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PURPLE DRAGON PRIVACY NOTICE

Last updated: May 2025 We respect the privacy of every person who visits or registers with Purple Dragon and uses the products and services that we make available such as our adventures, classes and events. This Privacy Notice (“Privacy Notice”) explains how Purple Dragon (Holdings) Limited (“Purple Dragon”) collects, uses, shares, transfers and otherwise processes your personal data in connection with our business, including the provision of our website at www.purpledragonplay.com (“Site”) and our Android and iOS mobile application (“App”) and the products and services we offer through our Site, App and any of our physical locations (“Services”). Purple Dragon is part of the NEXUS Luxury Collection, with its registered office at 303 Shirley Street, Nassau, The Bahamas (“NEXUS”). Purple Dragon is the controller of your personal data in respect of the activities set out in this Privacy Notice. This Privacy Notice should also be read in conjunction with our Cookie Notice and our Terms and Conditions.

Purpose of this Privacy Notice

This Privacy Notice explains our approach to any personal data that we might collect from you or which we have obtained about you from a third party and the purposes for which we process your personal information. This Privacy Notice also sets out your rights in respect of our processing of your personal data. Personal data means any information which relates to an identified or identifiable living individual. Individuals might be identified by reference to a name, an identification number, location data, an online identifier (such as an IP address) or to other factors that are specific to them, such as their physical appearance. We use your personal data for many reasons, from understanding how our users engage with our content to informing our marketing and advertising. This Privacy Notice is intended to assist you in making informed decisions when using our Site, App and Services and to understand how your personal information may be processed by us. Please take a moment to read and understand it. Our website contains links to other sites whose information practices may be different than ours. Visitors should consult the other sites’ privacy notices as Purple Dragon has no control over information that is submitted to, or collected by, these third parties.

About Us

Purple Dragon is a UK company with registered company number 08104548 and whose registered office is at 1 Vincent Square, London, SW1P 2PN. Purple Dragon is the data controller responsible for processing your personal information. This means that we are responsible for deciding how and why we hold and use your personal data. You can contact us by writing to the above address or by:

Directly from you We collect personal data when you:

  • Sign up for and use our App, Site and Services
  • Pay for a subscription or purchase any other Services;
  • Attend our events;
  • Enter prize draws we organise with third parties;
  • Complete our surveys;
  • Sign up for marketing communications;
  • Use mobile devices to access our content; and
  • Apply for a job with us.

Cookie data When you access and use our Site or App, we will collect personal data by using cookies and other similar technologies. For more information, please see our Cookie Notice. From third parties We may receive personal data about you from third parties. Such third parties may include analytics providers, and third parties that provide technical services to us so that we can provide our Services. When you register or book a ticket for any event organised by an event partner, your registration data may be shared with us by the event partner. We also use information on the content you have viewed on our Site and App and your interaction with the content to add you to groups with similar interests and preferences, so that we can make our online advertising more relevant. Sometimes we use data about your interests or demographics that third parties have collected from you online to add to these groups. Please refer to our cookie policy for more information on how we use cookies.

What personal data we collect

In providing our Site, App and Services, we may collect and process different types of personal data about you for different processing purposes. The types of personal data we collect depends on who you are and how you use our Site, App and Services. The below lists are not exhaustive. If you are prospective member of Purple Dragon, we may process:

  • Full Name;
  • Job Title;
  • Contact Information (postal address, email address, telephone numbers);
  • Children’s Details (number of children, name, date of birth, school);
  • How you found out about us.

If you are an individual member in receipt of our Services, the following information is collected both on our application forms and on our HelloYou membership system, and when you use our Services:

  • Full Name;
  • Contact Information (postal address, email address, telephone numbers, emergency contact);
  • Date of Birth;
  • Payment Information (bank details, debit or credit card details);
  • Personal Family Circumstances;
  • Allergy Information (including health information);
  • Images (photographs, family tree);
  • Video Recordings (activities at our premises, attendance at our events);
  • Marital status (married, living with your partner, divorced, single)
  • Household Details (size of your household, what professions / jobs do the people in your household do);
  • Children’s Details (number of children, name, date of birth, school);
  • Hobbies and Interests;
  • CCTV Footage.

If you are a visitor to Purple Dragon, we may process:

  • CCTV Footage;
  • Contact Information (postal address, email address, telephone numbers);
  • Visitor Records Information. (We require visitors to our premises to sign in at reception and we keep a record of visitors for a short period of time. Our visitor records are securely stored and only accessible on a need-to-know basis e.g. to look into an incident);

If you are a job applicant to Purple Dragon, we may process:

  • Full Name;
  • Contact Information (postal address, email address, telephone numbers, emergency contact);
  • CV Information (employment details, job title, education details, hobbies and interests);
  • Psychometric Testing Results;
  • Interview Information;
  • Diversity Information (gender, race, ethnic origin, age, religion, sexual orientation, disability);
  • Background Checks Information (DBS check results);
  • Any other personal data you provide in connection with your application.

Occasionally Purple Dragon engages third party businesses (i.e. other corporate entities). If you are a contractor or employee of a third-party businesses we engage, we may process a variety of personal data depending to the Services provided in question and in connection with your organisation’s relationship with us. When you use our Site and App we may also use cookies or similar technology to collect additional data, including:

  • Your IP address – a numerical code to identify your device and which can provide information about the country, region or city where you are based;
  • Behavioural Data – your browsing history of the content you have visited on our sites, including information on how you were referred to our Site via another website; and
  • Technical Data – details of your devices, for example, the unique device ID, unique advertising ID and browsers used to access our content.

Some of our Services may give you the option of providing more information about your cookie preferences, so that we can tailor your experience. For more information, please see our Cookies Notice.

How we use personal data and our legal basis

Our purpose in collecting personal information from you may be to verify your identity, help us deliver our Services, improve, develop and market new Services, carry out requests made by you via email/phone or in relation to our Services, investigate or settle inquiries or disputes, comply with any applicable law, court order, other judicial process, or the requirements of a regulator, enforce our agreements with you, protect the rights, property or safety of us or third parties, including our other customers or subscribers and users of our Services, provide support for the provision of our Services, recruitment purposes, and use as otherwise required by law. Further information about the purposes for which we use personal data collected through our Services is set out below.

Registration and access to our Site and App.

You will be required to register an account with us in order to gain access to our Services. Account applicants will need to complete the registration form by providing profile information such as Full Name and Contact Information. Once the account is registered, we will process your personal data, such as Technical Data to identify you when you log in to your account and access secure areas of our Site and App, administer your account and contact you about your account. We will also collect and process Technical Data and Behavioural Data when you use certain features and functionality on our Site and App. This data helps us understand how you use our Site and App so that we can improve them. What is our legal basis? It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you, or it is in our legitimate interest to use personal data in such a way to ensure that we provide access to our Services in a secure and effective way and so that we can make improvements.

Fulfilment of Services.

We collect and maintain personal data that you submit to us for the purpose of supplying our Services that you have requested from us. The personal data we process may include your Full Name, Contact Information, Household Details, Children’s Details and Payment Information so that we can fulfil the supply of Services, process any returns, maintain our user databases and to keep a record of how our Services are being used. What is our legal basis? It is necessary for us to use your personal information to perform our obligations in accordance with any contract that we may have with you or it is in our legitimate interest or a third party’s legitimate interest to use personal information in such a way to ensure that we provide the Services in the best way that we can. Where necessary we may also need to comply with legal obligations to fulfil the Services (e.g. in relation to child safeguarding issues).

Hosting and managing events.

We organise and host adventures, classes and events. We may process your Full Name and Contact Information to provide you with details about events where you have specifically requested information about them or where we have another lawful basis for sending that information to you. If you attend one of our events, we may use your personal data to record your attendance at the event and for related record-keeping purposes and, if relevant, we may collect and process any dietary requirements you may have including any Allergy Information. You may also feature in photographs taken at our events and such photographs may appear in publications that we make available. What is our legal basis? It is necessary for us to use your personal data in this way to perform our obligations in accordance with any contract that we may have with you where you have signed up to attend an event, or it is in our legitimate interest or a third party’s legitimate interest to use personal data in such a way to ensure that the event is operated in an effective way. Where we process allergy information and this constitutes health information, we do so with your consent. We may specifically ask your permission to use your photographs, quotes, testimonials, or other content that you make available or publish at the event. Where this is the case, our processing of your such personal data will be based on consent.

Marketing.

We carry out the following marketing activities:

Postal marketing.

We use your address details to send you marketing communications by post. What is our legal basis? It is in our legitimate interest to use your personal information for postal marketing.

Email marketing.

We use your email address to send you marketing communications by email, where you have consented to receive such marketing communications, or where we have another lawful basis to do so. What is our legal basis? We will only send you marketing communications via email where you have consented to receive such marketing communications, or where we have a lawful right to do so.

Promoting our business

Images and Video Recordings may be taken during activities or events at our premises and published for promotional and advertising material. What is our legal basis? It is in our legitimate interests to promote or advertise our business. You can opt out from having your personal data used for marketing purposes at any time by using the link in a marketing email or by contacting us using the details provided in the “About Us” section.

Prize draws and competitions.

From time to time, we may organise prize draws, prize competitions and other promotions with third party companies and charities for a chance to win our Services. If you win, we will receive and process your Full Name, Contact Information, Payment Information, and any other personal data volunteered by you in relation to your entry for the purposes of administering such promotions. Our promotions are subject to separate terms and conditions which are provided by the third party that runs the promotion and which you may be required to accept as a condition of entry. What is our legal basis? It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you (e.g. the fulfilment of our Services) or it is in our legitimate interest to use your personal data to enable us to ensure that we provide the Services in the best way that we can.

Customer services.

We use various user interfaces, including recorded calls, to allow you to request information about our Services. Contact Information may be requested in each case, together with details of other personal information that is relevant to your Service enquiry. This information is used in order to enable us to respond to your requests. What is our legal basis? It is in our legitimate interest or a third party’s legitimate interest to use your personal information in such a way to ensure that we provide the very best client service we can to you or others.

Surveys and feedback about our Services.

From time to we will contact you to invite you to provide feedback about our Services or for market research purposes via a survey. We use this information to help us improve the quality of service provided by our staff. We also use your feedback to monitor the quality of our Services. What is our legal basis? It is in our legitimate business interests to use the information you provide to us in your feedback for the purposes described above.

Recruitment.

We use your personal information for the following recruitment purposes:

  • CV Information, Interview Information, Psychometric Testing Results and Background Checks Information to assess your suitability for any position for which you may apply at Purple Dragon whether such application has been received by us online, via email or by hard copy or in person application.
  • Diversity Information, which is reviewed on an aggregated and anonymous basis, to review Purple Dragon’s equal opportunity profile in accordance with applicable legislation, ensure that Purple Dragon does not discriminate on the grounds of gender, race, ethnic origin, age, religion, sexual orientation, disability or any other basis covered by local legislation. All employment related decisions are made entirely on merit.

What is our legal basis? Where we use your personal information in connection with recruitment it will be in connection with us taking steps at your request to enter a contract we may have with you or it is in our legitimate interest to use personal information in such a way to ensure that we can make the best recruitment decisions for Purple Dragon. We will not process any special category data except where we are able to do so under applicable legislation. For example, we process information concerning your health to comply with our legal obligation to make any reasonable adjustments to the recruitment process. When you apply for roles that work with children, we process Background Checks Information in the interest of safeguarding children.

CCTV.

If you are a visitor to Purple Dragon, we have security measures in place at our premises, including CCTV and building access controls. We capture CCTV Footage. There are signs in our premises showing that CCTV is in operation. The images captured are securely stored and only accessed on a need-to-know basis (e.g. to look into an incident). CCTV recordings are typically automatically overwritten after a short period of time unless an issue is identified that requires investigation (such as a theft). What is our legal basis? It is in our legitimate interests to process your personal data so that we can keep our premises secure and provide a safe environment for our staff and visitors to our premises.

Insight, analysis and retargeting through Cookies.

We and our third-party partners use cookies, web beacons, pixel tags and other similar technologies to collect data from the devices that you use to access our Site, App and Services. The data that is collected includes Behavioural Data and Technical Data. Please see our Cookies Notice for further information. What is our legal basis? Where your data is collected through the use of non-essential cookies, we rely on consent to collect your personal data and for the onward processing purpose. In certain circumstances, we may rely on another lawful basis when we use your personal data collected via the use of cookies. For example, where we use personal data collected through the use of analytics cookies to analyse how you use our Site and App, it is in our legitimate interest to use your personal data in such a way to improve our Platforms and Services.

Third-party business employee data in provision of Services

For instance, if we are hiring a catering company to provide food at an event for the benefit of our members we may be provided with, and then process, personal information about the workers of the catering company, including but not limited to the name and contact details of the company’s workers. What is our legal basis? It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you or the organisation you represent, or it is in our legitimate interest to use personal data in such a way to ensure that we have an effective working relationship with you or the organisation you represent and are able to receive the products and services that you or your organisation provides, and provide our Services to others, in an effective way.

Business administration and legal compliance.

We use your personal information for the following business administration and legal compliance purposes:

  • to comply with our legal obligations;
  • to enforce our legal rights;
  • protect rights of third parties; and
  • in connection with a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets.

What is our legal basis? Where we use your personal information in connection with a business transition, to enforce our legal rights, or to protect the rights of third parties it is in our or a third party’s legitimate interest to do so. For all other purposes described in this section, it is our legal obligation to use your personal information to comply with any legal obligations imposed upon us.

Our App

Our App uses information on the content you have viewed. A list of the adventures and events that you have recently viewed is cached in the local storage on your mobile device. You can delete this history in the settings of the App. Information on what you have viewed in the app and information on bugs and crashes is also sent to us. You can choose to receive notifications on your mobile device via the App. You can manage these notifications in the settings of the App.

Security of your personal data

We are committed to keeping the personal information provided to us secure and we will take reasonable precautions to protect personal information from loss, misuse or alteration. We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:

  • unauthorised access;
  • improper use or disclosure;
  • unauthorised modification; and
  • unlawful destruction or accidental loss.

All of our members, employees, workers and data processors (i.e. organisations who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all visitors to our Site and App and all users of our Services.

Who we share your personal data with

We will only share personal data with others when we are legally permitted to do so. When we share data with others, we put contractual arrangements and security mechanisms in place to protect the data and to comply with our data protection, confidentiality and security standards. Please note that when processing your personal data we may need to share it with third parties or other entities within our group of companies as follows:

  • We share personal data with other entities in the NEXUS group of companies for the purpose of setting up your membership or arranging your access to our sister clubs within the NEXUS group.
  • We use third parties to support us in providing our Site, App and Services and to help provide, run and manage our internal IT systems. For example, providers of information technology, website hosting, and management, security and storage services. The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and personal data may be stored in any one of them.
  • Third party organisations that assist us in facilitating payments for our Services.
  • Third party organisations that assist us with our marketing activities.
  • Background checks providers, such as the DBS, only where disclosure is consistent with a ground for processing on which we rely and doing so is lawful and fair to you.
  • Auditors, lawyers, accountants and other professional advisers, for example, in connection with a business transition or sale of our assets.
  • Law enforcement or other government and regulatory agencies or to other third parties as required by, and in accordance with, applicable law or regulation.
  • Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.

International data transfers

Our company is based in the UK. Where necessary to deliver our Site, App or Services we will transfer personal information to countries outside the UK and the European Economic Area (“EEA”). Countries outside the UK and EEA do not have the same data protection laws as the UK and the EEA. In particular, countries outside the UK and EEA may not provide the same degree of protection for your personal data, may not give you the same rights in relation to your personal data and may not have a data protection supervisory authority to help you if you have any concerns about the processing of your personal data. However, when transferring your personal data outside the UK or the EEA, we will comply with our legal and regulatory obligations in relation to the personal information including but without limitation having a lawful basis for transferring personal information and putting appropriate safeguards in place to ensure an adequate level of protection for the personal information.

  • Adequacy decisions: We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission and/or the UK Government (as applicable).
  • Model clauses: Where we use certain service providers, we may use specific standard contractual clauses approved by the European Commission and/or the UK Information Commissioner’s Office which give personal data the same protection it has in the EEA and/or the UK.

How long we keep your personal data

In respect of personal data that we process in connection with the supply of our Site, App and Services, we retain your personal data for no longer than the period for which it is required to fulfil the purposes listed in this Privacy Notice, in accordance with our internal data retention policies and in compliance with our data protection obligations. We may then destroy such files without further notice or liability.

Your rights with regard to the personal data that we hold about you

You have the following rights in relation to the personal information we hold about you:

Your right of access.

If you ask us, we’ll confirm whether we’re processing your personal information and, if necessary, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.

Your right to rectification.

If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If you are entitled to rectification and if we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

Your right to erasure.

You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If you are entitled to erasure and if we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

Your right to restrict processing.

You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or you object to us. If you are entitled to restriction and if we’ve shared your personal information with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

Your right to data portability.

You have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.

Your right to object.

You can ask us to stop processing your personal information, and we will do so, if we are:

  • relying on our own or someone else’s legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or
  • processing your personal information for direct marketing.

Your rights in relation to automated decision-making and profiling.

You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us.

Your right to withdraw consent.

If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.

Your right to lodge a complaint with the supervisory authority.

If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the UK Information Commissioner’s Office (ICO). You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113. If you want to make any of these requests, please contact us using the details in the “About Us” section. We may need to request specific information from you to help us confirm your identity.

Changes to the Privacy Notice

To ensure that you are always aware of how we use your personal information we will update this Privacy Notice from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We will notify you by email of any significant changes. However, we encourage you to review this Privacy Notice periodically to be informed of how we use your personal information.