Effective Date: May 25, 2018
Last updated: Nov 19, 2018
We take great care of the personal data we process and review everything we do with respect to how it may influence our processing of personal data. To explain how exactly personal data is processed for our purposes, we summarize the important information in the following text. Please note, this serves only as an informative text to explain how is our personal data protection designed. This Privacy Policy briefly explains and describes the procedures and security measures we adopted to process personal data in accordance with the applicable law. More specific information on how we process the personal data we need in each of our filing systems may be found here.
WHO CONTROLS THE PROCESSED PERSONAL DATA?Any personal data provided to or collected by SPONSOR.ONLINE is processed and controlled by SPONSOR ONLINE LIMITED, registered seat: 21 D'Abernon Drive, Stoke D'Abernon, Cobham, England, KT11 3JE, Company Number: 12980112 (also referred to as “SPONSOR.ONLINE”, “we”, “us” or “our”). This Privacy Policy applies to personal data collected and processed by SPONSOR.ONLINE in connection with the services and products SPONSOR.ONLINE offers. SPONSOR.ONLINE is the sole controller of the personal data. We may choose to ask our business partners to process personal data in our name, in such cases we see to it that they adopt measures just as strict as we do when processing personal data.
WHAT KIND OF PERSONAL DATA IS BEING COLLECTED?
Personal data means any information that can be used to identify directly or indirectly a specific individual. We may collect personal data from a variety of sources. This includes personal data we receive directly from the individuals, personal data we collect automatically and personal data we collect from other sources, especially from our business partners, who share bulk data with us to optimize their use of our services.
We mostly collect personal data of contact persons at our business partners (sponsors, clubs) with whom we engage in business activities. Rarely, we directly collect and process personal data of the sponsor or the athlete, if they use our services as an individual and not as a business entity.
We make sure to collect only the personal data we necessarily need for our purposes, we do not process any other personal data. This data mostly includes the contact information we need to conduct business. Other personal data we process is needed to allow our business partners (clubs and sponsors) to maximize their potential and opportunities to find an optimal marketing match. We process data of users of our website to analyze and optimize its functionality.
When possible, we collect only anonymized or pseudonymized data, especially the data we collect for marketing purposes. This data is valuable for us, but we are not able to isolate and identify an individual from the bulk data we process. Even though the law does not require us to do so, we take as good care of this data as we do of the personal data we process.
Our services do not address anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with personal data, please contact us. If we become aware that we have collected personal data from children without verification of parental consent, we remove such information from our servers.
The law recognizes companies need to process certain personal data to successfully conduct business and it states conditions a company needs to meet to be allowed to process personal data. A company may process personal data of an individual with consent of the respective individual, or under certain circumstances, even without the consent of the individual. SPONSOR.ONLINE processes personal data without the individual’s consent when such processing is necessary for the performance of a contract to which the individual is a party or in order to take steps at the request of the individual prior to entering into a contract.
SPONSOR.ONLINE also processes personal data without the individual’s consent when such processing is necessary for compliance with a legal obligation to which SPONSOR.ONLINE is subject. Finally, SPONSOR.ONLINE processes personal data without the individual’s consent when such processing is necessary for the purposes of the legitimate interests pursued by SPONSOR.ONLINE or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the individual. On occasions different from the ones stated above, SPONSOR.ONLINE processes personal data only upon the individual’s consent.
We collect, process and disclose personal data only for specific and limited purposes. For example, to connect sponsors to clubs and vice versa, to help our clients and users optimize their SPONSOR.ONLINE experience, to process payments, to assess and handle any complaints, to develop and improve our products, services, communication methods and the functionality of our website, to provide personalized products, communications and targeted advertising as well as product recommendations. When possible, we leave absolute control of the personal data disclosed by the individual for the purpose of use of our website to the individual, who chooses when to disclose personal data to other users.
We also create profiles by analyzing the information of our users about online surfing, searching, buying behaviour and interactions with our consultants. SPONSOR.ONLINE does not process personal data using automated means. An automated decision is a decision which is made solely by automatic means, where no humans are involved in the decision-making process related to personal data.
As a global business, SPONSOR.ONLINE shares personal data internally with SPONSOR.ONLINE companies affiliated to a central body located in Switzerland and with selected third-parties. For example, we share personal data with third-party service providers and other third parties where we are required to disclose personal data we collect by law (mandatory disclosures). If another entity acquires us, personal data will be disclosed to such entity as part of the due diligence process and will be transferred to such entity as one of the transferred assets. Access to your personal data is only permitted among our employees and agents on a need-to-know basis and subject to strict contractual confidentiality obligations when processed by third-parties. We use standard contractual clauses approved by the European Commission to transfer personal data from the EEA or Switzerland to third countries.
FOR HOW LONG DO WE KEEP PERSONAL DATA?We will keep your personal data for as long as we need it for the purpose it is being processed for. For example, we keep the data related to a purchase, so we can perform the specific contract and after that, we will keep the personal data for a period which enables us to handle or respond to any complaints, queries, claims or concerns relating to the purchase. We retain the identifiable data we collect directly for targeting purposes for as little time as possible, after which we employ measures to permanently delete it. We will actively review the personal data we hold and delete it securely, or in some cases anonymize it, when there is no longer a legal, business or customer need for it to be retained.
HOW DO WE SECURE THE SAFETY OF THE PROCESSED PERSONAL DATA?We adopt security measures and policies with due regard to the state of the art. Our security measures are implemented by default to any processing activity we initiate and to any filing system of personal data we create. Our security measures are implemented by design to our own conditions of personal data processing with respect to current international risk management standards in information technology. We carefully analyze potential risks related to our processing of personal data and address any risks with due care until the risk is eliminated or minimalized to an acceptable extent. Also, we limit access to our databases containing personal data to authorized persons having a justified need to access such information.
WHAT ARE THE RIGHTS OF THE INDIVIDUALS WHOSE PERSONAL DATA WE PROCESS?An individual can exercise his/her right at any time by sending an email to: info@sponsoronline.eu. Individuals have a number of rights over how their data is processed and can exercise these rights at any point. Their rights include:
We will not reduce any rights under this Privacy Policy without a previous consent.
HOW DO YOU CONTACT US?In case of any questions or concerns about our Privacy Policy or data processing or if you would like to make a complaint about a possible breach of local privacy laws, please do so by sending an e-mail to e-mail address: info@sponsoronline.eu
HOW DO WE KEEP OUR POLICIES UP TO DATE?We will update this Privacy Policy whenever necessary to reflect customer feedback and changes in our products and services. When we post changes to this statement, we will revise the “last updated” date at the top. If the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of Privacy Policy changes). We will also keep prior versions of this Privacy Policy in an archive in case of need of a review.