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Privacy policy

Purpose of this Privacy Policy

This Privacy Policy aims to give you information on how we, ACG Strathallan collect and process your personal data through your use of our website, including any data you may provide through our website when you sign up to receive our marketing materials, purchase any of our products or services.

By voluntarily providing us with your personal data, registering for one of our events, purchasing one of our products or services or using our website, you are deemed to have agreed to the terms of this Privacy Policy.

It is important that you read this Privacy Policy together with any other privacy notice on our website from time to time so that you are fully aware of how and why we are using your data.

How is Your Personal Data Collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your: identity data, contact data, transaction data, financial data and marketing and communications data by filling in forms on our website or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you apply for one of our products or services.
  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

How we use Your Personal Data

We 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 the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data, save where we explicitly ask for consent. You have the right to fully or partially withdraw consent to marketing at any time by contacting us.

We do not knowingly collect any information from children under the age of 16 unless and until the relevant consent and authorisation has been provided for a student under 16 to use the products and services and for us to collect information from such student.

Purposes for Which we will use Your Personal Data

We have set out below, in tabular form, the ways in which we may use your personal data, and which of the legal bases we rely on to do so. Where appropriate, we have also identified our legitimate interests. Please note that we may process your data for more than one lawful ground depending on the circumstances and the specific purpose. Please contact us if you would like more detail about the specific legal ground which we are relying on to process your personal data, where more than one ground has been identified below. 

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest

To register you as a new customer

(a) Identity 
(b) Contact 
(c) Profile

Performance of a contract with you.

To process and fulfil your contract, including:

  • managing payments, fees and charges; and
  • managing your queries – this may include recording calls or communications with our teams.

(a) Identity 
(b) Contact
(c) Financial 
(d) Transaction 
(e) Marketing and Communications

Performance of a contract with you.

To collect and recover money owed to us in respect of your contract.

(a) Identity 
(b) Contact 
(c) Financial 
(d) Transaction

Performance of a contract with you.

To carry out fraud assessments

(a) Identity 
(b) Contact 
(c) Financial 
(d) Transaction
(e) Technical

Performance of a contract with you.

To notify you in relation to our legal obligations and documents, including changes to our terms or Privacy Policy

(a) Identity 
(b) Contact 
(c) Profile

Performance of a contract with you.

To help us improve our offering to our customers, including asking you to leave a review or take a survey, or provide customer insights

(a) Identity 
(b) Contact 
(c) Profile 
(d) Marketing and Communications

Necessary for our legitimate interests (to study how customers use our products/services, to improve our offering to our customers, to develop them and grow our business).

To enable you to partake in one of our awards or a competition

(a) Identity 
(b) Contact 
(c) Profile 
(d) Usage 
(e) Marketing and Communications

Performance of a contract with you to fulfil the promotion and run the awards/competition. We may also subsequently use your entries for the legitimate interests of understanding our customer base more effectively.

To administer and protect our business and websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity 
(b) Contact 
(c) Profile
(d) Technical

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise).

To deliver relevant website content, advertisements and other marketing material to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity 
(b) Contact 
(c) Profile
(d) Usage 
(e) Marketing and Communications
(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business to inform our marketing strategy and to improve our offering to you).

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical 
(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).

To make suggestions and recommendations to you about products or services that may be of interest to you

(a) Identity 
(b) Contact 
(c) Technical 
(d) Usage 
(e) Profile

Necessary for our legitimate interests (to develop our products/services and grow our business, and to improve our offering to you).

 

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional Offers From Us

We may use your identity, contact, technical, usage and profile datato form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased products (including publications) or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Opting Out

You can ask us to stop sending you marketing messages at any time by following the opt-out/unsubscribe links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, we will stop sending you marketing messages but we will continue to process your personal data if there are legitimate grounds for further processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly.

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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.  

If we need to use your personal data for an unrelated purpose, we will notify you first and provide you with information about that unrelated purpose.

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.

Disclosures of Your Personal Data

We may have to share your personal data with the parties set out below for the purposes set out in the table above – Purposes for Which we will use Your Personal Data:

  • Other companies in the group
  • External Third Parties as set out in the Glossary.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

We seek to ensure that all third parties respect the security of your personal data and to treat it in accordance with all applicable laws.

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.

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

How Long will you use my Personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any compliance, legal, accounting, or reporting requirements.

Your legal rights

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it, or if your personal data has been unlawfully processed. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) 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. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Submit a complaint to a supervisory authority if you think that any personal data relating to you has been processed in a way that is not permitted by this privacy policy or the law.

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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.  

If we need to use your personal data for an unrelated purpose, we will notify you first and provide you with information about that unrelated purpose. 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.