Privacy and cookies
Horizon Leisure Centres (‘The Borough of Havant Sport and Leisure Trust’) is committed to respecting the privacy of all visitor, members and customers to its website (the ‘website’).
What information does Horizon process?
From our general website
You may choose to provide personal information to us when you register with the website e.g. to register for online booking, sign up for a newsletter or ask us to contact you. You may be asked to provide certain information about yourself including your name, title, postal address, telephone number and/or email address. If you are registering for online booking, joining as a member or booking any classes you may also be asked to provide information about your health.
From call recordings
All calls involving external telephone numbers received or made are recorded for training and monitoring purposes.
We will not use any personal data obtained on a call recording for marketing purposes.
Call recordings are stored on a secure SSL encrypted platform and are deleted after 6 months.
Horizon do withhold the right to use call recordings as evidence in certain circumstances
From our specialist websites
We may also collect information automatically about your usage of our websites using cookies and other technology (for full details of what we use see the section below on “Cookies”). To that effect, we use your IP address (a series of numbers that identifies a computer on the internet) to collect, among other things, internet traffic data and data regarding your browser type and computer. If you do not want to receive cookies, you may reject them by using your browser settings provided they are not necessary for delivery of our website or services to visitors (for help with how to do this see the section below on “Cookies”).
If you seek to become a member, are provided with free advice about becoming a member or actually become a member, we will need information to confirm your identity e.g. your name, your date of birth, your address, as well as take a photograph of you for identification purposes. We may use this information as contact information for you and other parties. Advice on the information that we need to hold on you will be explained to you by a member of staff when you join.
If over the age of 18 you will be required to have a photograph taken for identification purposes at the time of joining as a member. If you are under 18 a parent or guardian will be required to consent to the photograph being taken when signing up for teen gym or teen workout classes.
We hold the right to refuse membership if no consent is given.
The photographs are only used to identify the account holder and the one looking to gain access to the gym and will NOT be used for any other purpose.
From third parties
We may also receive information about you from third parties such as our direct debit provider, through a medical referral from your GP or through our employment portal on the website.
Horizon have CCTV cameras throughout its centres for the purposes of crime prevention and health and safety and as such we may view or use CCTV footage in this way should a crime take place in or around its centres. This footage can be shared with appropriate authorities should they request it.
How does Horizon use this information?
We will use your information for the specific purpose(s) for which it has been provided or collected by us e.g.:
to provide information that you may request regarding the services that we offer.
to contact you regarding our current promotions.
to contact you via push notification via our mobile app.
to comply with our statutory and regulatory obligations.
to book you onto a course or event.
to administer your application for a vacancy.
to deal with your feedback, query or complaint.
to contact you for your views on our services.
We also use your information to administer, support, improve and develop our business generally and to enforce our legal rights and will only be used if you positively choose to opt in to receiving these communications.
We may also use the information that we collect about you for marketing and hospitality purposes e.g.:
to provide communications about us and other services we provide that may be of interest to you e.g. sending you newsletters
to provide you with updates on relevant areas of interest within the business
to contact you about other activities and events that we may undertake
Information gathered through cookies and similar technologies are used to measure and analyse information on visits to our websites, to tailor the websites to make them better for visitors and to improve technical performance. We will not use the data to identify you personally or to make any decisions about you.
We must have a lawful basis for processing your information; this will vary on the circumstances of how and why we have your information but typical examples include:
the activities are within our legitimate interests as a sport, leisure and play provider to engage with and provide services to prospective and current customers and personnel
you have given consent for us to process your information e.g. in relation to certain marketing activities
we are carrying out necessary steps in relation to a membership to which you are party to or prior to you entering into a membership contract.
to protect your vital interests e.g. if you were unfortunate enough to fall ill or suffer an injury on our premises
If we process any special categories of information i.e. information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, processing of genetic or biometric data for the purpose of uniquely identifying individuals, health data, or data concerning your sex life or sexual orientation, we must have a further lawful basis for the processing. This may include:
where you have given us your explicit consent to do so e.g. to cater for your medical needs when joining as a member or through the GP referral scheme.
where the processing is necessary to protect your vital interests or someone else’s vital interests
you have made the information public
the processing being necessary for reasons of substantial public interest
If you become a member of Horizon Leisure Centres, we may use your personal information to invite you to promotional events or other in-centre promotions for customers and/or to send you information that we think may be of interest to you. This is within our legitimate interests to use your information in this way.
If you do not wish to receive any direct marketing material or communications after you submit or provide your details, please contact our Marketing team using the details below (stating UNSUBSCRIBE in the heading of any email message) indicating if you do not wish to be contacted for one or more of these marketing purposes and/or via particular forms of communication e.g. email or telephone. Please note that the preferences that you state will override any registrations you or your organisation may have with the relevant preference organisations (such as the telephone preference services).
If you change your mind about being contacted by us in the future, or change address, or if any information that we hold about you is inaccurate or out-of-date, please let us know by emailing firstname.lastname@example.org, completing an Opt Out form in one of our receptions areas or writing to our Marketing team at: Marketing Team, Horizon Leisure Centre, Civic Centre Road, Havant, Hants PO9 2AY.
We may tailor our marketing and hospitality communications to the interests of particular customers and contacts to ensure we provide information and invitations of interest and relevance to them.
Disclosure of your information
Some of the information you provide to Horizon will be held on our computers in the UK and will only be accessed by or given to our staff (or staff of Horizon related entities) working in the UK. Some of the information you provide Horizon may be transferred to, stored and processed by third party organisations which process data for us and on our behalf. These third parties may be based (or store or process information) in the UK or elsewhere including outside of the EEA. As with many companies, these third parties may include third party IT platforms (including cloud based platforms), suppliers of administrative and support services and suppliers of other specialist products.
We may also transfer your information to other organisations or professional advisers with whom we are working on customer matters or to whom we are referring you for additional or separate advice.
We may also be obliged to disclose data under certain laws or by order of court or other competent regulatory body or may be permitted to disclose it under applicable data protection laws.
A list of our third parties can be supplied by asking a customer services representative or emailing email@example.com and requesting a list of relevant third parties.
Protection of your information
We have in place administrative, technical and physical measures designed to guard against and minimise the risk of loss, misuse or unauthorised processing or disclosure of the personal information that we hold.
Where we transfer information to third parties to enable them to process it on our behalf, we ensure that the providers meet or exceed the relevant legal or regulatory requirements for transferring data to them and keeping it secure.
We will also ensure that where information is transferred to a country or international organisation outside of the UK / EEA, we will comply with the relevant legal rules governing such transfers.
We keep your personal information no longer than is necessary for the purpose for which it was collected. Information on our document retention policy is available upon written request.
Where we store your data
All information you provide to us is stored on our secure servers and is protected using industry standard secure (SSL) encryption technology. All servers owned and maintained by Horizon are based within the EU.
You have certain rights in relation to your personal information, although those rights will not apply in all cases or to all information that we hold about you. For example, we may need to continue to hold and process information to establish, exercise or defend our legal rights. Alternatively, the rights may not be enforceable until the General Data Protection Regulation comes into force on 25 May 2018. We will tell you if this is the case when you contact us.
You have the right to request that we:
Provide you with a copy of your personal information that we hold
Update your personal information where it is out-of-date or incorrect
Delete personal information that we hold
Restrict the way in which we process your information
Consider any valid objections to our processing of your personal information
Provide information you have given to us to a third party provider of services (where our lawful basis for processing is consent and where processing is automated)
We will respond to your request (including providing information on whether the rights apply in the particular circumstances) within the applicable statutory time period, if the request warrants, Horizon reserve the right to charge an administration fee to cover the costs to the business to felicitate the request. If we are not sure of your identity, we may require you to provide further information in order for us to confirm who you are.
Changes to this policy
We may make changes to this policy from time to time as our business and internal practices and/or applicable laws change. We will not make any use of your personal information that is inconsistent with the original purpose(s) for which it was collected or obtained (if we intend to do so, we will notify you in advance wherever possible) or otherwise than is permitted by applicable law.
How to contact us
If you would like to get in touch to discuss this policy, how we use your personal information, to exercise your rights to be forgotten, request information under your Rights of Access (also known as Subject Access Request), to provide feedback or make a complaint about use of your information, please contact us as follows:
Mr Simon Smith, Data Protection Officer
firstname.lastname@example.org or to contact by post at the following address
Mr S Smith, Data Protection Officer, Havant Leisure Centre, Civic Centre Road, Havant, Hants PO9 2AY
You can also contact the Information Commissioner’s Office via https://ico.org.uk/ for information, advice or to make a complaint.
Cookies, also known as browsers or tracking cookies, are small text files that are added to your computer when you visit a website. They help websites to perform certain functions e.g. to know who you are if you log into a restricted part of a website, for shopping carts, and for tracking purposes.
At Horizon we use the following cookies:
Google analytics. We use Google analytics cookies on the website for tracking purposes. The cookies allow us to understand general traffic to our website for example number of visitors and length of time on site. This process does collect data, but in an anonymous form, to help us make improvements, develop the website and enhance the user experience.
Privacy preferences. We use a tracking cookie, which is added to your computer, to remember your cookie preferences i.e. if you have allowed or disallowed them.
Register for events. We have the ability for you to register for events on the website. If you do so this information goes directly into our database. In order to register our database adds an essential cookie (reaction server) to your computer.
Member services. For areas of our website that are password protected then an essential cookie is added to your computer, which is then automatically deleted after your session has ended.
Upon arriving at our website we have an ‘opt-in’ tracking cookie to your computer, unless you specify otherwise. See above for further information on the types of cookies that we use.
If you do opt-out then an opt-out preference cookie will be added to your computer, however if you delete all your cookies or use a different device then you will need to set your cookie preference again.
Please note that you cannot opt-out of the deployment of cookies that are necessary for delivery of our website or services to visitors.