Calzaghe Mini Dragons Limited is committed to protect the privacy of individuals who either visit our website or participate and attend one of our services. Furthermore, we protect the privacy of organisations, their agents and their clients for whom we provide a service.
1. Data Controller
The Data Controller who is responsible for your personal data is Calzaghe Mini Dragons Limited whose office is situated at Boulders Indoor Climbing Centre, St Catherine’s Park, Pengam Road, Cardiff CF24 2RZ. Our contact details are: Tel: 07863 183496 email: firstname.lastname@example.org
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We appreciate the chance to deal with any concern you have prior to raising the issue with the ICO.
2. Data collected from you and how it is processed
We are required to collect data from your organisation to provide our service. This includes contact details of your agents as well as data related to the performance of the Calzaghe Mini Dragons Limited programme. We will not share this information with any other third parties without seeking direct consent with you. This information will only be collected directly from an agent from your organisation.
We may request to have access to collect data in relation to the service user’s progress and development in order to assess the effectiveness of our programme. As a measure to protect their identity we will not access their name. Furthermore, we will not share this information with any other third parties without seeking direct consent with you.
2.3 Information we provide to third parties
We generally do not provide any personal data about your organisation, it’s agents or your residents to a third party. However, the following are times when personal data is provided to a third party:
• To any contracted professional who helps us deliver our service
• Where we are required to under legal obligations, which may include situations where notification is needed to a regulatory or supervisory authority in connection with the welfare of an individual, or otherwise.
3. How we use any personal data collected from you.
• Where we need to gather information to deliver our training or sessions or to monitor results
• Where it is necessary for our legitimate interests to allow us to organise and run safe and enjoyable activity or training courses for all attendees. We make sure that we consider and balance any potential impact on all involved (both positive and negative) and your rights before we process any personal data for our legitimate interests. If the data relates to your service users we will give extra consideration to the interests of your residents. We will ensure that no such personal data is processed where the impact on you overrides our interests unless we have your consent or are required or permitted by law.
• To send you newsletters or other communications that you have consented to receive (This forms part of our T&Cs). You may unsubscribe from these at any time by emailing email@example.com directly
• Where we are under a legal or regulatory obligation
From time to time we may take images. We will only take and/or use images after we have gained consent from you. Consent is collected by completing our consent form which will be issued should we wish to take and/or use images
4. International Transfers
We do not transfer your personal data outside of the European Economic Area 4.
5. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
6. Data retention
We will only retain your personal data for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data,
we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
7. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to: Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
7.1 Request correction of the personal data that we hold about you.
This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
7.2 Request erasure of your personal data.
This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
You have the right to object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
7.3 Request restriction of processing of your personal data.
This enables you to ask us to suspend the processing of your personal data in the following scenarios:
(a) if you want us to establish the data’s accuracy;
(b) where our use of the data is unlawful but you do not want us to erase it;
(c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
(d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
8. Request transfer of your personal data
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a
contract with you. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. If you wish to exercise any of the rights set out above, please submit a written request to the Calzaghe Mini Dragons Limited Data Protection Officer.
9. No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
10. What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
11. Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
13. Links to other Web Sites
Any comments or suggestions on how we manage your privacy will be welcome and can be submitted by emailing