Privacy Policy
  
THINKING SPORTS SOLUTIONS LIMITED

PRIVACY NOTICE


1. INTRODUCTION

1.1 This privacy notice (Privacy Notice) sets out the ways in which we, Thinking Sports Solutions
Limited (we, us, our), collect and use your personal data (your personal information) in connection
with our business, including via our website, which is accessible through the following hyperlinks:
http://thinking-sports.com and http://tslive.homesteadcloud.com. It also explains what rights you
have to access or change your personal data.

1.2 Our website is not intended for children. We do not knowingly collect or maintain the personal
information of children under the age of 13. If you are under the age of 13, please do not access
our website at any time or in any manner. We will take appropriate steps to delete the personal
information of persons under the age of 13.

2. ABOUT US


2.1 We are a company registered in England under company number 10057130, with our registered
address as set out below.


2.2
You can contact us as follows:

FAO: Peter Lamb, Director


Address: Thinking Sports Solutions Limited, 36 Broomfield, Bells Yew Green, Tunbridge
Wells, Kent, TN3 9AF


Telephone: (+44) 7942 241 850


3. INFORMATION WE MAY COLLECT ABOUT YOU


3.1
Information that you provide to us.

3.1.1
We will collect any information that you provide to us when you:

(a) make an enquiry, provide feedback or make a complaint over the phone, by
     email or on our website;
(b) submit correspondence to us by post, email or via our website;
(c) order products or services from our website;
(d) subscribe to our newsletter and mailing lists;
(e) fill in a form, conduct a search, respond to surveys, participate in promotions
     or use any other features of the website;
(f) register to and/or attend our events;
(g) submit a CV;
(h) submit an application to a job vacancy;
(i) ‘follow’, ‘like’, post to or interact with our social media accounts, including
    Facebook, Twitter and LinkedIn; and
(j) interact with us at trade shows and events.


3.1.2 The information you provide to us will include (depending on the circumstances):


(a) Identity and contact data: title, names, addresses, email addresses and phone
numbers;


(b) Profile data: if you’re registering for to use our service you may also provide
certain information such as your job title/position or language preference, and
details of any clubs, teams or organisations that you may work with;


(c) Financial Data: If you are purchasing services, you will also provide payment
details, which may include billing addresses, credit/debit card details and bank
account details;


(d) Employment and background data: If you are submitting a job application,
you may also provide additional information about your academic and work
history, qualifications, skills, projects and research that you are involved in,
references, proof of your entitlement to work in the UK, your national
insurance number, your passport or other identity document details, and any
other such similar information that you may provide to us;


(e) Survey data: from time to time we might ask if you would be willing to
participate in our surveys; if you agree, we will also collect any information
that you provide as part of that survey; and


(f) Sensitive information: If you are submitting a job application, you may
provide information about your race or ethnicity, religious beliefs, sexual
orientation, health and whether or not you have any disability.


3.1.3 Information we collect about you:


(a) Information contained in correspondence: We will collect any information
contained in any correspondence between us. For example, if you contact us
using a query button on our website or by email or telephone, we may keep a
record of that correspondence;


(b) Website usage data: We will collect information about your interactions with
the website, including information such as login data, IP address, page views,
searches, requests, pre-approvals, confirmations, and other actions on the
website;


(c) Technical data: We will also collect certain information about how you use our
website and the device that you use to access our website. This information
may be collected by a third-party website analytics service provider on our
behalf and/or may be collected using cookies or similar technologies. For more
information on cookies please read the COOKIES section below; and

(d) “Special categories” of particularly sensitive personal information require
higher levels of protection. We need to have further justification for collecting,
storing and using this type of personal information. We have in place
appropriate safeguards which we are required by law to maintain when
processing such data. We process special categories of personal information
where it is needed for reasons of substantial public interest for equal
opportunities monitoring.


3.2 Information we receive from third parties


3.2.1 In certain circumstances, we will receive information about you from third parties. For
example:


(a) Employers, recruitment agencies and referees: if you are a job applicant we
may contact your recruiter, current and former employers and/or referees,
who may be based inside or outside the EU, to provide information about you
and your application;


(b) Service providers: we may collect personal information from our website
developer, IT support provider and payment services providers;


(c) Publicly available sources: we currently use publicly available sources such as
Companies House, for instance to carry out identity and compliance checks.


3.2.2 We might also receive information about you from third parties if you have indicated
to such third party that you would like to hear from us.


4. HOW WE USE INFORMATION ABOUT YOU AND RECIPIENTS OF YOUR INFORMATION


4.1 We will use your information for the purposes listed below either on the basis of:
4.1.1 performance of your contract with us and the provision of our services to you;
4.1.2 your consent (where we request it);
4.1.3 where we need to comply with a legal or regulatory obligation; or
4.1.4 our legitimate interests or those of a third party (see paragraph 4.3 below).
4.2 We use your information for the following purposes:
4.2.1 To provide access to our website: to provide you with access to our website in a
manner convenient and optimal and with personalised content relevant to you
including sharing your information with our website hosts and developers(on the basis
of our legitimate interest to ensure our website is presented in an effective and
optimal manner);


4.2.2 To register your account: when you sign up to use or purchase our services, we will
use the details provided to us (on the basis of performing our contract with you);


4.2.3 Relationship management: to manage our relationship with you, which will include
notifying you about changes to our terms of use or privacy notice, and asking you to
leave a review or take a survey (on the basis of performing our contract with you, to
comply with our legal obligations and on the basis of our legitimate interests to keep
our records updated and study how our website and services are used);


4.2.4 User and customer support: to provide customer service and support (on the basis of
our contract with you or on the basis of our legitimate interests to provide you with
customer service), deal with enquiries or complaints about the website and share your
information with our website developer, IT support provider, as necessary to provide
customer support (on the basis of our legitimate interest in providing the correct
products and services to our website users and to comply with our legal obligations);


4.2.5 Prize draws, competitions and surveys: to enable you to take part in prize draws,
competitions and surveys (on the basis of performing our contract with you and our
legitimate interest in studying how our website and services are used, to develop them
and grow our business);


4.2.6 Recruitment: to process any job applications you submit to us, whether directly or via
an agent or recruiter including sharing this with our third party recruitment agency (on
the basis of our legitimate interest to recruit new employees or contractors);


4.2.7 Marketing: to keep in contact with you about our news, events, new service or website
features that we believe may interest you, provided that we have the requisite
permission to do so (either on the basis of your consent where we have requested it,
or our legitimate interests to provide you with marketing communications where we
may lawfully do so);


4.2.8 Advertising: to deliver relevant website content and advertisements to you and
measure or understand the effectiveness of the advertising we serve to you (on the
basis of our legitimate interests in studying how our services are used, to develop
them, to grow our business and to inform our marketing strategy);


4.2.9 Social media interactions: to interact with users on social media platforms including
Facebook,Twitter and LinkedIn, for example, responding to comments and messages,
posting, ‘retweeting’ and ‘liking’ posts (on the basis of our legitimate interest in
promoting our brand and communicating with interested individuals);


4.2.10 Analytics: to use data analytics to improve our website, products/services, marketing,
customer relationships and experiences (on the basis of our legitimate interests in
defining types of customers for our website and services, to keep our website updated
and relevant, to develop our business and to inform our marketing strategy);


4.2.11 Fraud and unlawful activity detection: to protect, investigate, and deter against
fraudulent, unauthorised, or illegal activity, including identity fraud (on the basis of our
legitimate interests to operate a safe and lawful business or where we have a legal
obligation to do so); and


4.2.12 Compliance with policies, procedures and laws: to enable us to comply with our
policies and procedures and enforce our legal rights, or to protect the rights, property
or safety of our employees and share your information with our technical and legal
advisors (on the basis of our legitimate interests to operate a safe and lawful business
or where we have a legal obligation to do so).


4.3 As outlined above, in certain circumstances we may use your personal information to pursue
legitimate interests of our own or those of third parties. Where we refer to using your information
on the basis of our “legitimate interests”, we mean our legitimate business interests in conducting
and managing our business and our relationship with you, including the legitimate interests
indicated in paragraph 4.2.


4.4 Where we use your information for our legitimate interests, we make sure that we take into
account any potential impact that such use may have on you. Our legitimate interests don’t
automatically override yours and we won’t use your information if we believe your interests
should override ours unless we have other grounds to do so (such as your consent or a legal
obligation). If you have any concerns about our processing please refer to details of “Your Rights”
in paragraph 9 below.


5. WHO WE MIGHT SHARE YOUR INFORMATION WITH


5.1 In connection with the purposes and on the lawful grounds described above and in addition to the
recipients of your information as described above, we will share your personal information when
relevant with third parties such as:


5.1.1 Partners and collaborators: Sports clubs and event organisers using the Thinking
Sports Systems, Opta Sports Data London, Sports Growth Partners Minneapolis


5.1.2 Our service providers: service providers we work with to deliver our business, who are
acting as processors and provide us with:


(a) website development and hosting services based in the UK and USA;
(b) IT, system administration and security services based in the UK;
(c) marketing and advertising services (including the Google AdWords service),
analytics providers (including Google Analytics) based in the UK and USA;
(d) social media services including Facebook,Twitter and LinkedIn based in the
USA;
(e) identity verification, fraud prevention and detection services based in the UK;
(f) banking services based in the UK;
(g) legal, accountancy, auditing and insurance services and other professional
advisers based in the UK; and
(h) recruitment service providers based in the UK, USA and Australia.


5.1.3 Regulators and governmental bodies: HM Revenue & Customs, regulators,
governmental bodies and other authorities acting as processors or joint controllers
based in the United Kingdom, who require reporting of processing activities in certain
circumstances;


5.1.4 Marketing parties: any selected third party that you consent to our sharing your
information with for marketing purposes;


5.1.5 Prospective sellers and buyers of our business: any prospective seller or buyer of such
business or assets, only in the event that we decide to sell or buy any business or assets;
and

5.1.6 Other third parties (including professional advisers): any other third parties (including
legal or other advisors, regulatory authorities, courts, law enforcement agencies and
government agencies) based in the United Kingdom where necessary to enable us to
enforce our legal rights, or to protect the rights, property or safety of our employees
or where such disclosure may be permitted or required by law.


5.2 We require third parties to maintain appropriate security to protect your information from
unauthorised access or processing.


6. COOKIES


6.1 We use cookies to ensure that you get the most out of our website. Cookies are small amounts of
information in the form of text files which we store on the device you use to access our website.
Cookies allow us to monitor your use of the software and simplify your use of the website.


6.2 If you do not wish for cookies to be installed on your device, you can change the settings on your
browser or device to reject cookies. For more information about how to reject cookies using your
internet browser settings please consult the “Help” section of your internet browser (or
alternatively visit http://www.aboutcookies.org). Please note that, if you do set your Internet
browser to reject cookies, you may not be able to access all of the functions of the website.


6.3 The names of the cookies used on our website and the purposes for which these cookies are used
are set out in the table below:


Cookie Name Purpose Duration
App_Key
App_Ses_Key
[authentication]
[authentication]
[session]
[session]


6.3 Our website may contain content and links to other sites that are operated by third parties that
may also operate cookies. We don’t control these third party sites or cookies and this Privacy
Notice does not apply to them. Please consult the terms and conditions and Privacy Notice of the
relevant third party site to find out how that site collects and uses your information and to
establish whether and for what purpose they use cookies.


7. HOW WE LOOK AFTER YOUR INFORMATION AND HOW LONG WE KEEP IT FOR


7.1 We operate a policy of “privacy by design” by looking for opportunities to minimise the amount of
personal information we hold about you. We use appropriate technological and operational
security measures to protect your information against any unauthorised access or unlawful use,
such as:


7.1.1 ensuring the physical security of our offices, warehouses or other sites;


7.1.2 ensuring the physical and digital security of our equipment and devices by using
appropriate password protection;


7.1.3 maintaining a data protection policy for, and delivering data protection training to, our
employees; and



7.1.4 limiting access to your personal information to those in our company who need to use
it in the course of their work.


7.2 We will retain your information for as long as is necessary to provide you with the services that
you have requested from us or for as long as we reasonably require to retain the information for
our lawful business purposes, such as for the purposes of exercising our legal rights or where we
are permitted to do. We operate a data retention policy and look to find ways to reduce the
amount of information we hold about you and the length of time that we need to keep it. For
example,


7.2.1 we archive our email and paper correspondence regularly and destroy information
older than 6 years;


7.2.2 we retain information relating to orders, refunds and website user queries for
approximately 6 years;


7.2.3 we maintain a suppression list of email addresses of individuals who no longer wish to
be contacted by us. So that we can comply with their wishes we must store this
information permanently; and


8. INTERNATIONAL TRANSFERS OF YOUR INFORMATION


8.1 Our company is located in the UK.


8.2 Many of our external third parties are based outside the European Economic Area (EEA) so their
processing of your personal data will involve a transfer of data outside the EEA.


8.3 Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection
is afforded to it by ensuring at least one of the following transfer solutions are implemented:


(a) 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. For further details, see European Commission: Adequacy of the
protection of personal data in non-EU countries;
(b) 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. For further details, see European Commission:
Model contracts for the transfer of personal data to third countries; and
(c) Where we use providers based in the US, we may transfer data 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. For further details,
see European Commission: EU-US Privacy Shield.


8.4 A list of the countries outside of the EEA to which we may transfer your personal information is
available here


8.5 Please contact us using the contact details at the top of this Privacy Notice if you want further
information on the specific mechanism used by us when transferring your personal data out of the
EEA.


9. YOUR RIGHTS TO THE INFORMATION WE HOLD ABOUT YOU


9.1 You have certain rights in respect of the information that we hold about you, including:


9.1.1 the right to be informed of the ways in which we use your information, as we seek to
do in this Privacy Notice;


9.1.2 the right to ask us not to process your personal data for marketing purposes;


9.1.3 the right to request access to the information that we hold about you;


9.1.4 the right to request that we correct or rectify any information that we hold about you
which is out of date or incorrect;


9.1.5 the right to withdraw your consent for our use of your information in reliance of your
consent (refer to paragraph 4 above to see when we are relying on your consent),
which you can do by contacting us using any of the details at the top of this Privacy
Notice;


9.1.6 the right to object to our using your information on the basis of our legitimate interests
(refer to paragraph 4 above to see when we are relying on our legitimate interests) (or
those of a third party)) and there is something about your particular situation which
makes you want to object to processing on this ground;


9.1.7 the right to receive a copy of any information we hold about you (or request that we
transfer this to another service provider) in a structured, commonly-used, machine
readable format, in certain circumstances;


9.1.8 in certain circumstances, the right to ask us to limit or cease processing or erase
information we hold about you; and


9.1.9 the right to lodge a complaint about us to the UK Information Commissioner’s Office
(https://ico.org.uk/) as well as a right to lodge a complaint with the relevant authority
in your country of work or residence.


Please note that we may need to retain certain information for our own record-keeping and research
purposes. We may also need to send you service-related communications relating to your App user account
even when you have requested not to receive marketing communications.


9.2 How to exercise your rights


9.2.1 You may exercise your rights above by contacting us using the details in paragraph 2 of
this Privacy Notice, or in the case of preventing processing for marketing activities also
by checking certain boxes on forms that we use to collect your data to tell us that you
don’t want to be involved in.


9.2.2 You may contact us viathe details at the top of this Privacy Notice if you wish to action
any of these additional rights and we will comply with your requests unless we have a
lawful reason not to do so.


9.3 What we need from you to process your requests


9.3.1 We may need to request specific information from you to help us confirm your identity
and to enable you 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.


9.3.2 You will not have to pay a fee to access your personal data (or to exercise any of the
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 will try to respond to all legitimate requests within
one month. Occasionally it may take us longer than a month if your request is
particularly complex or you have made a number of requests. In this case, we will notify
you and keep you updated.


10. SHARING DATA DIRECTLY WITH THIRD PARTIES


10.1 You might end up providing personal information directly to third parties as a consequence of your
interactions with our website and other services offered by us. We are not responsible for how
such third parties use personal data provided by you.


10.2 Please be responsible with personal information of others when using our website and the services
available on it. We are not responsible for your misuse of personal information, or for the direct
relationship between you and others when takes place outside of the website or our services.


11. THIRD-PARTY LINKS


The website 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 website, we encourage you to read the privacy notice of every website you
visit.


12. CHANGES TO THIS PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES


12.1 We may make changes to this Privacy Notice from time to time. We will post any changes to our
site, or notify you of any material changes by e-mail.


12.2 It is important that the personal data we hold about you is accurate and current. Please keep us
informed if your personal data changes during your relationship with us by updating your profile
account information or contacting us via the contact details at the top of this Privacy Notice.

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