Website Privacy Policy
Last updated on 7 March 2021


Thank you for choosing to be part of our community at SportFin limited. We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy notice or our practices with regard to your personal information, please contact us at privacy@sportfin.io.

Introduction
Important information and who we are
Welcome to Sportfin Limited’s Privacy and Data Protection Policy (“Privacy Policy”).
At Sportfin Limited (“we”, “us”, or “our”) we are committed to protecting and respecting your privacy and Personal Data in compliance with the United Kingdom General Data Protection Regulation (“GDPR”), the Data Protection Act 2018 and all other mandatory laws and regulations of the United Kingdom.
This Privacy Policy explains how we collect, process and keep your data safe. The Privacy Policy will tell you about your privacy rights, how the law protects you, and inform our employees and staff members of all their obligations and protocols when processing data.
The individuals from which we may gather and use data can include:
This Privacy Policy applies to all our employees and staff members and all Personal Data processed at any time by us.

Who is Your Data Controller and Data Protection Officer
Sportfin Limited is your Data Controller and responsible for your Personal Data.
We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights surrounding your Personal Data please contact the DPO using the details set out below:
Full name: Kyran Parker Email address: privacy@sportfin.io Postal address: Innovate Northumbria: Incubator, 115 New Bridge Street, Newcastle Upon Tyne, NE1 8ST, United Kingdom
You have the right to make a complaint at any time to the Information Commissioner’s Office (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.
Processing Data on Behalf of a Controller and Processors’ responsibility to you
In discharging our responsibilities as a Data Controller we have employees who will deal with your data on our behalf (known as “Processors”). Therefore, the responsibilities described below may be assigned to an individual, or may be taken to apply to the organisation as a whole. The Data Controller and our Processors have the following responsibilities:

LEGAL BASIS FOR DATA COLLECTION
Types of Data / Privacy Policy Scope
“Personal Data” means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together below. Not all of the following types of data will necessarily be collected from you but this is the full scope of data that we collect and when we collect it from you:
  • Profile/Identity Data: This is data relating to your first name, last name, gender, date of birth.
  • Contact Data: This is data relating to your phone number, addresses, email addresses, phone numbers.
  • Transactional Data: This is information of details and records of all payments you have made for our services or products.

We also collect, use and share Aggregated Data such as We also collect use and share Aggregated Data such as sport participation rates, sport volunteering rates and locations of deprivation information.. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.
We may also aggregate data to enable research or analysis so that we can better understand and serve you and others. For example, we may conduct research on your demographics and usage. Although this aggregated data may be based in part on Personal Data, it does not identify you personally. We may share this type of anonymous data with others, including service providers, our affiliates, agents and current and prospective business partners.
For the purposes of our business we also collect what is known under the GDPR as special categories of Personal Data. We collect the following types of special Personal Data:
Demographic Data: Information about gender, biological sex, race or ethnicity, occupation, disability and religious beliefs.
In order to collect this special kind of data we need enhanced legal justifications beyond the ordinary legal justifications under the GDPR. We explain which justifications we rely on in paragraph 2.2 below.
The Legal Basis for Collecting That Data
There are a number of justifiable reasons under the GDPR that allow collection and processing of Personal Data. The main avenues we rely on are:
  • “Consent”: Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy to receive email newsletters from us, or ‘opt in’ to a service.
  • “Contractual Obligations”: We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service.
  • “Legal Compliance”: We’re required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions.
  • •“Legitimate Interest”: We might need to collect certain information from you to be able to meet our legitimate interests - this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests. Examples could be your address, so that we know where to deliver something to, or your name, so that we have a record of who to contact moving forwards.
For the special categories of data that we collect, the enhanced legal justification we rely on is:
  • (a) the data subject has given explicit consent to the processing of such Personal Data for one or more specified purposes (“Explicit Consent”)

HOW WE USE YOUR PERSONAL DATA
Our Uses
We will only use your Personal Data when the law allows us to. Set out below is a table containing the different types of Personal Data we collect and the lawful basis for processing that data. Please refer to section 2.2 for more information on the lawful basis listed in the table below.
Examples provided in the table below are indicative in nature and the purposes for which we use your data may be broader than described but we will never process your data without a legal basis for doing so and it is for a related purpose. For further inquiries please contact our Data Protection Officer.
Activity Type of Data Legal Justification Lawful Basis for Processing Data
When a user signs up, we collect profile and identity data to allow the user to effectively use our platform, and for the purposes of impact reporting. Profile/Identity Data Explicit Consent We need to process this data to allow users full access to our platform functionalities, and to be able to effectively provide impact reporting services to the sport clubs on our platform.
When a user signs up, we collect email information from them. Contact Data Explicit Consent We need to collect contact information to manage user profile-related queries and issues.
When a user purchases products/services on our platform, we collect transactional data. Transactional Data Explicit Consent We need this data to manage queries/issues related to transactions made by users on our platform.
Marketing and Content Updates
You will receive marketing and new content communications from us if you have created an account and chosen to opt into receiving those communications. From time to time we may make suggestions and recommendations to you about goods or services that may be of interest to you.
Change of Purpose
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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact our Data Protection Officer.
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.
Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

YOUR RIGHTS AND HOW YOU ARE PROTECTED BY US
What Control Do I Have Over Sportfin Limited’s Use Of My Personal Data?
You may delete your account at any time – this will remove your account page from our systems and our related software.
We guarantee this will delete all stored data.
Your account information will be protected by a password for your privacy and security. You need to prevent unauthorized access to your account and personal information by selecting and protecting your password appropriately and limiting access to your computer or device and by signing off after you have finished accessing your account.
You can access information associated with your account by logging into your account you created with us.
Your account information will be protected by a password for your privacy and security. You need to prevent unauthorized access to your account and personal information by selecting and protecting your password appropriately and limiting access to your computer or device and by signing off after you have finished accessing your account.
California Privacy Rights: Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to privacy@sportfin.io.
How Does Sportfin Limited Protect Customers' Personal Data?
We are concerned with keeping your data secure and protecting it from inappropriate disclosure. We implement a variety of security measures to ensure the security of your Personal Data on our systems, including We implement certain cyber-security measures to ensure the security of your Personal Data on our systems, particularly in relation to protection of personal/identity based data and financial information (which is managed by our partners - Stripe). . Any Personal Data collected by us is only accessible by a limited number of employees who have special access rights to such systems and are bound by obligations of confidentiality. If and when we use subcontractors to store your data, we will not relinquish control of your Personal Data or expose it to security risks that would not have arisen had the data remained in our possession. However, unfortunately no transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under the control of Sportfin Limited to intercept or access transmissions or private communications unlawfully. While we strive to protect your Personal Data, we cannot ensure or warrant the security of any Personal Data you transmit to us. Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us.
Opting Out Of Marketing Promotions
You can ask us to stop sending you marketing messages at any time by Email us at privacy@sportfin.io to opt out.
Where you opt out of receiving these marketing messages, we will continue to retain other Personal Data provided to us as a result of interactions with us not related to your marketing preferences.
How to Request your Data and the Process for Obtaining it
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, if your request is clearly unfounded, we could refuse to comply with your request.
We may need to request specific information from you to help us confirm your identity and ensure you have the 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.

YOUR DATA AND THIRD PARTIES
Will We Share Your Data With Third Parties?
We may share non-Personal Data with third parties. We may share your Personal Data with subcontractors or affiliates (subject to confidentiality obligations to use it only for the purposes for which we disclose it to them and pursuant to our instructions).
We may also share Personal Data with interested parties in the event that Sportfin Limited anticipates a change in control or the acquisition of all or part of our business or assets or with interested parties in connection with the licensing of our technology.
If Sportfin Limited is sold or makes a sale or transfer, we may, in our sole discretion, transfer, sell or assign your Personal Data to a third party as part of or in connection with that transaction. Upon such transfer, the Privacy Policy of the acquiring entity may govern the further use of your Personal Data. In all other situations your data will still remain protected in accordance with this Privacy Policy (as amended from time to time).
We may share your Personal Data at any time if required for legal reasons or in order to enforce our terms or this Privacy Policy.
Third-Party Links
This Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy policy of every website you visit.

HOW LONG WILL WE RETAIN YOUR DATA FOR?
We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your Personal Data for a longer period than usual in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

AGE LIMIT FOR OUR USERS
You must not use Sportfin Limited unless you are aged 18 or older. If you are under 18 and you access Sportfin Limited by lying about your age, you must immediately stop using Sportfin Limited.
This website is not intended to be used by anyone under the age of 18, although accounts for children can be managed by their parents and/or legal guardians (after having provided explicit consent that they are the parent or legal guardian of the specific child and that they consent for the child’s data to be used for the purposes stated above).

INTERNATIONAL TRANSFER OF DATA
Your information may be stored and processed in countries and/or jurisdictions outside the UK, where Sportfin Limited has facilities. We are currently storing data in the UK.

NOTIFICATION OF CHANGES AND ACCEPTANCE OF POLICY
We keep our Privacy Policy under review and will place any updates on this webpage. This version is dated 7 March 2022. By using Sportfin Limited, you consent to the collection and use of data by us as set out in this Privacy Policy. Continued access or use of Sportfin Limited will constitute your express acceptance of any modifications to this Privacy Policy.

INTERPRETATION
All uses of the word "including" mean "including but not limited to" and the enumerated examples are not intended to in any way limit the term which they serve to illustrate. Any email addresses set out in this policy may be used solely for the purpose for which they are stated to be provided, and any unrelated correspondence will be ignored. Unless otherwise required by law, we reserve the right to not respond to emails, even if they relate to a legitimate subject matter for which we have provided an email address. As a matter of common sense, you are more likely to get a reply if your request or question is polite, reasonable and there is no relatively obvious other way to deal with or answer your concern or question (e.g. FAQs, other areas of our website etc.).
Our staff are not authorised to contract on behalf of Sportfin Limited, waive rights or make representations (whether contractual or otherwise). If anything contained in an email from a Sportfin Limited address contradicts anything in this policy, our terms or any official public announcement on our website, or is inconsistent with or amounts to a waiver of any Sportfin Limited rights, the email content will be read down to grant precedence to the latter. The only exception to this is genuine correspondence expressed to be from the Sportfin Limited legal department.

TERMS OF USE
Please also see our Terms of Use which set out the terms, disclaimers, and limitations of liability governing your use of Sportfin Limited.