Privacy
Policy
1. Important Information and Who We Are
Club DNA LTD (trading as Club DNA), located at Wigan Hall, New Market Street, Wigan, WN1 1HH, United Kingdom (company number 13073468), serves as the data controller. The organisation is committed to protecting personal data and respecting privacy.
This policy applies to:
- The System (accessible via website)
- The App (downloaded/installed on devices)
- Services accessible through either platform
Contact Information
Email: info@club-dna.com
Post: Club DNA Ltd, Wigan Hall, New Market Street, Wigan, WN1 1HH, United Kingdom
Complaints may be filed with the Information Commissioner's Office at ico.org.uk
2. Changes to This Policy and Duty to Inform
The organisation reviews this policy regularly. Updates are posted on the website, and users may need to accept changes to continue using the system. Users must inform the company of any changes to their personal data by contacting info@club-dna.com.
3. Third Party Links
The system may contain links to third-party websites with separate privacy policies. The organisation accepts no responsibility for these external policies or data collected through them.
4. The Data Collected
Types of personal data collected:
- Identity data
- Contact data
- Financial data
- Transaction data
- Device data
- Content data
- Profile data
- Usage data
- Marketing and communications data
- Location data
The organisation does not collect Special Categories of Personal Data (race, ethnicity, religious beliefs, sexual orientation, political opinions, union membership, health information, or biometric data) nor information about criminal convictions.
5. Consent to Installation
Users must consent to app installation and personal data processing. Consent can be withdrawn at any time via info@club-dna.com.
6. How Personal Data Is Collected
Information you provide
Submitted through forms, registration, or correspondence. Enquiries sent through the contact form on our website are received and delivered to us by our form-handling provider, Formspree, which acts as a data processor on our behalf.
Automatic collection
Device, content, and usage data collected via cookies and similar technologies.
Location data
GPS or other technology determines current location with user consent. Users can disable this in device settings.
Third-party sources
Analytics providers, advertising networks, payment services, and publicly available sources like Companies House and social media.
7. How Personal Data Is Used
Processing lawfulness:
- User consent
- Contract performance
- Legitimate interests (when not overridden by user rights)
- Legal or regulatory compliance
Marketing communications require opt-in consent. Personal data remains within the UK and is not transferred outside.
8. Purposes for Data Use
| Purpose | Data Types | Legal Basis |
|---|---|---|
| App installation and user registration | Identity, contact, financial, device, location | Consent / contract |
| In-app purchases | Identity, contact, financial, device, marketing, location | Consent / contract |
| Relationship management | Identity, contact, financial, device, marketing, location | Consent / contract / legitimate interests / legal compliance |
| Responding to enquiries sent through our website contact form | Identity, contact | Legitimate interests |
| Business administration and security | Identity, contact, device | Legitimate interests |
| Content delivery and analysis | Identity, contact, device, content, profile, usage, marketing, location | Consent / legitimate interests |
9. Data Security
All information is stored on secure servers. Users are responsible for password confidentiality. Strict procedures prevent unauthorised access. The organisation handles suspected breaches according to legal requirements.
10. Data Retention
Personal data is kept no longer than necessary. Basic user information may be retained up to six years for legal compliance. Data may be anonymised for research purposes without further notice. Accounts inactive for 24 months are treated as expired, and personal data may be deleted.
11. Your Legal Rights
Users may:
- Request access to personal data
- Request correction of inaccurate data
- Request erasure where no lawful basis exists
- Object to processing based on legitimate interests
- Request processing restriction
- Request data transfer in structured format
- Withdraw consent at any time
These rights can be exercised by contacting info@club-dna.com.
12. Glossary of Terms
Consent
Agreement to processing by accessing/downloading the system or providing clear opt-in. Can be withdrawn anytime.
Legitimate interest
The organisation's business interest in providing quality service, balanced against user rights.
Performance of contract
Processing necessary to fulfil contractual obligations enabling system use.
Comply with legal obligation
Processing required by law.
Data categories defined
- Identity data: Names, username, title, date of birth, gender
- Contact data: Address, email, telephone
- Financial data: Bank and payment card details
- Transaction data: Payment details and in-app purchases
- Device data: Device type, identifier, operating system, browser type
- Content data: Photos, videos, digital content stored on device
- Profile data: Username and password
- Usage data: Details about system/app use
- Marketing and communications data: Preferences for receiving marketing
- Location data: Current location via GPS or tracking technology
13. Cookies
This section covers the Club DNA platform. For the cookies used on this website, and to change your choices, see our Cookie Policy.
Cookies are small files of letters and numbers stored on your browser or device when agreed.
Strictly necessary
Required for system operation (login functions).
Analytical / performance
Track user numbers and movement to improve functionality.
Functionality
Recognise returning users and personalise content.
Targeting
Record visits and areas visited.
The organisation does not share cookie-collected information with third parties. Users can disable analytical, functionality, and targeting cookies, though blocking all cookies may prevent system access.