We collect, use and are responsible for certain personal information about you. When we do so we are subject to various laws in the United States and the General Data Protection Regulation which applies across the European Union (including in the United Kingdom), and we are responsible as “controller” of that personal information for the purposes of those laws.
"customer" means an individual who (a) has contacted us through any means to find out more about any Goods and/or Services we provide, or (b) may, or has, entered into a contract with us for the supply of any Goods and/or Services by us, (c) or otherwise interacted with us on at various events (such as martial arts events) that we organize and/or through the various online platforms that we maintain;
"personal data" means data, whether true or not, about a Customer who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access’
"goods and/or services" means any and all goods and services which we currently provide to our Customers or business partners, including event ticketing, media, advertising, sponsorship sales, retail of athleisure apparel and other sports-related items, mobile and/or console games, and apps, as well as other goods and services which we may provide in future from time to time;
"Special Category Personal Information" means personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership.
• Depending on the nature of your interaction with us, some examples of Personal Data which we may collect from you include name, residential address, email address, telephone number, nationality, gender, date of birth, marital status, employment information, financial information, age group, country of residence and hobbies and interests. We do not collect anything that would qualify as Special Category Personal Information.
COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
• We generally do not collect your Personal Data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorized by you to disclose your Personal Data to us (your "Authorized Representative") after (i) you (or your Authorized Representative) have been notified of the purposes for which the data is collected, and (ii) you (or your Authorized Representative) have provided written consent to the collection and usage of your Personal Data for those purposes, or (b) collection and use of Personal Data without consent is permitted or required by law. We shall seek your consent before collecting any additional Personal Data and before using your Personal Data for a purpose which has not been notified to you (except where permitted or authorized by law).
• We may collect and use your Personal Data for any or all of the following purposes: (a) performing obligations in the course of or in connection with our provision of the Goods and/or Services to you; (b) verifying your identity; (c) responding to, handling, and processing queries, requests, applications, complaints, and feedback from you; (d) managing your relationship with us; (e) processing payment or credit transactions; (f) complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority; (g) transmitting to any unaffiliated third parties including our third-party service providers and agents, and relevant governmental and/or regulatory authorities, whether in United States (USA) or abroad, for the aforementioned purposes; (h) any other incidental business purposes related to or in connection with the above; (i) to develop, test and improve our Goods and/or Services, including by conducting surveys and research, and testing and troubleshooting new products and
features; (j) to send you marketing and promotional communications (including that of our business partners and sponsors), communicate with you about our Goods and/or Services, surveys and let you know about our policies and terms.
We also use your information to respond to you when you contact us; (k) where applicable, to administer the award and grant of prizes in surveys or other non-commercial competitions that we may run from time to time; (l) any other purposes for which you have provided the information; and (m) use and share your Personal Data with our affiliates globally, including GGtoor Inc., for the purposes set out in this Section 4, including to send you marketing and promotional on the Goods and/or Services, offered by our affiliates. You have the right to opt out of receiving promotional communications at any time by:
• Contacting us at [contact details for marketing opt-out];
• Using the “unsubscribe” link in emails or “STOP” number in texts; or
• [updating your marketing preferences on our [link to preference center]].
We may ask you to confirm or update your marketing preferences if you instruct us to provide further [products AND/OR services] in the future, or if there are changes in the law, regulation, or the structure of our business.
We only allow our third-party service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. When possible, we also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
We have not sold or disclosed to a third party any Personal Data that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Customer or household.
• The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, our commercial, business and/or employment relationship has come to an end) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under a contract with you).
7. The consent that you provide for the collection, use and disclosure of your Personal Data will remain valid until such time it is being withdrawn by you inwriting. You may withdraw consent and request us to stop collecting, using and/or disclosing your Personal Data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.
8. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it. We may need to maintain some Personal Data to fulfil our legal or regulatory obligations or to show that we have treated you fairly. We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.
9. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our Goods and/or Services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 7 above.
10. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose Personal Data where such collection, use and disclose without consent is permitted or required under applicable laws.
11. If you wish to make (a) an access request for access to a copy of the Personal Data which we hold about you or information about the ways in which we use or disclose your Personal Data, or (b) a correction request to correct or update any of your Personal Data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
12. Please note that when permissible by law, a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
13. We will respond to your request as soon as reasonably possible. In general, our response will be within twenty-one (21) days. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so by law).
14. To safeguard your Personal Data from unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption, use of privacy filters, and disclosing Personal Data both internally and to our authorized third-party service providers and agents only on a need-to-know basis, and other measures introduced from time to time as appropriate. Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: “Transferring Your Personal Information Out of the EEA”.
15. To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:
• With our offices outside the EEA;
• With your and our service providers located outside the EEA;
• If you are based outside the EEA; or
• Where there is an international dimension to the services we are providing to you.
These transfers are subject to special rules under European and UK data protection law.
If you would like further information, please contact our Data Protection Officer below.
16. You should be aware, however, that no method of transmission over the internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
17. Your Rights Under the GDPR.
Right to Access
The right to be provided with a copy of your personal information (the right of access)
Right to Rectification
The right to require us to correct any mistakes in your personal information
Right to be Forgotten
The right to require us to delete your personal information—in certain situations
Right to Restriction of Processing
The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data
Right to Data Portability
The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
Right to Object
The right to object:
—at any time to your personal information being processed for direct marketing (including profiling);
—in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.
Right Not to be Subject to Automated Individual Decision-Making
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
• For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner's Office (ICO) on individual rights under the General Data Protection Regulation.
18. You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to exercise free of charge:
Disclosure of Personal Information We Collect About You
You have the right to know:
• The categories of personal information we have collected about you;
• The categories of sources from which the personal information is collected;
• Our business or commercial purpose for collecting or selling personal information;
• The categories of third parties with whom we share personal information, if any; and
• The specific pieces of personal information we have collected about you.
Please note that we are not required to:
• Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
• Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or
• Provide the personal information to you more than twice in a 12-month period.
Personal Information Sold or Used for a Business Purpose
In connection with any personal information we may sell or disclose to a third party for a business purpose, you have the right to know:
• The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and
• The categories of personal information that we disclosed about you for a business purpose.
You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the sale [or disclosure] of your personal information. If you exercise your right to opt-out of the sale [or disclosure] of your personal information, we will refrain from selling your personal information, unless you subsequently provide express authorization for the sale of your personal information. To opt-out of the sale [or disclosure] of your personal information, visit our homepage and click on the Do Not Sell My Personal Information link here: [URL].
Right to Deletion
Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:
• Delete your personal information from our records; and
• Direct any service providers to delete your personal information from their records.
Please note that we may not delete your personal information if it is necessary to:
• Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
• Debug to identify and repair errors that impair existing intended functionality;
• Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
• Comply with the California Electronic Communications Privacy Act;
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
• Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
• Comply with an existing legal obligation; or
• Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Protection Against Discrimination
the CCPA. This means we cannot, among other things:
• Deny goods or services to you;
• Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
• Provide a different level or quality of goods or services to you; or
• Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
Please note that we may charge a different price or rate or provide a different level or quality of [goods and/or services] to you, if that difference is reasonably related to the value provided to our business by your personal information.
19. We generally rely on Personal Data provided by you (or your Authorized Representative). In order to ensure that your Personal Data is current, complete and accurate, please update us if there are changes to your Personal Data by informing our Data Protection Officer in writing or via email at the contact details provided below.
20. We may retain your Personal Data for as long as it is necessary to fulfill the purpose for which it was collected, or as required or permitted by applicable laws.
21. We will cease to retain your Personal Data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the Personal Data was collected, and is no longer necessary for legal or business purposes.
Name of DPO: Miguel Munoz
Email Address: email@example.com
Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period.
If you choose to contact directly by [website/email/phone/in writing], you will need to provide us with:
• Enough information to identify you (e.g., your full name, address and customer or matter reference number);
• Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
• A description of what right you want to exercise and the information to which your request relates.
We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.
Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.
We hope that our Data Protection Officer can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.