COOKIES & PRIVACY POLICY Introduction: AcceleratedSeating.com is owned and operated by Accelerated Seating Limited (Company Number 15768699), registered at 128 City Road, London, EC1V 2NX. References to Accelerated Seating, “we”, “us”, or “our” refer to Accelerated Seating Limited. By interacting with us through our website (or otherwise) you may provide, or we may collect, certain information from which you are personally identifiable (which is referred to as personal data). For the purposes of the UK General Data Protection Regulation (and all other laws relating to the use your personal data), we are the “controller”, meaning that we are responsible for deciding how your personal data is used and more importantly, for keeping your data safe and only using it for legitimate reasons. We aim to protect your privacy and will take all steps necessary to comply with our legal obligations when using your personal data. This Cookies & Privacy Policy explains how we achieve this aim and your support is appreciated. Personal data which we collect: Here is a non-exhaustive list of the types of personal data that may come into our possession when you become our client or when you directly interact with us (when using our website or otherwise) or as necessary in the course of providing services whether to you or to a third party: (a) Identity – first name (including prefix or title), surname, the company you work for (if applicable), your title or position (if applicable), date of birth, passport information (or other identity information), tax status. (b) Contact – email address, telephone numbers and postal address. (c) Financial – all payment related information including bank account details and background information provided by you or collected as part of our business acceptance processes. (d) Business Information – provided to us by or on behalf of clients, suppliers, advisors or applicants, or generated by use in the course of providing services to our clients, which may include special categories of data. Special categories of personal data cover data about an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership. It also covers genetic data and biometric data and data concerning health, sex life or sexual orientation. This data is naturally more sensitive in nature and we will always treat it accordingly. (e) Marketing – contact information to send you newsletters, publications and invitations, your marketing preferences We may collect the following types of information from you when you use our website, through cookies and other tracking technologies: (a) Technical – this might include your IP address, browser information, location information, operating system and system configuration, network and software identification and device information (b) Usage Data – this includes information about how you use our website, such as click throughs, time spent on page, download errors etc. Certain of the above information will not identify you directly but may do so when combined with other information. The personal data may be used for: 1. Client registration Reason: Register you as a client of Finance in Sport Ltd and carry out our business acceptance procedures (including anti-money laundering, conflict and financial checks). Data: Identity, Contact & Financial, Business Legal basis: Compliance with legal obligations and perform contract with you. 2. Credit control: Reason: Issue invoices and process payments Data: Identity, Contact, Financial, Business Legal basis: Performance of a contract with you 3. Regulatory requirements Reason: To fulfil our legal, regulatory and risk management obligations, including establishing, exercising or defending legal claims. Data: All Legal basis: Performance of a contact with you; Necessary for compliance with legal obligation; Processing as necessary for the establishment, exercise or defence of legal claims. 4. Liaison with suppliers and advisors Data: Identity, Contact, Financial Legal basis: Performance of our contract with you 5. Recruitment Data: Identity, Contact, Business information Legal basis: Necessary for our legitimate interests (personnel recruitment). 6. Internal administration Data: All Legal basis: Performance of a contact with you; Necessary for compliance with legal obligation; Necessary for our legitimate interests (for effective business administration and service provision). 7. Professional & legal notices Reason: Notify you of changes to our Privacy Policy, our Terms of Business or other changes to our services. Data: Identity, Contact Legal basis: Performance of a contact with you; Necessary for compliance with legal obligation. 8. Fulfilling your requests Reason: To provide information requested by you which may involve contacting you by post, e-mail or phone. Data: Identity, Contact, Business information. Legal basis: Performance of a contact with you; Necessary for our legitimate interests (to ensure our clients are informed and satisfied with our services) 9. Promotion Reason: To promote our services, including sending updates, publications and details of events. Data: Identity, Contact, Marketing, Technical and Usage. Legal basis: Necessary for our legitimate interests (to develop our business and provide pertinent information to our clients and business contacts); Consent. 10. Visitor experience Reason: To improve your experience of our website. Data: Technical, Usage Legal basis: Necessary for our legitimate interests (to develop our business, improve our service and overall user experience). 11. Identification & Security Reason: Verify your identity and detect fraud and security issues. Data: All. Legal basis: Necessary for our legitimate interests (to prevent and detect fraudulent activity, security incidents and criminal activity). 12. Hospitality Reason: Hosting a meeting at our offices or an event at our offices or at a business partner’s office. Data: Contact, Identity, Business Information (including special categories of personal data about dietary or access requirements). Legal basis: Performance of a contract with you; Necessary to comply with a legal obligation; Consent. 13. Cookies and other tracking technology may be used to distinguish you from other users of our website and may: (a) be essential to the running of the website; (b) help the website to perform more effectively; (c) enable us to understand our customers’ browsing behaviour; and/or (d) allow us to improve the website. Importantly, we will not use any cookies/tracking technologies (or permit any third parties to place these on our website) which are not strictly necessary for the operation of the website, without first getting your consent. You can always change your mind about all types of cookies/tracking technologies (see “How to block these cookies/tracking technologies” section below). What are cookies and tracking technologies? These essentially enable us to store information on your browser or device to enable us or them to identify you and monitor certain activities, for the purposes set out in this policy. They may: (i) expire at the end of your browser session (allowing us to link your activities during that session – these are often called “session cookies”); (ii) be stored on your browser/device in between sessions, enabling us to remember your preferences and actions for future visits. They need to be manually deleted or will expire after the particular period set by that cookie – these are often referred to as “persistent cookies”; or (iii) be set by third parties – often referred to as “third party cookies”. Which types of cookies and tracking technologies do we use? 1. Strictly necessary, in order to operate our website. 2. Analytical/performance such as recognising and counting the number of website visitors, seeing how they navigate our website (including time spent on pages, errors, clicks, etc). This helps us to ensure that our website works effectively for you and improve our services to you. If you fail to provide personal data: Where we are legally obliged to collect personal data or in order to process your instructions or perform a contract we have with you and you fail to provide the relevant data, we may not be able to perform our contracted services or commence the same. We will notify you if this is the case at the time. Marketing: If you receive marketing communications from us and no longer wish to do so, you can opt-out at any time either by contacting us or by using the opt-out function detailed in the relevant marketing email. Please note that we may still need to send you service notifications by email, such as advising you of updated privacy terms or terms of business. Who do we share your data with? We do not pass your personal data onto any third parties for them to market their products/services to you. If in the future we decide that we want to, we will only do so if we have your consent. We do however share your personal data with third parties to help us deliver our services to you in the most effective way possible. These include third parties who assist us with: (a) Delivering relevant email marketing (to the extent you have not unsubscribed) (b) Detecting fraud or criminal activity. We may also share your personal data with certain trusted third parties in accordance with contractual arrangements in place with them, including: (a) Our professional advisers (b) Suppliers to whom we outsource certain support services such as word processing, translation, photocopying and document review (c) IT service providers (d) Third parties engaged in the course of the services we provide to clients and with their prior consent (e) Third parties involved in hosting or organising events or seminars. Where necessary, or for the reasons set out in this policy, personal data may also be shared with regulatory authorities, courts, tribunals, government agencies and law enforcement agencies. While it is unlikely, we may be required to disclose your information to comply with legal or regulatory requirements. We will use reasonable endeavours to notify you before we do this, unless we are legally restricted from doing so. If we share personal data with third parties, we will ensure that access is limited on a strictly need to know basis and is subject to suitable obligations relating to confidentiality and security. Do we send any of your data outside of the EEA? The European Economic Area or “EEA” is deemed to have good standards when it comes to data privacy. As such, we consciously limit the occasions when we may need to transfer or handle your data outside of the EEA. Where we do, for example where we are required to share your data with our Swiss or Australian offices or our service providers are based outside of the EEA, we make sure that your data is still treated fairly and lawfully in all respects (including making sure we have a legal ground for sending your data outside the EEA and putting in place all necessary safeguards for such arrangement). Where relevant, you will have the right to see a copy of any safeguards we put in place for international transfers of your data. Just get in touch with us if you would like to find out more. How long do we keep your data for? We will keep your data for as long as you are a client of Accelerated Seating and/or where you are still happy to hear from us about our latest news, events and services. Once you no longer wish to be engaged with Finance in Sport we may still need to keep hold of your data based on the requirements of applicable data protection laws and the purpose for which the information is collected and used, taking into account legal and regulatory requirements to retain the information for a minimum period, limitation periods for taking legal action, good practice and the business purposes of Accelerated Seating. Changes to our Privacy Policy: If we amend our Privacy Policy, it will be published on our website so please check back regularly to see if there have been any updates. If we make any substantial changes, we may also email you if it’s appropriate. Your rights: In certain situations, you are entitled to: (a) access a copy of your personal data; (b) correct or update your personal data, which you can do by contacting us and informing us of any changes; (c) erase your personal data; object to the processing of your personal data where we are relying on a legitimate interest (as set out in the above table); (d) restrict the processing of your personal data; (e) request the transfer of your personal data to a third party; or (f) where you have provided your consent to certain of our processing activities, in certain circumstances, you may withdraw your consent at any time. Your objection (or withdrawal of any previously given consent) could mean that we are unable to perform the actions necessary to achieve the purposes set out above (see ‘what personal data do we collect and what do we use it for? section) or that you may not be able to make use of the services offered by us. Please note that even after you have chosen to withdraw your consent we may be able to continue to process your personal data to the extent required or otherwise permitted by law, in particular in connection with exercising and defending our legal rights or meeting our legal and regulatory obligations. If you want to exercise any of these rights, please Contact Us. The good news is that you don’t have to pay a fee to exercise your rights, unless your request is clearly unfounded, repetitive or excessive (in which case we can charge a reasonable fee). Alternatively, we may refuse to comply with your request in these circumstances. Where your request is legitimate, we will always respond within one month (unless there is a legal reason to take longer, such as where your request is particularly complex). We may also need you to confirm your identify before we proceed with your request if it is not clear to us who is making the request. In addition to the above, you may get in touch with the ICO (Information Commissioner’s Office) if you are concerned about the way in which we are handling your personal data. However, where possible, we would really appreciate you speaking with us first if you have any concerns. Contact Us: If you would like to discuss anything in this policy or you want to exercise your rights, please get in touch by email at: enq@AcceleratedSeating.com