Privacy policy

SPORTING MEMORIES NETWORK CIC & THE SPORTING MEMORIES FOUNDATION
PRIVACY POLICY

1. INTRODUCTION

Sporting Memories Network CIC (SMN), Sporting Memories Foundation (SMF), Sporting Memories Network Scotland (SMNS) and Sporting Memories Foundations Scotland (SMFS) are committed to protecting your privacy and security. This policy explains how and why we use your personal data and to make sure you remain informed and in control of your information.

From the 25th May 2018, SMN, SMF, SMNS and SMFS will ask anyone requesting information or regular contact to ‘opt-in’. This means you’ll have the choice as to whether you want to receive regular updates from us, such as the newsletter and join our update list.

You can also decide:

• To stop receiving communications from us
• To update information
• To have your information removed from our systems
• To request a summary of what information we hold on you

We are also committed to keeping you informed in the unlikely event of a data breach.

We also promise that:

• We will not keep information for longer than ‘absolutely necessary’
• That we hold a regular review of all data we process
• That we will never sell your personal data
• That we will only ever share data with organisations we work with where necessary and if its privacy and security are guaranteed.
• That we will supply you with a record of the information held on request.

You can decide not to receive communications or change how we contact you at any time. If you wish to do so please contact us by email chris@sportingmemoriesnetwork.com or by writing to Sporting Memories Network, Ashfords, 2 Manor Court, Manor Mill Lane, Leeds, LS11 8LQ.

Questions?

Any questions you have in relation to this policy or how we use your personal data should be sent to admin@sportingmemoriesnetwork.com or addressed to Chris Wilkins, Sporting Memories Network, Ashfords, 2 Manor Court, Manor Mill Lane, Leeds, LS11 8LQ.

2. ABOUT US

Your personal data (i.e. any information which identifies you, or which can be identified as relating to you personally) will be collected and used by Sporting Memories Network, company number 7811301. It may also be used by Sporting Memories Foundation, company number 08571922, Sporting Memories Network Scotland, company number SC409470 and Sporting Memories Foundation Scotland, company number SC047268.

3. WHAT INFORMATION WE COLLECT

Personal data you provide

We collect data you provide to us. This includes information you give when joining or registering as a member of our groups, as a volunteer, when making a donation, placing an order for merchandise or communicating with us. For example:

• personal details (name, email, address, telephone etc.) when you join our groups or volunteer with us
• financial information if donating or buying merchandise (payment information such as credit/debit card Please see section 8 for more information on payment security); and
• If you purchase merchandise as a gift for someone, your details will be recorded (as will the recipients) and your relationship to that person may be recorded.

Information we generate

We conduct research and analysis on the information we hold, which can in turn generate personal data. For example, by analysing your interests and involvement with our work we may be able to build a profile which helps us decide which of our communications are likely to interest you.

Section 7 (Research and profiling) contains more information about how we use information for profiling).

Information from third parties

We sometimes receive personal data about individuals from third parties. For example, if we are partnering with another organisation (e.g. you provide your information to another organisation we’re collaborating with on a joint venture). Also, as explained in Section 11 (Cookies and links to other sites), we may use third parties to help us conduct research and analysis on personal data (and this can result in new personal data being created).

We may collect information from social media where you have given us permission to do so, or if you post on one of our social media pages.

4. HOW WE USE INFORMATION

We only ever use your personal data with your consent, or where it is necessary in order to:

• enter into, or perform, a contract with you;
• comply with a legal duty;
• protect your vital interests;
• for our own (or a third party’s) lawful interests, provided your rights don’t override the these.

In any event, we’ll only use your information for the purpose or purposes it was collected for (or else for closely related purposes):

Marketing

We use personal data to communicate with people, to promote Sporting Memories. This includes keeping you up to date with our news, updates, campaigns.

For further information on this please see Section 5 (Marketing).

Administration

We use personal data for administrative purposes (i.e. to carry on our business activities). This includes:

• performing our obligations to members of our groups;
• fulfilling orders for goods or services (where placed online), helping us respect your choices and preferences (e.g. if you ask not to receive marketing material, we’ll keep a record of this).

Internal research and analysis

We carry out research and analysis on our supporters, and customers to determine the success of campaigns and better understand behaviour and responses and identify patterns and trends.

This helps inform our approach towards understanding what would make Sporting Memories more effective organisations. Understanding our members, supporters, donors, volunteers, their interests and what they care about also helps us provide a better experience (e.g. through more relevant communications).

Research and profiling

We evaluate, categorise and profile personal data in order to tailor materials, services and communications and prevent unwanted material from filling up your inbox. This also helps us understand our supporters, improve our organisation and carry out research. Further information on profiling can be found in Section 7 (Research and profiling).

5. DISCLOSING AND SHARING DATA

We will never sell your personal data. If you have opted-in to marketing, we may contact you with information about our partners, or third-party products and services, but these communications will always come from SMN or SMF and are usually incorporated into our own marketing materials (e.g. newsletters).

We may share personal data with subcontractors or suppliers who provide us with services.

For example, if you order something from SMN your name and address will be shared with the delivery company. However, these activities will be carried out under a contract, which imposes strict requirements on our supplier to keep your information confidential and secure.

Occasionally, where we partner with other organisations, we may also share information with them (for example, if you register to attend an event being jointly organised by us and another organisation). We’ll only share information when necessary and we’ll make sure to notify you first.

6. MARKETING

From 25th May 2018, SMN, SMF, SMNS and SMFS will ask its supporters to “opt-in” for most communications. This includes all our marketing communications (the term marketing is broadly defined and, for instance, covers information about elderly isolation, dementia and our services/activities at Sporting Memories).

This means you’ll have the choice as to whether you want to receive these messages.

You can decide not to receive communications or change how we contact you at any time. If you wish to do so please contact admin@sportingmemoriesnetwork.com or write to Sporting Memories Network, Ashfords, 2 Manor Court, Manor Mill Lane, Leeds, LS11 8LQ.

What does ‘marketing’ mean?

Marketing does not just mean offering things for sale, but also includes news and information about:

• our organisation and its activities
• our role in supporting people over the age of 55 with isolation or early dementia issues through sporting reminiscence
• benefits and offers.
• products, services and offers (our own, and those of third parties) which may interest you.

When you receive a communication, we may collect information about you respond to or interact with that communication, and this may affect how we communicate with you in future.

Newsletters

The Sporting Memories newsletter is provided as a benefit of subscribers. We send these out to all our subscribers (unless you specifically ask us not to) and you can choose to unsubscribe from general marketing communications without giving up your subscription to the SMN, SMF, SMNS or SMFS.

7. RESEARCH AND PROFILING

This section explains how and why we use personal data to build profiles which enable us to understand our supporters, improve our relationship with them, and provide a better supporter experience.

Analysis and grouping

We analyse our support to determine common characteristics and preferences. We do this by assessing various types of information including behaviour (e.g. previous responses) or demographic information (e.g. age or location).
By grouping people together on the basis of common characteristics, we can ensure that group is provided with communications, products, and information that is most important to them. This helps prevent your inbox from filling up, and also means we aren’t wasting resources on contacting people with information thats isn’t relevant to them.

Profiling to help us understand our supporters

We profile individuals who opt in through our site and our membership services in terms of:

• How often they open emails from us
• How they respond to email correspondence
• Length of engagement

We collect information on preferences and interests (eg on different sports) so that we know what material you are mostly likely to be interested in.

Anonymised data

We may aggregate and anonymise personal data so that it can no longer be linked to any particular person. This information can be used for a variety of purposes, such as recruiting new supporters, or to identify trends or patterns within our existing supporter base. This information helps inform our actions and improve our campaigns, products/services and materials

8. HOW WE PROTECT DATA

We employ a variety of physical and technical measures to keep your data safe and to prevent unauthorised access to or use or disclosure of your personal information.

Electronic data and databases are stored on secure computer systems and we control who has access to information (using both physical and electronic means). Our staff receive data protection training and we have a set of detailed data protection procedures which personnel are required to follow when handling personal data.

Payment security

All electronic forms that request financial data will use the Secure Sockets Layer (SSL) protocol to encrypt the data between your browser and our servers.

If you use a credit card to make a donation or purchase something on-line, we will pass your credit card details securely to our Merchant Service Provider.

Our merchant service provider complies with the payment card industry data security standard. Counselling Tutor will never store your card details on any of our internal computer or network systems.

Of course, we cannot guarantee the security of your home computer or the internet, and any online communications (e.g. information provided by email or our website) are at the user’s own risk.

9. STORAGE

Where we store information

SMN, SMF, SMNS and SMFS operations are based in the UK and we store our data within the European Union. Some organisations which provide services to us may transfer personal data outside of the EEA, but we’ll only allow them to do so if your data is adequately protected.

How long we store information

We will only use and store information for so long as it is required for the purposes it was collected for. How long information will be stored for depends on the information in question and what it is being used for. For example, if you ask us not to send you marketing emails, we will stop storing your emails for marketing purposes (though we’ll keep a record of your preference not to be emailed).

We continually review what information we hold and delete what is no longer required. We never store payment card information.

10. KEEPING YOU IN CONTROL

We want to ensure you remain in control of your personal data. Part of this is making sure you understand your legal rights, which are as follows:

• the right to confirmation as to whether or not we have your personal data and, if we do, to obtain a copy of the personal information we hold (this is known as subject access request);
• the right to have your data erased (though this will not apply where it is necessary for us to continue to use the data for a lawful reason);
• the right to have inaccurate data rectified;
• the right to object to your data being used for marketing or profiling;
• the right to complain to a supervisory authority; and
• where technically feasible, you have the right to personal data you have provided to us which we process automatically on the basis of your consent or the performance of a contract. This information will be provided in a common electronic format.

Please keep in mind that there are exceptions to the rights above and, though we will always try to respond to your satisfaction, there may be situations where we are unable to do so.

If you would like further information on your rights or wish to exercise them, please write to Chris Wilkins at Sporting Memories Network, Ashfords, 2 Manor Court, Manor Mill Lane, Leeds, LS11 8LQ.

We can provide you with a template ‘subject access form’ which includes guidance on how to make your request (and will help us respond more quickly). Please contact us for a copy of this.

Complaints

You can complain to SMN, SMF, SMNS or SMFS directly by contacting Chris Wilkins using the details set out above. If you wish to make a complaint (which does not directly relate to your data protection and privacy rights), you can do so in accordance with our organisation's complaints policy.

If you are not happy with our response, or you believe that your data protection or privacy rights have been infringed, you can complain to the UK Information Commissioner’s Office which regulates and enforces data protection law in the UK. Details of how to do this can be found at www.ico.org.uk.

11. COOKIES AND LINKS TO OTHER SITES

Cookies

We use cookies for the following purposes:

• (a) Authentication - we use cookies to identify you when you visit our website and as you navigate our website.
• (b) Status - we use cookies to help us to determine if you are logged into our website.
• (c) Personalisation - we use cookies to store information about your preferences and to personalise the website for you.
• (d) Security - we use cookies as an element of the security measures used to protect our website and services generally.
• (f) Analysis - we use cookies to help us to analyse the use and performance of our website and services.
• Cookies used by our service providers

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/.

Managing cookies

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:

• (a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
• (b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
• (c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
• (d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies(Internet Explorer);
• (e) https://support.apple.com/kb/PH21411 (Safari); and
• (f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge)

Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use all the features on our website.

Links to other sites

Our website contains hyperlinks to other websites. We are not responsible for the content or functionality of any of those external websites (but please let us know if a link is not working).

If an external website requests personal information from you (e.g. in connection with an order for goods or services), the information you provide will not be covered by SMN, SMF, SMNS or SMFS Privacy Policy. We suggest you read the privacy policy of any website before providing any personal information.

When purchasing goods or services from any of the businesses that our site links to, you will be entering into a contract with them (agreeing to their terms and conditions) and not with SMF, SMN, SMFS or SMNS.

We use a third party provider, MailChimp to deliver our e-newsletters. Through it we gather statistics around email opening and clicks using industry standard technologies to help us monitor and improve our e-newsletter. For more information, please see MailChimp Privacy Policy You may unsubscribe at any time which will remove your contact details from our newsletter database. You may also re subscribe whenever you wish via our website.

We also use a third party provider, Donorfy, as our customer relation management system. The system holds all contact details and permissions to contact for all individuals we engage with. Further details on Donorfy's privacy policy can be found on their website.

You'll also find us on Facebook and Instagram via Meta, Twitter, as well as LinkedIn.

Here are their privacy policies:
Meta Privacy Policy
Twitter Privacy Policy
LinkedIn Privacy Policy
Donorfy Privacy Policy

12. CHANGES TO THIS PRIVACY POLICY

We’ll amend this Privacy Policy from time to time to ensure it remains up-to-date and accurately reflects how and why we use your personal data. The current version of our Privacy Policy will always be posted on our website.

This Privacy Policy was last updated on the 10th August 2022

Next Audit Cycle September 2023.