Data Protection Policy
Eastbourne Leisure is committed to protecting and respecting your privacy.
This policy (and any other documents referred to herein) sets out the basis on which any personal data we collect from you from our website www.eastbourneleisure.co.uk, or that you provide to us by other means, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purpose of the Data Protection Act (the Act), and the General Data Protection Regulations (GDPR), from 25 May 2018, the data controller is Eastbourne Borough Council and the Data Protection Officer is Oliver Dixon, Senior Lawyer.
1. Information we may collect from you
1.1 We may collect and process the following data about you:
a. Information that you provide by filling in forms on our Websites. This includes information provided at the time of registering to use the Website, subscribing to our service and any additional, posting material, contributions or requesting further services. We may also ask you for information when you enter a competition or promotion sponsored by us and when you report a problem with our Website.
b. If you contact us, we may keep a record of that correspondence.
c. We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
d. Details of transactions you carry out through our Websites.
e. Details of your visits to the Websites including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
2. IP addresses and cookies
2.1 We may collect information about your device, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.
2.2 For the same reason, we may obtain information about your usage of our Websites by using a cookie which is stored on the hard drive of your device. Cookies are used to make our Websites work and to deliver a better and more personalised service. They enable us:
a. To estimate our audience size and usage pattern.
b. To store information about your preferences, and so allow us to customise our Websites according to your individual interests.
c. To speed up your searches.
d. To recognise you when you return to our Websites.
2.3 This website is powered by Wix. The cookies used by Wix on our Websites are:
XSRF-TOKEN - Used for security reasons – Duration Session - Essential
Hs - Used for security reasons – Duration Session - Essential
svSession - Used in connection with user login – Duration 2 years - Essential
SSR-caching - Used to indicate the system from which the site was rendered - 1 minute - Essential
_wixCIDX - Used for system monitoring/debugging – Duration 3 months - Essential
_wix_browser_sess - Used for system monitoring/debugging – Duration session - Essential
consent-policy - Used for cookie banner parameters – Duration 12 months - Essential
smSession - Used to identify logged in site members – Duration Session - Essential
TS* - Used for security and anti-fraud reasons – Duration Session - Essential
bSession - Used for system effectiveness measurement - 30 minutes - Essential
fedops.logger.sessionId - Used for stability/effectiveness measurement – Duration 12 months - Essential
wixLanguage - Used on multilingual websites to save user language preference - 12 months - Functional
2.5 We may embed videos from our official YouTube channel using YouTube's privacy-enhanced mode. This mode may set cookies on your device once you click on the YouTube video player, but YouTube will not store personally-identifiable cookie information for playbacks of embedded videos using the privacy-enhanced mode. To find out more please visit YouTube's embedding videos information page: https://www.google.com/support/youtube/bin/answer.py?hl=en-GB&answer=171780
2.6 We may display either (or both) of the following widgets:
a. Feed widgets (widgets that display a feed from our social network page). These widgets do not create a cookie.
b. Sharing widgets (widgets such as Facebook Like, Twitter Share or AddThis) which enable you to share content from our websites to your friends or followers. By default these do not create a cookie until you have clicked on the graphic or icon representing the sharing network you would like to use. By clicking the graphic or icon you consent to transmitting data to the respective social network.
3. Where we store your personal data
3.1 All information you provide to us is stored on our secure servers located in the United Kingdom. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Websites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
3.2 The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Websites; any transmission is at your own risk. Once we have received your information, we will use appropriate procedures and security features to try to prevent unauthorised access.
4. Purpose of the processing, legal basis for the processing and retention periods
4.1 We use information held about you in the following ways:
a. To ensure that content from our Websites are presented in the most effective manner for you and for your device.
b. To provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes.
c. To carry out our obligations arising from any contracts entered into through our Websites.
d. To allow you to participate in interactive features of our service, when you choose to do so.
e. To notify you about changes to our service.
f. To regularly update you about our services and promotions in Newsletters.
4.2 We may also use your data to provide you with information about goods and services which may be of interest to you and we may contact you about these by email.
4.3 Where we permit our affiliates to use your data, we (or they) will contact you only if you have consented to this.
4.4 We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience.
4.5 Our lawful bases for processing personal data:
a. Dealing with enquiries - task carried out in the public interest.
b. Bookings (with review requests) and eShop orders - Necessary for the performance of a contract.
c. Marketing/eNewsletters – Consent.
4.6 Our retention periods for your personal data:
a. Operational Database records will be deleted after 18 months of last use, e.g. checking out of accommodation.
b. eMarketing Database records will be deleted after 24 months of last use, e.g. an email being sent.
4.7 Business records storage and publishing:
a. For storing and publishing business records on this website, our lawful basis for processing this data is “Public task”. The ICO website states the following, "the processing is necessary for you to perform a task in the public interest or for your official functions".
b. We store accommodation, venue and other business details (Trade Data) in our database to facilitate publishing them on this website. Our legal basis for this processing is part of our public task. Business details are, by their nature, already in the public domain and we are using them in a way the businesses would reasonably expect and could benefit from.
5. Disclosure of your information
5.1 We may disclose your personal information to third parties if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms and Conditions and other agreements; or to protect the rights, property, confidential information or safety of our Websites, customers, affiliates or others and in particular if we are required to prevent any fraud or fraudulent transactions. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
5.2 Our websites may, from time to time, 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 and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
6. Your rights
6.1 You have the right to ask us not to process your personal data for marketing purposes. We operate an optional choice for receiving marketing communications and will clearly name any other organisations who may process your personal data. You can exercise your right to prevent such processing at any time by using the unsubscribe function on a received marketing email or by contacting tel: 01323 738822
6.2 You are entitled to request a copy of any information we hold about you. Any such requests must be made in writing. If the information we hold about you is inaccurate you have a right to have this corrected and you have the right to request completion of incomplete data. You have the right to request the erasure of your personal data in certain circumstances (‘right to be forgotten’). You have the right to request that we stop, or restrict the processing of your personal data, in certain circumstances. Where possible we will seek to comply with your request, but we may be required to hold or process information to comply with a legal requirement. If you are dissatisfied with how the councils have used your personal information you have a right to complain to the Information Commissioner's Office.
The Sovereign Centre, Royal Parade, Eastbourne, East Sussex, BN22 7LQ
Tel: 01323 738822