PLAYER LENS PRIVACY POLICY

last updated on 24th May, 2018

Player Lens Ltd (“we”) are committed to protecting and respecting your privacy

This policy (together with our Terms of Use and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By using our website, application or other online services (our Service), you are accepting and consenting to the practices described in this policy.

For the purpose of the Data Protection Act 1998 (the Act) and the General Data Protection Regulation (GDPR), the data controller is Player Lens Ltd of Lakeview House, 4 Woodbrook Crescent, Billericay, Essex CM12 0EQ.

Our nominated representative for the purpose of the Act and the GDPR is Lee Hemmings, and he can be reached at lee@playerlens.com.

Distribution of player information is a core function of our business. If you are player and you submit your information to us (or if you are a club and you submit information about one of your players), we will share that information with other clubs that we believe will be interested in your player availability. If you do not wish to have player personal information shared with other clubs, you must not use our Services. If you are a club, you warrant and represent that you will treat any and all player information shared with you in compliance with the Act and the GDPR.

INFORMATION WE COLLECT FROM YOU
We will collect and process the following data about you:
  • Information you give us. This is information about you that you give us by filling in forms on our site www.playerlens.com (“our site”) or by corresponding with us by phone, e-mail or otherwise. It includes information that you provide when registering as a user of our Service such as your name, address, email address, telephone number, job title, financial information and your employer’s details. It also includes information you provide when you participate in discussion boards or other social media functions as part of our Service and when you report a problem with our Service (if applicable).
  • Information we collect about you. With regard to each use of our Service we will automatically collect the following information:
    • Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, device ID and type, the operating system used by your device and access times; and
    • Information about your use of our Service, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time),page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page and any phone number used to call us.
    • Information we receive from other sources. This is information we receive about you if you use any of the other websites we operate or the other services we provide. We work closely with third parties (including, for example, business partners, sub-contractors in technical, payment services, advertising networks, analytics providers, search information providers and credit reference agencies). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.
    This data is necessary for our legitimate interests and for us to fulfill our contractual obligations to you, and we rely on this as a lawful basis to use and process the data described above.
COOKIES

When you visit our Service, we may assign your device one or more cookies or other technologies that distinguish you from other users of our Service. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. If you are using our mobile application, we use mobile device IDs (the unique identifier assigned to a device by the manufacturer), or Advertising IDs (for iOS 6 and later), instead of cookies, to recognize you. We do this to store your preferences and track your use of our app. Unlike cookies, device IDs cannot be deleted, but Advertising IDs can be reset in “Settings” on your Phone.

USES MADE OF THE INFORMATION
We use information held about you in the following ways:
  • Information you give to us. We will use this information:
    • To carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
    • To provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
    • To provide you, or permit selected third parties to provide you, with information about services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data (the registration form);
    • To notify you about changes to our services; and
    • To ensure that content from our Service is presented in the most effective manner for you and for your computer.
  • Information we collect about you. We will use this information:
    • To administer our Service and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
    • To improve our Service to ensure that content is presented in the most effective manner for you and for your computer;
    • To allow you to participate in interactive features of our Service, when you choose to do so;
    • As part of our efforts to keep our Service safe and secure;
    • To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; and
    • To make suggestions and recommendations to you and other users of our Service about goods or services that may interest you or them.
  • Information we receive from other sources. We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
DISCLOSURE OF YOUR INFORMATION

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

As we mentioned above, distribution of player information is a core function of our business. If you are a player and you submit your information to us (or if you are a club and you submit information about one of your players), we will share that information with other clubs that we believe will be interested in your player availability.

We use Perform Group (Opta Pro) to provide player profiles, to support the functionality of our exchange and to allow clubs to profile players in our taking environment. We also use Amazon Web Services as our cloud storage provider, and Pipedrive for customer relationship management (CRM). These third parties have access to the personal information we share with their platforms.

Additionally, you agree that we have the right to share your personal information with:

  • Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
  • Selected third parties including:
    • Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
    • Analytics and search engine providers that assist us in the improvement and optimisation of our site; and
    • Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
We will disclose your personal information to third parties:
  • In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
  • If Player Lens Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms of Use and other agreements; or to protect the rights, property, or safety of Player Lens Ltd , our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

INTERNATIONAL TRANSFERS

The data that we collect from you is transferred to, and stored at, a destination outside the European Economic Area (EEA). By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated as securely as it would be within the EEA and under the GDPR. Such steps may include our entering into contracts with any third parties we engage and the use of Commission-approved Model Contractual Clauses. 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.

You can obtain more details of the protection given to your personal data when it is transferred outside Europe (including a copy of the standard data protection clauses which we have entered into with recipients of your personal data) by contacting us at contact@playerlens.com or at 1 Primrose Street, London EC2A 2EX.

HOW WE STORE AND SECURE YOUR PERSONAL DATA

The data that we collect from you is transferred to, and stored at, a destination outside the European Economic Area (EEA). By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated as securely as it would be within the EEA and under the GDPR. Such steps may include our entering into contracts with any third parties we engage and the use of Commission-approved Model Contractual Clauses. 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.

You can obtain more details of the protection given to your personal data when it is transferred outside Europe (including a copy of the standard data protection clauses which we have entered into with recipients of your personal data) by contacting us at contact@playerlens.com or at 1 Primrose Street, London EC2A 2EX.

HOW LONG WE STORE YOUR DATA

We only keep your personal information for as long as it’s necessary for our original legitimate purpose for collecting the information and for as long as we have your permission to keep it. We will delete your personal information when you delete your account by emailing contact@playerlens.com.

YOUR RIGHTS

We will ensure that your personal data is processed lawfully, fairly, and transparently and that it will only be processed if at least one of the following bases applies:

  • You have given your clear consent to the processing of your personal data for a specific purpose.
  • Processing is necessary for the performance of a contract to which you are a party (or for us to take steps at your request prior to entering into a contract with you).
  • Processing is necessary for our compliance with the law.
  • Processing is necessary to protect someone’s life.
  • Processing is necessary for us to perform a task in the public interest or in the exercise of official authority and the task/function has a clear basis in law.
  • Processing is necessary for our legitimate interests or the legitimate interests of a third party, except where there is a good reason to protect your personal data which overrides those legitimate interests, such as allowing us to effectively and efficiently manage and administer the operation of our business, maintaining compliance with internal policies and procedures, monitoring the use of our copyrighted materials, offering optimal, up-to-date security and obtaining further knowledge of current threats to network security in order to update our security.

Under the GDPR, you have the right to:

  • Withdraw your consent to the processing of your personal data at any time. Please note, however, that we may still be entitled to process your personal data if we have another legitimate reason for doing so (such as to comply with a legal obligation).
  • Be informed of what data we hold and the purpose for processing the data, as a whole or in parts.
  • Be forgotten and, in some circumstances, have your data erased by ourselves and our affiliates (although this is not an absolute right and there may be circumstances where you ask us to erase your personal data but we are legally entitled to retain it).
  • Correct or supplement any information we hold about you that is incorrect or incomplete.
  • Restrict processing of the information we hold about you (for example, so that inaccuracies may be corrected—but again, there may be circumstances where you ask us to restrict processing of your personal data but we are legally entitled to refuse that request).
  • Object to the processing of your data.
  • Obtain your data in a portable manner and reuse the information we hold about you.
  • Challenge any data we use for the purposes of automated decision-making and profiling (in certain circumstances—as above, there may be circumstances where you ask us to restrict our processing of your personal data but we are legally entitled to refuse that request).
  • Complain to a supervisory authority (e.g. the Information Commissioner’s Office (ICO) in the UK) if you think any of your rights have been infringed by us. (We would, however, appreciate the chance to address your concerns, so please contact us prior to taking this step).

You will not have to pay a fee to access your personal data (or to exercise any of the other rights) unless your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

You may revoke your consent for us to use your personal data as described in this Privacy Policy at any time by contacting us at contact@playerlens.com or at 1 Primrose Street, London EC2A 2EX, and we will delete your data from our systems. To enforce any of the above rights, please contact us at contact@playerlens.com or at 1 Primrose Street, London EC2A 2EX.

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at contact@playerlens.com or at 1 Primrose Street, London EC2A 2EX.

Our Service may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

We will notify you and any applicable regulator of a breach of your personal data when we are legally required to do so.

ACCESS TO INFORMATION

The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request will be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.

CHANGES TO OUR PRIVACY POLICY

Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

CHANGES TO OUR PRIVACY POLICY

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to contact@playerlens.com.

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