Data Protection is important. This document provides you with information about how we (Spoke Series) are handling, or are intending to handle, your personal information. With new ruling coming into effect on 25th May 2018 with the General Data Protection Regulation (GDPR) - a new legal framework that sets guidelines for the collection and processing of personal information of individuals within the European Union - Spoke Series is taking every precaution to ensure that personal data held is under the new compliance ruling.
If you are aged 18 or under, you will need to obtain your parent/guardian’s permission/consent before you provide any personal information to us. By agreeing, you confirm that you have consent.
Spoke Series are committed to protecting and respecting your privacy and complying with the principles of applicable data protection laws. This notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
To register for our events you must provide a valid email address so we can send you confirmation of your registration and your Entry Pack. The email address supplied (and any email addresses given when registering other people) may be used by the Event Organiser to send out information about the events you enter. Each participant agrees to assign and grant the right and permission for Spoke Series to use and publish any photographs/film/video/electronic representations and/or sound recordings of the participant on any Spoke Series activity, this may include posts, pictures and video footage you share on social media sites such as Facebook, Instagram and Twitter. The participant hereby releases Spoke Series from any and all liability from such use and promotion. The participant hereby authorises the reproduction, sale, copyright, exhibit, broadcast, electronic storage and/or distribution of said photographs/film/video tapes/electronic representations and/or sound recordings without limitation at the discretion of Spoke Series. The participant specifically waives any right to any compensation they may have for appearing in any of the photographs/film/video/electronic representations and/or sound recordings of the participant at the Spoke Series.
What personal information we collect from you:
- Name (first and last)
- Email address
- Phone number
- Date of birth
- Your gender
- A consent from you that you are fit & healthy enough to participate in our events
- IP address and Cookies
How and why we collect it:
You provide us this information to us electronically through the booking forms you complete on the Spoke Series website. We need to collect this information to allow us to run Spoke Series events, and properly plan for the appropriate number of participants.
Uses made of your information and the basis of processing:
Spoke Series will use your personal information to:
- Provide you with information, products or services that you request from Spoke Series or which we feel may interest you, where we are legally entitled to do so;
- Notify you about changes to our service;
- To gather statistics about participation and people interested in cycling; or
- To segment your personal data to make sure that you only receive information that is relevant to you. For example, if you are based in Chelmsford, to make sure that you do not receive information about events in Cornwall.
Spoke Series will not use any of the personal information we collect from you to make automated business decisions.
The legal basis on which we collect and process the personal data described above depends on the personal information concerned and the specific context in which we collect it. However, we will only use your personal information where we:
- Have your consent to do so;
- Need the personal data to perform a contract with you;
- Need to process your personal information for our legitimate interests and only where our legitimate interests are not overridden by your data protection interests or fundamental rights and freedoms;
- Have a legal obligation to collect personal information from you; or
- Need the personal information to protect your vital interests or those of another person.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time, and advise you whether the provision of your personal information is mandatory or not (as well as the possible consequences if you do not provide your personal information).
- We may also ask you for information when you report a problem or make a complaint and, if you contact us, we may keep a record of that correspondence.
- We may also ask you to complete optional surveys that we use for research purposes and to provide you with a more relevant customer experience.
- Information about emails and other communications we have sent to you and your interaction with them.
- Information from third parties where you consent to those other organisations sharing information they hold on you with us, and where those other organisations lawfully share your information with us.
How we secure it and information security:
Spoke Series will take all steps reasonably necessary including policies, procedures and security features to ensure that your data is treated securely and protected from unauthorised and unlawful access and/or use, and in accordance with this notice.
Unfortunately, the transmission of information via the internet is not completely secure and, although we will do our best to protect your personal data transmitted to us via the internet, we cannot guarantee the security of your data transmitted to our website from your device. Any transmission is at your own risk.
Any (hard) paper copies of your data, will only be used for sign-on sheets, or parental/guardian consent to participate on the day and are kept securely, they will be shredded after they are deemed necessary. Your data is only used for this purpose and isn’t shared with any other parties outside those involved with running the event and our data processors and suppliers.
Where any payments are being collected on our behalf, we require our payment providers to be compliant with the Payment Card Industry’s Data Security standards (PCI-DSS).
Spoke Series do not have access to any payment information you provide. Credit and Debit card details are held solely by the Payment Service Provider and are unknown to the Event Organisers.
Recipients of personal data and third parties with access to this:
We will share information about you with some of our suppliers who process data on our behalf to help us to provide services to you, we may also need to provide this information to a governing organisation or authority where appropriate. We undertake this data sharing on the basis of our legitimate interests.
Categories of organisation and purpose
- Marketing agencies - to provide relevant digital content to our customers
- Website content management system (CMS) - to update and improve the Spoke Series websites
- Database hosting companies - to host Spoke Series digital platforms (e.g. Spoke Series website) and associated customer databases to enable customers to log in and interact with the website
- Payment providers - to verify payments for Spoke Series products and services - Credit and Debit card details are held solely by the Payment Service Provider and are unknown to the Event Organisers.
- Cloud-based databases and file storage - for the purposes of properly running and managing our events
- Email broadcasting companies - to send emails to our customers
- SMS broadcasting companies - to send SMS and text messages to our customers
- Mailing houses - To send products and benefits to our customers that are not directly produced by Spoke Series (e.g. publications)
- Market research companies - to undertake research of our own customers
- Online learning hosting companies - to enable our customers to take part in online training and learning
- Governing bodies of cycling - to assist in event management, disciplinary issues and maintenance of competition licences (British Cycling, UCI and other federations)
- Spoke Series registered event organisers, ride leaders and officials - to enable event organisers, ride leaders and officials to manage Spoke Series registered activities and communicate with participants
- Sports results agencies - to collate results and reports for/on behalf of Spoke Series
How users can control any aspect of this:
If you no longer wish to be invited to participate in future Spoke Series events you can request to have your data removed from our systems by emailing email@example.com.
Data retention period
We will hold information about you in our data systems only for as long as we need it for the purpose for which we collected it, which is as follows:
- As long as you continue to use our services (including engaging with emails, entering cycling events, making purchases, or downloading content) we will retain and process information about you. In such cases, you will be considered to be an ‘active’ customer. If you have not been ‘active’ as a customer for a period of three years, Spoke Series will deactivate your customer account and delete any personal data relating to you.
- Personal data linked to the processing of insurance claims, subject access requests, disputes, safeguarding investigations, disciplinary or police matters will only be kept for as long as it necessary for those purposes, as each is applicable.
IP addresses and cookies:
We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.
For the same reason, 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.
In addition to the above we use third party cookies and pixels to advertise Spoke Series and our products across the internet (for example via Google AdWords Remarketing and other services). Remarketing will display relevant adverts tailored to you based on what parts of the Spoke Series website you have viewed by placing a cookie on your machine. This does not in any way identify you or give access to your computer. Remarketing allows us to tailor our marketing to better suit your needs and only display adverts that are relevant to you.
The data subject’s rights
Data protection laws grant you, as a Data Subject, certain ‘information rights’, which are summarised below:
- Right of access - You have the right to obtain a copy of information we hold about you
- Right of rectification or erasure - If you feel that any data that we hold about you is inaccurate, you have the right to ask us to correct or rectify it. You also have a right to ask us to erase information about you where you can demonstrate that the data we hold is no longer needed by us, or if you withdraw the consent upon which our processing is based, or if you feel that we are unlawfully processing your data. Please note that we may be entitled to retain your personal data despite your request, for example if we are under a separate legal obligation to retain it. Your right of rectification and erasure extends to anyone we have disclosed your personal information to and we will take all reasonable steps to inform those with whom we have shared their data about your request for erasure.
- Right to restriction of processing - You have a right to request that we refrain from processing your data where you contest its accuracy, or the processing is unlawful and you have opposed its erasure, or where we do not need to hold your data any longer but you need us to in order to establish, exercise or defend any legal claims, or we are in dispute about the legality of our processing your personal data.
- Right to Portability - You have a right to receive any personal data that you have provided to us in order to transfer it onto another data controller where the processing is based on consent and is carried out by automated means. This is called a data portability request.
- Right to Object - You have a right to object to our processing your personal data where the basis of the processing is our legitimate interests including but not limited to direct marketing and profiling.
- Right to Withdraw Consent - You have the right to withdraw your consent for the processing of your personal data where the processing is based on consent.
- Right of Complaint - You also have the right to lodge a complaint about any aspect of how we are handling your data with the UK Information Commissioner’s Office, which can be contacted at www.ico.org.uk.
- Right to Opt-out of Marketing Communications - You have the right to opt-out of marketing communications we send to you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you. To opt out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided below.
Any changes we may make to our Privacy Notice in the future will be posted on this page and, where appropriate, notified to you by date-stamped communication.
How to contact us
If you wish to contact us about your personal data or exercise any of the rights described above please contact: firstname.lastname@example.org
James Lord Spoke Series of 46 New Broad Street, London, EC2M 1JH.
- 18th May 2018