Privacy Policy

THE PADBALL BOXING COMPANY LTD
PRIVACY POLICY

CONTENTS
CLAUSES SUBJECT PAGE NO.
1. INTRODUCTION AND TERMS 1
2. WHO WE ARE AND HOW TO CONTACT US 1
3. THE DATA WE COLLECT ABOUT YOU 1
4. IF YOU FAIL TO PROVIDE PERSONAL DATA 2
5. HOW IS YOUR PERSONAL DATA COLLECTED? 2
6. HOW WE USE YOUR PERSONAL DATA 3
7. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA 3
8. DISCLOSURES OF YOUR PERSONAL DATA 6
9. INTERNATIONAL TRANSFERS 6
10. HOW LONG WILL YOU USE MY PERSONAL DATA FOR? 7
11. THIRD PARTY LINKS 8
12. DATA SECURITY 8
13. APPLICATIONS TO WORK FOR US 8
14. YOUR RIGHTS 8
15. CHANGES 9
16. COMPLAINTS 10

1. INTRODUCTION AND TERMS
The Padball Boxing Company Ltd (“We” or “us”) are committed to protecting and respecting your personal data and privacy. This privacy policy relates to our use of any personal data we collect from you from any of our services. Whenever you provide such information, we are legally obliged to use your information in line with all applicable laws concerning the protection of personal data; including the Data Protection Act 1998 and 2018 (DPA), and The General Data Protection Regulation 2016 (GDPR) together, and with other subsequent laws “Data Protection Laws”.
This website is not intended for children and we do not knowingly collect data relating to children.

2. WHO WE ARE AND HOW TO CONTACT US
2.1 For the purpose of the Data Protection Laws, the data controller is The Padball Boxing Company Ltd, registered company number 10713109.
If you want to request more information about our privacy policy or information regarding data protection you should contact us using the details provided below:
FAO: Privacy Officer
14 Redbrooke Road, Camborne, Cornwall, England, TR14 7AX
Email: mikemerry@thepadballboxingcompanyltd.com
Telephone: 07513273414 and ask to speak to the Privacy Officer

3. THE DATA WE COLLECT ABOUT YOU
3.1 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).
3.2 We collect and process Personal Data. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
3.2.1 Identity Data includes first name, last name, username or similar identifier.
3.2.2 Contact Data includes billing address, delivery address, home address, email address and telephone numbers.
3.2.3 Financial Data includes bank account and payment card details.
3.2.4 Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
3.2.5 Technical Data includes internet protocol (IP) address, 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.
3.2.6 Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
3.2.7 Usage Data includes information about how you use our website, products and services.
3.2.8 Marketing and Communications Data includes your preferences in receiving marketing from us.
3.3 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 Services Data to calculate peak energy usage. 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 notice.
3.4 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.

4. IF YOU FAIL 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 our services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

5. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• apply for our products or services;
• create an account on our website;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us feedback or contact us.
Automated technologies or interactions. As you interact with our website, we will 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. Please see our cookie policy [LINK TO PRIVACY POLICY] for further details.
Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
• Technical Data from the following parties:
• analytics providers such as Google based outside the EU;
• advertising networks based inside OR outside the EU; and
• search information providers based inside OR outside the EU.
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services based
inside OR outside the EU.
• Identity and Contact Data from data brokers or aggregators based inside OR outside the EU.
• Identity and Contact Data from publicly available sources such as Companies House and the Electoral
Register based inside the EU.

6. HOW WE USE YOUR PERSONAL DATA
6.1 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.
• To notify you about changes to our services.
• To provide you with information, products or services that you request from us or which we feel may interest you (where you have consented to be contacted for such purposes or where we have identified a Legitimate Interest);
• 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.
6.2 We also embrace the use of social media and may wish to process any comments made public by you.

7. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
7.1 We have set out below, in a table format, 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.
7.2 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 list below.

Purpose/Activity:
•To register you as a new customer
Type of data:
(a) Identity
(b) Contact
Lawful basis for processing including basis of legitimate interest:
•Performance of a contract with you

Purpose/Activity:
To process and deliver your services including:

(a) Manage payments, fees and charges
(b) Collect and recover money owed to us

Type of data:
(a) Identity
(b) Contact
(c) Financial
(d) Services
(e) Marketing and Communications

Lawful basis for processing including basis of legitimate interest:
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)

Purpose/Activity:
To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey

Type of data:
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications

Lawful basis for processing including basis of legitimate interest:
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

Purpose/Activity:
To enable you to partake in a prize draw, competition or complete a survey

Type of data:
(a) Identity
(b) Contact
(c) Usage
(d) Marketing and Communications

Lawful basis for processing including basis of legitimate interest:
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to identify how customers use our services, to develop them and grow our organisation)

Purpose/Activity:
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Type of data:
(a) Identity
(b) Contact
(c) Technical

Lawful basis for processing including basis of legitimate interest:
(a) Necessary for our legitimate interests (for running our business, 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

Purpose/Activity:
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

Type of data:
(a) Technical
(b) Usage

Lawful basis for processing including basis of legitimate interest:
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

Purpose/Activity:
To make suggestions and recommendations to you about goods or services that may be of interest to you

Type of data:
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile

Lawful basis for processing including basis of legitimate interest:
(a) Necessary for our legitimate interests (to develop our products/services and grow our business)

Purpose/Activity:
To administer our payroll to our employees

Type of data:
(a) Identity
(b) Contact
(c) Financial

Lawful basis for processing including basis of legitimate interest:
(a) performance of a contract with you
(b) necessary to comply with a legal obligation

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

Promotional offers from us
If you are an existing contact or customer we will only contact you by postal and electronic means (e-mail) with information about services or goods which you have previously purchased from us or enquired about. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by post or electronic means only if you have consented to this. You can choose to not receive these types of communication by contacting us.

Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences OR 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, warranty registration, 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. All information about the cookies we use, is set out in this privacy policy.

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.

8. DISCLOSURES OF YOUR PERSONAL DATA
8.1 We will keep your information within the organisation except where disclosure is required or permitted by law or when we use third party service providers (data processors) to supply and support our services to you. We have contracts in place with our data processors. This means that they cannot do anything with your personal data unless we have instructed them to do so. They will not share your personal data with any organisation apart from us. They will hold it securely and retain it for the period we instruct.
8.2 Please see below the list which sets out the categories of recipients of personal data.
SERVICE PROVIDED
IT Support Services
Email Provider
Accountancy provider
Solicitors
distribution companies (in the form of your name address only)
8.3 We may also share your 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.
8.4 We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

9. INTERNATIONAL TRANSFERS
We share your personal data (name and address only) with the distribution company. This will involve transferring your data outside the European Economic Area (EEA)
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

10. HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any 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 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.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see Your Rights below 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.

11. 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 notice of every website you visit.

12. DATA SECURITY
12.1 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.
12.2 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.

13. APPLICATIONS TO WORK FOR US
If you apply to work for us (directly or indirectly) in any role (including volunteers) we may receive data about you from third parties. In addition, we will keep the details of your application and any additional information provided to us by you or others during your application so that we can keep you informed of future opportunities that you may be interested in. If you do not wish for us to keep your details for this reason, please let us know by.

14. YOUR RIGHTS
14.1 Under the Data Protection Laws your rights are:
14.1.1 To be informed – We must make this privacy policy (sometimes referred to as a privacy notice) available with the emphasis on transparency over how we process your data.
14.1.2 Access – You are entitled to find out what details we may hold about you and why. We strive to be as open as we can be in terms of giving people access to their personal data. Individuals can find out if we hold any of their Personal Data by making a formal request under the Data Protection Laws. Such requests should be in writing to the contact details provided in this policy. In the instance that we do not hold information about you we will confirm this in writing at the earliest opportunity. If we do hold your personal data we will respond in writing within one calendar month of your request (where that request was submitted in accordance with this policy). The information we supply will:
(a) confirm that your data is being processed;
(b) verify the lawfulness and the purpose of the processing;
(c) confirm the categories of personal data being processed;
(d) confirm the type of recipient to whom the personal data have been or will be disclosed; and
(e) let you have a copy of the data in an intelligible form.
14.1.3 Rectification – We are obliged to correct or update your details. We will correct or update your data without delay provided you make the request in writing to the contact details provided in this policy, clearly specifying which data is incorrect or out of date.
14.1.4 Erasure – This is also known as the request to be forgotten. Under Data Protection Laws you have the right to erasure under specific circumstances. A request for your personal data to be deleted will be decided on a case by case basis and should be submitted in writing to the contact details provided in this policy.
14.1.5 Restrict processing – You have the right to ‘block’ or suppress the processing by us of your personal data.
14.1.6 Portability – You have the right to obtain and reuse your personal data that you have provided to us.
14.1.7 Object – You have the right to object to us processing your data in relation to direct marketing and or profiling.
14.1.8 Rights in relation to automated decision making and profiling – We do not use automatic decision making or profiling.
14.2 Please note that you may need to provide identification in order to prove who you are if you wish to invoke any of your rights as provided by the Data Protection Laws and as summarised above.
14.3 If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.

15. CHANGES
We keep our privacy policy under regular review and you should check back regularly to ensure you are aware of changes to it. We may display this notice to you from time to time to help ensure you are aware of its contents.

16. COMPLAINTS
You have the right to complain about the processing of your personal data. Please contact us using the details provided above. If you are still unsatisfied you have the right to complain to the
Information Commissioners Office. https://ico.org.uk/