This privacy notice (the “Privacy Notice”) describes how SportyFi Ltd, 20-22 Wenlock Road, London, England, N1 7GU ("SportyCo", "we" or "us") collects and uses the personal information you (”You”) provide us with on our website www.sportyco.io or www.sportyco.net or any of their subdomains or subpages (hereafter: “Website”). It also describes the choices available to You regarding the use of Your personal data and how You may access, update and delete this data.
1. Collection of Personal Data
We receive and store any information You enter on our Website or give us in any other way. This includes information that can identify You ("personal information"), including Your first and last name, telephone number, postal and e-mail addresses, user name and password (if applicable). We may collect the following personal information from You if You choose to become a User and register with us:
- The personal data You provide us, such as: contact details, bank details, tax information, demographic information, employment and educational history, personal documents,
- Contact Information such as name, e-mail address or phone number;
- Unique Identifiers such as user name, account number or password (if applicable);
- IP address;
- Other data specified as personal data under the Regulation (EU) of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the procession of personal data and on the free movement of such data (the “GDPR”).
Please note that even if You do not register or become a user or in case You do not provide us with Your e-mail, we may automatically gather information from Your computer such as Your IP address, browser type, referring/exit pages, and operating system. This information does not include personally identifiable information about You.
We may obtain information about Your general Internet usage by using a cookie file, which is stored on the hard drive of Your computer. Cookies contain information that is transferred to Your computer's hard drive. They help us improve our Website and to deliver a better and more personalized service. They enable us to:
- Estimate our audience size and usage pattern
- Store information about Your preferences, allowing us to customize our Website according to Your individual interests
- Speed up Your searches
- Recognize You when You return to our Website
Occasionally Your personal data may be used to allow us to better understand our audience and deliver more relevant advertising to You or people like You.
3. General Operational Purposes
We may use information gathered from You for various purposes in order to:
- Ensure that content from our Website is presented in the most effective manner for You and Your computer;
- Share information about our services;
- Notify You about changes to our services;
- Conduct statistical analysis;
- Develop and improve our Website.
4. Social Network Accounts
We may offer You to log into our Website using social network accounts, such as Facebook and Google+. This service will authenticate Your identity and provide You with the option to share certain personal information with us such as Your name, e-mail address and photo to pre-populate Your profile.
5. Our Personal Data Protection Principles
We are strongly committed to protecting the privacy and security of Your personal data. We are a "data controller”, which means that we are responsible for deciding how we hold and use Your personal data.
We will comply with data protection law, which says that personal data shall be:
- used lawfully, fairly and in a transparent way, applying the data minimization principle;
- collected only for valid purposes that we have clearly explained to You and not used in any way that is incompatible with those purposes;
- relevant to the purposes we have revealed to You and limited only to those purposes;
- accurate at all times and kept up to date;
- kept only as long as necessary for the purposes we have revealed to You.
- kept securely.
6. Use of Your Personal Data
In general, we use personal data to:
- Conduct research and analysis;
- Improve our Website and marketing efforts;
- Send You confirmations for sign up;
- Send You newsletters;
- Respond to Your questions.
All personal data will be used lawfully, in accordance with the GDPR, and for the purposes of improvement of our online services in order to offer You our product. At all instances we will strive to collect only such data that are required for the improvement of our services (data minimization principle), while in most instances we will only collect Your IP address and with Your explicit consent Your e-mail address.
In case You will decide to give us Your e-mail and potentially other personal data, You will have to give Your explicit consent to the collecting of Your personal data by us (opt-in function).
Majority of the information enables us to comply with our legal obligations or fulfill our contractual arrangements with You and other parties and sharing this information may be necessary for us to provide our services.
We use the personal data that we collect for the following purposes:
To comply with our legal or regulatory obligations, we may use Your personal data (and if You do not provide this personal data we may not be able to provide our services to You):
- to confirm Your identity in order to create Your account and ensure that You are eligible to use the services provided on the Website;
- to conduct required know Your client (KYC) and anti-money laundering (AML) checks on You, and associated financial crime and fraud monitoring, in connection with transactions You may conduct through the Website;
- in the case of investors, to confirm that You are eligible to make investments through the Website in accordance with relevant legislation;
- to enable us to comply with our obligations, including transaction recording, updates on Your investment and fundraising activity on the Website, other compliance responsibilities, and reporting to regulators and governmental authorities, if and when applicable.
To carry out our obligations under our contracts with You or others, we may use Your personal data:
- to process and administer payments in connection with the services provided on the Website.
- to assess Your suitability for and application to fundraise on the Website, to verify and approve the disclosures You make in Your campaign, to provide You with any campaign marketing and PR services, to facilitate the transactions, and exercise any rights that we may have;
- to facilitate any investments You may make, to exercise any rights You may have in connection with those contributions including by SportyCo, and to provide fundraisers with information about the progress of their campaigns and Your contributions;
- to provide You with information about Your account, including any campaigns You have created and any investments or payments You have made or have indicated an interest in making.
We have a legitimate interest in ensuring that the Website and our services operate effectively, and to do this we may use Your personal data:
- to monitor, improve and administer the Website and the services provided on the Website;
- to contact You to ensure customer satisfaction in respect of our role as a platform and service provider and assist You in getting the best value from our services;
- to respond to customer support or other enquiries requesting information. We may also intercept, record and/or monitor any communication(s) (including telephone calls or other electronic communications) between You and us. We may do so in order to resolve queries in the future and for the purposes of ensuring security, staff training and complying with our regulatory and legal responsibilities. In the case of communications by email You should note that, as emails are in general not encrypted (and may therefore be intercepted by third parties) and as the identity of the sender cannot be confirmed, You shall under NO circumstances provide Your security details, wallet address or similar by email.
We also have a legitimate interest in communicating with You and others, publicizing our business, and make sure that marketing, advertising, PR, and content we provide is effective, so we may use Your personal data:
- to enable us to conduct surveys and analysis, aggregate user profiles, and identify other potential customers;
- to advertise, publicize and promote our business, and to measure, understand, or improve the effectiveness of advertising we provide to You and others;
- in the case of individuals or businesses that have indicated an interest on the Website, to contact You to provide You with information about us or the services we offer and the campaigns on or Website, and on other selected products and services that we think may be of interest to You (unless You have or will ask us not to do so);
- to create and share informative content about our business or the industry in which we operate, including contacting You about reports we publish and new products we launch;
- in the case of journalists who are working in the sector in which we operate or related sectors, to provide You with news and updates about our business, and other relevant industry information.
- also, in certain other circumstances we may seek Your consent to use Your personal data. In such case we will ask You to confirm Your separate agreement to Your personal data being processed for a specific purpose, either through the Website of by another means.
7. Storage and Transfer of Your Personal Data, Security
The personal data collected by us will be used by us. The data that we collect from You may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA and working for us or one of our suppliers. Such staff may be engaged in, among other things, the processing of Your details and the provision of support services. Any potential transfer of personal data outside the EEA will be done in accordance with Chapter V. of GDPR. By consenting to the terms of this Privacy Notice, You agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Notice and in accordance with the GDPR. By providing us Your personal data, You agree that we may transfer such personal data to third parties. In such case we will ensure that Your rights will remain enforceable and effective legal remedies will be available to You following the transfer.
Any Personal Data that we collect will not be disclosed to any third parties, except under the following circumstances:
- we may disclose certain of Your personal data to third party service providers solely in the course of their provision of services to us and will take reasonable precautions to ensure that these service providers are obliged to keep Your personal data secure and confidential, in compliance with relevant legal requirements. In some instances, Your personal data may be transferred outside the European Economic Area; if this is the case we will take steps to ensure that the transfer is protected by safeguards provided under EU and UK law, such as model contract clauses or the EU-US Privacy Shield;
- we may disclose certain of Your personal data if we, in good faith, believe that we are required to do so by law, regulation or the order of court or other legitimate government body or arbitration panel. This includes, among other things, any personal data that may be requested by HM Revenue & Customs and the Financial Conduct Authority;
- we may tell You in one of the agreements that You enter into on the Website that we will disclose certain of Your personal data in connection with a transaction You conduct through the Website. We may also tell You how we will use or disclose Your personal data when You provide information to us in certain other circumstances.
We endeavor to take all reasonable steps to protect Your personal data. We also require that all our employees undergo mandatory data protection training. However, we cannot guarantee the security of any personal data You disclose online. In using the Website, You accept the inherent security implications of engaging in transactions online over the internet, and You agree that You will not hold us responsible for any breach of security unless we have been grossly negligent or in willful default.
8. Editing and Deleting Data
Every user of our Website can regulate, modify and rectify its personal data without requiring our permission by contacting us at [email protected] Modification of personal data is free of charge. Every user of our Website can erase its personal data without requiring our permission by contacting us at [email protected] Erasure of personal data is free of charge. At any time any user may restrict processing of its personal data and has the right to object, by contacting us at [email protected] Each user has the right of data portability by contacting us at [email protected] You can also contact us at: Data Protection Team, SportyFi Ltd, 20-22 Wenlock Road, London, England, N1 7GU.
If You wish to raise an objection to the processing of Your personal data or wish it to be deleted, You may do so by notifying us using the contact details above. It may be possible for us to restrict processing of Your personal data, or to delete it so long as we can still comply with our legal, regulatory and contractual obligations.
If You wish to object to direct marketing or other kind of communication we send to You, please notify us using the contact details above. To ensure that we respect Your request we may retain Your contact details on a suppression list.
Where we have processed information with Your consent then You may notify us using the contact details above to withdraw that consent at any time. Withdrawing Your consent will not affect the lawfulness of any processing we conducted prior to Your withdrawal, nor will it affect processing of Your information conducted in reliance on lawful processing grounds other than consent.
If You have created an account on the Website, You can see some of the personal data we hold about You in the “Profile Card” section of your account. If You wish to see a copy of all of Your personal data that we hold, please notify us using the contact details above. A request for a copy of Your personal data will generally be fulfilled free of charge, but we may charge a reasonable fee if the request is manifestly unfounded, excessive, or repetitive, or if You request multiple copies of the same information.
If You have concerns about how we collect and use Your data, please contact us. If you are dissatisfied with our response, You may have the right to raise Your concern with the UK Information Commissioner’s Office.
The e-mail addresses of our Users will only be used for sending the e-mail communication to the addressee. If You, as a User, want to unsubscribe from receiving e-mails, You can do so by contacting us at [email protected]
10. Changes to Our Privacy Notice
Any changes we may make to our Privacy Notice in the future will be posted on this webpage and, where appropriate, we will notify our Users about the amendments by e-mail.
11. The Right to Lodge a Complaint
Each user has a right to file a complaint with the supervising authority, which is in UK the Information Commissioner’s Office.
12. Contact Information
If You require more information about our privacy statement, please contact us at [email protected]