Who are we?
“whatspa.co.uk”, “hottubchooser.co.uk” and “WhatSpa? Magazine” (referred to in this policy as “we”, “us” or “our”) are trading names of Deep Blue Leisure Limited. Deep Blue Leisure Limited is registered in England and Wales, company registration number 04592955. Our registered address is Bridge House, Gainsborough Road, Bawtry, Doncaster, DN10 6HT. Deep Blue Leisure Limited is registered with the Information Commissioner’s Office (ZA322859) and is also authorised and regulated by the Financial Conduct Authority (FCA) for regulated consumer credit activity only. Our firm reference number is: 916085. You can check this on the Financial Services Register at https://register.fca.org.uk
What data we collect & how we use it
This section tells you what personal data we may collect from you and how we use it when you use our services:
- Electronic newsletters
We will offer a free electronic newsletter to users. What Spa? gathers the email addresses of users who subscribe and opt-in. Users may remove themselves from this mailing list by following the link provided in every newsletter that points users to the subscription management page. Users can also subscribe to the newsletters at the time of registration.
- Message boards/forums
Users of the site’s Message Boards and Forums must register separately for these services (both are free of charge) in order to post messages, although they needn’t register to visit the site. During registration the user is required to supply a username, password, and email address.
- “E-mail this to a friend”
Our site users can choose to electronically forward a link, page, or documents to someone else by clicking “e-mail this to a friend”. The user must provide their email address, as well as that of the recipient. This information is used only in the case of transmission errors and, of course, to let the recipient know who sent the email. The information is not used for any other purpose.
We may offer interactive polls to users so they can easily share their opinions with other users and see what our audience thinks about important issues. Opinions or other responses to polls are aggregated and are not identifiable to any particular user. What Spa? may use a system to “tag” users after they have voted, so they can vote only once on a particular question. This tag is not correlated with information about individual users.
What Spa? may occasionally conduct user surveys to better target our content to our audience. We sometimes share the aggregated demographic information in these surveys with our sponsors, advertisers and partners. We never share any of this information about specific individuals with any third party.
- Magazine & Brochure Requests
When a visitor requests a copy of What Spa? magazine or related literature from our websites or publications, What Spa? collects personal data about the requester, including but not limited to your name, postal address, telephone, and email to complete your request. This information will be forwarded to our fulfilment house in order to process the mailing of your free copy of What Spa? Magazine.If you have consented to receive marketing relating to our partners the information then the information that you provide will be sent via the What Spa? affiliate network and automatically forwarded to one or more of our affiliate partners who locally offers the types of hot tub or swimspa product(s) you have identified. Our affiliate partners include but are not limited to, wet leisure distributors and retailers. After our affiliate partner(s) receive your request for information, they may individually contact you directly via phone, e-mail or other communications to send you marketing & promotional information related to their products and services.
- Discount Vouchers Requests
When a visitor requests a personalised discount voucher, the voucher will be generated and emailed to you along with a copy to the relevant retailer of the product associated with the voucher. In order that your discount voucher can be validated and processed by the retailer, the unique serial number of the voucher, along with your name, email address and telephone number will be disclosed to the retailer. By requesting a voucher you give your consent for the above information to be disclosed for the purposes of validation and redemption of the voucher.
- Usage tracking
What Spa? tracks user traffic patterns throughout all of our sites. However, we do not correlate this information with data about individual users. What Spa? does break down overall usage statistics according to a user’s domain name, browser type, and MIME type by reading this information from the browser string (information contained in every user’s browser).What Spa? sometimes tracks and catalogs the search terms that users enter in our Search function, but this tracking is never associated with individual users. We use tracking information to determine which areas of our sites users like and don’t like based on traffic to those areas. We do not track what individual users read, but rather how well each page performs overall. This helps us continue to build a better service for you.
- Interest-Based Online Advertising
We use a company called Google to collect and analyse information about the use of our website(s). We use Google Analytics’ 3rd-party audience data such as age, gender, and interests to better understand the behaviour of our customers and work with companies that collect information about your online activities to provide advertising targeted to suit your interests and preferences. This information helps us serve relevant advertisements to you on Google, and also helps us to measure the effectiveness of our marketing campaigns. If you have an account with Google, manage your advertising settings, otherwise you can manage these settings through your web browser as is described above. We also use a company called Facebook to collect and analyse information about the use of our website(s). This information helps us serve relevant advertisements to you on Facebook, and also helps us to measure the effectiveness of our marketing campaigns. If you have an account with Facebook, manage your advertising settings.
Sharing your personal data
We may share your data with third parties:
- if we are under a legal or regulatory duty to do so;
- to lawfully assist the police or security services with the prevention and detection of crime or terrorist activity; and
- where such disclosure is necessary to protect the safety or security of any persons, and/or (e) otherwise as permitted under applicable law. We may share your data with our carefully selected partners (they may change from time to time) via the WhatSpa? Affiliate network but we will only do this if you have consented to receive marketing relating to our sponsors and partners or if one of the conditions in the paragraph above applies.
How we look after your data
We will protect the data that you entrust to us via appropriate security measures and controls. We’ll also ensure that other businesses we work with are just as careful with your data.
We will always take appropriate technical and organisational precautions to prevent the loss, misuse or alteration of your personal information. Our websites are encrypted and secure.
We will continually test, audit and monitor our compliance with Information Security standards and relevant Data Protection regulations.
All the personal data we process is processed by our staff in the UK. No information is sent by WhatSpa? outside of the European Economic Area (EEA).
We have ensured that appropriate protections are in place to make sure your personal data remains adequately protected and is treated in line with relevant Data Protection laws.
How long we keep your data
We hold your information only as long as necessary for each purpose we use it, we will provide detailed information about our retention in this section before 25th May 2018 to give you an understanding of how long we hold your information for.
- Right to be Informed
We will always be transparent in the way we use your personal data. You will be fully informed about the processing through relevant privacy notices.
- Right to access
You have a right to request access to the personal data that we hold about you and this should be provided to you. At present we are able to charge a small fee of £10. From 25th May 2018 this will be free of charge. If you would like to request a copy of your personal data, please contact us.
- Right to rectification
We want to make sure that the personal data we hold about you is accurate and up to date. If any of your details are incorrect, please let us know and we will amend them.
- Right to erasure
You have the right to have your data ‘erased’ in the following situations:
If you would like to request erasure of your personal data, please contact us via point 13. Please note that each request will be reviewed on a case by case basis and where we have a lawful reason to retain the data, it may not be erased.
- Where the personal data is no longer necessary in relation to the purpose for which it was originally collected or processed.
- When you withdraw consent.
- When you object to the processing and there is no overriding legitimate interest for continuing the processing.
- When the personal data was unlawfully processed.
- When the personal data has to be erased in order to comply with a legal obligation.
- Right to restrict processing
You have the right to restrict processing in certain situations such as:
- Where you contest the accuracy of your personal data, we will restrict the processing until you have verified the accuracy of your personal data.
- Where you have objected to processing and we are considering whether our legitimate grounds override your legitimate grounds.
- When processing is unlawful and you oppose erasure and request restriction instead.
- Where we no longer need the personal data but you require the data to establish, exercise or defend a legal claim.
- Right to data portability
You have the right to data portability in certain situations. You have the right to obtain and reuse your personal data for your own purposes via a machine-readable format, such as a .CSV file. If you would like to request portability of your personal data, please contact us via point 13, this only applies:
- To personal data that you have provided to us;
- Where the processing is based on your consent or for the performance of a contract; and
- When processing is carried out by automated means.
- Right to object
You have the right to object to the processing of your in the following circumstances:
- Direct marketing (including profiling). Remember you can opt out at any time from marketing communications; and
- Where the processing is based on legitimate interests;
- Processing for purposes of scientific/historical research and statistics.
- Rights in relation to automated decisions making including profiling
- You have the right to not be subject to a decision when it is based on automated processing. If you have any questions in relation to how your information is processed in this way, then please contact us using the information in point 13.
Contact the ICO
If you feel that we have not upheld your rights, we ask that you contact us to discuss this, so that we can try and help.
If you are not satisfied with our response, or believe we are not processing your data in accordance with the law you have the right to lodge a complaint with the Information Commissioner’s Office (ICO). Their details are supplied below:
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Telephone: 0303 123 1113.
If you have any questions in relation to how we handle your personal data then please write to us at: Deep Blue Leisure Limited, Bridge House, Gainsborough Road, Bawtry, Doncaster, DN10 6HT. You can also email us at: firstname.lastname@example.org