1. Introduction

1.1    We are committed to safeguarding the privacy of our website visitors and service users; in this policy we explain how we will handle your personal data.

1.2    You are asked to agree to our use of cookies in accordance with the terms of this policy when you first visit our website.

  1. Credit

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

  1. 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 our legitimate interest, namely monitoring and improving our website and services.

3.3    We may process your account data ("account data"). The account data may include your name and email address. The source of the account data is you. The account 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.

3.4    We may process your information included in your personal profile on our website ("profile data"). The profile data may include your name, address, telephone number and email address. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is consent.

3.5    We may process your personal data that are provided in the course of the use of our services ("service data"). The service data may include your name, address, telephone number and email address. 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 our legitimate interest, namely the proper administration of our website and business.

3.6    We may process information that you post for publication on our website or through our services ("publication data"). The source of the publication data is you. The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is our legitimate interest, namely the proper administration of our website and business.

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

3.8    We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The source of the notification data is you. 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.

3.9    We may process information contained in or relating to any communication that you send to us ("correspondence data"). The source of the correspondence data is you. 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 interest, namely the proper administration of our website and business and communications with users.

3.10  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 incumbent upon us, or in order to protect your vital interests or the vital interests of another natural person.

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

  1. Providing your personal data to others

4.1    We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes.

4.2    Financial transactions relating to our website and services are handled by our payment services providers, Paypal. You can find information about the payment services providers' privacy policies and practices at https://www.paypalobjects.com/webstatic/ua/pdf/EU/privacy.pdf

4.3    In addition to the specific disclosures of personal data set out in this Section 4, we may also disclose your personal data where that disclosure is necessary to comply with a legal obligation incumbent upon us, or in order to protect your vital interests or the vital interests of another natural person.

  1. 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    The hosting facilities for our website are situated in New York (USA) by Hawkhost. The European Commission has made an "adequacy decision" with respect to the data protection laws of that country. Transfers to that country will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.  https://support.hawkhost.com/index.php?/Knowledgebase/Article/View/192/0/general-data-protection-regulation

5.3    The email processing facilities for our website are situated in Chicago (USA) by Postmark. The European Commission has made an "adequacy decision" with respect to the data protection laws of that country. Transfers to that country will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission. Security and compliance for Postmark can be found at the following; https://postmarkapp.com/support/article/917-is-postmark-secure-and-redundant and https://postmarkapp.com/eu-privacy#summary

5.4    You acknowledge that personal data that you submit for publication through our website or services may be accessible via the internet around the world. We cannot prevent the use (or misuse) of that personal data by others.

  1. Retaining and deleting personal data

6.1    This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

6.2    Personal data that we process for any purpose will not be kept for longer than is necessary for that purpose.

6.3    Unless we explain otherwise to you, we will hold your information based on the following criteria:

(a)    for as long as we have reasonable business needs, such as managing our relationship with you and managing our operations; and/or

(b)    for as long as we provide services to you and then for as long as someone could bring a claim against us.

6.4   Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary to comply with a legal obligation incumbent upon us or regulatory guidance applicable to us, or in order to protect your vital interests or the vital interests of another natural person.

  1. 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.

  1. Your rights

8.1    In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

8.2    Your principal rights under data protection law are:

(a)    the right to access;

(b)    the right to rectification;

(c)    the right to erasure;

(d)    the right to restrict processing;

(e)    the right to object to processing;

(f)    the right to data portability;

(g)    the right to complain to a supervisory authority; and

(h)    the right to withdraw consent.

8.3    You have the right to have it confirmed whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access your personal data by visiting https://www.highglide.co.uk/your-profile/profile?layout=edit when logged into the website.

8.4    You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

8.5    In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed; you withdraw consent to consent-based processing; the processing is for direct marketing purposes; or the personal data has been unlawfully processed. However, there are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

8.6    In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

8.7    You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for the performance of a task carried out in the public interest or in the exercise of any official authority vested in us, or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

8.8    You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

8.9    You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

8.10  To the extent that the legal basis for our processing of your personal data is consent and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

8.11  If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

8.12  To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

8.13  You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this Section 8.

  1. 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.

  1. 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)    status - we use cookies to help us to determine if you are logged into our website;

(c)    personalisation - we use cookies to store information about your preferences and to personalise the website for you;

(d)    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;

(f)    analysis - we use cookies to help us to analyse the use and performance of our website and services; and

(g)    cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally.

  1. 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

  1. 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-cookies-website-preferences (Firefox);

(c)    http://www.opera.com/help/tutorials/security/cookies/ (Opera);

(d)    https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-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-and-privacy (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.

  1. Our details

13.1  This website is owned and operated by Highland Gliding Club Ltd.

13.2  We are a company limited by guarantee, registered in Scotland under registration number SC 155807, and our registered office is at 3 Station Road, Keith, Scotland AB55 5BU.

13.3  Our principal place of business is at Easterton Airfield, Birnie, Elgin, Scotland.

13.4  You can contact us:

(a)    by post, using the registered office address given above;

(b)    using our website contact form;

(c)    by telephone, on the contact number published on our website from time to time, when flying operations are active (normally weekends); or

(d)    by email, using the email address published on our website from time to time.

  1. Data protection officer

We have a dedicated data protection officer ("DPO"). You can contact the DPO by writing to us at our registered office address (see 13.2) marking your letter for the attention of the DPO, or by using the contact form on our website at https://www.highglide.co.uk/contactus/contact-data-protection-officer

Highland Gliding Club
Easterton Airfield
Birnie
Elgin
Scotland
United Kingdom
Tel - +44 (0) 1343 860272

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