The Dukes Club Privacy Statement

This Privacy Statement sets out how we, The Dukes Club, handle personal data that we process when you visit The Dukes Club website, register on the website, download resources, engage with other members in the forums or networking areas, register to attend an event, participate in a promotion or in connection with an actual or potential business or employment relationship with us.

It also describes your data protection rights, including a right to object to some of the processing which we carry out. More information about your rights, and how to exercise them, is set out in the “Data Subject Rights” section. For information about how we use cookies on this site, please see our Cookie Policy.

When we refer to Dukes Club we mean the company which runs the Dukes Club. This will initially be Dukes Education Group Ltd, but responsibility for the Dukes Club will later be transferred to another Dukes company, called DEG CLUB LTD. We will update the privacy notice and notify you once the change in controller takes place.

This Statement was last updated on 7th April 2022.

Information we collect

The types of information you may provide depends on the account type you are eligible for, but may include:

1. Contact information (such as name, email address, and phone number);

2. Dukes Nursery, School, College or Beyond the Classroom organisation you are affiliated with

3. Professional information (such as job title, industry, or subject taught and name of organisation);

4. Education information (such as level of education, higher education establishments attended, courses completed)

5. Username and password for the account you may establish on our website;

6. Name, age and class of the student(s) at a Dukes setting they attend, and or the Beyond the Classroom organisation they attended

7. Content (such as photographs and comments you provide);

8. Your marketing preferences, including any consents you have given us;

9. Information related to the browser or device you use to access our website;

10. If you purchase something from Club Rewards, information that is needed to fulfil your order, such as your debit or credit card details such as cardholder name, card number, expiration date.

11. Other information you wish to provide us about yourself, such as information about your profession and interests.

Purposes for which we process personal data, and legal basis for this use

We process this personal data for the following purposes:

As required to conduct our business and pursue our legitimate interests, in particular:

• Provide the website functionality, including member forums, the ability to search for an connect with other members, which enables messaging with other users within the website

• Manage and maintain your account with us

• Respond to your questions and comments and provide customer support

• Help diagnose problems with our server, administer the website, and compile broad statistical data

• Enforce our Terms of Use or other legal rights

Where you give us consent:

• Information or invitations to relevant Dukes Club events based on your preferences

• Information or invitations to rewards provided by Dukes organisations based on your preferences

• Information or invitations to partner rewards based on your preferences

• Tailor your experience on our website by providing content that is relevant to your interests and geographic region

Where we rely on your consent, you will always be able to control your preferences at any point via your account profile

To fulfil a contract with you:

• Where you make a purchase from Club Rewards

• For purposes which are required by law:

• In response to requests by government or law enforcement authorities conducting an investigation

• Complying with applicable laws and regulations

Withdrawing consent or otherwise objecting to direct marketing

Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your personal data for other purposes, such as those set out above. In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests. You have an absolute right to opt-out of direct marketing, at any time. You can do this by following the instructions in the communication where this is an electronic message, updating your preferences in any account or by contacting us using the details set out below.

Disclosure of your information to others

We do not sell, rent or trade your personal data to third parties. We may disclose your personal data in accordance with, and where permitted by, applicable law:

• in order for us to comply with our legal obligations, e.g. where we are required to disclose certain information to tax authorities

• to protect the security or integrity of our business, including our databases and systems

• to any of our outsourced service providers or suppliers to facilitate the provision of contracted services or goods or to provide expanded services to our customers and website visitors

• our payment processor is Stripe, in order to process the payments you make on Club Rewards. Stripe uses and processes your payment information in accordance with Stripe’s privacy policy, which you can access here.

• our e-mail service provider is SendGrid, used to send required and functional e-mail to our designated contact address. SendGrid uses and processes your e-mail address in accordance with it’s privacy policy, which you can access here

• outsource the processing of certain interactive website functions, administering email services, running special promotions and managing any rewards partners

• for the purposes of a joint venture, collaboration, financing, sale, merger, reorganisation, change of legal form, dissolution or similar event

• to any other third party where you have provided your consent

We also share aggregate information about The Dukes Club members with subsidiaries or associated offices in the Dukes Education Group. This information does not directly identify you and you will only be contacted by other members of our group if you have consented to receiving information from them.

Some events or initiatives listed on our website may be offered by another member of the Dukes Education Group. In these cases, the link from our website will direct you to their independent site, for which we are not responsible.

International transfer of personal data

When data is shared with subsidiaries or associated offices in the Dukes Education Group or third party service providers we use, your data may be transferred to countries which do not have the same level of data protection laws as those in the country where you are located. In particular, we use service providers in the US to assist with the managing and hosting of our website. We use legal mechanisms, including Standard Contractual Clauses, to help ensure that your rights and protections are guaranteed when the data is transferred. Please contact us at the contact details below if you want to receive further information regarding international data transfers.

Retention of personal data

Your personal data will be retained for the duration of our business relationship. If your account is inactive for two years, your account and all data associated to it will be deleted, unless we are required to keep it for longer by applicable local law or where we have a legitimate and lawful purpose to keep it.

Data subject rights

You have the right to ask us for a copy of your personal data; to correct, delete, or restrict (stop any active) processing of your personal data, to obtain the personal data you provide to us for a contract or with your consent in a structured, machine-readable format, and to ask us to share (port) this personal data with another controller.

In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the personal data to meet a contractual or other legal requirement, or where we are using the personal data for direct marketing).

These rights may be limited, for example, if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are included in both the GDPR and in the Data Protection Act 2018. We will inform you of relevant exemptions we rely upon when responding to any request you make.

To exercise any of these rights, or to obtain other information, such as a copy of a legitimate interests balancing test, you can get in touch with us via our Data Protection Champion using the details set out below. If you have unresolved concerns, you have the right to complain to an EU data protection authority where you live, work, or where you believe a breach may have occurred. This likely to be the Information Commissioner’s Office in the UK.

Public areas

This website may make chat rooms, networking areas, inbox messaging, forums, careers boards, message boards, and/or news groups available to its users at various times. Please remember that, unless otherwise stated, any information that is disclosed in these areas becomes public information and you should exercise caution when deciding to disclose your personal information in these areas. Do not use these areas to post personal information about third parties or discuss information about specific, identifiable patients.

Links to other websites

Our website may contain links to other websites. The Dukes Club is not responsible for the privacy practices or the content of unaffiliated third-party websites. To help ensure the protection of your privacy, we recommend that you review the privacy policy of any website you visit via a link from the website.

Contact us

If you have any questions or comments about this Privacy Policy, Dukes Club’s privacy practices, or if you would like us to update information or preferences you provided to us, please contact us at info@thedukesclub.com