Newquay Hornets Rugby Football Club ("Newquay Hornets RFC", "the Club", "we", "our" or "us") is committed to protecting the privacy and personal information of everyone involved with the Club.

This Privacy Policy explains how we collect, use, store, share and protect personal information when you visit our website, register as a member, participate in Club activities, communicate with us or otherwise engage with Newquay Hornets RFC.

We recognise the importance of protecting personal information, particularly where it relates to children and young people participating in rugby.

We are committed to handling personal information responsibly and in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and other applicable data protection legislation.

2. WHO WE ARE

Newquay Hornets RFC is a community rugby union club based in Newquay, Cornwall.

For the purposes of applicable data protection legislation, the Club is responsible for determining how and why personal information is processed in connection with its activities, where it acts as the data controller.

Club details:

Organisation: Newquay Hornets Rugby Football Club

Location: Newquay, Cornwall, United Kingdom

Website: [Insert official website address]

Email: [Insert official club email address]

For questions relating to this Privacy Policy or the handling of personal information, please contact the Club using the details above.

3. WHAT PERSONAL INFORMATION WE COLLECT

Depending on your relationship with the Club and how you interact with us, we may collect and process the following categories of personal information.

3.1 Personal Identification Information

- Full name.
- Date of birth.
- Gender, where relevant to rugby participation or administration.
- Contact details, including email addresses and telephone numbers.
- Home address.
- Emergency contact information.

3.2 Membership and Registration Information

- Membership details and membership category.
- Player registration information.
- Rugby participation and playing history.
- Team and squad information.
- RFU registration details and relevant membership identifiers.
- Membership payment records.

3.3 Parent, Carer and Guardian Information

Where children and young people participate in Club activities, we may collect information about their parents, carers or legal guardians, including:

- Names and contact details.
- Relationship to the player.
- Emergency contact information.
- Relevant permissions and consent records.

3.4 Health and Medical Information

Where necessary for the safe participation of individuals in rugby and other Club activities, we may collect limited health-related information, including:

- Relevant medical conditions.
- Allergies.
- Injury information.
- Medical requirements.
- Emergency medical information.
- Relevant fitness or participation restrictions.

This information may constitute special category personal data under UK GDPR and will receive additional protection.

3.5 Safeguarding Information

Where necessary to meet our safeguarding responsibilities, we may process information relating to safeguarding concerns, incidents, reports, referrals and relevant welfare matters.

Such information will only be accessed and shared by appropriately authorised individuals where there is a legitimate and lawful reason to do so.

3.6 Website and Technical Information

When you visit our website, we may collect technical information, including:

- IP address.
- Browser type and version.
- Device and operating system information.
- Website pages visited.
- Website usage and interaction information.
- Referral sources.
- Cookie and analytics information, where applicable.

3.7 Photographs and Video Recordings

The Club may collect and publish photographs and video recordings of players, teams, volunteers, officials and Club events.

This may include:

- Match photography.
- Training and team photographs.
- Club events and activities.
- Promotional and marketing content.
- Interviews and video content.

The Club will manage photography and video recordings in accordance with its safeguarding procedures, photography and videography arrangements and applicable data protection legislation.

4. HOW WE COLLECT PERSONAL INFORMATION

We may collect personal information through several channels, including:

- Directly from individuals when they contact the Club.
- Membership and player registration forms.
- Parent and guardian registration processes.
- Pitchero membership and website facilities.
- The Rugby Football Union's Game Management System (GMS), where applicable.
- Email correspondence and telephone conversations.
- Club events, training sessions and matches.
- Emergency contact and medical information forms.
- Website contact forms.
- Social media interactions.
- Photographs and video recordings.
- Relevant third-party organisations and governing bodies.

Where information is provided on behalf of another individual, such as a parent or guardian registering a child, the person providing the information should ensure that they are authorised to do so.

5. HOW WE USE PERSONAL INFORMATION

We use personal information where necessary to operate the Club, administer membership and support the safe and effective delivery of rugby and other Club activities.

5.1 Club Administration

- Managing membership applications and renewals.
- Maintaining accurate membership records.
- Communicating with members and families.
- Managing Club enquiries.
- Organising meetings and Club activities.
- Administering subscriptions and payments.

5.2 Rugby Administration

- Registering players with the relevant governing bodies.
- Managing teams, squads and player eligibility.
- Organising fixtures, training sessions and competitions.
- Recording match participation and results.
- Communicating with coaches, team managers and players.
- Meeting relevant RFU requirements.

5.3 Safeguarding and Welfare

- Supporting the welfare and protection of children and adults involved in the Club.
- Managing safeguarding concerns and reports.
- Maintaining relevant safeguarding records.
- Supporting emergency procedures.
- Meeting applicable RFU safeguarding requirements.

5.4 Health and Safety

- Responding to medical emergencies.
- Supporting safe participation in rugby.
- Managing relevant injury and medical information.
- Meeting health and safety responsibilities.

5.5 Communications and Marketing

- Providing Club news, announcements and updates.
- Promoting fixtures, events and activities.
- Sharing relevant membership information.
- Publishing approved photographs and videos.
- Promoting the Club and its activities through appropriate communication channels.

5.6 Website Administration

- Maintaining and improving our website.
- Monitoring website performance.
- Responding to website enquiries.
- Managing website security.
- Understanding how visitors use our website.

6. LAWFUL BASIS FOR PROCESSING PERSONAL INFORMATION

Under UK GDPR, we must have a lawful basis for processing personal information.

Depending on the circumstances, Newquay Hornets RFC may rely on the following lawful bases:

Contract

Managing membership arrangements and providing agreed Club services.

Legal obligation

Meeting applicable legal, regulatory and governing body requirements.

Legitimate interests

Administering the Club, communicating with members and promoting rugby activities, where our interests do not override individual rights.

Consent

Certain marketing activities, photography and other processing where consent is the appropriate legal basis.

Vital interests

Processing necessary to protect someone's life in an emergency.

Where we process special category information, including health or medical information, we will also identify an appropriate additional condition under Article 9 UK GDPR.

Where relevant, this may include explicit consent, employment, social protection or the establishment, exercise or defence of legal claims, depending on the specific circumstances and applicable legal requirements.

We will not rely on consent where another lawful basis is more appropriate.

7. CHILDREN AND YOUNG PEOPLE

Newquay Hornets RFC recognises its responsibility to protect the personal information and welfare of children and young people involved in the Club.

We may collect information about junior players to support registration, team management, communication, safeguarding, medical requirements and participation in rugby activities.

Where appropriate, information may be provided by a parent, carer or legal guardian.

We take particular care to ensure that children's personal information is:

- Collected only where necessary.
- Used for appropriate Club-related purposes.
- Accessed only by authorised individuals.
- Stored securely.
- Shared only where there is a lawful and appropriate reason.
- Retained only for as long as necessary.

The Club will take appropriate steps when obtaining consent or permissions relating to children, including photography and promotional activities, in accordance with applicable legislation and safeguarding guidance.

8. SHARING PERSONAL INFORMATION

We do not sell personal information to third parties.

However, we may share personal information with relevant organisations and individuals where necessary to operate the Club, fulfil our responsibilities or meet legal requirements.

8.1 Rugby Football Union (RFU)

We may share relevant information with the RFU and associated rugby organisations for purposes including:

- Player registration.
- Competition eligibility.
- Safeguarding.
- Rugby administration.
- Governing body compliance.

8.2 Pitchero

The Club uses Pitchero to support its website, membership administration, communications and other Club management activities.

Personal information may be processed through Pitchero when individuals register, manage their membership, access Club services or interact with the website.

Pitchero's own privacy arrangements and terms may also apply to its processing of personal information.

8.3 Club Officials and Volunteers

Relevant personal information may be shared with authorised committee members, coaches, team managers, safeguarding personnel and other volunteers where necessary to perform their responsibilities.

Access will be restricted according to the individual's role and requirements.

8.4 Payment Providers

Where payments are processed through third-party services, relevant information may be shared with the applicable payment provider to facilitate transactions.

8.5 Professional and Legal Organisations

We may share information with relevant professional advisers, insurers, legal representatives, regulatory bodies or public authorities where necessary and lawful.

8.6 Emergency Services

Where necessary to protect someone's health, safety or welfare, relevant information may be shared with emergency services or medical professionals.

We will only share information that is relevant and appropriate for the purpose.

9. RUGBY FOOTBALL UNION (RFU) AND GAME MANAGEMENT SYSTEM (GMS)

Newquay Hornets RFC may use the RFU's Game Management System (GMS) to support official rugby administration and player registration.

Information held within GMS may include player identification details, registration information, membership records and other information required for rugby administration.

The RFU may process personal information in accordance with its own privacy policy and data protection responsibilities.

Where information is shared between the Club and the RFU, this will be done where there is an appropriate lawful basis and a legitimate requirement.

The Club does not claim ownership of the RFU's systems or control over all processing undertaken by the RFU.

10. WEBSITE COOKIES AND ANALYTICS

Our website may use cookies and similar technologies to support functionality, improve website performance and understand visitor behaviour.

Depending on the website configuration, these may include:

- Essential cookies required for website operation.
- Analytics cookies used to understand website traffic and visitor behaviour.
- Functional cookies that support website features.
- Other technologies used by third-party services.

Where required, we will obtain appropriate consent before placing non-essential cookies or using similar technologies.

Visitors can manage their cookie preferences through the website's cookie management facilities.

Further information is available in our separate Cookie Policy.

11. EMAIL MARKETING AND CLUB COMMUNICATIONS

The Club may use personal information to send important communications relating to membership, fixtures, training, events, safeguarding and general Club administration.

Where appropriate, we may also send promotional communications about Club events, fundraising activities, merchandise, sponsorship opportunities and other initiatives.

Where electronic marketing consent is required, we will obtain it before sending relevant marketing communications.

Individuals can opt out of marketing communications at any time by using the unsubscribe facility where available or contacting the Club directly.

Opting out of marketing communications will not prevent the Club from sending essential administrative or membership-related messages.

12. DATA SECURITY

Newquay Hornets RFC takes appropriate technical and organisational measures to protect personal information against:

- Unauthorised access.
- Accidental loss.
- Destruction.
- Unauthorised disclosure.
- Unlawful processing.
- Unauthorised alteration.

Access to personal information will be limited to individuals who require it to fulfil their Club responsibilities.

The Club expects committee members, coaches, team managers and volunteers who handle personal information to do so responsibly and in accordance with relevant Club procedures.

Although we take reasonable steps to protect information, no method of electronic transmission or storage can be guaranteed to be completely secure.

13. HOW LONG WE KEEP PERSONAL INFORMATION

We only retain personal information for as long as necessary to fulfil the purposes for which it was collected, including meeting legal, regulatory, safeguarding and administrative requirements.

Retention periods may vary depending on the type of information and the circumstances.

Examples include:

Membership records: Retained for the duration of membership and an appropriate period afterwards for administration, financial records and potential legal requirements.

Financial records: Retained in accordance with applicable financial and tax record-keeping requirements.

Medical information: Retained only for as long as necessary for the relevant health, safety and administrative purposes.

Safeguarding records: Retained in accordance with applicable safeguarding guidance, legal requirements and relevant RFU procedures.

Website enquiries: Retained for as long as necessary to respond to and manage the enquiry.

Marketing information: Retained until an individual withdraws consent or otherwise requests removal, subject to any necessary suppression records.

Website analytics: Retained in accordance with the relevant platform and analytics settings.

When information is no longer required, it will be securely deleted, anonymised or otherwise disposed of appropriately.

14. YOUR DATA PROTECTION RIGHTS

Under applicable data protection legislation, individuals have a number of rights regarding their personal information.

Right of Access

You can request a copy of the personal information the Club holds about you.

Right to Rectification

You can request that inaccurate or incomplete personal information is corrected.

Right to Erasure

You can request that personal information is deleted in certain circumstances.

Right to Restrict Processing

You can request that the Club restricts the processing of your personal information in certain circumstances.

Right to Data Portability

You may request certain personal information in a structured, commonly used and machine-readable format where the right applies.

Right to Object

You may object to certain types of personal information processing, including processing based on legitimate interests and direct marketing.

Right to Withdraw Consent

Where processing is based on consent, you may withdraw that consent at any time.

Withdrawing consent does not affect the lawfulness of processing carried out before consent was withdrawn.

Some rights are subject to conditions and exemptions under data protection legislation.

15. MAKING A DATA PROTECTION REQUEST

If you wish to exercise your data protection rights or have concerns about how your personal information is being handled, please contact the Club using the contact details provided in this policy.

We may need to verify your identity before responding to a request.

We will normally respond within one month of receiving a valid request. This period may be extended where permitted by law, depending on the complexity and number of requests.

There is normally no charge for making a request, although charges may apply in limited circumstances permitted by law.

16. COMPLAINTS AND THE INFORMATION COMMISSIONER'S OFFICE (ICO)

If you are unhappy with how Newquay Hornets RFC has handled your personal information, we encourage you to contact the Club first so that we can investigate your concerns.

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK's independent data protection regulator.

Information Commissioner's Office

Website: [https://ico.org.uk/](https://ico.org.uk/)

Telephone: 0303 123 1113

You can find further information about your data protection rights and how to make a complaint through the ICO website.

17. EXTERNAL WEBSITES AND THIRD-PARTY SERVICES

Our website may contain links to external websites, including Pitchero, the RFU, social media platforms, sponsors and other organisations.

When you access an external website, its own privacy policy and data protection arrangements will apply.

Newquay Hornets RFC is not responsible for the privacy practices, content or security of external websites.

We encourage visitors to review the privacy policies of any external services they use.

18. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in legislation, Club activities, website functionality, technology or our data processing arrangements.

Any changes will be published on this page, with the updated date displayed at the beginning of the policy.

We encourage visitors and Club members to review this page periodically to remain informed about how personal information is handled.