Privacy Policy

General
- Halo Enterprises Netball Ltd, a company registered in England with company number 15256678 whose registered office is at 37 Dukes Avenue, London N10 2PX ("we", "us" and "our"), takes the privacy rights of the users of this website (the "Site"). We are the data controller and we will process your personal data in accordance with the Data Protection Act 2018, the Privacy and Electronic Communications 2003 and the General Data Protection Regulation which applies across the European Union and the United Kingdom and national laws which relate to the processing of personal data ("Data Protection Legislation").
- This privacy policy explains how we process personal data when you visit our Site or provide information to us in any other way. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
- Where we process the data of a user of our Site or someone who provides information about themselves directly to us, we will be the data controller. This policy explains how we collect and why we process data as a data controller.

Your data
- For the purposes of this privacy policy, "Your Data" means any information about you from which you are personally identifiable, including your name, age, address, email address and mobile telephone number, and other information from which you can be identified, which you (or a third party) may disclose to us, or otherwise uploaded via our Site or otherwise through your interaction with us at any time. We may create de-identified or anonymous data from personal data by excluding data components (such as your name, email address, or linkable tracking ID) that makes the data personally identifiable to you. Our use of anonymised and de-identified data is not subject to this Privacy Policy.

How we collect your data
- We may collect and process Your Data in the following circumstances:
  - whenever you visit our Site we may, with your consent, collect details of your visits including, but not limited to, traffic data, location data and other communication data and the resources you access (see section 3.2.2 below);
  - when you interact with our Site;
  - whenever you (provide Your Data on an online form on our Site;
  - whenever you provide Your Data to us when reporting a problem with our Site, making a complaint, making an enquiry or contacting us for any other reason;
  - whenever you complete one of our voluntary surveys that we use for research purposes; and
  - whenever you disclose Your Data to us, or we collect Your Data from you, in any other way, through our Site or otherwise.

- We may also collect data in the following ways:
  - IP Address - We may collect information about your device, including where available your Internet Protocol address, for reasons of fraud protection. We may also collect information about your device’s operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.
  - Cookies - A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. We use traffic log cookies to identify which pages are being used. This helps us analyse data about webpage traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system. Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

How we use your information
- We use Your Data mainly to perform any contract we may have with you and to provide our services to you (including through the Site), which includes to:
  - internal record keeping;
  - provide you with information, products or services that you request from us;
  - notify you about changes to our Site and our services;
  - process and deal with any complaints or enquiries made by you.

- We may also use Your Data to contact you for marketing purposes with your consent, or if you have interacted with our service and it is permitted by applicable data protection laws, where it is in our legitimate interest. Please see Section 7 for further details.
- We may share Your Data with our trusted third parties who help to facilitate our Site and offering to you or otherwise where it is in our legitimate interest to improve our Site or our offering to you - see sections 8 and 9 of this policy for further details. We do not sell your data.

Retention of your data
- Without prejudice to Section 6 below, we will only keep Your Data for as long as we reasonably require and, in any event, only for as long as Data Protection Legislation and our own internal rules and policies allow.

Supplier data
- We may collect details from suppliers such as a contact name, email address, telephone number and bank details in order to contact you about goods and/or services we have ordered from you, to place further orders and to pay you for the goods or services supplied. We may share your data with our employees to manage our relationship with you and we will keep the personal data for as long as we require your goods and services and for a period of 6 years further to being provided with the goods/services. You may exercise any of the rights referred to in section 15 of this policy in relation to your personal data.

Marketing
- In addition to the uses described in sections 2 to 6 above, we may also use Your Data for our legitimate interests including for marketing where permitted under applicable laws, market research and related purposes, such as:
  - providing you with information about our products and services, or related products and services via email/post/telephone/text which may be of interest to you;
  - asking you to participate in market research, for example surveys about topical issues, our services and products. We will always try to tell you before you participate in a survey how any information you provide in the survey will be used.

- Where we have your consent, we may use your data to market the services and products of sports focused brands and ask you to participate in related market research via email/post/telephone/text which may be of interest to you.
- We will always inform you before collecting Your Data if we intend to use Your Data for marketing, market research and related purposes. Where we intend to use Your Data for the marketing of services and products of third-party organisations and/or disclose Your Data to any third party for such purposes we will obtain your prior consent.
- Right to opt-out - You have a right to opt-out of receiving any marketing information (from us and/or a third party) at any time. To opt-out of receiving such information you can:
  - use the facility contained in any marketing communication you receive; or
  - email us at info@birminghampanthers.com.

- Where you have subscribed to receive marketing correspondence from us we will keep personal data for the period provided for in section 13 of this policy.

Disclosure of your data to Third Parties
- In addition to the third parties mentioned above, we may disclose Your Data (such as name, contact details) to third parties to fulfil our contractual obligations with you or for our legitimate interests as follows:
  - software providers that host our website, store data and provide other software services on our behalf;
  - to reputable third parties in order to gather general statistical information about our Site’s user base, sales patterns, traffic volumes and related matters but these details will not include information personally identifying you;
  - HM Revenue and Customs, regulators and other authorities who require reports of processing activities in certain circumstances;
  - marketing organisations to assist with the distribution of our marketing correspondence;
  - to the police, regulatory bodies or legal advisers in connection with any alleged criminal offence or where we are under a duty to disclose or share Your Data in order to comply with any legal obligation; and
  - to governing and representative bodies of sport and recreation including local and county leagues to improve the management and co-ordination of sport within their territory, and, where we have your consent, to undertake marketing and survey participation.

Cross border data transfers
- We host our data within the UK. In processing Your Data, it will sometimes be necessary for us to transfer Your Data outside the UK to third parties such as overseas advisors or service providers. Your Data may also be accessed by staff operating outside the UK who work for us or for one of our suppliers. This includes people engaged in, among other things, the provision of support services to us. In such circumstances, we will take all steps reasonably necessary to ensure that Your Data is treated securely and in accordance with this Privacy Policy and Data Protection Legislation. We may enter into contracts with entities based outside the UK, where this is required by Data Protection Legislation.

Data security
- Unfortunately, the transmission of information via the internet and mobile networks is not completely secure. Although we will do our best to protect Your Data, we cannot guarantee the security of Your Data which we transmit in accordance with this policy. Any transmission is at your own risk. Once we have received Your Data, we will use strict procedures and security features to try to prevent unauthorised access.
- Information you provide to us is stored on our secure servers or those of our third-party providers. We, or our third-party providers, have implemented appropriate physical, technical and organisational measures designed to secure your information against accidental loss and unauthorised access, use, alteration or disclosure. In addition, we limit access to personal data to those employees, agents, contractors and other third parties that have a legitimate business need for such access.

Links to other websites
- Our Site may, from time to time, contain links to and from the websites of third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these when you leave our Site, we encourage you to read the privacy notice/policy of every website you visit.

Legal basis for processing your personal data
- We will only use your personal data where the law allows us to. Most commonly, we will use your personal data in the following circumstances:
  - for performance of any contract we enter into with you;
  - where necessary for compliance with a legal or regulatory obligation we are subject to; and
  - for our legitimate interests (as described within this policy) where your interests and fundamental rights do not override these interests.

Access to, updating, deleting and restricting use of your data
- You have certain rights in relation to Your Data - for example, the right to request that we erase Your Data (or part thereof) at any time, which we will comply with unless we have a lawful reason to retain your information (for example, to comply with our legal obligations).
- You also have the right, subject to certain exemptions, to:
  - see Your Data held by us, and withdraw any consent you may have given to us to hold and use such data;
  - ask us to make any changes to ensure that Your Data held by us is accurate and up to date; and
  - in some cases, ask us to transfer any information we hold about you to a specified third party.

- If you wish to exercise any of these rights, please contact us at info@birminghampanthers.com.
- Please ensure that Your Data held by us is accurate and complete and you notify us of any changes to Your Data as soon as possible so that we can update our records.

Right to withdraw consent
- Where you have provided your consent to the collection, processing and transfer of your personal data, you may withdraw that consent at any time. This will not affect the lawfulness of data processing based on consent before it is withdrawn. To withdraw your consent please contact us at info@birminghampanthers.com.

Changes to our privacy policy
- Any changes we may make to this privacy policy in the future will be posted on this page. We encourage you to check this privacy policy from time to time for any updates or changes to the privacy policy. If we would like to use your previously collected personal data for different purposes than those we notified you about at the time of collection, we will provide you with notice and, where required by law, seek your consent before using your personal data for a new or unrelated purpose. We may process your personal data without your knowledge or consent where required by applicable law or regulation.

Contact us
- If you have any questions, comments or requests regarding this policy or how we use Your Data please contact our Data Protection Lead at info@birminghampanthers.com. This is in addition to your right to contact the Information Commissioners Office if you are unsatisfied with our response to any issues you raise at https://ico.org.uk/global/contact-us.