Moon Community Club Limited (“MCCL”, “we”, “us”, “our”) respects your privacy and is committed to protecting your personal information. We want to be transparent with you about how we collect and use your personal information.
This Policy contains important information about your personal rights to privacy. Please read it carefully to understand how we use your personal information.
The provision of your personal information to us is voluntary. However, without providing us with your personal information, your use of our services or your interaction with us may be restricted impaired. For example, you would not be able to become a member.
Before you read any further, it might be useful to explain what we mean by “personal information”. The relevant legal definition can be found here. In brief, it is information which relates to you and from which you can be identified, whether from that information alone or from that information combined with other information. It is a very broad definition, so lots of types of information can amount to personal information.
We collect personal information in the following ways:
2.1 When you give it to us directly
For example, personal information that you submit to us when you sign up as a member, request particular services or make general enquiries.
2.2 When you visit our website
When you visit or use our website, we automatically collect the following types of personal information:
2.3 When we obtain it indirectly
We also collect your personal information from third party sources. For example, your personal information may be shared with us by analytics providers and search information providers (for example, via cookies deployed by our website). To the extent we have not done so already, we will notify you when we receive personal information about you from such sources and tell you how and why we intend to use that personal information.
In general, we may combine your personal information from these different sources for the purposes set out in this Policy.
2.4 When it is publicly available
For example, if you interact with us on social media (such as Instagram) and depending on your privacy settings, certain information about your user account or profile (such as username, profile picture or other details in your profile).
We may collect, store and otherwise process the following kinds of personal information:
Do we use special categories of personal information?
Applicable data privacy law recognises certain categories of personal information as sensitive and therefore requiring more protection, for example information about your health, ethnicity and political opinions. This is known as “special category” personal information.
We do not set out to collect special categories of your personal information, but there may be unforeseen circumstances where we either need to (for example due to injury on our premises) or where members volunteer it (for example discussing political opinions on our message boards). When this happens, we only collect, or facilitate collection of, special categories of personal information where applicable data privacy law allows us to and where there is a good reason.
We mainly collect and use personal information because we can’t provide our services otherwise.
In general, we use your personal information to achieve the purposes set out in this Policy. In particular, we may use your personal information to:
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
Applicable data protection law requires us to rely on one or more from a set of “lawful bases” to collect and use your personal information. In short, these are six reasons recognised by regulators as giving us lawful grounds to collect and use your personal information.
We consider the grounds listed below to be relevant:
Applicable data privacy law allows us to collect and use your personal information if it is reasonably necessary to achieve our, your or others’ legitimate interests (as long as that use is fair, balanced and does not unduly impact your rights).
In brief, “legitimate interests” is a broad concept and can potentially include any reasonable, legitimate and valid objective (whether commercial or otherwise). Our legitimate interests could, for example, include provision, promotion or improvement of our services.
When we process your personal information to achieve such legitimate interests, we consider and balance any potential impact on you (both positive and negative), and your rights under applicable data protection law. We will not use your personal information for activities where our interests are overridden by the impact on you, such as where that use would be excessively intrusive (unless, for instance, we are otherwise required to or permitted to by law).
We will also share your personal information with selected third parties where required by law, where it is necessary to administer our working relationship with you or where we have another valid and lawful reason for doing so, including if you have given your consent.
Those selected third parties include:
We may also need to disclose your personal information to third parties:
Where appropriate, we require third parties to enter into contracts with us which place obligations on them to protect your personal information in line with our policies and procedures and our obligations under applicable data privacy law.
As a general rule, we keep your personal information for as long as you are an MCCL member. Once you are no longer a member (whether you actively cancel, purposely do not renew, we terminate your membership or your membership lapses for any reason), then we usually securely delete your personal information from our records.
However, there may occasionally be situations where we need to keep your personal information after your membership of MCCL ends (for example in case of legal dispute (whether active or prospective). In such instances, we keep your personal information as long as required in connection with the purpose(s) for which it is retained and used. As a general rule, we apply a backstop of 6 years to remove your personal information after the date your membership ends – we only keep it longer if there is a genuinely good reason to do so.
MCCL is committed to keeping your personal information safe and secure and therefore takes reasonable and proportionate technical and organisational precautions to prevent the loss, misuse or alteration of your personal information. We restrict access to those who have a need to know and we train staff in handling your personal information securely and in line with MCCL’s obligations under applicable data privacy law.
Unfortunately, there is no such thing as 100% security in the online environment. As a result we cannot and do not guarantee the security of any personal information you submit to us through or in connection with our website.
If you consider that your interaction with us is no longer secure (e.g. you consider that the security of any account you might have with us has been compromised), please immediately notify us by contacting us at firstname.lastname@example.org.
As we are a UK-based organisation, when we use your personal information internally we will not transfer it outside of the UK or European Economic Area (“EEA”). However, because (as set out in section 6 above) we share your personal information with third parties, it is possible information that we collect from you will be transferred to and stored in a location outside the UK or EEA.
Some countries outside of the UK or EEA have a lower standard of protection for personal information, including lower security requirements and fewer rights for individuals.
Where we cause your personal information to transferred, stored and/or otherwise used outside the UK or EEA in a country that does not offer an equivalent standard of protection to the EEA, we will take all reasonable steps necessary to ensure that the recipient implements appropriate safeguards (such as by entering into a contract which puts the recipient under similar obligations as if they were based in a the UK or a EEA country, or requesting that they have signed up to a domestic certification scheme which guarantees the same level of protection as in the UK or EEA) designed to protect your personal information and to ensure that your personal information is treated securely and in accordance with this Policy. If you have any questions about the transfer of your personal information, please contact us using the details below.
Applicable data protection law gives you certain rights to control how we use your personal information. These are as follows:
We are then required to stop using your personal information in the manner to which you object unless we can demonstrate a reason of compelling importance to continue (unless you object to our use of your personal information for marketing purposes, in which case we must stop regardless of any compelling grounds to continue).
We may ask you for additional information to confirm your identity and for security purposes before actioning any attempt to exercise these rights. Please note that some of these rights only apply in limited circumstances. For further information on how to exercise these rights, or the extent to which they may apply to you, please contact us using the details below.
We may use your contact details to provide you with information about our work, events, services and/or products which we consider may be of interest to you (for example, about similar products which you previously purchased, or as part of our members-only newsletter).
Where we do this via email, SMS or telephone, we will not do so without your prior consent (unless we are allowed to do so via applicable law).
Where you have provided us with your consent previously but do not wish to receive marketing material from us anymore, please let us know by emailing email@example.com. You can also opt out of receiving marketing emails from MCCL at any time by clicking the “unsubscribe” link at the bottom of our emails.
We may provide links our website directly to other sites. This Policy does not cover external websites and the privacy practices of their operators and we are not responsible for the content of those sites or the privacy practices of their operators. We encourage you to read the privacy notices of any external websites you visit via links you may click on our website.
When we process children’s personal information, where required we will not do so without their consent or, where required, the consent of a parent / guardian. We will always have in place appropriate safeguards to ensure that children’s personal information is handled with due care and safety.
We reserve the right to make changes to this Policy at any time. Any changes we may make to this Policy in the future will be posted on this page and, where appropriate and reasonably possible for us to do so, notified to you by email. We may also notify you in other ways from time to time about the processing of your personal information. This Policy was last updated on 5 March 2021.
Questions, comments and requests regarding this Policy are welcomed and should be sent via the following channels:
Post: WSM, Connect House 133-137 Alexandra Road, Wimbledon, London SW19 7JY