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ENGLAND SQUASH PRIVACY POLICY

Last update: December 2018

This policy sets out how England Squash Limited (registered number 02411107 whose registered office is at National Squash Centre, Rowsley Street, Manchester M11 3FF) (“England Squash”, “we”, “us” or “our”) collects and uses any personal data we collect or receive about you, why we collect and use your personal data, who we might share this information with and your rights in relation to your personal data.

GDPR”) and all other laws relevant to the handling of your personal data. We are the data controller for the purposes of GDPR (meaning that we are responsible for deciding how your personal data is used).

When we refer to “personal data”, we are referring to any information which can directly or indirectly identify you, as explained more fully below.

WHAT PERSONAL DATA WE COLLECT ABOUT YOU (OR RECEIVE FROM THIRD PARTIES)

  • Information that you provide to us – this may include any of the following types of personal data which you provide to us when you sign-up to be an England Squash member, when you enter a tournament, enquire about a coaching or referee course or otherwise when you communicate or interact directly with us:
    • Identity Data - first name, last name, gender, images of you, username or other user identifier, date of birth, nationality;
    • Contact Data – your phone numbers, email address and postal address;
    • Financial Data – bank or payment card details and details of any purchases you make through England Squash; and
    • Profile Data – you may provide feedback to England Squash through surveys or feedback forms and indicate your preferences to receiving marketing (from us or third parties).
  • Information that we collect about you – when you visit the England Squash website we automatically collect the following types of personal data, using cookies or other similar 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; and
    • Usage Data – this includes information about how you use the England Squash website, such as click throughs, time spent on page, download errors.
      Please review our Cookies Policy for further information.
  • Information that we receive about you from others – we may receive information about you when you use our connected platforms (such as the Club Locker platform referred to below) or from other relevant third parties, including your squash club or your county (provided in each case that the collection, transfer to, and use by, England Squash is lawful). The information which we collect from these third parties may include any or all of the above types of information. 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 (such as demographic data). This may have originally generated from your personal data but is not treated as personal data under GDPR (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.

Special category data - sometimes we may ask you to provide the following types of personal data, which are seen as more sensitive and are therefore afforded greater protection under GDPR. Prior to collecting and using any such data, we will obtain explicit consent from you (unless we have another legal basis for collecting and using this information) and will only use this data for the following purposes (or such other purposes as are explained to you at the time of collection):

  • Ethnicity data - this will be used to identify and keep under review equality of opportunity within England Squash and (anonymously) for statistical and reporting purposes.
  • Disability data - this will be used to identify and keep under review equality of opportunity within England Squash and (anonymously) for statistical and reporting purposes.
  • Injuries and other medical data - this may be collected by us directly from you, your county or via your club e.g. through a tournament withdrawal form. It will be used to assist with tournament results and rankings information and (anonymously) for statistical and reporting purposes.
  • Anti-doping related data - if you are an elite player who is required to participate in doping control procedures undertaken by a doping control officer appointed by UK Sport or England Squash, the results of such procedures may be used in results management, including associated disciplinary hearings, appeals and adjudications.
  • Criminal records data - we are registered with the Disclosure and Barring Service (DBS) to assist it in ensuring that those who take up England Squash appointments do not pose a risk to the children in our care. We may therefore process criminal records data disclosed by the DBS. This will be processed in accordance with the DBS’s Code of Practice for Registered Persons.

WHY WE USE YOUR DATA

We have set out in the table below, the purposes for using your personal data and the legal basis for doing so:

Purpose

Types of Data

Lawful basis

To register you as an England Squash member

Identity, Contact, Financial

Performance of a contract with you

To register you for a coaching or referee course

Identity, Contact, Financial

Performance of a contract with you

For internal administration and record keeping purposes

All

Performance of a contract with you

Necessary to comply with a legal obligation

Necessary for our legitimate interests (for effective business administration and service provision)

To perform any services you have requested (such as providing you with the benefits of England Squash membership or providing you with information you have asked for)

Identity, Contact, Financial

Performance of a contract with you

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 you

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 you

Necessary for our legitimate interests (to ensure our members and users are informed and satisfied with our service)

To enable us to process payments which you make, or your club makes on your behalf

Identity, Contact, Financial

Performance of a contract with you

To allow us to administer squash and squash 57 tournaments, including to assist with the running of tournaments, tournament entry and processing of results and rankings information.

Identity, Contact, Financial

Performance of a contract with you

Necessary for our legitimate interests (for efficiently managing tournaments and for the general development of the sports of squash and squash 57)

To promote squash and squash 57 events

Identity

Necessary for our legitimate interests (to improve attendance at events and develop our business generally)

Issuing coach and referee qualifications and managing referee appointments

Identity, Contact, Financial

Performance of a contract with you

To contact you about squash and squash 57 events, offers and opportunities available from England Squash

Identity, Contact, Profile

Necessary for our legitimate interests (to develop our business, including our events, products and services and to increase the profile of England Squash)

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 improve and personalise your experience of the England Squash website by delivering more relevant content and advertising and to ensure that the website is delivered to you in the most effective way possible

Identity, Contact, Profile, Technical, Usage

Necessary for our legitimate interests (to develop our business, improve our website and overall user experience and inform our marketing strategy)

To administer the England Squash website, including website trouble shooting, testing and analysis and to enable you to participate in interactive features of our website

All

Performance of a contract with you

Necessary for our legitimate interests (to ensure that our website is fully functional and operating in the most effective way for you)

To provide you with access to senior England rankings data provided to you through the Squash Levels website accessible through your England Squash member portal

Identity, Contact, Profile, Technical, Usage

Performance of a contract with you

England Squash is collaborating with US Squash in relation to the “Club Locker” platform (through a joint venture established in the United States). This collaboration will greatly improve the service that England Squash delivers to clubs and members. The Club Locker platform will offer various services and tools to players and clubs, including tournament and league management and rankings information. We may process your personal data on the Club Locker platform, strictly for the purposes of delivering to you the services offered by this platform and for internal England Squash administrative purposes.

All

Necessary for our legitimate interests (namely to facilitate the effective administration of squash and squash 57 at a national, county and club level)

To verify your identity and detect fraud and security issues

All

Necessary for our legitimate interests (to prevent and detect fraudulent activity, security incidents and criminal activity)

To enable you to participate in prize competitions, prize draws or complete a survey

Identity, Contact, Profile, Technical, Usage

Necessary for our legitimate interests (to develop our business, promote new products and services, obtain feedback from customers and users to improve our services)

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.

HOW LONG DO WE KEEP YOUR DATA FOR?

We will keep your data for as long as you are an England Squash member and/or where you are still happy to hear from us about our latest news, products and services. Once you no longer wish to be engaged with England Squash we may still need to keep hold of your 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). In such circumstances, we will only retain the minimum amount of data necessary for such reason.

THIRD PARTY WEBSITE LINKS

Please note that the England Squash website 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. England Squash 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.

INTERNATIONAL TRANSFERS OF YOUR DATA

Please be aware that the Club Locker platform (referred to above) is based in the United States and as such, personal data processed on the Club Locker platform will be transferred to, and processed on servers located in, the United States. England Squash will ensure that personal data processed through the Club Locker platform is treated fairly and lawfully in all respects (including putting in place all necessary safeguards for such transfer).

In the future, England Squash may need to transfer your personal information to other countries outside of the European Economic Area ("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 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 information 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.

DISCLOSURE OF YOUR PERSONAL INFORMATION

We may disclose your personal information for the following purposes:

  • We may disclose your personal information to our county associations, clubs, coaches, tournament organisers, agents, sub-contractors and consultants (including our consultant who manages referee appointments, marketing agencies, web developers, project consultants and finance agencies) who will process it strictly on our behalf for the purposes set out above.
  • We may disclose your personal information to US Squash for the purpose of administering the Club Locker platform referred to above. Further, we may disclose your personal information to Squash Levels for the purposes of giving you access to senior England squash rankings data.
  • Details of your performance in events, including images and/or video of you, may be published on our website and shared with certain third parties and be available to view by the general public. This information may include your date of birth because this uniquely identifies you and also allows event organisers to ensure that you are eligible. If you have opted in to the Club Locker ranking system, your name, date of birth (or age group category if you are a junior member) and county will be publicly available for ranking purposes. If you wish to opt out of the Club Locker ranking system at any time please opt-out using the process referred to below.
  • 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 you are an elite player, we may also be required to share your personal data with third party disciplinary panels, and anti-doping bodies.

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.

WHERE WE STORE YOUR DATA

Save in circumstances where your data is being processed through the Club Locker platform (as referred to above), we will store your data on UK servers and will ensure that such data is held securely in accordance with good industry standards. Where we have given you a password to access a part of the England Squash website 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 England Squash 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.

CHANGES TO OUR PRIVACY POLICY

If we amend our Privacy Policy, it will be published on the England Squash website so please check the website 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.

YOUR RIGHTS

In certain situations, you are entitled to:

  • access a copy of your personal data;
  • 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 if you are concerned about the way in which we are handling your personal data.

HOW TO OPT-OUT

You can opt-out of any third-party marketing that you have previously opted into (or any England Squash 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.

CONTACT US

If at any time you wish to get in touch with us, whether that is to exercise your rights or otherwise, please contact:

Email: enquiries@englandsquash.com.

Please write to us at: Louise Perry, England Squash Limited, National Squash Centre, Rowsley Street, Manchester M11 3FF

Telephone: 0161 231 4499