INTRODUCTION

1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED & USED
4. DISCLOSURES OF YOUR PERSONAL DATA
5. INTERNATIONAL TRANSFERS
6. DATA SECURITY
7. DATA RETENTION
8. YOUR LEGAL RIGHTS
9. WHO WE ARE, SCOPE & IMPORTANT INFORMATION

Controller

Concept Apps Ltd (referred to as we, us or our in this processing notice) is the controller and responsible for your personal data. We operate the site www.teamfeepay.com (Site) and the portal accessible through that Site (Portal). If you have any questions about this processing notice (including any requests to exercise any of your legal rights) please contact us by emailing support@teamfeepay.com.

Purpose of this Processing Notice

This processing notice aims to give you information on how we collect and process your personal data in a variety of circumstances. It is important that you read this processing notice so that you are fully aware of how and why we are using your data. This version was last updated on 25^th May 2023 and previous versions can be obtained by contacting us.

This notice only applies whenever we are acting as controller, and does not apply to any personal data that you provide to (or is provided to us by) any client of ours (in respect of whom, we are known as a “processor” for the purposes of data protection law). That organisation is the “controller” of that personal data (and they will be controller of all the personal data collected through our Portal). For example, this would include the registration data that you give to your club when signing up as a member – the club is the controller of that personal data and you should speak to it if you have any questions about the personal data it collects or its approach to data protection law.

2. THE DATA WE HOLD ABOUT YOU

Personal data means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about you when acting as controller, which we have grouped together as follows:

• Identity Data includes first name and last name, title and date of birth;
• Contact Data includes email address, postal address and phone number;
• 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;
• Usage Data includes information about how you use our website products and services and cookie data which is collected by our website
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we

have with you 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 services).

Your Duty to Inform us of Changes

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.

3. HOW IS YOUR PERSONAL DATA COLLECTED & USED?

We use different methods to collect personal data from and about you. The ways we collect it, what we collect and how and why we use that personal data is set out below:

Personal Data Type	Collection Method	Basis of Use (as appropriate)	Purpose
Identity Data Contact Data	Interactions instigated by you Data capture forms	Consent Contrac Legitimate Interests (to run our company)	To contact you To permit access to our Site and Portal To analyse and improve user relationships and interactions  To perform a contract we have entered into with a third party (like your club or organisation who is our client)
Technical Data Usage Data	Interaction with websites      Use of cookies	Legitimate interests (to administer our IT systems)	To keep our online avenues working, up to date and effective· To administer and protect our business and our website(including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data
Identity Data  Contact Data     Marketing and Communication s Data	From third parties like social media companies, advertising networks, electronic payment providers, data aggregators or your club or organisation	Consent Contract    Legitimate Interests (to run our company or deliver services to you)	To deliver our services to you To occasionally provide marketing content when accessing the Site or Portal
Identity Data Contact Data Marketing and Communication s Data	From you	Consent	To check your preferences regarding, and if requested send you, marketing content through email, text message or other methods you choose
Any of the above	As above	Legitimate interests (to protect and run our company)     Compliance e with law	Ancillary purposes, such as back-ups and archiving      Dealing with legal obligations (such as compliancewith tax law and identity verification requirements)

NOTE:

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).

Marketing

From time to time, we may ask users of our Site and Portal if they would like to receive texts or emails (or other methods that we will notify you at the time) from us relating to upcoming events and webinars or regarding offers and gift vouchers for purchasing goods and services from some organisations who ask us to do this. You do not have to sign up to receive these messages.

Where you have agreed to web advertising we may use certain limited information about you, such as your email address may be used to generate custom and lookalike audiences for advertising targeting to drive traffic to our website or promote our products and services. We may also exclude certain customers from certain digital advertising campaigns. We may also profile your data to provide you with marketing and offers that are relevant to you.

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us, as appropriate, at any time. Where you opt-out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service experience or other transactions.

We have a legitimate interest in processing your personal information for product and service purposes (see above ‘How we use your personal data’). This means we do not usually need your consent to send you product or service communications.

However, where consent is needed, we will ask for this consent separately and clearly.

We will get your express opt-in consent before we share your personal data with any company outside of our own for marketing unrelated to our company.

Cookies

You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see cookie policy.

4. DISCLOSURES OF YOUR PERSONAL DATA

From time to time, we may have to share your personal data with the parties (all established in the UK or European Union unless otherwise stated) set out below for the purposes set out in the table in paragraph 4 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 processing notice.
• HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances;
• Professional advisers including lawyers, bankers, auditors and insurers based in the European Union or the United Kingdom who provide consultancy, banking, legal, insurance and accounting services;
• Service providers such as salesforce.com, inc (t/a Heroku) who support our Platform and may transfer personal data outside EEA (on the basis of EU Model Clauses or Binding Corporate Rules (with more information available here: https://www.salesforce.com/company/privacy/)); Amazon Web Services, with the personal data being processed within the UK or EEA; and Inspectlet, to monitor and analyse user behaviour on our Site and may transfer personal data outside EEA (on the basis of EU Model Clauses (with more information available here: http://static.inspectlet.com.s3.amazonaws.com/Inspectlet_DPA.pdf).
• Other parties where you ask us to share that data, or we ask you and you

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.

5. INTERNATIONAL TRANSFERS

Where we transfer your personal data outside the UK other than to the European Economic Area (EEA), we ensure that a similar degree of protection is enforced as is required within the UK by ensuring that the recipients use and are bound by standard contractual clauses (otherwise known as Model Clauses) which may be enforceable by you regarding data protection (as well applying appropriate additional security measures), or the recipient countries have been deemed to provide an adequate

level of protection by the UK (which currently mirror the decisions taken by the European Commission (further details).

6. 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. We have also 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. 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. Please contact us if you would like more information regarding the security measures we use.

7. DATA RETENTION

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, how long a legal claim may be taken and whether we can achieve those purposes through other means, and the applicable legal requirements. We retain information regarding all financial transactions that take place using our Platform for 7 years. We will retain your other personal data within a reasonable period following the time you or your club/organisation close your/its account.

In some circumstances, we 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.

8. YOUR LEGAL RIGHTS

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

If you wish to exercise any of the rights set out above, please contact us. Note, however, that we may not always be able to comply with your request for specific legal or compelling legitimate reasons which will be notified to you, if applicable, at the time of your request.

No fee is 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.

Supervisory Authority Contact

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) or the Data Protection Commission (DPC) (https://www.dataprotection.ie/), the Irish supervisory authority for the General Data Protection Regulation (GDPR). We would, however, appreciate the chance to deal with your concerns before you approach the ICO or DPC so please contact us in the first instance at support@teamfeepay.com