The Cheltenham Trust – Privacy Policy – July 2o24

The Cheltenham Trust – Privacy Policy

The Cheltenham Trust is a registered charity focused on developing Cheltenham’s culture and sports, which are offered through community engagement, sustainable investment, and social enterprise. The Trust engages audiences through the arts, heritage, performance, tourism, sport, play and wellbeing opportunities.

The Cheltenham Trust is registered with the Charity Commission (number 1158606) and with the Information Commissioner’s Office as a data controller. Our Data Protection Officer can be contacted via email at [email protected].

This Privacy Policy sets out the basis for processing any personal data we collect from you or that you provide. Please read this Privacy Policy carefully to understand our views and practices regarding your data and how we will treat it.

The privacy policy covers The Cheltenham Trust, Cheltenham Town Hall, Leisure at Cheltenham, Pittville Pump Room and The Wilson.

Why do we need your information, and how do we use it?

Most of the personal data we process is provided directly by you. Under the UK General Data Protection Regulation (UK GDPR), we must have a lawful basis for processing this information.  We process your data for the following purposes:

  • To send you newsletters to which you have subscribed.
  • To send you a survey seeking your feedback on our services or events.
  • To process your membership/account and create or terminate your account.
  • To process your booking for a show and issue you with the tickets.
  • To process your booking(s) for leisure classes/activities.
  • To process your venue booking request and support you with managing the event.
  • To process your donation or sponsorship and any associated gift aid.
  • To send you an invoice and to chase any outstanding debt.
  • To process your continuous membership fee.
  • To process your refund request.
  • To process your booking request for a market stall at one of our artisans or festival markets.
  • To process your application to become a volunteer.
  • To respond to your enquiries.
  • To respond and investigate any complaints made.
  • To analyse your interactions with our website(s).
  • To manage our relationship with you.
  • To comply with legal and regulatory requirements.

We will use your personal data in the following circumstances:

  • When we need to perform the contract we are about to enter into or have entered into with you, e.g., when you hire our venue for your wedding.
  • Where we need to comply with a legal obligation.
  • Where you have provided your consent, e.g., to send you an email newsletter.
  • Where it is in our legitimate interests as a charity, e.g., to seek your feedback on an event or show to improve it.

What Type of Information is collected from you?

Depending on how you use our services or interact with our websites, we collect, store, and transfer some or all the following data:

  • Identity data: name, title, birthday (for membership)
  • Contact data: address, email address(es), telephone number, mobile phone number.
  • Financial data: payment or credit card details, bank account (for direct debits) information.
  • Transaction data: purchase history and your payments (including donations).
  • Business data: business name, job title, profession
  • Profile data: preferences and interests, user and account information, passwords, login history, and photo(s).
  • Technical data: (read our Cookie Policy) IP address, browser type and version, operating system.

Who do we share your data with?

We work with service providers to improve your experience. They help with website hosting, ticket booking, leisure bookings, event hire, accounting software, and web analytics.

We make sure that all parties respect the security of your data and handle it responsibly. Our service providers are only permitted to use your data for the specific purposes outlined in our agreement with them.

Do we transfer your personal data outside the UK?

No, we will only store your personal data on systems located in the UK.

How long will we retain your data?

We will only hold onto your personal data for as long as we really need it to serve the purposes for which we collected it. This may include meeting legal, regulatory, tax, accounting, or reporting requirements. In case of a complaint or potential legal dispute with you, we may have to keep your personal data for a bit longer.

When your data is no longer required, we will delete it according to our retention and disposal policies.

How do we protect your information?

We’ve taken steps to make sure your personal data is always safe and secure. We limit access to your information to only those who really need it, like our employees and trusted partners. They will only use your data as instructed and are obligated to keep it confidential.

If your data is ever at risk, we have procedures in place to address it, and we’ll let you know and inform the appropriate authorities if necessary.

Your Rights

Under data protection law, you have rights, including:

  • The Right of Access. You have the right to ask us for copies of your personal information.
  • The Right to Rectification. You have the right to ask us to rectify personal information you think is inaccurate.  You also have the right to ask us to complete information you think is incomplete.
  • The Right to be Forgotten. You can ask us to erase your personal information in certain circumstances.
  • The Right to Restrict of Processing. You have the right to ask us to restrict the processing of your personal data in certain circumstances.
  • The Right to Object. In certain circumstances, you have the right to object to the processing of your personal data.
  • The Right to Withdraw Consent. If we rely on consent to process your personal data, you can withdraw that consent at any time.
  • The Right to Portability. You have the right to ask that we transfer the personal data you gave us to another organisation or you in certain circumstances.

If you make a request, we have one month to respond. If you have any questions, please contact us at [email protected]. Please note that not all the above rights are absolute, and requests may be refused where exceptions apply.

How to Complain

If you have any concerns about our use of your personal information, you can complain to us at [email protected]. If you are unhappy with how we have used your data, you can also complain to the Information Commissioner’s Office (ICO). The ICO’s address is the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Alternatively, you can phone their helpline at 0303 123 1113 or complete an online form via the ICO website (https://www.ico.org.uk).

The Cheltenham Trust keeps any personal information about you held confidentially in accordance with the current Data Protection regulations, whether it is held on computer or in secure manual filing systems. We will store your personal information only if you chose to provide us with it, for example by completion of an electronic form on this website. In these circumstances, any personal information supplied will only be used to provide the requested information or service.

We may ask you to consent to receive information about our goods and services or donations.

If you are using goods and services of the Trust, applying for a role with the Trust, providing services to or for the Trust, we would ask for your; name / contact name, company name, address, date of birth, contact details, National Insurance number (employment only), proof of identity (as applicable), professional registration and/or qualifications (as applicable), and bank account details (only if paying for goods and services or requiring payment for goods and services provided).

Who your information may be shared with (internally and externally)

We may share your information with selected third parties including:

  • Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you. This would always be subject to a strict data protection contract between the Cheltenham Trust and the third party eg our mailshot mail house for brochure distribution.
  • Social media sites for the purposes of data analytics and targeted advertising
  • Analytics and search engine providers that assist us in the improvement and optimization of our websites

We may disclose your personal information to third parties:

  • In the event that the Cheltenham Trust or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets
  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply terms to use or terms and conditions of supply and other agreements; or to protect the rights, property, or safety of The Cheltenham Trust, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
  • Please note that sensitive personal data will not be shared with third parties without your consent.

The retention period depends on the context of the relationship.

If you are applying for a role and are unsuccessful, we will keep your data for 6 months, after which time it will be destroyed. If you become an employee of one of the partner Councils or clients, we will keep your data for a minimum of 6 years after the end of your employment after which time it will be destroyed.

  • We will not transfer your personal data to any other organisation.
  • We have implemented generally accepted standards of technology and operational security in order to protect personal data from loss, misuse, or unauthorised alteration or destruction.
  • Please note however that where you are transmitting information to us over the internet this can never be guaranteed to be 100% secure.
  • For any payments which we take from you online we will use a recognised online secure payment system.
  • We will notify you promptly in the event of any breach of your personal data which might expose you to serious risk.

You have rights under the Data Protection Legislations:

  • to access your personal data
  • to be provided with information about how your personal data is processed
  • to have your personal data corrected
  • to have your personal data erased in certain circumstances
  • to object to or restrict how your personal data is processed
  • to have your personal data transferred to yourself or to another business in certain circumstances.

The Data Protection law gives you the right to apply for a copy of information about yourself. This is called a ‘Subject Access Request’. The accuracy of your information is important to us to be able to provide relevant services more quickly. We are working to make our record keeping more efficient.

In the meantime, if you change your address or email address, or if any of your circumstances change or any of the other information we hold is inaccurate or out of date please email us or write to us at:

The Cheltenham Trust

Cheltenham Town Hall

1 Imperial Square

Cheltenham

Gloucestershire

GL50 1QA

Email: [email protected]

Leisure: Tel: 01242 528764

The Data Protection Legislation gives you the right to apply for a copy of information about yourself. This is called a Subject Access Request.

The Cheltenham Trust keeps any personal information about you held confidentially in accordance with the current Data Protection regulations, whether it is held on computer or in secure manual filing systems. We will store your personal information only if you chose to provide us with it, for example by complete an electronic form on this website. In these circumstances, any personal information supplied will only be used to provide the requested information or service.

Google, as a third party vendor, uses cookies to serve ads. Google’s use of the DART cookie enables it to serve ads to visitors based on their visit to sites they visit on the Internet. Website visitors may opt out of the use of the DART cookie by visiting the Google ad and content network privacy policy

Use of re-targeting functions on the website

Activation of interest-related advertising using “re-targeting”

This website uses so-called “re-targeting Tags”. A “re-targeting tag” is a JavaScript element which is positioned in the website source code. When a user visits a page on this website which contains a “re-targeting tag”, the provider of the online advertising (e.g. Google) places a cookie on the user’s computer and organises the advertising in accordance with retargeting target group lists. This cookie is subsequently used to activate re-targeting campaigns (“Interest-related advertising “) on other websites. Studies have proven that integrating interest-related advertising is of greater interest for the Internet user than an advert which has no direct relation to the person’s interest and previously visited websites.

A cookie is a small amount of data that a website places on your computer.

Why do websites use cookies?

Web pages have no memory. If you are surfing from page to page within a website, you will not be recognised as the same user across pages. Cookies enable your browser to be recognised by the website. So cookies are mainly used to remember the choices you have made – choices such as the language you prefer and the currency you use. They will also make sure you are recognised when you return to a website.

Do all cookies do the same thing?

No, there are different types of cookies and different ways of using them. Cookies can be categorised according to their function, their lifespan and according to who places them on a website.

How does The Cheltenham Trust (Leisure at Cheltenham / The Wilson / Cheltenham Town Hall/ Pittville Pump Room/ Prince of Wales Stadium) use cookies?

Our websites use the following types of cookie:

  • Technical cookies: We try to give our visitors an advanced and user-friendly website that adapts automatically to their needs and wishes. To achieve this, we use technical cookies to show you our website, to make it function correctly. These technical cookies are absolutely necessary for our website to function properly.
  • Functional cookies: We also use functional cookies to remember your preferences and to help you to use our website efficiently and effectively, for example by remembering your preferred currency and language, your searches and the accommodation you viewed earlier. These functional cookies are not strictly necessary for the functioning of our website, but they add functionality for you and enhance your experience.
  • Analytics cookies: We use these cookies to gain insight into how our visitors use the website, to find out what works and what doesn’t, to optimise and improve our website and to ensure we continue to be interesting and relevant. The data we gather includes which web pages you have viewed, which referring/exit pages you have entered and left from, which platform type you have used, date and time stamp information and details such as the number of clicks you make on a given page, your mouse movements and scrolling activity, the search words you use and the text you type while using our website. We also make use of analytics cookies as part of our online advertising campaigns to learn how users interact with our website after they have been shown an online advertisement, which may include advertisements on third-party websites. We will not know who you are, and only obtain anonymous data.
  • Commercial cookies: We use these to show you Tregenna advertisements on other websites. This is called “retargeting” and it aims to be based on your browsing activities on our website, such as the destinations you have been searching for, the accommodation you have viewed and the prices you have been shown.

How long do The Cheltenham Trust (Leisure at Cheltenham / The Wilson / Cheltenham Town Hall/ Pittville Pump Room/ Prince of Wales Stadium) cookies stay active?

The cookies we use have varying lifespans. The maximum lifespan we set on some of them is five years from your last visit to our website. You can erase all cookies from your browser any time you want to.

How can you recognise our cookies?

You can find our cookies in your browser settings.

Does The Cheltenham Trust (Leisure at Cheltenham / The Wilson / Cheltenham Town Hall/ Pittville Pump Room) use third-party cookies?

Yes, the Trust uses the services of trusted and recognised online advertising and marketing companies. The Trust may also use third-party providers for analytical purposes. To enable their services, these companies need to place cookies.

The providers we use are committed to building consumer awareness and establishing responsible business and data management practices and standards.

When it comes to online advertising and marketing companies, we strive to only work with companies that are members of the Network Advertising Initiative (NAI) and/or the Interactive Advertising Bureau (IAB). Members of NAI and IAB adhere to industry standards and codes of conduct. NAI and IAB members allow you to opt out of the behavioural advertising. Visit www.networkadvertising.org andwww.youronlinechoices.com to identify the NAI members that may have placed an advertising cookie file on your computer. To opt out of an NAI or IAB member’s behavioural advertising programme, simply check the box that corresponds to the company from which you wish to opt out.

In order to control the collection of data for analytical purposes by Google Analytics, you may want to visit the following link: Google Analytics Opt-out Browser Add-on.

Who has access to The Cheltenham Trust (Leisure at Cheltenham / The Wilson / Cheltenham Town Hall/ Pittville Pump Room/ Prince of Wales Stadium) cookie data?

Only The Cheltenham Trust has access to The Cheltenham Trust cookies. Cookies placed by third parties can be accessed by these third parties.

Using your browser settings in, for example, Internet Explorer, Safari, Firefox or Chrome, you can set which cookies to accept and which to reject. Where you find these settings depends on which browser you use. Use the “Help” function in your browser to locate the settings you need.

If you choose not to accept certain cookies, you may not be able to use some functions on our website. And opting out of an online advertising network does not mean that you will no longer receive or be subject to online advertising or marketing analysis. It means that the network from which you opted out will no longer deliver ads tailored to your web preferences and browsing patterns.

Does The Cheltenham Trust (Leisure at Cheltenham / The Wilson / Cheltenham Town Hall/ Pittville Pump Room) use web beacons?

As well as using cookies, The Cheltenham Trust sometimes uses web beacons. A web beacon is a tiny graphic image of just one pixel that’s delivered to your computer either as part of a web page request or in an HTML email message. Either directly or through service providers, we use these pixels as part of our online advertisements either on our website or on third-party websites to learn whether a user who is being shown an online advertisement also makes a reservation; to track conversion with partner websites and to analyse the traffic patterns of users to optimise the services we bring to you.