1. Introduction and who we are
Freedome UK Ltd (“We” “Us” or “Our”) are strongly committed to protecting and respecting your privacy.
Where you use our services, or your personal data is processed in connection with such services, and we control the purpose for which such personal data is processed, we will be the data controller of such information.
This Privacy Notice does not apply to, and we are not responsible for, any third party websites which may be accessible through links from our Website (please see clause 13 (Third-party websites) below for more information).
2. Scope of Privacy Notice
This Privacy Notice explains and describes:
- When this Privacy Notice applies.
- Information we collect about you.
- Legal basis for usage of personal data.
- Uses made of your information.
- Disclosure of your information.
- Security of information we store and transfer.
- How long we keep your personal data secure and private.
- What cookies are and how we use them.
- How we manage sensitive personal data.
- Your rights.
- Third-party websites.
- Jurisdiction and governing law.
- Changes to our Privacy notice.
- Status of this statement.
- Further information.
3. When this Privacy Notice applies
3.1. This Privacy Notice applies:
- to your usage and activities at any of our parks;
- to your use of any of our facilities, services or products where we are performing a data controller function;
- where you apply to us for a job or work placement;
- where you are a supplier of services or products to us and Personal Data is provided to us; and/or
- to any personal information collected from third parties where we are the controller of such information.
3.2. This Privacy Notice additionally applies to our Website and online services, including freedomeparks.com, and any other website, mobile app or other online service created or hosted by us from time to time on which this Privacy Notice appears (together, our “online services”) through which we may collect certain details if, for example, you want to subscribe to any publications or newsletters that we may periodically issue.
4. Information we may collect from you
We may collect and process the following data about you:
4.1. Information you give us. You may give us information about you by filling in forms on our Website, providing payment details where relevant, or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you use our Website, place an order for activities at any of our trampoline parks or complete the Risk Acknowledgment and Disclaimer on our Website, enter a competition, promotion or survey, and when you report a problem with our Website. The information you give us may include current and historical data including your name, date of birth, telephone numbers, address, other contact details, billing information, financial and credit card information, details of height and weight and physical or medical condition in connection with the activities that we operate at our parks. We may also collect personal data about your other interactions with us, including any contact we have with you in person, by telephone, email or online.
4.2. Information we may collect about you. With regard to each of your visits to our Website we may collect the following information:
(a) Technical information, including the Internet protocol (IP) address used to connect your computer, tablet, mobile or other device (each being a “Device”) to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, information you post online either on our Website or on a third- party social media site to which we have access.
(b) Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Website (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
4.3. Information we may collect from third parties. We may receive information about you if you use any other websites that we operate or may operate from time to time or other services we provide. We may initially share information amongst members of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries (“Affiliates”). We may also work with third parties such as regulatory authorities, recruitment agencies, credit reporting agencies, information or service providers, publicly available records, and the third parties described in clause 8 (Disclosure of your information) below which include, business partners, sub- contractors in technical, payment and delivery services, advertising networks, analytics providers and search information providers.
4.4. We may collect information from other sources, such as social media platforms that share information about how you interact with our social media content, and any information gathered through these channels will be governed by the privacy settings, policies, and/or procedures of the applicable social media platform, which we strongly encourage you to review.
4.5. We will handle any unsolicited information in accordance with law, including destroying or de-identifying such information where we are required to do so.
4.6. If you apply for a job or work placement with us then you may need to provide information about your education, employment, racial background and state of health. As part of your application you will be asked to provide your explicit consent to our use of this information to assess your application and to allow us to carry out both recruitment analytics and any monitoring activities which may be required of us under applicable law as an employer. We may also carry out screening checks (including reference, background, directorship, financial probity, identity, eligibility to work, vocational suitability and criminal record checks) and consider you for other positions.
4.7. We may exchange your personal data with academic institutions, recruiters, screening check providers, health service providers, professional and trade associations, law enforcement agencies, recruitment analytics providers, referees and your current and previous employers. We may also gather additional information about you from publicly available resources such as LinkedIn or other social or professional media platforms and collate this with the information that you provide to us. Without your personal data, we may not be able to progress considering you for positions with us.
4.8. In some instances, personal data must be provided to us in order for us to legally or contractually perform services to you, for example where we are obligated to gather personal data for health and safety purposes including in the event of an emergency . Where relevant we will highlight to you those details that we are obligated to collect.
5. Legal basis for usage of personal data
5.1. Where we intend to use your personal data, we rely on the following legal grounds:
(a) Legitimate interests: Where we consider use of your information as being (a) non-detrimental to you, (b) within your reasonable expectations, and (c) necessary for our own, or a third party’s legitimate purpose, we may use your personal data, which may include:
- for our own direct marketing or continued communication;
- the prevention of fraud;
- our own internal administrative purposes; personalisation of the service(s) we provide to you;
- ensuring network and information security, including preventing unauthorised access to electronic communications networks and stopping damage to computer and electronic communication systems; and/or
- reporting possible criminal acts or threats to public security to a competent authority.
(b) Consent: You may be asked to provide your consent in connection with certain services that we offer, for example in respect of any processing of your personal data for our marketing purposes which are not possible under our legitimate interests, or in respect of certain special categories of personal data such as your health or racial background for which we are legally obliged to gain your consent due to the sensitive nature of such information and the circumstances in which it is gathered or transferred. Where we are reliant upon your consent, you may withdraw this at any time by contacting us in accordance with clause 19 (Further Information) below, however please note that we will no longer be able to provide you with the products or services that rely on having your consent.
(c) Performance of a contract: We may need to collect and use your personal data to enter into a contract with you or to perform a contract that you have with us. For example, to record your disclaimer of certain types of liability due to the nature of risk associated with usage of our parks, and where we respond to your requests and provide you with services in accordance with our Terms and Conditions or other applicable terms of business agreed with you.
(d) Compliance with a legal obligation: We may be required to process your information due to legal requirements, including employment laws, tax laws, health and safety laws and other regulatory provisions applicable to us as a provider of trampoline park services.
6.2. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your Device and are widely used in order to make websites work, or work more efficiently to improve the user experience, as well as to provide certain information to the owners of the site. Cookies contain information that is transferred to your Device’s hard drive or Device.
6.3. We may, for example, collect information about the type of device you use to access our online services, the operating system and version, your IP address, your general geographic location as indicated by your IP address, your browser type, the content you view and features you access on our online services, the web pages you view immediately before and after you access our online services, whether and how you interact with content available on our online services, and the search terms you enter on our online services.
6.4. Our Website sets cookies which remain on your computer for differing times. Some expire at the end of each session and some remain for longer so that when you return to our Website, you will have a better user experience.
6.5. We use the following cookies:
(a) Strictly necessary cookies. These are cookies that are required for the operation of our Website. They include, for example, cookies that enable you to log into secure areas of our Website, use a shopping cart or make use of e-billing services.
(b) Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.
(c) Functionality cookies. These are used to recognise you when you return to our Website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
(d) Targeting cookies. These cookies record your visit to our Website, the pages you have visited and the links you have followed. We will use this information to make our Website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
6.6. Except for essential cookies, all cookies will expire after a period reasonable to their general application.
6.7. If you do not wish cookies to be stored on your Device, you can block them by activating the relevant setting on your browser which can usually be found in the “help” section. More information on how to do this is available here: www.allaboutcookies.org or www.youronlinechoices.eu. However please note that, if you use your browser settings to block cookies (including essential cookies) you may not be able to access all or parts of our Website. Your usage of the Website without changing your browser cookies settings will indicate your consent to usage of cookies in accordance with this section of our Terms and Conditions. You can change your cookie settings at any time.
7. Uses made of your information. We use information in the following ways in order to provide you with, and improve, our services:
7.1. Information you give to us. We will use this information:
(a) to carry out our obligations arising from any agreements entered into between you and us for your usage of our parks including the provision to you with information and services that you request from us, providing our services, activities or online content and dealing with your requests and enquiries;
(b) to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
(c) to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. Where we permit selected third parties to use your data, we (or they) will contact you only if you have consented to this. If you do not want us to use your data in this way, please tick the relevant box situated on the page on which we collect your data;
(d) to notify you about changes to our parks, activities we offer, service or products;
(e) to contact you in relation to service updates that affect you, regulatory updates that affect our services and any additional information in relation to our service that we think you may find interesting;
(f) to analyse and improve the services offered on our Website; and
(g) to ensure that content from our Website is presented in the most effective manner for you and on your Device.
7.2. Information we collect about you. We will use this information:
(a) to administer our Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
(b) to improve our Website to ensure that content is presented in the most effective manner for you and for your Device;
(c) to allow you to participate in any interactive features of our Website or our services generally, when you choose to do so;
(d) as part of our efforts to keep our Website safe and secure;
(e) to personalise the way the Website content is presented to you and provide you with the most user- friendly navigation experience. We may also use and disclose information in aggregate (so that no individuals are identified) for marketing and strategic development purposes;
(f) to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
(g) to use IP addresses to identify the location of users, to block disruptive use, to establish the number of visits from different countries and to determine whether you are accessing the services from the UK or not; and
(h) to make suggestions and recommendations to you and other users of our Website about goods or services that may interest you or them.
7.3. Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
7.4. We may not be able to do some or all of these things without your personal data.
7.5. If at any time we intend to change the purpose for which we hold your personal data, for example to offer you with a complimentary service that we may provide in the future, we will give you prior information of that new purpose so you are aware of this.
8. Disclosure of your information
8.1. We may, in providing our services and operating our business, allow access to your personal data to our Affiliates for our internal administrative purposes such as billing, promoting our parks, events, activities and other services, and providing you or your organisation with services, provided in all instances that such processing is consistent with section 5 (Legal basis for usage of personal data) above and applicable law.
8.2. We will not rent or sell your information to third parties without your consent, except as noted in this Privacy Notice or advised to you in writing and consented to by you. We will not be responsible or held liable for the actions of third party sites from which you may have linked or been directed to our Website.
8.3. We may share your information with selected third parties contracted to us where any of the following will apply:
(a) You have consented to us sharing your personal data in this way.
(b) It is necessary to protect the rights and interests, property, or safety of any person in attendance at one of our parks, or others.
(c) agents or contractors who assist us in providing our services require such information, for example in fulfilling requests for information, receiving and sending communications, updating marketing lists, analysing data, providing support services or in other tasks from time to time. Our agents and contractors will only use your information to the extent necessary to perform their functions.
(d) It is necessary to protect the rights and interests, property, or safety of our customers, or others.
(e) business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
(f) advertisers and advertising networks that require the data to select and serve relevant adverts to you and others; and
(g) analytics and search engine providers that assist us in the improvement and optimisation of our Website.
8.4. In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; and personal data held about our customers may be one of the transferred assets in the event of sale of the assets of our business to a third party.
8.6. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide you on our behalf. When such third parties no longer need your personal data to fulfil this service, they will dispose of such details in line with our procedures unless they are themselves under a legal obligation to retain information (provided that this will be in accordance with applicable data
privacy laws). If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.
8.7. We also provide anonymous statistical information about users of our Website and related usage information to reputable third parties, including analytics and search engine providers.
8.8. We own the database rights in the information collected via our online services. We do not sell, rent, or otherwise share information that reasonably identifies you or your organisation with unaffiliated entities for their independent use except as expressly described in this Privacy Notice or with your express prior permission.
8.9. We may share information that does not reasonably identify you or your organisation as permitted by applicable law.
9. Security of information we store and transfer
9.1. We take steps to hold information securely in electronic or physical form. All electronic data you provide to us is stored on secure servers. Any payment transactions will be encrypted using Secure Sockets Layer (SSL) technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website or our service, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. It is important for you to protect against unauthorised access to your password and to your computer so we advise that you sign off when you have finished using a shared computer strongly recommend and that you do not use the browser’s password memory function as that would permit other people using your Device to access your personal information.
9.2. The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”) that do not have a similar standard of protection laws to the UK. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of any order, the processing of payment details and the provision of support services. We will always require your personal information to be treated to at least UK standards, and by submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Notice.
9.3. Our information security is supported by a variety of processes and procedures, and we store information in access controlled premises or electronic databases requiring logins and passwords. All our employees, officers or contractors and third party providers with access to confidential information are subject to access controls and confidentiality obligations, and we require our third-party data storage providers to comply with appropriate information security industry standards.
9.4. Whilst we continually strive to ensure that our systems and controls are updated to reflect technological changes, the transmission of information via the internet is not completely secure, and as such we cannot guarantee the security of your data transmitted to our online services which is at your own risk.
9.5. If you communicate with us using a non-secure web platforms, you assume the risks that such communications between us are intercepted, not received, delayed, corrupted or are received by persons other than the intended recipient.
9.6. Once we have received your information, we will take reasonable steps to use procedures and security features to try to prevent unauthorised access, modification or disclosure.
10. How long do we keep your personal data secure and private
10.1. We will keep your personal data only for as long as is reasonably necessary to fulfil the purposes that such data was originally collected in accordance with our internal data retention polices or to comply with our legal and regulatory obligations.
10.2. A maintained copy of our retention policy is available upon request. Should you wish to review our retention policy then please contact us in accordance with section 19 (Contact) below.
11. How we manage sensitive personal data
Certain information is defined as ‘sensitive’ (racial or ethnical origin, political opinions, religious believes, trade union membership, physical or mental health, sexual life, biometric information and criminal proceedings and offences). If we ever deal with sensitive personal information we will only use this information to provide the service you require and we will ask for your explicit consent.]
12. Your rights
12.1. Under applicable data protection legislation, we have a duty of care to ensure that your personal data is accurate and up to date. Therefore, please contact us to update or correct your information if this changes or if you believe that any information that we have collected about you is inaccurate at email@example.com.
12.2. Where you have consented to our processing of certain personal data, you can at any time withdraw such consent and/or tell us not to contact you with updates and information regarding our products and services (or part of them) either at the point such information is collected, (by leaving the relevant box unticked) or, where you do not wish us to continue to use your information in this way, by following the unsubscribe instructions on any communications sent to you. Please note that where you withdraw your consent we will no longer be able to provide you with the products or services that rely on having your consent. You can also exercise this right at any time by contacting us using the contact details at the end of this Privacy Notice.
12.3. You can request:
(a) access to the personal data we hold about you
(b) corrections or updates to your details;
(c) the erasure of your personal data;
(d) the portability of personal data that you have provided to us in a structured, commonly used and machine-readable format.
12.4. You also have the right to object to, or request the restriction of, our use of your personal data.
12.5. If you would like to exercise any of the rights set out in this section, please contact us using the details set out in section 18 (Further information) below. We may refuse to provide access where we have legitimate reasons for doing so under applicable data privacy laws, and in exceptional circumstances may charge a fee for access if the relevant legislation allows us to do so, in which case we will provide reasons for our decision.
12.6. You may submit a complaint to the Information Commissioners Office, details of which can be found at https://ico.org.uk/global/contact-us.
12.7. If you make a privacy complaint, we will respond to let you know how your complaint will be handled. We may ask you for further details, consult with other parties and keep records regarding your complaint.
13. Third party websites
13.1. Our Website may contain links to and from the websites of our partner networks, advertisers and other third parties. This Privacy Notice does not address the privacy, security, or other practices of the third parties that provide such content.
13.2. If you follow a link to any of these websites, please note that they 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.
14.1. We will provide you with an “opt in” mechanism which will give you the opportunity to positively indicate that you would like for us to send you further communications. At any time you can “opt-out” through the link mechanism on any correspondance that we have with you so that you can opportunity indicate that you do not want us to send you such further communications, or by emailing us at firstname.lastname@example.org. Once you have “opted-out” we will not send you any marketing material.
14.2. Opting-in will be up to you and, in addition, if you do not want us to use your personal information for a particular purpose or disclose it to a third party, you may “opt out” at any time by contacting us as provided below. Please note though, by opting-out, you may not be able to participate in certain activities on our Website.
15. Jurisdiction and governing law
All matters relating to the Website are governed by the laws of England and Wales, without reference to conflict or choice of law principles. You agree that the jurisdiction and venue for any legal proceeding relating to the Website shall be in appropriate courts located in England and Wales. We do not warrant or imply that the Website or materials on it are appropriate for use outside of this jurisdiction. The information contained on this Website concerning any products or services is applicable only in the jurisdiction and these products or services may not be available in all locations. If you are located outside of this jurisdiction, you are solely responsible for compliance with any applicable local laws.
16. Changes to our Privacy Notice
Any changes we may make to our Privacy Notice in the future will be posted on this page and, where appropriate, notified to you by e-mail or by a notice displayed on the homepage of our Website. Please check back frequently to see any updates or changes to our Privacy Notice.
17. Status of this statement
17.1. Your provision of personal data to us or use of our online services constitutes your acceptance of the terms of this Privacy Notice.
17.2. As technologies and information governance practices develop, and data privacy laws (and surrounding guidance) evolve, we may need to revise this Privacy Notice. You should therefore review this page regularly to ensure that you are aware of any changes to its terms.
17.3. We will post any Privacy Notice changes on this page and, if the changes are significant or may materially impact upon your rights, we will provide a more prominent notice or contact you by other means (including, for certain services, email notification of Privacy Notice changes).
18. Further information
18.1.To find out more about us please visit www.freedomeparks.com.
18.2. We can, at your request, confirm what information we hold about you and how it is processed. If we do hold personal data about you, you can request the following information by contacting us using the details below:
(a) Identity and the contact details of the person or organisation that has determined how and why to process your data.
(b) The purpose of the processing as well as the legal basis for processing.
(c) If the processing is based on our legitimate interests or a third party, information about those interests.
(d) The categories of personal data collected, stored and processed.
(e) Recipient(s) or categories of recipients that the data is/will be disclosed to.
(f) How long the data will be stored.
(g) The source of personal data if it wasn’t collected directly from you.
(h) Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
18.3. In order to verify the identity of those who make a request to us, we will accept the following forms of ID when information on your personal data is requested:
(b) Driving licence, Birth certificate,
(c) Utility bill dated within the last 3 months.
19.1. If you have any questions, concerns or comments about this Privacy Notice, or want to submit a written complaint about how we handle your personal data, please contact us [or our EU Representative] via any of the following means:
19.2. Our contact details are as follows:
Contact address: Unit 1B Colesium Way Ellesmereport CH659HD
Tel: 0151 3567494
Our Data Compliance Manager is Peter Brown