Protecting Your Privacy

1. Introduction

Welcome to The Sports Integrity Initiative’s privacy notice.

The Sports Integrity Initiative respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

We hope the following sections will answer any questions you may have but if not, please do get in touch with us.

It Is likely that we will need to update this Privacy Notice from time to time. We will notify you of any significant changes, but you’re welcome to come back and check it whenever you wish.

2. Who we are

When you are using and providing personal information on The Sports Integrative Initiative’s website, The Sports Integrative Initiative Limited is the data controller.

3. The legal bases we rely on

The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:

Consent

In certain situations, we can collect and process your data with your consent.
For example, when you tick a box to receive email newsletters.
When collecting your personal data, we will always make clear to you which data is necessary in connection with a particular service.

Contractual obligations

In certain circumstances, we need your personal data to comply with our contractual obligations.
For example, if you request a service from us, we will ask for your details.

Legal compliance

If the law requires us to, we may need to collect and process your data.
For example, we can pass on details of people involved in fraud or other criminal activities affecting The Sports Integrative Initiative to law enforcement.

Legitimate interest

In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.
For example, we will use your address details to send you direct marketing information by post, telling you about products and services that we think might interest you.

4. When do we collect your personal data?

• When you subscribe with us.
• When you engage with us on social media or participate in a reader forum.
• When you fill out our online forms.
• If you telephone us or if we call you, the call may be recorded for quality, training and management purposes.
• We may also record your enquiries via online chat for the same purposes.
• If you provide us with any personal information on paper.
• When you contact us by any means with queries, complaints etc.
• When you ask us to email you information about a service.
• When you book any kind of appointment with us or book to attend an event.
• When you choose to complete any surveys we send you.
• When you comment on or review our services.
• When you fill in any forms.
• When you’ve given a third-party permission to share with us the information they hold about you.
• When our suppliers and contractors share information with us.
• We collect data from publicly-available sources when you have given your consent to share information or where the information is made public as a matter of law.

Information from devices

We also collect information indirectly from you, from the device you may be using when you interact with our website. This can include your geographic location, which for example may be required to provide services to you that have copyright restrictions. We may also collect information from cookies placed on your computer or your device. Please contact our Data Protection Lead for more information about our use of cookies.

Social login

If you log in to our website or online services through a third-party site, such as Facebook, that site may pass information to us, such as, user ID, name associated with the ID, email address and location, plus other information permitted under the privacy policy for that website. Our website may also return information about you to that social networking site regarding your login.

Posts, comments and interaction

When readers enter into a conversation, for example through the use of polls, comments, text messages, email, phone, radio or letters we reserve the right to display this content indefinitely in any relevant context subject to our editorial judgement. This may be anonymised in the case of testimonials or customer service conversations.

Public information and posts

Any information about yourself or others that you submit on social media sites, including chat rooms, blogs and forums, will be viewed by other people. As such, this personal data may be viewed, collected and used by third parties, including search engines, over which we have no control. We are not responsible for either the information you submit/post or otherwise make available in such public areas or any use that may be made of such information by any third party.

Other sources

We may also obtain information about you from other companies that have your permission to share information about you, as well as from other online and offline sources. We may combine this information with information we collect directly or indirectly from you.

Information about other people

By giving us information about another person, you confirm that they have appointed you to act for them, for you to provide us with their information, including sensitive personal data, and to the transfer of their information abroad and to receive on their behalf any data protection notices.

5. What sort of personal data do we collect?

We use your information to provide you with our services, to provide a greater personalised experience and to manage our relationship with you, including allowing you to interact, comment, and participate in our website. We collect:

• Details of your interactions with us online, in writing or on the telephone to assist with complaints, comments you make, brands you show an interest in, web pages you visit and how and when you contact us.
• Details of your visits to our website and which site you came from to ours.
• Information gathered by the use of cookies in your web browser.
• Personal details which help us to recommend services of interest. We will only ask for and use your personal data collected for recommending services of interest and to tailor your experience with us. It is always your choice whether you share such details with us.
• Your comment and reviews.
• To deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country and telephone code where your computer is located, the web pages viewed during your visit, the advertisements you clicked on, and any search terms you entered.
• Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.

6. How and why do we use your personal data?

We want to give you the best possible user experience and we look to achieve this by gaining a detailed picture of who you are by combining the data we have about you. We may use your information to monitor and improve and protect our products, content, services and website, both online and offline. We may also provide you with help and support where we believe it is required.

The data privacy law allows this as part of our legitimate interest in understanding our readers and customers and providing the highest levels of service.

The content on our website and in our communications with you may be adjusted depending on what we know about the content, products and services that you may like. This means we can highlight content and articles that we believe will be of interest to you. We provide personalisation by using cookies, IP addresses, web beacons, URL tracking and app settings. Please contact our Data Protection Lead for more information about how we use these.

Of course, if you wish to change how we use your data, you are welcome to contact our Data Protection Lead. However, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some of the services you may have asked for. For example, if you have withdrawn consent to subscribe with us, we can no longer keep you updated with articles and events.

Here is how we will use your personal data and why:

Developing, testing and improving our systems and services we provide to you

We do this on the basis of our legitimate business interests. For example, we will record your browser’s Session ID to help us understand more when you leave us online feedback about any problems you are having.

Responding to your queries, requests or complaints

We may use your information so that we may respond to you. We may also keep a record of our communications with you to inform and demonstrate how we communicated with you to assist us with future communications with you. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service we can.

Market research and analytics

We may use your information to conduct market research to improve the services we offer and to develop new products and services.

Deliver relevant advertising

We use targeted advertising to provide online advertisements that we believe are more relevant to your interests. We deliver online adverts based on the way you interact with us on our websites, mobile apps and tablet editions of our products and services. We may use information obtained through your participation in offers and events to deliver more relevant online adverts. We may also use your device’s location to deliver relevant online advertising. The information is aggregated and advertising based on your interests and profile is then displayed, when you visit websites or apps that use the same advertising networks. For more information please contact our Data Protection Lead for our Cookie Policy.

Third party advertising

Advertising content may be adjusted depending on personal information. In some instances, this targeted advertising may be created by third parties and the information will be collected and held by these third parties outside of our control. We accept no responsibility for the content of advertising material, including any error, omission or inaccuracy contained within it.

Relevant communications

Unless you have told us otherwise, we may use your information to send you newsletters, bulletins and other information about your chosen services.

Direct marketing

We want to bring you offers that are most relevant to your interests at particular times. This may include communications by post, telephone, email and messages to your mobile phone and through social media (such as Facebook and Twitter) about us and our services, events and offers, including for a reasonable time after you may have ceased a subscription or service with us.
Of course, you are free to opt out of hearing from us by any of these channels at any time.

7. How we protect your personal data

We know how much data security matters to all of our readers and customers and we treat your data with care and respect and take all appropriate steps to protect it.

When you complete our registration forms or use our services, we may transfer your information to processors outside the European Economic Area but will do so with appropriate measures and controls in place to protect that information in accordance with applicable data protection legislation.

When you give us information about another person, you confirm that they have appointed you to act for them and agreed to the transfer of their information abroad.

We regularly monitor our system for possible vulnerabilities and attacks.

8. How long will we keep your personal data?

Whenever we collect or process your personal data, we will only keep it for as long as is necessary for the purpose for which it was collected.

At the end of that retention period, your data will be deleted. If you ask us to delete your information before that time, we may not be able to do so, due to technical, legal, regulatory and contractual constraints. For example, we would need to retain your name and contact details for suppression purposes if you do not want to receive direct marketing from us.

For further information, please contact our Data Protection Lead.

9. Who do we share your personal data with?

We sometimes share your personal data with trusted third parties. For example, to help personalise our services to your, for fraud management, to manage any enquiries or complaints and so on. To ensure those organisations keep your data safe and protect your privacy:

• We provide only the information they need to perform their specific services.
• They may only use your data for the exact purposes we specify in our contract with them.
• We work closely with them to ensure your privacy is respected and protected at all times.
• If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.

Examples of the third parties we work with are:

• IT companies who support our website and other business systems.
• Direct marketing companies who help us manage our electronic communications with you.
• Google/Facebook to show you products that might interest you while you’re browsing the internet. This is based on either your marketing consent or your acceptance of cookies on our website. Please contact our Data Protection Lead for details on our Cookies Policy.
• Data insight companies to ensure your details are up to date and accurate.
• Our services may be linked to websites operated by third party companies, and may carry advertisements or offer content, functionality, games, newsletters, contests, or applications developed and maintained by unaffiliated companies. We are not responsible for the privacy practices of unaffiliated companies, and once you leave the services or click an advertisement you should check the applicable privacy policy of the other service.

Sharing your data with third parties for their own purposes:

We will only do this in very specific circumstances, for example:
• With your consent, given at the time you supply your personal data, we may pass that data to a third party for their direct marketing purposes. For instance, if you tick a box agreeing that a company other than The Sports Integrity Initiative, may send you promotional information directly. Or if we run a joint event with another company and you agree to receive direct communications from them.
• For fraud management, we may share information about fraudulent or potentially fraudulent activity on our systems. This may include data sharing about individuals with law enforcement bodies.
• We may also be required to disclose your personal data to the police or other enforcement or regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and we take the privacy of our customers into consideration.
• We may, from time to time, expand, reduce or sell the company and this may involve a transfer of part or the whole business to new owners. If this happens, your personal data will, where relevant, be transferred to the new owner or controlling party, under the terms of this Privacy Notice.
• For further information, please contact our Data Protection Lead.

10. Where your personal data may be processed

Sometimes we may need to share your personal data with third parties and suppliers outside the European Economic Area (EEA). For example, this may be required to provide support services.
If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the EEA. For example, our contracts with third parties stipulate the standards they must follow at all times. If you wish for more information about these contracts, please contact our Data Protection Lead.
Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.

11. What are your rights over your personal data?

You have the right to:
• Request access to the personal data we hold about you, free of charge in most cases.
• Request the correction of your personal data when out of date, incomplete or incorrect.
• Request the erasure of your personal data.
• Object to our processing your personal data, for example, for direct marketing.
• Request that we stop any processing of your personal data after you withdraw your consent
• Request restriction of the processing of your personal data.
• Request the transfer of your personal data.
• Withdraw your consent.

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

We 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. If we choose not to action your request, we will explain the reasons for our refusal in full.

Updating your information

Please ensure you update your personal information or tell us if it changes or is inaccurate.

Direct marketing

You can change your mind about receiving direct marketing from us by contacting us using the details below or by following the unsubscribe instructions in the communication. Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.

Controlling other communications

You can control communications such as bulletins and other information about your chosen services by following the unsubscribe instructions in the communication. You may still receive other communications that are relevant to your chosen services but do not relate to that specific type of communication. Where this is the case, you will be able to unsubscribe from these communications in the same way.

12. Contacting us

Our Data Protection Lead is available to help you:

Email: [email protected]

If you feel that your data has not been handled correctly or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office at www.ico.org.uk/concerns. If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence.

This notice was last updated on 20/05/2018 and may be amended from time to time.