Privacy Policy

Horizon Leisure Centres (‘The Borough of Havant Sport and Leisure Trust’) is committed to respecting the privacy of all visitors, members and customers to its website (the ‘website’).

Please read the following privacy policy to understand how we use and protect the information that you provide to us or that we obtain or hold about you and to understand your rights in relation to the information that we have. This policy applies to data about living identifiable individuals only.
What information does Horizon process?

You may 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 email address. If you register for online booking, join as a member or book any classes, you may also be asked to provide information about your health.

All calls involving external telephone numbers received or made are recorded for training and monitoring purposes.

We will not use personal data from a call recording for marketing purposes.

Call recordings are stored on a secure SSL-encrypted platform and are deleted after six months.
Horizon does withhold the right to use call recordings as evidence in certain circumstances.

Suppose you use any of our specialist websites, e.g. our recruitment portal. In that case, you may be asked for information additional to your contact details, e.g. info about your employment history, salary, or work permissions. The use of that information is subject to a separate privacy policy available on that site. Please check that privacy policy before supplying any information.

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. Suppose you do not want to receive cookies. In that case, you may reject them by using your browser settings, provided they are not necessary for the delivery of our website or services to visitors (for help with how to do this, see the section below on “Cookies”).

Suppose you seek to become a member and are provided with free advice about becoming a member or become a member. In that case, we will need the information to confirm your identity, e.g., your name, date of birth, and address, and 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 to you will be explained to you by a staff member when you join.
If you are over 18, you must have a photograph taken for identification when joining as a member. If you are under 18, a parent or guardian must consent to the picture 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.

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 has CCTV cameras throughout its centres for crime prevention and health and safety, and as such, we may view or use CCTV footage in this way should a crime occur in or around its centres. This footage can be shared with appropriate authorities should they request it.

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. We will only be used if you positively choose to receive 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. about certain marketing activities
• We are carrying out necessary steps concerning a membership to which you are a party or before entering into a membership contract.
• To protect your vital interests, e.g. if you were unfortunate enough to fall ill or injured on our premises.

Suppose 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 to uniquely identify individuals, health data, or data concerning your sex life or sexual orientation. In that case, we must have a further lawful basis for the processing. This may include:

• 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 is required for reasons of substantial public interest

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 to send you information that may interest 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 get in touch with 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 via particular forms of communication, e.g. email or telephone. Please note that the preferences 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 info@horizonlc.com, 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.

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 the EEA. As with many companies, these third parties may include third-party IT platforms (including cloud-based platforms), administrative and support services and suppliers, and 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 specific laws or by a 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 info@horizonlc.com and requesting a list of relevant third parties.

We will take all steps reasonably necessary to ensure that your data is treated securely and by this privacy policy; please see the section “Protection of your information” below.

We have administrative, technical and physical measures designed to guard against and minimise the risk of loss, misuse or unauthorised processing or disclosure of our personal information.

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 when information is transferred to a country or international organisation outside 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 is stored on our secure servers and protected using industry-standard fast (SSL) encryption technology. All servers owned and maintained by Horizon are based within the EU.

You have certain rights concerningsonal information, although those rights will not apply in all cases or to all information we have about you. For example, we may need to continue holding and processing 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
• Please update your data where it is out-of-date or incorrect
• Delete personal information that we hold
• Restrict how 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 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 unsure of your identity, we may require you to provide further information to confirm who you are.

We may make changes to this policy from time to time as our business and internal practices and applicable laws change. We will not use your personal information 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) otherwise than is permitted by applicable law.

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), provide feedback or make a complaint about the use of your information, please get in touch with us as follows:

 info@horizonlc.com or to contact by post at the following address

 Data Protection, 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 and advice or to complain.