SPORTS TRADING MEDIA LTD PRIVACY AND DATA SECURITY POLICY

As you may know data protection laws are changing in the UK [General Data Protection Regulation (“GDPR”) May 25, 2018], and as such we are providing an up to date description of how we use your data, the ways in which it is shared, and your rights over your data. If you no longer wish to receive the newsletters or communications, you can unsubscribe with the link provided.

Business Privacy Policy

Sports Trading Media Ltd, respects your privacy and is committed to protecting your personal data, this privacy policy sets out how we use and protect any information that you give us when you interact with us by visiting our web sites, opening our emails, making a purchase, or other form of direct communication.

Who we are and other Important Information?

Sports Trading Media Ltd is committed to ensuring that your privacy is protected. Should we ask you to provide information by which you can be identified when using this web site, then you can be assured that it will only be used in accordance with this privacy statement.

This web site is not intended for children (those under the age of 18), and we do not knowingly collect data relating to children.

If you are under the age of 18 you must leave this site immediately. Fraudulent use of this web site may make you subject to civil or criminal sanctions.

We do not collect sensitive data such as ethnic origin, religious beliefs, and medical issues.

Sports Trading Media Ltd may change this policy from time to time by updating this page and will inform you when updates have occurred using a ‘pop up’ banner on the Web Site. You should check this page from time to time to ensure that you are happy with any changes. This policy was last updated on 27^th August 2019.

Contact Details

Our details are:

Sports Trading Media Ltd, registered in the UK company number 12069310.
Our registered office is: 106 MARGUERITE DRIVE, LEIGH-ON-SEA, ENGLAND, SS9 1NW
Our Postal Address is: 106 MARGUERITE DRIVE, LEIGH-ON-SEA, ENGLAND, SS9 1NW
You can contact us by email: gladiatortrading27@gmail.com

We always appreciate the chance to deal with any concerns you may have relating to your data before you approach the Information Commissioner’s Office (ICO. Please contact us in the first instance and we will be happy to help you. However, you have the right to make a complaint at any time to the ICO. Please read https://ico.org.uk/your-data-matters/ for further details.

Your Duty to Us

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

Third Party Links

This web site may include links to third-party web sites, 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 third-party web sites and are not responsible for their privacy statements. If you leave our web site, please refer to and read the Privacy Policy of every web site you visit.

How we collect your Personal Data

We collect your Personal Data via direct interaction with you when you:

• Visit our web sites and sign up for a newsletter;
• Purchase a product or service from us;
• Opt in to a free subscription service from us;
• Request to be kept aware of our services;
• Give us feedback;
• Interact with our web sites;
• Open marketing emails we have sent you.

We may also collect anonymous data when you visit our websites without using a password or login. Such data is not classed as personal data because you cannot be identified from it.

What We Collect

Personal Data means any information about an individual from which that person can be identified.

We may collect, use, store, and transfer the following information about you (we have grouped the data we collect as follows, to enable ease of understanding):

1. Identity Data: Your first and last name, including any title
2. Contact information: Including your billing address, delivery address, email address and telephone number
3. Financial Data: We do not store or process your card details ourselves. They are processed and stored via a contracted third-party service provider, who encrypt your payment card details. We are unable to see your full credit card details.
4. Transaction Data: Details about transactions you have made including payments to us along with other details of product and services you have purchased from us. As well it is also stored by a contracted third-party service provider who is GDPR compliant.
5. Profile Data: Your username and password, your login data, purchases or orders made by you, your interests, preferences, feedback and survey responses.

What we do with the information we gather

We require the information we gather to understand your needs and provide you with a better service for the following reasons:

• To perform the contract, we are about to enter or have entered into with you.
• 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.
• Internal record keeping.
• We may use the information to improve our products and services.
• We may periodically send promotional emails and postal mailings about new products, special offers or other information which we think you may find interesting using the email and postal addresses which you have provided. This may include information about products available from other 3^rd parties.
• We may contact you if we have a financial query relating to any purchases you have made from us
• We may contact you if we have a customer service-related issue to discuss with you.
• From time to time, we may also use your information to contact you for market research purposes. We may contact you by email or post. We may use the information to customise the web site according to your interests. We do not store your credit card details. They are processed and stored via a contracted third-party service provider, who encrypt your payment card details. We are unable to see your full credit card details.

Generally, we do not rely on consent as a legal basis for processing your personal data, unless you have not purchased a product from us but have specifically requested that we send you information or marketing material.

Where we rely on legitimate interest as the lawful basis for processing your personal data, we will consider and balance any potential impact on you before we process such data for our legitimate interests. In such cases where our interests would be outweighed by the impact on you, we do not process your personal data, unless there is another lawful basis for us to do so, such as consent, or to comply with a legal or regulatory obligation.

We do not conduct online behavioural tracking of our customers.

We will only use your personal data for the purpose for which we collected it, unless we need to use it for another reason which is compatible with the original purpose.

If we need to use your personal data for a purpose which is unrelated to the reason it was collected, we will notify you and explain the legal basis on which we can use it.

In some rare cases, we may process your personal data without your knowledge or consent. This would only be done as required or permitted by law, such as if we are instructed to process your data by Court Order, as part of a criminal investigation, or similar.

Marketing

We will usually only send you marketing, which may be in the form of a letter through the post, or by email, if you have previously purchased a product or service from us or as the result of a historical joint promotion with another Company in which case we consider there is a legitimate interest for us to process your data and send you information.

If you have not previously purchased from us, but have specifically requested to receive information from us, then you have consented to us sending such information and we rely on your express consent in order to process your data.

In cases where we consider there is a legitimate interest for us to send you such information, we continually review the basis for this interest. Should we discover that you have not opened any emails from us for a long time, or if a postal mailing is returned with person unknown at the address for example, then we will stop processing your personal information and will remove your details from our database unless there is a legitimate basis for us to keep it.

In the case where we send you a marketing communication, it may be necessary for us to pass your personal details to a third party in order to send such communication. For example, we may need to pass your Identity Data, and your Contact Data, to our printers in order to have letters and envelopes printed with your name and address. Where it is necessary for us to do this, we will do our best to ensure your personal data is processed securely. We only use suppliers who are GDPR compliant.

Opting Out of Marketing

You can opt out of receiving marketing communications from us at any time. To opt out of our email communications, simply ‘unsubscribe’ using the link provided on one of our emails or email us at gladiatortrading27@gmail.com

Security

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

In the case of a data breach or suspected data breach, we have put procedures in place to deal with such a situation swiftly and will notify you and any applicable regulatory organisation where we are legally required to do so.

Please be aware that the internet can never be a completely secure medium for communication. We cannot guarantee the security of information you send to us, or which we send to you, via the internet. We are not responsible for any damage which you, or others, may suffer as a result of the loss of confidentiality of such information, save in such cases as we have used your data illegally or failed in our duty to keep it secure to the best of our ability.

Length of Retention of Personal Data

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

In some circumstances you may be able to ask us to delete your data. In some cases where deletion is not legally possible, we may still be able to anonymise your data

Your Legal Rights

You have the right to:

Request access to your personal data. You will receive a copy of the personal data we hold about you and you can check that we are processing it on a lawful basis.

Correct or update the personal data we hold about you in order to ensure accuracy.

Request that we erase your personal data, unless there is a legal reason which overrides your request. In cases where we are unable to erase your personal data because there is a legal obligation for us to process it, you can request that we restrict our processing of your data to only those functions lawfully required. This may be that some, but not all, of the personal data we hold can be erased.

Object to our processing of your personal data if we are relying on the basis of legitimate interest and you feel that your fundamental rights and freedoms override our legitimate interest.

Withdraw your consent for us to process your personal data, in the case where we are relying on consent as the lawful basis for us to process your data. This will not affect the lawfulness of any processing carried out before you withdraw your consent.

If you wish to exercise any of these rights, please contact us in writing by emailing us at gladiatortrading27@gmail.com

You will not normally have to pay a fee to access your personal data, unless your request is clearly unfounded, repetitive, or excessive. In such cases we may either charge a fee or refuse your request.

Data access requests will normally be responded to within one month, unless your request is extremely complex or if you make several separate and updated requests. We will remain in contact with you to update you of any ongoing delays and the reasons for these.

Your Personal Information

We will not sell, lease or distribute your personal data to third parties unless we are required by law to do so. We may use your personal information to send you promotional information about third parties which we think you may find interesting unless you tell us that you do not wish for this to happen.

You may request details of personal information which we hold about you under the Data General Data Protection Regulation (GDPR) (EU) 2016/679. If you would like a copy of the information held on you, or have any other related query, please send an email to gladiatortrading27@gmail.com

If you believe that any information, we are holding on you is incorrect or incomplete, please email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.

Questions, Comments, or Report of Incidents

You may direct questions, comments or reports to: gladiatortrading27@gmail.com

Last amended 28^th August 2019