Privacy Notice

 

COOPAH LIMITED - PRIVACY NOTICE

 

About our privacy notice

Welcome to Coopah Limited’s (‘Coopah’)’s privacy notice.  Coopah takes your privacy seriously. Please read this privacy notice carefully as it contains important information about who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

Controller

Coopah is a digital media, sports and events company and is the data controller for the purposes of this privacy notice.  We are responsible for certain personal data about you that we collect and use to supply you with our products and services via our website and/or our app.  If you have any questions about this notice or about how we handle your data, please ’contact us’ as follows:

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

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 your relationship with us.

Types of personal data

Personal data or personal information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed. This is known as anonymised data, which falls outside the scope of Data Protection Laws.

Coopah may collect, use, store and transfer different kinds of personal data about you which we have grouped together:

·       Identity Data includes first name, last name, username or similar identifier and title.

·       Contact Data includes billing address, delivery address, email address and telephone numbers.

·       Transaction Data includes details about payments to and from you and other details for the provision of services you have purchased from us.

·       Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website/app.

·       Profile Data includes your username and password, searches made by you, your ratings and comments, preferences, feedback and survey responses, your training regime, your progress, your personal best. 

·       Usage Data includes information about how you use our website/app and services.

·       Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

·       Special Category Data: includes your heart rate, and information that could be used to make an assessment about your health or fitness levels such as personal best, running speed or recovery time after training. 

·       Location Data: includes your device’s GPS-based location as collected by your network or service.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract or where you have provided us with your express consent, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel a product you have purchased from us but we will notify you if this is the case at the time.

How we collect your personal data

Directly from you: You give us your personal data in your direct interactions with us. Such personal data includes Identity Data, Contact Data, Financial Data, Profile Data, Usage Data, Technical Data, Marketing and Communications Data and special category data (i) by filling in forms on our website/app (ii) by leaving ratings and comments (iii) by corresponding with us by email or post (iv) by calling us over the telephone.

This includes personal data you provide when you:

  • subscribe to our service or publications.

  • request marketing to be sent to you.

  • give us feedback or contact us if you have any concerns.

  • participate in our marketing or other promotional events.

·       From your use of our website/app:

Coopah gathers information and statistics collectively about visitors to our website/app. Analysis of this information demonstrates the most frequently used sections of the website/app and assists us in continually improving the online service. You give us your personal data, which includes Profile Data, Usage Data, Technical Data and/or Marketing and Communications Data when you use our website/app or which we have agreed with you to use or when you review any publications or marketing material we send you. Please see our cookies notice for more information.

Indirectly: Third-party sources: We may receive Identity Data Contact Data, Special Category Data or Location Data about you from third parties such as Garmin or Strava when:

·       we provide our services or other parties send us your personal data to enable the provision of those service. 

·       you provide your personal data to a third party for the purpose of sharing it with us.

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How we use your personal data

Coopah will only use your personal data when the law allows us to. We will use your personal data in the following circumstances:

  • Performance of a contract: Where we need to perform the contract we are about to enter into or have entered into with you. For example when you sign up to our services.

  • Legal obligation: Where we need to comply with a legal obligation. For example for accounting or legal purposes.

  • Legitimate interests: 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.

  • Consent: We may rely on consent as a legal basis for processing your personal data for example where we are processing Special Category Data, or in order to send direct marketing to you. Where we do rely on consent you have the right to withdraw consent at any time. Please contact us at this  link to withdraw consent. Please also see Marketing communications and Special Category data sections below.

 

Purposes for which we will use your personal data

We have set out below in a table format a description of all the ways we plan to use your personal data and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Special Category data

Due to the nature of our services you may provide special categories of personal data to us. Special categories of personal data under Data Protection Laws can include health-related information or information that can be used to infer conclusions regarding an individual’s health or fitness. As a user of our services you may provide this information for use of the service. Where this is the case, our lawful basis for processing special categories of data is with your explicit consent.

 

 Marketing communications

You may receive marketing communications from Coopah if you have if you have consented for us to send you this information or if you  have requested information from us or purchased products from us and you have not opted out of receiving that marketing.

You have the right to object to processing of your personal data for direct marketing purposes at any time. You can unsubscribe from receiving marketing communications from us by using the unsubscribe methods contained in communications we send to you or by contacting us. Please contact us at this  link if you would like to unsubscribe. 

How we share your personal data

We may share your personal data in order to provide our services to you we have set out details of such parties below. All third parties to which we transfer data are required to respect your personal data, keep it secure and process it only for the specified purposes for which it has been collected.

  • Internally: Your personal data will be used by our employees and contractors who are working on providing your services to you on a need-to-know basis.

  • Suppliers: This would include service providers who support our business including IT and communication suppliers, accounting software suppliers, email notification suppliers and outsourced business support to ensure our service runs smoothly.

  • Third parties with whom we partner: such as charities and other organisations who may have generated a code so that you can use our services and our app, or other fitness based apps that we engage with to provide our services such as Strava. 

  • Professional advisers: This would include lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

  • Law enforcement bodies, regulators and other authorities: This is to comply with our legal requirements or adhere to good practices.

  • Advertising networks and analytics service providers: This is to support and display ads on our website, apps and other social media tools.

  • Third parties context of sale:  This is in the context of the acquisition or transfer of any part of our business or in connection with the business reorganisation. 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 notice.

International transfers

It is sometimes necessary for us to transfer your personal data to countries outside the UK. In those cases we will comply with applicable UK laws designed to ensure the privacy of your personal data.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

·       We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; or

·       Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

To find out more about the specific safeguarding mechanism used please contact us at this link.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, 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.

The transmission of information via the internet is not completely secure. Although we will take reasonable measures to protect your personal data, Coopah cannot guarantee the security of your information transmitted and any transmission is at your own risk.

Data storage and retention

Coopah will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal information we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means and the applicable legal, regulatory, tax, accounting or other requirements.

Coopah may 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. 

Children data

This website/app is not intended for children and we do not knowingly collect data relating to children. Pursuant to Data Protection Laws this means to individuals under the age of 13 or 16 depending on the country.

Data Subject Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see below (Your legal rights) to find out more about these rights. If you wish to exercise any of these rights please contact our privacy team. 

 No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

 

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Your legal rights

 Request access to your personal data: This is known as a "data subject access request" and enables you to receive a copy of the personal data Coopah hold about you.

Request correction of your personal data: This enables you to have any incomplete or inaccurate information we hold about you corrected.

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. Note: We may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you at the time of your request.

Object to processing of your personal data: This is where we are processing your personal data based on a legitimate interest or those of a third party and you may challenge this.  However, we may be entitled to continue processing your information based on our legitimate interests or where this is relevant to any legal claims. 

Request restriction of processing your personal information: This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the information's accuracy (b) where our use of the information is unlawful but you do not want us to erase it (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.

Request transfer of your personal information (“data portability”): This is where in some circumstances we will provide to you or a third party you have chosen your personal data in a structured, commonly used, machine-readable format.

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

Automated decision making:  This is where decisions are made about you by automated means. We do not carry out automated decision making which results in legal or similarly significant effect.

 

Last updated: October 2024