Privacy policy

1. Introduction

1.1 We are committed to safeguarding the privacy of our website visitors and
service users.

1.2 This policy applies where we are acting as a data controller with respect to
the personal data of our website visitors and service users; in other words,
where we determine the purposes and means of the processing of that
personal data.

1.3 By using our website and agreeing to this policy, you consent to our use of
cookies in accordance with the terms of this policy.

1.4 In this policy, "we", "us" and "our" refer to Snowdonia Watersports Ltd.

2. Credit

2.1 This document was created using a template from SEQ Legal (https://
seqlegal.com).

3. How we use your personal data

3.1 In this Section 3 we have set out:

(a) the general categories of personal data that we may process;
(b) the purposes for which we may process personal data; and
(c) the legal bases of the processing.

3.2 We may process data about your use of our website and services ("usage
data"). The usage data may include your IP address, geographical location,
browser type and version, operating system, referral source, length of visit,
page views and website navigation paths, as well as information about the
timing, frequency and pattern of your service use. The source of the usage
data is our analytics tracking system. This usage data may be processed for
the purposes of analysing the use of the website and services. The legal basis
for this processing is consent.

3.3 We may process your personal data that are provided in the course of the use
of our services ("service data”). The source of the service data is you or
your employer. The service data may be processed for the purposes of
operating our website, providing our services, ensuring the security of our
website and services, maintaining back-ups of our databases and
communicating with you. The legal basis for this processing is consent OR our
legitimate interests, namely the proper administration of our website and
business OR the performance of a contract between you and us and/or taking
steps, at your request, to enter into such a contract.

3.4 We may process information contained in any enquiry you submit to us
regarding goods and/or services ("enquiry data"). The enquiry data may be
processed for the purposes of offering, marketing and selling relevant goods
and/or services to you. The legal basis for this processing is consent.

3.5 We may process information that you provide to us for the purpose of
subscribing to our email notifications and/or newsletters ("notification
data"). The notification data may be processed for the purposes of sending
you the relevant notifications and/or newsletters. The legal basis for this
processing is consent.

3.6 We may process information contained in or relating to any communication
that you send to us ("correspondence data"). The correspondence data
may include the communication content and metadata associated with the
communication. Our website will generate the metadata associated with
communications made using the website contact forms. The correspondence
data may be processed for the purposes of communicating with you and
record-keeping. The legal basis for this processing is our legitimate interests,
namely the proper administration of our website and business and
communications with users.

3.7 We may process any of your personal data identified in this policy where
necessary for the establishment, exercise or defence of legal claims, whether
in court proceedings or in an administrative or out-of-court procedure. The
legal basis for this processing is our legitimate interests, namely the
protection and assertion of our legal rights, your legal rights and the legal
rights of others.

3.8 In addition to the specific purposes for which we may process your personal
data set out in this Section 3, we may also process any of your personal data
where such processing is necessary for compliance with a legal obligation to
which we are subject, or in order to protect your vital interests or the vital
interests of another natural person.

3.9 Please do not supply any other person's personal data to us, unless we
prompt you to do so.

4. Providing your personal data to others

4.1 We may disclose your personal data to any member of our group of
companies (this means our subsidiaries, our ultimate holding company and all
its subsidiaries) insofar as reasonably necessary for the purposes, and on the
legal bases, set out in this policy.

4.2 We may disclose your personal data to our insurers and/or professional
advisers insofar as reasonably necessary for the purposes of obtaining or
maintaining insurance coverage, managing risks, obtaining professional
advice, or the establishment, exercise or defence of legal claims, whether in
court proceedings or in an administrative or out-of-court procedure.

4.3 Financial transactions relating to our website and services are OR may be
handled by our payment services providers, Stripe, Barclaycard and/or
Paypal. We will share transaction data with our payment services providers
only to the extent necessary for the purposes of processing your payments,
refunding such payments and dealing with complaints and queries relating to
such payments and refunds. You can find information about the payment
services providers' privacy policies and practices at the respective websites on
the three above providers.

4.4 We may disclose your enquiry data to one or more of those selected third
party suppliers of goods and services identified on our website for the
purpose of enabling them to contact you so that they can offer, market and
sell to you relevant goods and/or services. Each such third party will act as a
data controller in relation to the enquiry data that we supply to it; and upon
contacting you, each such third party will supply to you a copy of its own
privacy policy, which will govern that third party's use of your personal data.
We would only do the above with your express permission.

4.5 In addition to the specific disclosures of personal data set out in this Section

4, we may disclose your personal data where such disclosure is necessary for
compliance with a legal obligation to which we are subject, or in order to
protect your vital interests or the vital interests of another natural person. We
may also disclose your personal data where such disclosure is necessary for
the establishment, exercise or defence of legal claims, whether in court
proceedings or in an administrative or out-of-court procedure.

5. International transfers of your personal data

5.1 In this Section 5, we provide information about the circumstances in which
your personal data may be transferred to countries outside the European
Economic Area (EEA).

5.2 N/A - No facilities outside UK

5.3 The hosting facilities for our website are situated in UK

5.4 Google Analytics are situated in the USA. The European Commission has
made an "adequacy decision" with respect to the data protection laws of each
of these countries. Further information on Google Website https://
privacy.google.com/businesses/compliance/

6. Retaining and deleting personal data

6.1 Personal data that we process for any purpose or purposes shall not be kept
for longer than is necessary for that purpose or those purposes.

7. Amendments

7.1 We may update this policy from time to time by publishing a new version on
our website.

7.2 You should check this page occasionally to ensure you are happy with any
changes to this policy.

7.3 We may notify you of changes to this policy by email or through the private
messaging system on our website.

8. Your rights

8.1 You may instruct us to provide you with any personal information we hold
about you; provision of such information will be subject to:
(a) We will provide a copy of the information free of charge. However, we can
charge a ‘reasonable fee’ when a request is manifestly unfounded or
excessive, particularly if it is repetitive.
(b) the supply of appropriate evidence of your identity (for this purpose, we will
usually accept a photocopy of your passport certified by a solicitor or bank
plus an original copy of a utility bill showing your current address).

8.2 We may withhold personal information that you request to the extent
permitted by law.

8.3 You may instruct us at any time not to process your personal information

8.4 In practice, you will usually either expressly agree in advance to our use of
your personal information for marketing purposes, or we will provide you with
an opportunity to opt out of the use of your personal information for
marketing purposes.

9. About cookies

9.1 A cookie is a file containing an identifier (a string of letters and numbers) that
is sent by a web server to a web browser and is stored by the browser. The
identifier is then sent back to the server each time the browser requests a
page from the server.

9.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent
cookie will be stored by a web browser and will remain valid until its set
expiry date, unless deleted by the user before the expiry date; a session
cookie, on the other hand, will expire at the end of the user session, when
the web browser is closed.

9.3 Cookies do not typically contain any information that personally identifies a
user, but personal information that we store about you may be linked to the
information stored in and obtained from cookies.

10. Cookies that we use

10.1 We use cookies for the following purposes:
(a) authentication - we use cookies to identify you when you visit our
website and as you navigate our website.
(b) security - we use cookies as an element of the security measures used
to protect user accounts, including preventing fraudulent use of login
credentials, and to protect our website and services generally.
(c) analysis - we use cookies to help us to analyse the use and
performance of our website and services; and
(d) cookie consent - we use cookies to store your preferences in relation to
the use of cookies more generally.

11. Cookies used by our service providers

11.1 Our service providers use cookies and those cookies may be stored on your
computer when you visit our website.

11.2 We use Google Analytics to analyse the use of our website. Google Analytics
gathers information about website use by means of cookies. The information
gathered relating to our website is used to create reports about the use of our
website. Google's privacy policy is available at: https://www.google.com/
policies/privacy/.

12. Managing cookies

12.1 Most browsers allow you to refuse to accept cookies and to delete cookies.
The methods for doing so vary from browser to browser, and from version to
version. You can however obtain up-to-date information about blocking and
deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookieswebsite-preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internetexplorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-andprivacy (Edge).

12.2 Blocking all cookies will have a negative impact upon the usability of many
websites.

12.3 If you block cookies, you will not be able to use all the features on our
website.

13. Our details

13.1 This website is owned and operated by Snowdonia Watersports Ltd.

13.2 We are registered in England and Wales under registration number: 10451271, and our registered office is at Clegyr, Llanaelhaearn,
Caernarfon, Gwynedd LL54 5AD.

13.3 Our principal place of business is at Unit 2, Y Glyn, Llanberis, Caernarfon,
Gwynedd LL55 4EL.

13.4 You can contact us:

(a) by post, to the postal address given above;
(b) using our website contact form;
(c) by telephone, 01286 879001; or
(d) by email, using [email protected]
14. Data protection officer
14.1 Our data protection officer's contact details are: Chris Thorne,
[email protected]