Privacy Policy – Bath

Index

1. What personal information do we collect?
2. How do we use your personal information?
3. How do we share your personal information?
4. What rights do you have?
5. How do we store your personal information?
6. Does this Privacy Policy apply to other websites?
7. How do we transfer your personal information?
8. Do we use cookies?
9. How will we amend this Privacy Policy?
10. COVID-19 Contact Tracing Privacy Notice

Forward

This Privacy Policy sets out how Bath Racecourse [and Arena Racing Corporation Limited] ([collectively, ]“ARC”, “we” or “us”) process any personal information you provide while visiting this website (the “Website”) or the Arena Racing mobile application (the “App”).

Bath Racecourse is a company part of the Arena Racing Company Group (“Group”). Bath Racecourse and Arena Racing Corporation Limited are the controllers of your personal information in relation to this App.

1. What personal information do we collect?

We use different methods to collect personal information from and about you including:

• Communications via our Website or App: You may provide personal information to us when you register for certain services, access various content or features, or if you directly contact us via the Website or App. This includes, for example via enquiry forms, ‘contact us’ pages, brochure download forms, online registration forms and e-newsletter sign up forms. You may also provide personal information to us if you enter into competitions via the Website or App. The types of information we may collect from you includes personal details (including your name, date of birth and gender), contact information (including email address, postal address, and telephone numbers).
• Communications via our SMS Service Provider: You may provide personal information to us when you send a text message to us whilst attending an event at our Racecourses.
• Your interactions with us at our Racecourses: For example, you may give us your permission to take a photograph of you and to take your name, for use on social media or on screen at the Racecourse on the day of an event. We will also process the personal information of any vendors or third parties providing commercial services at our Racecourses, for example, providers of concession stands, food and drink outlets, or bookmakers.
• Goods or Service you request: Where you request goods or service from us, for example purchasing tickets to attend our Racecourses, we will collect your personal information in order to process your request and otherwise contact you following a purchase. The types of information we may collect from you includes personal details (including name, date of birth and gender), contact information (including email address, postal address, and telephone numbers).
• Automated technologies or interactions: When you use our Website or App, we will automatically collect technical information about your equipment, browsing actions and patterns, including information collected through cookies, web beacons and other, similar technologies. Please see our Cookies page for more details.

2. How do we use your personal information?

2.1 For operational purposes and to provide services:

• Dealing with your enquiries and requests and carrying out our obligations that arise from any contract we may enter into with you, such as processing and fulfilling an order or request and providing reservation and booking services.
• Information you enter into our booking forms may be collected and stored briefly by us so that we may contact you in relation to the nature of your enquiry/attempted transaction, even if you do not confirm the transaction. This information may be used to send operational emails to enquire as to why the transaction was not completed, these are services emails that will enquire whether there was an operational or technical problem with the checkout.
• If you submit your views to us electronically or otherwise, we may circulate them internally for training and management purposes.
• To administer our records internally.

2.2 To keep you informed:

• To provide you with marketing information about other services or products we offer that are similar to those that you have already purchased. This will be in accordance with the marketing preferences that you indicated when you completed any of our online forms.
• We will only contact you about our products and services for marketing purposes by email, phone calls or SMS message, when you have given us your consent to do so, for each appropriate method of contact. If you change your mind about what marketing you would like to receive from us or third parties (including our commercial partners) at any time, you can unsubscribe via the link in any marketing communication or alternatively email ARC Data Team. Please note, even if you unsubscribe, we may still need to send you services messages such as booking confirmations, abandonment emails and updates making you aware of changes to this Privacy Policy.
• Where you have given us your consent, to deliver effective and personalised marketing material and content from our Racecourses and only where you have consented, other companies within our Group and to assist us in the improvement and optimisation of advertising, marketing material and content, our services and websites we operate.
• We may use information that we hold about you to show you relevant advertising on third party websites, such as Facebook, Instagram and Twitter. This could involve showing you an advertising message where we know that you have purchased from us in the past or have opted in to receive marketing communications from us.

2.3 To improve our services and products:

• To conduct data analysis and insight to better understand the services and products our customers want from us. This data is used to administer the Website or App and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes. Your data is anonymised for this purpose and cannot be used to identify you as an individual.
• To measure, understand or monitor the effectiveness of advertising, promotions, marketing material and content and any joint initiatives with our affiliates, suppliers, partners, subcontractors and other selected third parties.
• To facilitate email retargeting. This means that we may send you an email where you have not followed through with an online purchase. This will happen in one of two ways:

1. If you are an existing customer of ours (with an email address and have logged into your account) and you abandon a transaction you will receive a re-targeting email from us, sent with the intent of re-capturing the sale.
2. If you opt to leave your contact details and request to be contacted after abandoning a transaction you will receive a re-targeting email from us, sent with the intent of re-capturing the sale.

2.4 Legal basis for processing:

Data protection laws require us to process your personal information on a legal basis. We process your personal information on the following legal bases:

• Consent: We will send you marketing messages through various channels (such as email, phone calls, SMS message or direct mail) about us and our events and fixtures. We will only do this when you have provided us with your consent to do so. More information on marketing communications is set out at section 2.2 above. We will only take your photo and use it for marketing or social media purposes with your explicit consent.
• Legitimate interests: We use your personal information to effectively manage our business and improve our services. We will only rely on this basis where our legitimate interests do not outweigh your privacy and data protection rights.
• Performance of a contract: When you make a transaction with us, this forms a contract between you and us. In order for us to fulfil our obligations under this contract we will need to collect and process your personal information. Failure to provide us with accurate personal or financial data or objecting to this type of processing may result in us being unable to provide goods and/or services to you.

3. How do we share your personal information?

We may disclose your personal information to the following categories of recipients:

• Any member of our Group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006. Our Group includes: Bath Racecourse, Brighton Racecourse, Chepstow Racecourse, Doncaster Racecourse, Ffos Las Racecourse, Fontwell Park Racecourse, Great Yarmouth Racecourse, Hereford Racecourse, Lingfield Park Racecourse, Newcastle Racecourse, Sedgefield Racecourse, Southwell Racecourse, Royal Windsor Racecourse, Uttoxeter Racecourse, Wolverhampton Racecourse, Worcester racecourse; Central Park, Newcastle, Nottingham, Sunderland and Perry Bar Greyhound Stadia.
• Our service providers that we engage to provide services for us. Where we provide your personal information to third party services providers, they are required to keep your personal information confidential and secure, and must only use your personal information as instructed by us. Your information is shared with the following categories of service provider to enable us to run our business:

1. Email providers (USA & UK)
2. Email re-targeting provider (UK)
3. SMS service provider (UK)
4. Mailing houses (UK)
5. IT service providers (UK)
6. CRM service providers (UK)
7. Business intelligence data insight provider (UK)
8. Booking and reservation partners (UK)
9. Marketing data quality service provider (UK)
10. Wi-Fi service provider (UK)
11. Market research service provider (UK)

• The personal information you provide to us in the course of making a transaction, along with the details of your purchase, will automatically be provided to our partners REWARDS4RACING LIMITED (“R4R”). R4R is a third-party company that provides our racing loyalty points programme. If you choose to sign up and create an R4R account, R4R will retain your personal information to administer the programme. However, if you do not sign up to our loyalty points programme, R4R will delete your personal information. For further information on how R4R handles your personal information, please visit the R4R website and read the R4R privacy policy.
• Our selected commercial partners and sponsors where you have chosen to participate in surveys, competitions or other marketing-related initiatives relating to your use of our goods and services.
• A prospective seller or buyer in the event of a sale or purchase of any Group company or asset so that the buyer can continue to provide you with information and services.

We may also disclose your personal information when obliged to do so by law, or the disclosure is necessary under applicable law, or requested to do so by governing and industry bodies, to the extent necessary for regulatory reasons.

4. What rights do you have?

Under data protection laws, you may have the following rights:

• The right to access personal information that we hold about you.
• The right to require us to update our records to ensure the data we hold is accurate.
• The right to require us to delete your personal information. There will be instances where this right is restricted (see section 2.4: legitimate interests).
• The right to restrict how we process your data (for example, if you dispute its accuracy, we may restrict its processing until your complaint is resolved).
• The right to require us to transfer your data to another organisation (only where we process your personal information under sections 2.4: consent or legitimate interests).
• The right to object to data processing. There will be instances where this right is restricted (see section 2.4: legitimate interests).
• The right not to be subject to the decision of an automated process, such as profiling, when this would produce a legal effect on you.
• The right to withdraw your consent (only in respect of personal information processed under section 2.4: consent). We will make this a simple and easy process for you through ‘unsubscribe’ links in all of our marketing communications.

To request a copy the personal information we hold about you, please email ARC Data Team. We will provide you with a copy of the data we hold on you within 28 days of receiving your request. When you submit a request, we will ask you for additional information to confirm your identity and entitlement to submit such a request. If we consider that your request is manifestly unfounded, excessive or repetitive, we reserve the right to charge you an administrative fee.

To exercise any of your rights in connection with your personal information, please email ARC Data Team. We will process any request in line with any local laws and our policies and procedures. You also have the right to lodge a complaint about how we process your personal information with the supervisory authority in your country. We aim to respond to enquiries within 3 working days.

5. How do we store your personal information?

We will only store your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

6. Does this Privacy Policy apply to other apps and/or websites?

This Privacy Policy shall only be applicable to the Website or App and/or other websites or apps that are owned and/or operated by our Group. The Website or App may contain links to other apps and/or websites that are outside our control and are not covered by this Privacy Policy. If you access other apps and/or websites using the links provided, the operators of these apps and/or websites may collect information from you that will be used by them in accordance with their privacy policy, which may differ from ours.

We would like to make you aware that we regularly promote our content over social media (Facebook, Twitter, Instagram). These apps and/or websites have their own privacy policies and terms and conditions, which are separate from our own and your exposure to marketing will be contingent on the preferences you have registered with these apps and/or websites.

7. How do we transfer your personal information?

Given that the internet is a global environment, using it to collect and process personal information necessarily involves the transmission of data on an international basis. This means for instance that it may be necessary to transfer your personal information outside the European Economic Area (“EEA”). Whenever we transfer your personal information to a country outside the EEA:

• We will transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information by the European Commission. For further details, see European Commission: Adequacy of the protection of personal information in non-EU countries.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal information the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal information to third countries.
• Where we use providers based in the US, we may transfer personal information to them if they are part of the Privacy Shield which requires them to provide similar protection to personal information shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

8. Do we use cookies?

Yes. You can view our Cookies Policy at any time using the following link: Cookies Policy.

9. How will we amend this Privacy Policy?

We may amend this Privacy Policy from time to time. If we do, we will post an updated version of the Privacy Policy on this webpage with the date it has been updated.

10. COVID-19 Contact Tracing Privacy Notice

In addition to the policy details above, which will continue to apply, the following information relates specifically to how we will use your information for tracing and contacting people who may have come into contact with persons displaying symptoms of Coronavirus connected with attendance at any of our sites.

A. What personal information do we collect?

· personal information – such as: your name, address, contact details as well as special category personal information – such as health information about virus symptoms.

B. How do we collect your personal information?

· information is collected from the ticket sales process and on-site regarding attendees who have symptoms of coronavirus and staff who may have had contact with them. These identified members of staff provide details of other people they have had contact with, who may in turn be asked for details of others they have had contact with.

C. How will your personal information be used?

· your information will be used to contact you and to contact persons who you have stated you have had contact with. This contact may be made by us or by another relevant organisation (such as public health organisations, relevant local authorities etc.).

· anonymised data may also be used in research and analysis of the Covid-19 response.

D. How do we share your personal information?

· We sometimes need to share your information within the Group or with other organisations. We will only share your information when necessary and when the law allows us to, and we will only share the minimum information we need to.

· In certain cases, we may also share your information with other individuals and organisations. For example, with public health organisations and relevant local authorities for track and trace purposes. Sometimes, we might share your information without your knowledge.

· We will never sell your information to anyone else.

E. Legal basis for using your information

· the legal basis on which we use your information is that we process the information for reasons of substantial public interest and to protect public health.

This Privacy Policy was last updated on 6th June 2023.