Direct Marketing

Glasgow Life is the operating name of Culture & Sport Glasgow, a Scottish Charity (Scottish Charity Number SC037844) and having its registered address at Commonwealth House, 38 Albion Street, Glasgow G1 1LH, is the controller of personal information collected for our processing purposes. See below for our contact details and our Data Protection Officer.

You are giving us your personal information to allow us to process it for direct marketing purposes. 

Direct Marketing

When you agree to receive personalised marketing communications about our services, promotions, newsletters, press releases, and/or offers, we use your email address and any other information you give us to provide you with the information or other services, until you ask us to stop (using the 'unsubscribe' instructions provided with each email communication or on our online marketing preference portal, or by telephone, email, or post), or until the information or service is no longer available.

Competitions, Promotions and Offers

From time-to-time we may provide you the opportunity to participate in various promotions, offers or competitions including joint promotions and prize draws with our selected partners. If you participate, we will request certain personal information from you. Participation in these promotions, offers or competitions is completely voluntary and you have a choice about disclosing this information. The requested information typically includes contact information (such as name, address, telephone and or membership number). We use this information to:

• inform the prize winners of the promotion, competition or offer
• verify eligibility
• update our member contact records accordingly

where you have provided consent, share your contact details with our competition/promotion partners for direct marketing purposes.

We also use your information to verify your identity where required, contact you by post, email or telephone and to maintain our records.

The information we have received from you consists of the following:

• name and email address
• postcode
• marketing preferences and any other specific fields requested on the competition form.  

We rely on the following legal bases for processing your personal information:

• On the basis of your consent - you can withdraw consent at any time

If you are under 13 years of age your parent or guardian will need to give us permission to provide you with these services.

We are legally obliged to safeguard public funds so details will be checked internally for fraud prevention and verification purposes and may be shared with other public bodies for the same purpose. We are legally obliged to share certain data with other public bodies such as HMRC and will do so where the law requires this; we will also generally comply with requests for specific information from other regulatory and law enforcement bodies where this is necessary and proportionate. Information is also analysed internally in order to provide management information, inform service delivery reform and similar purposes. This is in accordance with our Information Use and Privacy Policy and the Privacy Statement set out in full on our website.

Additionally, where you have consented during entry to joint competitions, promotions or prize draws, we may share your personal information with our selected partners for their direct marketing purposes.  Similarly, our partners may share personal information about their competition entrants with us where consent has been obtained. Any such sharing will only occur where you have provided clear consents for this purpose.

In all cases, we ensure that:

• clear consent is obtained before any sharing occurs
• you are informed about which partner(s) your information may be shared with
• you can withdraw your consent for future marketing from either party at any time
• partners are bound by appropriate data sharing agreements to protect your information.

In order to provide services to you, we may need to appoint other organisations to carry out some activities on our behalf. These may include, for example, payment processing organisations, delivery organisations, mailing houses and contractors or consultants providing services to Glasgow Life (or directly to service users) where we need to provide them with personal information to allow them to provide these services on our behalf. We select these organisations carefully and put measures in place to make sure that they only follow our instructions when processing your personal information.

Specifically, for our direct marketing and customer contact, Glasgow Life uses a customer relationship management system powered by Adestra, their registered office based in Ireland.

We will not sell or rent your information to any third-party organisations. 

Almost all Glasgow Life data is held within the UK and Ireland.  Any overseas data transfers require additional internal approvals and we only send data overseas where we have been able to put in place measures to make sure that your personal information is as safe and respected in the overseas country, or countries in question, as it is in the UK. We will always respect your privacy and security if we transfer your data abroad.

We only keep your personal information for the minimum period amount of time necessary. Sometimes this time period is set out in the law, but in most cases it is based on the business need. Glasgow Life maintains a records retention and disposal schedule which sets out how long we hold different types of information for. This is available on our website at www.glasgowlife.org.uk/rrs.

Access to your information – you have the right to request a copy of the personal information that we hold about you.

Correcting your information – we want to make sure that your personal information is accurate, complete and up to date. Therefore you may ask us to correct any personal information about you that you believe does not meet these standards.

Deletion of your information – you have the right to ask us to delete personal information about you where:

• you think that we no longer need to hold the information for the purposes for which it was originally obtained
• we are using that information with your consent and you have withdrawn your consent – see Withdrawing consent to using your information 
• you have a genuine objection to our use of your personal information – see Objecting to how we may use your information below
• our use of your personal information is contrary to law or our other legal obligations.

Objecting to how we may use your information – you have the right at any time to tell us to stop using your personal information for direct marketing purposes.

Restricting how we may use your information – in some cases, you may ask us to restrict how we use your personal information. This right might apply, for example, where we are checking the accuracy of personal information that we hold about you or we are assessing the objection you have made to our use of your information. This right might also apply if we no longer have a basis for using your personal information, but you don't want us to delete the data. Where this right is realistically applied will mean that we may only use the relevant personal information with your consent, for legal claims or where there are other public interest grounds to do so.

Withdrawing consent to using your information – where we use your personal information with your consent you may withdraw that consent at any time and Glasgow Life will stop using your personal information for the purpose(s) for which consent was given.

Please contact us if you wish to exercise any of these rights.

Email marketing campaigns published by Glasgow Life contain tracking facilities. Subscriber activity is tracked and stored in our Customer Relationship Management system which manages our email newsletter campaigns for future analysis and evaluation. Such tracked activity may include; the opening of emails, the clicking of links within the email content, times, dates and frequency of activity. This information is used to refine future email campaigns and supply the user with more relevant content based around their activity (automated processing, including profiling for personalisation). In compliance with the Privacy and Electronic Communications Regulations 2003 (as amended) subscribers are given the opportunity to un-subscribe at any time through an automated system. This process is detailed at the footer of each email campaign.

For general enquiries, queries or exercising your data protection rights, you can contact Glasgow Life by:

• Post: 38 Albion Street, Glasgow, G1 1LH
• Telephone: 0141 287 4350
• Email: info@glasgowlife.org.uk

We aim to resolve all complaints about the way Glasgow Life processes your personal information. You can contact our data protection officer about any data protection matter but you also have the right to complain to the Information Commissioner’s Office (ICO). Contact details for our data protection officer and the ICO are available on our website at www.glasgowlife.org.uk/privacy/data-protection-concerns.

Please note if your complaint is not about a data protection matter or concerns the handling of your personal information, please contact us using the complaints procedures in place at www.glasgowlife.org.uk/commentsandcomplaints.

• To learn more about how we handle your personal information, please visit: www.glasgowlife.org.uk/privacy
• If you need help in another format, such as large print, braille or audio, please ask a staff member, contact us or visit: www.glasgowlife.org.uk/accessibility

Glasgow Life (and its sub-brands) are operating names of Culture and Sport Glasgow (“CSG”) a Scottish charity (No SCO37844) incorporated under the Companies Acts and limited by guarantee, registered in Scotland with Company No SC313851. Culture and Sport Glasgow (Trading) CIC (“CSG CIC”) is a trading subsidiary of CSG, a community interest company, registered in Scotland with Company No SC313850. CSG and CSG CIC (registered office at 38 Albion Street, Glasgow, G1 1LH) are collectively referred to by CSG’s operating name “Glasgow Life” for the purposes of our Privacy Statement and privacy notices (available at www.glasgowlife.org.uk/privacy). Glasgow Life delivers cultural, sporting and learning activities on behalf of Glasgow City Council, inspiring Glasgow’s citizens and visitors to lead richer and more active lives.