Last updated 24th May 2018
Sensitive DataWe do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.
2. When do we collect personal information?
We collect your personal information in a number of instances, including when you:
• Register your details as a new client of ours
• Book to attend a session.
• Visit our Website.
• Engage with us on social media;
• Contact us by any means with questions about a service, product or treatment or to raise a complaint;
• Ask one of our colleagues to email you information about a service or product;
• Enter prize draws or competitions;
• Comment on or review our products and services. Any individual may access personal information related to them, including opinions. So, if your comment or review includes information about the colleague who provided that service, it may be passed on to them if requested;
• Fill in any forms.
• Have given a third-party permission to share the personal information they hold about you with us;
• Phone us, we sometimes record phone conversations for record or training purposes; and/or
• Use our car park or Centre which usually have CCTV systems operated for the security of both customers and colleagues and for the prevention of crime.
These systems may record your image during your visit.
3. What personal information do we collect and why?
The personal information that we collect about you broadly falls into the following categories:
Information that you provide voluntarilyWhen you register as a client, book an appointment, attend an event or enter a prize draw/competition, you will be asked for some essential information including your title, first name, surname, postal address, email address, telephone, details of your pet and, if applicable, payment information. These are collected to help us:
• Provide care to your pet;
• Register your details as a new client of ours.
• Manage your pets progress.
• Process payments due to us (including services for your pet);
• Contact you about your pet, account or credit status where required;
• Prevent and detect fraud – to do this, we may need to disclose information to assist legal or debt recovery processes;
• Understand your needs and listen to your feedback via market research/analysis, customer polls and surveys;
• Enhance your K9 Aqua Sports experience by delivering personally tailored offers;
• Send you reminders about appointments.
• Send you marketing and promotional offers and to manage your marketing preferences if you elect not to receive marketing and promotional offers from us;
• Speed up your form filling processes if you've registered online;
• Conduct analytics to understand how our services are used; and/or
• Notify you about changes to our service.
Information that we collect automaticallyWhen you visit our Website or Social Media, we may collect certain information automatically from your device. In some countries, including countries in the European Economic Area, this information may be considered personal information under applicable data protection laws.
Specifically, the information we collect automatically may include information like your IP address, device type, operating system, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how your device has interacted with our Website or Social Media, including the pages accessed and links clicked.
Collecting this information enables us to better understand the visitors who come to our Website or Social Media, where they come from, what content on our Website or Social Media is of interest to them, what they have viewed or looked at and in some instances what they have purchased. We use this information for internal analytics purposes, to improve the quality and relevance of our Websites and Social Media to our visitors and users and to deliver personally tailored retail offers (both on the website and through triggered email, Social Media, SMS and direct mail (but only where you have agreed to these channels)). Some of this information may be collected using cookies, tracking pixels and similar tracking technology, as explained further under the heading “Cookies and similar tracking technology” below.
Information that we obtain from third party sourcesFrom time to time, we may receive personal information about you from third party sources, but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us.
If you have any questions about the third parties we obtain personal information from, please contact us using the contact details provided under the “How to contact us” heading below.
Enhancing our dataWhere we have obtained your personal information from various sources (including personal information we have lawfully obtained from third parties) we may combine this information in certain circumstances to enhance our understanding of your requirements and preferences in relation to our products and services. This is necessary for the purposes of our legitimate interests to ensure that we provide you the most appropriate offers for products and services and to personalise your K9 Aqua Sports experience.
Conducting analyticsWe will use the personal information we hold about you (as well as pseudonymised or anonymised information generated from your personal information) to carry out analysis and research. We carry out all such analysis and research on the basis that it is necessary for the purposes of our legitimate interests in understanding our clients and ensuring that our services and products meet the needs of our customers. We undertake data analytics, whereby we combine information we hold on a large scale in order to:
• Learn more about our clients and their preferences;
• To identify patterns and trends amongst our clients;
• Enhance user experience on our Websites and Social Media;
• Provide information, content and offerings tailored to our clients' needs;
• For general research and statistical purposes;
• For aggregated reporting purposes within Canine Aqua Centre Ltd.
• To help us develop new services and products;
• To monitor performance of our services;
• To be able to send you personalised marketing messages; and
• To display online advertisements to you.
We will use your personal information (including by anonymising and aggregating it with other customers' personal information) for sales, supply chain and financial analysis purposes, to determine how we are performing and where improvements can be made. This is necessary for the purposes of our legitimate interests in understanding how our business is performing and considering how to improve our performance.
Purposes for processing your personal data
Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.
We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us at email@example.com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing|
|To register you as a new customer||(a) Identity|
|Performance of a contract with you|
|To process and deliver your order including: |
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
|(a) Identity |
(e) Marketing and Communications
|(a) Performance of a contract with you|
(b) Necessary for our legitimate interests to recover debts owed to us
|To manage our relationship with you which will include: |
(b) Asking you to leave a review or take a survey
|(a) Identity |
(d) Marketing and Communications
|(a) Performance of a contract with you|
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests to keep our records updated and to
study how customers use our products/services
|To enable you to partake in a prize draw, competition or complete a survey||(a) Identity|
(e) Marketing and Communications
|(a) Performance of a contract with you |
(b) Necessary for our legitimate interests to study how customers use our
products/services, to develop them and grow our business
|To administer and protect our business and our site (including|
troubleshooting, data analysis, testing, system maintenance, support, reporting
and hosting of data)
|(a) Identity |
|(a) Necessary for our legitimate interests for running our business,|
provision of administration and IT services, network security, to prevent fraud
and in the context of a business reorganisation or group restructuring exercise
(b) Necessary to comply with a legal obligation
|To deliver relevant content and advertisements to you and measure and|
understand the effectiveness of our advertising
|(a) Identity |
(e) Marketing and Communications
|Necessary for our legitimate interests to study how customers use our|
products/services, to develop them, to grow our business and to inform our
|To use data analytics to improve our website, products/services, marketing,|
customer relationships and experiences
|(a) Technical |
|Necessary for our legitimate interests to define types of customers for our|
products and services, to keep our site updated and relevant, to develop our
business and to inform our marketing strategy
|To make suggestions and recommendations to you about goods or services that|
may be of interest to you
|(a) Identity |
|Necessary for our legitimate interests to develop our products/services and|
grow our business
You will receive marketing communications from us if you have: requested information from us or purchased goods or services from us; or if you provided us with your details and ticked the box at the point of entry of your details for us to send you marketing communications; and in each case, you have not opted out of receiving that marketing. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. You can ask us or third parties to stop sending you marketing messages at any time by emailing us at: firstname.lastname@example.org at any time. Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.
4. Who do we share your personal information with?We may disclose your personal information to the following categories of recipients:
o Service providers who provide IT and IT companies who support our Websites, Social Media and other business systems
o Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
o HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
o Direct marketing companies or other third parties who help us manage electronic communications with you;
o Google, Facebook, Instagram, Twitter and similar platforms to show you services that might interest you while you’re browsing the internet; This is based on either your marketing consent or your acceptance of cookies, tracking pixels or similar tracking technology on our websites, as explained further under the heading “Cookies and similar tracking technology” below; and/or
o Customer review companies (so you can leave feedback and we can improve our service to you); and/or
o Competition or prize-draw partners
• to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights or apply our Terms and Conditions, or (iii) to protect your vital interests or those of any other person;
• to any other person with your consent to the disclosure.
Where we share your personal information with third party service providers and partners we apply a policy to ensure your personal information is safe and in order to protect your privacy. Our policy requires:
• We provide only the information they need to perform their specific services.
• They may only use your data for the exact purposes we specify in our contract with them.
• We work closely with them to ensure that your privacy is respected and protected at all times.
• If we stop using their services, any of your personal information held by them will either be deleted or rendered anonymous (subject to applicable law). If you have any questions about the third parties we share your personal information with, please contact us using the contact details provided under the “How to contact us” heading below.
5. Legal basis for processing personal informationOur legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally collect personal information from you only (i) where we need the personal information to perform a contract with you, (ii) where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms, or (iii) where we have your consent to do so. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.
If we ask you to provide personal information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “How to contact us” heading below.
7. How do we keep your personal information secure?We use appropriate technical and organisational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. Specific measures we use include:
• Encrypting your personal information.
• Keeping your information up-to-date and accurate. Please note that, to do this, we require you to tell us if any of your details such as your name or address change; and
• Having in place strict security procedures for the storage and disclosure of your information to prevent unauthorised access.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted to and/or through our Website or Social Media; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
8. International data transfersCountries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria. Some of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:
• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
• Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
• Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time. Please email us at email@example.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
9. Data retentionWe will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, 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.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see below for further information. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Your data protection rightsYou have the following data protection rights:
• If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us.
• In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.
You can exercise these rights by contacting us using the contact details provided under the “How to contact us” heading below.
• You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the “How to contact us” heading below.
• Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
• You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, see the section headed “contacting the regulator” below.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to: • Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.
You can see more about these rights at:
If you wish to exercise any of the rights set out above, please email us at firstname.lastname@example.org, 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.
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.
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.
The website complies with the new GDPR laws and requirements. Your privacy is taken very seriously, and we are dedicated to handling your information in a secure and responsible manner.
You can visit the majority of our website without revealing any personal information about yourself. However, there are times when we need to collect information, so we can provide the services that you request. We may keep this information in a database.
How we collect personal information
b) Website analytics
Each time a user visits our website, web analytics software provided by a third party generates an anonymous analytics cookie. This is for statistical purposes and includes information such as most visited pages, types of browsers used to access our site, technology used, referring sites, IP addresses, geographical and demographic information. The information collected is not linked to any personally identifiable information.
c) Completion of our online forms We collect information about you when you complete any of our online forms or provide us with feedback. The information we require from you will be indicated on the form as required. It helps us if you provide the other information we ask for, but you are under no obligation to do so.
How we use personal informationWe use your personal information for the following purposes:
– To deliver the information you request
– To enable you to easily contact us, apply for posts online or competitions
– To provide you with further information from us in the form of latest news Blog posts
We will not sell or disclose any personal information such as your e-mail address to third parties without your prior consent.
How long do we keep your data?We are required under UK tax law to keep your basic personal data (name, address, contact details) for a minimum of 6 years. Generally, however, such personal data held on our management system will not be accessed after this time but is likely to be retained.
Records remain the property of the client and at any time a request may be made for a copy of the records.
What are your rights?You may have access to your personal data held at any time on request. If at any point you believe that the personal information we hold is incorrect, you can request to have it corrected or deleted. Under the GDPR rulings, we would inform our users within 72 hours if any breach of security occurs that might compromise your data.
Opting outIf you no longer wish to receive communications from Canine Aqua Centre Ltd, you can opt out of receiving them. You can do this a few ways: – Click unsubscribe from e-mails that you receive from us. – Email us at email@example.com stating your full name and contact details.
External LinksEven though this website seeks to provide quality, safe and relevant external links, users ought to apply a policy of caution before following any external web links from this website. Such links are followed at the user’s own risk.
The website owners can neither guarantee nor verify the contents of any externally linked website despite their very best efforts. The website owners cannot be held liable for any damages or implications as a result of visiting any external links mentioned.
We encourage you to be cautious and to read the privacy statements of each and every website that collects your information.
This privacy statement only applies to information collected on this website.
Social mediaInteractions made through external social media services that this website and the company participate with are subject to the terms and conditions as well as the privacy policies held with each social media service.
Users are encouraged to use social media platforms sensibly and with due care and attention in respect of their own privacy and personal details. We will never ask for sensitive information through social media services and encourage users wishing to discuss sensitive details to get in contact through primary communication channels like phoning us or e-mail.
We reserve the right to publish client pet photos and reviews from our Centres Facebook page on our latest news website Blog posts and other social media such as Google Plus. Should you wish any pet photos to be removed from our website or social media pages, please contact us at firstname.lastname@example.org and the required image/s will be removed straight away.
To disallow any further images of your pet on any of our social media and company website pages, please e-mail us at email@example.com to update your preference.
We aim to keep the Personal Data we hold about you accurate and up to date. If you tell us that we are holding any inaccurate Personal Data about you, we will delete it or correct it promptly. Please e-mail us at firstname.lastname@example.org to update your Personal Data.
11. Contacting the regulatorIf you feel that your personal information has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal information, you have the right to raise a complaint with the Information Commissioner’s Office. You can contact them by calling 0303 123 1113 or go online to www.ico.org.uk/concerns (please note we cannot be responsible for the content of external websites).