Privacy Policy

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

We collect, use and are responsible for certain personal data about you when you:

• engage with us in any pre- contractual discussions on behalf of a club or organisation,
• ask us for information about our services or platform,
• enter into a contract with us on behalf your organisation or club.

When we do so we comply with UK General Data Protection Regulation (UK GDPR) and to the extent required by law, the EU General Data Protection Regulation (EU GDPR) in relation to our wider operations in the European Economic Area (EEA). We are registered with the Information Commissioner’s Office.

We, us, our	Azolve Limited and our group companies.
Personal data	Any information relating to an identified or identifiable individual
Special category personal data	Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership Genetic and biometric data (when processed to uniquely identify an individual) Data concerning health, sex life or sexual orientation
Data subject	The individual who the personal data relates to

Key terms

It would be helpful to start by explaining some key terms used in this policy:Personal data we collect about you

We may collect and use the following personal data about you:

• your name and contact information, including email address, IP address, and telephone number
• your gender, if you choose to give this to us
• Information about how you use our website, platform, IT, communication and other systems

We collect and use this personal data to provide information to you about us or our services, and to improve and enhance our services. If you do not provide personal data we ask for, it may delay or prevent us from providing information to you.

How your personal data is collected

We collect most of this personal data directly from you via our website and platform. However, we may also collect information from cookies on our platform. We and our technology partners use cookies and other technologies for registration and personalisation purposes. Our application utilizes “cookies”, anonymous identifiers, container tags and other technologies in order for us to provide our service and ensure that it performs properly. Such cookies and similar files or tags may also be temporarily placed on your device. Certain cookies and other technologies serve to recall Personal Data, such as an IP address, previously indicated by a user. To learn more about our practices concerning cookies, please see our Cookies Policy.

How and why we use your personal data

Under data protection law, we can only use your personal data if we have a proper reason, e.g.:

• where you have given consent;
• to comply with our legal and regulatory obligations;
• for the performance of a contract with an organisation or club that has a contract with us, or to take steps at your request before entering into a contract with an organisation or club;
• to process payments with the organisation or club with whom we have a contract; or
• for our legitimate interests or those of a third party.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.

The table below explains what we use your personal data for and why.

What we use your personal data for	Our reasons/legal basis
Allowing you to use our platform and website	For our legitimate interests to ensure that access to the platform/website is controlled for the protection of all users and to allow you to use our platform and website
Manging our relationship with the club or organisation with whom we have a contract, including managing payments	For our legitimate interests to ensure that we manage our contractual relationships effectively
Preventing and detecting fraud	For our legitimate interests or those of a third party, i.e. to minimise fraud that could be damaging for you and/or us
Ensuring our acceptable use policy and other business policies are adhered to.	For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures and best practices
Operational reasons, such as improving, enhancing and developing our services and ensuring our security processes are adequate	For our legitimate interests or those of a third party, so we can deliver the best service through our platform and secure information of all authorised users
Ensuring the confidentiality of commercially sensitive information	For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations
Preventing unauthorised access and modifications to systems and our platform	For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for you and/or us To comply with our legal and regulatory obligations
Updating customer records	To perform our contract with an organisation or club, or to take steps at your request before entering into a contract with an organisation or club To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about our services and platform
Marketing our services to: —existing and former customers; —third parties who have previously expressed an interest in our services; —third parties with whom we have had no previous dealings.	For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers
External audits and quality checks, e.g. for accreditations such as ISO	For our legitimate interests or a those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards To comply with our legal and regulatory obligations

Where we process special category personal data, we will also ensure we are permitted to do so under data protection laws, e.g.:

• we have your explicit consent;
• the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent; or
• the processing is necessary to establish, exercise or defend legal claims.

Marketing

We may use your personal data to send you updates by email, about our platform and our services.

We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. However, where consent is needed, we will ask for this separately and clearly.

You have the right to opt out of receiving marketing communications at any time by contacting us at the address below.

We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

We will always treat your personal data with the utmost respect and never sell it to other organisations for marketing purposes.

Who we share your personal data with

We routinely share personal data with:

• companies within the Azolve group
• third parties we use to help deliver the platform and service to you, e.g. email providers and infrastructure providers;
• other third parties we use to help us run our business, e.g. marketing agencies or website hosts; and
• our banks;

We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.

We may also need to:

• share personal data with external auditors, e.g. in relation to accreditations (ISO) and the audit of our accounts;
• disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations;
• share some personal data with other parties, such as potential buyers of some or all of our business or during a restructuring—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations.

We will not share your personal data with any other third party.

Where your personal data is held

Personal data may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal data with’).

Some of these third parties may be based outside the UK and EEA. For more information, including on how we safeguard your personal data when this happens, see below: ‘Transferring your personal data out of the UK and EEA.

How long your personal data will be kept

We will only retain your data for as long as necessary to fulfil the purposes we collected it for. Once those purposes have been achieved then, unless a different purpose for processing your data arises, it will be permanently deleted.

Transferring your personal data out of the UK and EEA

It is sometimes necessary for us to share your personal data outside the UK/EEA, e.g.:

• employees of the Azolve group of companies located outside the UK/EEA;
• with your and our service providers located outside the UK/EEA;
• if you are based outside the UK/EEA;

We understand that some countries offer a lower standard of protection and will only transfer your data abroad where we are confident that your data will be properly protected.

In particular, we will only transfer your data to countries that have been deemed to offer an adequate level of protection, or where there are specific contractual protections in place with the recipient. Where do we rely on contractual safeguards then we will only use Standard Contractual Clauses approved for use by the ICO. Please contact us to know more about Standard Contractual Clauses and how we use them.

Your rights

You have the following rights, which you can exercise free of charge:

Access	The right to be provided with a copy of your personal data
Rectification	The right to require us to correct any mistakes in your personal data
Erasure (also known as the right to be forgotten)	The right to require us to delete your personal data—in certain situations
Restriction of processing	The right to require us to restrict processing of your personal data in certain circumstances, e.g. if you contest the accuracy of the data
Data portability	The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object	The right to object: —at any time to your personal data being processed for direct marketing (including profiling); —in certain other situations to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests.
Not to be subject to automated individual decision making	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, please contact us (see ‘How to contact us’ below) or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights.

If you would like to exercise any of those rights, please:

• email, call or write to us—see below: ‘How to contact us’; and
• provide enough information to identify yourself (e.g. your full name, address and customer or matter reference number) and any additional identity information we may reasonably request from you;
• let us know what right you want to exercise and the information to which your request relates.

Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

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

However, please note that despite our best efforts we cannot guarantee the security of information being exchanged over the internet and, where our website contains links to other website plug-ins and applications that are not operated by us, clicking on those links or enabling those connections may allow third parties to collect or share data about you.

How to complain

Please contact us if you have any query or concern about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with the Information Commissioner or any relevant European data protection supervisory authority.

Changes to this privacy policy

This privacy notice was published on [insert date] and last updated on [insert date].

We may change this privacy notice from time to time and we ask that you check back here on a regular basis to read this privacy notice.

How to contact us

Individuals in the UK

You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

Our contact details are shown below:

Our contact details: Phil Robinson
Address: Azolve Limited, 1 Lonmay Road, Glasgow, G33 4EL Email: phil.robinson@azolve.com Tel: +44 (0)141 459 0105

Individuals in the EEA

We have appointed David Pring to be our data protection representative within the EEA. His contact details are david.pring@azolve.com.

Individuals within the EEA can contact us direct (see above) or contact our European representative.