1. Important information and who we are
HBS Sports Limited is the data controller and is responsible for your personal data.
Note that you may contact the Information Commissioner’s Office (“ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk) at any time if you are not satisfied with the way we have handled your data. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
We may make changes to this policy from time to time and if we make material changes, we will inform you through our Services. A change to this policy will be treated as a change to your contract under the terms of service.
By using our Services, you give consent to the collection, processing, use and sharing of your personal data. We will give you choices about how and with whom you share personal data.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- “Identity Data” including, for example, name and date of birth.
- “Contact Data” includes your address, any billing or delivered addresses, email addresses telephone numbers and other contact details.
- “Financial Data” includes bank account and payment card details.
- “Transaction Data” includes details about payments to and from you and products and services you have purchased from us.
- “Technical Data” includes IP addresses, login data, browser data, operating systems, platform and other technology on the devices you use to access this site.
- “Profile Data” includes your usernames, passwords, purchases, and preferences and personal data about you each time you post, upload content, send messages, fill out forms, submit details or communicate with other users.
- “Performance Data” includes the data collected relating to your physical performance by apps used by the site (including with any hardware we supply) and from the results of matches played by football players.
- “Usage Data” includes information about how you use our site.
- “Marketing Data” includes your preferences concerning marketing and other communications.
We do not collect data about your race, ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, healthcare, genetic or biometric data). We do not collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services).
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact, Financial, Profile and other data by entering your details on our site and by communicating with us and with others on the site. You may also share Profile, Contact and Performance Data with others and us on the site.
- Automated technologies or interactions. As you interact with our site, we may automatically collect Technical Data, Profile Data and Performance Data about you. We collect data by using cookies, site logs, our apps and other technologies.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as such as analytics providers (such as Google, based outside the EU and clubs and football associations across the world). We may also receive Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
4. How your personal data will be used and shared
We may process, use and share your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. If you need further details, you may contact us through the Service.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you, set up and operate your account||Identity
|Performance of our contract with you|
|To process and deliver orders, provide you with the services, promote you and manage payments.||Identity
To manage our relationship with you and others on the site, provide ongoing services which will include:
||Identity Contact Profile Performance Marketing||
|To administer and protect our business and this site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||
|To use data analytics to improve our site, products, services, customer relationships and experiences||
|To develop, update and keep the site relevant, to ensure it provides you want you want out of the site.|
|To contact you with suggestions, recommendations, training opportunities and information that may be of interest an and keeping you informed.||Identity Contact Profile Performance Usage Marketing Technical||
Promotional offers and marketing
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and opportunities may be relevant for you.
Unless you opt out as part of the Service, we will use this information to make you aware of such products and services and opportunities.
Only other users may contact you on the site and only by the means permitted on our site.
We will get your express opt-in consent before we share your personal data with any other third party for any marketing or other purpose.
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 need any further information, you can contact us through the Service.
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.
5. Disclosures of your personal data
The personal data obtained and uploaded to our site may be shared with the parties set out below for the purposes set out in the table in paragraph 4 above.
- Other users through the messaging system provided in the Service;
- Service providers in the UK who provide IT and system administration services;
- Professional advisers including lawyers, bankers, auditors and insurers based in the UK for the purposes of providing professional services;
- HM Revenue & Customs, regulators and other authorities in the UK who require reporting of processing activities in certain circumstances; and
We require all third parties and other users 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.
6. International transfers
Profile and Performance Data will be visible to all users of the Services and you will be able to communicate with and share information with users who may be based outside of the European Economic Area (“EEA”). Any processing of your personal data may therefore involve a transfer of data outside the EEA.
All users are required to agree to the data processing terms set out in our online terms.
Nevertheless, we may restrict or prevent:
- any transfer of personal data to countries that have not been deemed to provide an adequate level of protection for personal data by the European Commission.
- certain service providers or users from accessing or sharing personal data where we consider that it may conflict with any data protection rule binding on us.
- any transfer of personal data to a person in the US that is not a are part of the Privacy Shield, which requires any third party provider in the US to provide similar protection to personal data shared between the Europe and the US.
Please contact us through the Service if you want further information.
7. 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.
8. Data retention
How long will you use my personal data for?
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 and legal compliance purposes.
In some circumstances you can ask us to delete your data: you will have the option to do this through the Service.
In some circumstances we may 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.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You may contact us through the Service to:
- Access to your personal data;
- Correct any personal data.
- Erase your personal data.
- Adjust your privacy settings.
If you Contact Us to request more details, we try to respond to all legitimate requests within one month. Occasionally it may 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.
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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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 format. 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.
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