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Purpose

This notice tells you about how Proform Racing Ltd ("we" or "us") uses information about you.

Please read it carefully and contact us if you have any questions.

It covers information which relates to an identifiable individual (including employees and workers). It does not cover information about companies or other legal entities. In this notice we refer to this information as "personal information" but you may also see this information referred to as "personal data" in some places.

References to "we", "us", "our" or "Proform Racing" in this notice relate to Proform Racing Ltd.

Data Protection Principles

Under the General Data Protection Regulation ("GDPR") and UK Data Protection Act 2018 (together, "Data Protection Law"), Proform Racing must comply with data protection principles when processing your personal information. The principles require that your personal information is:

1. processed lawfully, fairly and in a transparent manner;
2. collected for specified, explicit and legitimate purposes;
3. relevant to, and limited to what is necessary for, the purpose(s) for which it was obtained;
4. accurate and kept up to date;
5. kept for no longer than is necessary;
6. kept safe; and
7. not transferred outside of the European Economic Area without adequate protection.

Types of Information

We collect and hold different types of information:

Personal information. This is information from which a person can be directly identified. This includes things like name and email address.

Sensitive personal information. This is personal information that requires special treatment under Data Protection Law. It includes details about a person's health, religion or ethnic origin. Proform Racing has strict controls in place for sensitive personal information.

Anonymous data. This is information from which no individual can be identified. This includes for example aggregated or purely statistical data.

Lawful Basis for Processing

All processing (use) of your personal information must be justified by a "lawful basis" for processing.

Most commonly we will use your personal information on the following bases:

• Consent. Some processing, particularly the use of new technologies, may require your consent. If consent is the only lawful basis for processing, it will be made clear, for example at time of sign-up, that you may refuse consent.
• Performance of a contract. Some uses of your information may be necessary for us to perform a contract with you or to take steps at your request prior to entering into a contract, for example to enter into a loan agreement.
• Legal obligation. We may also process your personal information for legal reasons where there is a legal obligation on us or where it is in our legal interests. This includes, for example, our obligation to comply with the requirements of our regulator.
• Legitimate interests. Where we consider that there are good business reasons to collect personal information, we balance our interests against your interests and rights. This is the most flexible lawful basis for processing your personal information - more information and examples about how we process your personal information for our legitimate interests is set out below.
• Vital Interests. Very occasionally, in an emergency, we may rely on your vital interests as the lawful basis to use your personal information.
• Public Interests. In certain very limited circumstances, we may rely on the public interest as the lawful basis for our use of your personal information.
• Legal Claims. In some cases, we may need to use your personal information to handle and resolve legal disputes.

How we Collect Data

Collected directly. This includes the personal information you give us when you sign up for, or use, our service. For example, when you become a member and pay by credit or debit card, we will collect the card details in order to process the payment.

Collected from a third party. This includes personal information collected from our business partners or other companies from whom you have also bought products or services. We will only collect your personal information from a third party where we have ensured that we may lawfully do so.

Collected from a publicly available source. In some situations, we may also access publicly available sources to obtain your personal information.

When we Use Data

The situations in which we will collect and process your personal information are set out below with some examples:

1. Making a decision about your service application. When you apply to become a member, we will collect and use your personal information in order to decide if we will accept you as a member.
2. Providing a service. In order to provide our service to you, we will collect and use your personal information. For example, for the provision of certain services, we may need to verify your identity. This may include photo ID and a utility bill / bank statement for address verification.
3. Administering a service. When administering your membership with us, we may use your personal information. For example, we may use your personal information to recover any outstanding fees.
4. Marketing communications. When sending you marketing communications, we will collect and use your personal information. For example, we may send you details about new products or services by email, post or other means.
5. Market research. We may contact you to ask for feedback on products or services you have bought or have been offered to you, to improve our business. For example, we may ask for product/service feedback using surveys, interviews, focus groups and testing groups.
6. Improving our services. We analyse collected information to improve our existing services, to improve the efficiency of our business operations and to develop new services.
7. Developing new services. We use anonymised or pseudonymised information when developing new services. For example, we may use anonymised transactional information to develop a new product for customers.
8. Preventing and detecting fraud. Fraud prevention and detection agencies may use your personal information to prevent and detect fraud, and this includes the use of personal information to investigate claims of fraud.
9. Managing risk. As part of our obligation to manage risk, we may use personal information in order to assess and mitigate the risks to our business and our customers.
10. Complying with laws and regulations. We may need to collect and process your personal information to comply with laws and regulations that apply to us. For example, we are required to retain certain customer records for a certain number of years.
11. Requests by regulators. We may collect and process your personal information at the request of a regulator.
12. Responding to complaints. We may collect and process your personal information to respond to complaints.
13. Legal action. We may use personal information to prosecute or defend legal action to protect the interests of both Proform Racing and/or our customers.

Automated Decision-Making

The provision of some of our services may involve automated decision-making using your personal information. This means that decisions may be made by automated means without human involvement. For example, when you apply for a new service with us you may be subject to automated screening. As part of this screening, your data may be reviewed against our acceptance criteria.

You have the right to object to automated decision-making which has a significant effect on you and you can request a reconsideration of any adverse automated decision made by contacting us.

Sharing Data

We may share personal information with the following entities and individuals:

• Organisations or people within Proform Racing Ltd. This means sharing personal information with other Proform Racing employees if they need this information to do their job.
• Third party service providers. This means sharing your personal information with third parties who provide products and services to us or to our customers, as agreed. For example, we may share your personal information with service providers who administer our technical or business processes. These third parties must protect your personal information to the same extent as Proform Racing and can only use it for the purposes specified by Proform Racing.
• Fraud prevention organisations. Fraud prevention and detection agencies may use your personal information to prevent and detect fraud, and this includes the use of your personal information to investigate claims of fraud.
• Government and law enforcement bodies. In some circumstances, we may need to share your personal information with the police, courts and other government bodies and agencies.
• Regulators. We may share your personal information with our regulators.
• Our professional advisers. Where necessary, we may share your personal information with our lawyers, financial advisers and auditors.

Data Security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Data Retention

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances, we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

Rights of Access, Correction, Erasure

Under the GDPR and UK Data Protection Act 2018, you have rights as an individual which you can exercise. More information about your rights is available from the Information Commissioner's Office (ICO) which is the UK's supervisory authority for data protection issues.

Please contact us using our contact form, if you would like to exercise any of these rights.

Cookies and Tracking Policy

A cookie is a small text file containing a unique identifier that is automatically placed on the user's computer or other device when the user visits a website. Cookies and the information they store help Proform Racing to remember your preferences and by recognising you, improve your online experience.

For more information about cookies, please visit All About Cookies.

You can choose to refuse cookies by altering the settings on your internet browser. For further information please see the 'Managing Cookies' section below. However, if you do not accept cookies, you may experience some inconvenience in your use of certain features on our websites.

Unless you have adjusted your browser settings so that it will refuse cookies, our systems will assume that you consent to cookies being sent when you first visit our websites.

Cookies We Use

Our websites uses the following types of cookies:

Managing Cookies

Most browsers allow you to refuse to accept cookies. If you would like to do so, please follow the instructions at All About Cookies - Manage Cookies.

If you block cookies, you may not be able to use all the features on our websites.

Changes to this Notice

We reserve the right to update this privacy notice at any time and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

If you have any questions about this privacy notice, please contact us.