Privacy Policy

Hartley Country Club Privacy Policy
In this Privacy Notice, references to “we”, “us”, “our” or “HCC” are to Hartley Country Club Limited registered in England and Wales with company number 11741R whose registered office is at Culvey Close, Hartley, Kent. DA3 8BS.

For the purposes of the General Data Protection Regulation or “GDPR” (and all other laws relating to the use your Personal Data), we are the “data controller”, meaning that we are responsible for deciding how your Personal Data is used and more importantly, for keeping your Personal Data safe and only using it for legitimate reasons.

We are committed to protecting your privacy and will take all steps necessary to comply with our legal obligations when using your Personal Data.

What Personal Data do we collect?

You may have provided us with the following types of Personal Data when you joined HCC or when using our website or whilst using your Club discount card to purchase items.

  • Identity – first name, surname, gender, date of birth
  • Contact – email address and address
  • Financial – bank details (if you pay your membership by direct debit), billing address, payment history


How do we use your Personal Data?

HCC uses the information collected from you for purposes including the following:

  • to administer your membership of HCC
  • for internal administration and record keeping
  • to answer your enquiries which may involve contacting you by post, e-mail or phone
  • to process payments that you make through our website
  • to contact you about HCC events and important news
  • to give you the opportunity to provide us with feedback through reviews and surveys
  • to process job applications
  • to notify you of changes to this Privacy Notice, our terms and conditions or other changes to our services or products

What is our legal basis for processing your Personal Data?
We use your Personal Data on the following bases:

  • To perform a contract i.e; your membership of HCC
  • To comply with legal and regulatory obligations
  • For legitimate business purposes (see “How do we use your Personal Data” section above) In certain cases, with your consent
  • We may process your Personal Data for more than one lawful basis depending on the specific purpose for which we are using it. Importantly, we will only use your Personal Data when the law allows us to.


Who do we share your Personal Data with?
HCC does not share any of your Personal Data with any third party.

What is our Personal Data retention policy?
We will keep your Personal Data for as long as you are a member of HCC. Upon cessation of your membership your Personal Data will be removed from our records after a reasonable time has elapsed.

How do we keep your Personal Data secure?
Our data-base is kept safe and secure to prevent unauthorised access or use or loss of your data. We also make sure that third parties involved in the administration of our data-base software who handle your data when helping us to deliver our services are subject to suitable confidentiality and security standards.

Despite the security measures we implement, please be aware that the transmission of data via the internet is not completely secure. As such, we cannot guarantee that information transmitted to us via the internet will be completely secure and any transmission is at your own risk.

Your rights as a data subject
At any point whilst HCC is in possession of, or processing your Personal Data, you may have the
following rights:

  • Right of access – you have the right to request a copy of the Personal Data that we hold about you.
  • Right of rectification – you have a right to correct Personal Data that we hold about you that is inaccurate or incomplete.
  • Right to be forgotten – in certain circumstances you can ask for the Personal Data we hold about you to be erased from our records.
  • Right to restriction of processing – where certain conditions apply you have a right to restrict the processing of your Personal Data.
  • Right of portability – you have the right to have the Personal Data we hold about you transferred to another organisation.
  • Right to object – you have the right to object to certain types of processing such as direct marketing, as well as processing we undertake based on our legitimate interests.
  • Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.


If you want to exercise any of these rights, please contact the HCC office
admin@hartleycountryclub.co.uk.

In addition to the above, you may get in touch with the ICO (Information Commissioner’s Office) if you are concerned about the way in which we are handling your Personal Data. However, where possible, we would really appreciate you speaking with us first if you have any concerns.

How to opt-out of HCC marketing
To unsubscribe from HCC newsletters or any other marketing emails, you simply need to click on the unsubscribe link at the bottom of the relevant communication you have received. Alternatively, please contact the HCC office admin@hartleycountryclub.co.uk.

Contact details
If you would like to discuss anything in this Privacy Notice or if you want to exercise your rights, please get in touch:

By Post:
Data Protection
Hartley Country Club Limited
Culvey Close, Hartley, Kent DA3 8BS

By email:
admin@hartleycountryclub.co.uk.


Use of Email Tracking Pixels

All emails sent by the system contain a tracking pixel. This is used to track whether each email has been opened by the recipient, and when. This information can be viewed by those users of the system with permission to view email delivery reports. We do not display any information regarding the location of the recipient. Note that the tracking pixel is only activated if the recipient chooses to download images into their email client.

Data Processor

We, Hartley Country Club, make use of the myClubhouse software supplied by Simmetrics Ltd to process personal data we include on our myClubhouse website in accordance with our privacy policy set out above. Simmetrics Ltd processes your personal data on our behalf and they can only do so in accordance with our written instructions. You can find the details of our data processor’s privacy policy here: http://www.myclubhouse.co.uk/Home/PrivacyPolicy.

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