Privacy Policy

01. Introduction

1. We are committed to safeguarding the privacy of our website visitors and the users of our service.
2. This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and users of our service; in other words, where we determine the purposes and means of the processing of that personal data.
3. We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.
4. In this policy, “we”, “us” and “our” refers to Mellors Group Urban Playground Holdings Ltd. For more information about us, see Section 12.

02. How we use your personal data

In this Section 2 we have set out:

1. the general categories of personal data that we may process;
2. in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
3. the purposes for which we may process personal data; and the legal bases of the processing.

We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

3. We may process your license holder data (“license holder data“). The account data may include your name, email address and telephone number. The source of the account data is you or your employer. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

4. We may process your information included in your personal account on our website or through our sales software (“account data“). The account data may include your name, address, telephone number, email address, gender and date of birth. The account data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is consent.

5. We may process information that you post for publication on our website or through our services (“publication data“). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent.

6. We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.

7. We may process information relating to our customer relationships, including customer contact information (“customer relationship data“). The customer relationship data may include your name, your contact details, and information contained in communications between us and yourself. The source of the customer relationship data is you. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is consent.

8. We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“transaction data“). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.

9. We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.

● We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
● We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
● In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
● Please do not supply any other person’s personal data to us, unless we prompt you to do so.

03. Providing your personal data to others

1. We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

2. We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

3. We may disclose your personal data to our suppliers to that extent as reasonably necessary for the performance of a contract between you and us, to protect our legitimate interests, namely the proper protection of our business against risks, or in order to protect your vital interests or the vital interests of another natural person.

4. Financial transactions relating to our website and services are handled by our payment services providers, Creditcall. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices at https://www.creditcall.com/privacy-policy.

5. In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

6. In respect of any such Personal Data, we are acting as a Controller (which means we are the business responsible for making the decision to collect the Personal Data in the first place, and deciding what to collect and how to use it). We use a company called Velocity Worldwide UK Ltd (Velocity) to help us to connect with our customers and run some of our marketing services. This means that they may handle Personal Data as a Processor (they are acting on our behalf and authorised to use the Personal Data in accordance with our instructions).

04. International transfers of your personal data

In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

2. The hosting facilities for our website are situated in within the UK and Amazon Cloud Servers in the USA. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to [each of these countries] will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which you can obtain from the https://ico.org.uk.

3. Adequacy decision can be found at https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en

4. You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

05. Retaining and deleting personal data

This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

2. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

3. We will retain your personal data for as long as is reasonably necessary for the purposes listed in Section 2 of this Policy. In particular, where there has been no interaction from a consumer (e.g. a purchase, email open, newsletter sign up), a record will be archived after 1 year and deleted after 3 years.

4. We maintain a data retention policy which we apply to records in our care. Where your personal data is no longer required and we do not have a legal requirement to retain it, we will ensure it is either securely deleted or stored in a way such that it is anonymised, and the Personal Data is no longer used by the business.

5. Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

06. Amendments

1. We may update this policy from time to time by publishing a new version on our website.

2. You should check this page occasionally to ensure you are happy with any changes to this policy.

07. Your rights

In this Section 7, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

2. Your principal rights under data protection law are:

1. the right to access;
2. the right to rectification;
3. the right to erasure;
4. the right to restrict processing;
5. the right to object to processing;
6. the right to data portability;
7. the right to complain to a supervisory authority; and
8. the right to withdraw consent.

3. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

4. In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: where the personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

5. In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

6. You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

7. You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

8. You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

9. To the extent that the legal basis for our processing of your personal data is:

1. consent; or
2. that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format.

However, this right does not apply where it would adversely affect the rights and freedoms of others.

● If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
● To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
● You may exercise any of your rights in relation to your personal data by written notice to us.

08. About cookies

1. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

2. Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

3. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

09. Cookies that we use

We use cookies for the following purposes:

1. authentication – we use cookies to identify you when you visit our website and as you navigate our website (cookies used for this purpose are: gadwp_wg_default_dimension, gadwp_wg_default_metric, gadwp_wg_default_swmetric, gwcc);

2. status – we use cookies to help us to determine if you are logged into our website (cookies used for this purpose are: _ga, _gid, _gat_[UID],_gwcc, _dc_gtm_[UID]);

3. personalisation – we use cookies to store information about your preferences and to personalise the website for you (cookies used for this purpose are: _ga, _gid, _gat_[UID],_gwcc, _dc_gtm_[UID]);

4. security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally (cookies used for this purpose are: _ga, _gid, _gat_[UID],_gwcc, _dc_gtm_[UID]);

5. advertising – we use cookies to help us to display advertisements that will be relevant to you (cookies used for this purpose are: _ga, _gid, _gat_[UID],_gwcc, _dc_gtm_[UID]);

6. analysis – we use cookies to help us to analyse the use and performance of our website and services (cookies used for this purpose are: _ga, _gid, _gat_[UID],_gwcc, _dc_gtm_[UID]); and

7. cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally (cookies used for this purpose are: _ga, _gid, _gat_[UID],_gwcc, _dc_gtm_[UID]).

The types of cookies used may change or be withdrawn as we develop and update are sites.

10. Cookies used by our service providers

1. Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

2. We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/. The relevant cookies are: _ga, _gid, _gat_[UID],_gwcc, _dc_gtm_[UID]).

3. We publish Google AdSense advertisements on our website. To determine your interests, Google will track your behaviour on our website and on other websites across the web using cookies. This behaviour tracking allows Google to tailor the advertisements that you see on other websites to reflect your interests (but we do not publish interest-based advertisements on our website). You can view, delete or add interest categories associated with your browser by visiting: https://adssettings.google.com. You can also opt out of the AdSense partner network cookie using those settings or using the Network Advertising Initiative’s multi-cookie opt-out mechanism at: http://optout.networkadvertising.org. However, these opt-out mechanisms themselves use cookies, and if you clear the cookies from your browser your opt-out will not be maintained. To ensure that an opt-out is maintained in respect of a particular browser, you may wish to consider using the Google browser plug-ins available at: https://support.google.com/ads/answer/7395996. The relevant cookies are: _ga, _gid, _gat_[UID],_gwcc, _dc_gtm_[UID].

11. Managing cookies

Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

1. https://support.google.com/chrome/answer/95647?hl=en(Chrome);

2. https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences(Firefox);

3. http://www.opera.com/help/tutorials/security/cookies/(Opera);

4. https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies(Internet Explorer);

5. https://support.apple.com/kb/PH21411(Safari); and

6. https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy(Edge);

Blocking all cookies will have a negative impact upon the usability of many websites.If you block cookies, you will not be able to use all the features on our website.

12. Our details

1. This website is owned and operated by Mellors Group Urban Playground Holdings Ltd.

2. We are registered in England and Wales under registration number 09986983, and our registered office is at 16 Long Row, Nottingham, NG1 2DH.

You can contact us:
1. by post, 16 Long Row, Nottingham, NG1 2DH.
2. using our website contact form at www.urbanplayground.co.uk
3. by telephone, on 0115 9679991 or
4. by email, using hello@urbanplayground.co.uk.

13. Privacy Officer

1. Under GDPR the company does not have a statutory requirement to have a data protection officer. The Privacy Officer is responsible for ensuring that the company discharges it’s obligations under GDPR. S/he is also responsible for maintaining a log of data breaches and notifying the Information Commissioner’s Office, and any affected members, in accordance with our legal obligations.

usage data	data obtained by customers accessing and browsing our website
license holder data	data obtained as part of the contractual relationship between us and license holders
account data	data obtained through the process of registering an account
publication data	data received from external sources advertising on Urban Playground’s website
enquiry data	data obtained through enquiries made by the customer, by email, telephone or the website contact form
customer relationship data	data received through feedback forms, customer surveys or the registration of data for participation in a promotion/offer
transaction data	data obtained as a result of the sales process
notification data	data obtained through customer consent