This Privacy Policy sets out how Sportable Technologies Limited (registered number 09044327 whose registered office is at Gate A, StoneX Stadium, Greenlands Lane, London, England, NW4 1RL) (“Sportable”, “we”, “us” or “our”) collects and uses any personal data we collect or receive about or from you in respect of Sportable’s products, services and/or platforms (collectively, the “Sportable Service”), why we collect and use your personal data, who we might share this personal data with and your rights in relation to your personal data.
We are committed to protecting and respecting your privacy and complying with our obligations under the General Data Protection Regulation and the Data Protection Act 2018 and all other laws relevant to the handling of your personal data in respect of the Sportable Service (the “Privacy Laws”). We are the data controller for the purposes of the Privacy Laws (meaning that we are responsible for deciding how your personal data is used) and for ensuring it is handled in accordance with applicable privacy laws.
When we refer to “personal data”, we are referring to any information which can directly or indirectly identify you, as explained more fully below.
Information that you provide to us – this may include any of the following types of personal data which you provide to us when you use the Sportable Service, enquire about any aspect of the Sportable Service, or otherwise when you communicate or interact directly with us:
⦿ Identity Data – first name, last name;
⦿ Profile Data – you may provide feedback to Sportable through surveys or feedback forms and indicate your preferences to receiving marketing (from us or third parties); and
⦿ Contact Data – your phone number(s), email address and postal address.
Information that we collect about you – when you visit or use the Sportable Service we may collect the following types of personal data, using our software, hardware and other technologies:
⦿ Technical Data – this might include your IP address, account log-in information, browser information, location information, operating system and system configuration, network and software identification and device information;
⦿ Usage Data – this includes information about how you use the Sportable Service, such as click throughs, time spent on page, download errors;
⦿ In-Play Data – this is information collected by the Sportable Service during matches, training, and other sporting activity and includes spin, speed, distance, hang-time, height and/or kick/pass type; and
⦿ Athlete Data - this is information we collect on athletes who use the Sportable Service during matches, training and other sporting activity, usually as a result of our relationship with the Customer (as defined below). This will include name, team and position, and will be linked to In-Play Data.
Information that we receive about you from others – we may receive certain of the information about you referred to above from the team, club, league or other entity of which you are a member or representative and with whom we have a contractual relationship (a “Customer”). If we receive information from third parties we may combine this with information that we currently hold about you and process such combined information for the purposes set out below.
In addition to the above, please note that we may use and share aggregated data. This may have originally generated from your personal data but is not treated as personal data under the Privacy Laws (as it doesn’t individually identify you). On such basis, we can use this data for any purpose. If this aggregated data is ever combined with other data in such a way that you can be personally identified, we will only use that data in accordance with this Privacy Policy.
It is important that the information we hold about you is accurate. Please keep us informed of any changes to your personal information.
To register the Customer with the Sportable Service
Identity, Contact,
Performance of a contract with a Customer
For internal administration and record keeping purposes
All
Performance of a contract with a Customer
Necessary to comply with a legal obligation
Necessary for our legitimate interests (for effective business administration and service provision)
To provide, maintain, administer, improve and develop the Sportable Service
All
Performance of a contract with a Customer
Necessary for our legitimate interests (for effective business administration and service provision)
Consent
To notify you of changes to our Privacy Policy, our Terms and Conditions or other changes to our services or products
Identity, Contact
Performance of a contract with a Customer Necessary to comply with a legal obligation
To answer your enquiries which may involve contacting you by post,
e-mail or phone
Identity, Contact
Performance of a contract with a Customer
Necessary for our legitimate interests (to ensure our Customers are informed and satisfied with our service)
To contact you about Sportable promotions
Identity, Contact, Profile
Necessary for our legitimate interests (to improve our products and services and develop our business generally)
Consent
To contact you about third party products and services which we believe may be relevant to you (where you have indicated you would like to hear about these)
Identity, Contact, Profile
Consent
To verify your identity and detect fraud and security issues
Identity, Contact, Profile
Necessary for our legitimate interests (to prevent and detect fraudulent activity, security incidents and criminal activity)
To use for marketing and promotional purposes on our website and social platforms.
Identity, In-Play Data, Athlete Data
Necessary for our legitimate interests (for effective business administration and service provision).
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 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.
We will keep your personal data for as long as the term of our contract with the relevant Customer. After this point we may still need to keep hold of your personal data if there is a legal reason for doing so (such as for tax purposes or where we need to resolve any disputes with you or a Customer). In such circumstances, we will only retain the minimum amount of data necessary for such reason. We may retain aggregated data for any purposes.
Please note that the Sportable Service may include links to third party websites. If you choose to click through to the relevant third party’s website, you will be subject to the terms and conditions of use and privacy policy of the relevant third party. Sportable does not accept any responsibility or liability for these policies of your use of such third-party websites. Please check the terms of these policies before using the relevant third party’s website.
We store your personal data on servers in the European Economic Area. Sportable may need to transfer your personal data to other countries outside of the EEA. This may happen if any of our servers are from time to time located in a country outside of the EEA or if any of our service providers or Customers are located in a country outside of the EEA. Before we proceed with any such transfer, we will ensure that we have a legal ground for doing so and have made sure that all adequate protections are in place. These countries may not have similar data protection laws to the EEA. If we transfer your personal data outside of the EEA in this way, we will take the appropriate steps to ensure that your privacy rights continue to be protected and that we continue to process your data in a fair and lawful manner.
Where relevant, you will have the right to see a copy of any safeguards we put in place for international transfers of your data.
We may disclose your personal data for the following purposes:
⦿ To any Customer of which you are a member or representative, for the purposes of fulfilling our contractual obligations to that Customer.
⦿ To our third-party service providers who assist us with delivering the Sportable Service.
⦿ Where you have explicitly consented to us doing so, we may disclose your personal data to third parties for marketing purposes. You can opt-out of any marketing preferences at any time by following the process referred to below.
⦿ We may also be required to share your personal data with third parties if required by law or regulation. In such circumstances, we will make sure that the disclosure is only to the extent required by law or regulation.
If we share personal data with third parties, we will ensure that access is limited on a strictly need to know basis and is subject to suitable obligations relating to confidentiality and security.
We ensure that personal data is held securely in accordance with good industry standards. Where we have given you a password to access a part of the Sportable Service you are responsible for keeping this password secure and confidential. Please do not share this with anyone else.
Please be aware that the transmission of data via the internet is not completely secure. Although Sportable uses its best endeavours to keep your data secure, we cannot guarantee that information transmitted to us via the internet will be completely secure and any transmission is at your own risk.
If we amend our Privacy Policy, it will be published on the Sportable website or other Sportable platform so please check regularly to see if there have been any changes. We may also email you to notify you of any substantial changes to this Privacy Policy if appropriate.
In certain situations, you are entitled to:
⦿ correct your personal data;
⦿ erase your personal data;
⦿ object to the processing of your personal data where we are relying on a legitimate interest (as set out in the above table);
⦿ restrict the processing of your personal data;
⦿ request the transfer of your personal data to a third party; or
⦿ where you have provided your consent to certain of our processing activities, in certain circumstances, you may withdraw your consent at any time (but please note that we may continue to process such personal data if we have legitimate legal grounds for doing so).
If you wish to exercise any of these rights, please contact us using the details set out in the “Contact Us” section below. You will not have to pay a fee to exercise any of these rights, unless your request is clearly unfounded, repetitive or excessive (in which case we can charge a reasonable fee). Alternatively, we may refuse to comply with your request in these circumstances.
In addition to the above, please note that you have the right to make a complaint at any time to the Information Commissioner’s Office or your relevant regulator if you are concerned about the way in which we are handling your personal data.
You can opt-out of any third-party marketing that you have previously opted into (or any Sportable marketing) either by contacting us using the details set out below in the “Contact Us” section or by using the opt-out function detailed in the relevant marketing email.
If at any time you wish to get in touch with us, whether that is to exercise your rights or otherwise, please contact:
Email: info@sportable.com
Please write to us at: Sportable Technologies Limited, Gate A, StoneX Stadium, Greenlands Lane, London, England, NW4 1RL
