Privacy
Policy.

Introduction

Welcome to Grapple Hacker. We respect your privacy and are committed to protecting your personal data.

This Privacy Policy explains how we collect, use, store and protect your personal information when you:

• Visit or use our website.
• Contact us by email, telephone, online form or in person.
• Register your interest in Grapple Hacker.
• Book or attend a class or training session.
• Become a member of Grapple Hacker.
• Take part in activities, events or services provided by Grapple Hacker.

Grapple Hacker aims to comply with applicable UK data protection law, including the UK General Data Protection Regulation and the Data Protection Act 2018.

Who We Are

For the purposes of applicable data protection law, Grapple Hacker is responsible for deciding how and why your personal information is processed.

If you have any questions about how we handle your personal data, you can contact us using the details above.

Information We Collect

The information we collect depends on how you interact with Grapple Hacker. We aim to collect only information that is reasonably necessary for the relevant purpose.

Information you provide to us

This may include:

• Your name.
• Email address.
• Telephone number.
• Membership and class information.
• Attendance and booking information.
• Information contained in enquiries or communications with us.
• Emergency contact information where relevant.
• Information needed to administer payments or memberships.
• Information you voluntarily provide about your training needs or circumstances.

Information relating to training and safety

Where relevant to participation in training, we may collect information about injuries, medical conditions, physical limitations or other health information that you choose or are required to provide for safety purposes.

Health information receives additional protection under UK data protection law. See the Health Information section below.

Information collected automatically

When you visit our website, certain technical information may be collected automatically depending on the technologies and services active on the website. This may include:

• IP address.
• Browser type and version.
• Device type and operating system.
• Pages visited and approximate interaction data.
• Referring website or source.
• Cookie and similar technology information.

How We Use Your Personal Data

We may use personal information for purposes including:

• Responding to enquiries and requests.
• Providing information about classes and services.
• Managing memberships, bookings and attendance.
• Administering payments and membership records.
• Communicating important information about classes, memberships or changes to services.
• Managing health and safety information where necessary for training.
• Maintaining appropriate emergency contact information.
• Improving our website, services and member experience.
• Preventing fraud, misuse or other unlawful activity.
• Complying with legal, accounting and regulatory obligations.
• Establishing, exercising or defending legal claims where necessary.

We will not use your personal information for purposes that are incompatible with the reason it was originally collected without taking appropriate steps to inform you where required by law.

Lawful Basis for Processing

We only process personal data where we have a lawful basis to do so under applicable data protection law.

Where we rely on legitimate interests, those interests may include operating and improving Grapple Hacker, managing our relationship with members and prospective members, maintaining security and protecting our business and members.

Health Information

Information concerning a person's health is treated as special category data under the UK GDPR and receives additional protection.

If you provide health, injury or medical information to us, we will only use it where necessary and appropriate for purposes such as training safety, adapting participation, responding to an emergency or complying with relevant legal requirements.

Where required by law, we will identify both a lawful basis under Article 6 of the UK GDPR and an appropriate additional condition under Article 9 before processing special category data.

We aim to limit access to health information to people who need it for the relevant purpose and will not use health information for unrelated marketing purposes.

Cookies and Website Tracking

Our website may use cookies and similar technologies. Cookies are small files or pieces of information stored on your device when you visit a website.

Depending on the technologies active on the website, cookies may be used for purposes such as:

• Making the website function correctly.
• Remembering preferences.
• Understanding how visitors use the website.
• Measuring website performance.
• Supporting marketing or advertising activity where applicable.

Strictly necessary cookies may be used where required for the operation of the website. Where applicable law requires consent for non-essential cookies or similar technologies, we will request consent before using them.

You can also control or delete cookies through your browser settings. Disabling certain cookies may affect how the website functions.

If we introduce additional analytics, advertising or tracking technologies, we will update this policy and provide any required consent mechanism.

Sharing Your Data

We do not sell or rent your personal information.

We may share information with trusted third parties where necessary to operate Grapple Hacker and provide our services. These may include:

• Website hosting and technical service providers.
• Email and communication providers.
• Membership, booking or class management providers.
• Payment and financial service providers.
• Professional advisers such as accountants, insurers or legal advisers where appropriate.
• Emergency services or other relevant organisations where necessary for safety.
• Government, regulatory or law enforcement bodies where legally required.

Where a third party processes personal data on our behalf, we expect appropriate contractual and security arrangements to be in place.

International Transfers

Some service providers we use may process personal information outside the United Kingdom.

Where personal information is transferred outside the UK, we will take appropriate steps to ensure that the transfer is lawful and that suitable safeguards are in place as required by applicable data protection law.

Depending on the circumstances, this may include relying on an adequacy decision, appropriate contractual safeguards or another lawful transfer mechanism.

Data Security

We take reasonable technical and organisational measures to protect personal information against unauthorised access, accidental loss, misuse, alteration or disclosure.

Access to personal information is limited to people and service providers who need it for legitimate purposes.

However, no method of transmitting information over the internet or storing information electronically can be guaranteed to be completely secure.

Data Retention

We keep personal information only for as long as reasonably necessary for the purposes for which it was collected, including where necessary to:

• Provide our services.
• Manage memberships and records.
• Meet accounting, tax or other legal obligations.
• Resolve disputes.
• Establish, exercise or defend legal claims.
• Maintain appropriate business records.

Different types of information may be retained for different periods. When information is no longer required, we will take reasonable steps to securely delete or anonymise it.

We do not retain personal information indefinitely simply because it has been collected.

Marketing Communications

We may occasionally send information about Grapple Hacker, classes, events, offers or other services where permitted by law.

Where consent is required for electronic marketing, we will obtain the appropriate consent before sending those communications.

You can unsubscribe from marketing communications at any time by using the unsubscribe option provided in the communication or by contacting us at:

info@grapplehacker.com

Opting out of marketing does not prevent us from sending essential service or administrative communications relating to your membership, bookings, payments, safety or other services you have requested.

Your Rights

Depending on the circumstances and applicable legal requirements, you may have rights in relation to your personal data, including the right to:

• Request access to personal information we hold about you.
• Ask us to correct inaccurate or incomplete information.
• Ask us to delete personal information where there is no lawful reason for us to continue processing it.
• Ask us to restrict processing in certain circumstances.
• Object to certain processing, including direct marketing.
• Withdraw consent where processing is based on consent.
• Request portability of certain information where the right applies.

These rights are not absolute and exceptions may apply under data protection law.

To exercise your rights, contact us using the details in the Contact Us section.

We may need to verify your identity before responding to a request.

Children and Young People

Grapple Hacker may offer or allow participation by young people where appropriate.

Where we collect personal information relating to a child or young person, we will take appropriate steps to provide privacy information in a way that is understandable and appropriate for their age and circumstances.

Where parental or guardian involvement or consent is required for membership, participation or the processing of personal information, we will request it.

We will take particular care with children's information and will not use it for direct marketing in circumstances where doing so would breach applicable data protection or electronic marketing rules.

Automated Decision Making

We do not currently intend to make decisions about members or prospective members based solely on automated processing where that decision has legal or similarly significant effects.

If this changes, we will provide the information required by applicable data protection law, including information about the logic involved and the relevant rights and safeguards where applicable.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes to our business, services, technology or legal requirements.

The latest version will be published on this page with the relevant effective and updated dates.

We encourage you to review this page periodically so that you remain aware of how we handle personal information.

Contact Us

If you have a question about this Privacy Policy or how Grapple Hacker handles your personal information, please contact us.

Complaints

If you have concerns about how we have handled your personal information, we encourage you to contact us first so that we can try to resolve the issue.

You also have the right to complain to the UK's independent data protection regulator, the Information Commissioner's Office (ICO).