Privacy Policy
Sport, Teaching and Education (S.T.E.P.) Ltd understands that your privacy is important to you and that you care about how your personal data is used.
We respect and value the privacy of everyone who visits this website, https://www.stepcoaching.co.uk (“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
Please read this Privacy Policy carefully and ensure that you understand it.
Your acceptance of this Privacy Policy is deemed to occur upon your first use of Our Site AND You will be required to read and accept this Privacy Policy when signing up for an Account. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.
Definitions and Interpretations
In this Policy the following terms shall have the following meanings:
Account - means an account required to access and/or use certain areas and features of Our Site and/or services.
Cookie - means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below; and
Cookie Law - means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003.
Information About Us
Our Site is operated by Sport, Teaching and Education (S.T.E.P.) Ltd registered in England under company number 11680360 .
Registered address: 39 Glenview, Abbey Wood, London, SE2 0SA
Data Protection Officer: Harry Sampson
Email Address: harry@stepcoaching.co.uk.
Telephone number: 07505 997 579
What does this policy cover?
This Privacy Policy applies only to your use of Our Site and the services we provide. Our Site may contain links to other websites.
Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
What is Personal Data?
ersonal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
What are my rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
a) The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.
b) The right to access the personal data we hold about you. Part 13 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 15 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
h) Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
What Data do we collect?
Depending upon your use of Our Site and/or services, we may collect some or all of the following personal and non-personal data (please also see Part 14 on our use of Cookies and similar technologies).
In order to provide our sport development services, we will obtain details including:
‣ contact details of those booking, or registering to receive information about our sport services and those for each child who will attend our sport services
‣ date of birth for example, where the service you require has age related restrictions or for verification purposes
‣ support information other information that is relevant to parent / guardian / child’s needs such as any allergy information or treatment that may need to be given to help the child at the session
‣ kit sizes
‣ gender / disability / ethnicity information • feedback we receive and your interest in our cricket development services
‣ IP address;
‣ Web browser type and version;
‣ Operating system;
‣ A list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;
The information will be obtained from this Website, telephone conversations, emails and written and verbal communications and from records of the session.
We may supplement the information that you provide with other information that we obtain from our dealings with you (such as other related events you or someone you book for have attended, achievements in sport and details from National Governing Bodies services, such as England and Wales, and their Play-Cricket website or which we receive from other Bexley, Greenwich or Lewisham borough cricket organisations.
How we use your Personal Data
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for the following purposes:
‣ Providing and managing your Account; For registration and general administration (including verification, welfare and security checking)
‣ Providing and managing your access to Our Site;
‣ Personalising and tailoring your experience on Our Site;
‣ Supplying our products and services to you. Your personal details are required in order for us to enter into a contract with you.
‣ Personalising and tailoring our products AND services for you.
‣ Communicating with you. This may include responding to emails or calls from you.
‣ For record keeping purposes
‣ To ensure appropriate certificates are prepared at the end of the sessions
‣ To carry out market research so that we can improve the goods and services we offer
‣ For research purposes and to enable us to understand requirements and develop cricket related courses and other services
‣ To keep under review equal opportunities within NGB sports or ethnicity information to enable us to monitor and ensure compliance with anti-discrimination policies or to comply with our obligations to Sport England
‣ Supplying you with information by email AND/OR post that you have opted-in to (you may unsubscribe or opt-out at any time by letting us know via our contact form).
‣ Analysing your use of Our Site and gathering feedback to enable us to continually improve Our Site and your user experience.
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email AND telephone AND post with information, news, and offers on our products AND services. You will not be sent any unlawful marketing or spam.
We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
How long will you keep my Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
‣ We will normally keep your personal data for three years. If, after this point, you have not taken up any further services, we will keep only minimal personal data about who has been booked on / attended each of our sessions/events, an outline of any incidents at the sessions and any preferences or consents.
Consent and lawful processing of personal data
‣ The legal basis for the collection and processing of your personal data is:
‣ For administration and programme delivery: that it is necessary to fulfil the contract that you are going to enter into or have entered into with us
‣ For dealing with medical needs: that you have given your explicit consent
‣ For direct marketing: that you have given your consent
‣ For equality and inclusion: that you have given your explicit consent for
‣ In all other cases: that it is necessary for our legitimate interests which are to build a programme to encourage participation in sport and this does not prejudice or harm rights and freedoms of parents / guardians
How and Where do you Store or Transfer my Personal Data?
We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR as follows.
We use specific contracts with external third parties that are approved by the European Commission for the transfer of personal data to third countries. These contracts ensure the same levels of personal data protection that would apply under the GDPR. More information is available from the European Commission.
Where we transfer your data to a third party based in the US, this may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar to those in Europe. More information is available from the European Commission. Disclosing your personal information In order to provide our products and services, we may, occasionally, appoint other organisations to carry out some of the processing activities on our behalf. These may include, for example, technology hosts, printing companies and mailing houses. In these circumstances, we will ensure that personal information is properly protected and that it is only used in accordance with this Privacy Policy.
Coach use of your personal information
In order to provide and administer courses and events, we will provide relevant details to coaches. Coaches will also be provided with contact details for each person who is booked for one of their courses / events and also the details of the attendee (if different) and any special needs or medical information that it is important for them to know. We only permit instructors to use this information to deal with the administration of the course or event and any medical support purpose. They are not permitted to use it for any other purpose.
The payment card information you provide will only be available to the payment provider (currently Sqaure). This will not be available to the S.T.E.P. Ltd or the coach.
We take the security of personal information seriously. We employ security technology, including firewalls, and Secure Socket Layers to safeguard information and have procedures in place to ensure that our paper and computer systems and databases are protected against unauthorised disclosure, use, loss and damage.
We only use third party service providers where we are satisfied that they provide adequate security for your personal data.
How do you share my Personal Data?
We will not share any of your personal data with any third parties for any purposes, subject to one important exception.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
How can I control my Personal Data?
In addition to your rights under the GDPR, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and at the point of providing your details and by managing your Account).
You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”).
These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.