DATE LAST REVISED: FEBRUARY 2024
Commando Joe’s Fun and Fitness Ltd. (Commando Joe’s or ‘we’ or ‘us’ or ‘our’) gather and process your personal information in accordance with this privacy notice and in compliance with the UK Data Protection Act 2018, the EU General Data Protection Regulation 2016/679, UK implementing laws and regulations relating to data protection and privacy. This notice provides you with the necessary information regarding your rights and obligations, and explains how, why and when we collect and process your personal data.
Commando Joe’s registered office is at 5 Meadowcroft Way, Leigh, Wigan, WN7 3XZ and we are a company registered in England and Wales under company number 06824659. We are registered on the Information Commissioner’s Office Register of Data Controllers under registration number ZA281155, and act as the data controller. Our Appointed Person for the organisation is Dan Kelly, Managing Director, and we can be contacted at firstname.lastname@example.org and +44 (0)844 800 3212 if you have any queries.
This policy will apply to our contract with you (or your organisation) and it governs your use of our website and online portals, and you are therefore advised to read it carefully. Terms used within it have the meaning(s) given in applicable legislation. By working with us, and/or by providing your personal data to us, you understand, accept and consent to the data processing practices described in this policy.
Any changes we make to this policy will be posted on this page. You are advised to check back frequently as, unless your consent is required, any changes will be binding on you when you continue to use our portals or work with us after the date of the relevant change.
INFORMATION THAT WE COLLECT
Commando Joe’s processes your personal information to meet our legal and contractual obligations and to provide you with our products and services through our Instructor led and School led programmes, our COJO Online Portal and our Parents’ Portal. We will never collect any unnecessary personal data from you and we do not process your information in any way, other than already specified in this notice, our applicable portal terms or as otherwise notified to you from time to time (including in our contracts or user terms).
Your personal data will be held and stored by us on servers and data centres located within the UK. All personal data is processed by UK based staff who are regulated by our internal staff data protection policy.
We 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 online Portals or our website or by corresponding with us. This is our primary route of data capture and how we capture the vast majority of the data we process about you, so you must ensure it is accurate when providing it to us. This includes information you provide when you are in receipt of our services, register for email alerts, request literature, sign-up for newsletters or enter a competition, promotion or survey and personal contact on person or through social media. The information you give us may include your name, address, email address and other contact information, as well as other personal information associated with the services we provide. This includes school related information, such as preferences and interests, year group data, special educational needs (if any), date of birth, gender, additional languages, receipt of free school meals.
- Information we collect about you. When you visit our sites we may automatically collect the following information:
- technical information, including the Internet Protocol (IP) address used to connect your computer to the internet, your login information, your geographic location, browser type and version, browser plug-in types and versions, operating system and platform; and
- information about your visit, including the source of your visit, the full click path, mouse movement, through our sites (including date and time); services you viewed, searches made on our sites, page response times, download errors, length of visits to certain pages, page interaction information (such as page scrolling, mouse clicks, mouse movements and keyed text), and methods used to browse away from the page. This information may be collected using a website recording service.
- Information we collect at receipt and opening of emails. From time to time when you open an email sent by us we may automatically collect the following information:
- technical information, including; your geographic location, browser type and version, device type and operating system and platform
- Information during online purchases. We collect information about you during the registration, enrolment, and payment/checkout processes on our website. Purchase and payment details for access to our online portals are taken from organisations (such as the schools we work with) directly and do not typically relate to individual bank accounts or card / payment details. When you register an account with us, we’ll ask you to provide information including your name, billing address, email address, phone number, credit card/payment details and optional account information like username and password. We’ll use this information for purposes, such as, to:
- Send you information about your account, orders, courses, and memberships
- Communicate with you about courses and memberships that you’re enrolled in
- Respond to your requests, including refunds and complaints
- Process payments and prevent fraud
- Set up your account for our site
- Comply with any legal obligations we have, such as calculating taxes
- Improve our site’s offerings
- Send you marketing messages, if you choose to receive them
When you create an account, we will store your name, address, email and phone number, which will be used to populate the enrolment and checkout for future purchases and enrolments. Retention of account details is also necessary to enable us to monitor and track curriculum progress.
HOW WE USE YOUR PERSONAL DATA (LEGAL BASIS FOR PROCESSING)
Commando Joe’s takes your privacy very seriously and will never disclose or share your data to third parties unless required to do so by law or to enforce any of our contractual terms. We do not sell your personal data to third parties at any time. We only retain your data for as long as is necessary and for the purposes specified in this notice. Where you have consented to us providing you with promotional offers and marketing, you are free to withdraw consent at any time. The purposes and reasons for processing your personal data are detailed below:
- We collect your personal data in the performance of a contract or to provide our services to you or your organisation; and
- We collect your personal data to respond to enquiries and to supply relevant marketing information about our services
You have the right to access any personal information that Commando Joe’s processes about you and to request information about:
- What personal data we hold about you
- The purposes of the processing
- The categories of personal data concerned
- The recipients to whom the personal data has/will be disclosed
- How long we intend to store your personal data for
- If we did not collect the data directly form you, information about the source
If you believe that we hold any incomplete or inaccurate data about you, you must tell us to correct and/or complete the information and we will strive to update/correct it as quickly as possible.
You also have the right to request erasure of your personal data or to restrict processing in accordance with data protection laws, as well as to object to any direct marketing from us and to be informed about any automated decision-making that we use.
If we receive a request from you to exercise any of the above rights, we will ask you to verify your identity before acting on the relevant request; this is to ensure that your data is protected and kept secure and to avoid inadvertent disclosures of your data to the wrong person.
SHARING AND DISCLOSING YOUR PERSONAL INFORMATION
We do not share or disclosure any of your personal information without your consent, other than for the purposes specified in this notice or where there is a legal requirement. We host all personal data relating to contacts we liaise with in connection with our services through our wider group databases, and access to that data is made available to other companies within the Edwin Group and may be used for marketing and data analytics purposes.
Commando Joe’s uses third-parties to provide defined services and business functions set out below. All processors acting on our behalf only process your data in accordance with written instructions or contractual terms from us and comply fully with this privacy notice, the data protection laws, our contracts with those third parties and any other appropriate confidentiality and security measures.
We obtain personal data from you directly. We disclose your personal data to the following third parties, for the reasons stated:
- Payment details are shared with the third parties listed in this policy, for the reasons stated;
- Mailgun Technologies, Inc provide our email delivery services for sending, receiving and tracking emails to you in connection with ordinary correspondence and account management purposes.
Our website uses Google Analytics, a web analytics service provided by Google, Inc (Google). Google Analytics uses “cookies”, which are text files placed on your computer to help analyse how you use our website only (not our portals). The information generated by the cookie about your use of the website (including your IP address) will be transmitted to, and stored by, Google on US-based servers. Google use this to evaluate your use and compile reports on activity for us, and providing other service relating to website activity and internet usage. Google will not associate your IP address with any other data held by Google. You my refuse cookie use by selecting appropriate settings on your browser. However, by doing so, your ability to use the website or our portals may be restricted.
All personal data relating to our customer accounts is accessible by our UK based staff who have administrator level access who need to know to manage and administer your account. If we discover that any of your personal data processed by our online portals is lost, destroyed or becomes damaged, corrupted or unusable, we will notify you or our customer (depending on the affected data) within 24 hours of discovery or otherwise in accordance with our contract with our customer or our applicable portal user terms.
Any personal data you provide to us for upload to our portals must be transferred to us via our secure transfer protocols. Personal data provided by other means (such as by email) cannot be processed by us, unless it is to an email address we have directly provided to you or you are responding to an existing email chain.
What rights you have over your data
You have rights in certain circumstances, under data protection laws in relation to your personal data. These rights include:
- Request access to your personal data (commonly known as a “data subject access request”).
- Request correction of the personal data that we hold about you.
- Request erasure of your personal data. When business have no good reason to continue processing data, this will enable you to remove/delete your personal data.
- Withdraw consent for any data we are processing (where we are processing personal data on the basis of your consent).
If you would like to exercise any of above mentioned rights, you can use the information in Contact section below.
CONSEQUENCES OF NOT PROVIDING YOUR DATA
You are not obligated by law to provide your personal information to Commando Joe’s, however, as this information is required for us to provide you with our products or services, we will not be able to offer some/all of our products or services to you without it which may impact your subscription.
STORING YOUR DATA
As stated above, your personal data will be held and stored by us on servers and data centres located within the UK. All personal data is processed by UK based staff who are regulated by our internal staff data protection policy.
Commando Joe’s only ever retains personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations. We always maintain complete, accurate and up-to-date records to demonstrate our compliance with data protection laws and our contracts. We are required under UK contract laws to keep your basic personal data (name, address, contact details) for a minimum of 6 years after which time it will be destroyed.
Where we are using your details for direct marketing, we will keep such data until you notify us to delete the data or withdraw your consent.
Once your subscription expires, any personal data processed by us in connection with that subscription, including through our online portals, will be retained for a maximum of 6 weeks after your subscription has expired (as set out in your contract). After that point, it may be recoverable for a further week as part of our data backup process. We always notify your organisation prior to irretrievably deleting any personal data.
PROMOTIONS & OFFERS
Occasionally, Commando Joe’s would like to contact you with details of the products and services that we provide or to circulate our newsletters. If you consent to us using your contact details for these purposes, you have the right to modify or withdraw your consent at any time by using the opt-out/subscribe options in the relevant communication or correspondence, or by contacting Commando Joe’s directly.
LINKS TO OTHER WEBSITES
The Commando Joe’s website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
LODGING A COMPLAINT
Commando Joe’s only processes your personal information in compliance with this privacy notice, our contract with you (or your organisation) and in accordance with the relevant data protection laws. If, however you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, you have the right to lodge a complaint with the supervisory authority.
In the first instance please contact:
Dan Kelly, Managing Director
Commando Joe’s Fun and Fitness Ltd
Telephone +44 (0)844 800 3212