We are company number 5730335 registered in England. Our registered office is at 17 Prime Parkway, Mansfield Road, Derby, DE1 3QB.
1. This is a notice to inform you of our policy about all information that we record about you. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you ("personal information") and information that could not. In the context of the law and this policy, "process" means collect, store, transfer, use or otherwise act on information.
2. We take seriously the protection of your privacy and confidentiality. We understand that all our clients and employees are entitled to know that their personal data will not be used for any purpose unintended by them, and will not accidentally fall into the hands of a third party.
3. We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.
4. Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).
5. The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. We do this now, by requesting that you read the information provided at www.knowyourprivacyrights.org
6. Unless mentioned below, we do not share, or sell, or disclose to a third party, any information collected through our company and contracts taken out with our company.
What is personal data and special category data?
Personal data is defined in the GDPR as any information relating to an identified or identifiable natural person. It can include obvious data like your name but also identification numbers, online identifiers and/or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person.
Special category data includes data revealing race or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and genetic data, biometric data, data concerning health or data concerning a person's sex life or sexual orientation.
The basis on which we process information about you
The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.
If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.
If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.
1. Information we process because we have a contractual obligation with you
When you buy a service, product or create an account on our website, or otherwise agree to our terms and conditions, a contract is formed between you and us.
In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.
We may use it in order to:
1.1. provide you with our services
1.2. verify your identity for security purposes
1.3. sell products to you
1.4. provide you with suggestions and advice on products, services and how to obtain the most from using our company, our services or our websites.
We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.
Additionally, we may aggregate this information in a general way and use it to provide class information, for example to monitor our performance with respect to a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable.
We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
2. Information we process with your consent
Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including [job opportunities and] our products and services, you provide your consent to us to process information that may be personal information.
Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to agree to our use of your email address or website cookies.
Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply.
Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally.
We will never pass or sell your name, contact information or any other business details to any associated businesses or third parties.
You may withdraw your consent for email marketing or any other form of contact at any time by instructing us firstname.lastname@example.org. However, if you do so, you may not be able to benefit from, or use our services or our website further.
3. Information we process for the purposes of legitimate interests
We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.
Where we process your information on this basis, we do after having given careful consideration to:
• whether the same objective could be achieved through other means
• whether processing (or not processing) might cause you harm
• whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so
For example, we may process your data on this basis for the purposes of:
• record-keeping for the proper and necessary administration of our contracts and records within the organisation
• responding to unsolicited communication from you to which we believe you would expect a response
• protecting and asserting the legal rights of any party
• insuring against or obtaining professional advice that is required to manage The Gladiator Group risk
• protecting your interests where we believe we have a duty to do so
4. Information we process because we have a legal obligation
We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation.
For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.
This may include your personal information.
Specific uses of information you provide to us:
5. Information provided on the understanding that it will be shared with a third party
Our website allows you to post information with a view to that information being read, copied, downloaded, or used by other people.
5.1. posting a message our forum
5.2. tagging an image or other users to follow
5.3. clicking on the message icon next to another profile to send a message to convey your agreement, disagreement or other related information.
In posting personal information, it is up to you to satisfy yourself about the privacy level of every person who might use it.
We do not specifically use this information except to allow it to be displayed or shared and you have a full privacy section within our websites that puts you in control of the information you add and who it can be seen by and what is also displayed in the public domain.
We do store it, and we reserve a right to use it in the future in any way we decide but you will always be notified and have access to whether it will be displayed or not.
Once your information enters the public domain, we have no control over what any individual third party may do with it. We accept no responsibility for their actions at any time.
Provided your request is reasonable and there is no legal basis for us to retain it, then we should agree to your request to delete personal information that you have posted on our websites. You can make a request by contacting us at email@example.com stating your details and what you require.
6. Complaints regarding content on our website
Our websites are mainly a publishing and social medium. Anyone may register and then publish information about himself, herself, clubs, organisations, businesses or other relevant information pertinent to each site.
We attempt to moderate user generated content, but we are not always able to do so as soon as that content is published.
If you complain about any of the content on our website, we shall investigate your complaint.
If we feel it is justified or if we believe the law requires us to do so, we shall remove the content while we investigate.
Free speech is a fundamental right, so we have to make a judgment as to whose right will be obstructed: yours, or that of the person who posted the content that offends you.
If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.
7. Information relating to your method of payment
We will only store any information about your debit or credit card or other means of payment when you first provide it to us until the payment is complete usually with the same day. If we keep any debit or credit card information over night it is locked away in the company safe and the cross shredded when used.
We never store any payment information in order to make repeat purchasing of goods and services and rely on customers to repeat payment information each time, which makes us PCI DSS compliant as a worldpay partner.
We take the following measures to protect your payment information:
7.1 your payment information is taken and encrypted on our worldpay servers.
7.2 we do not keep all your payment information so as:
7.2.1 to prevent the possibility of our duplicating a transaction without a new instruction from you;
7.2.2 to prevent any other third party from carrying out a transaction without your consent
7.3. access to your payment information is restricted to authorised staff only
7.4. if we ask you questions about your payment information, we only show [partial detail OR the first four OR the last four digits of the debit or credit card number], so that you can identify the means of payment to which we refer.
We automatically delete your payment information when a credit or debit card has been used to take payment in full unless you specify otherwise in which case any details will be secured in a safe or encrypted on or payment system servers.
Payment information is never taken by us or transferred to us either through our website or otherwise. Our employees and contractors never have access to it.
At the point of payment, we transferred your payment details to a secure page on the virtual terminal of our Worldpay payment website. That page and the receipt may be branded to look like a page on our website or have our company logo on, but it is not controlled by us.
8. Information about your direct debit
When you agree to set up a direct debit arrangement or standing order mandate, the information you give to us is passed to our own bank Nat West or your bank for processing according to our instructions. We do keep a copy of these which are kept securely locked away until last payment is made and then they are cross shredded.
[We keep this information only for the duration of the direct debit or standing order arrangement.]
We are registered under the direct debit guarantee scheme. This provides for the customer's bank to refund disputed payments without question, pending further investigation. Direct debits can only be set up for payments to beneficiaries that are approved originators of direct debits. In order to be approved, these beneficiaries are subjected to careful vetting procedures. Once approved, they are required to give indemnity guarantees through their banks.
9. Job application and employment
If you send us information in connection with a job application, we may keep it for up to three years in case we decide to contact you at a later date.
If we employ you, we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment. After your employment has ended, we will keep your file for 10 years before destroying or deleting it unless otherwise requested.
10. Sending a message to our support team
When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need.
We record your request and our reply in order to increase the efficiency of our business.
We do not keep any personally identifiable information associated with your message, such as your name or email address.
When we receive a complaint, we record all the information you have given to us.
e use that information to resolve your complaint.
If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.
We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.
12. Affiliate and business partner information
This is information given to us by you in your capacity as an affiliate of us or as a business partner.
It allows us to recognise visitors that you have referred to us, and to credit to you commission due for such referrals. It also includes information that allows us to transfer commission to you.
The information is not used for any other purpose.
We undertake to preserve the confidentiality of the information and of the terms of our relationship.
We expect any affiliate or partner to agree to reciprocate this policy.
13. Use of information we collect through automated systems when you visit our website: Cookies
Cookies are small text files that are placed on your computer's hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.
Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.
Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.
13.1. to track how you use our website
13.2. to record whether you have seen specific messages we display on our website
13.3. to keep you signed in our site
13.4. to record messages or connections on our site while you request them
14. Personal identifiers from your browsing activity
Requests by your web browser to our servers for web pages and other content on our website may be recorded.
We may record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.
We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.
15. Information we obtain from third parties
Although we do not disclose your personal information to any third party (except as set out in this policy), we sometimes receive data that is indirectly made up from your personal information from third parties whose services we use.
No such information is personally identifiable to you.
16. Third party advertising on our website
Third parties may advertise on our website. In doing so, those parties, their agents or other companies working for them may use technology that automatically collects information about you when their advertisement is displayed on our website.
17. Credit reference
To assist in combating fraud, we share information with credit reference agencies, so far as it relates to clients or customers who instruct their credit card issuer to cancel payment to us without having first provided an acceptable reason to us and given us the opportunity to refund their money.
18. Access to your own personal information
18.1. At any time you may review or update personally identifiable information that we hold about you, by signing in to your account on our website.
18.2. To obtain a copy of any information that is not provided on our website or has been obtain under a contract agreement you may send us a request at firstname.lastname@example.org
18.3. After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any further security information from you.
19. Removal of your information
If you wish us to remove personally identifiable information from our website or information we hold from entering into a business contract with us, you may contact us at email@example.com
This may limit the service we can provide to you though.
20. Verification of your information
When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.
21. Use of our websites by children
21.1. We do not sell products or provide services for purchase by children, nor do we market to children.
21.2. If you are under 16, you may use our website only with consent from a parent or guardian
21.3. We collect data about all users of and visitors to these areas regardless of age, and we anticipate that some of those users and visitors will be children
21.4. Such child users and visitors will inevitably visit other parts of the site and will be subject to whatever on-site marketing they find, wherever they visit.
21.5. Encryption of data sent between us
We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us where necessary.
Whenever information is transferred between us that is necessary to be secure, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.
22. How you can complain
22.2. If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
22.3. If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner's Office. This can be done at https://ico.org.uk/concerns/
23. Retention period for personal data
23.1. to provide you with the services you have requested and associated services that may be deemed of interest to you;
23.2. to comply with other law, including for the period demanded by our tax authorities;
23.3. to support a claim or defence in court.
24. Compliance with the law
However, ultimately it is your choice as to whether you wish to use our website and other company services.
Last upated May 2018.
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