1. Who we are

Our website address is: www.club.silversurfers.com

Silverhairs Limited, the company which owns the website www.silversurfers.com (Site) and www.club.silversufers.com (Site), is totally committed to protect any personal data you provide to us and to process your personal data in accordance with this Privacy Policy and applicable laws.
This policy (together with our Terms and Conditions and any other documents referred to on it) sets out how we use and protect information that you give to us when you use the Site and also when giving us your data and information for emails.

For the purpose of The General Data Protection Regulation (Regulation EU 2016/679) (“GDPR”), the data controller is Silverhairs Limited.10 Queen Street Place, London, United Kingdom, EC4R 1AG
Email: [email protected]

2. We Promise:

• To keep your data safe and private
• Not to sell your data
• To make it easy for you to manage your data at any time

3. What do we do with the information that we collect about you and why may we do this?

We may process your personal information for certain legitimate business and community purposes, which include some, or all of the reasons stated in this section:

Sometimes, we need your information to be able to contact you to provide the service you wish to use, such as a Silversurfers Club+ subscription. In those cases, by signing up to the service you are agreeing that we will have to send you service communications to run the service itself, and we will not offer you the chance to opt-out from receiving those messages until you decide you no longer wish to use the services.

As well as the communications we send you, we also offer you the opportunity to choose whether to hear from specific companies and organisations that we work in association with, including (but not limited to) the service providers we work with. If you  wish to hear from them you will have to opt in via a tick box (or because you choose to engage with them directly).

As a member by subscribing to Silversurfers Club+ you are able to:
Participate in our Forums and Chat Rooms, Participate in Live Events and Discussions, Participate in Polls, Upload photos, poems and short stories and be updated with articles that you have identified as being of interest

3.1 We may use your information if you have registered with the Site and its blogs, forums, and if you request access to our Facebook, Pinterest, Instagram and Twitter accounts.
If you have registered your email address and requested to receive our emails we will use this to send you our email newsletters which contain information, competitions, adverts, discounts and links to other websites.
3.2 If you enter your details in a competition or a promotion we may ask for details of your address or phone number or email so that we can contact you and send you details of the competition or promotion or if we need to notify any winners. We will only share this data with the prize draw partner if you consent to this by ticking the relevant box.
3.3 We also use information held about you in the following ways:
(a) to ensure that content from our site is presented in the most effective manner for you and for your computer;
(b) to provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes;
(c) to carry out our obligations arising from any contracts entered into between you and us;
(d) to allow you to participate in interactive features such as forums, chat rooms, showcase photo and literature sharing and polls when you choose to do so; and
(e) to notify you about changes to our service.
3.4 If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means but only if you have consented to this by opting in to receive third party communications.
3.5 If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the Account Information website page on which we collect your data.
3.6 We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 500 men aged over 50 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in London SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience. All data passed to the advertiser is anonymised.

Whenever we process data for these purposes we will ensure that we always keep your Personal Data rights in high regard and take account of these rights.

You have the right to object to this processing if you wish and if you wish to do so please click here. Please bear in mind that if you object this may affect our ability to carry out the tasks above for your benefit.

4 How long may we keep your personal information for?

4.1 We will hold your personal information on our systems for as long as is necessary for the relevant activity. If you delete your Silversurfers account then all your personal information is deleted immediately.

5 Where do we store your personal data?

5.1 The data that we collect from you may be transferred to and stored at, a destination outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

Silversurfers uses a USA based company called MailChimp to send out email newsletters to our members and they securely store our members’ email addresses on their database. MailChimp are also used by many other companies in the UK for sending out email newsletters. The GDPR contains provisions that address the transfer of personal data from EU member states to third-party countries, such as the United States.

The GDPR requires that certain conditions be met before personal data is transferred outside the EU, identifying a number of different legal grounds that organizations can rely on to perform cross-border data transfers. One legal ground for transferring personal data set out in the GDPR is an “adequacy decision.” An adequacy decision is a decision by the European Commission that an adequate level of protection exists for the personal data in the country, territory, or organization where it is being transferred.

The Privacy Shield framework constitutes one such example of an adequacy decision. MailChimp participates in and has certified its compliance to the Privacy Shield framework, and they are committed to treating all personal data received from EU member countries in accordance with the Privacy Shield framework’s applicable principles.

6 How do we use cookies and website analytics?

6.1 The Site, in common with most websites, has cookies which enable a much easier experience for our users and also allow us to improve our site. Cookies are simply “text files” which contain just two pieces of information which a website name and a unique user ID (a user ID is the same as a username. It’s just a sequence of characters and numbers that is used when you log into a computer or onto the Internet and is used for identification). Our website uses cookies to distinguish you from other users of our website. For detailed information on the cookies we use and the purposes for which we use them see our Cookie policy.
6.2 Cookies work by being downloaded onto your Personal Computer (PC) the first time you visit a website. Then the next time you visit that website your PC just checks to see if it has a Cookie that is relevant to that site and send the information contained in the Cookie back to the website. All this takes milliseconds. The website then “checks” that you have been on it before by the use of the Cookie check and with this then varies the content which is presented to you on the website according to what you have used the previous time or even multiple times.
6.3 Some Cookies are much more sophisticated for example they can record how long you stay on certain pages and what you click on in those pages and even your preferences for page layouts, and which banner adverts you prefer so that different adverts can be shown to you. The benefits of Cookies are many; they really make your interaction with websites much easier so for example, they remember details when you are shopping online making this experience much easier
6.4 We also use Google analytics on our Site which measure how many users and customers we have on the website and which pages they visit. We use this information to understand how our Site is performing and many large websites use similar analytics from companies like Google.

7 Banners, links and contacts to other websites

When using our Site you may go through to other websites, blogs, forums, adverts, competition and offers. When doing this, this Site’s privacy policy does not apply and the privacy policy and terms and conditions of that website, blog, forum, advert, competition apply. We take no responsibility or liability for any information, cookies or information collected by these other sites. Please check these policies before you submit any personal data to these sites.

8 How do we keep your personal information secure?

8.1 We are dedicated to maintain the security of all your data and to prevent unauthorized access through the implementation of appropriate technical measures, as far as is reasonably possible. Such security measures also include access restrictions, i.e. that data may be accessed only by a limited number of persons within Silversurfers.com
8.2 All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
8.3 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

09. Who do we share your information with and why do we do this?

9.1 We may disclose your personal information to third parties:
(a) in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
(b) if Silverhairs Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets;
(c) if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or legal claim, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of Silverhairs Limited, our customers, or others. This includes exchanging information with other companies and organisations, contractors, suppliers and service providers for the purposes of fraud protection and credit risk reduction.

10 How can you change, update or delete your personal information?

You have the right to ask us not to process your personal data for marketing purposes. We will inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by ticking certain boxes to opt-in to marketing communications or by updating your preferences in the “My Account” area of Silversurfers.com and on the forms we use to collect your data. You can also exercise the right at any time by contacting us

11. Your Rights

We have listed below the rights you have over your information and how you can use them.
These rights will only apply in certain circumstances. They will generally not be available if there are outstanding contracts between us, if we required by law to keep the information or if the information is relevant to a legal dispute.

• Access: You are entitled to ask us if we are processing your information and, if we are, you can request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Correction: You are entitled to request that any incomplete or inaccurate personal information we hold about you is corrected.
• Erasure: [You are entitled to ask us to delete or remove personal information in certain circumstances.] or [You have a right to be forgotten and you can ask that our systems stop using your information.] There are also certain exceptions where we may refuse a request for erasure, for example, where the personal data is required for compliance with law or in connection with claims.
• Restriction: You are entitled to ask us to suspend the processing of certain of your personal information about you, for example, if you want us to establish its accuracy or the reason for processing it.
• Transfer: You may request the transfer of certain of your personal information to another party.
• Objection: Where we are processing your personal information based on a legitimate interest (or those of a third party) you may object to processing on this ground. However, we may be entitled to continue processing your information based on our legitimate interests.
• In addition, you have the right to object at any time to your personal data being processed for direct marketing purposes.
• Automated decisions: You may contest any automated decision made about you where this has a legal or similar significant effect and ask for it to be reconsidered.
• Consent: Where our processing is based on your consent you have the right to withdraw your consent at any time.
• Complaint: You also have a right to lodge a complaint with a supervisory authority, in particular in the Member State in the European Union where you are habitually resident, or where an alleged infringement of Data Protection law has taken place. In the UK you can make a complaint to the Information Commissioner’s Office (Tel: 0303 123 1113 or at www.ico.org.uk).

12 We will tell you if we change our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail.

13 How you can contact us

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed here