DP Leisure and 360 Play is committed to protecting your privacy, and takes its responsibilities regarding the security of customer information very seriously. This policy explains how we use customer information and how we protect your privacy.
The policy is written so you are fully informed about practices and to ensure you are fully informed on how DP Leisure and 360 Play use and process your data. We hope the following information will answer any questions you have but if not, please do get in touch with us via email at DPO@DpLeisure.co.uk
DP Leisure GB Ltd is the management company for the 360 Play Group of companies all of which are owned by DP Associates who’s Founder and Managing Director is Duncan Phillips. Duncan Phillips set the group up to deliver meaningful family play experience to families like his own. Since founding the company in January 2008 the Group of companies has never shared or intends to share marketing information with third party organisations. It is necessary to share information regarding financial processing or business transactions i.e. bank payments, memberships and credit and debit card transactions. This will be carried out in accordance to current regulation, guidance and best practice and always in a secure and responsible manner.
We may collect additional information in connection with your participation in any promotions or competitions offered by us and information you provide when giving us feedback. We may contact you by post, e-mail or telephone to ask your opinions.
360 Play is a membership facility, therefore to protect our customers we have a legitimate interest to collect personal information prior to allowing entrance to the 360 Play centres. Upon successful registration and payment of your registration fee you will be sent an introduction email containing our terms and conditions of business. You should only join and pay your membership fee if you have read and accepted our terms and condition these can be found on the rear of the registration card, displayed at each centre prior to entry and on our website. Receiving this introduction email is mandatory to complete our registration process. Upon receipt of this initial email you then have an option to opt out of subsequent membership information and marketing corresponded. If you do not want to receive commercial communications from us, please select your choices by using the opt-out box available on the introduction email. You will also be able to unsubscribe at anytime by following the unsubscribe link in any of our email communications.
Providing your detail and your registration payment being taken is seen as your agreement to abide by our terms and conditions.
Please note there may be instances where it may be necessary for us to communicate with you for administrative or operational reasons relating, for example, to advise you of alterations to opening hours.
Third Party Sharing
The only personal data which will be shared will be information relating to payment of services, this may include information about your method of payment and bookings, to the credit or debit card company that issued the card with which you made your booking. For your convenience and information the DP Leisure / 360 Play websites provides links to other websites. DP Leisure / 360 Play would like to make you aware that these sites may have different security and privacy policies and those we have no control over and take no responsibility for any information contained in these sites.
The information that you provide to us will be held in our systems, which are located on our premises or those of an appointed third party. We may also allow access to your information by other third parties who act for us for the purposes set out in this policy or for other purposes approved by you.
Security to protect your information and data retention. When you book a party, register on-line or enter personally identifying information, your details are transmitted across the internet securely using high-grade encryption (128 bit). Furthermore, as required by the UK Data Protection Acts of 1984 and 1998, we follow strict security procedures in the storage and disclosure of information which you have given us, to prevent unauthorised access.
Our security procedures mean that we may request proof of identity before we are able to disclose sensitive information to you. In the circumstances set out in this policy where DP Leisure / 360 Play passes your information to a third party, we will ensure that the security measures that such party has in place in relation to the processing of your data are at least as stringent as those employed by DP Leisure / 360 Play. This does not apply where we are required by law to pass your information to a third party. We will retain your information for a reasonable period or as long as the law requires
Website and Social Media
Cookies are small pieces of information that are stored by your browser on your computer’s hard drive. They enable us to provide features such as remembering aspects of your last booking search to make subsequent searches faster. Cookies can be deleted from your hard drive if you wish. Most web browsers automatically accept cookies, but you can change your browser settings to prevent that. Even without a cookie you can use most of the features on the web site. Our cookies do not contain any personally identifying data.
Use of pixels
In order to understand how our customers interact with the emails and the content that we send, we use pixels in the email in order to understand who has opened the message. In order to provide our content in the most interesting way, we may also use pixels to learn whether you can receive emails in text or html form.
The Legal basis we rely on
In specific situations, we can collect and process your data with your consent.
- Providing your detail, payment of your registration fee triggers an initial introduction email, within this email is an option to opt out of further membership correspondence.
- If you tick a box to receive email newsletters.
When collecting your personal data, we’ll always make clear to you which data is necessary in connection with particular services.
In certain circumstances, we need your personal data to comply with our contractual obligations.
- If you set up a direct debit, annual membership.
- Book a birthday party, group visit.
If the law requires us to, we may need to collect and process your data.
- We can pass on details of people involved in fraud and other criminal activity
In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.
- Sending of the introduction email to ensure all members are aware of Terms and conditions.
- As part of your membership we will supply you with current offer, promotions or changes in operating times.
- We will use your admission history to offer you promotions and offers which may be relevant to you.
- We will also use your address details to send you direct marketing information by post, telling you about offers and activities that we think might interest you.
In specific situations we may be required to share information to facilitate treatment of preserve life.
- If you had an accident within one of our centers, we may be required to disclose information to the emergency services.
When we collect your personal Data
- When you visit any of our websites, and use your account to buy products and services.
- When you make an online purchase.
- When you become a member on your first visit to one of our centres.
- When you engage with us on social media.
- When you contact us by any means with queries, complaints etc.
- When you ask one of our team to email you information about a product or service, like a birthday party booking or private hire.
- When you enter prize draws or competitions.
- When you book any kind of event with us.
- When you choose to complete any surveys we send you.
- When you comment on or review our products and services.
What Sort of personal data we collect
- When you first join our membership at your first visit to a 360 attraction you have an account set with us: your name, gender, date of birth, address, email and telephone number. We will also hold photographs of accompanied children to verify them to the family membership set up and enhance the security.
- Details of your interactions with us through head office, in store, or online.
- We collect notes from our conversations with you, details of any complaints or comments you make, details of purchases you made or booked.
- Details of your visits to our websites or apps, and which site you came from to ours.
- Personal details which help us to recommend offers of interest.
- Payment card information.
- Your comments and activities we may have provided to you ie Birthday Parties.
- Your image may be recorded on CCTV when you visit a 360.
- To deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country and telephone code where your computer is located, the web pages viewed during your visit, the advertisements you clicked on, and any search terms you entered. Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.
How and why we use your personal data
Primarily we collect registration information to enhancing the safety of our guests.
We also want to give you the best possible customer experience, by amalgamating all information we hold on you we are able to offer you promotions, products and services that are most likely to interest you. In the case of annual pass members, we’ll also offer you relevant rewards. Data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service.
Here’s how we’ll use your personal data and why:
- To process any orders that you make by using our websites, or in 360.
- To respond to your queries, refund requests and complaints. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
- To protect our business from fraud and other illegal activities.
- To protect our customers, premises, assets and team members from crime, we operate CCTV systems in our attractions and car parks which record images for security. We do this on the basis of our legitimate business interests.
- To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud.
- If we discover any criminal activity or alleged criminal activity through our use of CCTV, fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. We aim is to protect the individuals we interact with from criminal activities.
- With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email, web, text, telephone and through our head office about relevant offers and activities including tailored special offers, discounts, promotions, events, competitions and so on.
Of course, you are free to opt out of hearing from us by any of these channels at any time.
- To send you relevant, personalized communications by post in relation to updates, offers, services and products. We’ll do this on the basis of our legitimate business interest.
You are free to opt out of hearing from us by post at any time.
- To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice, product recall notices, and legally required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
- To administer any of our prize draws or competitions which you enter based on your consent given at the time of entering.
- To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests.
- To comply with our contractual or legal obligations to share data with law enforcement.
For example, when a court order is submitted to share data with law enforcement agencies or a court of law
- To send you survey and feedback requests to help improve our services and facilities. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you.
Of course, you are free to opt out of receiving these requests from us at any time by updating your preferences in your online account.
- To build a rich picture of who you are and what you like, and to inform our business decisions, we’ll combine data captured from your visits to 360 play attractions and data from publicly-available lists as we have described in the section ‘What Sort of Personal Data do we collect?’ We’ll do this on the basis of our legitimate business interest.
For example, by combining this data, this will help us personalise your experience and decide which inspiration or content to share with you.
- To process your booking/appointment requests (for example with a birthday party booking or special event booking)
Combining your data for personalised direct marketing
We want to bring you offers and promotions that are most relevant to your interests and particular age group of children. To help us form a better, overall understanding of you as a customer, we combine your personal data gathered from membership with your visit history at any of the 360 play attractions across the UK.
How we protect your personal data
We know how much data security matters to all our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.
We secure access to all transactional areas of our websites using ‘https’ technology.
Access to your personal data is password-protected, and sensitive data such as payment card information) is secured and tokenised to ensure it is protected.
Where we have given you a password to access certain areas of the Website you are responsible for keeping this confidential and we ask that you do not share this password.
How long will we keep your personal data
Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected. When you first join 360 Play as a member we will keep you membership data for up to 5 years from the date of your last visit or transaction with us.
At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.
Some examples of customer data retention periods:
When you place an order, we’ll keep the personal data you give us for seven years so we can comply with our legal and contractual obligations
When you book a birthday party, we’ll keep the personal data you give us for seven years so we can comply with our legal and contractual obligations.
Accident or Insurance claim
If your data is taken as part of an incident or accident at one of our 360 play attractions we will keep your details for 21 years.
In the case of an Insurance claim or a claim for damages against the company we will keep relevant data for 21 years.
This section sets out the appropriate actions and procedures which DP Leisure / 360 Play follows in respect of the use of CCTV (closed circuit television) surveillance systems (“CCTV Systems”) at our premises.
Please note that all premises are monitored by CCTV 24 hours a day. DP Leisure / 360 Play reserves the right for its employees and contractors to review footage as required and by entering onto our sites you consent to your image being recorded and reviewed and waive any and all claims in relation to same. Recorded CCTV footage will be stored securely and retained in compliance with the Data Protection Act 1998. DP Leisure / 360 Play is registered as a Data Controller with the ICO.
In drawing up this policy, due account has been taken of the following:
- The Act and any other relevant Data Protection legislation;
- The CCTV Code of Practice produced by the Information Commissioner (“Code of Practice”); and
- The Human Rights Act 1998.
This policy will cover all employees and persons providing a service to DP Leisure / 360 Play, visitors and all other persons whose image(s) may be captured by our CCTV Systems.
In processing CCTV surveillance data, our staff will consider carefully the type of personal data being processed and in particular whether there is any personal data which falls within the definition of “sensitive personal data” or “special category personal data” as defined in the Act. Such data includes:
- Ethnic origin or race;
- Political opinion;
- Religious and philosophical beliefs;
- Trade Union membership;
- Health – mental or physical;
- Sexual life or sexual orientation
- Genetic data; and
- Biometric data for the purpose of uniquely identifying a natural person.
We will also ensure that the personal data is only processed in accordance with the following requirements:
- It will be processed fairly, lawfully and in a transparent manner;
- It will only be collected for specified, explicit and legitimate purposes and not further processed in any manner incompatible with those purposes;
- It will be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
- It will be accurate and, where necessary, kept up to date;
- It will not be kept for longer than is necessary for the purposes for which the personal data are processed; and
- It will be processed in a manner that ensures appropriate security of the personal data.
Initial Assessment Procedures
The purpose of the use of the CCTV Systems and the collection and processing of CCTV images is for the prevention or detection of crime or disorder, apprehension and prosecution of offenders (including use of images as evidence in criminal proceedings), interest of public and employee Health and Safety, protection of public health and the protection of the Our property and assets.
Prior to any camera installation DP Leisure / 360 Play will ensure that the installation complies with this policy and that the use of any camera is justified, necessary and proportionate. DP Leisure / 360 Play will regularly assess whether the use of any camera and the CCTV System as a whole continues to be justified, necessary and proportionate.
Location of the Cameras
The location of the equipment is carefully considered, because the way in which images are captured needs to comply with the Act.
All cameras are located in prominent positions within public and staff view and do not infringe on sensitive areas. All CCTV surveillance is automatically recorded and any breach of this location policy will be detected via controlled access to the CCTV System and auditing of the CCTV System.
Quality of the Images
The images produced by the equipment will as far as possible be of a quality that is effective for the purpose(s) for which they are intended. Upon installation, all equipment is tested to ensure that only the designated areas are monitored and suitable quality pictures are available in live and play back mode. All CCTV equipment is maintained under contract.
Processing the images
Images which are not required for the purpose(s) for which the equipment is being used will not be retained for longer than is necessary. While images are retained, it is essential that their integrity be maintained, whether it is to ensure their evidential value or to protect the rights of people whose images may have been recorded. Access to and security of the images is controlled in accordance with the requirements of the Act.
All images are digitally recorded and stored securely within the system’s hard drives. Images are stored for a minimum of 14 days, and stored for no more than 31 days.
Where the images are required for evidential purposes or disciplinary proceedings, a copy file will be moved to an access controlled confidential location on the network and held until completion of the investigation. Viewing of images within the system is controlled by a person nominated to act on behalf DP Leisure / 360 Play. Only persons trained in the use of the equipment and authorised can access data.
Access to and disclosure of images to third parties
Access to, and disclosure of, the images recorded by our CCTV System and similar surveillance equipment is restricted and carefully controlled. This ensures that the rights of individuals are preserved and the continuity of evidence remains intact should the images be required for evidential purposes e.g. a police enquiry or an investigation being undertaken as part of an internal procedure.
Access to the medium on which the images are displayed and recorded is restricted to authorised staff and third parties as authorised from time to time for specific purposes. Access to and disclosure of images is permitted only if it supports the purpose for which such images were collected.
Access to images by individuals
The Act gives any individual the right to request access to CCTV images which contain their personal data.
Individuals who request access to images must submit this formally in writing, with sufficient details to identify the section of footage with which they are concerned and to enable DP Leisure / 360 Play to satisfy itself that the person making the request is the data subject of that specific recording. Upon receipt of the request DP Leisure / 360 Play will determine whether disclosure is appropriate and whether there is a duty of care to protect the images of any third parties. If the duty of care cannot be discharged then the request can be refused.
A written response will be made to the individual, giving the decision (and if the request has been refused, giving reasons) within 21 days of receipt of the request.
The Information Commissioner’s Office has the power to bring enforcement actions against companies where it considers that there’s been a breach of one or more of the Data Protection principles.
If you have any complaints relating to this CCTV policy or our use of your personal data, please contact us: The Data Protection Officer – DPO@DpLeisure.co.uk
What are your rights over your personal data?
An overview of your different rights
You have the right to request:
- Access to the personal data we hold about you, free of charge in most cases.
- The correction of your personal data when incorrect, out of date or incomplete.
- For example, when you withdraw consent, or object and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end.
- That we stop using your personal data for direct marketing (either through specific channels, or all channels).
- That we stop any consent-based processing of your personal data after you withdraw that consent.
- Review by a team member of any decision made based solely on automatic processing of your data (i.e. where no human has yet reviewed the outcome and criteria for the decision).
You have the right to request a copy of any information about you that 360 play holds at any time, and also to have that information corrected if it is inaccurate. To ask for your information, please contact Data Administrator @ DP House, Sunrise parkway, Linford Wood, Milton Keynes MK14 6NU, or email DPO@DpLeisure.co.uk
If we choose not to action your request we will explain to you the reasons for our refusal.
Your right to withdraw consent
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
Where we rely on our legitimate interest
In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.
Checking your identity
To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.