Last updated: February 11th 2021
1. What does this notice cover?
This notice describes how [SportsTribal Ltd] (“SportsTribal“, “we“, “us” or “our“) processes your personal data. It also describes your data protection rights, including a right to object to some of the processing which SportsTribal carries out. More information about your rights, and how to exercise them, is set out in the “Your choices and rights” section.
This notice applies to users of the SportsTribal website and apps (the “platform”). The data processing described in this notice may be limited as required by applicable law.
We may also provide you with additional information when we collect personal data, where we feel it would be helpful to provide relevant and timely information.
2. What personal data we collect
Information that you share with us
We collect the following information about you when you visit our platform, subscribe to our service or contact us:
– information to identify you – such as your name, date of birth, home address and contact details;
– information necessary to establish and access your SportsTribal account such as your email address, username and password;
– information related to the browser or device you use to access our platform;
– payment information, including billing address and credit card details, where you subscribe to our services;
– your marketing preferences including any consents you have given us;
– the content of communications you send us;
– when you participate in user feedback surveys, we may collect your name, e-mail address and mobile phone number.
We collect most of this information from you directly when you subscribe to our services or otherwise interact with our platform. We also obtain the following information about you from our partners:
Information from your online interactions
We collect the following information from your interaction with the Services:
– how you access the Services and the devices that you use to access the Services. This includes collecting unique online identifiers such as IP address and 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 Services;
– information about how you use the Services, including but not limited to your video consumption and playback (what you watch, how long you watch it for and when), sign-in and sign-out, playback error and browsing information;
– information about how you engage with our online marketing; including information about whether our marketing is delivered to you and how you interact with it; and
– any e-mail communications, including attachments, which you send to us.
Third parties or publicly available sources
We may receive personal information about you from various third parties as set out below:
– if you log into the Services through a third-party account such as Facebook, we will collect certain information relating to your account with those third parties including your name, profile image, age group, gender and other information available on your public profile. You can manage the data which is shared by such third parties with us by amending your preferences through using the privacy settings which these third parties provide on their platforms;
– technical data from the following parties:
– analytics providers based inside and outside the EU, such as Google (Google Analytics);
– advertising networks based inside and outside the EU, such as SpotX, Magnite, Axiom, Freewheel, Pubmatic, EMX, StackAdapt, Meta and Google Ad Manager;
– data management platform providers based inside and outside the EU, such as Red Bee Media;
For further information about how each of these parties collect and use your data, please see the ‘Third-party advertising companies’ section below;
– identity and contact data from data brokers, aggregators and publicly available sources; and
– third parties that provide certain services to us within the Services, for example, facilitating and administering customer feedback forms, newsletter subscriptions and competitions.
3. Why we collect, use and store this personal data
We collect, use and store your personal data for the reasons set out below.
To fulfil a contract, or take steps linked to a contract, that we have with you. This includes:
– taking payments;
– communicating with you;
– providing customer service; and
– administering competitions and providing customer services.
As required to conduct our business and pursue our legitimate interests, in particular:
– we will use your information to provide the SportsTribal products and services you have requested, and respond to any comments or complaints you may send us;
– we monitor use of our platform to help us monitor, improve and protect our services;
– we use information you provide to personalise our services for you;
– if you provide a credit or debit card as payment, this will be processed by third parties to check the validity of the sort code, account number and card number you submit in order to prevent fraud;
– we use information you provide as well as information which we have collect about you to investigate any complaints received from you, or from others, about our platform, products or services;
– we will use data in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation); and
– we use data of some individuals to invite them to take part in market research.
Where you give us consent:
– we will send you direct marketing in relation to our relevant products and services[, or other products and services provided by our affiliates and carefully selected partners.]
– we place cookies and use similar technologies in accordance with our Cookies section below and the information provided to you when those technologies are used
– on other occasions where we ask you for consent, we will use the data for the purpose which we explain at that time.
For purposes which are required by law:
– In response to requests by government or law enforcement authorities conducting an investigation.
Withdrawing consent or otherwise objecting to direct marketing
Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests. You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by following the instructions in the communication where this is an electronic message, or by contacting us using the details set out below.
What are cookies?
We also use other forms of technology such as pixel tags or SDKs which serve a similar purpose to cookies and which allow us to monitor and improve our platform. When we talk about cookies, this term includes these similar technologies.
What cookies do we use and what information to they collect?
– Strictly Necessary cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.
– Measurement and Performance cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.
– Advertising and Targeting cookies: these cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.. Please see the “Third Parties” section below for more details.
– Content Personalisation: Content personalisation cookies (and similar technologies) allow us to select and deliver content for you to ensure our services are most relevant to your interests and provide the best experience for you. This does not include personalisation of advertising. You can choose whether to allow the setting of these cookies with the “Content Personalisation” toggle above. IAB TCF Choices: Below you can customise how IAB Framework Participants may use your personal data.
– Social Media cookies: These cookies are set by a range of social media services that we have added to the site to enable you to share our content with your friends and networks. They are capable of tracking your browser across other sites and building up a profile of your interests. This may impact the content and messages you see on other websites you visit. If you do not allow these cookies you may not be able to use or see these sharing tools.
How do you manage these technologies?
If you want to delete any cookies that are already on your device, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies.
To manage your cookie consent preferences, please click Manage Preferences link below.
5. How we share your personal data
We share information with third-party service providers to facilitate or to provide certain services on our behalf. This will include:
IT infrastructure companies that facilitate our provision of the Services to you;
third parties who provide first level customer support on our behalf such as Zendesk who assist us in providing customer services;
IT support service providers;
other third-party service providers, for the purpose of providing or tracking our customers’ use of the Services.
These companies are authorised to use your personal information only as necessary to provide these services to us.
Personal data will also be shared with third party service providers, who will process it on our behalf for the purposes identified above. In particular, we use third party providers of website hosting, maintenance, advertising, analytics and marketing services.
In the event that SportsTribal is sold or integrated with another business, your details may be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new owners of the business.
In the event that personal data is transferred outside of the UK or the EEA to an organisation in a country which is not subject to an adequacy decision by the EU Commission or considered adequate as determined by applicable data protection laws, we will take steps to ensure your personal information is adequately protected (e.g. by way EU Commission approved Standard Contractual Clauses or a vendor’s Processor Binding Corporate Rules or by relying on such other data transfer mechanisms as available under applicable data protection laws). A copy of the relevant mechanism can be obtained for your review on request by using the contact details below.
6. Your choices and rights
You have the right to ask us for a copy of your personal data; to correct, delete or restrict processing of your personal data; and to obtain the personal data you provide in a structured, machine readable format. In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement).
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law or have compelling legitimate interests to keep. If you have unresolved concerns, you have the right to complain to a data protection authority where you live, work or believe a breach has taken place. In the UK this is the Information Commissioner’s Office (the “ICO”).
Data that is mandatory is indicated on relevant forms that you complete. Where provision of data is mandatory, if relevant data is not provided, then we will not be able to fulfil your requests to register, make a purchase or otherwise engage with SportsTribal. All other provision of your information is optional.
7. How long we retain your personal data
Where we process registration data, we do this for [as long as you are an active customer of SportsTribal and for 2 years after this.
Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data so that we can respect your request in future.
Where we process personal data for site security purposes, we retain it for 14 months.
Where we process personal data in connection with performing a contract, we keep the data for 6 years from your last interaction with us.
8. Updates to this privacy notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
9. Contact us
The data controller for your personal data will be [SportsTribal Ltd].
If you have questions about this privacy notice or wish to contact us for any reason in relation to our personal data processing, please contact us at [email protected].