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Schedule 1 - Privacy Policy
1. Introduction
1.1 We are committed to safeguarding the privacy of our website visitors, app users and service users.
1.2 This privacy policy (“Policy”) sets out the basis on which we will process any personal data we collect from you, or that you provide to us, or which is provided to us by a third party acting for you or on your behalf, in relation to the event we organise which you have signed up for (or have been signed up for) (“Event”) and when you visit our website . This Policy also describes what cookies we use on our website and provides you with information on how you can disable cookies. This Policy does not apply to information collected by third parties, including through any application or content that may link to or be accessible from our website.
1.3 In this Policy, “we” or “us” refers to Square Mile Sport Services Ltd being a limited liability partnership registered in England and Wales with registration number OC335861 and whose registered office is at 5th Floor, 110 High Holborn, London, WC1V 6JS.
2. Who we are
2.1 We are a controller for the purposes of the Data Protection Laws. This means that we are responsible for deciding how to hold and use personal data about you. Square Mile Sport Services Ltd is required under Data Protection Laws to notify you of the information contained in this Policy.
3. What Personal Data we collect
3.1 We collect some or all of the following personal data from you when you register to participate in the Event and create your website account and when you participate in the Event:
i) Name ii) Email iii) Phone number iv) Birthday v) Gender vi) Postal address vii) Medical information viii) Emergency Contact Name and Contact Number ix) Company Name x) Job Title xi) Bloomberg client status
3.2 If you fail to provide us with the above information, we will not be able to process your registration or allow you to participate in the Event.
3.3 If you register for the Event as part of a team, some of the above information may be provided to us by a member of your team on your behalf to allow us to contact you to complete your Event registration.
3.4 We will keep your personal data only for as long as is necessary for the purpose for which it was collected, or to meet our legal or regulatory requirements. Your personal data will be securely destroyed or put beyond use when it is no longer required, in accordance with our data retention and disposal policies.
4. How we use your Personal Data
4.1 We will collect and process your Personal Data principally to enable us to provide our services to you in connection with the Event, including using your personal data:
i) to confirm and verify your identity; ii) to administer the Event and enable you to participate in the Event; iii) to contact you regarding important details for the Event; iv) for the compilation of anonymised statistical information; v) to satisfy our legal, accounting or reporting requirements; vi) to ensure the security of our website and services; and v) to process payments. Please note that we do not store any credit card or other payment information once the transaction has been completed.
Our lawful bases for these uses are because they are necessary for us to perform a contract between us or because it is in our legitimate interests (note that where we rely on legitimate interests as a legal basis you have a right to object to this in certain circumstances– you can find out more below).
4.2 We process your sensitive information (including data concerning your health) where this is necessary to protect your health or vital interests.
5. Who we share your Personal Data with and why
5.1 Personal Data will be shared with Bloomberg for marketing and internal reporting purposes, specifically
i) Name
ii) Email
iii) Phone number
iv) Company Name
v) Job Title
vi) Bloomberg client status.
5.2 We may share your Personal Data with the following third parties who perform services on our behalf in connection with the Event:
i) If you register for the Event as part of a team, a designated leader or contact person for your team, to enable them to complete or update your registration; ii) The local delivery agency contracted by us as detailed in Schedule 2 of these Terms and Conditions, to enable them to operate the event, internal administration and provide customer service; iii) City Specific Medical Providers in connection with any medical assistance given to you in relation to the Event; iv) Market Partner (Positivo Marketing Ltd), to enable them to manage results delivery through our App; v) Results Base, to enable them to process timing chips for the Event; vi) Marathon Photos, in connection with Event photography; vii) Bloomberg LP, if you confirm that you are a client of theirs, to enable them to manage their client list in each case, solely to the extent necessary to deliver those services and strictly in accordance with all applicable data protection laws.
5.3 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5.4 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
5.5 You acknowledge that any medical information supplied during registration, where deemed necessary, may be used to treat or otherwise assist you as a result of any illness or injury at the Event. You undertake and agree to inform the us of any change in your medical condition from the Registration Date up to and until the start of the Event. Nothing in this paragraph shall give the us the obligation to process, analyse, or otherwise take action on, any medical information provided by the Participant either during or after the registration process.
5.6 In the event that you become ill during or after the Event and require medical attention, we will provide your details to any Event medical provider, or any doctor or hospital for the purpose of you receiving any required treatment in accordance with your vital interests.
6. International transfers
6. 1 In addition to the transfers of personal data to our city-specific agents and medical providers as set out in schedule 2 of the Terms and Conditions, some of our service providers have offices located outside of the European Economic Area (the EEA), including Marathon Photos. As a result, in addition to the countries set out below in schedule 2 of the Terms and Conditions the information you provide to us may be transferred to the following countries outside the European Economic Area (the EEA): New Zealand, Canada, China. Where we transfer personal data outside the EEA we will ensure the countries have been approved by the European Commission as providing adequate data protection (such as New Zealand and Canada) or else we will ensure that appropriate safeguards are in place to keep your personal data secure, including via standard contractual clauses or Privacy Shield.
7. How we keep your information secure
7.1 We are committed to ensuring the confidentiality of the personal data that we hold. We have put in place measures to protect the security of your information. Details of these measures are available upon request.
7.2 We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
8. Your rights to access and correct Personal Data
8.1 You have various rights under law in relation to your personal data, including the following:
i) the right to access; ii) the right to rectification; iii) the right to erasure; iv) the right to restrict processing; v) the right to object to processing; vi) the right to data portability; vii) the right to complain to a supervisory authority; and viii) the right to withdraw consent.
8.2 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
8.3 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
8.4 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
8.5 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
8.6 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
8.7 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose. You'll be able to opt-out from marketing emails we send you by clicking on the unsubscribe link at the bottom of those emails.
8.8 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
8.9 To the extent that the legal basis for our processing of your personal data is:
i) consent; or ii) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
8.10 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
8.11 You may exercise any of your rights in relation to your personal data by clicking here, in addition to the other methods specified in this Section 8.
9. Cookies
9.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
9.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
9.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
10. Cookies that we use
10.1 We use cookies for the following purposes:
i) authentication - we use cookies to identify you if you are logged in – such as to complete a Bloomberg Square Mile Relay team registration or for submitting your team details;
ii) status - we use cookies to help us to determine if you are logged into the website, as outlined in point (i);
iii) security - we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;
iv) analysis - we use cookies to help us to analyse the use and performance of our website and services via Google Analytics;
11. Cookies used by our service providers
11.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
11.2 We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy/.
12. Managing cookies
12.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links and you can learn more about cookies generally here:
i) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
ii) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
iii) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
iv) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
v) https://support.apple.com/kb/PH21411 (Safari); and
vi) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
12.2 Blocking all cookies will have a negative impact upon the usability of many websites.
13. How to contact us
13.1 This website is owned and operated by Square Mile Sport Services Ltd
13.2 We are registered in England Wales with registration number OC335861 and registered office is at 5th Floor, 110 High Holborn, London, WC1V 6JS.
13.3 You can contact us if you have questions about this Policy, need further information about our privacy practices, or wish to obtain a copy of your personal data or update your personal data.
i) by post, to the postal address given above; ii) using our website contact form, iii) by telephone, on +44 (0) 207 240 7700 or iv) by email, using [email protected]
13.4 You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. You can contact the Information Commissioner’s Office on their helpline 0303 123 1113 or at https://ico.org.uk/concerns/.
14. Changes to our Privacy Policy
14.1 We may update this policy from time to time by publishing a new version on our website.
14.2 We will take reasonable steps to make you aware of any material changes to this Policy, but we also recommend you that you revisit this page from time to time to keep informed of our current privacy practices.
14.3 Privacy Policy last updated on 13th December 2018