Privacy Policy

Who we are

Deep Blue Scuba Dive Club is a Scottish Charitable Incorporated Organisation (SCIO) registered in Scotland with number SC046575.

Registered address: 10a Dick Place, Edinburgh EH9 2JL

Main trading address:16 West Gorgie Parks, Edinburgh EH14 1UT.

We are regulated by the Office of the Scottish Charity Regulator (OSCR)

We area Professional Association of Dive Instructors (“PADI”) 5-star Instructor Development Centre.

Our website address is: http://deepbluescuba.co.uk.

What personal data we collect and why we collect it

What Does This Notice Cover?

This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.

What is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

The personal data that we use is set out in Part 5, below.

What are my rights?

Under the GDPR, you have the following rights, which we will always work to uphold:

  1. The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
  2. The right to access the personal data we hold about you. Part 10 will tell you how to do this.
  3. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
  4. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 11 to find out more.
  5. The right to restrict (i.e. prevent) the processing of your personal data.
  6. The right to object to us using your personal data for a particular purpose or purposes.
  7. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
  8. Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

What Personal Data Do You Collect?

We may collect some or all of the following personal data (this may vary according to your relationship with us):

  • Name;
  • Date of birth;
  • Gender;
  • Address;
  • Email address;
  • Telephone number;
  • Payment information;
  • Information about your preferences and interests;
  • Previous dive certifications and experience
  • Personal medical information relevant to your dive training

Your personal data may also be obtained from the following third parties:

PADI, SSI, CMAS, NAUI and similar dive training organisations when checking your previous dive certifications and experience for training purposes, or for ensuring that you are in teaching status where relevant.

Comments

When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

Media

If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Cookies

If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracing your interaction with the embedded content if you have an account and are logged in to that website.

How Do You Use My Personal Data?

Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data will be used for the following purposes:

  • Supplying our training courses, dive trips and other services to you. Your personal details are required in order for us to enter into a contract with you.
  • Personalising and tailoring our services for you including members’ discounts available
  • Communicating with you. This may include responding to emails or calls from you.
  • Supplying you with information by email that you have opted-in to (you may unsubscribe or opt-out at any time by using the Unsubscribe link at the foot of every newsletter email.
  • Checking your dive certifications and/or teaching status

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and/or telephone and/or text message with information, news, and offers on our products or services. You will not be sent any unlawful marketing or spam. we will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

  • Membership data – 7 years or as required by OSCR;
  • Course bookings – 7 years or as required by OSCR and/or our insurers
  • Billing information and accounting records – 7 years or as required by OSCR

Paper records including PADI liability releases, medical forms, shore sheets etc – 7 years or as required by PADI and/or our insurers.

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

 

How and Where Do You Store or Transfer My Personal Data?

We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR as follows.

We share your data with external third parties, as detailed below, that may be based outside of the EEA. The following safeguards are applied to such transfers:

We will only transfer your personal data to countries that the European Commission has deemed to provide an adequate level of personal data protection. More information is available from the European Commission.

Where we transfer your data to a third party based in the US, this may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar levels of data protection to those in Europe. More information is available from the European Commission.

Any posts or comments on this website together with your related data may be transmitted to an automated spam checking service.

Please contact us for further information about the particular data protection mechanism used by us when transferring your personal data to a third country.

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

  • Paper records are stored at 16 W Gorgie Place, Edinburgh. This is kept locked when not occupied, and a log is kept of all keyholders
  • Online records are maintained with providers including Google (G-Suite), Xero, Dropbox, iContact and PADI. Access to all of these is protected by login and password. Allocation of logins is controlled, and individuals must be given specific permission to access records containing personal data.

Do You Share My Personal Data?

We may sometimes contract with the following third parties to supply products and/or services to you on our behalf. These may include payment processing, accounts, delivery, and marketing. In some cases, those third parties may require access to some or all of your personal data that we hold.

  • Xero – xero.com – for billing, accounting and payment services
  • Paypal paypal.com for payment services
  • Stripe stripe.com for payment services
  • iContact icontact.com for newsletter administration and mailing list administration
  • PADI padi.com for provision of dive training materials and resources, dive certifications, and incident reports
  • Emergency First Response emergencyfirstresponse.co.uk for first aid training materials and first aid certifications
  • OSCR oscr.org.uk where they request membership lists for governance purposes
  • Our insurance brokers from time to time – for calculating insurance premiums, adding drivers to our van insurance, adding staff to our dive insurance policy and similar

If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above

If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown above or below or via contact us. To make this as easy as possible for you, a Subject Access Request Form may be provided on request for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within 4 weeks and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use contact us (for the attention of the Treasurer and add the subject line “GDPR Subject Access Request”

Changes to this Privacy Notice

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be made available on our website – www.deepbluescuba.co.uk .