Privacy Policy

The Wave Privacy Policy

Last updated: December 2024

Your privacy is important to us and we are committed to protecting any information about you that we collect and store. In this privacy policy we will tell you what personal information we collect, how we look after it, how we use it and how the law protects you.

1. 1. How to use our Privacy Policy

This privacy policy gives you information on how and why we collect and processes your personal data, for example any data you may provide when you sign up to our newsletter, purchase a surf session, sign our Acknowledgment of Risk and Waiver or book a stay at The Camp.

We keep our privacy policy under regular review. This version was last updated in December 2024.  Please check this page from time to time to ensure that you are aware of any updates.

1. 2. Who We Are

The Wave is made up of different legal entities. Your data will be shared across these group companies to keep you informed about our products and services, to handle complaints and queries and to give you the best customer service we can. When we mention “The Wave”, “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in The Wave Group responsible for processing your data. We will let you know which entity will be the controller for your data when you purchase a product or service with us. The Wave Group Limited is the controller and entity responsible for this website.

We are not required by law to have a Data Protection Officer (DPO), but if you have any questions about this privacy policy or our privacy practices, including any requests to exercise your legal rights (paragraph 10), please contact us using the information set out in the contact details section (paragraph 11).

3.The types of personal data we collect about you

Personal data means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you when you:

• Use our website. We collect Technical Data, which includes information such as your IP address, browser, network location, operating system and device. Usage Data, which includes information about how you use our website. This information helps us produce anonymised data about our user’s browser behaviours and improve our digital customer journey and product offering.
• Purchase products from our website (including booking tickets for a surf session or a stay at The Camp). We collect Identity Data which includes first name, last name, title, date of birth and car registration number (if you book a stay at The Camp). Contact Data, which includes billing address, delivery address (if purchasing online retail), email address and telephone number. Financial Data, which includes bank account and payment card details. Transaction Data, which includes details about payments to and from you and other details of products and services you have purchased from us.

• Contact the Customer Contact Centre. We collect Identity Data and Contact Data, which includes first name, last name and email address.
• Interact with us via social media (such as Facebook and Instagram) including sending us direct and private messages. We collect Profile Data which may include your username, interests, preferences and feedback.
• Sign up for our newsletter. We collect Identity Data which includes your name and email address and Marketing and Communications Data which includes your preferences in receiving marketing from us and our third parties and your communication preferences.

• Participate in a competition with us. We collect Identity Data including your name, contact information, delivery address and Financial Data (if applicable).
• Are captured by our CCTV system when you visit The Wave site. We operate CCTV around the lake and the solar park for operational, health and safety and security purposes. Your Image Data is collected if your image is captured on the CCTV footage.

• Are captured by our on-site photography team or automated video capture service provider, Flowstate Zone Pty Ltd (“Flowstate”). Your Image Data may be collected when we take photographs or recordings of lake sessions to be made available for purchase by customers. We may also take photographs, live stream footage or recordings of The Wave site for promotional and marketing purposes where your Image Data is collected if your image is captured by our photographers.

• You make use of our First Aid facilities while on site. We collect Identity Data including your name, Contact Data including your email address and telephone number and Medical Data, including details of any accident or incident on site.
• Register for and use Flowstate, the automated video capture system. Flowstate uses AI and non-biometric markers to group clips of surf sessions together for purchase by customers. For more information on Flowstate, see paragraph 11.

We also collect, use and share Aggregated Data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate customer’s Usage Data to calculate the percentage of customers who book into specific lake sessions to analyse general trends and help us improve our lake mix.

We do not knowingly collect any personal information from children under the age of 18. If you are aged under 18 please ask your parent or guardian’s permission before you provide any personal information to us.

4. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Your interactions with us: You may give us personal data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• Register for an account on our website;
• Purchase a product or book a surf online;
• Book to stay at The Camp;
• Sign our Acknowledgement of Risk and Waiver;
• Apply for a job;
• Subscribe to our newsletter;
• Interact with us via social media;
• Make use of our on-site First Aid facilities;
• Enter a competition, promotion or survey; or
• Give us feedback or contact the Customer Contact Centre.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
• Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:
• Technical Data is collected from the following parties:
• analytics providers such as Google; and
• advertising networks such as Meta and Google Ads;
• Contact Data, Financial Data and Transaction Data is collected from providers of technical, payment and delivery services such as Stripe, Verifone and Barclaycard.
• Contact Data and Identity Data may be provided by schools, clubs and other organizations that make bookings with us on behalf of a group.
• Identity Data, Contact Data and Transaction Data is collected by Anytime Booking and Booking.com, systems providers that take online bookings for The Camp.

5. How we use your personal data

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

• Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you (e.g. when you have made a booking for a surf session).
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter or where it is required under law (e.g. if you use our on-site first aid facilities).

The table below sets out a description of the ways we plan to use the personal data that we collect, and which of the legal bases we rely on to do so.

Performance of a Contract: To provide you with the products and services you have booked with us.
Type of Data	Purpose / Use
Identity Data and Contact Data	To register you as a customer and to allow you to make bookings for lake sessions, to stay at The Camp or purchase products from our website. To process and deliver your booking and to send you information about it (e.g. confirmation email, link to waiver). To manage our relationship with you, including inviting you to take part in competitions or surveys, dealing with enquiries or complaints.
Financial Data and Transaction Data	To take payment for your booking and issue any refunds / credits.
Profile Data	To provide you with the products and services you have purchased and for related purposes such as customer service, handling complaints and queries.
Image Data	To give you the option to purchase videos of your surf sessions if you have registered for Flowstate (for more information, see paragraph 11).
Legitimate Interests: we may process your personal data where we have legitimate business grounds to do so.
Identity Data and Contact Data	To prevent fraud. To improve our website and customer experience. To respond to customer enquiries. To have an accurate record of all customers.
Technical Data	To improve our website and customer experience, including troubleshooting, data analysis, system support and testing, maintenance and reporting.
Profile Data and Usage Data	To develop and improve our website and product offering. To create customer segments for the purpose of carrying out targeted marketing and promotions. To understand how customers use our products and services, for analytics and modelling and to create business intelligence and insights. To deliver relevant website content to customers and improve the digital customer journey.
Image Data	To take photos of: (i) The Wave site, for use in our promotional and marketing materials, including via our website and social media channels; and (ii) of specific lake sessions, to enable us to make photos available for purchase by you. We ensure that notices are in place on site to inform you of on-site photography. If you do not wish to be captured in videos or photographs on site or in specific lake sessions please inform a member of staff and we can put appropriate measures in place. To use CCTV to prevent and detect inappropriate or unlawful activities around the site, to protect our business interests and the safety and well-being of customers. To capture footage of surfers in the reef area of the lake to make the footage available for purchase via our service provider, Flowstate. The footage is collected automatically and can be purchased via the Flowstate website. If footage is not purchased it is deleted after 30 days. Flowstate will handle your personal information in accordance with their privacy policy (available here: https://flowstate.zone/en/privacy  ). If you have any concerns over the footage captured by the Flowstate system please inform a member of staff to discuss options.
Consent: We may seek your explicit consent to process your personal data.
Marketing and Communications Data	To contact you about our products, services and promotions. To invite you to take part in surveys and competitions.
Health Data	To provide you with on-site first aid and keep a record of accidents and incidents.
Image Data	If you register with Flowstate, you can control whether your sessions are private or be made public. If you select the public setting, you also consent for Flowstate and The Wave to use your footage for promotional and marketing purposes. You have full control over your privacy settings and can update this at any time.
Legal Compliance: We may need to comply with a legal requirement.
Identity Data, Profile Data and Contact Data	To defend any legal claims. To detect fraud.
Financial and Transaction Data	To detect fraud and comply with HMRC requirements. To defend any legal claims.
Image Data	To use CCTV to prevent and detect inappropriate or unlawful activities.
Health Data	To report any accidents and incidents that occur on site to the relevant authorities.

Special Category Data

Before collecting and/or using any special category data, such as Medical Data, we will establish an additional lawful basis, such as your explicit consent or the establishment, exercise or defence of legal claims.

Marketing

We will provide you with clear choices on how we use your personal data for marketing and advertising purposes.

Direct Marketing

During the registration process on our website when your personal data is collected, you will be asked to indicate your preferences for receiving direct marketing communications from us via email, SMS or the telephone.

We may also analyse your Identity Data, Contact Data, Technical Data, Usage Data and Profile Data to form a view about which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please click on the paperclip symbol in the bottom left corner of your screen.

This will take you to our cookie policy and allow you to change your cookie preferences.

 

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6.Disclosures of your personal data

We may share your personal data with the parties set out below.

Service providers acting as processors who provide IT and system administration services:

• Vivaticket, who provide our centralised ticketing system;
• Flowstate, who provide the Flowstate automated video capture system;
• ZenDesk, who provide our CRM system;
• Anytime Booking, who manage bookings for The Camp;
• BeCalm and Alert 6, who provide our Health and Safety and Incident Reporting system;
• Cloudflare, who provide DNS and cyber security protection;
• Power BI, which we use to anonymise and analyse our data, and create business intelligence reports;
• Zenfolio, who provide the system which allows customers to purchase photos of lake sessions;
• Zensell, who provide the system for our group sales (such as corporates and schools); and
• Woo-Commerce, who provide the system for our online retail.

Analytics providers who assist us with the improvement and optimisation of our website:

• Google Analytics and Google Ads;
• CookieBot, who manage cookies and trackers;
• DotDigital, who we use to create and send emails and provide analytics around email opening and click-through rates;
• Sprout Social, to manage social media posts and provide analytics; and
• Experian, to analyse customer data and segment user profiling.

 

Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services. In particular, Barclaycard EPDQ, Verifone and Stripe who are our payment providers.

HM Revenue & Customs, Health and Safety Executive, regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances (e.g. accident reporting).

Other companies in The Wave Group Limited Group.

Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

1. 7. International transfers

We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law.

Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that we use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK.

1. 8. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

1. 9. Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see paragraph 10 below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

1. 10. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

You have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
• If you want us to establish the data’s accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us (see Contact details, paragraph 12).

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

11. Flowstate 

Flowstate is a video capture technology provided by Flowstate Zone Pty Ltd. Flowstate uses AI to identify surfers and compile their clips, creating video content of their surf sessions that can be purchased. Flowstate does not process biometric data. The system uses pattern matching techniques, based on non-biometric features such as wetsuit tags and board markings, to group together similar-looking surfers. Flowstate will handle your personal information in accordance with their privacy policy, available here.

Flowstate is only available for surfers using the reef section of the lake (Waikiki, intermediate, advanced, expert turns and expert barrels sessions). The video cameras for Flowstate are installed at The Wave site and capture footage automatically of all reef surf sessions. The footage is publicly available on The Wave pool zone on the Flowstate website.

On The Wave pool zone page you can find yourself in the identified and grouped surfers, and purchase your content. You are able to choose whether or not your purchased content is publicly available on The Wave’s Flowstate activity feed, or is private and viewed only by you. If you set your content to public mode, you consent to your images and recordings being used by Flowstate and The Wave for marketing and commercial purposes.

We ask all surfers to only purchase content that has been assigned to them, but we cannot guarantee that all customers will follow this instruction. If you do not wish your content to published on The Wave pool zone, please let a member of The Wave staff know in advance of your session.

Flowstate may share images, recordings and other information associated with the Flowstate system with us. We have a data processing agreement in place with them to ensure that Flowstate will collect, process and share your personal data securely and in accordance with the law.

Although your footage will be grouped together and assigned to your account, it is possible that you may appear briefly in the background of other surfers footage. All footage captured by the system will be deleted 30 days after it is collected.

The purpose of the collection and processing by Flowstate is to enable us to provide surfers who opt-in with high quality video footage of their surf sessions which can be used as a coaching tool to track development.

If you have any concerns about the footage captured by the Flowstate cameras please speak to a member of The Wave staff.

1. 12. Contact details

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us using the following contact details:

• • For the Attention of: Legal Counsel
  • Email address: legal@thewave.com
• Postal address: The Wave, Main Road, Easter Compton, BS35 5RE

1. 13. Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

1. 14. Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated in December 2024.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

1. 15. Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.