Your information will be held by the company within the Sporting Club IOM Group that collects your personal data.. This privacy notice is to let you know how companies within the Group promise to look after your personal information. This includes (but is not limited to) what you tell us about yourself, what we learn by having you as a member of Sporting Club Isle of Man Limited, or where you may be part or one of our teams, and the choices you give us about what marketing you want us to send you. This notice also tells you about your privacy rights and how the law protects you.
1. ABOUT THIS POLICY
1.1 Scope of this policy
It also relates to our use of any personal information we collect through other means, such as
1.2 Policy updates
3. ABOUT THE SPORTING CLUB IOM GROUP
2.1 Who are we?
We are the Sporting Club IOM group of companies that operate in the Isle of Man. The Group’s vision is to create and develop sports teams based on the Isle of Man to propel team and individual performances within each sport to the highest level possible. The Group’s mission is to create, support and develop sporting opportunities, alongside the required infrastructure, for Manx residents via the creation and development of Isle of Man based sporting teams towards professional levels.
For a full list of Group companies please click on the following link: www.sportingclub.im/clubs. This list may change from time to time as the Group evolves. You’ll find our registered address below. We will let you know which company you have a relationship with when you interact with us (for example, when you purchase membership or a product or event ticket from us).
2.2 Who’s the Data Controller?
3. WHAT INFORMATION DO WE GATHER AND HOW DO WE COLLECT IT?
3.1 What types of information do we collect about you?
The type of information we collect about you depends on the nature of your interactions with us. Depending on the circumstances, we may receive or collect personal information about you, when you contact the Sporting Club IOM Group for example by doing any of the following:
Data you give to us:
Data we collect when you use our services:
3.2 Personal information about others
We may collect information from you about others, such as members of your household or family (e.g. where you purchase a season ticket for you and your family). If you give us information about another person it is your responsibility to ensure and confirm that:
4. WHEN DO WE NEED TO COLLECT YOUR SENSITIVE INFORMATION?
In certain circumstances, we will collect information that is deemed sensitive. This is most likely to include:
We seek to limit any sensitive personal data that we collect and, unless we have other specific lawful reasons to use this information (such as in an emergency situation), we will ask for your consent to collect it.
5. HOW THE LAW PROTECTS YOU
Your privacy is protected by law. This section provides an overview of how that protection works.
Data protection law states that we are only allowed to use personal information if we have a proper reason to do so. This includes sharing it outside the Sporting Club IOM Group. The law states that we must have one or more of the following reasons:
A legitimate interest is when we have a business or commercial reason to use your information. But even then, it must not unfairly go against what is best or right for you. If we rely on our legitimate interest, we will tell you what that is. The section below (“How We Use Your Information”) contains a list of the ways in which we may use your personal information, and the reasons we rely on to do so. This is also where we tell you what our legitimate interests are.
6. HOW WE USE YOUR INFORMATION
We will only use your personal data fairly and where we have a lawful reason to do so. We are allowed to use your personal data if we have your consent or another legally permitted reason applies. These include to fulfil a contract we have with you, when we have a legal duty that we have to comply with, or when it is in our legitimate business interest to use your personal data. We can only rely on our legitimate business interest if it is fair and reasonable to do so. We may use information to:
|Uses of personal data||Our lawful basis for using your personal data|
|· To provide guidance on applications for membership and all membership matters and related relevant services, to manage and administer our operational/ business relationships, including to communicate with our members, sponsors and service providers/supplier; to manager and administer all memberships, including membership payments, to collect and recover money that is owed to us and to keep records.||To fulfil our contracts with our membership and others, and to comply with legal and regulatory obligations including accounting, tax and data protection.|
|· To undertake due diligence on sponsors and suppliers before we engage with them.
· To comply with laws and regulations that apply to us.
|To comply with our legal and regulatory obligations,|
|· To provide information services to members and potential members, including by email updates and newsletters; and to invite you to events, including sporting events, that we may organise from time to time. This may include surveys to obtain feedback from you post events.
· To develop and carry out marketing activities and to show you information that is of interest to you, based on our understanding of your preferences (we may combine information you give us with information we may receive about you from third parties to help us understand you better).
|Where you have consented and expressed a preference to receive marketing communications; or if we feel it is appropriate and relevant to our relationship with you.|
|· To run our Sporting Club IOM Group in an efficient and proper way (e.g. auditing and managing the Group capability, managing risk for the Group, finances, planning, communications with service providers and sponsors, responding to member complaints and seeking to resolve them).||When needed for the efficient operation of our business.|
|· To maintain lists to ensure that you do not receive communications from us where you have objected to this or have unsubscribed.||To safeguard your rights and comply with our legal obligations.|
|· To optimise our website. To collate information on how you interact with us and our services so that we can improve this if felt necessary||Where we have consent from you or on the basis of our legitimate interests to operate and present an effective and convenient website to our website users.|
|· To ensure security and protect our business interests.||In certain circumstances, we may use your information to ensure the security of our services, offices and people, including to protect against, investigate and deter fraud, unauthorised or illegal activities, systems testing, maintenance and development (on the basis of our legitimate interests to run a safe and lawful operation/business or where we have a legal obligation to do so).|
|· Sharing personal data if we decide to invite third parties to invest in part or all of Sporting Club IOM Group.||When needed to comply with our legal obligations and to facilitate the transaction.|
Groups of personal information
We collect and use lots of different types of personal data. Personal data is any information that relates to you and that identifies you either directly from that information or indirectly, by reference to other information that we have access to. The personal data that we collect, and how we collect it, depends upon how you interact with us. Categories of personal data that we collect include:
|Contact||Such as your name, address, email address and telephone number.|
|Socio-Demographic||This includes details about your work or profession, nationality and education.|
|Contractual||Details about the products or membership services we provide to you.|
|Transactional||Details about payments from members or sponsors or to service providers.|
|Locational||Data we get about where you are, such as may come from your mobile phone or the address where you connect a computer to the internet.|
|Behavioural||Details about how you use our products and when you attend our events.|
|Communications||What we learn about you from letters, emails, conversations between us, feedback and survey responses.|
|Open data and public records||Details about those we engage/work with that are found in public records such as the isle of Man Companies Registry, UK Companies House, the UK Electoral Register, and information about you that is openly available on the internet.|
|Usage data||Other data about how you use our products and services.|
|Documentary data||Details about you that are stored in documents in different formats, or copies of them. This could include things like your passport or drivers licence, if we need to see them.|
|Special types of data||The law and other regulations treat some types of personal information as special. We will only collect and use these types of data if we have a proper reason to do so, which we can justify and the law allows us to do so:
· Racial or ethnic origin
· Religious or philosophical beliefs
· Trade union membership
· Genetic and bio-metric data
· Health data including gender
· Criminal convictions and offences.
|Consents||Any permissions, consents, or preferences that you give us. This includes things like how you want us to contact you.|
|Financial||Billing and financial information such as billing address, bank account and payment information.|
7. HOW WE MAY SHARE YOUR INFORMATION OUTSIDE OF THE SPORTING CLUB IOM GROUP
7.1 If you apply for membership of Sporting Club Isle of Man Limited, or purchase a product or service (such as sporting goods or event tickets), your personal information may be shared with and processed by companies within the Sporting Club IOM Group, and also with persons working on behalf of the Group, who assist the Group in the management and administration of membership or with the sale of any of the products you purchase from the Group (including third parties providing services to them). Your information may also be disclosed when we believe in good faith that the disclosure is:
We may also share your personal data when you have consented to us doing so.
We may disclose your information to third party service providers to conduct our operations/business, for example, to assist in managing and storing data, provide data analytics, conduct market research and to communicate with you effectively. This may include any online or digital partners we work with, so we, or our online or digital partners on our behalf, can communicate with you through their platforms.
Where we do share your information with third parties, we will wherever possible require them to maintain appropriate security to protect your information from unauthorised access or processing.
7.2 If you choose not to give personal information
We may need to collect personal information by law, or under the terms of a contract we have with you (such as the terms and conditions of membership, if you are a member of the Sporting Club Isle of Man).
If you choose not to give us this personal information, it may delay or prevent us from meeting our obligations. It may also mean that we cannot perform services needed to properly administer your membership or our relationship with you. It could mean that we have no option but to cancel your membership or an order for a product.
Any data collection that is optional would be made clear at the point of collection.
7.3 Our service providers and suppliers
We are based in the Isle of Man. If we send personal information to countries outside the European Economic Area (‘EEA’), we will ensure that there will be a contract in place to make sure the recipient protects the data to the same standard as the EEA. This may include following international frameworks for making data sharing secure. We will only transfer your personal data outside of the European region under the following circumstances:
When you’ll hear from us
We may from time to time use your personal information to send you marketing by post, by phone, through social media, by email and by text. We may also use your personal information to help us identify, tailor and package Sporting Club IOM Group products and services, determine pricing and offer discounts that we believe may be of interest to you (such as replica team kit, and event tickets).
We can only use your personal information to send you marketing material if we have your permission or a legitimate interest as described above.
If you don’t want to receive emails from us, you can click on the ‘unsubscribe’ link that appears in all emails we send. If you don’t want to receive texts from us you can tell us by contacting us at any time. Otherwise, you can always contact us to update your contact preferences.
You have the right to object to direct marketing and profiling (the automated processing of your information to help us evaluate certain things about you, for example, your personal preferences and your interests) relating to direct marketing. Please see the section about your rights for more details.
8.2 Opting out of or withdrawing your consent in relation to marketing
If you no longer want to hear from us, you can opt out or unsubscribe by:
Third parties and marketing
We might rely on third parties to help us manage our marketing communications, but we won’t share your information with any third parties for their marketing purposes unless you agree to our doing so.
9. OUR SITE AND COOKIES
9.1 What we collect when you interact with our sites and any apps we may use/offer
As you may already know, most websites collect certain information automatically about the way in which you interact with them. This might include your IP address, geographical location, device information (such as your hardware model, mobile network information, unique device identifiers) browser type, referral source, length of visit to the site, number of page views, the search queries you make, and similar information.
This information will be collected by us or by a third party site analytics service provider and will be collected using cookies.
As we’ve described above, we use this information to save your settings, such as the last item you searched for so you can find it easily the second time, help improve our functionality and services, run diagnostics, analyse trends, track visitor movements, gather broad demographic information and personalise our services and provide you with tailored marketing that we think you may be interested in, if you have told us that you’re happy to receive marketing from us.
9.2 What do we mean by “cookies”?
Cookies are small amounts of information in the form of text files that we store on the device you use to access our site or our marketing communications. Cookies allow us to monitor your use of our services and improve them. For example, a temporary cookie is also used to keep track of your “session”. Without that temporary cookie you will not be able to purchase products or access other services that may be offered via our site.
If you don’t want 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 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 site.
10. YOUR RIGHTS
Under data protection legislation you have various rights in respect of the personal information that we hold about you, including:
You may also have the right, in certain circumstances to:
Please note that we reserve the right to retain certain information for our own record-keeping (for example, to ensure that you do not receive marketing communications that you have opted-out of receiving) and to defend ourselves against any claims. We may also need to send you service-related communications relating to the services that we provide to you even when you have requested not to receive marketing communications.
10.3 How to exercise your rights
11. HOW WE LOOK AFTER YOUR INFORMATION
11.1 We are committed to protecting the confidentiality and security of the information that you provide to us. We put in place appropriate technical, physical and organisational security measures to protect against any unauthorised access or damage to, or disclosure or loss of, your information. By way of example we:
Links to other sites and resources
12. HOW LONG WE KEEP YOUR INFORMATION FOR
We do not keep your personal data for any longer than is necessary to fulfil the purpose for which we collected it, or to comply with any legal, regulatory or reporting obligations or to assert or defend against legal claims. We will generally keep your data for no longer than six years for one of these reasons:
We may keep your data for longer than six years if we cannot delete it for legal or technical reasons. We may also keep it for research or statistical purposes. If we do, we will make sure that your privacy is protected and only use it for those purposes.
13. HOW TO CONTACT US
The Privacy Officer
Sporting Club IOM Group
Isle of Man
However, if you remain dissatisfied with our response, you have the right to take the matter up with the Isle of Man Information Commissioner’s Office (ICO). The ICO is an independent authority and the Isle of Man’s supervisory authority for information rights.
You can contact the Information Commissioner via the ICO website at https://www.inforights.co.im.
LAST UPDATED: March 2020