1.1 Important information and who we are
Welcome to Padel4all Limited’s Privacy and Data Protection Policy (“Privacy Policy”).
At Padel4all Limited (“we”, “us”, or “our”) we are committed to protecting and respecting your privacy and Personal Data in compliance with the United Kingdom General Data Protection Regulation (“GDPR”), the DPA 2018 and all other mandatory laws and regulations of the United Kingdom.
This Privacy Policy explains how we collect, process and keep your data safe. The Privacy Policy will tell you about your privacy rights, how the law protects you, and inform our employees and staff members of all their obligations and protocols when processing data.
The individuals from which we may gather and use data can include:
- Customers
- Suppliers
- Business contacts
- Employees/Staff Members
- Third parties connected to your customers
and any other people that the organisation has a relationship with or may need to contact.
This Privacy Policy applies to all our employees and staff members and all Personal Data processed at any time by us.
1.2 Who is Your Data Controller
Padel4all Limited is your Data Controller and responsible for your Personal Data. We are not obliged by the GDPR to appoint a data protection officer and have not voluntarily appointed one at this time. Instead, we have appointed a data privacy manager who is 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 data privacy manager by email at play@padel4all.com or by post to 35 Shearing St, Bury St Edmunds, Suffolk, IP32 6FE, United Kingdom.
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.
2.1 Types of Data / Privacy Policy Scope
“Personal Data” 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 which we have grouped together below. Not all of the following types of data will necessarily be collected from you but this is the full scope of data that we collect and when we collect it from you:
- Profile/Identity Data: This is data relating to your first name, last name, gender, date of birth.
- Contact Data: This is data relating to your phone number, addresses, email addresses, phone numbers.
- Marketing and Communications Data: This is your preferences in receiving marketing information and other information from us.
- Financial Data: These are your banking details e.g. your account number and sort code.
- Transactional Data: This is information of details and records of all payments you have made for our services or products.
- Technical Data: This is your IP address, browser type and version, time zone setting and location, operating system and platform, and other technology on the devices you use to engage with us.
- Customer Support Data: This includes feedback and survey responses.
- Usage Data: information about how you use our website, products and services.
We also collect, use and share Aggregated Data such as how often customers book to play. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. 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.
We may also aggregate data to enable research or analysis so that we can better understand and serve you and others. For example, we may conduct research on your demographics and usage. Although this aggregated data may be based in part on Personal Data, it does not identify you personally. We may share this type of anonymous data with others, including service providers, our affiliates, agents and current and prospective business partners.
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, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
2.2 The Legal Basis for Collecting That Data
There are a number of justifiable reasons under the GDPR that allow collection and processing of Personal Data. The main avenues we rely on are:
- “Consent”: Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy to receive email newsletters from us, or ‘opt in’ to a service.
- “Performance of a contract”: We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service.
- “Legal obligation”: We’re required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions.
- “Legitimate Interest”: We might need to collect certain information from you to be able to meet our legitimate interests – this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests. Examples could be your address, so that we know where to deliver something to, or your name, so that we have a record of who to contact moving forwards.
3.1 Our Uses
We will only use your Personal Data when the law allows us to. Set out below is a table containing the different types of Personal Data we collect and the lawful basis for processing that data. Please refer to section 2.2 for more information on the lawful basis listed in the table below.
Examples provided in the table below are indicative in nature and the purposes for which we use your data may be broader than described but we will never process your data without a legal basis for doing so and it is for a related purpose. For further inquiries please contact us.
- When a user signs up and creates an account, Contact Data is collected on the lawful basis of:
(a) Consent: You will need to include Personal Data when filling in the Company profile on the platform so the content you create is linked to your profile.
(b) Contractual Obligation: In order to use our Platform you need to contract with us so this data is necessary to form the contract between us.
(c) Legitimate Interest: We need to understand where you are logging in from so we know whether you can take advantage of our services, and what browser you are using so we can understand our customer demographic to help diagnose service provision issues, to keep our records up-to-date and analyse how customers use our services. - User makes a booking on the Website, Transactional Data is collected on the lawful basis of:
(a) Consent: You will need to include Personal Data when filling in a booking on the Platform so the content you create is linked to your profile. We will retain the name that is stated on the credit/debit card you enter into our Stripe API (via Playtomic) but all other card details are stored by them and not retained by us.
(b) Contractual Obligation: In order to use our Platform you need to contract with us so this is necessary to form the contract between us. We need to retain your Transactional Data so that we can comply with our legal obligation to send you an invoice following a purchase.
(c) Legitimate Interest: We need to know who you are so that we know who to deliver the service to once it has been purchased (i.e. give access to a court). It also enables us to provide support to the right individual in case there is an issue with court access or anything else. - To use data analytics to improve our website, products /services, marketing, customer relationships and experiences, Technical Data is collected on the lawful basis of:
(a) Legitimate interest: To define types of customers for our products and services, to keep our Site and Platform updated and relevant, to develop our business and to inform users about marketing strategy. - When a User uses our live chat support and voluntarily leaves their email address or has previously logged into the Platform, Contact Data is collected on the lawful basis of:
(a) Consent: We ask you for your email so we can easily get back in touch with you and connect the conversation history to an individual. It also allows us to register you as a User to be able to enter into a contract with you.
(b) Legitimate Interest: We need to understand where you are logging in from so we know whether you can take advantage of our services, and what browser you are using so we can understand our customer demographic to help diagnose service provision issues, to keep our records up-to-date and analyse how customers use our services. - When a user signs up to a session or event, Profile/Identity Data is collected on the lawful basis of:
(a) Legitimate Interest: We display participant names for sessions and events to enable you to view the other participants, facilitating a more social playing environment. - When a Padel4all member (PadelPlus or Off-PeakPlus) makes a court booking they can select the name of another member as a participant to that booking from a dropdown member list. Profile/Identity Data is collected and shown on the lawful basis of:
(a) Legitimate Interest: We display a list of member names to members who book courts to enable the court to be charged at the correct rate. Displaying the names allows us to ensure that the correct per person rates are applied for each court booking.
3.2 Marketing and Content Updates
You will receive marketing and new content communications from us if you have created an account and chosen to opt into receiving those communications. From time to time we may make suggestions and recommendations to you about goods or services that may be of interest to you.
3.3 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.
4.1 What Control Do I Have Over Padel4all Limited’s Use Of My Personal Data?
You may delete your account at any time – this will remove your account page from our systems and our related software.
We guarantee this will delete all stored data.
Your account information will be protected by a password for your privacy and security. You need to prevent unauthorized access to your account and personal information by selecting and protecting your password appropriately and limiting access to your computer or device and by signing off after you have finished accessing your account.
You can access information associated with your account by logging into your account you created with us.
Your account information will be protected by a password for your privacy and security. You need to prevent unauthorized access to your account and personal information by selecting and protecting your password appropriately and limiting access to your computer or device and by signing off after you have finished accessing your account.
California Privacy Rights: Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to play@padel4all.com.
4.2 How Does Padel4all Limited Protect Customers’ Personal Data?
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.
4.3 Opting Out Of Marketing Promotions
You can ask us to stop sending you marketing messages at any time by replying saying “unsubscribe” or clicking the “unsubscribe” button at the bottom of our communications.
Where you opt out of receiving these marketing messages, we will continue to retain other Personal Data provided to us as a result of interactions with us not related to your marketing preferences.
4.4 How to Request your Data and the Process for Obtaining it
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, if your request is clearly unfounded, we could refuse to comply with your request.
We may need to request specific information from you to help us confirm your identity and ensure you have the 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.
5.1 Will We Share Your Data With Third Parties?
We may share Personal Data with 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. We may share your Personal Data at any time if required for legal reasons or in order to enforce our terms.
We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your Personal Data for a longer period than usual in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
In some circumstances you can ask us to delete your data, please contact us for further information.
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 further notice to you.
You must not use Padel4all Limited unless you are aged 16 or older. If you are under 16 and you access Padel4all Limited by lying about your age, you must immediately stop using Padel4all Limited. This website is not intended for children and we do not knowingly collect data relating to children.
Your information may be stored and processed in the US or other countries or jurisdictions outside the US where Padel4all Limited has facilities. We are currently storing data in the EU and so you are permitting and consenting to the transfer of information, including Personal Data, outside of the US.
We keep our Privacy Policy under review and will place any updates on this webpage. This version is dated 1 January 2021. 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.
All uses of the word “including” mean “including but not limited to” and the enumerated examples are not intended to in any way limit the term which they serve to illustrate.