1. What is the purpose of this document?
Euro Sport & Event Management Ltd (“we“, “our“, “us“, “ESEM”) along with all other members of the ESEM group of companies (the “Group”) is committed to protecting the privacy and security of our partner’s/business contacts’ personal information. This privacy notice describes how we collect and use personal information about you during and after your working relationship with us, in accordance with data protection legislation, including, as applicable: the Data Protection Act 2018, the UK General Data Protection Regulation (“UK GDPR”) and the General Data Protection Regulation (EU) 2016/679 (“EU GDPR”) (all as amended, updated or re-enacted from time to time).
ESEM is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about our partners/business contacts including our travel agent clients (“you”, “your”). We are required under data protection legislation to notify you of the information contained in this privacy notice.
It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information. These other applicable privacy notices include for example our website privacy notice.
2. The kind of information we hold about you
We may collect, store, and use the following categories of personal information about you:
- Contact details such as name, title, telephone numbers and email addresses; and
- Information regarding your organisation such as your role, company address and location.
We typically collect personal information about you/your organisation when you interact with us including via our website, email or telephone. We may also collect additional personal information throughout the period of us working with you.
3. How we will use information about you
We will use your personal information as follows:
- To administer or otherwise carry out our obligations arising from any contracts entered into with you/your organisation or to take steps to enter into any contracts between you/your organisation and us.
- To fulfil any requests you have made, or to contact you with information relevant to your interaction with us.
Our lawful basis for these activities above is necessity to perform any contract we have with you/your organisation.
- For audit purposes of the Group.
- For fraud monitoring and prevention.
Our lawful basis for these activities above is the pursuit of our legitimate interests of operating and expanding our business activities lawfully.
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information. If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you or your organisation (such as providing our services to you). We will only use your personal information 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 we need to use your personal information 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 information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.
4. Data Sharing
We may share your data with third parties, including third-party service providers and other entities in the Euro Sport & Event Management Group. We may sometimes be obliged to disclose your personal information by law such as by a regulator with appropriate power or court order or to otherwise comply with the law.
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.
In the course of carrying out the activities referred to above we may transfer your personal information between our Group within the UK and Spain.
We will take steps to ensure that your data is adequately protected in accordance with Data Protection Act 2018, the UK GDPR and the EU GDPR (where applicable). In the event that personal data is transferred outside of the UK or the EEA to an organisation in a country which is not subject to an adequacy decision by the EU Commission or considered adequate as determined by applicable data protection laws, we will take steps to ensure your personal information is adequately protected (e.g. by way of approved Standard Contractual Clauses or a vendor’s Processor Binding Corporate Rules or by relying on such other data transfer mechanisms as available under applicable data protection laws). A copy of the relevant mechanism can be obtained for your review on request by using the contact details below.
5. Data retention
How long will we use your information for?
We will only retain your personal information 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. Details of retention periods for different aspects of personal information we process are available in our Data Retention Policy which is available from Christian Machowski at firstname.lastname@example.org. 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. In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer working with us, we will retain and securely destroy your personal information in accordance with our Data Retention Policy.
6. Rights of access, correction, erasure, and restriction
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes (for example, email marketing or phone calls).
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing 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.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact Christian Machowski at email@example.com in writing and they will explain any conditions that may apply.
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such 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 the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact Christian Machowski at firstname.lastname@example.org. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Further guidance on your rights is available from the Information Commissioner’s Office (https://ico.org.uk/ ). You have the right to complain to the UK’s supervisory office for data protection, the Information Commissioner’s Office at https://ico.org.uk/concerns/ if you believe that your data has been processed unlawfully.
7. Changes to this Privacy Notice
If you have any questions about this privacy notice or how we handle your personal information, please contact Christian Machowski at email@example.com. We reserve the right to update this privacy notice at any time for example if the law or regulatory requirements change, if technology changes or to make the Group’s operations and procedures more efficient. We will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
This privacy notice does not override any applicable national data privacy laws and regulations in countries where the Group operates.
Edition Date: February 2023