PRIVACY POLICY

Welcome to KickTown’s Privacy Policy!

Your personal information is important to us and we respect it. We are committed to protecting information about you and to being open with you as to what we do with the information we hold about you.

Introduction:

It is therefore important that you read this Privacy Policy (and any other Privacy Policy we may give to you) as it tells you how we look after your information when you visit our website (regardless of where you visit it from) and tells you about your rights and how the law protects you. Where we provide you with any other Privacy Policy or notice, this policy is designed to be in addition to and not in place of that other policy.

This Privacy Policy tells you how we collect and use information about you through your use of this website, including any information you may provide through this website, when you contact us, when you purchase our wristbands and other products or when you make arena bookings or use any of our other services.

Important information and who we are:

Our full name is KickTown Limited, and for the purposes of the data protection laws in the UK, we are the ‘data controller’. This means that we decide how and why the personal information you give us is used.

If you have any complaints:

If you are unhappy at any time with the way in which we have used your personal information you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO). The Information Commissioner’s Office is the authority in the UK responsible for data protection issues. If you are not in the UK but are in Europe, you can make a complaint to your local body responsible for data protection issues. These are usually known as ‘competent supervisory authorities.

Having said this, if you are unhappy with anything we do or have done we would love the opportunity to put it right so please do let us know.

If we, or you, need to change anything:

We keep this privacy policy under regular review.

This version was last updated on 10 July 2019.

It is important that the information we hold about you is up to date and correct. Please do let us know if any of your personal information changes so that we can update our records.

Other websites and links:

Our website may contain links to other websites, plug-ins and apps. Clicking on those links or enabling those connections may allow other people to collect or share information about you. We do not control anyone else’s websites and are not responsible for their privacy policies or for the content, accuracy or opinions expressed on such websites.  We do not investigate, monitor or check anyone else’s websites for accuracy or completeness and the inclusion of any linked website on or through our website does not mean we approve or endorse the linked website.

If you decide to leave this website and access anyone else’s websites, plug-ins and/or applications you do so at your own risk.  We encourage you to read the privacy policy of every website you visit.

What we collect:

The data protection laws protect ‘personal data’. Personal data means any information that we can identify an individual from.  We also sometimes refer to this as ‘personal information’.

We may collect and use lots of different types of personal information about you. To help you understand the types of information we collect and use we have grouped them together as follows:

  • Identity Data this includes your name, your title, your date of birth and your gender.
  • Contact Data this is everything which we can use to get in touch with you such as your address, your email address and your telephone numbers.
  • Financial Data this includes bank account and payment card details.
  • Transaction Data this includes details about payments to and from and what they relate to.
  • Profile Data this includes things like your username and password, your player profile(s), purchases or orders made by you, your interests, preferences, feedback and survey responses as well as any performance data linked to your account and any images, videos or other content which you upload to our website.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and other organisations and how you would like us to keep in contact with you.
  • Technical Data this includes technical things such as your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.
  • Usage Data this includes information about how you use our website, products and services.

Personal data does not include information where your identity has been removed or which is not associated with or linked to your information. This is known as anonymous data.

We also sometimes collect, use and share Aggregated Data such as statistical or demographic data. This may be used for any purpose. Aggregated Data may come from your personal data but is not considered personal data in law as it does not directly or indirectly reveal who you are. For example, we may bring together Usage Data to calculate the percentage of users accessing a specific website feature. However, if we connect Aggregated Data with your personal data so that it can identify you, we treat that data as personal data and will use it only in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes information about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Sometime the law or an agreement we have with you requires us to collect personal information, if that is the case and you don’t give us that information when we ask for it, we may not be able to perform any agreement with you or we may not be able to enter into an agreement with you (for example, to provide you with products or services that you request). In this case, we may have to cancel a product or service you have requested but we will tell you if this is the case at the time.

How we get your information:

We get your personal data in a number of ways:

  • Directly from you. You might give us personal information such as your Identity, Contact and Financial Data by filling in forms on this website, or by contacting us by post, phone, email, via our website or in some other way, when you place an order or make a booking with us or when you attend one of our arenas.
  • Automatically. As you use our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We may collect this personal data by using cookies, server logs and other similar technologies. Our cookie policy tells you more about how and why we use cookies on our website. A copy of our cookie policy can be found on our ‘Terms and Policies’ page which can be accessed here.
  • From others. We may receive personal information about you from various other people such as:
    • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Diverse Interactive Limited, Square, Amazon or WooCommerce who may be based inside or outside the EU,
    • Identity, Contact and Profile Data from other people who tag you in photos, videos or other materials uploaded to the website or from the people who operate our arenas.
    • Identity, Contact, Transaction and Technical Data from the app store from which you download our App.

What we use your information for:

We only use your personal data when the law allows us to.  We may collect and process your personal information for the following purposes:

  • Website or App account – when you sign up for an account on our website or via our App (also known as a User Account), we will need your Identity and Contact Data so that we can identify you as an account holder. You will also be asked to create Profile Data including a username and password.  Your account will also hold details of things you have bought from us and/or arena bookings you have made (Transaction Data), and any preferences that you set for your account (Marketing and Communications Data). It will also allow you to register Player Profiles, as to which see below.
  • Ordering our products or making arena bookings – we will use your Identity, Contact, Financial and Transaction Data in order to register you as a customer and to process and deliver products to you as well as for processing arena bookings. Including processing your payments. This is necessary for the purpose of performing our agreement with you.
  • Contacting us – when you contact us with an enquiry or to request information, we will use your Identity and Contact Data to respond to you.
  • Player Profiles – when you or a third party Website or App account holder registers a player profile for you, we will need your Identity, Contact and Profile Data to set up and keep track of your profile and to make sure we provide you with the best possible experience in accordance with our legitimate interests.
  • Monitoring – when you engage in any chat room, bulletin board or similar service, we may offer from time to time, or if you upload any videos, photos or other materials we will use your Identity, Contact and Profile Data to monitor how you are using these services and to contact you if we deem you to be using them inappropriately in accordance with our legitimate interests.
  • Advertising, marketing and keeping in touch – we may use your Identity, Contact, Technical, and/or Usage Data to tell you about things which we think may be of interest to you. When we do this we will only send information that is we think is relevant to your use of our services. This is necessary for our legitimate interests in growing and developing our business and promoting our products and services.  Customers may receive marketing communications from us if they have requested information from us or purchased services from us and have not opted out of receiving that marketing.  We will however ask for express consent before we share personal information with anyone else for marketing purposes.  You can ask us to stop sending marketing communications, just let us know that you no longer want these.
  • Surveys – If you choose to complete a survey that we use for research purposes we will retain the information that you provide in response to that survey. This is necessary for our legitimate interest in understanding our customers and developing our business and marketing strategy.
  • Administration – we may use your Identity, Contact and Technical Data for the purpose of protecting our business and our website, including troubleshooting, data analysis, testing and system maintenance, support, reporting and hosting of data. This is necessary for our legitimate interest in running our business, to ensure security, to prevent fraud and where we have to reorganise, sell or restructure our business, and for where we need to do so to comply with the law.
  • Website Analytics – as you navigate our website, Technical and Usage Data may be collected automatically. We do this to find out things such as the number of visitors to the various parts of the website, and to help us to improve our website. This is necessary for our legitimate interest in defining types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy.
  • Fault reporting – if you contact us to report a fault with our website, we will use the Identity and Contact Data provided for the purposes of rectifying that fault in accordance with our legitimate interests.
  • Recruitment – personal data provided for an employment opportunity will be processed so as to allow us to process and evaluate the merits of that application in accordance with our legitimate interests.

We may also use your personal information, where the law allows us to, as follows:

  • To deal with and/or respond to any enquiry or request made by you prior to entering into any contract or agreement with us or as a result of such contract or agreement.
  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where we need to comply with a legal or regulatory obligation, including the prevention of crime.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Generally we do not rely on you consenting to us using your personal information in the ways set out above other than in relation to sending someone else’s direct marketing communications to you via email or text message or where you are setting up a User Account and/or agreeing to provide your Location Data through our App. When you are using our App a separate privacy policy applies which can be found on our ‘Terms and Policies’ page which can be accessed here.

Where you tell us we can use your personal information for marketing you can change your mind at any time (withdraw consent) by updating your account preferences or by contacting us.

Where we refer to legitimate interest above, this means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we use your information for our legitimate interests. We do not use your personal information for activities where the impact on you outweighs our interests (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests and weigh these up against your rights by contacting us.

We will only use your personal data for the purposes we collected it for, unless we reasonably believe that we need to use it for another reason and that reason is compatible with the original purpose we obtained your information for. If you want to find out more about how the use of your information for the new purpose is compatible with the original purpose, please do get in touch and we would be happy to give you further details of this.   If we need to use your personal data for an unrelated purpose, we will let you know and will explain why that use is lawful.

You should be aware that we may use your personal information without telling you or asking your permission, provided this is in line with the above rules, where this is required or permitted by law.  This may include removing you from our marketing database where we have not heard from you for sometime.

Who we provide your information to:

Your personal data will only be given to those of our employees or workers that need to use it for the reason it was collected.  We will not give your personal information to anyone else except in the following circumstances:

  • On occasion, we need to hire other companies to help us to serve you better and in some of these cases we may need to share your personal information with them so they can perform the tasks we have asked them to perform, such as IT support providers, software and app developers (including Diverse Interactive Media Limited), printers, couriers and delivery services, marketing agencies, market research providers and any third parties we engage to operate any arena on our behalf.
  • Where we need to perform our agreement with you, including where you have asked us to do so or where we need to take steps to enforce any contract which may be entered into between us.
  • Where we are under a legal duty to do so in order to comply with any legal obligation.
  • In order to protect the rights, property or safety of our business, our employees and workers, customers, suppliers and others. This includes exchanging information with other companies and organisations for the purposes of fraud prevention, internet safety and credit risk reduction.
  • If we sell our business or any of its assets to a third party, in which case the information that we hold about our customers may be one of the transferred assets.
  • With other companies in the KickTown group, such as KickTown Guernsey Limited for the purposes of the effective administration of the KickTown group in accordance with our legitimate interests and where any member of the KickTown group is assisting us with the provision of our goods or services to you. 

Where someone else is using your personal information to help us provide our goods and services to you, you can rest assured that we ensure that they respect the security of your personal data and treat it in accordance with the law. We do not allow anyone else to use your information for their own purposes and only allow them to use your personal data in the ways we tell them they can.

Sending your information abroad

Some of the people we work with may be based outside the European Economic Area (“EEA”) so when they need to use or have access to your personal data this will mean your information has to be sent outside the EEA.

Whenever we transfer your personal information out of the EEA, we ensure a similar level of protection is given to it by ensuring at least one of the following safeguards is in place:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
  • Where we use providers based in the US, we may send your information to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

Please contact us if you want to know more about the specific mechanism used by us when transferring your personal data out of the EEA.

How we keep your information secure

We are committed to ensuring that your personal data is secure. In order to make sure your information is not accessed or disclosed when it shouldn’t be, we have put in place the measures which we think are suitable to safeguard and secure your information, these include physical, electronic and managerial procedures.  In addition, the access to and use of your personal data is restricted to our employees who need it to perform a specific job or task. Where your personal information is shared with anyone else in line with this policy responsible measures are used to protect your personal data.

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

You should be aware that the transmission of information over the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee its security when it is sent to our website; when you send to or enter information on to our website it is at your own risk. Once we have received your information, we will use strict measures and security features to try to prevent any unauthorised access.  We urge you to take every precaution to protect your personal data when you are on the internet which ever device you use to access it.

How long we keep your information for.

We will only keep your personal information for as long as we need it for the purpose we collected it, this includes meeting any legal, accounting, or reporting requirements we may have.

To decide how long it we keep your personal information for, we think about the amount, nature, and sensitivity of the that information, the potential risk of harm from unauthorised use or disclosure, the reason for using your personal information and whether we can achieve those purposes another way, as well as any relevant legal requirements.

For example:

  • By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for 6 years after they cease being customers for tax purposes.
  • We will retain details of your user account, player profiles, customer orders and bookings, including your personal data, for a period of 7 years from the date you close your account or delete a player profile to enable us to deal with any follow-up communications from you or to ensure that we are in possession of all relevant papers in the event of a legal claim relating to the contract between us.

In some circumstances you can ask us to delete your data: see ‘The rights you have’ below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be linked to you) for research or statistical purposes, when we do this we may use this information indefinitely without further notice to you.

The rights you have:

The law gives you a number of rights in relation to your personal information, which are set out below:

  • 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 that we hold about you and to check that we are lawfully using it.
  • Request correction of the personal data that we hold about you. This means that you can have any incomplete or inaccurate information that we hold about you corrected, although we may need to verify the accuracy of the new personal information that you provide to us.
  • Request erasure of your personal data. This means you can ask us to delete or remove personal data where there is no good reason for us continuing to have 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 used your personal data unlawfully or where we are required to delete your personal data to comply with local law. Please be aware, 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 someone else) 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 carry on using your personal data which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the use of your personal data: (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 delete 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 someone else. We will provide to you, or the person or organisation you have chosen, your personal data in a structured, commonly used, machine-readable format (such as on a disk or memory stick). Please be aware, this right only applies to certain, 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 your consent (where you have told us we can) to use your personal information. However, this will not affect the lawfulness of any use 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 tell you if this is the case at the time you withdraw your consent. You can ask us to stop sending you marketing messages at any time by following the “unsubscribe” (or similar) links on any marketing message sent to you or by contacting us at any time.  Where you opt out of receiving these marketing messages, this will not apply to personal information provided to us as a result of a purchase, product/service experience or other transactions.

If you wish to exercise any of your rights, please let us know by writing to us at the address listed at the end of this privacy policy, addressed for the attention of the data privacy manager.

You will not have to pay us anything to access your personal information or to exercise any of your other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.  Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us a bit longer if your request is particularly complicated or if you have made a number of requests. In this case, we will notify you and keep you updated.

How you can contact us

KickTown Limited

Les Palmiers, The Grange, St Peter Port, Guernsey, GY1 1RQ

Email: dataprotection@kicktownfootball.com