Privacy Policy

Square Mile Sport Services Limited ("Square Mile Sport", "us", "we", "our", "SMS" and similar terms) is committed to the protection of your personal data. This Privacy Policy ("Policy") governs the manner in which Square Mile Sport collects, uses, maintains, discloses and otherwise processes personal data. Please also read our Terms of Use which sets out the term governing the Services (as defined below).

Please take your time to read this Policy carefully to understand our policies and practices regarding your personal data.

This policy was written in English. To the extent a translated version conflicts with the English version, the English version will take precedence. Unless otherwise indicated, this Privacy Policy does not apply to third party products or services or the practices of companies that we do not own or control, including other companies you might interact with on or through the Services.

CONSENT TO INSTALLATION OF THE APP

Under data protection laws, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes, and your rights in relation to your personal data. This information is set out below and it is important that you read the information provided.

How you can withdraw consent: Once you provide consent you may change your mind and withdraw consent at any time by contacting us at [email protected]  but that will not affect the lawfulness of any processing carried out before you withdraw your consent.

INTRODUCTION

This Privacy Policy and our App Terms of Use apply to your use of:

• our App once you have downloaded a copy of the App onto a mobile telephone or handheld device ("Device"); and
• the services accessible through the App ("Service").

This Privacy Policy 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 practices regarding your personal data and how we will treat it.

WHO WE ARE

We are Square Mile Sport Services Limited, a company registered in England with company number 11015254, whose registered office is at 110 High Holborn, 5th Floor, London, WC1V 6JS. As an organisation based in England we are bound by English law.  We are registered as a Data Controller with the Information Commissioners’ Office and our registration number is ZA428945.

CONTACTING US

Our contact details are as follows:

Postal address: 110 High Holborn, 5th Floor, London, WC1V 6JS marking your correspondence For the Attention of the ‘Data Protection Team’.

Email: [email protected] and include the words ‘For the Attention of the Privacy Team’ in the subject line.

Telephone: +44 (0)207 240 7700

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. The ICO’s address is: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. ICO Helpline number: 0303 123 1113. ICO website:  https://ico.org.uk/concerns/.

THE DATA WE COLLECT ABOUT YOU

We may collect, use, store and transfer different kinds of personal data about you as follows:

• Name.
• Gender.
• Password.
• Age range.
• Email address.
• Company.
• Office location.
• Office Department.
• What activities you like doing.
• Fitness trackers.
• Your well-being – through feedback, not monitoring.
• Data about your Device (the type of Device you use, a unique device identifier (for example, your Device's IMEI number), your mobile operating system, the type of mobile browser you, your country use and time zone setting.
• Information about your usage of the App.
• Details of the features you use.
• Your marketing preferences.

Aggregated data: We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific feature of the App. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

Location data: We also collect and process location data when you use the Services. We do not track your device location when you are not using the App. If you would like to stop device location tracking, you can do so by adjusting your device settings.

Health data: We may collect or infer health data (which is classified as special category data). Before you can upload health information to the App, you must give your explicit consent to the processing of that health data by SMS. You can withdraw your consent to SMS processing your health data at any time.

HOW IS YOUR PERSONAL DATA COLLECTED?

We collect personal data when you:

• download and register for the App;
• correspond with us (for example, by email, telephone or [live chat]);
• complete or upload activities using the App, such as distanced covered;
• report a problem with the App or the Service. If you contact us, we will keep a record of that correspondence; and
• provide us with your marketing preferences.

Information we collect about you and your device. Each time you use our App we will automatically collect personal data about your Device and your usage of the App.

COOKIES

To enable you to log into the App we need to direct you to a browser session and we use a persistent cookie for such browser session. The persistent cookie is not used to track you, it is used to authenticate the user browser session.

HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

• Where you have consented before the processing.
• Where we need to perform a contract we are about to enter or have entered 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.
• Where we need to comply with a legal or regulatory obligation (including where we need to establish, pursue or defend legal claims).

We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us via [email protected].

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes except for Bloomberg, who are entitled to receive certain personal data that you automatically permit as part of your acceptance of the Terms and Conditions and this Privacy Policy needed to create an account.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the third parties set out below for the following purposes:

Bloomberg: Certain Personal Data listed below will be shared with Bloomberg for marketing and internal reporting purposes, specifically:

1. i) Name ii) Email iv) Company v) Office vi) Department vi) Bloomberg client status.

Affiliates: We may share your information with persons/ entities under common control with us, who are required to comply with the terms of this Privacy Policy with regard to your personal data.

Purchaser of our business: Any third party to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

Third party service providers: So that they can perform functions on our behalf in relation to the purposes set out in this Policy (for example, website hosting, social media analysis providers, marketing email service providers, customer support, data analysts, website developers, app developers), including OneSignal (in respect of push notifications) and MailChimp (in relation to marketing email services).

To government and similar authorities: If we are compelled to do so by government and law enforcement authorities (including without limitation authorities such as the police) or otherwise as required or permitted by law, including but not limited to in response to court orders and subpoenas. We also disclose user information when we have reason to believe that someone is causing injury to or interference with our rights or property, other users of our site, or anyone else that could be harmed by such activities. Additionally, we cooperate with law enforcement inquiries and other third parties to enforce laws, intellectual property rights and other rights.

To our professional advisors: To enforce or apply the Terms of Use for our App or to protect the rights, property, or safety of our company or our customers.

To our hosting providers and IT support companies: our App is hosted in the cloud, currently with AWS, who host all user data on servers within the EEA.

We also share information about the users of the App in an anonymous or aggregate form with third parties including advertisers, business partners, and sponsors, to understand customer trends and patterns and manage and improve our business relationships.

INTERNATIONAL TRANSFERS

We do not transfer your personal data outside the UK or European Economic Area (EEA). Your personal data is collected and stored on servers within the United Kingdom.

Where there is a need to transfer your data outside of the UK or European Economic Area (EEA) we will ensure that the relevant and appropriate safeguards are put in place as required by English law. The need to transfer your data will be determined by the location of your employer as part of setting up a private challenge.

DATA SECURITY

Much of the information you provide to us will be transmitted electronically, e.g. information provided via the App or by email. We would remind you that information transmitted via the internet is not completely secure and although we will do our best to protect any information transmitted in this way, we cannot guarantee its complete security.

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password that enables you to access the App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

In addition, we limit access to your personal data to those staff, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

DATA RETENTION

We will retain the information you give us, the information we collect through your use of your Device and your location data for so long as the App is installed on your Device. Following your deletion of your account, it may take up to 90 days to fully delete your personal information and system logs from our systems. Additionally, we may retain information to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, enforce our Terms of Use and take other actions permitted by law. The information we retain will be handled in accordance with this Privacy Policy.

In the event that you do not use the App for a period of 24 months then we will treat the account as expired and your personal data may be deleted.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

We retain personal information used to send you direct marketing for as long as we can lawfully market to you. Where we no longer have grounds to market to you (e.g. because you opt-out) or the details we hold are no longer up-to-date (e.g. the email address we hold is invalid) you are able to change your marketing preferences at anytime within the APP.

YOUR LEGAL RIGHTS

Under certain circumstances you have the following rights under data protection laws in relation to your personal data.

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• if you want us to establish the data's accuracy;
• where our use of the data is unlawful but you do not want us to erase it;
• where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
• you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

CHANGES TO THIS PRIVACY POLICY

We keep this Privacy Policy under regular review. The last version was updated on 25^th August 2022.

We reserve the right to modify this Privacy Policy at any time. Please review it occasionally. If we make changes to this Privacy Policy, the updated Privacy Policy will be posted on the Services in a timely manner and, if we make material changes, we will provide a prominent notice. If you object to any of the changes to this Privacy Policy, you should stop using the Services and delete your account and the app from your mobile device.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you by contacting us emailing [email protected].  Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services. Please check these policies before you submit any personal data to these websites or use these services.