Last updated: 11 September 2026

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1. Who we are

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Coldingham Bay Bayers CIC, trading as Brave Bayers and Wild & Freezing, is a Community Interest Company registered in Scotland.

 

Company number: SC785366
Website: www.wildandfreezing.co.uk
Email: coldinghambravebayers@gmail.com

 

For the purposes of UK data-protection law, Coldingham Bay Bayers CIC is the controller of the personal information described in this policy.

 

This policy explains what information we collect, why we use it, who we may share it with, how long we retain it and the rights available to you.

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2. When this policy applies

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This policy applies when you:

• visit our website;

• contact us;

• create an account;

• make or manage a booking;

• attend one of our sessions, classes, courses or community programmes;

• complete a registration, evaluation or feedback form;

• subscribe to communications;

• apply for support;

• interact with us through social media; or

• otherwise provide personal information to us.

3. Information we collect

Depending on how you interact with us, we may collect the following information.

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Contact information

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This may include your:

• name;

• email address;

• telephone number;

• address or partial postcode; and

• emergency contact details, where genuinely required.

 

Booking and participation information

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This may include:

• the service, event, class or programme booked;

• booking dates and attendance records;

• cancellations, rescheduling and waiting-list information;

• lane, session or activity choices;

• eligibility information, such as age confirmation or postcode area;

• payment status and transaction references;

• relevant correspondence; and

• reasonable access or participation support requested by you.

 

Payment information

 

Payments may be processed through Wix or another payment provider. We generally receive transaction and payment-status information rather than complete payment-card details.

Payment providers process payment information under their own privacy terms and security arrangements.

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Forms, questionnaires and evaluation information

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When you complete a registration, feedback or evaluation form, we may collect:

• age range;

• partial postcode;

• how you heard about a programme;

• activity levels;

• confidence and community-connection ratings;

• wellbeing information;

• programme expectations;

• barriers to participation;

• access or support requests; and

• written comments or feedback.

Where possible, questions about wellbeing and personal circumstances are optional.

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Health and other sensitive information

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Information about a person’s physical or mental health may be special-category personal data under UK data-protection law.

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We only request this information where it is relevant to:

• providing appropriate participation or access support;

• administering an activity safely;

• responding to an incident; or

• evaluating a wellbeing programme.

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Please do not send detailed medical records or diagnoses unless we specifically explain why the information is necessary and how it will be handled.

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Communications

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We may keep records of emails, form submissions, messages, enquiries, complaints and other correspondence.

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Website and device information

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When you use our website, Wix and enabled website services may collect information such as:

• IP address;

• browser and device type;

• operating system;

• approximate location;

• pages viewed;

• referring website;

• dates and times of visits;

• interactions with the website; and

• cookie or similar technology identifiers.

More information is provided in the Cookies section below.

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4. How we collect information

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We may collect personal information:

• directly from you;

• through Wix Bookings, Wix Forms or other Wix features;

• when someone makes an authorised booking on your behalf;

• through programme partners or referral organisations, where they are permitted to provide it;

• when you communicate with us;

• when attendance is recorded; and

• automatically through cookies and similar website technologies.

If someone provides information about another person, they should have that person’s permission to do so.

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5. Why we use your information and our lawful bases

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We only use personal information when we have a lawful basis under UK data-protection law.

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Providing bookings, services and programmes

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We use information to:

• create and administer bookings;

• check programme eligibility;

• manage capacity, attendance, cancellations and waiting lists;

• communicate essential session information;

• provide requested services;

• arrange reasonable participation support; and

• keep appropriate service records.

We rely on performance of a contract where applicable and on our legitimate interests in operating and administering our services.

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Programme monitoring and evaluation

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We may use registration, attendance, questionnaire and feedback information to:

• understand who our programmes reach;

• understand participants’ starting points;

• measure changes and outcomes;

• improve future services;

• fulfil reasonable monitoring requirements; and

• prepare reports for programme partners and funders.

We rely on our legitimate interests in evaluating and improving our community programmes. Where identifiable evaluation answers reveal health or wellbeing information, we will normally rely on your explicit consent as the relevant special-category condition.

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Choosing not to answer optional evaluation questions will not affect your right to participate.

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Health, access and support information

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Where you voluntarily provide health or wellbeing information so that we can offer support or evaluate a programme, we will normally rely on your explicit consent.

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In a genuine emergency, we may use necessary information to protect your or another person’s vital interests where the legal requirements are met.

 

Financial and legal administration

 

We may use information to:

• maintain financial and accounting records;

• prevent or investigate fraud;

• respond to legal claims;

• meet insurance requirements; and

• comply with legal, regulatory or safeguarding obligations.

We rely on legal obligations, legitimate interests and, where applicable, the establishment, exercise or defence of legal claims.

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Responding to enquiries

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We use contact and correspondence information to answer questions, manage complaints and provide requested information.

We rely on our legitimate interests in communicating with people who contact us and taking steps at your request.

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Marketing and updates

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We may send newsletters, programme announcements or promotional communications where you have consented or where another lawful method of communication is available.

You can unsubscribe at any time by using the link in an email or contacting us.

Service messages about an existing booking are not marketing and may still be sent when necessary.

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Website operation, security and improvement

We use necessary technical information to operate, secure and troubleshoot our website.

Where analytics or non-essential cookies are used, they will only be activated in accordance with the choices available through our cookie-consent system.

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6. Explicit consent for wellbeing information

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Where we rely on explicit consent to use health or wellbeing information:

• the request for consent will be clear and separate;

• we will explain what information is involved and why it is needed;

• providing the information will be optional unless it is objectively necessary for a service you have requested;

• we will keep a record of the consent; and

• you may withdraw it at any time.

Withdrawing consent does not affect processing that lawfully took place before withdrawal.

To withdraw consent, email coldinghambravebayers@gmail.com.

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7. Automated decision-making

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We do not currently make solely automated decisions using personal information that produce legal or similarly significant effects.

Automated systems may perform administrative functions such as checking booking capacity, validating form entries or sending confirmation messages. Staff can review issues where appropriate.

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8. Who we share information with

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We may share personal information only where necessary with:

• authorised staff, directors, instructors, coaches and volunteers;

• Wix, which provides our website, forms, bookings, contact-management and related services;

• payment processors;

• email and communications providers;

• professional advisers, insurers and accountants;

• IT, security and administrative service providers;

• delivery partners where this is necessary to provide a programme;

• regulators, emergency services, courts or public authorities where legally required; and

• another organisation involved in a business transfer or restructuring, subject to appropriate safeguards.

 

Access is limited to information relevant to the recipient’s role.

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Programme partners and funders, including Live Borders and The National Lottery Community Fund, may receive combined or anonymised monitoring and evaluation information. We do not routinely provide them with identifiable questionnaire responses unless we have told you, have an appropriate lawful basis and the disclosure is necessary.

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Where a partner collects information independently for its own purposes, that organisation may act as a separate controller and its own privacy policy will apply.

We do not sell personal information.

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9. Wix and other service providers

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Our website is hosted on the Wix.com platform. Wix provides services including website hosting, databases, forms, bookings, contact management, communications and, where enabled, payment facilities.

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Information submitted through our website or a Wix standalone form may be stored and processed using Wix systems.

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Further information about Wix’s handling of personal information is available in the Wix Privacy Policy at: https://www.wix.com/about/privacy

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10. International transfers

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Some service providers may process personal information outside the United Kingdom.

Where a restricted international transfer takes place, we will take reasonable steps to ensure that an appropriate legal transfer mechanism or safeguard applies. This may include:

• UK adequacy regulations;

• the UK International Data Transfer Agreement;

• the UK Addendum to approved contractual clauses; or

• another safeguard recognised under UK data-protection law.

 

You may contact us for further information about safeguards relevant to your information.

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11. How long we retain information

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We keep identifiable personal information only for as long as reasonably necessary for the purpose for which it was collected.

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Our normal retention approach is:

• Booking and participation records: up to six years after the relevant service or programme ends where required for financial, contractual, insurance or legal purposes.

• Financial and transaction records: normally six years after the end of the relevant accounting period.

• Programme questionnaires and identifiable evaluation responses: until programme evaluation and associated funding reporting are complete, and normally no longer than 24 months after the final report.

• Anonymised evaluation information: may be retained for longer because it no longer identifies an individual.

• Routine enquiries and correspondence: normally up to two years after the last meaningful contact.

• Marketing records: until consent is withdrawn, an objection is made or the information is no longer required. Mailing lists will be reviewed periodically.

• Accident, incident, safeguarding or insurance records: for the period reasonably required by applicable legal, insurance and safeguarding obligations.

• Cookie and analytics information: according to the duration disclosed through our cookie settings and the relevant provider’s retention controls.

We may retain information for longer where necessary to establish, exercise or defend a legal claim, comply with a legal requirement or respond to an unresolved complaint.

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When identifiable information is no longer required, we will delete or anonymise it.

 

12. Security

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We take reasonable organisational and technical measures to protect personal information against accidental loss, unauthorised access, alteration, disclosure or destruction.

Measures may include:

• limiting access according to role;

• using password-protected systems;

• controlling Wix collaborator permissions;

• using secure service providers;

• reviewing access when roles change; and

• avoiding unnecessary collection of sensitive information.

 

No online service can guarantee absolute security. If we become aware of a personal-data breach, we will assess it and make any notifications required by law.

 

13. Cookies and similar technologies

 

Our website uses cookies and similar technologies.

Some cookies are strictly necessary for the website, security, bookings and other requested functions. Other cookies may support analytics, preferences, embedded content or marketing.

Non-essential cookies will not be placed before consent where consent is legally required. You can accept, reject or manage these cookies using our cookie controls.

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Withdrawing cookie consent will not affect cookies that are strictly necessary for the website to work.

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Further information about the cookies currently used, their providers, purposes and duration should be displayed through our cookie settings or separate Cookie Policy.

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14. Marketing communications

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We will only send electronic marketing where permitted by the Privacy and Electronic Communications Regulations and UK data-protection law.

 

Marketing consent is separate from:

• booking a service;

• participating in a programme;

• receiving essential service information; and

• completing an evaluation questionnaire.

 

You can unsubscribe from marketing at any time. We may retain limited suppression information to ensure that we respect your preference.

 

15. Photographs, video and testimonials

 

We will explain how photographs, video recordings or testimonials are intended to be used before collecting them.

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Where consent is the appropriate basis, participation in photography or publicity will be optional and recorded separately from general programme registration.

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We will not assume that attendance at an activity means consent to identifiable promotional use.

 

16. Children’s information

Our services are primarily intended for adults unless a particular activity expressly states otherwise.

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Where a service is available to children or young people, we will use age-appropriate information and obtain parent or guardian involvement where required. We do not knowingly collect children’s personal information through adult-only services.

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17. Your data-protection rights

Depending on the circumstances, you may have the right to:

• be informed about how your information is used;

• request access to your personal information;

• ask us to correct inaccurate or incomplete information;

• ask us to delete information;

• ask us to restrict the use of information;

• object to processing based on legitimate interests;

• receive certain information in a portable format;

• withdraw consent at any time; and

• object to direct marketing.

 

These rights are not absolute and may depend on the lawful basis and circumstances of the processing.

 

To exercise a right, contact coldinghambravebayers@gmail.com. We may need to verify your identity before responding.

 

We normally respond within one month. We will explain if we require additional time or cannot fulfil a request.

 

18. Complaints

 

Please contact us first if you have concerns about how we use your information:

Email: coldinghambravebayers@gmail.com

 

You also have the right to complain to the UK Information Commissioner’s Office:

Website: https://ico.org.uk/make-a-complaint/
Telephone: 0303 123 1113
Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

 

19. Links and third-party services

Our website may contain links to external websites, social-media services, booking partners or other organisations.

 

We are not responsible for how an independent third party handles information through its own services. Please review its privacy information before providing personal details.

 

20. Changes to this policy

We may update this policy when our services, systems or legal obligations change.

The latest version will be published on this page with its updated date. If a change materially affects how we use information already collected, we will take reasonable steps to bring the change to the attention of affected individuals before the new use begins.

 

21. Contact us

For questions about this policy, our use of personal information or your data-protection rights, contact:

Coldingham Bay Bayers CIC
Company number: SC785366
Email: coldinghambravebayers@gmail.com
Website: www.wildandfreezing.co.uk