Privacy policy

The purpose of the Policy

This policy (together with any other documents we refer to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

Who we are

“We” or “us” means 1610 Limited, a limited company (number 06727055) whose registered address is Trinity Sports & Leisure, Chilton Street, Bridgwater, TA6 3JA.

If you wish to contact us, please click here https://www.1610.org.uk/contact-us/

By contacting us, using our services, or visiting our website (our “site”), you are accepting and consenting to the practices described in this policy unless you inform us otherwise and we agree in writing to a variation of the Policy.

Who this policy applies to

This policy applies to both Customers and Users except as otherwise stated for interpretation, the following words have the following meanings:

“Customers” - any recipient of our services, whether it be directly provided by us or indirectly through a third party associate.

“Services” - any assistance we provide to you, including but not limited to; membership support; advice; access to and use of facilities and activities information etc.

“Web Visitors” - anyone visiting our site.

Information we collect from you

We may collect and process the following data about you:

Information you give us

You may give us information about you by filling in forms on our site or by corresponding with us by phone, e-mail or otherwise. This includes information you provide if you register to use our site, subscribe to our service, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, and when you contact us. The information you give us may include your name, address, e-mail address and phone number, employer, financial information, physical ability, medical history and current health conditions, and personal description.

Information we collect about you

We collect the following information for Web Visitors and Customers:

• technical information, including the Internet Protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
• information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (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.

For Customers only, we may also collect some or all of the following:

• name, salutation, gender;
• employer, employment status;
• contact details (including, but not limited to, telephone number; email address; social media handle; etc.);
• your physical ability, medical history and current health conditions.

Information we receive from other sources

For Web Visitors and Customers - We also work with third parties (including, for example, business partners, sub-contractors, advertising networks, analytics providers, and search information providers) and may receive information about you from them. The information we receive from these third parties will be information that they have collected from you.

For Customers only - We may receive information about you from third parties such as your employer or medical professional. Certain equipment we offer for use can collect your personal data. When that data is collected from you, you should be informed by those third parties at that stage that it may be shared internally by us and combined with data collected from multiple sources.

Uses made of the information

We use information held about you in the following ways:

Information you give to us.

We will use this information to:

• to notify you about changes to our service;
• to ensure that content from our site is presented in the most effective manner for you and for your device;
• to tailor our services and membership offerings to your requirements.

Where you have indicated to us that you are happy for us to do so, we may also use this information:

• to provide you with information about other services we offer that are similar to those that you have already enquired about or receive from us; and
• 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 by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please leave the relevant box blank situated on the form on which we collect your data.

Information we collect about you

Examples of how we will use this information include (but are not limited to);

• to administer our services and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to improve our site to ensure that content is presented in the most effective manner for you and for your device;
• to allow you to participate in interactive features of our services, when you choose to do so;
• as part of our efforts to keep our services, site and premises safe and secure;
• to measure or understand the effectiveness of our service.

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).

Disclosure of your information

You agree that we can share your personal information with:

• For Customers only - our suppliers and sub-contractors for the performance of any contract we enter into with them to allow us to provide services to you, and only where they are under a duty to deal with your personal data in accordance with the Data Protection Act 1998 and the General Data Protection Regulation ((EU) 2016/679); and
• For Web Visitors only - analytics and search engine providers that assist us in the improvement and optimisation of our site.

Covid 19 - Test and Trace

1610 will store, and provide on request, attendance and associated contact information to the Government’s Test and Trace authorities to assist them in identifying those who may have come into contact with Covid-19 infected individuals. Any personal data used solely for Test and Trace will only be retained for 21 days.

We use third party processors and as such may share your information with them. The processing of this information will be in line with the third parties privacy policy. The third party processors we use are as follows:

We may also disclose your personal information to other third parties not listed in this policy:

• 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.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use or terms and conditions of supply of services and other agreements; or to protect the rights, property, or safety of 1610 Limited, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
• For Customers only - to provide our Services.

Anonymous disclosure of information

We may share information in fully anonymised form

Please rest assured this type of sharing of data will only be in anonymised format and you will not be identifiable from the collated data we disclose.

Where we store your personal data

The data that we collect from you will be stored within the UK. By providing us with your personal data, you agree to this storing and/or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

All information you provide to us is stored on our secure servers or on secure servers operated by a third party. Third Parties we work with may transfer your data outside of the EEA, and if they do we will ask them to ensure it is treated in accordance with the UK law. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of data and information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Your rights

You have the right to ask us not to process your personal data for marketing purposes. We will ask for your permission before collecting your data if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. If you have given us permission to disclose information about you to a third party, you may revoke that permission at any time by contacting us.

You have the right to request any of the following; we ask that you send such requests to our contact details as listed above:

• Right to Access – to access all the data we hold about you;
• Right to Erasure – that we erase all data we hold about you, if the data is no longer being used for the purposes you have consented to or if you revoke your consent as above.
• Right to Data Portability – to easily copy or transfer the data we hold about you from us to another service provider.

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites 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.

Data retention

We will not store your data for any longer than is necessary.

For Customers only - If you are a user of our services, then your information will be held for as long as you continue to use our services.

If you cease to use our services, your personal data maybe anonymised for statistical purposes and then archived. We will store your data for up to 7years of the date you stop using our services.

Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

Updated Jan 2023