Updated August 2025

We understand that you are trusting us with your private information and this statement explains how we might hold and use it.

1. Introduction

1.1 We are committed to safeguarding the privacy of Shine customers.

1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and customers; in other words, where we determine the purposes and means of the processing of that personal data.

1.3 We use first-party cookies on our website, for the provision of our website and services.

1.4 Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications. You can access the privacy controls via the My Account section.

1.5 In this policy, "we", "us", "our" and “Shine” refer to Shine Wraparound Care Limited and/or Shine Sports Facilities Limited.

1.6 This policy also addresses our handling of special category data and criminal offence data in accordance with applicable data protection laws.

2. Data Protection Officer

2.1 Any questions, reports or concerns in relation to data protection or GDPR should be shared with our Data Protection Officer:

by email, DPO@myshine.co.uk
by writing, Shine Sports Ground, Lime Trees Road, Bristol, BS6 7XW

3. How we use your personal data

3.1 In this section we have set out:

the general categories of personal data that we may process, including special category data and criminal offence data (employees, contractors only);
the purposes for which we may process personal data; and
the legal bases of the processing, as required by the UK GDPR.

3.2 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 Google Analytics. 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.

3.3 We may process your user data ("user data"). The user data may include your name, address, telephone numbers, email address and marketing preferences. The source of the user data is from you creating or updating your account with us. The user 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 proper administration of our website and businesses.

3.4 We may process information included in the attendee profiles on our website ("attendee data"). The attendee data may include the name, date of birth, school, medical information and additional parent/carers of attendees you register with us. The attendee 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 our legitimate interests, namely the proper administration of our website and businesses.

3.5 We may process your personal data that are provided in the course of the use of our services ("order data"). The order data may include orders you have placed with us for our goods and services. The source of the service data is you. The order 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 proper administration of our website and businesses.

3.6 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 businesses.

3.7 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 from you.

3.8 In addition to the specific purposes for which we may process your personal data set out in this Section 3, 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.

3.9 Please do not supply any other person's personal data to us, unless we prompt you to do so.

3.10 The legal basis for processing special category data will typically include explicit consent, the establishment, exercise, or defence of legal claims, or where it is necessary for reasons of substantial public interest, such as safeguarding children.

3.11 The legal bases for processing criminal offence data will generally involve explicit consent, the necessity of carrying out obligations and exercising rights in the field of employment and social security law or the necessity for reasons of substantial public interest.

4. Special Categories of Personal Data

4.1 Special category data that we may process includes details about health, race, ethnic origin, and genetic data. The legal basis for processing this data will often be explicit consent, protecting vital interests where the data subject is incapable of giving consent, or the necessity for carrying out the obligations and exercising specific rights of the data controller or the data subject in the field of employment and social security and social protection law.

4.2 We may process special category data for safeguarding purposes, which is necessary to protect the vital interests of the data subject or another individual where the data subject is physically or legally incapable of giving consent.

5. Criminal Offence Data

5.1 We may process criminal offence data where it is necessary for compliance with a legal obligation, where it is necessary for the performance of a task carried out in the public interest, or where we have explicit consent from you. This data will be handled with the utmost care and in accordance with the safeguards required by law.

6. Providing your personal data to others

6.1 We will not disclose your personal data to any third parties except in the following circumstances:

To schools or other agencies directly linked to the safeguarding or organisational requirements of the event or activity run by Shine. For example, we may share the ‘Attendee List’ for a given session with the host school to ensure appropriate supervision and site management.
To third-party organisations that deliver activities booked through Shine, where necessary for the delivery of the service.

6.2 Where you have provided consent to receive marketing communications, we may share your contact details (such as your name and email address) with the third-party organisation delivering the activity you booked. This allows them to contact you directly about their own services and future offerings.

Please note that these organisations act as independent data controllers and are responsible for their own privacy practices. You will have the opportunity to opt out of their communications at any time.

6.3 Financial transactions relating to our website and services are handled by our payment services provider, Stripe. We will share transaction data with Stripe only to the extent necessary for processing your payments, issuing refunds, and handling related queries. You can find Stripe’s privacy policy at https://stripe.com/gb/privacy.

6.4 We may also share your data with companies we contract with to support our services, including but not limited to Digital Ocean and Postmark, for purposes such as hosting and email delivery.

7. Retaining and deleting personal data

7.1 This section 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.

7.2 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.

7.3 We will retain your data as follows:

user data for up to three years since you last placed an order with us
attendee data for up to three years since last attendee a Shine activity
order data and transaction data for up to seven years since the order was placed
accident recording To maintain the highest standards we will retain accident records for children attending our sessions up to the age of 21.
child protection To maintain the highest standards we will retain child protection records indefinitely
notification data until you opt out of receiving such notifications or we deem it no longer appropriate to send these to you

7.4 Notwithstanding the other provisions of this Section 6, 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.

8. Amendments

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

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

8.3 We may notify you of changes to this policy by email.

9. Your rights

9.1 In this section 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.

9.2 Your principal rights under data protection law are:

the right to access;
the right to rectification;
the right to erasure;
the right to restrict processing;
the right to object to processing;
the right to data portability;
the right to complain to a supervisory authority; and
the right to withdraw consent.

9.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access your account data by visiting https://www.myshine.co.uk/account when logged into our website.

9.4 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.

9.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were 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 compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

9.6 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, in the interests of safeguarding and/or child protection, 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.

9.7 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, safeguarding and/or child protection or the processing is for the establishment, exercise or defence of legal claims.

9.8 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.

9.9 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.

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

consent; or
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.

9.11 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.

9.12 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.

9.13 You may exercise any of your rights in relation to your personal data by contacting us at section 10.4.

9.14 You have the right to be informed about processing of your special category data and criminal offence data, including the legal basis for the processing and any additional safeguards in place.

10. About cookies

10.1 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.

10.2 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.

10.3 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.

11. Cookies that we use

11.1 We use cookies for the following purposes:

authentication - we use a cookie to identify you when you visit our website and as you navigate our website. The cookie used for this purpose is "shinesesh".
status - we use a cookie to help us to determine if you are logged into our website. The cookie used for this purpose is "shinesesh".
security - we use a 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. The cookie used for this purpose is "shinesesh".

12. Our details

12.1 This website is owned and operated by Shine Wraparound Care Limited.

12.2 We are registered in England and Wales under registration number 09588978, and our registered office is at Shine Sports Ground, Lime Trees Road, Bristol, BS6 7XW.

12.3 Our principal place of business is at Shine Sports Ground, Lime Trees Road, Bristol, BS6 7XW.

12.4 You can contact us:

using the form on our contact page;
by telephone, on the contact number published on our contact page;
by email, using the email address published on our contact page.

13. How to make a complaint

13.1 To exercise all relevant rights, queries or complaints please in the first instance contact our Data Protection Officer (Alex Withers) using the following contact details:

by email, DPO@myshine.co.uk
by writing to us, Shine Sports Ground, Lime Trees Road, Bristol, BS6 7XW

13.2 If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office:

by phone, 0303 123 1113
by email, casework@ico.org.uk
or writing to them Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.

14. Credit

14.1 This document was created using a template from SEQ Legal ( https://seqlegal.com).

CALLICROFT PRIMARY ACADEMY

Shine Clubs April - July 26