Last updated: 21.06.2021
Who we are
b_together is part of the COMO Group, and may share your personal data with other entities within that group for the purposes of administering the COMO Club Recognition Programme if you register and opt in to the COMO Club Recognition Programme. Where it does so, COMO Group will process your personal data in accordance with its Privacy Statement and Cookies Policy here: [LINK] https://www.comoclub.com/web-privacy-policy.
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:
• Children’s Identity Data includes first name, last name, date of birth, gender and photographs.
• Children’s Profile and Care Data includes a child’s needs, where we need this information to provide the requested services, information on the child while in our care in order to provide reports to the parent or guardian.
• Children’s Accessibility Data includes personal data related to health provided to us in order to access our facilities or services (for example if wheelchair access is required or information on allergens or other conditions).
• 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.
• 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.
• Accessibility Data includes personal data related to health which you provide to us in order to access our facilities or services (for example if wheelchair access is required or information on allergens).
• Marketing Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Certain categories of personal data receive particular protection under the laws of certain countries. For example, in the UK/EU, special categories of personal data (this includes details about 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) as well as data relating to criminal convictions and offences receive enhanced protection. We will comply with applicable laws when processing such personal data.
If you fail to provide personal data
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.
We use different methods to collect data from and about you including through:
· Direct interactions. You may give us your Identity, Contact, Financial, Profile, Accessibility and Children’s Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• apply for our products or services;
• create an account on our website, mobile application or sign up to be a Club member;
• sign up a child to our childcare, classes and camps;
• when you visit our restaurant facilities;
• when you stay in our accommodation or book our event space;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us feedback or contact us.
· Third parties or publicly available sources. We may be given information about you from third parties, such as social media platforms and analytics providers such as Google. We may also collect information that is publicly available, for example, when we interact with you through social media.
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 obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message or before processing special categories of personal data. You have the right to withdraw your consent at any time by contacting us below.
We may also rely upon protection of vital interests as a lawful basis for processing special categories of personal data, for example to disclose your personal data to emergency services where we believe it is necessary to protect your vital interests or the vital interest of another person.
Purposes for which we will use your personal data
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/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register new customers and children||(a) Identity
(c) Children’s Identity Data
|Performance of a contract with you|
|To provide services to you, including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(g) Children’s Data
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
(c) Consent, in respect of special categories of personal data
|To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(e) Children’s Data
|(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
|(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, website and mobile application (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity
(d) Children’s Data
|(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
|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
|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
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
|To operate CCTV at our premises||Images of you and of children at our premises||Necessary for our legitimate interests (to maintain the safety and security of our premises and for the prevention / detection of crime)|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You can update your marketing preferences by logging in to your account on our website or using our mobile application by contacting us using the details below
Promotional offers from us
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 and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.
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 or other transactions.
Change of purpose
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.
We may share your personal data with the parties set out below for the purposes set out in the table above.
· other companies within the COMO Group for marketing, business, administrative and legal purposes;
· Facebook, Twitter or Instagram or any other social media platforms that b-together may use from time to time, if you use your account with them to sign up / in with us, if applicable;
· service providers, business partners, suppliers, subcontractors or agents (for example, fitness, medical and healthcare professionals providing assessments for treatments, IT services, travel planning, reservation, booking, rewards management, customer relationship management, business development and marketing support services) who perform functions such as marketing, payment, fulfilment and delivery of orders, administration and processing of payments, as well as bookings and reservations;
· professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services;
· vendors who provide services to us, such as fulfilling orders, providing data processing and other information technology services, managing promotions, and carrying out research and analysis. We do not allow these vendors to use this information or to share it for any purpose other than to provide services on our behalf;
· government or other law enforcement agencies, in connection with the investigation of unlawful activities or for other legal reasons;
· third parties, who acquire us or substantially all of our assets, in which case your personal data (including any sensitive personal data) will be one of the transferred assets (however, we will let you know before this happens); and
· analytics and search engine providers that assist us in the improvement and optimization of the b-together website.
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.
We may share your personal data in a manner which involves transferring your data outside the UK or the country you are located depending on the circumstances. This includes Singapore and United Kingdom, but also countries where our external service providers are based or hosting your personal data on our behalf.
If we transfer your personal data, we will always do so under strict conditions of confidentiality and similar levels of security safeguards.
As mentioned above, please note that the rights of governmental and law enforcement authorities to access your personal data may also differ depending on where the personal data is held. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or Singapore, using the details set out below.
We have put in place appropriate technical and organisational measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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.
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 for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
If you are in the UK or EEA, under certain circumstances, you have the following rights under data protection laws in relation to your personal data:
• 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:
· If you want us to establish the data’s accuracy.
· Where our use of the data is unlawful but you do not want us to erase it.
· 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.
· 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.
If you are located in other countries, you may have other rights under applicable data protection laws.
If you wish to exercise any of the rights set out above, we recommend that you use our dedicated data subject access request form here. Alternatively, you can contact us using the details below.
No fee usually required
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 could refuse to comply with your request in these circumstances.
What we may need from you
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.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could 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.
Email address: email@example.com
Postal address: Quadrant House, Floor 6, 4 Thomas More Square, London, United Kingdom, E1W 1YW
If you are in the UK, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.