PRIVACY POLICY

Kilturka is committed to protecting your personal data and respecting your privacy. This policy explains what we collect, why, how we use it and the rights you have under UK data protection law.

1. Data Controller

Kilturka (“we”, “us”, “our”) is the data controller responsible for your personal data in connection with our club, website, memberships, bookings and activities. Our club operates at Unit 4, Northgate Studios, Sharp Street, Manchester M4 5DA, United Kingdom.

2. Contact information

For any privacy matter, or to exercise your rights, contact us at info@kilturka.com or by post at the address above, marking your letter “Data Protection”.

3. Personal data we collect

Depending on how you interact with us, we may collect:

• Membership data: name, contact details, date of birth (to confirm age eligibility), membership type, start and renewal dates, and membership status.
• Visitor data: name and contact details for single visits and check-ins.
• Gaming station booking data: the stations, dates and times you reserve.
• Activity registration data: the sessions you sign up for, team details you provide, and attendance.
• Payment and transaction information: records of payments, amounts, dates and order references. Card details are handled by our payment provider; we do not store full card numbers.
• Customer service communications: correspondence when you contact us by email, form or in person.
• Contact form data: the name, email, enquiry type and message you submit.
• Technical and website data: IP address, device and browser information, and cookie data (see section 6).

4. Legal bases for processing

We rely on the following lawful bases under UK GDPR:

• Contract — to provide memberships, admission, bookings and activities you’ve requested.
• Legal obligation — to meet accounting, tax and other statutory duties.
• Legitimate interests — to run and secure the club, prevent misuse, respond to enquiries and improve our services, balanced against your rights.
• Consent — for non-essential cookies and for electronic marketing where required. You can withdraw consent at any time.

5. Website analytics

We may use analytics tools to understand how our website is used and to improve it. Analytics cookies and similar technologies are only set where you have given consent, in line with PECR. Analytics data is used in aggregate and not to identify you personally.

6. Cookies and similar technologies

Our website uses cookies and similar technologies. Strictly necessary cookies are essential for the site to function and do not require consent. All other categories — preference, statistics and marketing — are only set with your consent, which you give (and can change or withdraw) through our cookie banner. Our use of cookies complies with UK GDPR and the Privacy and Electronic Communications Regulations (PECR).

7. Electronic marketing communications

We will only send you marketing emails where you have consented, or where permitted for similar products and services to those you’ve obtained from us, in accordance with PECR. Every marketing message includes an easy way to unsubscribe, and you can opt out at any time by emailing info@kilturka.com.

8. Data retention

We keep personal data only for as long as necessary:

• Membership and booking records for the duration of your membership and up to six years afterwards, to meet legal and accounting requirements.
• Payment/transaction records for up to six years for tax purposes.
• Enquiry and customer service records for up to two years.
• Marketing consents until you withdraw them.

When data is no longer needed, we securely delete or anonymise it.

9. Data sharing

We do not sell your personal data. We share it only where necessary with:

• Service providers and processors who help us operate — for example, payment processing, booking software, IT hosting and email — under contracts that require them to protect your data and use it only on our instructions.
• Professional advisers such as accountants, where required.
• Authorities or regulators where we are legally obliged to disclose.

10. International data transfers

Where a service provider processes data outside the UK, we ensure appropriate safeguards are in place — such as UK adequacy regulations or the International Data Transfer Agreement (IDTA) / addendum to the EU Standard Contractual Clauses — so your data receives an equivalent level of protection.

11. Data security

We use appropriate technical and organisational measures to protect personal data against loss, misuse and unauthorised access, including access controls, secure hosting and staff confidentiality obligations.

12. Your rights

Under UK GDPR you have the right to:

• access your personal data;
• have inaccurate data corrected;
• have your data erased in certain circumstances;
• restrict or object to processing;
• data portability;
• withdraw consent at any time where processing is based on consent.

To exercise any of these, email info@kilturka.com. We will respond within one month. Exercising your rights is free unless a request is manifestly unfounded or excessive.

13. Children’s and minors’ privacy

Our club admits young people aged 13 and over, with additional conditions for under-18s. Where we collect data about a person under 18, we do so with appropriate parental or guardian consent where required and collect only what is necessary. We do not knowingly market to children.

14. Automated decision-making

We do not carry out automated decision-making that produces legal or similarly significant effects on you, and we do not profile you in that way.

15. Policy updates

We may update this policy from time to time. The current version is always available on our website, with the “last updated” date shown above. Material changes will be brought to your attention where appropriate.

16. Complaints procedure

If you have a concern about how we handle your data, please contact us first at info@kilturka.com so we can put things right. You also have the right to lodge a complaint with the UK supervisory authority:
Information Commissioner’s Office (ICO)
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Helpline: 0303 123 1113
Website: ico.org.uk
You may contact the ICO at any time, though we’d appreciate the chance to resolve your concern first.