GDPR Policy
1. Who we are:
Company Name: Rebelle Surf
Company Address: Shore Rd, Strandhill, County Sligo
Contact details: rebellesurf@gmail.com/0830643552
Data protection officer: Melanie White
2. Where do we process personal data:
Rebelle Surf stores and process personal data in Ireland. Bookings made online are processed by Rezgo outside of Ireland. Here is a link to their privacy Policy https://www.rezgo.com/privacy-policy
Purpose of the processing:
Rebelle Surf School process personal data for the following purpose(s):
⦁ Client administration
⦁ Direct Marketing (not currently)
⦁ Provision of goods or services
⦁ Legal obligations
⦁ Employee administration
⦁ Booking page Insights
⦁ Keeping accurate records for revenue etc.
⦁ The legal basis for this processing is:
⦁ Consent
⦁ Where the processing enables us to enhance, modify, personalise or otherwise our services / communications for the benefit of our customers.
⦁ To better understand how people interact with our websites.
⦁ To determine the effectiveness of promotional campaigns and advertising.
3. Types of Information Collected
We retain two types of information:
“Personal Data”:
This is data that identifies you or can be used to identify or contact you and may include your name, address, email address, user IP addresses in circumstances where they have not been deleted, clipped or anonymised and telephone number. Such information is only collected from you if you voluntarily submit it to us.
“Non-Personal Data”:
Like most websites, we gather statistical and other analytical information collected on an aggregate basis of all visitors to our website. This Non-Personal Data comprises information that cannot be used to identify or contact you, such as demographic information regarding, for example, user IP addresses where they have been clipped or anonymised, browser types and other anonymous statistical data involving the use of our website.
4. Recipient(s) of the personal data:
In general, the third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us. However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions.
For these providers, we recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by these providers.
For Voucher sales we use Stripe and Rezgo.
For online bookings we use Rezgo and Stripe.
Rezgo
Our booking system is hosted by Rezgo. They provide us with the online e-commerce platform that allows us to sell our services to you. Your data is stored through Rezgo’s data storage, databases and the general Rezgo application. They store your data on a secure server behind a firewall.
5. Details of transfers to third country/countries:
Certain providers may be located in or have facilities that are located a different jurisdiction than either you or us. So if you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.
See above Info on Rezgo booking system.
As an example, if you are located in Canada and your transaction is processed by a payment gateway located in the United States, then your personal information used in completing that transaction may be subject to disclosure under United States legislation, including the Patriot Act.
Once you leave our business’s website or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy or our website’s Terms of Service.
GOOGLE ANALYTICS
Our website uses Google Analytics to help us learn about who visits our site and what pages are being looked at.
LINKS
When you click on links on our site, they may direct you away from our site. We are not responsible for the privacy practices of other sites and encourage you to read their privacy statements.
6. Security
Your Personal Data on our booking system is held on secure servers hosted by Amazon AWS in a data centre in Dublin. To protect your personal information, we take reasonable precautions (including appropriate technical and organisational measures) and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed.
7. Data Retention period:
Rental consent forms will be kept for 6 months
Kids/teens camp consent forms will be kept for 4 months
Accident reports will be kept for 3 years
Payment details will be kept for 6 years after the end of the financial year
In accordance with our obligations under the Data Protection Acts 1988 and 2002 we will update or delete your Personal Data accordingly. To find out what Personal Data we hold on you or to have your Personal Data updated, amended or removed from our database, please email us at rebellesurf@gmail.com
8.1 Your rights:
You have the following rights in respect to the personal data that Rebelle Surf School hold on you. Please contact us at the address above in order to exercise any of these rights:
⦁ The right to be informed:
⦁ You have the right to receive “fair processing information”.
⦁ The right of access:
You have the right to obtain:
⦁ Confirmation of your personal data being processed
⦁ Access to a copy of your personal data
⦁ And any other supplementary information
⦁ The right to rectification
⦁ You have the right to have your personal data corrected if it is inaccurate or incomplete
⦁ The right to erasure (includes withdrawal of consent)
⦁ You have the right to have your personal data erased, in the following circumstances:
⦁ You withdraw consent.
⦁ The personal data has to be deleted to comply with a legal obligation.
⦁ The personal data was unlawfully processed.
⦁ Where the personal data is no longer necessary in relation to the purpose for which it was originally collected.
⦁ Where you object to the processing and there is no superseding legitimate requirement to continue the processing.
⦁ The personal data is processed in relation to the offer of “information society services” to a child.
⦁ The right to restrict processing
⦁ You have the right to ‘block’ or suppress processing of personal data
⦁ The right to data portability
⦁ You have the right to obtain and reuse their personal data for their own purposes across different services.
⦁ The right to object
⦁ You have the right to object to:
⦁ Processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling).
⦁ Direct marketing (including profiling).
⦁ Processing for purposes of scientific/historical research and statistics.
⦁ Rights in relation to automated decision making and profiling
⦁ You have the right not to be subject to a decision when:
⦁ It is based on automated processing.
⦁ It produces a legal effect or a similarly significant effect on the data subject.
8.2 The right to complain:
If you feel that Rebelle Surf School has not fulfilled its obligations under the General Data Protection Regulation 2016/679, then you have the right to lodge a complaint with the Data Protection Commissioner (DPC).
The DPC offers guidance on how to make a complaint here:
https://www.dataprotection.ie/docs/Making-a-Complaint-to-the-Data-Protection-Commissioner/r/18.htm
9. Automated decision making, including profiling:
Rebelle Surf School do not use any automated decision making (The ability to make decisions without human involvement) or profiling (Automated processing of personal data with the aim on evaluating personal aspects relating to a person or group of people).
10. Age of consent
By using this site, you represent that you are at least the age of majority in your state or province of residence, or that you are the age of majority in your state or province of residence and you have given us your consent to allow any of your minor dependents to use this site.
11. Changes to this privacy policy
We reserve the right to modify this privacy policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the website. If we make material changes to this policy, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it.
12. Cookies
Our online booking page and google analytics uses cookies to help us learn about who visits our site and what pages are being looked at.
Questions and contact information
If you would like to: access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information contact our Data protection officer at rebellesurf@gmail.com.com or by mail at:
Rebelle Surf
C/O Data Protection Officer,
Montana, Buenos Ayres Drive, Strandhill, County Sligo, Ireland