Waffle Sport Privacy Notice
WHAT THIS PRIVACY NOTICE IS FOR
Waffle Sport provides live-streaming devices to cricket clubs. This policy is intended to provide information about how Waffle Sport will use (or "process") personal data about individuals including: its staff; its customers (both past, current and prospective) and all who interact with the company. Collectively, we refer to these individuals /customers as Waffle Sport’s community.
This information is provided because Data Protection Law gives individuals rights to understand how their data is used. Everyone is encouraged to read this Privacy Notice and understand the company’s obligations to its entire community.
This Privacy Notice applies alongside any other information the company may provide about a particular use of personal data, for example when collecting data via an online or paper form.
This Privacy Notice also applies in addition to the company’s other relevant terms and conditions and policies, including:
any contract between Waffle Sport and its customers;
Waffle Sport’s Data Retention & Destruction Of Records Policy.
Anyone who works for, or acts on behalf of, Waffle Sport (including staff, volunteers, investors and service providers) should also be aware of and comply with this Privacy Notice as well as any current or sample contracts which also provides further information about how personal data about those individuals will be used.
RESPONSIBILITY FOR DATA PROTECTION
Waffle Sport has appointed a lead for data protection and this person reports directly to the Company Director. For more information, please contact Waffle Sport using the below details:
Mr Benjamin Lester
WHY WAFFLE SPORT NEEDS TO PROCESS PERSONAL DATA
In order to carry out its ordinary service to its customers, the company needs to process a wide range of personal data about individuals (including current, past and prospective customers) as part of its daily operation.
Some of this activity Waffle Sport will need to carry out in order to fulfil its legal rights, duties or obligations – including those under a contract with Waffle Sport.
Other uses of personal data will be made in accordance with Waffle Sport’s legitimate interests, or the legitimate interests of another, provided that these are not outweighed by the impact on individuals, and provided it does not involve special or sensitive types of data.
TYPES OF PERSONAL DATA PROCESSED BY THE COMPANY
Account registration and administration of your Waffle Sport account (in which case we collect the following categories of personal data: Name, contact number and email address)
Uploads or posts to the Services (in which case we collect the following categories of personal data: any Personal Data included within the content that you upload or post)
Customer support and technical assistance (in which case we collect the following categories of personal data: Name, postal address, geo-location, telephone number and email address)
Processing your order for products or Services offered by Waffle Sport (in which case we collect the following categories of personal data: Name, postal address, billing address, payment details, telephone number and email address)
Newsletter subscriptions (in which case we collect the following categories of personal data: Name, postal address and email address)
Access to Waffle Sport products or Services on social networks or third-party services (in which case we collect the following categories of personal data: Those categories of data that you provide in accordance with your settings on the social networks or third party services)
HOW WAFFLE SPORT COLLECTS DATA
Generally, Waffle Sport receives personal data from the individual customer directly. This may be via a form, or simply in the ordinary course of interaction or communication (such as email or written communication).
However in some cases, personal data will be supplied by third parties (for example another company or club, or other professionals or authorities working with that individual); or collected from publicly available resources such as Twitter, Instagram, Facebook and Club Website.
WHO HAS ACCESS TO PERSONAL DATA AND WHOM WAFFLE SPORT SHARES IT WITH
Occasionally, Waffle Sport will need to share personal information relating to its community with third parties, such as:
professional advisers (e.g. lawyers and marketing/social media advisers)
social media platforms such as Facebook/Twitter/Instagram all maintained by Waffle Sport.
For the most part, personal data collected by Waffle Sport will remain within the company and will be processed by appropriate individuals only in accordance with access protocols (i.e. on a ‘need to know’ basis). Particularly strict rules of access apply in the context of:
records containing names/addresses/contact details/locations; and
bank account/payment details.
HOW LONG WE KEEP PERSONAL DATA
Waffle Sport will retain personal data securely and only in line with how long it is necessary to keep for a legitimate and lawful reason. Typically, the legal recommendation for how long to keep ordinary general series files is up to 7 years following departure from the company. However, some files/data series may be kept for longer depending on their value and interest to the company. If a data file is to be kept for longer than the retention period, all relevant parties will be informed and given a right to erasure.
If you have any specific queries about how our retention policy is applied, or wish to request that personal data that you no longer believe to be relevant is considered for erasure, please contact Waffle Sport on the contact details at the top of this policy. However, please bear in mind that the company will often have lawful and necessary reasons to hold on to some personal data even following such request.
A limited and reasonable amount of information will be kept for archiving purposes, for example; and even where you have requested we no longer keep in touch with you, we will need to keep a record of the fact in order to fulfil your wishes (called a "suppression record").
KEEPING IN TOUCH AND SUPPORTING WAFFLE SPORT
Waffle Sport will use the contact details of its community to keep them updated about the activities of Waffle Sport, including by sending updates and newsletters, by email and by post. Unless the relevant individual objects, the company will also:
Post regular updates on social media platforms using example images/footage from fixtures streamed using Waffle Sport
Contact customers about their activity and experience when using Waffle Sport
Collect information from publicly available sources such as websites and social media
Should you wish to limit or object to any such use, or would like further information about them, please contact Waffle Sport in writing. You always have the right to withdraw consent, where given, or otherwise object to direct marketing or fundraising. However, the company is nonetheless likely to retain some of your details (not least to ensure that no more communications are sent to that particular address, email or telephone number).
Rights of access, etc.
Individuals have various rights under Data Protection Law to access and understand personal data about them held by the company, and in some cases ask for it to be erased or amended or have it transferred to others, or for the company to stop processing it – but subject to certain exemptions and limitations.
Any individual wishing to access or amend their personal data, or wishing it to be transferred to another person or organisation, or who has some other objection to how their personal data is used, should put their request in writing to Waffle Sport.
Waffle Sport will endeavour to respond to any such written requests as soon as is reasonably practicable and in any event within statutory time-limits (which is one month in the case of requests for access to information, but actually fulfilling more complex requests may take 1-2 months longer).
Waffle Sport will be better able to respond quickly to smaller, targeted requests for information made during term time. If the request for information is manifestly excessive or similar to previous requests, the company may ask you to reconsider or require a proportionate fee (but only where Data Protection Law allows it).
Requests that cannot be fulfilled
You should be aware that the right of access is limited to your own personal data, and certain data is exempt from the right of access. This will include information which identifies other individuals or information which is subject to legal privilege (for example legal advice given to or sought by the company, or documents prepared in connection with a legal action).
You may have heard of the "right to be forgotten". However, we will sometimes have compelling reasons to refuse specific requests to amend, delete or stop processing your personal data: for example, a legal requirement, or where it falls within a legitimate interest identified in this Privacy Notice. All such requests will be considered on their own merits.
DATA ACCURACY AND SECURITY
Waffle Sport will endeavour to ensure that all personal data held in relation to an individual or club is as up to date and accurate as possible. Customers must please notify the company of any significant changes to important information, such as contact details, held about them.
An individual has the right to request that any out-of-date, irrelevant or inaccurate or information about them is erased or corrected (subject to certain exemptions and limitations under Data Protection Law): please see above for details of why the company may need to process your data and of whom you may contact if you disagree.
Waffle Sport will take appropriate technical and organisational steps to ensure the security of personal data about individuals, including policies around the use of technology and devices, and access to systems that hold personal and sensitive data. All Waffle Sport staff will be made aware of this policy and their duties under Data Protection Law and receive relevant training ahead of handling customers data.
QUERIES AND COMPLAINTS
Any comments or queries on this policy should be directed to Waffle Sport using the contact details below:
Mr Benjamin Lester
If an individual believes that Waffle Sport has not complied with this policy or acted otherwise than in accordance with Data Protection Law, they can make a referral to or lodge a complaint with the Information Commissioner’s Office (ICO), although the ICO recommends that steps are taken to resolve the matter with the company itself before involving the regulator.
Updated May 2019
To Be Reviewed May 2020