INTRODUCTION

Athlete Career Transition (ACT) Group Ltd respects your privacy and is committed to protecting your personal data. This Privacy Policy will inform you as to how we look after your personal data, when you visit our website (regardless of where you visit it from) or use our services and tell you about your privacy rights and how the law protects you.

Athlete Career Transition (ACT) Group Ltd is committed to the protection of personal data and the fundamental rights of data subjects, in compliance with relevant laws such as the General Data Protection Regulation (GDPR) and any data protection, electronic communications or e-privacy laws, rules or guidance that are in force in the UK from time to time, including the Data Protection Act 1998 or 2018 or any successor legislation.

In order to support a robust approach to personal data protection and information security in general, Athlete Career Transition (ACT) Group Ltd has adopted recommendations by supervisory authorities and industry best practices.

PURPOSE OF THIS PRIVACY POLICY

This Privacy Policy aims to give you information on how Athlete Career Transition (ACT) Group Ltd collects and processes your personal data through our product demo and your use of this website or our services, including any data you may provide through this website when you sign up to our services, visit our web pages or contact us.

This website and our services are 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 notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements any other notices or policies and is not intended to override them.

DEFINITIONS

In this document, we adopt the same definitions as the GDPR, in particular:

Personal data ‘means any information relating to an identified or identifiable natural personal (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person’.

Processing ‘means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction’.

Controller ‘means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law’.

Data Subject ‘means a natural person whose personal data is processed by a controller or processor’.

Processor ‘means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing’.

Personal data breach ‘means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed’.

Definitions from ISO/IEC 29134:2017 also apply, in particular:

Data protection impact assessment (DPIA), also known as privacy impact assessment, means an ‘overall process of identifying, analysing, evaluating, consulting, communicating and planning the treatment of potential privacy impacts with regard to the processing of personally identifiable information, framed within an organization’s broader risk management framework’.

ROLES AND RESPONSIBILITIES

When Athlete Career Transition (ACT) Group Ltd is responsible for your personal data and makes all the decisions about how your data is processed, we are acting as the controller. Athlete Career Transition (ACT) Group Ltd is also responsible for this website. However, when we are processing your personal data on behalf of a third party in accordance with their strict instructions, we are acting as a data processor.

In this Privacy Policy, references to Athlete Career Transition (ACT) Group Ltd, "we", "us" or "our" means Telectica Ltd. References to “you”, “your”, “yours” means you, the data subject.

We have appointed a Data Protection Officer (“DPO”) and a Data Protection Manager who are responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the DPO or data protection manager using the details set out below.

CONTACT DETAILS

Full name of legal entity: Steve Moore

Email address: Steve@athletecareertransition.com

Registered office: Athlete Career Transition (ACT) Group Ltd, Staverton Court, Cheltenham, United Kingdom, GL51 0UX

YOUR DUTY TO INFORM US OF CHANGES

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you. The type of data we collect about you depends on your relationship with us. For example, if you are a company officer or shareholder with details in our product demo, if you are a visitor to our website or a customer to our services. In all cases, we have grouped together the different kinds of data we may or are likely to collect from you:

Transaction Data which may include details about payments to and from you and other details of products and services you have purchased from us.

Technical Data which may include internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website and our product demo.

Profile Data which may include your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

Usage Data which may include information about how you use our website, products and services.

Marketing and Communications Data which may include your preferences in receiving marketing from us and our third parties and your communication preferences.

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 in law as this data does not directly or indirectly reveal your identity.

For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. 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 which will be used in accordance with this Privacy Policy.

From time to time, we may collect some Special Categories of Personal Data about you (for example, if you are an executive contained in our product demo, or if you are one of our employees) (which may include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data), as well as information about criminal convictions and offences.

Should a case arise for lawful processing Special Categories of Personal Data as set out above, we ensure that all of the appropriate safeguards are in place, including the completion of a Data Protection Impact Assessment (DPIA), the introduction of any additional organisational or technical measures to reduce the associated privacy risk to an acceptable level as well as an appropriate lawful basis for processing. In respect of DPIAs, ACT Athlete Career Transition (ACT) Group Ltd has adopted detailed procedures for conducting a DPIA and its reporting structure, in line with ISO/IEC 29134:2017.

IF YOU ARE UNABLE TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). 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 the time.

IF YOU ARE UNABLE TO PROVIDE PERSONAL DATA

How your personal data is collected will depend on your relationship with us, for example, if you are a company executive with details in our product demo, if you are a visitor to our website or a customer to our services. We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

-register for our product demo or services;

-create an account on our website;

-request marketing to be sent to you;

-enter a competition, promotion o survey; or

-give us some feedback.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

Third parties or publicly available sources. We may receive personal data about you from third parties and public sources, especially concerning company executives or other individuals contained in our product demo.

Identity and Contact Data from publicly available sources such as public corporate websites.

Where we obtain personal data from third party suppliers, we always ensure that these suppliers are bound to respect data protection laws and your privacy rights pursuant to their contract with us.

HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will 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 or with other third parties.

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 or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data including in relation to sending direct marketing communications to you via email. You have the right to opt out of marketing or ask any questions about how we process your personal data by contacting us at any time. Please use: Steve@athletecareertransition.com

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

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 need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below:

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing.

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you registered for our product demo and, in each case, you have not opted out of receiving that marketing.

OPTING OUT

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or 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 product/service purchase, product/service experience or other transactions.

COOKIES

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. For more information about the cookies we use, please see below our cookie policy.

HOW WE USE COOKIES

Our site (https://www.ACT.community) uses cookies to distinguish you from other users of our site. A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual, therefore providing a good experience whilst at the same time allowing us to improve our site. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. By accessing our site, you are consenting to us using cookies on your system. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This will prevent you from taking full advantage of the website.

TYPES OF COOKIES

Cookies fall into any of four categories:

Strictly necessary, which are required for the site's essential functions to work properly.

Performance cookies, which allow us to analyse how the site is used in order to improve it. These cookies contain no personal information that identifies a visitor, and all information collected is aggregated and therefore anonymous. By using our site, you agree that we can place these types of cookies on your device.

Functionality necessary, which allow the website to remember choices that you make, such as user name, language, etc. These cookies do not allow your browsing activity on other sites to be tracked by ACT (Telectica Ltd). When you choose to allow your browser to remember your login details, you agree that we can place these types of cookies on your device.

Targeting necessary, which are used to deliver adverts more relevant to the user and their interests. For logged in users, there are no ads served at all, so these cookies only apply to logged-out visitors.

THIRD PARTIES

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

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 wish to get an explanation as to how the 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 we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table above.

EXTERNAL THIRD PARTIES INCLUDING:

(a) Service providers acting as processors who provide IT and system administration services (b) Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services (c) HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers and who may require reporting of processing activities in certain circumstances (d) Our customers or customers (for product personal data) and for all personal data, other third parties from time to time which may include market researchers.

Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

PERSONAL DATA BREACHES

Athlete Career Transition (ACT) Group Ltd has established a personal data breach response procedure, adopting recommendations from ISO/IEC 29134:2017 and addressing privacy law requirements related to notification of personal data breaches.

DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine 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 we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for 6 years after they cease being customers for tax and legal purposes.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may 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 further notice to you.

DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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 they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

YOUR RIGHTS

Athlete Career Transition (ACT) Group Ltd shall keep records of data personal data processing activities and develop appropriate procedures to ensure it can satisfy your rights as a data subject where applicable, namely:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. The right to erasure enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on 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 certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

WHAT WE MIGHT NEED FROM YOU

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.

TIME LIMIT TO RESPOND

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 YOU ARE NOT SATISFIED

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).

We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.