We, at TRUE SWING LTD, care about and respect your privacy. We’d like to explain what personal information we have about you and how we use it, as well as letting you know about our practices with regard to your privacy so that you know exactly what is happening with your data and what we are doing to keep it safe.
Where we refer to “we” or “us” in this policy, we mean TRUE SWING LTD, or any company or division in our group.
We are registered in the UK with Company No. 120 810 38 and our VAT number is 361 785 376.
WHAT INFORMATION DO WE COLLECT?
We collect a wide variety of information and the types we collect from you will vary dependent on whether you’re an individual customer, another business, ordering a product or a service or participating in a promotion or competition (amongst other things). Here are the types of information we may collect from time to time along with sources which tell you where we may receive the data from.
Information we may gain directly from you:
- Your name, age & contact details (including phone numbers, emails and addresses)
- Your opinions, feedback, comments or views
- Your banking details or payment card information (we do not retain these details)
- Your business details (which may include contact details, job titles and other information you would be expect to share when engaging in business with us)
- Your image within photography
- Special Request data which may include special category data such as Disability & accessibility requirements, dietary requirements or other information that may be deemed sensitive
- Your employment history and application data (including CV’s).
Information we may receive from other external third parties:
- Names, addresses, contact details/business details if necessary through the course of business
- Financial information, such as the results of a credit check
- Advertising preferences & analytical information (in particular from social media websites, pixels, clickstream data, cookies and Google Analytics).
We strive to collect the minimum amount of data necessary in order to perform the request for a product or service being made and so in some cases, failure to enter the requested information may result in us not being able to provide the product or service.
WHEN DO WE COLLECT YOUR INFORMATION?
We may collect your information in a number of ways. Here is an overview of the circumstances in which data is gathered.
- When you use our websites or a form is filled out on our websites (including from analytics)
- Correspondence via phone, email or otherwise with one of our team members
- When you subscribe to our products or services
- When you place an order with us
- If you have an accident at one of our sites
- When you or an analytics provider provide us with your marketing preferences (including where we use the services of social media platforms to determine your potential interest in a product or service)
- When you sign a contract or agreement with us
- To participate in a discussion board or other social media function on our sites
- To enter a competition, promotion or survey that we are running
- When you report a problem with one of our websites
- When you apply for a job with us
- When you visit our venues.
WHY DO WE NEED YOUR PERSONAL DATA?
There are a number of reasons we may request or collect your information. A summary of these can be found below:
- For the administration and support of a contract such as an order of goods, a trade agreement, an operations agreement or a service you’ve requested
- For the administration of a job application
- To request ongoing credit reference services to ensure your ongoing suitability for credit terms (if required)
- To respond to an enquiry, feedback or complaint you may have sent to us
- To improve the products or services we offer
- To administer our websites including troubleshooting, data analysis, testing, research, statistical and survey purposes. Also to keep it safe, secure and accessible
- To administer a promotion, offer or competition that you may participate in
- To notify you about any changes to our services
- For the communication of marketing materials (including e-mail, advertisements on social media, and in certain circumstances, phone calls)
For absolute clarity we do not intend our marketing materials to be received by anybody under the age of 18 due to the nature of our business. Your personal data may be used to determine whether you meet this criteria.
MARKETING
We may use your details to make an informed decision on products or services we think you may be interested in. This is marketing and we will always ask for your consent before we do this where we intend to send you materials via e-mail or text. We will also always ask your consent before we pass your details to any external third parties so that they can market to you too.
We understand that you may change your mind about receiving these types of emails or texts so you can ask us to stop at any time. This will only apply to data you have supplied in accordance with signing up to marketing services. Data provided for other purposes will remain in our systems in line with this policy.
WHO MIGHT RECEIVE A COPY OF YOUR PERSONAL DATA?
Throughout the course of activities it may be necessary for an external third party to receive a copy of your personal data. All of our external third parties are thoroughly vetted and are subject to contractual requirements and assessment of security standards in order to become an approved supplier. They are only permitted to process your personal data for the specified purpose and not for their own benefit.
Your data may be shared with any member of our group or trading divisions but external third parties may include any of those set out in the glossary, as relative to your circumstances.
- Business Partners, suppliers and sub-contractors where they are performing a contract we have entered into with them
- Advertising networks and support teams of this function to select and serve the relevant ads to you (particularly where we may share some of your details with a third party to enable delivery of more suitable advertisements to your social media homepage)
- Analytics and search engine providers that assist us in optimising our site
- Website & website services hosts including payment processors
- Agencies that assist in sending our marketing communications; and
- Authorities or organisations where there is a legal obligation for us to do so or for the prevention of fraud
- We may share your email address with our third party who then utilise the feature, looking at demographics and other traits like interests taken from information that you have uploaded onto Facebook in order to bring our advertisements to the people who might be interested in them most.
Our site may contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies which we do not accept any responsibility or liability for. Please check these policies before you submit any personal data to these websites.
HOW LONG WILL WE KEEP YOUR DATA?
We will only hold on to your personal data for as long as we need it to fulfill the purposes we collected it for. This includes considering the amount, nature and sensitivity of the data and the risk of any potential harm mishandling of this data may cause. We also consider if and when we can achieve the purposes we collected it for or if we can complete this without the personal data. We also consider legal, tax and reporting requirements that impose limitations on how long we hold the data for. It may be kept for a longer period of time if we reasonably predict there will be an element of legal action within our relationship with you.
CHANGES
We regularly review our policy so that we can ensure it is accurate and informative. Any changes will be made on this page. Please check back for updates.
It is also important that any personal data we hold about you is up to date and accurate. Please update us if any of the details we hold about you change so that we can ensure our records reflect these changes.
COOKIE POLICY
When you visit our websites we use cookies. Cookies allow us to identify the computer or device you’re using to access our websites – but we can’t identify you personally.
You can set up your web browser to refuse cookies, but this website may then fail to operate correctly.
GLOSSARY
Some terms we use in this policy may be difficult to understand so we’ve provided a breakdown below to help you clarify what we mean.
Legitimate Interest means the interest of our business in managing and carrying out our business functions so that we can give you the highest quality services/products and the best and most secure experience. We consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We will not use your personal data where our interests are overridden by your fundamental rights (unless we have your consent or are required or permitted to by law). If you need further detail on how we assess our legitimate interests against any potential impact on you in relation to certain circumstances, please contact us.
Performance of Contract means processing your data where you are a party to a contract and we need your personal data in order to carry out that contract or to take steps at your request if you are thinking of entering into a contract with us.
Legal obligation means processing your personal data where we have to comply with a law that applies to us.
Consent means you have specifically let us know that we can process your data for the purpose already given to you.