Privacy Policy
INTRODUCTION
Welcome to Universal Sport Instalaciones’ Privacy Policy.
Universal Sport Instalaciones respects your privacy and is committed to protecting your personal data. This Privacy Policy will tell you how we look after your personal data when you visit our website (regardless of where you visit) and inform you about your privacy rights and how the law protects you.
Our Privacy Policy complies with the General Data Protection Regulation (EU) 2016/679) GDPR and Organic Law 3/2018 (Spain), of 5 December, on the Protection of Personal Data and guarantee of digital rights.
This Privacy Policy is dated 21 October 2020.
Content:
1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE GATHER ABOUT YOU
3. HOW YOUR PERSONAL DATA IS GATHERED
4. HOW YOUR PERSONAL DATA IS USED
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
1. IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY POLICY
Universal Sport Facilities wants to ensure that you understand what information we hold about you, how we will use it and for what purpose. This Privacy Policy is intended to provide you with information about how Universal Sport Facilities collects and processes your personal data through your use of this website, including but not limited to data you may provide through this website when you subscribe to our latest news and updates, sign up to our newsletter, would like to join our Supporters and Runners programme or request more information about our current opportunity by completing the form.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this Privacy Policy together with any other privacy policy or fair processing policy that we may provide on specific occasions when we collect or process personal data about you so that you are fully aware of how and why we use your data . This Privacy Policy supplements other privacy notices and policies and is not intended to override them.
CONTROLLER
Universal Sport Facilities is the controller (collectively referred to as Universal Sport Facilities, ‘we’, ‘us’, “us” or ‘our’ in this privacy policy) and is responsible for deciding how we hold and use certain personal information about you.
We have not appointed a Data Protection Officer. If you have any questions about anything in this policy, please do not hesitate to contact the Data Protection Team using the details below.
CONTACT DETAILS
If you have any questions about this Privacy Policy or our privacy practices, please contact our Data Protection Team in the following ways:
Full name of the legal entity: Decopave España S.L
Email Address: : Contact Us
Postal address: Apartado de correos 2039, 29604 Marbella
You have the right to lodge a complaint at any time with the Spanish Data Protection Agency, which oversees data protection compliance in Spain. Details of how to do this can be found at http://www.agpd.es/.
However, we would welcome the opportunity to address your concerns before you approach the Spanish Data Protection Agency, so please contact us in the first instance.
CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF THE CHANGES
We may update this Privacy Policy in accordance with changes in the way we process personal data. We will post any new version of the Privacy Policy on our website.
It is important that the personal data we hold about you is accurate and up to date. Please keep us informed if your personal data changes during your relationship with us.
THIRD PARTY LINKS
This 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 policy of each website you visit.
DATA PROTECTION PRINCIPLES
We will ensure that the personal information we hold about you is:
used in a lawful, fair and transparent manner;
collected only for specific and legitimate purposes that we have clearly explained to you and not used in a way that is incompatible with those purposes;
adequate, relevant and limited to what is necessary in relation to the purpose we have told you;
accurate and up to date;
not kept in a form that allows you to be identified for longer than necessary and kept only for as long as necessary for the purpose we have told you;
kept securely;
not transferred to another country without appropriate safeguards in place.
2. THE DATA WE GATHER ABOUT YOU
Datos personales, o información personal, significa cualquier información sobre una persona a partir de la cual se pueda identificar a esa persona. No incluye datos donde se ha eliminado la identidad (datos anónimos).
Podemos recopilar, usar, almacenar y transferir diferentes tipos de datos personales sobre usted que hemos agrupado de la siguiente manera:
Personal data, or personal information, means any information about an individual from which that individual can be identified. It does not include data where identity has been removed (anonymised data).
We may collect, use, store and transfer different types of personal data about you which we have grouped as follows:
Identity data includes [first name, maiden name, family name, surname, user name or similar identifier, marital status, title, date of birth, nationality, gender, status and tax information, passport/national identity card details and country of domicile, your employment and employment history, job title and role, educational profile, interests and other information relevant to our provision of professional services].
Contact details include [billing address, delivery address, home/business address, email address and telephone numbers].
Financial data includes [income, expenditure, assets and liabilities, sources of wealth, as well as details of your bank account, payment card accounts and other information necessary to process payments and for fraud prevention purposes].
Transaction data includes [details of payments to and from you and other details of products and services you have purchased from us].
Technical data includes [internet protocol (IP) address, your login details, browser type and version, time zone settings and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website].
Profile data includes [your username and password, purchases or orders placed by you, your interests, preferences, comments and survey responses].
Usage data includes [information about how you use our website, products and services].
Marketing and communications data includes [your preferences for receiving marketing from us and our third parties and your communication preferences].
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We also collect, use and share aggregated data, such as statistical or demographic data, for any purpose. Aggregated data may be derived from your personal data, but is not considered personal data by law, as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature of the website. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data to be used in accordance with this Privacy Policy.
We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health information and genetic and biometric data). We also do not collect information about criminal convictions and offences.
IF YOU DONT PROVIDE PERSONAL DATA
Cuando necesitemos recopilar datos personales por ley, o según los términos de un contrato que tengamos con usted, y usted no proporcione esos datos cuando se los solicite, es posible que no podamos ejecutar el contrato que tenemos o estamos tratando de celebrar con usted (por ejemplo, para proporcionarle bienes o servicios). En este caso, es posible que tengamos que cancelar un producto o servicio que tenga con nosotros, pero le notificaremos si este es el caso en ese momento.
3. HOW YOUR PERSONAL DATA IS COLLECTED
Where we need to collect personal data from you by law, or under the terms of a contract we have with you, and you do not provide that data when requested to do so, we may not be able to perform the contract we have or are seeking to enter into with you (for example, to provide goods or services to you). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at that time.
Direct interactions. You may give us your identity, contact and financial details by filling in forms or communicating with us by post, telephone, email or other means. This includes personal data you provide when:
– Requesting our services;
– Place and order,
– Send an email to our general enquiries address,
– Interact directly with us personally,
– Subscribe to our latest news and updates;
– Request marketing to be sent to you;
– Request more information about our current opportunities by filling in the form,
– Send us your comments or contact us.
Automated technologies or interactions. As you interact with our website, we automatically collect technical data about your computer, browsing actions and patterns. We collect this personal data through the use of cookies and other similar technologies.
Third parties or publicly available sources. We may receive personal data about you from public records and various third parties (including your organisation, agents, advisers, intermediaries or custodians of your assets and our clients or those involved in the matter that we rarely deal with).
We may also collect personal information about you from persons or entities authorised by you to provide information to us.
Welcome to Universal Sport Instalaciones’ Privacy Policy.
Universal Sport Instalaciones respects your privacy and is committed to protecting your personal data. This Privacy Policy will tell you how we look after your personal data when you visit our website (regardless of where you visit) and inform you about your privacy rights and how the law protects you.
Our Privacy Policy complies with the General Data Protection Regulation (EU) 2016/679) GDPR and Organic Law 3/2018 (Spain), of 5 December, on the Protection of Personal Data and guarantee of digital rights.
This Privacy Policy is dated 21 October 2020.
Content:
1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE GATHER ABOUT YOU
3. HOW YOUR PERSONAL DATA IS GATHERED
4. HOW YOUR PERSONAL DATA IS USED
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
1. IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY POLICY
Universal Sport Facilities wants to ensure that you understand what information we hold about you, how we will use it and for what purpose. This Privacy Policy is intended to provide you with information about how Universal Sport Facilities collects and processes your personal data through your use of this website, including but not limited to data you may provide through this website when you subscribe to our latest news and updates, sign up to our newsletter, would like to join our Supporters and Runners programme or request more information about our current opportunity by completing the form.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this Privacy Policy together with any other privacy policy or fair processing policy that we may provide on specific occasions when we collect or process personal data about you so that you are fully aware of how and why we use your data . This Privacy Policy supplements other privacy notices and policies and is not intended to override them.
CONTROLLER
Universal Sport Facilities is the controller (collectively referred to as Universal Sport Facilities, ‘we’, ‘us’, “us” or ‘our’ in this privacy policy) and is responsible for deciding how we hold and use certain personal information about you.
We have not appointed a Data Protection Officer. If you have any questions about anything in this policy, please do not hesitate to contact the Data Protection Team using the details below.
CONTACT DETAILS
If you have any questions about this Privacy Policy or our privacy practices, please contact our Data Protection Team in the following ways:
Full name of the legal entity: Decopave España S.L
Email Address: : Contact Us
Postal address: Apartado de correos 2039, 29604 Marbella
You have the right to lodge a complaint at any time with the Spanish Data Protection Agency, which oversees data protection compliance in Spain. Details of how to do this can be found at http://www.agpd.es/.
However, we would welcome the opportunity to address your concerns before you approach the Spanish Data Protection Agency, so please contact us in the first instance.
CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF THE CHANGES
We may update this Privacy Policy in accordance with changes in the way we process personal data. We will post any new version of the Privacy Policy on our website.
It is important that the personal data we hold about you is accurate and up to date. Please keep us informed if your personal data changes during your relationship with us.
THIRD PARTY LINKS
This 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 policy of each website you visit.
DATA PROTECTION PRINCIPLES
We will ensure that the personal information we hold about you is:
used in a lawful, fair and transparent manner;
collected only for specific and legitimate purposes that we have clearly explained to you and not used in a way that is incompatible with those purposes;
adequate, relevant and limited to what is necessary in relation to the purpose we have told you;
accurate and up to date;
not kept in a form that allows you to be identified for longer than necessary and kept only for as long as necessary for the purpose we have told you;
kept securely;
not transferred to another country without appropriate safeguards in place.
2. THE DATA WE GATHER ABOUT YOU
Datos personales, o información personal, significa cualquier información sobre una persona a partir de la cual se pueda identificar a esa persona. No incluye datos donde se ha eliminado la identidad (datos anónimos).
Podemos recopilar, usar, almacenar y transferir diferentes tipos de datos personales sobre usted que hemos agrupado de la siguiente manera:
Personal data, or personal information, means any information about an individual from which that individual can be identified. It does not include data where identity has been removed (anonymised data).
We may collect, use, store and transfer different types of personal data about you which we have grouped as follows:
Identity data includes [first name, maiden name, family name, surname, user name or similar identifier, marital status, title, date of birth, nationality, gender, status and tax information, passport/national identity card details and country of domicile, your employment and employment history, job title and role, educational profile, interests and other information relevant to our provision of professional services].
Contact details include [billing address, delivery address, home/business address, email address and telephone numbers].
Financial data includes [income, expenditure, assets and liabilities, sources of wealth, as well as details of your bank account, payment card accounts and other information necessary to process payments and for fraud prevention purposes].
Transaction data includes [details of payments to and from you and other details of products and services you have purchased from us].
Technical data includes [internet protocol (IP) address, your login details, browser type and version, time zone settings and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website].
Profile data includes [your username and password, purchases or orders placed by you, your interests, preferences, comments and survey responses].
Usage data includes [information about how you use our website, products and services].
Marketing and communications data includes [your preferences for receiving marketing from us and our third parties and your communication preferences].
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We also collect, use and share aggregated data, such as statistical or demographic data, for any purpose. Aggregated data may be derived from your personal data, but is not considered personal data by law, as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature of the website. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data to be used in accordance with this Privacy Policy.
We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health information and genetic and biometric data). We also do not collect information about criminal convictions and offences.
IF YOU DONT PROVIDE PERSONAL DATA
Cuando necesitemos recopilar datos personales por ley, o según los términos de un contrato que tengamos con usted, y usted no proporcione esos datos cuando se los solicite, es posible que no podamos ejecutar el contrato que tenemos o estamos tratando de celebrar con usted (por ejemplo, para proporcionarle bienes o servicios). En este caso, es posible que tengamos que cancelar un producto o servicio que tenga con nosotros, pero le notificaremos si este es el caso en ese momento.
3. HOW YOUR PERSONAL DATA IS COLLECTED
Where we need to collect personal data from you by law, or under the terms of a contract we have with you, and you do not provide that data when requested to do so, we may not be able to perform the contract we have or are seeking to enter into with you (for example, to provide goods or services to you). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at that time.
Direct interactions. You may give us your identity, contact and financial details by filling in forms or communicating with us by post, telephone, email or other means. This includes personal data you provide when:
– Requesting our services;
– Place and order,
– Send an email to our general enquiries address,
– Interact directly with us personally,
– Subscribe to our latest news and updates;
– Request marketing to be sent to you;
– Request more information about our current opportunities by filling in the form,
– Send us your comments or contact us.
Automated technologies or interactions. As you interact with our website, we automatically collect technical data about your computer, browsing actions and patterns. We collect this personal data through the use of cookies and other similar technologies.
Third parties or publicly available sources. We may receive personal data about you from public records and various third parties (including your organisation, agents, advisers, intermediaries or custodians of your assets and our clients or those involved in the matter that we rarely deal with).
We may also collect personal information about you from persons or entities authorised by you to provide information to us.
4. HOW DO WE USE YOUR PERSONAL DATA
We will only use your personal data where we are permitted to do so by law. We will generally use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal obligation.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
Below, we set out, in table format, a description of all the ways in which we plan to use your personal data and on which of the legal bases we rely to do so. We have also identified what our legitimate interests are where applicable.
Please note that we may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please contact us if you require details of the specific legal basis we are relying on to process your personal data where more than one basis has been set out in the table below.
Purpose / Activity
Type of data
Lawful basis for processing including legitimate interest basis
To register you as a new customer
(a) Identity
(b) Contact
To perform a contract with you
To process and deliver your order, including:
(a) Handling payments, fees and charges
(b) To collect and recover monies owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts owed to us)
To manage our relationship with you, which will include:
(a) Notifying you of changes to our terms or privacy policy
(b) Asking you to leave a review or respond to a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for compliance with a legal obligation
(c) Necessary for our legitimate interests (to keep our records up to date and to study how customers use our products / services)
To allow you to complete a survey
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and to grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and data hosting)
(a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests (for the operation of our business, the provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and to measure or understand the effectiveness of the advertising we provide to you.
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Necessary for our legitimate interests (to study how customers use our products/services, develop them, grow our business and inform our marketing strategy)
Use data analytics to improve our website, products/services, marketing, customer relationships and experiences.
(a) Technical
(b) Use
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website up to date and relevant, to grow our business and inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you.
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications
Necessary for our legitimate interests (to develop our products/services and grow our business)
MARKETING
We use mailing lists to manage how we communicate with you. This allows us to record and manage how we contact you and to manage your preferences and bookings for our events.
This data helps us to ensure that our mailing list remains up to date; it also provides us with basic information about our interests and to personalise our communications with you.
PROMOTIONAL OFFERS FROM US
We may use your identity, contact, technical, usage and profile data to form an opinion about what we think you may want or need, or what may be of interest to you. This is how we decide what products, services and offers may be relevant to you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving such marketing.
THIRD PARTY MARKETING
We will obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes.
EXCLUDE
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, warranty registration, service experience or other transaction.
COOKIES
As you interact with our website, we may collect personal information about you from time to time.
We collect this personal data through the use of cookies and other similar technologies. Cookies are used to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.
A cookie is a small file of letters and numbers that we store in your browser or on your computer’s hard drive if you agree. Cookies contain information that is transferred to your computer’s hard drive.
We use cookies to help us remember and process the items in your shopping cart, understand and save your preferences for future visits, track advertisements and compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future. We use Google AdWords remarketing to advertise the Trigger across the web. AdWords remarketing will display relevant ads tailored to you based on which parts of the TriggerApp website you have viewed by placing a cookie on your machine. This cookie does not identify you in any way or give you access to your computer. The cookie is used to say ‘This person visited this page, so show them ads related to that page’. Google AdWords remarketing allows us to tailor our marketing to better suit your needs and only show ads that are relevant to you.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you would like an explanation of how processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and explain the lawful basis for allowing us to do so.
Please note that we may process your personal data without your knowledge or consent in accordance with the above rules where required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may need to share your data with third parties where required to do so by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.
Such third parties include your organisation, our own customer in a particular matter, an external service provider or third parties to whom we may choose to sell, transfer or merge parts of our business or assets. Alternatively, we may seek to acquire or merge with other businesses. If there is a change in our business, the new owners may use your personal data in the same manner as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law.
6. INTERNATIONAL TRANSFERS
We may transfer our personal information outside the EEA. If we do so, you can expect a similar level of protection in respect of your personal information.
7.DATA SECURITY
We take the security of your personal information seriously and have implemented internal controls and security measures to protect it.
We have implemented appropriate security measures to prevent your personal data from being lost, used or accessed in an unauthorised manner, altered or accidentally disclosed. Personal data will only be transferred to a data processor if it agrees to comply with those measures, or if it implements appropriate measures itself. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and are subject to a duty of confidentiality.
We have implemented procedures to deal with any suspected personal data breaches and will notify you and any applicable regulator of a breach where we are legally obliged to do so.
8. DATA RETENTION
FOR HOW LONG WILL WE USE YOUR PERSONAL DATA
We will only retain your personal data for as long as is reasonably necessary to fulfil the purposes for which we collect it, including to comply with legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe that there is a prospect of litigation in respect of our relationship with you.
In determining the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether you can achieve those purposes through other means, and any applicable legal, regulatory, tax, accounting or other requirements. The longest period for retaining your data is 6 years from the date the matter is concluded.
In some circumstances, we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without notice.
9. YOUR LEGAL RIGHTS
You have certain rights in relation to your personal data which are summarised here:
Right to be informed and to receive clear, transparent and easily understandable information about how we use your personal data and your rights; that is why we provide you with the information in this privacy notice.
Request access to your personal data (commonly known as a ‘data subject access request’). This allows you to receive a copy of the personal data we hold about you and to verify that we are processing it lawfully.
Request correction of the personal data we hold about you. This allows you to correct any incomplete or inaccurate data we hold about you, although we may need to verify the accuracy of the new data you provide.
Request erasure of your personal data. This allows you to ask us to delete or erase personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or erase your personal data where you have successfully exercised your right to object to processing (see below), where we have unlawfully processed your information or where we need to erase your personal data to Comply with local laws. However, please note that we may not always be able to comply with your erasure request for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to the processing of your personal data where we rely on a legitimate interest (or those of a third party) and there is something in your particular situation that makes you want to object to the processing on this ground because you feel it has an impact on your rights and freedoms. You also have the right to object where we process your personal data for direct marketing purposes. In some cases, we can demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request the restriction of the processing of your personal data. This allows you to ask us to stop processing your personal data in the following scenarios:
If you want us to establish the accuracy of the data.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to retain the data even if we no longer need it because you need it to establish, exercise or defend legal claims.
You have objected to our use of your data, but we must check whether we have compelling legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide you, or a third party you have chosen, with your personal data in a structured, commonly used and machine-readable format. Please note that this right only applies to automated information that you initially gave your consent for us to use or where we use the information to enter into a contract with you.
Withdraw consent at any time where we rely on your consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide you with certain products or services. If this is the case, we will notify you at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
NO FEE REQUIRED
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.
WHAT WE MAY NEED FROM YOU
We may need to ask you for specific information to help us confirm your identity and to 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 anyone who is not entitled to receive it. We may also contact you to request further information in relation to your request to expedite our response.
TIME LIMIT FOR REPLYING
We try to respond to all legitimate requests within one month. Occasionally, it may take longer than one month if your request is particularly complex or if you have made several requests. In this case, we will notify you and keep you informed.
We will only use your personal data where we are permitted to do so by law. We will generally use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal obligation.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
Below, we set out, in table format, a description of all the ways in which we plan to use your personal data and on which of the legal bases we rely to do so. We have also identified what our legitimate interests are where applicable.
Please note that we may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please contact us if you require details of the specific legal basis we are relying on to process your personal data where more than one basis has been set out in the table below.
Purpose / Activity
Type of data
Lawful basis for processing including legitimate interest basis
To register you as a new customer
(a) Identity
(b) Contact
To perform a contract with you
To process and deliver your order, including:
(a) Handling payments, fees and charges
(b) To collect and recover monies owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts owed to us)
To manage our relationship with you, which will include:
(a) Notifying you of changes to our terms or privacy policy
(b) Asking you to leave a review or respond to a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for compliance with a legal obligation
(c) Necessary for our legitimate interests (to keep our records up to date and to study how customers use our products / services)
To allow you to complete a survey
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and to grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and data hosting)
(a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests (for the operation of our business, the provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and to measure or understand the effectiveness of the advertising we provide to you.
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Necessary for our legitimate interests (to study how customers use our products/services, develop them, grow our business and inform our marketing strategy)
Use data analytics to improve our website, products/services, marketing, customer relationships and experiences.
(a) Technical
(b) Use
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website up to date and relevant, to grow our business and inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you.
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications
Necessary for our legitimate interests (to develop our products/services and grow our business)
MARKETING
We use mailing lists to manage how we communicate with you. This allows us to record and manage how we contact you and to manage your preferences and bookings for our events.
This data helps us to ensure that our mailing list remains up to date; it also provides us with basic information about our interests and to personalise our communications with you.
PROMOTIONAL OFFERS FROM US
We may use your identity, contact, technical, usage and profile data to form an opinion about what we think you may want or need, or what may be of interest to you. This is how we decide what products, services and offers may be relevant to you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving such marketing.
THIRD PARTY MARKETING
We will obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes.
EXCLUDE
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, warranty registration, service experience or other transaction.
COOKIES
As you interact with our website, we may collect personal information about you from time to time.
We collect this personal data through the use of cookies and other similar technologies. Cookies are used to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.
A cookie is a small file of letters and numbers that we store in your browser or on your computer’s hard drive if you agree. Cookies contain information that is transferred to your computer’s hard drive.
We use cookies to help us remember and process the items in your shopping cart, understand and save your preferences for future visits, track advertisements and compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future. We use Google AdWords remarketing to advertise the Trigger across the web. AdWords remarketing will display relevant ads tailored to you based on which parts of the TriggerApp website you have viewed by placing a cookie on your machine. This cookie does not identify you in any way or give you access to your computer. The cookie is used to say ‘This person visited this page, so show them ads related to that page’. Google AdWords remarketing allows us to tailor our marketing to better suit your needs and only show ads that are relevant to you.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you would like an explanation of how processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and explain the lawful basis for allowing us to do so.
Please note that we may process your personal data without your knowledge or consent in accordance with the above rules where required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may need to share your data with third parties where required to do so by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.
Such third parties include your organisation, our own customer in a particular matter, an external service provider or third parties to whom we may choose to sell, transfer or merge parts of our business or assets. Alternatively, we may seek to acquire or merge with other businesses. If there is a change in our business, the new owners may use your personal data in the same manner as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law.
6. INTERNATIONAL TRANSFERS
We may transfer our personal information outside the EEA. If we do so, you can expect a similar level of protection in respect of your personal information.
7.DATA SECURITY
We take the security of your personal information seriously and have implemented internal controls and security measures to protect it.
We have implemented appropriate security measures to prevent your personal data from being lost, used or accessed in an unauthorised manner, altered or accidentally disclosed. Personal data will only be transferred to a data processor if it agrees to comply with those measures, or if it implements appropriate measures itself. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and are subject to a duty of confidentiality.
We have implemented procedures to deal with any suspected personal data breaches and will notify you and any applicable regulator of a breach where we are legally obliged to do so.
8. DATA RETENTION
FOR HOW LONG WILL WE USE YOUR PERSONAL DATA
We will only retain your personal data for as long as is reasonably necessary to fulfil the purposes for which we collect it, including to comply with legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe that there is a prospect of litigation in respect of our relationship with you.
In determining the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether you can achieve those purposes through other means, and any applicable legal, regulatory, tax, accounting or other requirements. The longest period for retaining your data is 6 years from the date the matter is concluded.
In some circumstances, we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without notice.
9. YOUR LEGAL RIGHTS
You have certain rights in relation to your personal data which are summarised here:
Right to be informed and to receive clear, transparent and easily understandable information about how we use your personal data and your rights; that is why we provide you with the information in this privacy notice.
Request access to your personal data (commonly known as a ‘data subject access request’). This allows you to receive a copy of the personal data we hold about you and to verify that we are processing it lawfully.
Request correction of the personal data we hold about you. This allows you to correct any incomplete or inaccurate data we hold about you, although we may need to verify the accuracy of the new data you provide.
Request erasure of your personal data. This allows you to ask us to delete or erase personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or erase your personal data where you have successfully exercised your right to object to processing (see below), where we have unlawfully processed your information or where we need to erase your personal data to Comply with local laws. However, please note that we may not always be able to comply with your erasure request for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to the processing of your personal data where we rely on a legitimate interest (or those of a third party) and there is something in your particular situation that makes you want to object to the processing on this ground because you feel it has an impact on your rights and freedoms. You also have the right to object where we process your personal data for direct marketing purposes. In some cases, we can demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request the restriction of the processing of your personal data. This allows you to ask us to stop processing your personal data in the following scenarios:
If you want us to establish the accuracy of the data.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to retain the data even if we no longer need it because you need it to establish, exercise or defend legal claims.
You have objected to our use of your data, but we must check whether we have compelling legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide you, or a third party you have chosen, with your personal data in a structured, commonly used and machine-readable format. Please note that this right only applies to automated information that you initially gave your consent for us to use or where we use the information to enter into a contract with you.
Withdraw consent at any time where we rely on your consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide you with certain products or services. If this is the case, we will notify you at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
NO FEE REQUIRED
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.
WHAT WE MAY NEED FROM YOU
We may need to ask you for specific information to help us confirm your identity and to 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 anyone who is not entitled to receive it. We may also contact you to request further information in relation to your request to expedite our response.
TIME LIMIT FOR REPLYING
We try to respond to all legitimate requests within one month. Occasionally, it may take longer than one month if your request is particularly complex or if you have made several requests. In this case, we will notify you and keep you informed.