We never rent, or sell access to your data to anyone else, nor do we make use of it ourselves for any purpose other than to provide our services or if required to so do by law.
Server Security:
The UCS Active Website is hosted on a Digital ocean droplet in London in the European Economic Area (EEA).
The security of your Personal Information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security. We use industry standard encryption between your browser and the server which is signified by the https in the browser url bar and the green “Secure” bag next to the url.
Digital ocean servers located in London are certified for
- SOC 1 Type II
- SOC 2 Type II
- ISO/IEC 27001:2013
- PCI-DSS
Digital Ocean: Physical Security
Our datacenters are co-located in some of the most respected datacenter facility providers in the world. We leverage all of the capabilities of these providers including physical security and environmental controls to secure our infrastructure from physical threat or impact. Each site is staffed 24/7/365 with on-site physical security to protect against unauthorized entry. Security controls provided by our datacenter facilities includes but is not limited to:
- 24/7 Physical security guard services
- Physical entry restrictions to the property and the facility
- Physical entry restrictions to our co-located datacenter within the facility
- Full CCTV coverage externally and internally for the facility
- Biometric readers with two-factor authentication
- Facilities are unmarked as to not draw attention from the outside
- Battery and generator backup
- Generator fuel carrier redundancy
- Secure loading zones for delivery of equipment
Infrastructure Security
Digital Ocean's infrastructure is secured through a defense-in-depth layered approach. Access to the management network infrastructure is provided through multi-factor authentication points which restrict network-level access to infrastructure based on job function utilizing the principle of least privilege. All access to the ingress points are closely monitored, and are subject to stringent change control mechanisms.
Systems are protected through key-based authentication and access is limited by Role-Based Access Control (RBAC). RBAC ensures that only the users who require access to a system are able to login. We consider any system which houses customer data that we collect, or systems which house the data customers store with us to be of the highest sensitivity. As such, access to these systems is extremely limited and closely monitored.
Additionally, hard drives and infrastructure are securely erased before being decommissioned or reused to ensure that your data remains secure.
Access Logging
Systems controlling the management network at Digital Ocean log to our centralized logging environment to allow for performance and security monitoring. Our logging includes system actions as well as the logins and commands issued by our system administrators.
Security Monitoring
Digital Ocean's Security team utilizes monitoring and analytics capabilities to identify potentially malicious activity within our infrastructure. User and system behaviors are monitored for suspicious activity, and investigations are performed following our incident reporting and response procedures.
Droplet Security & Employee Access
The security and data integrity of customer Droplets is of the utmost importance at Digital Ocean. As a result, our technical support staff do not have access to the backend hypervisors where virtual servers reside nor direct access to the NAS/SAN storage systems where snapshots and backup images reside. Only select engineering teams have direct access to the backend hypervisors based on their role.
Snapshot and Backup Security
Snapshots and Backups are stored on an internal non-publicly visible network on NAS/SAN servers. Customers can directly manage the regions where their snapshots and backups exist which allows the customer to control where their data resides within our datacenters for security and compliance purposes.
First Party Cookies
While using our website, the following cookies may be placed on your computer:
Cookie names:
- _ga
- _gat_gtag_UA_xxxxxxxxx_x
- _gid
- _gmb_ga_test
- __utma
- __utmb
- __utmc
- __utmz
- __utmx
- __utmxx
Purpose:
These cookies are for Google Analytics.
We use Google Analytics to help us understand how our website is used by visitors. We evaluate and report, and use this anonymous information to make improvements to the website.
Google Analytics is a service provided by Google, Inc. Google Analytics is widely used across the web and all data is anonymised meaning the cookies carry no personally identifiable information.
If you would like to opt-out of Google Analytics monitoring your behaviour on our sites please use this link (https://tools.google.com/dlpage/gaoptout/)
For more information on Google Analytics cookies please see:
https://support.google.com/analytics/answer/6004245
Cookie Names:
- SID
- SSID
- IDE
- DSID
- NID
- SAPISID
- CONSENT
- APISID
- 1P_JAR
- HSID
Purpose:
These cookies are for Google Adwords Remarketing.
We using Google Adwords Remarketing to show appropriate ads to people who have visited our website on Google’s Display Network. Google uses their doubleclick.net service to do this. These cookies themselves contain no personally identifiable information.
Find out more about double click’s cookies here:
https://support.google.com/dfp_premium/answer/2839090?hl=en
Cookie names:
- exp_expiration
- exp_cookies_allowed
- exp_last_visit
- exp_last_activity
- exp_sessionid
Purpose:
We use Expression Engine to power our website. Expression Engine cookies are used to track a user's recent activity, last visit and general site movements. Like the Google Analytics cookies, these contain no personally identifiable information. These cookies will only be used if you log in to the website. UCS Active members on the whole are not required to log in to the site.
Declining First Party cookies will have an impact on the performance of our site;
Third Party Cookies
In addition to the above cookies, the following sites may set their own cookies whilst browsing our site.
Twitter
Facebook
These cookies will generally only be set if you are signed in to (or have been signed into) a matching account and are generally linked to the use of the Social Media buttons on our site and many others throughout the web. The use of these cookies is likely to have been detailed in each of these sites' Terms and Conditions or Privacy Policies. Please see links below for further details:
Facebook Privacy Policy
http://www.facebook.com/about/privacy/
Twitter Privacy Policy
https://twitter.com/privacy
Declining Third Party cookies will have little to no impact on the performance of our site;
Cookies
Although we believe that cookies pose little threat to your privacy, we understand that you may still want to turn them off. Whilst we would encourage you to keep our first party cookies enabled (so that we can make your on-site experience better), the following links provide guidance on how to manage cookie permissions through your browser's settings. This includes instructions on how to delete existing cookies and block them from being set in the future:
Firefox: Enable and disable cookies that websites use to track your preferences
http://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences?redirectlocale=en-US&redirectslug=Enabling+and+disabling+cookies
Safari: Managing Cookies
http://support.apple.com/kb/index?page=search&fac=all&q=cookies%20safari
Google Chrome: Manage cookies
http://support.google.com/chrome/bin/answer.py?hl=en-GB&answer=95647
Opera: Security & Privacy in Opera
http://www.opera.com/browser/tutorials/security/privacy/
Internet Explorer: How to manage cookies in Internet Explorer 9
http://windows.microsoft.com/en-GB/windows7/How-to-manage-cookies-in-Internet-Explorer-9
How to delete cookie files in Internet Explorer
http://support.microsoft.com/kb/278835
More information about cookies, including how to block them or delete them, can be found at www.allaboutcookies.org
Forms Data
We have a number of forms on the UCS Active website to allow members and potential members to contact and make enquiries to UCS Active.
These forms allow with their associated data are:
Book A Visit:
We use this form for members to arrange a tour of the club.
- Name - So we can use your name when you come in and in all contact with you
- Address - So we can check your eligibility for membership*
- Postcode - So we can check your eligibility for membership*
- Contact Number - So we can call you to arrange a suitable time
- Email Address - So we can email to arrange a suitable time
- D.O.B - So we can check for eligibility and so we arrange a suitable tour and membership
- Enquiry Message - So you can let us know any enquiry specifics
- IP Address - Taken when a user submits the enquiry and is used for audit and spam management
- Time and Date - Taken when a user submits the enquiry and used to make sure we reply in a timely manner.
Class Bookings
We use this form for booking on to classes.
- Name - So we can use your name when you come in and in all contact with you
- Member or Non Member - We limit availability for non members
- Contact Number - So we can reply to your enquiry
- Email Address - so we can reply to your enquiry
- Class - the class you are enquiring about so we can reply appropriately
- Enquiry Message - So you can let us know any enquiry specifics
- IP Address - Taken when a user submits the enquiry and is used for audit and spam management
- Time and Date - Taken when a user submits the enquiry and used to make sure we reply in a timely manner.
Email Sign Up
We use this form to allow people to subscribe to our UCS Active club newsletter.
- Email Address - so we can subscribe you.
- IP Address - Taken when you subscribe and is used for audit and spam management
- Time and Date - Taken when you subscribe
All newsletters have an unsubscribe link in them, but you can also unsubscribe at any time by emailing as info@ucsactive.org.uk and the subject of “Please Unsubscribe me from the Newsletter”.
General Enquiry Form
Used for all general enquiries
- Name - So we can use your name when you come in and in all contact with you
- Contact Number - So we can reply to your enquiry
- Email Address - so we can reply to your enquiry
- Enquiry Message - So you can let us know any enquiry specifics
- IP Address - Taken when a user submits the enquiry and is used for audit and spam management
- Time and Date - Taken when a user submits the enquiry and used to make sure we reply in a timely manner.
Club Hub Feedback
We use this form to receive feedback on the Club facilities
- Our Staff - Rating of 0-5 stars
- What we offer - Rating of 0-5 stars
- Maintenance & Cleanliness - Rating of 0-5 stars
- Our facilities - Rating of 0-5 stars
- Your Feedback - Open text allowing for a user to offer feedback on the Club
- Name - So we can contact you for further details and to discuss your feedback
- IP Address - Taken when a user submits the enquiry and is used for audit and spam management
- Time and Date - Taken when a user submits the enquiry and used to make sure we reply in a timely manner.
Kids Active Dance Enquiry
This form is used for users to enquiry about the Kids Active Dance classes
- Name - So we can use your name when you come in and in all contact with you
- Contact Number - So we can reply to your enquiry
- Email Address - so we can reply to your enquiry
- Member or Non Member - We limit availability for non members
- Enquiry Message - So you can let us know any enquiry specifics
- IP Address - Taken when a user submits the enquiry and is used for audit and spam management
- Time and Date - Taken when a user submits the enquiry and used to make sure we reply in a timely manner.
Membership Enquiry
We use this form to allow people to enquire about join UCS Active
- Name - So we can use your name when you come in and in all contact with you
- Address - So we can check your eligibility for membership*
- Postcode - So we can check your eligibility for membership*
- Contact Number - So we can call you to arrange a suitable time
- Email Address - So we can email to arrange a suitable time
- D.O.B - So we can check for eligibility and so we arrange a suitable tour and membership
- Connection to UCS - So we can check for eligibility and membership type
- How did you hear about us - So we can audit our marketing and processes
- Enquiry Message - So you can let us know any enquiry specifics
All form data that is submitted is cleared after 6 months with the exception of Hub Feedback which is annomanised.
We keep the Hub feedback data for audit purposes.
*UCS Active membership eligibility is subject to place of residence, and the discretion of the management.
Website Members Data
If you have a website account on the UCS Active site we store the following details about you.
This is the core membership data Expression Engine keeps on each member.
- Member_id - This is unique id number to identify you across the website
- Group_id - This determines the permissions the logged in user has.
- Username - This is used for the member to sign in to the site
- Screen_name - This is used as the public name of the logged in user
- Password - This is a Hashed version of the users password. We do not keep the user’s password in plain text nor can we restore it back to plain text.
- Unique_id - a unique identifier for the member.
- Crypt_key - the Key used to create the password hash.
- Email - the users email address
- Ip_address - the ip address the user last used
- Join_date -the date the user account was created
- Last_visit - the date the user last logged in to the account
- Last_activity - the date the user last edited content or settings
- Total_entries - the total number of entries the user has created on the website
- Total_comments - the total number of comments the user has written on the website
- Last_entry_date - the date the user last created an entry
- Language - the language the user uses Expression Engine with
- Timezone - the time zone Expression Engine shows dates in
- Time_format - the format time is shown in Expression Engine
- Include_seconds - Whether or not the user likes to see seconds on dates inside Expression Engine
- Date_format - the format dates are shown in Expression Engine for that user
- Salt - the salt used for creating their password
Email Marketing
We use Mailchimp to send our Club newsletters. We only send to people who have signed up for the newsletter and UCS Active members. You may unsubscribe at any point using the unsubscribe link which appears in each newsletter or by emailing info@ucsactive.org.uk with the subject “Please unsubscribe me from the UCS Active Newsletter”.
Click here to find out more about how MailChimp store your data.
https://mailchimp.com/legal/privacy/
Membership Management Software
We use the club management system EZ Runner to manage all membership records and operational requirements.
Click here to find out more about how EZ Runner stores your data.
http://www.ez-runner.com/index.php/en/2-uncategorised/17-privacy-policy
Data Protection Officer
Our designated Data Protection Office is Chloe Chaldecott. You can contact Chloe directly via dataprotection@ucsactive.org.uk.
UCS Active is a family friendly, relaxed, sociable gym with clean, state-of-the-art facilities for the Hampstead community to enjoy. We are wholly owned by University College School Foundation and all profits made are gifted to the Foundation to help fund bursaries. We respect your privacy and are committed to protecting your personal data carefully, sensibly and legally.
This privacy notice describes the personal information that we collect and receive about you (including any data you provide when you join us as a member or sign up to our Kids Active or In Body assessments), the purposes for which we use it and the steps we take to safeguard your personal data. It also informs you about your privacy rights under the new GDPR legislation and how that legislation protects you.
Please note, we have a separate policy covering use of our website and booking classes through our Club Hub portal, which is available for you to view at www.ucsactive.org.uk/site-info/privacy-policy
This privacy notice was last updated on 14th November 2018. Unless stated otherwise, this privacy notice applies to all personal data we collect or receive about you.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Key Roles
Data Controller: UCS Active
Data Processor:
EZ Runner Systems Ltd. Data Protection Officer: Chloe Chaldecott
DPO Contact Details:
E-mail: dataprotection@ucsactive.org.uk | Phone: 0207 433 2127
Postal Address:
Chloe Chaldecott
Data Protection Office UCS Active
Frognal
Hampstead
NW3 6XH
What Personal Data do we collect about you?
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, receive, use, store and transfer different kinds of personal data about you which we have grouped together follows:
Identity Data: First name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data: home address, email address and telephone numbers.
Financial Data: includes bank account and payment card details.
Transaction Data: includes details about payments to and from you.
Profile Data: includes your usernames and passwords, details of your membership, your class bookings, your notes of relevant interactions with us, feedback and survey responses.
Usage Data: includes dates and times you signed into the club using your membership cards.
Marketing and Communications Data: includes your preferences in receiving our newsletter.
Aggregated Data: May be derived from your personal data but is not considered personal indirectly reveal your identity. For example, we occasionally run Usage reports to determine peak times for attendance. Data in these reports is anonymised. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
Special categories of Personal Data: (defined as race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). We do not collect Special Category Data unless you opt in to our In-Body Assessment programme.
How do we collect and receive your Personal Data
We collect and receive personal data from you through direct interactions with us.
For example: You may give us your Identity, Contact and Financial Data by filling in membership forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• join us as a member;
make phone or in person bookings for our products or services;
• contact us (whether by post, phone, email or otherwise) or provide us with feedback.
• Tap in or manually register attendance at UCS • Active with your membership card or verbally and services, we collect Usage Data.
If you have a monthly Direct Debit Member- ship we may also receive your Contact, Financial and Transaction Data from BACS, our EU based provider of technical, payment, debt recovery and fraud protection services.
How do we use your Personal Data?
UCS Active will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform a contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests. Where we need to comply with a legal or regulatory obligation.
You can read more on the following pages about the types of lawful basis that we rely on to process your personal data, and the purposes for which we will use your personal data.
Marketing
We provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Marketing from us
As part of the membership sign up, you can opt in to receiving communications from UCS Active, including but not limited to Member Newsletters, Club Alerts, and alerts to changes to the Terms and Conditions. If you do not opt in, you will not receive these communications.
Opting Out
If you opted into receiving communications, and subsequently wish to opt out, you can do so at any time by following the opt-out links on any marketing message sent to you or by contacting the Data Protection Officer at gary.kruse@ucsactive.org.uk
If you opt out of receiving marketing messages from us but remain a customer, you will continue to receive non-marketing communications (including, but not limited to, information communications about your class bookings or other appointments with us and communications relating to the management of your membership).
Third-Party Marketing
UCS Active does not share your data with Third Parties for Marketing purposes.
Change of Purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Sharing your Personal Data
We do not sell or share your personal data with other organisations for their marketing purposes. We only share your personal data as explained in this privacy notice.
We may share your personal data (for the purposes set out in the table above explaining our use of your personal data) with external third parties (such as EZ Runner and BACS) who perform certain functions on our behalf or provide us with services to enable us to deliver our products and services and manage our business. The services these third parties provide include our membership management system, payment processing and debt collection services, communication distribution services and marketing and data analysis services.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law, including putting in place appropriate contractual obligations and protections. We do not allow our third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes for which we engage them and in accordance with our instructions.
Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Data Retention
We will only retain your personal data for as long as necessary to fulfil the purposes outlined in the table above. By law we have to keep basic
information about our customers (including Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you want to exercise any of the rights set out below, please contact the Data Protection Officer at gary.kruse@ucsactive.org.uk or call 0207 433 2127. Your legal rights include:
Request access to your personal data (commonly known as a “data subject access request”).
Request correction of any incomplete or inaccurate personal data that we hold about you.
Request erasure of your personal data where we no longer need it for the purposes for which it was collected. Object to processing we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms
Request restriction of processing of your personal data.
Request the transfer of your personal data to you or to a third party where this is technically feasible.
Withdraw consent at any time where we are relying on consent to process your personal data.
Please note that, whilst UCS Active will make every effort to fulfil its legal obligations under these rights, there may be instances where we may not be able or required to comply with your requests due to specific legal obligations, or where we can demonstrate a compelling legitimate interest to continue to process your data which overrides your rights and freedoms. In such circumstances, this will be communicated to you in writing (please see Time Limit to Respond below).
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights).
What we may need from you
We may request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particu- larly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Complaints
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection (www.ico.org.uk). However, UCS Active would appreciate the opportunity to deal with any data protection issues arising, so please contact us in the first instance (see DPO contact details under Key Roles above).