Privacy Policy 

This Privacy Policy describes how we collect, use and disclose your personal information when you use our Service.

Any definitions used in this Policy not explicitly defined herein share the same definitions as used in our Terms and Conditions. By using our Service you agree to this Privacy Policy. If you do not agree to this Privacy Policy please do not use or access our Service.

We’re committed to providing you with relevant information about how your personal information and our Service interact, and what your data protection rights are.

We may update this Policy from time to time. The last update was November 2024 and any changes will be published here. 

What is personal data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

Your Rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are in brief set out below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

  • Your right of access
    You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for.
  • Your right to rectification
    You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete.
  • Your right to erasure
    You have the right to ask us to delete your personal information.
  • Your right to restriction of processing
    You have the right to ask us to limit how we can use your personal information.
  • Your right to object to processing
    You have the right to object to the processing of your personal data.
  • Your right to data portability
    You have the right to ask that we transfer the personal information you gave us to another organisation, or to you.
  • Your right to withdraw consent
    When we use consent as our lawful basis, you have the right to withdraw your consent at any time. You can read more about this right here.

If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request (subject access request), please email sam@moonshineadventure.co.uk.

How we use your personal information

We collect your personal information to provide our Service to you. What personal information we collect and why depends on how you interact with us. We may use data we collect about you to communicate with you, provide our Service, comply with any applicable legal obligations, enforce any applicable terms of service, and to protect or defend our Service, our rights and the rights of our users or others.

If you book an Adventure, we will also collect the personal information of anyone else you include in your booking, so you must ensure they have seen this Privacy Policy.

An illustrative summary of our practices is below:

  • Direct Marketing (eg, newsletter)
    • Personal data: name, email address
    • Why we collect this data: For us to promote our Service
    • Legal basis: Consent 
  • Marketing Materials (testimonials etc)
    • Personal data: Photographs, video recordings, Comments, records of consent, etc.
    • Why we collect this data: For us to promote our Service
    • Legal basis: Consent
  • Adventures (holiday provision)
    • Personal data: Names and Contact details; Date of birth; ID documents; Payment details; Health information (dietary requirements, allergies, health conditions, access needs)
    • Why we collect this data: In order for us to deliver you our Adventures; comply with terms and conditions of our suppliers; and cater to your needs in relation to a booking.
    • Legal basis: Contract; Legal Obligation; Vital Interests
  • Loyalty programme
    • Personal data: Name, Email Address, Payment Details
    • Why we collect this data: In order to administer the loyalty programme
    • Legal basis: Contract
  • Learning, Evaluation and Archive
    • Personal data: Recorded images; Feedback data, which may include name and/or demographic details
    • Why we collect this data: In order to improve our Service
    • Legal basis: Consent
  • Recruitment and Management
    • Personal data: Names and contact details; Addresses; Payment details; Health information; National Insurance Number; Employment History; Education History; Right to work information
    • Why we collect this data: In order to deliver our Service
    • Legal basis: Consent; Contract; Vital Interests; Legal Obligation
  • Finance
    • Personal data: Name and contact details; Addresses; Payment Details
    • Why we collect this data: Details are necessary for us to operate and support our statutory documentation requirements
    • Legal basis: Contract; Legal Obligation
  • Website
    • Personal data: IP address; website and app user journey information; location data
    • Why we collect this data: To tailor our Site to your needs (e.g. language selection); to improve our Site; to target and measure the effectiveness of marketing
    • Legal basis: Consent

Retention of personal information

We will keep your information only for as long as it is necessary to fulfil the purposes described below unless a longer retention is required by law, after which we will delete or anonymise it. The period we keep your information will vary depending on your interactions with us. For example, we may keep a record of correspondence with us, for example, if you have made a subject access request, for as long as is legally necessary. Similarly, when you unsubscribe from our email newsletters or promotional emails, we will keep a record of your email address to ensure we do not send you marketing emails in the future.

Lawful Bases

The following summarises how the lawful bases we rely on may affect your data protection rights.

  • Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
  • Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
  • Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.

Where we get personal information from

  • Directly from you
  • Cookies (where you have consented to their use)
  • Suppliers and service providers

Who we share information with

We work with a number of service providers in the course of providing services to you.

We may need to transfer your personal information to these processors in order to deliver our Service, for example:

  • With vendors or other third parties who perform services on our behalf (eg, IT management, payment processing, data analytics, advertising, caterers and freelance Game Masters).

We may also share your personal information with:

  • Warranty and guarantee providers;
  • Organisations we’re legally obliged to share personal information with;
  • Publicly on our website, social media or other marketing and information media.

Some of these third parties may be based outside of the European Economic Area (“EEA”). Organisations that are based outside of the EEA may not be subject to the same level of controls regarding data protection as exist within the UK and the EEA.

Data Security

We make use of technical and organisational security measures in order to keep your personal information secure. However, the transmission of information via the internet is not completely secure, and although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to this website, therefore any transmission is at your own risk.

How to complain

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details on our website.

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the Information Commissioners Office:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

Website: https://www.ico.org.uk/make-a-complaint

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© Copyright The Moonshine Adventure Company Ltd 2024. All rights reserved.

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