Digital Sports Mgmt - Information Security Policy
Last Updated 8 September 2021
The protection of your personal data is very important to us. This notice explains how and why we use personal data. This notice also provides contact information and important information about your data protection rights.
Who we are and how to contact us:
We are Digital Sports Mgmt (company number 10245433). We are responsible for deciding how and why we use the personal data we collect in connection with our business.
If you have any questions about this privacy notice or our use of personal data, or if you want to exercise your data protection rights please contact us on dataprotection@digitalsportsmgmt.com
How do we receive personal data:
For the most part we receive personal data from you directly. This will be the case, for example, where:
we have a contract with you to represent you and we ask you to provide information so we can fulfil our contract with you and to promote you generally (for example by displaying profiles of the influencers we represent on our website);
we create content in which you feature in connection with the business relationship between us (such as live stream or video content);
we correspond with you in the course of our day to day business (including corresponding with the personnel of our clients); and
we receive enquires via the ‘contact us’ section of our website.
In certain limited situations we receive personal data from other sources:
From time to time we assist our clients with competitions. In connection with that we may receive the winner’s details from our client to allow us to administer the prize. This may include your name, address, contact details, date of birth and if the prize involves international travel, your passport details.
If you apply for a job with us we may carry out a general internet search about you and receive information about you from references you provide or recruiters you or we work with which may include information about your career history, qualifications and suitability for the proposed role.
Please also note our website uses cookies, which may collect certain information about you and your device (such as IP address). You have the option to decline the use of non-essential cookies when you visit our website. Please see our cookie notice for further information about the cookies we use and why.
Why we use your personal data and our lawful basis for doing so:
Under data protection law we must tell you why we use your personal data and identify a lawful basis for using your personal data. This information is set out below
Talent we represent: We use your personal data for the following purposes:
for day to day business correspondence;
to fulfil our contracts with you, for example, to promote you and introduce to clients we work with;
to facilitate engagements you have signed up to with our clients (such as marketing campaigns, event activations and gaming tournaments as well as associated travel and accommodation);
to produce content featuring you (such as live streams and videos) in connection with engagements you have entered into with our clients; and
to pass onto clients data analytics relating to your social media accounts which you have provided to us for that purpose.
We use your information in this way because (i) it is necessary so that we can meet our contractual obligations to you; or (i) because it is in each of our legitimate interests for commercial reasons.
If you do not provide information that is necessary for our contract with you, we may no longer be able to work together.
We will also use your personal data where necessary to meet any legal obligations we are under which may include for example, processing required for tax and accounting purposes.
Competition Winners: We use your personal data to administer prizes run in collaboration with our clients. This is in each of our, your and our client’s legitimate interests to ensure competitions are correctly administered. Prize winners may be announced publicly in line with our client’s regulatory obligations which could include for example your name and the county you live in.
Business contacts: We use your personal data for day to day correspondence with personnel of businesses that we currently have a working relationship with in connection with that engagement and with other business contacts for business development and marketing purposes. This is in our legitimate interests for commercial reasons.
Job applicants: We use your personal data to assess your suitability for a job with us. This is in each of our legitimate interests, for recruitment purposes.
Website users: We use personal data to respond to enquiries you have submitted to us. This is in each of our legitimate interests to pursue business opportunities.
Data collected from cookies on our website is used in accordance with our cookie notice.
Who we share your personal data with:
If you are featured in content we create (such as live streams or videos) or if you are an influencer that we represent whose profile features on our website, that content will likely be made publicly available, worldwide on social media and the internet more broadly.
We may also disclose your personal data in the following circumstances:
where we represent you:
we may pass on information about you to business partners and clients we work with who we think may be interested in your services; and
where you have entered into a contract with one of our business partners or clients we will pass on information relevant to that engagement which you have provided to us for that purpose (for example, analytics associated with your social media account to measure the success of a campaign);
to travel and accommodation providers, where we are arranging this on your behalf;
if you are a competition winner in a competition we are running in collaboration with a client, we may share information about you with our client in connection with that competition;
to service providers who require access to personal data in order to provide their services to us (for example cloud service providers, such as Google Cloud, messaging platforms such as Slack and website hosting providers such as Squarespace);
to potential purchasers or investors and our and their advisors in relation to a business transaction, such as a reorganisation, restructuring, merger, change of control or sale of assets;
as necessary to establish, exercise or defend our legal rights; and
where required by the courts, regulators or law.
International transfers:
As mentioned above to the extent you feature in content or promotions we have created, they may be made publicly available, worldwide. Similarly, talent whose profiles are displayed on our website may be accessed by internet users around the world.
Other than that, we do not generally send any personal data outside the UK and Europe. Data we hold as a business is stored on servers in the UK and Ireland.
As and when we work with new service providers or clients, to the extent they are based outside the UK and Europe in a jurisdiction which the UK has not recognised as having an essentially equivalent data protection regime and who will have access to any personal data, we will put in place appropriate safeguards to protect your personal data (such as putting in place specific contractual clauses), unless an exemption applies under data protection law.
How long we retain your personal data
We retain your personal data for as long as we have a lawful reason to do so, which includes providing our services to you, complying with legal and regulatory obligations we are under, and resolving disputes and enforcing agreements.
In determining how long to hold your personal data we will consider legal and regulatory requirements and also whether it is necessary for us to keep it to achieve the purposes we've described in this notice. Where it is no longer necessary for us to keep it, we'll delete it or we'll anonymise it so that you cannot be identified from it.
Where we have a contract with you, we will retain information relating to you and your engagement for as long as we are working together. If our relationship comes to an end we will retain information after that where we need to for legal and dispute resolution purposes and in line with our record keeping policies.
We retain business communications while we are doing business together or pursuing a potential new opportunity. We may retain communications after this time in line with our record keeping policies, which is generally no more than 6 years.
Where we receive a website enquiry we retain the information as long as needed to respond to that enquiry.
Where we process personal data of competition winners we retain their details for up to one year after the competition.
We retain information about job applicants for as long as we are considering their application. For successful job applicants, application information will be retained in accordance with our staff retention policy.
Your data protection rights
If we hold your personal data you have the following rights:
to be informed about how we use your personal data (which is what this notice is for);
to access a copy of the personal data we hold about you;
to require us to correct any inaccuracies in your personal data;
where we have sought your consent, to withdraw your consent at any time (although please note that generally we do not rely on consent to use your personal data);
to ask us not to process your personal data for direct marketing purposes.
to restrict our use of your personal data;
to object to our use of personal data;
to require us to provide a copy of your personal data to others; and
to require us to erase your personal data.
There are exceptions to the rights of individuals in relation to their personal data and, in certain circumstances, your rights may be limited. The Information Commissioner’s Office provides more information about data protection rights - www.ico.org.uk.
If you wish to exercise any of your rights please contact us on dataprotection@digitalsportsmgmt.comYou also have the right to complain to the Information Commissioner’s Office (which is the UK’s data protection regulator) about our use of your personal data. For more information please see: https://ico.org.uk/make-a-complaint/
We ask that in the first instance you contact us so that we can try to address your concerns directly.
Updates to this privacy notice
We may update this privacy notice from time to time to make sure it is up to date. When we do, we will revise the “last updated” date at the top of the notice. We'll endeavour to make you are aware of material changes to it but we suggest you also check this notice from time to time so that you know our latest privacy practices.