Wentworth’s Commitment To Your Privacy
The Data Protection Act 2018
The Data Controller
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 (www.ico.org.uk). However, we always welcome the opportunity to address any concerns you may have before you notify the ICO of any concerns.
Section 1 – What Information Do We Collect And How Do We Use It?
We collect and use information about you to ensure that we can continue to provide you with a luxury club experience. You provide us with your information directly when you sign up to become a Wentworth Club Member, make a purchase, use the Wentworth Clubhouse online, or register to take part in events. The information below provides you with a breakdown of what personal information we collect about you, and how and why we process that information:
Information collected when you join as a Wentworth Club Member
When you become a Wentworth Club Member we collect certain personal information about you and your family members if you choose to have a Family Membership, including your name, address, date of birth, occupation, nationality, bank details, your email address and your telephone and/or mobile number.
The most exclusive news about events, products and services is reserved for Wentworth Club Members. Should you become a Wentworth Club Member and opt in to hear about news and exclusive offers, depending on your Membership preferences we will contact you about the many benefits reserved for Wentworth Club Members including Club events, birthday treats, complimentary Club Magazine, Club services, dining, pro shop promotions golf days and other benefit as a member of the Club. Your information will also be used in Wentworth to check your levy and to track your usage so that we can monitor customer engagement to improve our service.
From time to time, we may also collect publicly available information about you which is not essential to delivery of the exclusive Wentworth experience but which enables us to learn more about you and, in turn, provide a more tailored service. If you would like to stop Wentworth using this information about you in this way, please contact us at firstname.lastname@example.org
We will process your personal data to maintain your membership with us, to provide our member services to you, to communicate with you and to maintain our member database. The reason we process this data is to ensure we fulfil our membership contract with you, and also to ensure the proper administration of your membership (our legitimate interest).
Information Collected When You Make A Purchase
When you make a purchase at our Club Pro Shop, purchase tickets for events or pay for your membership, we will collect necessary information about you to ensure we can fulfil your order or chosen service.
If you choose to pay by card, we will need to collect your payment information in order to process card payments. We may also need to ask for additional information from you, e.g. to prevent fraudulent transactions, to comply with anti-money laundering obligations for high value transactions, or to ensure that we comply with our legal obligations such as age restrictions applicable to the sale of alcohol.
Wentworth may provide products and services that will be delivered, collected or provided at a later date; contact details and delivery information may be collected from you so that we may complete your order. We may use third party companies to deliver our services and will need to share your contact information with them for this purpose.
We will process this personal data in order to perform our contract with you and to ensure we supply the products and services you have purchased from us. The reason we process this personal data is to fulfil your contract with us, and to properly administer your transaction (our legitimate interest).
When you register an interest in Wentworth through our website, participate in social media functions on our site, and when you report a problem with our website, we may collect certain information from you. The information you give us may include your name, address, occupation, email address and phone number.
If you communicate with us, we may process the information contained in your communication. This information may include your name and contact information, the content of your communication and any metadata our website generates where you communicate with us using the contact form on our website.
We will process this data so we can deal with your enquiry, or to address your query or concern. The reason we process this data is to ensure the proper administration of your enquiry and our business (our legitimate interest).
Information supplied when you participate in Competitions, Prize Draws, Giveaways, Events and Offers
When you participate in a competition, prize draw, giveaway or offer, or sign up to attend one of our events, you will provide certain information to participate in the event or promotion. You may also provide personal information for a guest(s) for one of our events. When you do this, please ensure your guest(s) have consented to you providing us with their information. We will assume you have obtained your guest(s)’ consent when you provide us with their personal information for these purposes. Your and your guests’ information will be deleted shortly after the promotion or event has finished, unless you or they have signed up to receive marketing communications from us.
We will collect this information to ensure we can properly administer and manage the events and promotions we operate, including securing your registration at an event, and selecting and contacting prize winners (our legitimate interest). During the events, we will be taking photos at the event. These images will be used by Wentworth to share news about the event, and to publicise our future events. Images may be used in press releases, printed publicity and published on the Wentworth’s website. They will be stored securely, and we will delete them after they are no longer needed for publicity purposes. We may also share photos with members of Wentworth for their personal use. If you would prefer for you or your child not to be photographed, please speak to the specific organiser at the time or notify us in writing.
The reason we process this data is to ensure the proper administration of your membership and our business (our legitimate business interest).
Information relating to your Marketing Preferences
Wentworth will only send you marketing communications where you have consented to receive them and using your preferred channels of communication. To ensure that you are still happy to hear from us, we will contact you to ask you whether you want to opt-in of receiving marketing communications from us.
We will only continue to send you marketing communications where you expressly tell us that you want to and our legal basis for processing this data is that you have given you consent to receiving such marketing communications.
If you have opted-in to receive marketing communications from us you can manage your marketing preferences at any time. Please contact email@example.com to manage your marketing communications preferences and tell us what you want to hear about and how you want Wentworth to communicate with you.
Information relating to use of the Junior Club and Scholar Membership
As part of the Wentworth Club Membership, Wentworth operates the Junior Club and scholar Membership that offers members additional exclusive benefits, promotions and events tailored towards children under the age of 13. Where a child joins Wentworth Club, we will ask the child’s parent or guardian to complete our child record form. It is important that where we are responsible for a child who is participating in one of our junior benefits, promotions or events, without their parent or guardian being in attendance, we have certain information relating to that child, so we can fulfil our duty of care and administer emergency care and assistance if required. Therefore, we may ask you to provide us with details of any medical conditions of the child. This information will be stored securely and accessed only when necessary.
Wentworth only collects the information of children where the parent or guardian has given their consent. Wentworth does not knowingly collect information from customers under the age of 13 directly. In the event that we learn that we have collected personal information from anyone under the age of 13 without parental consent, we will delete it immediately.
We collect information relating to children, including (where necessary) medical information, only where this is strictly necessary in order to preserve the vital interests of the child. We will treat such information with the highest care and will not retain this information for longer than is necessary. If you are a parent or guardian of a child who is part of the Junior Club and/or scholar Membership, you can request that we provide you with details of the information we hold on your child by contacting our Data Protection Officer using the details provided.
Information relating to Club Analytics
While you are walking around the Wentworth and the courses, we collect footfall information to understand Members journeys better and visitor “traffic” levels across different parts of the club. Please note that, Wentworth only uses this information at a general level to understand customer footfall patterns. This information is not used for the purpose of identifying you individually.
Information required when you use The Wentworth Spa
For details about how your information is used when you visit the Spa at Wentworth, please see the section below dealing specifically with the processing of personal data by The Wentworth Spa.
Regulatory information including medical information and CCTV images
To ensure your safety and for the prevention and detection of crime, CCTV is in operation during your visit to and around Wentworth. We retain CCTV images for a reasonable period after they are collected, and will retain those images for a longer period if they are required for any legal or regulatory reasons.
Please be aware that if we are requested to provide CCTV images of you or any other personal information relating to you by the police or any other regulatory or government authority investigating suspected illegal activities, we are obliged do so.
We collect this information so we can protect your vital interests and the vital interests of and all other persons using, visiting or working at Wentworth.
Information we collect about you when you use our website
With regard to each of your visits to our website we will automatically collect the following information:
- Technical information, such as your Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform. We will obtain this data through our analytics tracking system. We process this data so we can analyse how our website is used so we can improve our website and our services;
- Information about your visit, including pages you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page. We process this data so analyse how our website is used so we can improve our website and our services.
Information We Receive About You From Other Sources.
This is information we receive about you if you use any of the other websites we operate or the other services we provide.
We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies). We may receive personal data about you from these organisations. Those organisations will have their own privacy policies detailing how they process personal data.
Section 1 – Cookies
Section 2 – When will we disclose your personal data to others?
- We may need to share your personal information with certain selected third parties including
We may share your information with our affiliated companies operating the exclusive member clubs Ten Trinity Square and the Global Elite Club. We will only share your personal data if you have consented that we can do this. Your information will be shared in accordance with the Act. If you join Ten Trinity Square and/or the Global Elite Club, your personal data will be processed in accordance with their privacy policies which are available on their websites.
Our business partners, suppliers and sub-contractors for the purpose of performing any contract we have with you or them. For example, we may use suppliers to provide services to members on our behalf to enhance our membership experience;
Analytics and search engine providers that assist us in the improvement and optimisation of our website;
Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
- We will also disclose your personal information to third parties in the following circumstances:
If we sell or buy any business or assets, in which case we may need to disclose certain personal data to the prospective seller or buyer of such business or assets.
If all or most of our assets are acquired by a third party, in which case personal data held by us about our members will be one of the transferred assets.
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce any legal agreement we have with you; or to protect our rights or property, or the safety of us, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Section 3 – Where do we store your personal data and how do we keep your Information Secure?
All data that you provide to Wentworth will be stored securely. We make sure that we have information security measures in place to keep your information secure. Where we ask third parties to work on our behalf, before sharing information we always make sure that they have sufficient information security measures in place.
We will not share your information with any third parties who might wish to market their goods and services to you unless you have provided your consent. Information you provide to Wentworth may be shared within companies forming part of the Reignwood group companies. We also work with a number of third parties to help us deliver an excellent service to you.
We will always try to ensure that your personal data is processed within the UK and the European Economic Area. In some circumstances this will not be possible. In circumstances where it is necessary for us to transfer your personal outside the UK and European Economic Area, we will only transfer such personal data to third parties where we have carried out due diligence on such third parties to ensure they will protect your personal data using similar standards and safeguards as we have. We will also have contractual provisions in place with such third parties to ensure your personal data is protected. Such contractual provisions will be based on the standard contractual clauses approved by the European Commission for the transfer of data outside the UK and the EEA or such other appropriate standards as are required from time to time by the European Commission or the UK Government. You consent to the transfer of your personal data outside of the EEA, as long as we comply with these requirements.
All information you provide to us is stored on our secure servers, including payment information. . Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
We have appropriate security measures in place to prevent personal information from being accidentally lost or from being used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Section 4 – How Long Will Wentworth Keep My Information?
(a) Wentworth is committed to keeping your personal information only for so long as is reasonably necessary to fulfil the purposes we collected it for or where we have a legitimate interest to continue doing so. We will only retain your personal information for as long as necessary to fulfil the purposes for which we collected it which will include satisfying any legal, accounting, or reporting requirements. Any personal data that we process will be deleted from our systems once we have completed the purpose for which we were processing the personal data. In some cases, the purpose for which we are processing your personal data will last for a considerable period (for example, if you are a long term member of ours, we will need to store your data until our relationship with you comes to an end).
(b) 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. We will take into consideration a number of factors such as your relationship with us, your engagement with us, and the fulfilment of contracts we have with you. Where Wentworth no longer requires information to be in a format where you can be identified personally, e.g. where we keep information for analytical and research purposes or transaction information, we will remove any personal details about you..
(c) We may need to retain your personal data where this is necessary to comply with our legal or regulatory obligations, or to protect the vital interest or the vital interests of another natural person.
Section 5 – Your Rights
Under the Act you have the following fundamental rights:
- The right to access the personal data we hold about you;
- The right to have your personal data corrected if there are errors or inaccuracies in it, or your personal data is incomplete;
- The right to restrict the processing we carry out in relation to your personal data;
- The right to object to the processing we carry out in relation to your personal data;
- The right to have the personal data we hold about you provided to you in a useable format;
- The right to complain to a supervisory authority (in the UK this is the Information Commissioner’s Office (www.ico.org.uk)) about how and/or why we are processing your personal data;
- The right to tell us you no longer consent to us processing your personal data.
Section 6 – How Can You Manage The Information We Hold About You?
As part of our commitment to exceptional customer service, where you have provided your consent, we personalise your experience, by only sending marketing communications about the most exclusive products, services and events that we believe you will be interested in. You have always been able to withdrawn your consent for these communications but now it is easier than ever to manage your preferences:
- If you have an online account, you can manage your communication preferences through our Preference Centre by logging in to your account here
- Alternatively, contact firstname.lastname@example.org. You can also unsubscribe from all email marketing communications via the “Unsubscribe” link at the bottom of each of our email marketing communications.
It can take up to two weeks for your preferences to be registered on our system, so you may still receive communications from us during this period.
Making a Data Subject Access Request
Should you wish to know more about what information we hold about you including making changes to, or requesting the deletion of, information that we hold about you, you are also entitled by law to make a Data Subject Request. You can make such a request by emailing us at email@example.com (quoting “Data Subject Request”). Please note that we may need to exclude certain information as part of your request, e.g. in order to protect the privacy of other individuals or if we are permitted to exclude the information for legal or other reasons.
We will ask you to provide appropriate evidence of your identity before we respond to your request. Typically this identification evidence will be a photocopy of your passport or photo driving licence, which a solicitor or bank has certified as being a true copy of the original and a copy of a recent utility bill detailing your current address.
Full name of legal entity: Wentworth Club Limited
Email address: Compliance@wentworthclub.com
Postal address: Wentworth Drive, Virginia Water GU25 4LS
If we specifically change the way in which we use your personal information or if we need to notify you about a change to the information that we hold about you, we will specifically contact you.
Security of our website is of utmost importance to us. Our site uses software to provide high level encryption technology. Although we use advanced security measures to protect your information against loss, misuse and alteration, as is the case with all computer networks linked to the internet, we cannot make absolute guarantees over the security of the information you provide over the internet and as such we cannot be held responsible for it.
We will never contact you by email to ask you to send or confirm any of your personal details, if we need any information of this nature we will only contact you by telephone.
We advise that you never send any sensitive information, such as passwords or credit card information, via email.
Where you have chosen to create a password to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
The Spa at Wentworth Club
The Wentworth Spa is a collaboration between Wentworth and leading experts in the fields of holistic wellbeing and aesthetic medicine. Wentworth Club and The Wentworth Spa will deliver a spa experience to our members and their guests whilst maintaining the highest standards of privacy.
In some instances we engage practitioners to supply spa services to our members. These practitioners are required to handle your personal data in compliance with the Act.
How Does The Spa Use Client Data?
The Wentworth Spa uses personal information such as your name and contact details for the following reasons:
- To contact you about your booking;
- To contact you with any pre-treatment information or aftercare information;
- To provide spa treatments and services;
- and where you have consented:
- To contact you with information about the latest spa products, events and services
- In an emergency, Wentworth will contact the person you provide as an emergency contact
How Will The Practitioners Within The Spa Use Client Data?
The Wentworth Spa will only share your personal data with those individuals who need to know your personal data in order to arrange and provide your treatment and/or spa services. Full details of how your practitioner will use your personal data can be found within your Wentworth Spa Registration Form, which you will complete at your first visit to The Wentworth Spa. Personal data obtained for medical treatments will be stored for up to 10 years (how long we retain such personal data is determined by reference to industry requirements, including the guidelines issued by the General Medical Council). Clients have the right to request from the practitioner access their personal data as well as the right to have such data corrected or deleted once is no longer necessary.
Generally, The Wentworth Spa practitioners will use your personal data for one or more of the following reasons:
- To ensure that you are in a fit state of health to receive your chosen treatment or service
- To develop a bespoke treatment for you
- To contact you about your treatment;
- and where photographs or video footage is taken:
- To demonstrate the success of a treatment or program plan
Should you choose to visit another treatment provider, your data will not be shared with any additional treatment providers unless you give explicit consent.
Photographs Or Videos Taken Within The Wentworth Spa
For some of the treatments offered within The Wentworth Spa, before and after photographs are mandatory. This is to demonstrate evidence of an effective treatment in case you later decide to contest the success of any treatment you receive.
If photographs are mandatory, your treatment provider will make this clear prior to any photographs being taken.
Unless you give your explicit consent for other uses, all photographs taken of you within The Wentworth Spa will only be used to demonstrate the effect of your treatment. Photographs and videos will not be used for any purpose other than to record the effectiveness of the treatment.
Photographs and videos will never be used for any other purposes without your express prior written consent.