubscribe link contained at the bottom of any marketing email we send to you and following the instructions which appear in your browser following your clicking on that link;
  • sending an email to info@ukskydivingadventures.com, asking that we stop sending you marketing communications or by including the words “OPT OUT”.

For more information on how to object to our use of information collected from cookies and similar technologies, please see the section entitled How to accept or reject cookiesin our cookies policy, which is available here: https://www.ukskydivingadventures.com/cookie-policy

Sensitive Personal Information

‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.

We do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us.

If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information under Article 9(2)(a) of the General Data Protection Regulation. We will use and process your sensitive personal information for the purposes of deleting it.

Changes to our Privacy Policy

We update and amend our Privacy Policy from time to time.

Minor changes to our Privacy Policy

Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its effective date onwards.

Major changes to our Privacy Policy or the purposes for which we process your information

Where we make major changes to our Privacy Policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email (where possible) or by posting a notice on our website.

We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.

Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.

Children’s Privacy

Because we care about the safety and privacy of children online, we comply with the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying regulations protect the privacy of children using the internet. We do not knowingly contact or collect information from persons under the age of 18. The website is not intended to solicit information of any kind from persons under the age of 18.

It is possible that we could receive information pertaining to persons under the age of 18 by the fraud or deception of a third party. If we are notified of this, as soon as we verify the information, we will, where required by law to do so, immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers. If you would like to notify us of our receipt of information about persons under the age of 18, please do so by sending an email to info@ukskydivingadventures.com

Copyright, credit and logo

This Privacy Policy is based on a General Data Protection Regulation (Regulation (EU) 2016/769) (GDPR) compliant template provided by GDPR Privacy Policy. For further information, please visit https://gdprprivacypolicy.org

The copyright in this Privacy Policy is either owned by, or licensed to, us and is protected by copyright laws around the world and copyright protection software. All intellectual property rights in this document are reserved.

Where we display the GDPR Privacy Policy logo on our website, this is used to indicate that we have adopted a privacy policy template provided by GDPR Privacy Policy as the basis for this Privacy Policy.

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