Scottish Canals understands and respects the importance of your privacy and is committed to protecting your personal information. This privacy policy sets out how Scottish Canals uses and protects any information that you give us when you use this website or when you correspond with us in person, by mail or over email or phone call.

Should we ask you to provide certain information by which you can be identified when using this website or in communications with us, you can be assured that it will only be used in accordance with this privacy policy.

We may change this policy from time to time by updating this page. The date of last update is the date on which this is uploaded to the website.

 

Who are we?

Scottish Canals (“we,” “our,” “us”) are the data controller for the purposes of the Data Protection Act 2018 (“DPA”) and the UK General Data Protection Regulation (“UK GDPR”) in respect of the personal information which we hold about you.

Our full contact details are:

Records Manager and Data Protection Officer.

Email address: data.protection@scottishcanals.co.uk

Postal address: Scottish Canals, Canal House, Applecross Street, Glasgow G4 9SP

Telephone number: 0141 332 6936

 

What information do we collect?

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact data includes billing address, delivery address, email address and telephone numbers.
  • Financial data includes bank account and payment card details.
  • Transaction data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical data includes internet protocol (IP) address, your login data, 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.
  • Profile data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage data includes information about how you use our website, products and services.
  • Marketing and communications data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We do not generally collect any special categories of personal data about you (this 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). Nor do we collect any information about criminal convictions and offences. However, from time to time we may need to collect limited health data about you in order to enable us to make our facilities accessible to you or in connection with the provision of our services and will only do so to the extent that processing relates to personal data which are manifestly made public by you or with your consent.

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

You decide if you want to submit personal information to us when making a booking or purchase; entering into a contract with us; or submitting your personal data via our website or directly to us (by post, phone, email or otherwise).

 

How do we use your information?

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:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Further information about the legal basis we rely on is set out below in the Glossary section of this privacy policy.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that 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 contact us 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/ActivityType of dataLawful basis for processing including basis of legitimate interest
To register you as a new customer

(a) Identity

(b) Contact

Performance of a contract with you

To process and deliver your order/purchase or contract with us, including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(c) Issue tickets or confirmation to you

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(c) Contacting you regarding your mooring

(a) Identity

(b) Contact

(c) Profile

(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

(b) Contact

(c) Profile

(d) Usage

(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 this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(c) Technical

(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 website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website 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

(b) Contact

(c) Technical

(d) Usage

(e) Profile

Necessary for our legitimate interests (to develop our products/services and grow our business)
To issue our newsletter to you

(a) Identity

(b) Contact

Necessary for our legitimate interests (to develop our products/services and grow our business)

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Who do we share your personal data with?

We may have to share your personal data with the parties set out below for the purposes set out in the table above.

  • Service providers acting as processors based in the UK who provide IT and system administration or application services, including PlanIT (who provide maintenance and development services for our financial management system and will have access to your name, contact and bank account details), Target Applications Ltd. (who provide our customer survey applications and will have access to your name, email address, and phone number, if provided, for feedback purposes), Campaign Monitor (who will have access to your e-mail address so that we can send you our updates) and, if you provided your details through our website, MadeBrave (who maintains our website) will have access to those details;
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

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.

 

Where do we send your data?

Some of our external third party service providers have operations outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, 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 by UK Government. The third countries deemed by UK Government to have an adequate level of data protection do not currently differ from the European Commission’s list.
• Where we use certain service providers, we may use specific contracts approved by UK Government which give personal data the same protection it has in the UK (model contracts).
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

 

How do we secure data?

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect about our customers. 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 put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

Controlling your personal information

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms.

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

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 when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

You have the right to ask us not to contact you for marketing purposes and / or to withdraw your consent to direct marketing at any time. You can exercise this right by ticking the appropriate box when we contact you. You can also exercise this right at any time after giving consent by contacting us at data.protection@scottishcanals.co.uk.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, experience or other transactions.

What are your legal rights?

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

You have 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.
  • Withdraw consent.

These rights are explained below in the Glossary in more detail.

If you wish to exercise any of the rights set out above, please contact us.

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.

 

How long will we use your personal data?

We will keep your information only for as long as we need it to provide you with the goods, services or information you have requested, to administer your relationship with us, to comply with the law, or to ensure we do not communicate with people that have asked us not to. When we no longer need information we will always dispose of it securely, using specialist companies if necessary to do this work for us.

 

Important Contacts

If you have any questions, comments or requests regarding your personal information (including how to stop us contacting you with updates) please contact data.protection@scottishcanals.co.uk.

If you are unhappy with how we handle your personal information, you can contact us at data.protection@scottishcanals.co.uk and / or notify the Information Commissioner’s Office (ICO) by calling their helpline on 0303 123 1113. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

 

Cookies policy

Most websites you visit will use cookies in order to improve your user experience by enabling the website to ‘remember’ you, either for the duration of your visit (using a ‘session cookie’) or for repeat visits (using a ‘persistent cookie’).

Cookies do lots of different jobs, like letting you navigate between pages efficiently, storing your preferences, and generally improving your experience of a website. Cookies make the interaction between you and the website faster and easier. If a website doesn’t use cookies, it will think you are a new visitor every time you move to a new page on the site.

Some websites will also use cookies to enable them to target their advertising or marketing messages based for example, on your location and/or browsing habits.

 

What is in a cookie?

A cookie is a simple text file that is stored on your computer or mobile device by a website’s server and only that server will be able to retrieve or read the contents of that cookie. Each cookie is unique to your web browser. It will contain some anonymous information such as a unique identifier and the site name and some digits and numbers. It allows a website to remember things like your preferences or what’s in your shopping basket.

 

What to do if you don’t want cookies to be set?

Some people find the idea of a website storing information on their computer or mobile device a bit intrusive, particularly when this information is stored and used by a third party without them knowing. Although this is generally quite harmless you may not, for example, want to see advertising that has been targeted to your interests. If you prefer, it is possible to block some or all cookies, or even to delete cookies that have already been set; but you need to be aware that you might lose some functions of that website.

 

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

 

Glossary

Legal Basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Legal Rights

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

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