Legacy Elite Performance Limited (Company Number 10305632) of c/o Derede Associates Limited, Unit 14a Waterside Business Park, Livingstone Road, Hessle, East Yorkshire, HU13 0EG (us or we) are committed to protecting your personal data and respecting your privacy.

Introduction

This policy (together with our Conditions of Use as set out on our website www.legacyeliteperformance.com, (Conditions of Use) and any additional terms of use incorporated by reference into the Conditions of Use, together our Terms of Use) applies to your use of:

• Legacy Excel mobile application software (App) available on our site, once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device).
• Any of the services accessible through the App (Services) that are available on the App Site or other sites of ours (Services Sites).

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

Children/Minors – We are dedicated to the protection of children’s personal information, and we will not actively market to children or use this information for purposes outside the Legacy Excel service. See the section below called Policy for Children which deals with how what data will collect, and how we will process any data relating to children/minors (whether provided by the child/minor or by their parents/guardian). The Policy for Children will (in relation to information relating to children/minors) supersede any conflicting general provisions in this Privacy Policy. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

This policy is provided in a layered format so you can click through to the specific areas set out below. Alternatively, you can download a pdf version of the policy here

IMPORTANT INFORMATION AND WHO WE ARE

THE DATA WE COLLECT ABOUT YOU

HOW IS YOUR PERSONAL DATA COLLECTED?

HOW WE USE YOUR PERSONAL DATA

DISCLOSURES OF YOUR PERSONAL DATA

INTERNATIONAL TRANSFERS

DATA SECURITY

DATA RETENTION

YOUR LEGAL RIGHTS

GLOSSARY

DESCRIPTION OF CATEGORIES OF PERSONAL DATA

Important information and who we are

Legacy Elite Performance Limited is the controller and is responsible for your personal data.

We have appointed a data privacy manager. If you have any questions about this privacy policy, please contact them using the details set out below.

Contact details

Our full details are:

• Full name of legal entity: Legacy Elite Performance Limited
• Name or title of data privacy manager:
• Email address of data privacy manager: info@legacyeliteperformance.com
• Postal address: c/o Derede Associates Limited, Unit 14a Waterside Business Park, Livingstone Road, Hessle, East Yorkshire, HU13 0EG
• Telephone number: 01482 450281

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 or other competent supervisory authority of an EU member state if the App is downloaded outside the UK.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

This version was last updated on the date set out above. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you when you next start the App or log onto one of the Services Sites. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services.

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.

Third party links

Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. 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, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.

The data we collect about you

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

• Identity Data.
• Contact Data.
• Financial Data.
• Transaction Data.
• Device Data.
• Content Data.
• Profile Data.
• Usage Data.
• Marketing and Communications Data.
• Location Data.

We explain these categories of data here.

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 App feature. 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.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

How is your personal data collected?

We will collect and process the following data about you:

• Information you give us. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us about you by filling in forms or completing data fields on the App and the Services Sites (together Our Sites), or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the App Site, download or register an App, subscribe to our Services, search for an App or Service, make an in-App purchase, enter a competition, promotion or survey, and when you report a problem with an App, our Services, or any of Our Sites. If you contact us, we will keep a record of that correspondence.
• Information we collect about you and your device. Each time you visit one of Our Sites or use one of our Apps we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies. Please see our cookie policy for further details.
• Location Data. We also use GPS technology to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings.
• Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
  • Device Data from the following parties:
    • analytics providers such as Google based outside the EU;
    • advertising networks inside or outside the EU; and
    • search information providers based inside or outside the EU.
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside or outside the EU;
  • Identity and Contact Data from data brokers or aggregators based inside or outside the EU; and
  • Identity and Contact Data from publicly available sources such as Companies House and the electoral register based inside the EU.
• Unique application numbers. When you want to install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.

Cookies

We use cookies to distinguish you from other users of the App, App Site, the distribution platform (Appstore) or Services Sites and to remember your preferences. This helps us to provide you with a good experience when you use the App or browse any of Our Sites and also allows us to improve the App and Our Sites. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy.

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.

Click here to find out more about the types of lawful basis that we will rely on to process your personal data.

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.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Purposes for which we will use your personal data

Disclosures of your personal data

When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table Purposes for which we will use your personal data:

• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• Specific third parties listed in the table Purposes for which we will use your personal data above.
• 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 policy.

International transfers

Some of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, 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 by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Data security

All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer (SSL) technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, 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.

We will collect and store personal data on your Device using application data caches and browser web storage (including HTML5) and other technology.

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

Data retention

By law we have to keep basic information about our customers (including Contact, Identity, 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: see Your legal rights below for further information.

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.

In the event that you do not use the App for a period of 12 months then we will treat the account as expired and your personal data may be deleted.

Your legal rights

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

Please click on the links below to find out more about these rights:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer or your personal data.
• Right to withdraw consent.

You also have the right to ask us not to continue to process your personal data for marketing purposes.

You can exercise any of these rights at any time by contacting us at info@legacyeliteperformance.com or Legacy Elite Performance Limited, c/o Derede Associates Limited, Unit 14a Waterside Business Park, Livingstone Road, Hessle, East Yorkshire, HU13 0EG.

Policy for Children

The Legacy Excel service may be used to encourage engagement and participation by children in sporting and other activities, and we anticipate that children will wish to access the Legacy Excel service, visit Our Sites, use the Services and consume Content. We encourage parents and guardians to be actively involved in assisting and supervising their children when using Legacy Excel, although we have carefully designed our system as a child-friendly online environment.

Legacy Excel avoids collecting or saving any personal/identifying data relating to children, and we routinely anonymise information on all users under 18 years of age which we are aware of. We will not actively market chargeable products or services to children, or use any information provided by children for purposes outside the Legacy Excel service.

We ask that all users under 18 years of age obtain permission from their parent/guardian before personally registering to use the Legacy Excel service. We also require all use by children under 13 of Legacy Excel, including input of data, is permitted only with adult supervision (by the registered parent or guardian account holder). Parents or legal guardians should supervise children when online and we recommend that parental control tools are used to manage use by all children.

Glossary

Lawful basis

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product 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 obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Third parties

Internal third parties

Other companies in our corporate group acting as joint controllers or processors and who are based in the EEA and provide IT and system administration services and undertake leadership reporting.

External third parties

Service providers acting as processors (based within and outside the EEA) who provide IT and system administration services.

Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers (based within and outside the EEA) who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue and Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.

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 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:
  1. if you want us to establish the data's accuracy;
  2. where our use of the data is unlawful but you do not want us to erase it;
  3. 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
  4. 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.

Description of categories of personal data

• Identity Data: first name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender.
• Contact Data: billing address, delivery address, email address and telephone numbers.
• Financial Data: bank account and payment card details.
• Transaction Data: includes details about payments to and from you and details of in-App purchases (where applicable).
• Device Data: includes the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting.
• Content Data: includes information stored on your Device, including login information, performance and other personal profile data, photos, videos or other digital content, check-ins.
• Profile Data: includes your username and password, in-App purchase history, your interests, preferences, feedback and survey responses.
• Usage Data: includes details of your use of any of our Apps or your visits to any of Our Sites including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
• Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Location Data: includes your current location disclosed by GPS technology.