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Privacy Policy

 

GGL GROUP PRIVACY POLICY

This Privacy Policy explains how the Global Gymnastics Limited group of companies (“GGL Group”), which includes Global Gymnastics Limited and ManageMe Limited, will process the data relating to you that you provide to us (or that we may collect) when you visit the Nick Ruddock Gymnastics’ website at www.nickruddock.com (“Website”), use any of our online services including online event booking and purchasing, or otherwise engage with us.

At GGL Group, we are committed to protecting and respecting your privacy.

  1. INTRODUCTION AND GENERAL TERMS

The Website is operated on behalf of the GGL Group by Global Gymnastics Limited (“we, us, our, GGL”), a company incorporated in England & Wales with company number 11636158 and registered office at 75 Buccleuch Street, Barrow-In-Furness, Cumbria, England, LA14 1QQ.

Where we decide the purpose and means for the processing of personal data relating to you, we are the “controller”. As controller, we will comply with all applicable data protection laws, including the General Data Protection Regulation 2016/679 and Data Protection Act 2018.

If you have any questions or comments about this Privacy Policy please contact us at:

Email: [email protected]


Please read this Privacy Policy carefully as it contains important information about the following:

  • What information GGL Group may collect about you or receive from others;
  • How and why GGL Group will use that information;
  • Whether GGL Group will disclose information about you to anyone else; and
  • Your choices and rights regarding the personal information we hold about you.

This Privacy Policy should be read in conjunction with our other policies and procedures, website terms of use, notices or agreements with you, as may be relevant.

  1. INFORMATION WE MAY COLLECT ABOUT YOU

We collect and process the following information which may include your personal data:

Customer Services (including visiting our Website)

Type of information

Purpose of the processing and legal basis for the processing

Who is this information shared with?

We may ask you for, or you may submit, personal and non-personal information to us when contacting us through our Website (including via our live chat messaging features), by telephone or via email, in relation to the products and services that we offer, to sign up for our webinars or to submit other enquiries.

Personal data that we may obtain includes:

·     your first and last name

·     company name (if applicable)

·     email and/or postal address

·     phone number(s)

·     your username (typically your email address) and password

·     online identifiers, such as IP or MAC address, cookies and tracking data and other unique user identifiers

·     your data held by social media, such as Google or Facebook (where permitted by your account settings)

·     any other personal information you voluntarily provide in a free-text message or otherwise

We may legally process the personal information that we hold on the basis that we have a legitimate interest, under our legal obligations and/or for the performance of a contract, including processing for the following purposes:

·     to provide you with information about the products and services that we offer, including news about upcoming GGL Group company events and coaching consultancy programmes

·     to set up and administer your user account

·     to enter into and  perform our contract for sales of our products and services;

·     to respond to your enquires, such as when you use our Contact webpage to submit your message

·     when you sign up to Join Nick's Community, to receive regular emails with podcasts, blogs and event content

·     when you use our other online services (including our coaching programmes and other packages available for gymnastics coaches and club owners)

·     to manage risk or prevent other illegal or prohibited activities;

·     to resolve issues or fix problems in relation to our Website

We may obtain more sensitive personal data (known under law as special categories of personal data), such as data revealing racial or ethnic origin or concerning your health (or that of others), if you voluntarily supply it through an online submission.

If you volunteer such information, you will be consenting to our processing it in relation to the purpose for which you have provided it.

For example, in certain circumstances, we may ask you for your dietary requirements and/or details of any disability.  This is solely for use to provide any special catering or disability access you may require.

We keep your information confidential. We will not sell your information.  We may disclose your information to our personnel and to third party suppliers or subcontractors (including our independent consultants, data analytics and/or online targeted advertising providers, and cloud-based data processing and hosting providers).

If we do share your information, we will only do so insofar as it is reasonable or necessary for the operation of our business, including for the purposes set out in this Privacy Policy, and provided that the recipients do not make independent use of the information and have agreed to adhere to the rules set out in this Privacy Policy. 

In some instances, this data sharing may involve the transfer of information outside the EU. Please see our section on International Data Transfers below.

 

Setting Up Your Account

Type of information

Purpose of the processing and legal basis for the processing

Who is this information shared with?

When you set up your user account, we will ask you to provide us with personal information, which may include the following:

·       full name

·       job title and company/club name (if applicable)

·       email address

·       postal address (including country of residence)

·       telephone number(s)

·       information about your athletes (e.g. gymnastics level, past achievement)

We may legally process the personal information that we collect on the basis that we have a legitimate interest, under our legal obligations and/or in the performance of a contract:

●      to register and administer your user account

●      to respond to your enquiries

●      to provide you with information about the bespoke coaching and other GGL Group services that we offer, including email, SMS or other reminders to complete your order or about products you’ve previously clicked-on

●      to identify and improve our understanding of our current customers and help us find potential customers with similar interests

●      to respond when you submit applications, such as in relation to our Inner Circle Membership, or related queries

We keep your information confidential. We will not sell your information.  We may disclose your information to our personnel (including personnel in our group of companies) and to third party suppliers or subcontractors (including our independent consultants, data analytics providers and cloud-based data processing and hosting providers).

If we do share your information, we will only do so insofar as it is reasonably necessary for the purposes set out in this Privacy Policy, and provided that the recipients do not make independent use of the information and have agreed to adhere to the rules set out in this Privacy Policy. 

In some instances, this data sharing may involve the transfer of information outside the EU. Please see our section on International Data Transfers below.

 

Marketing, Advertising and Social Media

Type of information

Purpose of the processing and legal basis for the processing

Who is this information shared with?

Our Website does not contain third party advertising.

We may collect information about you in order to send you our promotional or marketing communications, such as:

·     your name (first and last)

·     your email address

·     your telephone number(s)

·     any other personal information that you may provide in a message you submit to us

While we do not permit third party advertising on our Website, if you do link to one of our social media platforms you may be subject to targeted marketing via that site.

The Website contains links to GGL Group’s social media pages on Facebook, Twitter, Instagram, YouTube, iTunes Preview and LinkedIn.

These third party websites have their own respective privacy policies (which we would advise you to read) for which those sites are solely responsible.

Should you visit those social media pages and choose to follow or connect with us on social media, GGL Group may receive personal information from the social media providers, including personal information in your profile (depending on your social media privacy settings). For example, that may include:

·     your name (and/or your social media unique user name)

·     your email and/or postal address

·     your telephone number(s)

·     IP or MAC address

·     your gender and/or age

·     your general interests and preferences (e.g. Likes, Shares, Posts)

 

If we do receive any personal information about you from these third party social media sites, we will not process your information for the purposes of direct marketing unless you have provided your consent or it is otherwise lawful for us to do so.

We may use this information to find out more about our digital community so that we can better understand and serve our customers and Website visitors (for example, to create bespoke content by analysing general interests).

We may process personal information that we collect about you via social media to improve the relevancy of our marketing, including the creation of custom audiences and lookalike audiences. This allows us to offer more relevant marketing to potential new customers and service users without using information that personally identifies you.

Where we provide you with information about our products, services or offers (such as via our email updates), we will only use your personal information in this way in accordance with laws relating to marketing directly to individuals, and in the pursuit of our legitimate interest of marketing our business.

In some cases, we will do this on the basis that you have provided your consent (including where you submit your details and responses to specific questions to request discounts or further information about specific products or services).

If you have subscribed to Join Nick’s Community, which adds subscribers to our mailing list, we will provide your details to our third party email service provider that helps us to produce and manage our newsletters.

If you change your mind, you may opt-out at any time via the unsubscribe feature that appears in our emails or by emailing [email protected]

 

We may share your personal information with these social media sites to enable them to provide targeted marketing messages where you have indicated your agreement to receive these messages from them or where it is otherwise lawful to do so.

In some instances, this may include you submitting your details and answering questions on lead ad forms to receive further information or prompt us to contact you directly.

We engage third party sub-processors and service providers to assist us with our data collection, analysis and marketing, including:

·       BombBomb (video email services) www.bombbomb.com/gdpr/

·       Facebook Ads as  supported by FB’s various sub-processors (targeted advertising services) www.facebook.com/policy.php

·       GrooveJar (pop-up apps services) www.groovejar.com/privacy_policy

·       Infusion Software, Inc. (email marketing services) www.infusionsoft.com/legal/privacy-policy), in connection with Field.Space www.fieldspace.io/privacy-policy/

·       Kajabi, LLC (website host and support services) https://kajabi.com/policies/privacy/

·       Tidio LLC (Live-chat messaging service provider) https://www.tidiochat.com/en/privacy-policy/

·       Typeform, SL.  (embedded web applications services) https://admin.typeform.com/to/dwk6gt

·       Zapier, Inc. (CRM data integration service) www.zapier.com/privacy/

We will not otherwise share with any other third party the personal information that we obtain about you for the purposes of marketing, unless you have provided your consent or it is otherwise lawful for us to do so.

If you would like us to delete the personal information that we have received about you from these sites, please email us at [email protected]

If you do not want us to receive further information about you from these sites, you should also contact the sites directly to turn off the ‘follow’ setting.

If you would like to have deleted the personal data that you’ve shared with the social media accounts that you have joined or that you follow, please contact the social media providers directly.

Using Your Personal Data (including photographs) in our Marketing, Advertising and on Social Media

We want to share our news, including stories and footage from our events, with others interested in the gymnastics community. 

If you participate in or attend one of our events, you may be photographed or recorded in event footage that we and/or our trusted photographers record or that is recorded by our trusted third party partners.  We may publish those images as well as any posts, recommendations or testimonials that you provide in our marketing, promotional, training or other materials.

Where we process these categories of personal data, we may do so in the pursuit of our legitimate interests as a world class gymnastics and professional sports education, events and consultancy services provider, on the basis of consent from the relevant individuals, (including that of our event participants, purchasers of our products and services and our followers on social media or where it is otherwise lawful to do so.

 

While our training and coaching consultancy communications and materials will mostly be available only to our customers and/or registered account holders, our marketing, advertising and content on social media will usually be available to the public at large.

If you do not want us to publish or otherwise process recorded images of you or re-publish your posts, recommendations or testimonials, you may contact us to make such request by emailing us at [email protected] or by post to our Data Protection Manager at GGL Group, 75 Buccleuch Street, Barrow-In-Furness, Cumbria, England, LA14 1QQ.

 

Financial Data

(including Event Bookings and Purchasing Services)

 

Type of information

Purpose of the processing and legal basis for the processing

Who is this information shared with?

Via our Website, we offer you the opportunity to purchase our products and services such as online masterclasses and digital courses and resources, membership to our Inner Circle package and tickets to our events. 

If you chose to make an online purchase, we will collect some financial details from you including the following personal information:

·     your name (first and last)

·     your email address

·     your postal address (including billing address)

·     your country location (including postcode)

·     your telephone number(s)

·     credit or debit card details (including name on card, card number (last four digits only), expiry date, CVC)

·     information about your purchase (e.g. dates and quantity of tickets purchased)

·     information about your purchase (e.g. dates and quantity of tickets purchased)

We may collect and process these financial details to provide our customers with our products and services for which an order has been placed.

We process this personal data in order to perform our sales contract with you and to meet our legal obligations or legitimate interests as a world class gymnastics and professional sports education, events and consultancy services provider.

We may contact you and/or any other event attendees (as identified by the purchaser at time of purchase) about your purchase.  For example, with details on your tickets or your attendance at an event.  We may also create and store a record of your purchase history.

Financial transactions via our e-store are handled by us in conjunction with our third party card payment services provider.

Via the links on our Website (including via our e-store webpage), you may be re-directed to one or more of our third party card payment processing service providers that will require further financial personal details in order to complete your purchasing request.

Our third party online payment service providers include:

·       GoCardless Ltd. www.gocardless.com/legal/privacy

·       Stripe, Inc. https://stripe.com/gb/privacy

·       SamCart, Inc. www.samcart.com/privacy-policy/

·       Xero Ltd. www.xero.com/au/about/terms/privacy/

·        

When you make a purchase via our third party payment services providers, we will only share personal information in so far as it is necessary for the operation of our business (including completion of sales), and provided that those service providers do not make independent use of the information and adhere to applicable data protection laws (including as set out in their respective privacy policies).

 

Data Analytics and Cookies

Our Website uses cookies, such as Facebook pixel, and other mechanisms to collect log and analytical information, to help analyse how visitors use the site, to compile statistical reports on Website activity and to improve our marketing function.  

To find out more about the use of cookies, please visit:

·       http://www.allaboutcookies.org/

To find out more about Facebook pixel and to learn how to opt out, please visit:

·       https://www.facebook.com/privacy/explanation

·       https://www.facebook.com/business/learn/facebook-ads-pixel

Our Website also uses website analytics, including Google Analytics, to evaluate and improve our Website, personalise your experience and to offer the best, most accessible service possible to all of our customers. 

To find out more about Google Analytics and to learn how to opt out, please visit:

·        How Google uses data when you use our partners' sites or apps, or

·        https://tools.google.com/dlpage/gaoptout/.

When you visit our Website, these analytics service providers may collect the following data, which will almost always be anonymised and aggregated before reporting back to us:

·        number of visitors to our Website;

·        pages visited while at the Website and time spent per page;

·        page interaction information, such as scrolling, clicks and browsing methods;

·        websites where visitors have come from and where they go afterwards (clickstream), including date and time, products or services that you viewed, searched for or hovered over;

·        page response times and any download errors; and

·        Internet protocol (IP) address used to connect, browser type and version (including any browser plug-in details) and operating system and your time zone setting and login information

·        other technical information relating to end user device, such as IP address or browser plug-in.

We process this information to understand how visitors use our Website and to compile statistical reports regarding that activity.  This processing is crucial to the running of our online business. 

We process this analytics information for a number of purposes, including:

·        to help us improve our Website and the online services to ensure that content, including marketing and promotional content, is presented in the most effective manner for you and for your device;

·        to understand how, and how often, users visit and interact with our Website and social media and use our online services;

·        to understand how visitors interact with our Website and each other;

·        to find out statistical information about the use of the Website;

·        to monitor the technical operation of our Website (e.g. response times, downloading / uploading errors);

·        to obtain other technical information relating to end user devices;

·        to administer our services and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

·        to compile statistical reports regarding visitor activity (for example, your IP address is used to approximate the country from which you access our Website, and we aggregate this information together so we can see from what regions or countries most of the visitors to our Website originate); and

·        to protect against and remove objectionable uploaded content.

This analysis is fundamental to the running of our online business and we therefore undertake such monitoring in the pursuit of our legitimate interests in improving our Website, and to provide a better service and source of information to visitors.

       
  1. DATA SHARING

We will share your information with third parties only in the ways that are described in this Privacy Policy. If you would like to find out more about how the third parties listed in this policy use your information, this should be set out in their respective privacy policies.

We keep your information confidential, but may disclose it to our personnel, suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this Privacy Policy. However, this is on the basis that they do not make independent use of the information, and have agreed to safeguard this information.

In addition, we may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).

If we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email, account message and/or a prominent notice on our website of any change in ownership or uses of this information, as well as any choices you may have regarding this information.

We may also disclose your personal information to third parties in order to enforce or apply the terms of agreements between us, to investigate potential breaches, or to protect the rights, property or safety of the companies forming part of the GGL Group, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

If you send us objectionable content, or behave in a disruptive manner when using our Website, we may process any personal information that you have submitted to us, including in your personal messages, to respond to and stop such behaviour.  Where we reasonably believe that you are or may be in breach of the law (i.e. the content you share on the Website amounts to harassment or is defamatory), we may use your personal information to inform relevant third parties about the content, such as your email or internet provider or law enforcement agencies.

  1. CONSUMER CONTROL AND OPT-OUT OPTIONS

If you do not wish to receive promotional or other marketing material from us or third parties then you can opt-out by clicking on the unsubscribe link in those emails or contacting us at [email protected] at any time. 

  1. YOUR RIGHTS IN RELATION TO PERSONAL DATA WHICH WE PROCESS RELATING TO YOU

You have a number of rights in relation to the way we process personal data about you.  Where an individual makes a request in accordance with provisions of the GDPR, we aim to comply without undue delay, and within one month at the latest.  Those data subject rights include the right to make the following requests:

  • to ask for confirmation and information about the personal data that we process about you, including a copy of data we are processing about you;
  • to have inaccuracies corrected or incomplete personal data made complete;
  • to ask us to restrict, stop processing, or to delete your personal data;
  • to request a machine readable copy of your personal data, which you can use with another service provider. Where it is technically feasible, you can ask us to send this information directly to another provider if you prefer; and
  • to not be subject to automated decision-making, including profiling; and
  • to make a complaint to the data protection supervisory authority.

To make a request, please let us know by contacting our Data Protection Manager on the details below.

  1. Data Retention

In accordance with data protection laws and good commercial practice, we do not retain data in a form that permits identification of the person(s) to whom it relates for any longer than is necessary.

If you would like us to stop using your personal information, please email us at [email protected]

  1. DATA RELATING TO CHILDREN

We do not knowingly use the Website to solicit data from or market or sell to children under the age of 13. If a parent or guardian becomes aware that his or her child has provided us with information or may be receiving communications from us or otherwise interacting with us without consent of a parent or guardian, we ask that this be brought to our immediate attention.  We will make it our priority to address this situation and delete information relating to a child as soon as practicable.  In such an event, please contact us at [email protected]

  1. Security OF DATA

We will take commercially reasonable, appropriate technical and organisational measures to ensure a level of security appropriate to the risk that could be encountered via the use of our Website and services, taking into account the likelihood and severity those risks might pose to the rights and freedoms of our Website visitors.

In particular, we will take precautions to protect against the accidental or unlawful destruction, loss or alteration, and unauthorised disclosure of or access to the personal information transmitted, stored or otherwise processed by us.

Please be aware that, while we make the security of our Website and your personal information a high priority and devote considerable time and resources to maintain robust IT security, no security system can prevent all security breaches. When you choose to share your personal information with us, you accept the aforesaid and provide your information at your own risk.  

  1. INTERNATIONAL DATA TRANSFERS

The personal data that we collect from you (or obtain about you) may be transferred to, and stored at, or accessed from a destination outside the European Economic Area (EEA).  For example, in addition to our own servers, we use US-based Dropbox, Inc. as a file hosting service for cloud-storage (www.dropbox.com).

Personal data may be transferred to and processed by staff operating outside the EEA who work for us or for one of our suppliers or third party service providers, many of whom may operate from multiple locations including non-EEA based operations or engage sub-processors located outside the EEA.  This includes staff engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services.

There are adequate safeguards in place to ensure that any international transfers of personal data to our group companies or third party service providers meet the requirements of EU data protection laws.

If you would like to find out more about these safeguards or if you have any other queries or comments in relation to this policy, please let us know by emailing us at [email protected]

  1. CHANGES TO THIS POLICY

This Privacy Policy may be updated from time to time. We will notify you of any changes to this policy by posting the new version of the Privacy Policy on our Website. You are advised to consult this Privacy Policy webpage regularly for any changes.

  1. HYPERLINKS TO THIRD PARTY WEBSITES

Our Website may contain hyperlinks to third party websites.  These third party websites operate independently from us, and we cannot accept any responsibility or liability for the privacy practices of such third parties nor the availability of these external sites or resources.  The appearance of such links on our Website is not an endorsement.  Should you use any of these websites, such use is at your own risk and we would advise that you review their respective privacy policies.

  1. CONTACT US

Questions, comments and requests in relation to this Privacy Policy are welcome and should be addressed to [email protected]

Alternatively, you may address these to our Data Protection Manager at GGL Group, 75 Buccleuch Street, Barrow-In-Furness, Cumbria, England, LA14 1QQ.

 

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