Welcome to the World Kusano-Ha Shitoryu Kenpo Karate-Do Association’s (“WKKA”) privacy notice.
WKKA respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.
1. Important Information and Who We Are
Purpose of this Privacy Notice
This privacy notice aims to give you information on how WKKA collects and processes your personal data, including any data you may provide through our website, when purchasing a product or service or taking part in a survey.
Due to the nature of the services we provide, our organisation also collects and processes personal data relating to children. Where consent is required in accordance with this privacy notice, it will be obtained from the respective parent or legal guardian of the child whose data is being processed.
It is important that you read this privacy notice, together with any other privacy notice or fair processing notice we may provide, so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
WKKA is the controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy notice).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions, please contact the data privacy manager using the details set out below.
Our full details are:
World Kusano-Ha Shitoryu Kenpo Karate-Do Association (WKKA)
Data privacy manager for the Scotland branch: Donald Morrison (Country Chief for WKKA Scotland and England)
Email address: firstname.lastname@example.org
Telephone number: 07887 795070
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Your Duty to Inform Us of Changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third Party Links
Our 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.
2. The Data we Collect About You
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, last name, details on parental status or guardianship, title, date of birth and gender.
Contact Data includes home address, email address and telephone numbers.
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 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 may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law (as this data does not directly or indirectly reveal your identity). For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.
With the exception of health data, we do not 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 genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Where it is necessary to collect and process data about your health, we will keep this to a minimum and obtain your explicit consent.
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, 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.
3. How is Your Personal Data Collected
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your 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 and use our products or services; or
submit enquiries, registrations or other forms on our website; or
subscribe to our newsletters and other publications; or
request marketing to be sent to you; or
enter a promotion or survey; or
give us some feedback.
Automated technologies or interactions. As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
Third parties. We may receive personal data about you from various third parties, such as analytics providers like Google Analytics.
4. How We Use Your Personal Data
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 to give you the best goods and services we can. We make sure we consider and balance any potential impact on you before we process your personal data for our legitimate interests. We will also not use your personal data where our interests are overridden by the impact on you.
Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting our data privacy manager.
Purposes for which We will Use Your Personal Data
The following is 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:
Necessary for the performance of a contract:
To register you as a new member.
To process and deliver your goods and services.
To manage our relationship with you.
Necessary for our legitimate interests:
To administer your membership and protect our organisation.
To deliver relevant content and publications to you and measure or understand the effectiveness of the publications we serve to you.
To enable you to take part in a promotion or to complete a survey.
To use data analytics to improve our website, products and services, marketing, member relationships and general experience of our organisation.
To make suggestions and recommendations to you about goods or services that may be of interest to you.
Necessary for our legal or regulatory obligations.
To comply with relevant law and regulation in order to provide goods and services.
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.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. In doing so, we have established the following personal data control mechanisms:
Promotional Offers From Us. We may use your Identity, Contact, Transaction, 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 to receive newsletters or other marketing communications and, in each case, you have not opted out of receiving that marketing.
Third-Party Marketing. We will get your express opt-in consent before we share your personal data with any other third party for marketing purposes.
Opting Out. You can ask us or third parties to stop sending you marketing messages at any time by contacting our Data Privacy Manager.
5. Disclosures of Your Personal Data
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.
6. International Transfers
We do not transfer your personal data outside the European Economic Area (EEA) without your consent.
Our website service provider (Wix) may store your personal data in data centers located in the United States of America, Ireland, South Korea, Taiwan and Israel. Wix may also use other jurisdictions as necessary for the proper delivery of website services or as may be required by law. Any transfer to a country, outside the European Union, that does not ensure an adequate level of protection by its own laws and regulations, will be undertaken in accordance with the Standard Contractual Clauses (2010/87/EU), which requires the same level of protection required by the European Commission.
7. Data Security
We have put in place appropriate security 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 individuals and third parties who have a 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.
8. Data Retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements.
9. 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 (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). Note: 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 that you feel impacts 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 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. 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 wish to exercise any of those rights, please contact our data privacy manager, having considered the following:
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 may 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.
Time Limit to Respond. 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.