Full name of legal entity: Tremmorr Ltd
Email address: firstname.lastname@example.org
Postal address: 50 Wray Common Road, Reigate, Surrey, RH2 0NB
This privacy notice aims to give you information on how we collect and processes your personal data through your consensual use of our websites, including data you may provide when making an enquiry. It is important that you read this notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
This notice supplements the other notices and is not intended to override them. TREMMORR are the processors and are responsible for your personal data whilst it is in our care.
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 (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. Use the email address email@example.com for these concerns.
Please keep us informed if your personal data changes during your relationship with us. Our websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit. The most common scenario will be you arriving at one of our charity partners websites.
TREMMORR only uses your data for communicating with you regarding the current order and any future orders or services deemed relevant to you. The details we hold for our own purposes are the information supplied by you on our checkout form. All other information that is recorded in the use of our websites and services is to support your quick and easy passage to taking part in these events.
TREMMORR Statement of Intent
WE DO NOT SELL AND WILL NEVER SELL YOUR PERSONAL INFORMATION TO ANY THIRD PARTY WITHOUT YOUR PRIOR PERMISSION.
TREMMORR Direct Communications
The Data We Collect on You
Personal data, or personal information, means any information about an individual from which that person can be identified.
1) If you visit our website (regardless of where you visit it from):
• 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 this website.
• Profile Data – includes purchases, orders and enquiries made by you.
• Usage Data – includes information about how you use our website and our services.
2) If you make an enquiry about an event or charity:
• Identify Data includes your first name, last name & email address
• Contact Data correspondence address and telephone numbers.
3) Marketing and Communications Data includes your preferences in receiving marketing from us or our partners you have selected
• Identity Data, Contact Data and Marketing and Communications Data
• Demographic data includes age and gender.
• Financial Data includes your payment details.
• Transaction Data includes details about payments to and from you and other details of services, you have purchased from us.
How TREMMORR Collects Personal Data
How TREMMORR will Use Your Data
1) With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email or telephone, or post with information, news and offers on Our products and services. We fully protect your rights and comply with our obligations under the Data Protection Act 1998, the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015 and the General Data Protection Regulation 2018.
2) Advertisers whose content appears on Our Site may engage in what is known as “behavioural advertising” – advertising which is tailored to your preferences, based on your activity. Your activity is monitored using Cookies. You can control and limit your data used in this way by adjusting your web browser’s privacy settings. Please note that We do not control the activities of such advertisers, nor the information they collect and use. Limiting the use of your data in this way will not remove the advertising, but it will make it less relevant to your interests and activities on Our Site.
3) Where we need to comply with a legal or regulatory obligation. Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us. 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. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been broken down below.
Below is a breakdown of where and why TREMMORR will obtain and process data about you and the legal reasons for doing so.
We have used the following key for data types
1) To register you as a new user/customer
Type of Data – I & C
Lawful Basis of Processing – (a) Performance of a contract with you
2) To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
Type of Data – I, C, P & M
Lawful basis of processing (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
3) To enable you to partake in a prize draw, competition or complete a survey
Type of Data I, C, P, U & M
Lawful Basis of Processing – (a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
4) To administer and protect our business and our websites
(including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Types of Data – I, C & T
Lawful Basis for Processing (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
5) To deliver relevant website content to you and measure or understand the effectiveness of the content we serve to you
Types of Data – I, C, P, M, D & T
Lawful Basis for Processing – Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to improve our marketing strategies.
6) To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Types of Data – T & U
Lawful Basis for Processing – Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
7) To make suggestions and recommendations to you about goods or services that may be of interest to you
Types of Data – I, C, T, P & D
Lawful Basis for Processing – Data Necessary for our legitimate interests (to develop our products/services and grow our business)
You will receive marketing communications from us if you have requested information from us, if you provided us with your details when you entered an event or registered interest in a charity and, in each case, you have not opted out of receiving that marketing.
Third-party marketing – We will get your express opt-in consent before we share your personal data with any charity or company outside of TREMMORR for marketing purposes. Opting out, you can ask us or third parties to stop sending you marketing messages at any time by contacting us or using the unsubscribe options on our emails. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of signing up to take part in an event for a charity.
We may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. They help us to improve our site and to deliver a better and more personalised service. They enable us:
1. To estimate our audience size and usage pattern.
2. To store information about your preferences, and so allow us to customise our site according to your individual interests.
3. To speed up your searches.
4. To recognise you when you return to our site.
Change of Purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of your Personal Data
We may have to share your personal data with the parties set out below for the purposes set out in the table above.
• External Third Parties as set out in the Explained Terms section.
• Third parties 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 notice. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
• We will transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. Where your personal data is to be transferred to any country not appearing on the European Commission list, we will ensure there is an agreement in place between us and the relevant third party which contains certain requirements that are designed to protect your personal data.
Data Security & Retention
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. 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.
How long will you use my personal data for? We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. By law we have to keep basic information about our customers (including Financial and Transaction Data) for six years after they cease being customers for tax purposes. In some circumstances you can ask us to delete your data.
Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see the Explained Terms to find out more about these rights. If you wish to exercise any of these rights, please contact us. 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 may 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 may 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.
Explanation of Key Terms
LAWFUL BASIS – Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us. Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
THIRD PARTIES External Third Parties
• Charities based in the EEA where you have chosen to take part in an event for your chosen charity.
• Events based in the EEA where you have chosen to take part in
• As per our license with RunBritain or National Governing Body of running, we submit the race results which include your name, club and age category and they are posted on the relevant website.
• Professional advisers including lawyers, bankers, auditors and insurers based in the EEA who provide banking, legal, insurance and accounting services.
YOUR LEGAL RIGHTS
You have the right to: 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 affects 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:
(a) if you want us to establish the data’s accuracy;
(b) where our use of the data is unlawful but you do not want us to erase it;
(c) 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
(d) 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.