Privacy Statement

PRIVACY STATEMENT

Aspire Zone Foundation ("AZF") is the controller, in respect of your personal data, and is committed to protecting and respecting your privacy. Any references to "us" or "we" within these Terms shall mean the AZF.

This privacy statement sets out the basis on which we will process any personal information that we may collect about you as you access our application “AZF” (the "Application"). We therefore ask you to read this privacy statement carefully so that you are fully aware of how and why we are using your personal data.

THE INFORMATION THAT WE COLLECT ABOUT YOU

We may collect, process, store, and transfer the following information about you:

Information that you give us: This is information about you that you give to us by: entering and using the Application, creating an account, making purchases, requesting alerts and marketing notifications, or corresponding with us by telephone, post, email or otherwise. It may include:
- Identity Data such as first name, last name, gender, nationality, country, date of birth, and gender
- Profile Data such as username, password, purchases and orders made by you, your interests, preferences, feedback and survey responses
- Contact Data such as email address, phone numbers
- Financial including bank account and payment card details
- Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences
- Transaction Data including details about payments to and from you and other details of products and services you have purchased from us

Information that our Application and other systems collect about you: Our Application will automatically collect some information about you and your visit, including:
- Technical Data such as the internet protocol (IP) address used to connect your device to the internet, other information such as browser type and version, time zone setting and location
- Usage Data such as information about the pages you visit and how you use our Application

If you exchange emails, telephone conversations or other electronic communications with our employees and other staff members, our information technology systems will record details of those conversations and may also record their content.

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 WE USE YOUR DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract, we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights to not override those interests.
Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data, although we will get your consent before sending third party direct marking communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

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 goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

PURPOSES FOR WHICH WE USE YOUR PERSONAL DATA

We may use your information for the following purposes:

Purpose/Activity	Type of Data	Lawful basis for processing including basis of legitimate interest
Register you as a new customer	(a) Identity (b) Contact	Performance of a contract with you
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include notifying you about changes to our Terms or Privacy Statement	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications (e) Usage	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
Comply with our legal and regulatory obligations and bring and defend legal claims	(a) Identity (b) Contact	Necessary to comply with a legal obligation
Deliver relevant content and advertisements to you	(a) Identity (b) Contact (c) Profile (e) Marketing and Communications	Necessary for our legitimate interests

We may, from time to time, review information about you held in our systems – including the contents of and other information related to your email and other communications with us – for compliance and business-protection purposes as described above. This may include reviews for the purposes of disclosure of information relevant to litigation and/or reviews of records relevant to internal or external regulatory or criminal investigations.

To the extent permitted by applicable law, these reviews will be conducted in a reasonable and proportionate way and approved at an appropriate level of management. They may ultimately involve disclosure of your information to governmental agencies and litigation counterparties.

CHANGE OF PURPOSE

We will only use your personal data 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 data 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 data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

MARKETING

We may use your Identity, Profile, Contact, Transaction, Technical, and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You will only receive marketing communication from us if you have agreed to do so

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

THIRD-PARTY MARKETING

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

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by contacting us 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 product/service purchase or other transactions.

DISCLOSURE AND INTERNATIONAL TRANSFER OF YOUR INFORMATION

We may disclose personal information about you where it is reasonably necessary for the various purposes set out above:

where applicable, to service providers who host our Application or other information technology systems or otherwise hold or process your information on our behalf, under strict conditions of confidentiality and security;
to the Ministry of the Interior for the purpose of processing visa applications;
to third parties who operate any relevant global distribution system;
to a person who takes over our business and assets, or relevant parts of them; or
in exceptional circumstances:
- to competent regulatory, prosecuting and other governmental agencies, or litigation counterparties, in any country or territory; or
- where we are required by law to disclose.

These disclosures may involve transferring your personal information overseas. If you are in the European Economic Area (or the UK, after it has left the European Economic Area), you should be aware that this may include transfers to countries outside the European Economic Area / UK, which do not have similarly strict data privacy laws. In those cases, where we transfer personal data, we will do so in accordance with a applicable laws, for example by ensuring that our arrangements with them are governed by data transfer agreements or mechanisms, designed to ensure that your personal information is protected (including, where appropriate, under an agreement on terms approved for this purpose by the European Commission). Please contact us using the "Contact Us" form on the Application if you would like to know what agreements are in place or to see a copy of them.

THIRD-PARTY WEBSITES AND APPLICATIONS

The Application may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Application, we encourage you to read the privacy policy of every website and application you visit.

RETENTION AND DELETION OF YOUR INFORMATION

We intend to keep your personal information accurate and up-to-date. We will delete the information that we hold about you when we no longer need it or in circumstances when you exercise your legal rights.

We do not keep your personal data for any longer than is reasonably necessary to fulfil the purpose for which we collected it or to comply with any legal, regulatory or reporting obligations or to assert or defend against legal claims.

To determine how long we keep your personal data, we consider the amount, sensitivity and nature 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, regulatory, tax, accounting or other requirements.

In some circumstances we will anonymise your personal data (so that it can be no longer associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

YOUR RIGHTS

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

Right of access to the personal information that we hold about you.
Right to correct any inaccurate personal information to be corrected.
Right to request your personal data is deleted.
Right to object to processing of personal data.
Right to request restriction of processing your personal data.
Right to request transfer of your personal data, known as a "data portability" right, to you or a new service provider.
Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us using the "Contact Us" form on the Application.

You have the right to lodge a complaint with the relevant supervisory authority at any time. We would, however, appreciate the chance to deal with your concerns before you approach the applicable regulator, so in the event of any concerns please contact us in the first instance: using the "Contact Us" form on the Application.

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.

CHANGES TO THIS POLICY

Any changes we make to this privacy statement in the future will be posted to our Application and also available if you contact us using the "Contact Us" form on the Application. Please keep us up to date if there are any relevant changes to the personal data that we hold about you.

CONTACT US

We welcome questions, comments and requests regarding this privacy statement and our processing of personal information, please contact us using the "Contact Us" form on the Application.

Last updated: 31.10.2019