Privacy Policy | Sportseen

1. Introduction

1.1 Sportseen LLP is committed to with respecting and protecting your privacy.

1.2 This Privacy Policy (together the Standard Terms and Conditions for Advertisers and any other documentation appearing on our website, http//www.sportseen.tv ("the Website")) describes the type of information and data that we collect from you ("you/your") through your use of our services ("the Services") and the Website and how that information and data may be used or disclosed by us and the safeguards we use to protect such information and data.

1.3 Please read this Privacy Policy carefully to understand our policies regarding your information and data and how we, Sportseen LLP, the primary controller of the personal information and data we have collected from you, will treat such personal information or data provided to us or collected by us when you use the Services or the Website.

1.4 By using or accessing the Website or the Services, you agree to the collection, use and disclosure of your personal data and information in accordance with this Privacy Policy, which is fully compliant with the provisions of all applicable laws that concern the processing of personal data and privacy including applicable guidance and codes of practice issued by the UK’s Information Commissioner’s Office ("ICO") and including, without limitation, such legislation as (i) the General Data Protection Regulation 2018 (“GDPR”); (ii) the Privacy & Electronic Communications Regulations 2003 (“PECR”); and (iii) any other additional, implementing, derivative or related legislation adopted in the United Kingdom.

1.5 The Website and the Services may contain links to third party websites that are not covered by this Privacy Policy. We therefore ask you to review the privacy policy statements of any such third party websites and applications to understand their information practices.

1.6 This Privacy Policy may be supplemented by additional privacy statements, terms or notices and may change from time to time and your continued use of the Website or the Services is deemed acceptance by you of such changes, so please check periodically for any updates you may receive directly from us or you may find published on the Website.

1.7 Your acceptance of this Privacy Policy is deemed to occur upon your first use of the Website or acquisition of our Services. If you do not accept and agree with this Privacy Policy, you must stop using our Website immediately.

1.8 You have the right to make a complaint at any time to the ICO, the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance. It is important that the personal information and data we hold about you is accurate and current, so please keep us informed if your personal data changes during your relationship with us.

1.9 If you have any comments on this Privacy Policy, please email them to gdpr@sportseen.tv.

2. Who We Are

2.1 We work on our own behalf and on behalf of various sporting federations, our main line of business being contacting, via various media and telecommunications platforms, existing and prospective customers in relation to booking advertising space and take advantage of promotional and marketing opportunities at sports grounds and venues around the world.

2.2 Under the provisions of the GDPR, Sportseen LLP is deemed to be the 'data controller' in respect of any and all third party personal data and information and, accordingly, we are hereby providing you with the following details about us as we are required to do so under the terms of the GDPR:

- the Website address is www.sportseen.tv;

- our full company name is Sportseen LLP, which is a limited liability partnership incorporated at the laws of England and Wales and registered at Companies House in the UK under company number OC389450;

- Sportseen LLP’s registered address is 113 Upper Richmond Road, Putney, London SW15 2TL, United Kingdom, and our office phone number is +44 20 7820 5080.

- our nominated data protection representative is Tim Cotton, solicitor & legal adviser to Sportseen LLP, and he can be contacted at gdpr@sportseen.tv or directly at tjpcotton@hotmail.com.

2.3 We respect your right to privacy and will only process your personal information and data in accordance with the GDPR, for as long as the GDPR or similar legislation is in full force and effect in the United Kingdom.

3. What we may collect

3.1 Personal data or personal information means any information about an individual from which that person can be identified. It does not include any data where the identity has been removed (i.e. anonymous data).

3.2 We collect information about you in two primary ways: (1) from your input when you become a customer of ours and acquire advertising, marketing or promotional rights through the Services; and (2) through automated technologies when you view or access the Website.

3.3 The types of personal information and data that we collect from you depends on how you interact with the Website or us and the Services we actually provide to you, but the personal information and data we are likely to collate include:

contact details, such as your business name, email address, postal address, social media handle and phone number and the names, telephone numbers and email addresses of your personnel and staff;
information about your business’ products and details contained within the advertisements you will provide to us in order that we may deliver the Services on your behalf;
payment information, such as credit or debit card numbers and bank details;
comments, feedback and other information you provide to us, including information that you send to our customer support and messages, appointment inquiries and other information that you wish us to share with the sporting federations and other clients whom we represent;
technical data includes 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 the Website;
usage data including information about how you use the Website and the Services;
marketing and communications data includes your preferences in receiving marketing from us and our third parties and your communication preferences; and/or
analytics data including third-party analytics services (such as Google Analytics) to evaluate your use of the Website, compile reports on activity, collect demographic data, analyse performance metrics and collect and evaluate other information relating to the Website and internet usage. These third parties use cookies and other technologies to help analyse and provide the data. By accessing and using the Website, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy.

3.4 We do not collect any Special Categories of Personal Data (as defined in the GDPR) about you, including details 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. we do not knowingly collect information from children under the age of 13 or target the Services or the Website to children.

3.5 Depending on how you interact with us, the Website and the Services, we will use your personal data and information for the following purposes, without limitation:

to provide, activate and manage your access to and use of the Services;
to process and fulfill the Services;
to provide technical, product and other support in relation to the Services;
to enhance and improve the Services and our other products and offerings;
to respond to your requests, inquiries, comments and concerns;
to notify you about changes, updates and other announcements related to the Services, the Website, our other products and offerings and this Privacy Policy;
to provide you with promotional messages and other information about the Services, our clients and other third parties;
to invite you to participate in user testing and surveys as well as sweepstakes, competitions and similar promotions;
to identify usage trends and develop data analysis, including for purposes of research, audit, reporting and other business operations; and/or
to comply with our legal obligations, to resolve disputes or to enforce our agreements.

3.6 Under GDPR, we will ensure that your personal data is processed lawfully, fairly and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following bases applies:

a) you have given consent to the processing of your personal data for one or more specific purpose;

b) processing is necessary for the performance of a contract or agreement to which you are a party or in order to take steps at the request of you prior to entering into such a contract or agreement;

c) processing is necessary for compliance with a legal obligation to which we are subject;

d) processing is necessary to protect the vital interests of you or another natural person;

e) processing is necessary for the performance of a task carried out in the public interest; and/or

f) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party such as making or receiving payments.

3.7 If we, in the course of providing the Services to you, receive from you personal data or information in relation to another data subject, we expect you to have complete responsibility for ensuring that the contents of this Privacy Policy are brought to that data subject’s attention and you to have obtained their consent in the process.

3.8 In some instances, it may be appropriate for us to combine your data with other data or information that we may be holding about you, such as combining your name with your geographic location or your browsing or purchasing history.

4. How we may collect and use your data

Depending on how the Services are actually provided, we share personal data and information with our clients, i.e. sporting federations and their agents and representatives, sporting venue owners and their contractors, plus with banks and payment processors, IT service providers, mailing houses and shipping agents, all of whom we require to act in compliance with this Privacy Policy, the GDPR and any other appropriate confidentiality and security measures.
We use data to carry out direct B2B marketing and sales. We comply in full with the TPS (Telephone Preference Service) and CTPS (Corporate Telephone Preference Service) to prevent unwanted sales and marketing calls. We maintain a ‘Do Not Call’ list in line with Ofcom regulations.

4.3 We (or third party data processors, agents and sub-contractors acting on our behalf) may collect, store and use your personal data and information by way of different methods to collect data from and about you, including through direct interactions. You may give us your personal data and information by filling in forms via our Website or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

a) present Website content;

b) use any of the Services;

c) create an account on the Website;

d) request marketing to be sent to you;

e) enter into an agreement or contract with us;

f) enter into a competition, promotion or survey; or

g) give us some feedback.

We also receive data from GDPR compliant data providers and online resources in the public domain.

4.4 In addition to the above, we may use the data and information in the following ways:

a) to personalise your Website experience and to allow us to deliver the type of Services, content and product offerings in which you are most interested;

b) if you have opted-in to receive an email newsletter from us, to send you periodic emails. If you would no longer like to receive such emails, please refer to Clause 8 below. If you have not opted-in to receive email newsletters, you will not receive these emails. Visitors who register or participate in other site features such as marketing programmes will be given a choice whether they would like to be on our email list and receive email communications from us;

c) to present the Website content effectively to you;

d) to provide information and services that you request, including the Services;

e) to fulfil our contracts or agreements with you.

f) to provide the relevant Services to you; and

g) to notify you of any changes or amendments to the Services, your contracts or agreements with us or this Privacy Policy.

4.4 If you are already our customer, we will only contact you electronically about things similar to the Services which were previously sold to you.

4.5 If you do not want us to use your personal data as outlined herein, you should contact us at gdpr@sportseen.tv and we will delete your data from our systems. However, you acknowledge that this will limit our ability to provide the best possible Services to you.

4.6 We will only use your personal data in accordance with applicable law, including the GDPR. We agree not to do anything that we have not outlined under this Privacy Policy and we will not send you any unsolicited marketing or spam. We will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the GDPR, the PECR and any other relevant legislation.

5. Cookies

5.1 All Cookies used by and on the Website are used in accordance with current applicable law.

5.2 We use cookies to recognise you and your preferences, to improve the Website’s performance and to collect analytical information for ourselves and our business partners. Without the knowledge gained, we would not be able to provide the Services we do.

5.3 We use “session cookies” and “persistent cookies”. “Session cookies” allow us to track your actions during a single browsing session, but they do not remain on your device afterwards, while “persistent cookies” remain on your device between sessions and we use them to authenticate you and to remember your preferences. We can also use them to balance the load on our servers and improve your experience on the Website. We also may use “third party cookies”, including Google Analytics, which may help us to analyse how users use the Website and to count the number of people who use the Website. Google Analytics stores your IP address anonymously and neither Sportseen LLP nor Google associate your IP address with any personally identifiable information or data of yours.

5.4 None of the cookies employed by us are classified as “Behavioural Targeting” and, if, at any time, you wish to disable our cookies, you may do so through the settings on your browser. However, if you choose to disable or delete our cookies that will prevent certain important areas and features of the Website (and potentially the Services) from functioning properly.

6. Where we store your data and security

6.1 We may transfer your collected data to storage outside the United Kingdom and the European Economic Area (EEA). It may be processed outside the EEA to fulfil your order and to receive the Services and/or to deal with payment. If we do store or transfer data outside the UK and the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and the EEA under the GDPR. Such steps may include, but not be limited to, the use of legally binding contractual terms between us and any third parties with whom we engage. Your acceptance of this Privacy Policy is your consent to permit us to store or transfer data outside the UK and the EEA if it is necessary for us to do so.

6.2 Data security is of the utmost importance to us and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through our Website or the operation of the Services. 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 all subject to a legally-binding duty of confidentiality.

6.3 We have put in place procedures to deal with any suspected personal data breach and we will notify you and any applicable regulator of a breach where we are legally required to do so. This includes the following safeguards:

6.3.1 access to our building is restricted only to authorised persons;

6.3.2 desks and cupboards in our premises are kept locked when not in use if they hold confidential information of any kind;

6.3.3 paper documents are disposed of by shredding in a manner to ensure confidentiality;

6.3.4 we use industry standard protection electronic firewalls and encryption;

6.3.5 we employ password protection to protect all sensitive personal data;

6.3.6 we ensure our employees are trained in the importance of data security; and

6.3.7 any payments made by you will be securely encrypted.

6.4 Notwithstanding the security measures above, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to us personal data via the internet and you take the risk that any sending of that personal data is secure, subject always to us complying with our obligations under this Privacy Policy.

6.5 We will keep your personal data for as long as is necessary, which shall be a maximum of seven (7) years after our business or commercial relationship with you has ended, subject always to our compliance with the GDPR and any other legislative or regulatory requirements. We review our data retention obligations regularly.

7. Disclosing your information

7.1 Notwithstanding any other provisions of this Privacy Policy, we are entitled to disclose your information in the following cases:

7.1.1 if we want to sell our business or company, we can disclose it to the potential buyer.

7.1.2 we can disclose it if we have a legal obligation to do so or in order to protect other people's property, safety or rights;

7.1.3 we can exchange information with others to protect against fraud or credit risks.

7.2 Where any of your personal data is required for such a purpose outlined in Clause 7.1 above or elsewhere in this Privacy Policy, we will take all reasonable steps to ensure your personal data will be handled safely, securely and in accordance with your rights, our obligations and the obligations of the relevant third parties under the GDPR and applicable law.

8. Your rights

8.1 When you submit information via the Website, you may be given options to restrict our use of your data. We aim to give you controls on our use of your data, including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided.

8.2 Under the GDPR, you have the right to:

- request access to, deletion of or correction of, your personal data and information held by us, at no cost to you;

- request that your personal data be transferred to another person (data portability);

- be informed of what data processing is taking place;

- restrict or object to our processing of your personal data and information; and

- complain to a supervisory authority such as the ICO.

8.3 In the event that we use your personal data for the purposes of automated decision-making and those decisions have a legal or similar significant effect on you, you have the right to challenge to such decisions under the GDPR, requesting human intervention, expressing their own point of view and obtaining an explanation of the decision from us.

8.4 You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes.

8.5 To enforce any of the foregoing rights or if you have any other questions about our Website or this Privacy Policy, please contact us at gdpr@sportseen.tv or our nominated data protection representative and legal adviser, Tim Cotton, at tjpcotton@hotmail.com.

9. Links to other sites

Please note that our terms and conditions and our policies will not apply to other websites to which you may link from our Website. We have no control over how your personal data is collected, stored or used by such other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

10. Terms and Conditions

Please also visit our Standard Terms and Conditions for Advertiser on the Website, which establish the use, disclaimers and limitations of liability governing the use of our Website.

11. Your Consent

By using the Website and the Services, you consent to our Privacy Policy.

12. Dispute Resolution

12.1 The Parties will use their best efforts to negotiate in good faith and settle any dispute that may arise out of or relate to this Privacy Policy or any breach of it.

12.2 If any such dispute cannot be settled amicably through ordinary negotiations between the parties, then the laws of England and Wales, including the GDPR, shall be applicable for resolving any disputes and the courts of England shall have exclusive jurisdiction.

Last updated: 11th January 2021