Privacy Policy
PSC Website Privacy Policy
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Effective from August 26, 2020
1. Please read carefully
Porthmadog Sailing Club cares deeply about the privacy of visitors to its website and members. To that end, this Privacy Policy (“Privacy Policy”) describes how Porthmadog Sailing Club (“Porthmadog Sailing Club”, “PSC”, “we”, “our”, or “us”), collect, use, and share your Personal Information, as well as an explanation of the data rights you may have in that Personal Information. This Privacy Policy applies to all sailing-club.org users, including unregistered visitors, registered users, and club members of all membership types (collectively, “Users”, “you”, or “your”), and to all PSC services, including our website (including www.sailing-club.org and any of its subdomains, the “Website”), mobile applications (“Mobile Apps”, “Wix App”, “PorthmadogSC”), and related services (collectively, the “Services”). This Privacy Policy is not intended to override the terms of any contract you have with us, nor any rights you may have under other applicable data privacy laws.
Prior to accessing or using our Services, please read this policy and make sure you fully understand our practices in relation to your Personal Information. If you read and fully understand this Privacy Policy, and remain opposed to our practices, you must immediately leave and discontinue all use of any of our Services. If you have any questions or concerns regarding this policy, please contact us at webmaster@sailing-club.org.
2. What Personal Information do we collect
2.1. User Information:
To provide you the Services, we must collect Personal Information relating to an identified or identifiable natural person (“Personal Information”). We collect Personal Information you provide us, from your use of the Services, and from other sources. Here are the types of Personal Information we collect about you:
2.1.1 Information you provide us. When you register for our Services, purchase and/or renew Club memberships, use any of our Services; and/or when you contact us directly by any communication channel (e.g., PSC’s website, emails, phone calls with Committee members), you may provide us Personal Information, such as name, email address, phone number, payment information, information you include in your communications with us, and Personal Information contained in scanned identification documents (such as an ID card, driver’s license, passport, or official company registration documents).
2.1.2 Information we collect when you use the Services. When you visit, download, and/or use any of our Services, we may collect aggregated usage Personal Information, such as Visitors’ and Members’ browsing and ‘click-stream’ activity on the Services, session heatmaps and scrolls, non-identifying Personal Information regarding the Visitor’s or Member’s device, operating system, internet browser, screen resolution, language and keyboard settings, internet service provider, referring/exit pages, date/time stamps, etc
2.1.3 Information we collect from other sources. We may receive Personal Information about you from third-party sources, such as
2.1.3.1 security providers, fraud detection and prevention providers for example to help us screen out users associated with fraud
2.1.3.2 social media platforms – we do not collect Personal Information from your usage of social media platforms, or share your Personal Information with any social media platforms
2.1.3.3 advertising and marketing partners in order to monitor, manage and measure our ad campaigns.
2.2 Collection of Personal Information by Wix.com
2.2.1 Wix.com may also collect Personal Information pertaining to website Visitors and Members, solely for and on PSC’s behalf.
2.2.2 Members who download the Wix app are deemed by Wix to have a separate relationship directly with Wix and thus not governed by this Privacy Policy.
2.3 PSC Membership Enquiry and Application Form Information
2.3.1 We also collect information that is provided to us by prospective PSC Members (“Applicants”), when they either enquire about membership or apply for membership, by e-mail or by using the forms on the website.
3 Why do we collect such Personal information
We use your Personal Information for the following purposes:
3.1 To provide and operate the Services;
3.2 To further develop, customize, expand, and improve our Services, based on Members’ common or personal preferences, experiences and difficulties;
3.3 To provide our Members with ongoing assistance and technical support;
3.4 To be able to contact our Users with general or personalised service-related notices and promotional messages (as further detailed in Section 8 below);
3.5 To help us to update, expand and analyse our records to identify new Members;
3.6 To facilitate, sponsor, and offer certain events, and promotions, determine participants’ eligibility, monitor performance, contact winners, and grant prizes and benefits;
3.7 To create aggregated statistical data and other aggregated and/or inferred information, which we may use to provide and improve our Services;
3.8 To enhance our data security and fraud prevention capabilities; and
3.9 To comply with any applicable laws and regulations.
We use your Personal Information for the purposes set out in Section 3 where:
3.10 Our use of your Personal Information is necessary to perform a contract or to take steps to enter into a contract with you (e.g. annual membership renewals, winter storage of cruisers);
3.11 Our use of your Personal Information is necessary to comply with a relevant legal or regulatory obligation that we have; or
3.12 Our use of your Personal Information is necessary to support legitimate interests and business purposes (for example, to maintain and improve our Services by identifying technical issues), provided it is conducted in a way that is proportionate and that respects your privacy rights.
4 How we share your Personal Information
We may share your Personal Information with service providers and others (or otherwise allow them access to it) in the following manners and instances:
Third Party Service Providers: PSC has partnered with a number of selected service providers, whose services and solutions complement, facilitate and enhance our own. These include hosting and server co-location services, communications and content delivery networks (CDNs), data and cyber security services, billing and payment processing services, fraud detection and prevention services, e-mail distribution and monitoring services, performance measurement, data optimization providers, content providers, and our legal and financial advisors (collectively, “Third Party Service Provider(s)”).
PSC may share the following categories of Personal Information with Third Party Service Providers for a business purpose:
· identifiers, including name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, or other similar identifiers
4.1 Law Enforcement, Legal Requests and Duties: PSC may disclose or otherwise allow access to your Personal Information pursuant to a legal request, such as a subpoena, legal proceedings, search warrant or court order, or in compliance with applicable laws, if we have a good faith belief that the law requires us to do so, with or without notice to you.
4.2 Protecting Rights and Safety: PSC may share your Personal Information if we believe in good faith that this will help protect the rights, property or personal safety of PSC, any Members, or any member of the general public, with or without notice to you.
4.3 Social Media Features and Framed Pages:
4.3.1 Our website and services deliberately exclude certain Social Media features, widgets, and single sign on features that are present on other websites and services, such as the “Facebook Connect,” “Google Sign-in,” “Facebook Like”, or “Share this” button or other interactive mini-programs (“Social Media Features”).
4.3.2 Our Services may enable you to share your Personal Information with third parties directly, such as via page framing techniques to serve content to or from Third-Party Service Providers or other parties, while preserving the look and feel of our Website and Services (“Frames”). Please be aware that if you choose to interact or share any Personal Information via such Frames, you are in fact providing it to these third parties and not to us, and such interactions and sharing are governed by those third parties’ policies and not ours. Examples of framed pages on the PSC website are
4.3.2.1 Tide timetables feature for downloading pdfs
4.3.2.2 PSC Weather Station
4.3.2.3 PSC on YouTube
4.4 Connection with a Change in Control: In addition, should PSC undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your Personal Information may be shared with the parties involved in such event.
4.5 Upon Your Further Direction: PSC may also share your Personal Information with third parties for other purposes upon your further direction or with your explicit approval.
5 Where do we store your Personal Information?
Members’ Personal Information may be stored by Wix.com in data centres located in the United States of America, Ireland, Japan and Israel. Wix.com may use other jurisdictions as necessary for the proper delivery of PSC Services and/or as may be required by law (as further explained below).
Porthmadog Sailing Club is based in The United Kingdom, which is considered by the European Commission to be offering an adequate level of protection for the Personal Information of EU Member State residents.
PSC affiliates and Third-Party Service Providers that store or process your Personal Information on PSC’s behalf are contractually committed to keep it protected and secured, in accordance with industry standards and regardless of any lesser legal requirements which may apply in their jurisdiction.
5.1 Transfer of EU Personal data : If you are located in Europe, when we will transfer your Personal Information to the United States or anywhere outside Europe, we will make sure that (i) there is a level of protection deemed adequate by the European Commission or (ii) that the relevant Model Standard Contractual Clauses are in place.
6 Use of PSC Members’ Personal Information by Wix
Wix may collect, store and process certain Personal Information of PSC Members, solely on PSC’s behalf and at our direction. For example, PSC has imported their e-mail contacts from third-party services like Gmail, imported the Membership database previously held offline by the Membership Secretary, and otherwise collected and managed contacts via the Website. Such contacts are then stored with Wix, on PSC’s behalf.
For such purposes, Wix serves and shall be considered as a “Processor” and not as the “Controller” (as both such capitalized terms are defined in the European Union General Data Protection Regulation (“GDPR”)) of such Users-of-Users Information.
PSC is considered as the “Controller” of such PSC Members’ Information and is responsible for complying with all laws and regulations that may apply to the collection and control of such Members’ Information, including all privacy and data protection laws of all relevant jurisdictions.
The Processing of the PSC Members’ Personal Information shall take place within the territory of the European Union, Israel or a third country, territory or one or more specified sectors within that third country of which the European Commission has decided that it ensures an adequate level of protection and such processing and transfer will be in accordance to the Data Processing Agreement – Users (“DPA"). Any transfer to and Processing in a third country outside the European Union that does not ensure an adequate level of protection according to the European Commission, shall be undertaken in accordance with the Standard Contractual Clauses (2010/87/EU) set out in Annex 1of the DPA. For the sake of clarity, “Processing” should be understood as per the definition provided in the DPA.
PSC is responsible for the security, integrity and authorized usage of Personal Information about PSC Members and for obtaining consents, permissions and providing any required data subject rights and fair processing notices required for the collection and usage of such Personal Information.
Wix cannot provide legal advice to PSC or PSC Members, however Wix do recommend that we publish and maintain clear and comprehensive privacy policies on their our Website in accordance with any applicable laws and regulations, and that all PSC Members carefully read those policies and make sure that they understand and, to the extent required by applicable law, consent to them.
If you are a visitor or a Member of PSC, please read the following: Wix has no direct relationship with PSC Members whose Personal Information it processes. If you are a visitor or a member of PSC and would like to make any requests or queries regarding your Personal Information, please contact PSC directly. For example, if you wish to request to access, correct, amend, or delete inaccurate Personal Information processed by Wix on behalf of PSC, please direct your query to PSC (who is the “Controller” of such data). If Wix is requested by PSC to remove any PSC Members’ Personal Information, we will respond to such requests in a timely manner upon verification and in accordance with applicable law (for example, thirty (30) days under the GDPR). Unless otherwise instructed by PSC, Wix will retain PSC Members’ Personal Information for the period set forth in Section 11 below.
7 Use of cookies and other third-party technologies
We and our Third-Party Service Providers use cookies and other similar technologies (“Cookies”) in order for us to provide our Service and ensure that it performs properly, to analyse our performance, and to personalize your experience.
You can learn more about how we use cookies and similar technologies and how you can exercise control over them in our Cookie Policy (Bosun’s Shed / Rules on the website).
Please note that we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, however, most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.
8 Communications from PSC
8.1 Promotional Messages: We may use your Personal Information to send you promotional content and messages by e-mail, text messages, notifications within the website or the Wix app and similar forms of communication from PSC or our partners (acting on PSC’s behalf) through such means. If you do not wish to receive such promotional messages or calls, you may notify PSC at any time or follow the “unsubscribe” or STOP instructions contained in the promotional communications you receive.
8.2 Service and Billing Messages: PSC may also contact you with important information regarding our Services, or your use thereof. For example, we may send you a notice (through any of the means available to us) if a certain Service is temporarily suspended for maintenance; reply to your request for support or e-mail; send you reminders or warnings regarding upcoming or late payments for your current or upcoming subscriptions; or notify you of material changes in our Services. It is important that you are always able to receive such messages. For this reason, you are not be able to opt-out of receiving such Service and Billing Messages unless you are no longer a PSC Member.
9 Your rights in relation to your Personal Information
PSC agrees that it is imperative that you have control over your Personal Information. Pursuant to privacy regulations worldwide, PSC has taken steps to enable you to request access to, receive a copy of, update, amend, delete, or limit the use of your Personal Information.
Before fulfilling your request, we may ask you for additional information in order to confirm your identity and for security purposes. We reserve the right to charge a fee where permitted by law (e.g. if your request is unfounded or excessive).
You have the right to file a complaint with your local supervisory authority for data protection (but we still recommend that you contact us first).
If you are a PSC Member, and you wish to receive a copy, access and/or request us to make corrections to the Personal Information that you have stored with us or wish to request a list of what Personal Information (if any) pertaining to you we disclosed to third parties for direct marketing purposes, please contact the PSC webmaster. We will make reasonable efforts to honour your request promptly (unless we require further information from you in order to fulfil your request), subject to legal and other permissible considerations.
10 Questions and Complaints
If you have any questions or concerns about our collection, use or disclosure of Personal Information, or if you believe that we have not complied with this Privacy Policy or applicable data protection laws, please contact us – our details are set out at the end of this Privacy Policy.
Our Data Protection Officer team will investigate the complaint and determine whether a breach has occurred and what action, if any, to take. We take every privacy complaint seriously and will make all reasonable efforts to resolve your complaint promptly and in accordance with applicable law.
You can file a complaint with your local supervisory authority for data protection at any time, however we recommend that you contact us first so we can try to resolve it.
11 Data Retention
We may retain your Personal Information for as long as your PSC Membership is active, as indicated in this Privacy Policy, or as otherwise needed to provide you with our Services.
We may continue to retain your Personal Information after you resign your PSC Membership and/or cease to use any particular Services, as reasonably necessary to comply with our legal obligations, to resolve disputes regarding other PSC Members, prevent fraud and abuse, enforce our agreements and/or protect our legitimate interests.
We maintain a data retention policy which we apply to Personal Information in our care.
12 Security
PSC has implemented security measures designed to protect the Personal Information you share with us, including physical, electronic and procedural measures. Among other things, we offer HTTPS secure access to most areas on our Services; the transmission of sensitive payment information (such as a credit card number) through our Shop, Invoices and Subscriptions is protected by an industry standard SSL/TLS encrypted connection; and Wix.com regularly maintain a PCI DSS (Payment Card Industry Data Security Standards) certification. We also regularly monitor our systems for possible vulnerabilities and attacks, and regularly seek new ways and Third Party Services for further enhancing the security of our Services and protection of our Visitors’ and Members’ privacy.
Regardless of the measures and efforts taken by PSC, we cannot and do not guarantee the absolute protection and security of Members’ Personal Information, or any other information you upload, publish or otherwise share with PSC or anyone else. We encourage you to set strong passwords when you register for your account on the PSC Website, and avoid providing us or anyone with any sensitive Personal Information of which you believe its disclosure could cause you substantial or irreparable harm.
Furthermore, because certain areas on our Services are less secure than others (for example, if you set a Post to be “Public”, or if you browse to a non-SSL page), and since e-mail and instant messaging are not recognized as secure forms of communications, we request and encourage you not to share any Personal Information on any of these areas or via any of these methods.
If you have any questions regarding the security of our Services, you are welcome to contact us at privacy@sailing-club.org.
13 Third-Party Websites
Our Services may contain links to other websites or services. We are not responsible for such websites’ or services’ privacy practices. We encourage you to be aware when you leave our Services and to read the privacy statements of each and every website and service you visit before providing your Personal Information. This Privacy Policy does not apply to such linked third-party websites and services.
14 Public and restricted-access forums and Member content
Our Services offer both publicly accessible and restricted-access forms of blogs and forums on the website, in PSC presentations, newsletters, social media and video-sharing sites. Please be aware that any Personal Information you provide in any such areas may be read, collected, and used by others who have access them. To request removal of your Personal Information from any of our Services, feel free to contact us at privacy@sailing-club.org.
In accordance with the PSC Declaration, photographs or video recordings that carry information with which a PSC Member under the age of 18 can be identified must not be shared on any PSC Service.
Notwithstanding and without prejudice to all other terms in this Privacy Policy, the PSC webmaster reserves the right to moderate, edit and/or remove any content shared on the PSC website. If you feel this has been enacted unfairly then please contact the Commodore to appeal.
15 Updates and interpretation
We may update this Privacy Policy as required by applicable law, and to reflect changes to our Personal Information collection, usage and storage practices. If we make any changes that we deem as “material” (in our sole good faith discretion), we will notify you prior to the change becoming effective. In relation to any updated Privacy Policy, we will, as required by applicable law, notify you, seek your consent and/or take any other measures. We encourage you to periodically review this page for the latest Information on our privacy practices. Unless stated otherwise, our most current Privacy Policy applies to all information that we have about you, with respect to our Website, PSC Apps, Mobile Apps and other Services.
Any heading, caption or section title contained herein is provided only for convenience, and in no way defines or explains any section or provision hereof, or legally binds any of us in any way.
This Privacy Policy was written in English, and may be translated into other languages for your convenience. You may access and view other language versions by changing your PSC Website language settings. If a translated (non-English) version of this Privacy Policy conflicts in any way with its English version, the provisions of the English version shall prevail.
16 Contacting us
If you have any questions about this Privacy Policy or wish to exercise any of your rights as described in Sections 12 or 14 please refer to those sections or contact the Data Protection Officer team at privacy@sailing-club.org. We will attempt to resolve any complaints regarding the use of your Personal Information in accordance with this Privacy Policy.
You may also contact us by post at:
· Porthmadog Sailing Club, The Harbour, Porthmadog, Gwynedd. LL49 9AY