Introduction

Your information is very important to us and we look after your information carefully in line with data protection and privacy laws. We’ve set out below more detail on what information we collect about you and how we use that information. Please read this policy carefully so you know what we are doing with your information.

We may update this privacy policy from time to time and will post any changes on our website at https://incrowdsports.com/terms-privacy-policy so it’s a good idea to come back and read through them again, from time to time. If we are making significant changes to this privacy policy, we may communicate such changes through other means (such as email notification if appropriate).

Which company does this policy cover?

Any reference to “we”, “us” and “our” is to InCrowd Sports Limited.

InCrowd Sports Ltd is a company registered in England and Wales (registered number is 9366216) with registered office at Fifth Floor, Mimet House, 5a Praed Street, London, W2 1NJ. We are a data controller (registered with number ZA046865) in relation to the collection and use of your personal data.

What services does this policy cover?

Our services may include (without limitation) software applications on mobile devices and website devices which are wholly controlled by us, or third party software applications which use our software as libraries and/or integrations (the “Services”). This policy covers all of the Services and any reference to “you” or “your”, means you as user of our Services.

What information do we collect?

What information we collect about you depends which of our Services you are using. The information that we may collect includes:

• your name, address, postcode, email address, date of birth, telephone number, social log-ins, payment details and service details (if applicable);
• information about your use of our Services including details of your internet protocol (IP) address, operating system, browser version, cookie details, response to questions, polls and games you interact with on our Services, the content you viewed on our Services, how long you stayed and on which Services, and your navigation around the Services;
• location data from your IP address or by accessing global positioning functionality on your device (e.g. GPS). We may use this so that we can “geo-block” or regionalise our Services to ensure that the Services operate correctly and provide information to event organisers about their attendees;
• information about your device and device type;
• other data from time to time to help us provide you with improved products and services – for example when we ask you to fill in a survey or questionnaire;
• other data to ensure and check compliance with the EULA and/or otherwise as required by law.

We use this information for the purposes set out in the “How will we use your information” section below, which purposes are either necessary to enable us to fulfil our contractual obligations to you in connection with the Services or are pursuant to our legitimate interests, namely to enable us to deliver the Services in a tailored and user friendly way and to help us to improve and update our Services.

When and how do we collect information?

We (or our third party suppliers who assist us with providing the Services (“Our Suppliers”)) may collect information about you:

• when you register for Services, including (without limitation) when buying or subscribing for content from us or when you otherwise update your details;
• when you contact us with an enquiry or other feedback;

• when you participate in interactivity, for example, when you submit an entry to a competition or prize draw, or you vote in one of our polls;
• when you request to be sent communications such as updates or newsletters;
• in monitoring your use of the Services including (without limitation) your browsing and content interactivity and communications sent by you via the Services;
• when we are checking compliance with the Terms of Use and/or otherwise as required by law;
• through the use of “cookies” and/or other devices. For full details, see our cookie policy and the section entitled “Cookies and similar devices” below;
• when you disclose your personal information to us or otherwise through the Services at any other point; and
• from third party suppliers who have confirmed to us that they are authorised to pass your information to us in accordance with your legal rights.

We may also combine information that you provide on one Service with information collected from other Services and/or with information that is publicly available or that we receive from other reputable sources. All information will be stored and used in accordance with this privacy policy.

Cookies and similar devices

In addition, in common with many other online services, we and our authorised third parties may use “cookies” and/or other tools to store and sometimes track information about you.

What are cookies?

We may use “cookies”, which are small text files that are stored on your computer or internet enabled equipment when you visit certain online pages or across our Services that record your preferences. We may use cookies to track your use of our Services and its features. We may also use cookies to monitor traffic, improve the Services and make it easier and/or more relevant for your use. You may occasionally get cookies from companies with links on our Services. We do not control these cookies, and these cookies are not subject to our Privacy Policy.

If we choose to use cookies or other similar tracking or storage technologies, we will provide you with more information about these and the opportunity for you to select your preferences for using such technologies. Please note that by not accepting the use of certain cookies or similar technologies you may not be able to access certain information and certain features within our Services or they may not function as intended.

How will we use your information?

Your information may be used by us and Our Suppliers to:

• monitor, develop and improve the Services and/or your experience. This may include personalising the advertising and content you see, based on the details given by you and/or your activity on the Services;
• assist in, and administer the provision of, Services to you;
• send you or provide you with product and service recommendations;
• process payments from you to us (where applicable) on our behalf;
• process and deal with any complaints or enquiries made by or about you;
• investigate any suspected breach of the Terms of Use or the breach of other terms and conditions otherwise relating to you;
• contact you with service messages;
• monitor compliance with the Terms of Use or other applicable terms and conditions including by way of (i) checking postings or submissions in connection with your use of the Services, and/or (ii) using keyword triggers to investigate usage that may be inappropriate;
• administer the prize if you are a prize winner, and to publish or otherwise make available a list of prize winners (as described in the competition T&Cs); and/or
• provide you with access to one or more social networking sites from the Services. If you choose to connect to a social networking site from the Services, your personal information may be shared between InCrowd and your social networking account(s). Any personal data shared with a third party social network provider will be processed in accordance with their own privacy policy.

How long will we keep your information?

We will retain your personal data on our systems only for as long as is strictly necessary for the purposes for which such data was originally collected, being the period during which we are contracted to provide you with the Services (or for such longer period as may be required by law, including in connection with any tax obligations).

What are the privacy implications of the TribeHive Connect network?

The TribeHive Connect network is InCrowd’s technology that provides a connectivity boost within crowded venues such as football matches. Updates to content available within the app shared by all are delivered from phone to phone within the venue. When your personal content, such as your personal Twitter timeline or your Tweets, goes over the TribeHive Connect network, it is encrypted using state of the art technology (AES 256), using a shared secret held only on your phone and our secure portal server. You can be sure that no one can read your data in transit. Our apps do not read any other personal data on your phone, except where you have given permission.

Will I be sent marketing messages?

To further our legitimate interest of marketing to our existing customer base, we may provide relevant marketing to you within the scope of the relevant Service you are using. We will only send you marketing messages outside of the use of the Services if you indicate that you consent (e.g. by “opting-in”) to receiving such messages. These messages will only be sent to you via the method of communication which you have indicated as your preference. Where we have your consent or are otherwise permitted to do so, we may:

• send you information by email, telephone, SMS, mail or other methods of communication about new services and special offers from us;
• send you information by email, telephone, SMS, mail or other methods of communication about related products or services of selected third parties that may be of interest to you; and
• where a specific “3^rd party” opt-in has been provided by you, pass your details to selected third parties so that they may send you information by email, telephone, SMS, mail or other methods of communication about products or services that may be of interest to you.

How to opt-out/unsubscribe to marketing communications

To stop receiving marketing communications from us, you can use the ‘unsubscribe’, ‘stop’ or similar facility contained in any such communication or you can email us at the email address set out in “Contact Details” below stating that you do not wish to receive further communications from us.

To opt-out of receiving any such communications from a third party, you will need to contact the applicable third party. Please note that we are not responsible for the communications or the content of any communications you receive from any such third party.

We do not pass or sell your personal information to third parties for any other purpose than as set out in this privacy policy. Unless you have given us your consent to pass your details to a third party, any marketing referred to in this section is conducted by us on our own behalf or on behalf of third parties to whom we have not given any access to your data.

Do we share your information?

We may pass information about you to other parties as follows, provided in each case, we are lawfully entitled to do so:

• to third parties authorised by us and acting on our behalf such as our employees, contractors, suppliers and/or agents including without limitation our customer care teams to administer the Services provided to you by us now or in the future;
• to third parties who have engaged us to administer services on their behalf, such as sporting governing bodies and sports clubs. These third parties may have their own privacy policies and/or terms and conditions of use, which we recommend you read before using any such services. In certain circumstances, we may be acting as a joint data controller with the relevant third party. In which case, we will be jointly responsible for complying with relevant data protection laws in relation to the collection and use of your personal data;
• where we have your consent to do so, for marketing communications (see section on “Marketing Communications” above);
• as part of general statistical information about the Services’ user base, sales patterns, traffic volumes and related matters. These details will not include information personally identifying you;
• to the police, regulatory bodies or legal advisers in connection with any alleged criminal offence, unlawful activity or suspected breach of the Terms of Use and or the breach of other terms and conditions or otherwise where required by law. We will co-operate with any law enforcement authorities or court order requesting or directing us to disclose the identity or location of or any other information about anyone breaching any relevant terms and conditions or otherwise for the prevention or detection of crime or the apprehension or prosecution of offenders;
• if there are changes to our business (see section below on “Changes to our business”).

We may also display targeted advertisements based on the personal information that we or our clients hold. We do not provide your personal information to advertisers but advertisers and ad serving companies may assume that you meet the targeting criteria for that ad, for example men aged 18-30.

Please note this policy does not cover companies, services or applications that we do not own or control, or people that we do not employ or manage, including (without limitation) third party websites or applications/widgets (e.g. from “social media” platforms such as Facebook or Twitter) which we link to or offer via our Services, nor does it cover advertisers. Also, it does not cover certain pages and services provided via our Services which are hosted, managed and operated by other parties. These services, applications and third parties may have their own privacy policies and/or terms and conditions of use, which we recommend you read before using any such services. These third parties and services are wholly independent of us and are solely responsible for all aspects of their relationship with you and any use you may make of such services.

Transferring your data outside of the European Economic Area (“EEA”)

Certain third parties with whom we share your data (as referred to above) may be based outside of the EEA, in countries which may not have as comprehensive data protection laws. However, where we share your information with such third parties, we will, where practicable, provide you with information as to where your data is being transferred and why and take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this privacy policy. We will also ensure that relevant EU Commission approved contractual model clauses are in place to safeguard the transfer and processing of your data in these countries (to the extent required). Please contact us if you would like to see a copy of these clauses.

Changes to our business

If we decide to change or re-organise the structure of our business, we may need to pass your personal information to one of our group companies so that we can continue to effectively deliver the Services to you.

Also, if we become involved in a merger, acquisition, restructuring, reorganisation or other transaction involving the sale of some or all of our or our group companies’ assets, then your information may be included in the assets which are transferred to the new owner and may be provided to the entities and advisors involved. Such a transaction may involve us: (i) retaining the right to continue to use transferred personal information in addition to the right of the new owner to use such information; and (ii) engaging in additional transfers of personal information (including new personal information) with the new owner from time to time following such a transaction.

If there are changes to our business (such as a re-organisation or restructuring), your personal information will remain subject to this privacy policy (as amended from time to time). However, where your personal information is transferred to a new owner following a merger or acquisition, it may be subject to a different privacy policy. We or the new owner, will provide notice to you at your email address on file (where available) before any of your personal information becomes subject to a different privacy policy.

Are my details safe?

We have adopted strict security processes, in accordance with good industry practice, to prevent the unauthorised access to, or disclosure of, your personal data. Notwithstanding our implementation of these policies, please note that we cannot guarantee the security of any data that you send to us via the internet or which is collected using online devices/tracking technology.

Please always think carefully before disclosing information to other users or otherwise making your information publicly available. It is important that you are aware that any information you disclose to another user may then be disclosed by that user. We have no responsibility or control over the contents of communications made between users of our Services.

Your rights

In certain situations, you are entitled to: (i) request access to your personal data; (ii) request that we correct your personal data; (iii) request that we erase your personal data; (iv) request the restriction of processing of your personal data; (v) request the transfer of your personal data to a third party; or (vi) where you have provided your consent to certain of our processing activities, you may withdraw your consent at any time (but please note that we may continue to process such personal data if we have legitimate legal grounds for doing so).

To exercise these rights please contact us using the contact details set out below in the “Contact Us” section.

Please note that you also have a right to complain to the Information Commissioner if you believe that we are mishandling your information.

How can I change my details?

If you register your details for certain Services and open a user account with us, you may change or update some of your details at any time via your account. If you are not registered for these Services but wish to update your details then please contact us (see “Contact Us” section below). If your details become outdated, please make sure that you update your details as soon as possible.

Contact Us

Please contact us by phone +44 (0)20 3137 9873, via email enquiries@incrowdsports.com or post at Fifth Floor, Mimet House, 5a Praed Street, London, W2 1NJ.