Marlborough Flying Club Privacy Policy: Protecting Your Personal Data

At Marlborough Flying Club, we are committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy outlines how we collect, use, disclose, and safeguard your data when you interact with our website and services.

1. Introduction

Welcome to the Marlborough Flying Club website (https://marlboroughflyingclub.com). Marlborough Flying Club (“we”, “us”, “our”) is committed to protecting and respecting your privacy. This policy explains how we collect, use, store, and protect your personal data when you visit our website, interact with us, or use our services (such as membership enquiries, trial flight bookings, etc.).

This policy complies with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

2. Data Controller

For the purpose of the UK GDPR and the Data Protection Act 2018, the data controller is:
MARLBOROUGH FLYING CLUB LTD
Draycot Aerodrome, Chisledone, Swindon, Wilstshire
Company number 15913804

If you have any questions about this privacy policy or our data protection practices, please contact us using the details below:

3. Information We Collect About You

We may collect and process the following types of personal data:

  • Identity Data: Includes first name, last name, title, date of birth, membership status.
  • Contact Data: Includes billing address, delivery address, email address, telephone numbers.
  • Financial Data: Includes bank account and payment card details (often processed securely by a third-party payment provider – see Section 7).
  • Transaction Data: Includes details about payments to and from you and other details of products and services you have purchased from us (e.g., membership fees, flight bookings).
  • Technical Data: Includes internet protocol (IP) address, your login data (if applicable), browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  • Usage Data: Includes information about how you use our website, products,7 and services (e.g., pages visited, time spent on site).
  • Marketing and Communications Data: Includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  • Profile Data: Includes usernames and passwords (if applicable for member areas), purchases or orders made by you, your interests, preferences, feedback, and survey responses.
  • Special Category Data: In specific circumstances related to flight training or membership safety requirements, we might need to collect sensitive information (e.g., health declarations relevant to fitness to fly). We will only collect this with your explicit consent or where legally required and will treat it with the highest level of security.

4. How We Collect Your Personal Data

We collect data in the following ways:

  • Direct Interactions: You may give us your Identity, Contact, Financial, and Profile Data by filling in forms (e.g., contact forms, membership applications, booking forms) or by corresponding with us by post, phone, email, or otherwise.
  • Automated Technologies or Interactions: As you interact with our website, we10 may automatically collect Technical Data about your equipment, Browse actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. Please see our Cookie Policy Highly Recommended to Create a Separate One for further details.
  • Third Parties or Publicly Available Sources: We may receive personal data about you from various third parties such as analytics providers (e.g., Google Analytics), payment service providers, or publicly available sources.

5. Lawful Basis for Processing Your Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Performance of Contract: Where we need to perform the contract we are about to enter into or have entered into with you (e.g., processing your membership application, booking a trial flight).
  • Legitimate Interests: Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not17 override those interests (e.g., responding to inquiries, improving our website and services, administration, security).
  • Legal Obligation: Where we need to comply with a legal or regulatory obligation (e.g., financial record keeping, aviation safety regulations).
  • Consent: Where you have given us specific consent to use your personal data for a particular purpose (e.g., sending you marketing newsletters). You have the right to withdraw consent at any time.

6. How We Use Your Information

We use the information we collect for various purposes, including:

  • To provide and manage our services (e.g., memberships, flight bookings, training).
  • To process payments and manage financial transactions.
  • To respond to your enquiries and communications.
  • To manage our relationship with you, including notifying you about changes to our terms or privacy policy.
  • To administer and protect our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data).
  • To deliver relevant website content and measure or understand the effectiveness of the content we serve to you.
  • To use data analytics to improve our website, services, marketing, customer relationships, and experiences.
  • To send you marketing communications (where you have consented) about club news, events, and offers.
  • To comply with legal and regulatory requirements (including aviation safety).
  • For safety and emergency contact purposes (e.g., next of kin details for members).

7. Data Sharing and Third Parties

We may have to share your personal data with the parties set out below for the purposes set out in Section 6:

  • Service Providers: Companies that provide IT and system administration services, website hosting, analytics (e.g., Google Analytics), payment processing (e.g., Stripe, PayPal, GoCardless), booking systems Google and High Level, email marketing platforms engaged with Facebook and High Level.
  • Professional Advisers: Including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.
  • HM Revenue & Customs, Regulators, and Other Authorities: Such as the Civil Aviation Authority (CAA), who require reporting of processing activities in certain circumstances.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

8. International Data Transfers

Some of our external third-party providers may be based outside the UK or European Economic Area (EEA), so their processing of your personal data will involve a transfer of data outside the UK/EEA.

Whenever we transfer your personal data out of the UK/EEA, we ensure a similar degree of protection is afforded to it 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.
  • Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK (e.g., Standard Contractual Clauses or the UK’s International Data Transfer Agreement).

Please contact us if you want further information on the specific mechanism used31 by us when transferring your personal data out of the UK/EEA.

9. 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. These measures include [Briefly mention general measures like encryption where appropriate, access controls, secure servers – avoid excessive detail].

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 procedures to deal with any suspected personal data breach and will notify you and any applicable regulator (like the ICO) of a breach where we are legally required to do so.

10. Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process it, and applicable legal requirements. For example:

  • Membership data may be kept for the duration of the membership plus a reasonable period afterwards (e.g., [Specify period, e.g., 6 years] for legal/financial records).
  • Enquiry data may be kept for [Specify period, e.g., 1-2 years] after the enquiry is resolved.
  • Website analytics data may be anonymised or retained for [Specify period, e.g., 26 months].

11. Your Data Protection Rights

Under UK data protection law, you have rights including:

  • Right of Access: To request access to your personal data.
  • Right to Rectification: To request correction of inaccurate personal data.
  • Right to Erasure: To request deletion of your personal data (under certain conditions).
  • Right to Restrict Processing: To request the restriction of processing your personal data.
  • Right to Data Portability: To request the transfer of your personal data to you or a third party.
  • Right to Object: To object to processing where we rely on legitimate interests.
  • Right to Withdraw Consent: To withdraw consent at any time where we rely on consent to process your data.

To exercise any of these rights, please contact us using the details in Section 2. You will not usually have to pay a fee, but we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. We may need to request specific information from you to help us confirm your identity.

12. Cookies and Tracking Technologies

Our website uses cookies and similar technologies to distinguish you from other users, provide functionality, and analyse website usage. For detailed information on the cookies we use and the purposes for which we use them, please see our Cookie Policy. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

13. Children's Privacy

Our website and services45 are not intended for children under the age of 16, and we do not knowingly collect data relating to children without parental consent where required. If we become aware that we have collected personal data from a child under 16 without verification of parental consent, we will take steps to remove that information.

14. Links to Other Websites

Our 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.

15. Changes to This Privacy Policy

We keep our privacy policy under regular review. Any changes we make will be posted on this page and, where appropriate, notified to you by email or through a website notice. Please check back frequently to see any updates or changes. This policy was last updated on 16/04/2025.

16. How to Complain

If you have any concerns about our use of your personal information, you can make a complaint to us using the contact details in Section 2.

You also have the right to lodge a complaint with the UK’s supervisory authority for data protection issues, the Information Commissioner’s Office (ICO).

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline53 number: 0303 123 1113

ICO website: https://www.ico.org.uk

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