Privacy Policy

1. Who we are

We are Simmetrics Ltd, a company registered in England and Wales under registered number 3386764 and whose registered office it at W8a Knoll Business Centre, 325-327 Old Shoreham Road, Hove, United Kingdom, BN3 7GS, UK.

Our data protection registration number is ZA018588.

In this Privacy Policy, references to “we”, “the company”, “us”, “our” or “Simmetrics” means Simmetrics Ltd. References to “you” and “your” are to users of our websites.

We are data controllers of the Personal Information collected on the sites listed below at section 2 or when you contact us by other means. “Personal Information” is information about you which can be used alone, or combined with other information, to identify you personally.

We are data processors of Personal Information collected by our Clubhouse Subscribers (as defined below in section 3) in respect of your membership with their club or organisation. This means that we process your Personal Information on their behalf and can only do so in accordance with their written instructions. See section 3 below for further information.

2. Application of this Privacy Policy

We are committed to safeguarding the privacy of our website visitors; this Privacy Policy sets out how we will collect, use and otherwise handle Personal Information we receive from you when you visit the following websites which are owned and operated by us, or when you contact us by other means:

• http://www.simmetrics.co.uk
• http://www.myclubhouse.co.uk
• http://www.the-clubhouse.co.uk
• http://www.myclubhouse.biz
• http://www.myclubhouse.co
• http://www.myclubhouse.eu
• http://www.myclubhouse.me

Important Notes:

This Privacy Policy does not apply to myClubhouse web application sites used by clubs and other organisations, “Clubhouse Subscribers”. If you are registered on a myClubhouse web application site with a Clubhouse Subscriber, the Clubhouse Subscriber is the data controller of your Personal Information and you should review the privacy policies of these Clubhouse Subscribers.

By using our websites, you agree to the terms of this Privacy Policy.

3. Personal Information we collect

• Your name
• Your email address
• Your telephone number
• Your billing address and billing details
• Your job title/position
• What we learn about you from communications between us Information about the products/services we provide to you
• Consent – if you provide us with information based on your consent, any consents you provide to us
• Information you provide to our Clubhouse Subscribers

4. Where we collect your Personal Information from

• When you complete the Contact Us page on www.myclubhouse.co.uk when registering interest in our products and services or contacting us with queries
• When you register on www.myclubhouse.co.uk to request a free trial of our products and services
• When you email or call us for information or assistance
• In correspondence between us, including emails
• Information you provide when registering with our Atlassian JIRA Service Desk system to report bugs, issues etc. and request support in respect of any technical issues with our products and services
• When you provide your Personal Information to our Clubhouse Subscribers

5. How we use your Personal Information

Data protection law provides that we are allowed to use your Personal Information only if we have a proper reason to do so. The law provides that we must have one or more of the following reasons:

• To fulfil a contract with you or because you have asked us to take specific steps before entering into a contract; or
• We have a legal duty; or
• When it is in our legitimate interest – i.e. we have a business or commercial reason to use your Personal Information; or
• When you consent to it.

Where we collect and process Personal Information on the basis of consent, you have the right to withdraw your consent at any time (your rights). Please bear in mind that, if you withdraw your consent, this may affect our ability to carry out the tasks above for your benefit.

Where we collect and process Personal Information on the basis of legitimate interests, we cannot use it against your rights and interests and we will tell you what our legitimate basis is for processing. You have the right to object to this processing if you wish. [Add link to Your Rights section].Please bear in mind that, if you object, this may affect our ability to carry out the tasks above for your benefit.

The following sets out the lawful bases on which we rely to process your Personal Information, as well as our legitimate interests for doing so:

What we use your Personal Information for	Lawful basis for processing	Our legitimate interests
To provide our products and services to you	Fulfilling contracts Our legitimate interests Our legal duty	Keeping our records up to date Complying with laws or regulations that apply to us
To manage our relationship with you/your club or organisation, including invoicing	Your consent Fulfilling contracts Our legitimate interests Our legal duty	Keeping our records up to date Complying with laws or regulations that apply to us
To provide advice, guidance or support about our products and services	Your consent Fulfilling contracts Our legitimate interests Our legal duty	Keeping our records up to date Complying with laws or regulations that apply to us Developing products and services and what we charge for them
To notify you of new features and/or functionality in respect of our products and services	Fulfilling contracts Our legitimate interests Our legal duty	Keeping our records up to date Complying with laws or regulations that apply to us Developing products and services and what we charge for them
To notify you of new and upcoming releases of our products and services	Fulfilling contracts Our legitimate interests Our legal duty	Keeping our records up to date Complying with laws or regulations that apply to us Developing products and services and what we charge for them
To market our products and services	Your consent Our legitimate interests	Developing products and services and what we charge for them
To comply with laws and regulations which apply to us	Our legal duty
To exercise our rights under our agreements with you/your club/organisation	Fulfilling contracts

6. Cookies

You can read more about how we use cookies in our Cookies Policy, which should be read together with this Privacy Policy.

7. Information Sharing

In order to provide you with technical assistance or advice or guidance in connection with our products and services, we may share your Personal Information with organisations we use to provide our products and services to you and which may host your Personal Information on our behalf. We will only do this if they agree to keep your Personal Information safe and secure.In addition, we may disclose your Personal Information:

• to other third parties such as regulators and law enforcement agencies;
• to the extent that we are required to do so by law;
• in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud and crime prevention and detection) reducing credit risk).

Except as provided in this Privacy Policy, we will not provide your Personal Information to third parties.

8. International data transfers

We will ensure that, to the extent that any Personal Information transferred by us outside the European Economic Area (EEA) is transferred:

• only to a country our countries that the European Commission has determined ensures an adequate level of protection; or
• where we have put in place appropriate safeguards, for example by using a contract for transfer which contains specific provisions relating to data protection that have been adopted by the European Commission or competent national data protection authority; or
• where you have consented to this or there is another lawful basis on which are entitled to rely to make the transfer.

9. Retention of Personal Information

We aim to retain Personal Information only for as long as it is required for the specific purposes for which it was collected, as described in this Privacy Policy. Where we are required, for example, as a result of a legal or regulatory obligation, to store Personal Information for longer, Personal Information will be dealt with in accordance with this Privacy Policy.

10. Security

We will take reasonable technical and organisational precautions in accordance with applicable data protection laws to prevent the loss, misuse or alteration of Personal Information provided to us.

We will store all Personal Information provided to us on our secure (password- and firewall-protected) servers.

All electronic transactions entered into via the website will be protected by encryption technology.

You are responsible for keeping your password and other login details confidential. We will not ask you for your password (except when you log in to our websites).

Whilst we have security processes in place to help protect your Personal Information and to prevent unauthorised access to and use of your Personal Information, you acknowledge that Personal Information that is transmitted over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

11. Children

We do not knowingly collect, use or otherwise handle Personal Information relating to children under the age of 16 and our websites are not targeted at children under 16.

12. Updates to this Privacy Policy

We may update this Privacy Policy from time to time by posting a new version on our website. You should check this page occasionally to ensure you are happy with any changes. All changes will take effect as soon as the updated policy is published, subject to all applicable law.

We may also notify you of material changes to our Privacy Policy by email where we have already collected Personal Information about you and/or where legally required to do so, and may request that you agree to these changes.

13. Your rights and how to contact us

If you wish to contact us:

• regarding any queries or objections about our collection, use or handling of your Personal Information;
• for access to the Personal Information we collect about you;
• to correct, update or delete your Personal Information; or
• to withdraw your consent where you have given us consent to processing your Personal Information; or
• regarding any of your other rights relating to your Personal Information under applicable privacy laws

please click here to send an email or post to the following address: Simmetrics Ltd, 13 Southway, Carshalton, Surrey, SM5 4HP. To protect your privacy and security, before responding to you, we may request that you supply us with appropriate evidence of your identity. If we still require further information to be able to correctly identify you, (we may ask for a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).

We may withhold such Personal Information to the extent permitted by law.

If you are unhappy with the way we have handled your Personal Information, you can also make a complaint to the Information Commissioner's Office (ICO) who is responsible for making sure that organisations comply with the law on handling personal information. https://ico.org.uk/global/contact-us/

14. Third Party Websites

Where our sites contain links to third party websites, for example, social media channels like Twitter, you should review the privacy policy of that channel before clicking on the relevant link to learn more about what Personal Information that channel will collect, use and otherwise handle about you. We are not responsible for the privacy policies or practices of third party websites.