Privacy Policy
Privacy Policy
1.0 INTRODUCTION
This Privacy Policy (“Privacy Policy”) is part of the https://lokkaroom.com (“Lokkaroom Service Terms”) for the use of:
(i) the Lokkaroom software application or any related software application (“Apps”);
(ii) the Lokkaroom website https://www.lokkaroom.com and/or any sub-website and/or associated domains (and/or sub-domains) of https://lokkaroom.com (the “Site”); and
(iii) the services available via the Apps and the Site (“Services”).
The Apps, Site and Services are provided in or from the United Kingdom (“UK”) by TMA Sports Management Limited and its subsidiaries, whether direct or indirect (hereinafter collectively referred to as “We”, “Us”, “Our”, “Lokkaroom” and/or “TMA Sport”), to each of our customers (“You”, “Your” and “User”).
We decide the purposes and means of processing of personal data that is collected about you when you deal with us. We are committed to protecting and respecting your privacy and we have legal obligations to do so as the ‘controller’ of your personal data under the Data Protection Act 2018 (the “Act”).
This Privacy Policy explains the types of personal data collected, the purposes for which it is collected and processed, the legal basis for that, the organisations or types of organisations with whom we may share your personal data, and detailed information about Your various rights relating to your personal data and how to exercise them.
It is necessary for you to agree to the ”Lokkaroom”, including this Privacy Policy, and for us to collect, process, share and store the personal data as described, in order for us to be able to transact and communicate with you, and interact with you via the Apps and the Site and provide the Service.
The Apps and Site may from time to time contain links to and from the websites of partner networks, advertisers and affiliates. If you follow a link to any of those websites, please note that those websites have their own privacy policies and we do not accept any responsibility or liability for those policies. Please check those policies and any relevant service terms and conditions before you submit any personal data to those websites. We are not responsible for the content of any other websites or services.
Please contact us at marketing@tmasport.com for any clarification You may need.
2.0 PERSONAL DATA WE COLLECT ABOUT YOU
We may collect, store and use the personal data described in the table in Annex A to this Privacy Policy, and process it for the purposes and on the legal basis specified in that table. We explain the purposes of processing further in Clause 3 below.
You will see in that table that we most commonly use your personal data on the following legal grounds:
- Where we need to perform an obligation under a contract with you, such as the Lokkaroom Service Terms, or take steps at your request before agreeing a contract with you;
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights that require the protection of personal data do not override those interests;
- Where we need to comply with a legal or regulatory obligation; and
- Where you have consented before the processing.
Personal data will be stored in accordance with Clause 5 of this Privacy Policy.
Your personal data can be updated within your Lokkaroom profile.
3.0 WHAT WE USE YOUR PERSONAL DATA FOR
We explain the purposes for which we use each type of your personal data in the middle column of the table in Annex A to this Privacy Policy.
Should We need to process Your data for a new purpose in the future, which is entirely unrelated to the above, We will inform You of such processing in advance and You may exercise Your applicable rights (as explained below) in relation to such processing.
Finally, do note that without certain Personal Data relating to You, We may not be in the position to provide some or all of the services You expect from Us or even to guarantee the full functionality of Our Site and/or Apps.
4.0 ACCURACY OF PERSONAL DATA
All reasonable efforts are made to keep any Personal Data We may hold about You up-to-date and as accurate as possible. You must ensure that the information you give Us is always accurate and up to date. You can check the information that We hold about You at any time by contacting Us at marketing@tmasport.com.
If You find any inaccuracies, We will correct them and where required, delete them as necessary. Please see below for a detailed list of Your legal rights in terms of any applicable Data Protection Laws.
5.0 MARKETING AND ADVERTISING
We give you choices about what marketing and advertising you see on the Site. You have a choice to opt-in to receiving marketing and advertising specifically tailored for you.
We use personal data you have provided to us, and responses to our survey questions, for our loyalty programme and to work out if certain advertising and marketing will be of interest to you. We may use an automated process to create a profile for you.
You can ask us to stop sending you any targeted marketing or advertising messages at any time by contacting us through marketing@tmasport.com.
Further information on your rights and how to exercise them is included in the table in Annex B.
6.0 TRANSFERS TO THIRD COUNTRIES
As a general principle, the Personal Data We process about You (collected via any of our Sites or Apps or third-parties) will be stored and processed within the UK.
In some cases, it may be necessary for Us to transfer Your Personal Data to (EU)/European Economic Area (EEA) or any other non-EEA country deemed by the Information Commissioner’s Office (ICO) to offer an adequate level of protection.
In some cases, it may be necessary for Us to transfer Your Personal Data to a non-EEA country not considered by the ICO to offer an adequate level of protection. In such cases, apart from all appropriate safeguards that We implement, in any case, to protect Your Personal Data, We have put in place additional adequate measures. For example, We will ensure that the recipient is bound by the UK Standard Contractual Clauses designed to protect Your Personal Data. You are welcome to contact Us for more information regarding the adequate safeguards we have in place in relation to such data transfers.
7.0 INTERNET COMMUNICATIONS
You will be aware that data sent via the Internet may be transmitted across international borders even where the sender and receiver of information are located in the same country. We cannot be held responsible for anything done or omitted to be done by You or any third party in connection with any Personal Data prior to Our receiving it including but not limited to any transfers of Personal Data from You to Us via a country having a lower level of data protection than that in place in the UK, and this, by any technological means whatsoever.
Moreover, We shall accept no responsibility or liability whatsoever for the security of Your data while in transit through the internet unless Our responsibility results explicitly from a law having effect in UK.
8.0 SHARING OF PERSONAL DATA WITH THIRD-PARTIES
We will not disclose your personal data to any third party, except as explained in the table in Annex A to this Privacy Policy. The exceptions to this will be exclusively for the performance of a contract or fulfilment of your request – for example, purchasing a ticket or a piece of merchandise.
If some or all of our business is bought by a third party, personal data held by us will be transferred and may be disclosed to the prospective seller or buyer of such business under the same conditions as this Privacy Policy. This is necessary for the purposes of the legitimate interests pursued by us and the third party, and would not be overridden by your interests or fundamental rights and freedoms which require protection of personal data.
9.0 DATA STORAGE AND SECURITY
All information you provide to us is stored on our secure servers, located in the United Kingdom.
We use all reasonable endeavours to ensure that appropriate technical and organisational measures are in place to protect your personal data from unauthorised or unlawful processing and against accidental loss, destruction or damage.
Your personal data will be stored for as long as you use Lokkaroom; and for such time afterwards as required by law or six years from when you stop using Lokkaroom (which is the legal limitation period).
Please note that using the internet or mobile networks is not completely secure, so we cannot guarantee the security of your data transmitted between your device(s) and the Apps or Site. Any such transmission is at your own risk.
Where Your Personal Data is no longer required by Us, We will either securely delete or anonymize the Personal Data in question.
10. COOKIES
When You visit Lokkaroom (and any sub-domain), we will collect certain categories of Personal Data automatically through the use of cookies and similar technologies, as detailed in Annex A.
A cookie is a small file of letters and numbers that we store on your browser, computer, or device. Cookies send information back to the originating website on each subsequent visit, or to another website which recognises that cookie.
We may use the following cookies:
Strictly necessary cookies – These are cookies that are required for the operation of the Site.
Analytical cookies – Allow us to recognise and count the number of visitors and users and see how they use the Site. This helps us to improve the way our Site works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies – Used to recognise you when you return to our Site. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting cookies – These record your visit to our Site, the pages you have visited and the links you have followed. We will use this information to make our Site and the information displayed on it more relevant to your interests.
We may also share this information with third parties for this purpose.
Please note that third parties (including, for example, providers of external services like web traffic analysis services) may also use cookies, over which we have no control. You should refer to their privacy policies or cookie policies for the relevant information about those cookies.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies.
11. MINORS
Lokkaroom requires parental consent for any user under the age of 16. We will never intentionally collect Personal Data from such persons, however if consent has been given, we assume that permission has been given to collect data from this user. This consent is given when a user creates their Lokkaroom account.
If you want to revoke this consent, please email marketing@tmasport.com.
12. YOUR RIGHTS UNDER THE DATA PROTECTION LAWS
Under the Act, you have a number of rights. The first right is to receive confirmation as to whether or not any of your personal data is being processed and certain other information, as we have set out in this Privacy Policy.
The table in Annex B at the end of this Privacy Policy explains the following rights which the Act gives you in relation to your personal data, and any exceptions to those rights:
(a) Right of access
(b) Right to rectification
(c) Right to erasure
(d) Right to request the restriction of processing concerning you
(e) Right to data portability
(f) Right to object to processing
(g) Right to ask us not to process your personal data for direct marketing purposes
(h) Right not to be subject to automated individual decision-making, including profiling.
Please note that you may exercise these rights (subject to any applicable exceptions) by contacting us through marketing@tmasport.com.
WHAT WE MAY REQUIRE FROM YOU
We may need to request specific information from You to help us verify your identity and understand the nature of Your complaint or request, to confirm Your identity and ensure Your right to access the information (or to exercise any of Your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
HOW QUICKLY WILL WE RESPOND TO YOUR REQUEST?
In all cases, We will try to act on your requests as soon as reasonably possible, within a maximum of one month of receipt of the request, which period may be extended by two (2) more months where necessary, taking into account the complexity and number of the requests. We shall inform You of any such extension within one (1) month of receipt of the request, together with the reasons for the delay.
TMA SPORTS MANAGEMENT LIMITED – COMPANY DETAILSTMS Sports Management Limited, a company registered in England and Wales, with company registration number 12744600 and whose registered office address is at Thrive Hubs Ltd, 25, The Crescent, Plymouth, Devon, UK, PL1 3AD, is the data controller responsible for processing Your Personal Data that takes place via the Site, our Apps or in the manner explained above.
If you have any questions/comments about privacy or should You wish to exercise any of Your individual rights, please contact Us by sending an email to the following address: info@tmasport.com with the subject “PRIVACY
REQUEST” or by writing to:
‘DATA PROTECTION OFFICER
TMA SPORTS MANAGEMENT LIMITED,
THRIVE HUBS LTD, 25 THE CRESCENT,
PYLMOUTH, DEVON
UNITED KINGDOM,
PL1 3AD.’
14. UPDATES
We may amend this Privacy Policy. Any changes we may make to our Privacy Policy in the future will be posted on this page.
We reserve the right to unilaterally modify this Privacy Policy at any time, particularly if statutory obligations so mandate or the interest of our users’ security so requires. To let You know when we make changes to this Privacy Policy, We will amend the revision date at the top of this page. The modified Privacy Policy will apply from such revision date. We will not officially notify you about such changes, and it is therefore in Your own interest to check this Privacy Policy page from time to time so as to familiarize yourself with any changes.
15. COMPLAINTS
If You think that We are using Your information in a way which breaches Data Protection Laws, You have the right to lodge a complaint with the appropriate Data Protection Supervisory Authority, in the UK, this will be the Information Commissioner’s Office (IOC) which may be accessed by clicking this link https://ico.org.uk/. We kindly ask that You please attempt to resolve any issues You may have with Us first.
16. GENERAL
This Privacy Policy is governed by English law and either of us can bring legal proceedings in the courts of England and Wales in relation to any dispute arising out of or in connection with these Lokkaroom Service Terms, except that you may bring proceedings in Northern Ireland or Scotland if you are resident there.
Annex A
Personal Data Collected |
Purpose |
Lawful Basis for Processing |
• Full legal name, email address, residential address and mobile/phone number. • A number or code attributed to you by a government to identify who you are, such as a passport number or national identity number (including nationality). • Details about You that are stored in documents such as passports, identity cards and utility bills that confirm Your identity and prove the residential address; as well as any other additional documentation as deemed necessary by Our compliance teamWe may monitor, record, store and use any telephone, email or other communication.
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· For the purposes of setting up an account on our system, · For the purposes of managing our relationship with you, · For the purposes of establishing and investigating any suspicious behaviour in order to protect our business from any risk, fraud or other illegal activities · Research and statistics so that We may understand Our Users’ needs and to develop and improve Our services/activities. · For the purposes of evaluating your queries and/or requests you send us to use/receive any of our services (including customer support services). · For the purposes of maintaining and updating the user accounts records on our system. · For the purposes of continuing to manage our relationships with you. · For the purposes of developing and managing our brands, products and services. · To manage and administer the Site and/or Apps; · to enable you to use the Site and/or Apps; · to check any order or other instructions given to us; · for training purposes; · to improve the quality of our customer service; · to deal with enquiries, complaints and feedback from you; · to send you contractual notices; · to keep you informed about your activity relating to the Site and/or Apps; To disclose to third parties for: · the sports teams/Clubs, Players/Sportspersons whose digital assets, tickets, branded goods and services You have specifically opted to use, buy or interact with through our Site and/or Apps · To comply with a current judicial proceeding, a court order or legal process served on us or our Site and/or Apps, any request by any regulator who may have jurisdiction over us or for audit purposes and to meet obligations to any relevant regulatory authority or taxing authority; · To enforce this Privacy Policy or the Lokkaroom Service Terms; · To agents and subcontractors, acting for us, to use for the purpose of operating the Site and/or Apps; · to assist any type of investigation into Your actions); · In the event of TMA Sports Management Limited or any of its subsidiaries being involved in a merger, sale, restructure, acquisition, joint venture, assignment or transfer (of business, shares, assets or otherwise); · To protect and defend Our rights (including the right to property), safety, or to those of Our affiliates, of Users of Our Site; · To protect against abuse, misuse or unauthorized use of Our Site or Apps; · Cloud Service Provider for the hosting of data under state-of-the-art security protocols and our exclusive control. · IT Service Providers for the maintenance and support of our IT systems/Site(s) with restricted access and under strict controls. · Customer Support Software Providers for the provision of a customer support software in order to provide our users with a high-level customer support with restricted access and our strict controls. · Public Authorities for compliance with legal obligations and only after verifications are made into necessity of disclosure. · Our independent financial and legal advisors for the provision of legal and financial support to TMA Sport and affiliated entities · Business partners with whom we have a co-operation or partnership agreement to facilitate and improve the services and goods referred to you, including the tailoring of such services and goods, if deemed appropriate. · For the purpose of fulfilling orders using our dropship e-commerce model. |
· performance of a contract · compliance with a legal obligation · legitimate interests |
Information about your device, mobile device or other item of hardware through which you access the Site and/or Apps and your visits to and use of the Site and/or Apps (including your device, operating system, length of visit, page views that you use). Details about how and when you use Our services (our Site and/or Apps) IP address of the computer connected to the internet, location data through the mobile phone and Apps used and GPS data. Personal information such as your name, address and purchase history.
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· For the purposes of providing You with Our services, especially those provided via the Apps. · to analyse and improve the features offered on the Site and/or Apps. · To ensure that content on the Site and/or Apps is presented in the most effective manner for you and for your device; · For the purposes of internal data analysis. To disclose to third parties for: · the sports teams/Clubs, Players/Sportspersons and retailers whose digital assets, tickets, merchandise and services You have specifically opted to use, buy or interact with through our Site and/or Apps · To comply with a current judicial proceeding, a court order or legal process served on us or our Site and/or Apps, any request by any regulator who may have jurisdiction over us or for audit purposes and to meet obligations to any relevant regulatory authority or taxing authority; · To enforce this Privacy Policy or the Lokkaroom Service Terms; · For the purpose of fulfilling orders using our dropship e-commerce model. |
· performance of a contract · legitimate interests |
Information relating to your time taken to respond to questions, links you have clicked; and length of time you have spent on the Site and/or Apps,
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· To deal with enquiries, complaints and feedback from you; · to analyse and improve the features offered on the Site and/or Apps. To disclose to third parties for: · the sports teams/Clubs, Players/Sportspersons whose digital assets, tickets, branded goods and services You have specifically opted to use, buy or interact with through our Site and/or Apps · To comply with a current judicial proceeding, a court order or legal process served on us or our Site and/or Apps, any request by any regulator who may have jurisdiction over us or for audit purposes and to meet obligations to any relevant regulatory authority or taxing authority; · To enforce this Privacy Policy or the Lokkaroom Service Terms;
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· performance of a contract · compliance with a legal obligation · legitimate interests
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Correspondence between you and us
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· to manage and administer the Site and/or Apps; · to enable you to use the Site and/or Apps; · to deal with enquiries, complaints and feedback from you;
To disclose to third parties for: · the sports teams/Clubs, Players/Sportspersons whose digital assets, tickets, branded goods and services You have specifically opted to use, buy or interact with through our Site and/or Apps to help deal with complaints; · To comply with a current judicial proceeding, a court order or legal process served on us or our Site and/or Apps, any request by any regulator who may have jurisdiction over us or for audit purposes and to meet obligations to any relevant regulatory authority or taxing authority; · To enforce this Privacy Policy or the Lokkaroom Service Terms;
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· performance of a contract · compliance with a legal obligation · legitimate interests
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Details of your answers to Questions via the Site and/or Apps
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· to conduct surveys · to manage and administer the Site and/or Apps; · to enable you to use the Site and/or Apps; · for statistical analysis; · to develop and improve the Site and/or Apps;
To disclose to third parties for: · the sports teams/Clubs, Players/Sportspersons whose digital assets, tickets, branded goods and services You have specifically opted to use, buy or interact with through our Site and/or Apps; · To comply with a current judicial proceeding, a court order or legal process served on us or our Site and/or Apps, any request by any regulator who may have jurisdiction over us or for audit purposes and to meet obligations to any relevant regulatory authority or taxing authority; · To enforce this Privacy Policy or the Lokkaroom Service Terms; · to agents and subcontractors, acting for us, to use for the purpose of operating the Site and/or Apps;
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· performance of a contract · compliance with a legal obligation legitimate interests |
Records of any telephone, email or other communication with you
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· to improve the quality of our customer service.
To disclose to third parties for: · To comply with a current judicial proceeding, a court order or legal process served on us or our Site and/or Apps, any request by any regulator who may have jurisdiction over us or for audit purposes and to meet obligations to any relevant regulatory authority or taxing authority; · To enforce this Privacy Policy or the Lokkaroom Service Terms;
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· performance of a contract · compliance with a legal obligation · legitimate interests
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Name, email address, sporting preferences, purchase history
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· Direct marketing (e.g. mailing lists for newsletters); · For the purposes of subscribing to a newsletter or mailing list. · For the purpose of sending personalised communications and product recommendations.
To disclose to third parties for: · Marketing and Customer Retention Management Tools for the provision of marketing email communications send-outs under our strict control and management. · Advertising partners and social media platforms for marketing purposes to send adverts to You because You may be interested in Our services or to send Our adverts to people who have a similar profile to You, utilizing Our advertising, sponsor and affiliate partners. · For the purpose of fulfilling orders using our dropship e-commerce model.
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· Consent
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Annex B
You may exercise these rights at any time by contacting us through info@tmasport.com, as explained in paragraph 12 of the Privacy Policy.
Rights |
Exception |
Right of Access: To obtain from us confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and the following information: (a) the purposes of the processing; (b) the categories of personal data concerned; (c) the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations; (d) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period; (e) the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing; (f) the right to lodge a complaint with a supervisory authority; (g) where the personal data are not collected from the data subject, any available information as to their source; (h) the existence of automated decision-making, including profiling and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject. |
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Right to rectification: to obtain from us without undue delay the rectification of inaccurate personal data concerning you. We must communicate to each recipient to whom the rectified personal data have been disclosed, unless this proves impossible or involves disproportionate effort. We shall inform you about those recipients if you request that information. |
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Right to erasure: to obtain from us the erasure of personal data concerning you without undue delay where: (a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; (c) you object to the processing based on legitimate interest where there are no overriding legitimate grounds for the processing; (d) the personal data have been unlawfully processed; (e) the personal data have to be erased for compliance with a legal obligation to which we are subject. We must communication to each recipient to whom the erased personal data have been disclosed, unless this proves impossible or involves disproportionate effort. We shall inform you about those recipients if you request that information. |
Processing is necessary for (b) compliance with a legal obligation which requires processing by law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in us; or (e) the establishment, exercise or defence of legal claims. |
Right to request the restriction of processing concerning you: to be obtained from us where: (a) the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of the personal data; (b) the processing is unlawful and you oppose the erasure of the personal data and request the restriction of its use instead; (c) we no longer need the personal data for the purposes of the processing, but it is required by you for the establishment, exercise or defence of legal claims; (d) you object to the processing based on legitimate interest pending the verification whether our legitimate grounds override yours. We must communication to each recipient to whom the restricted personal data have been disclosed, unless this proves impossible or involves disproportionate effort. We shall inform you about those recipients if you request that information. |
Where processing has been restricted under this right, such personal data shall, with the exception of storage, only be processed: (a) with your consent; or (b) for the establishment, exercise or defence of legal claims; or (c) for the protection of the rights of another natural or legal person; or (d) for reasons of important public interest of the UK.
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The right to data portability: to receive your personal data, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from us, where: (a) the processing is based on consent or is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract; and (b) the processing is carried out by automated means. You have the right to have the personal data transmitted directly from us to another controller, where technically feasible. The exercise of this right shall be without prejudice to the right to erasure.
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That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.
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The right to object to processing: to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on processing necessary for the purposes of the legitimate interests pursued by us or a third party (except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data), including profiling.
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Where: (a) we demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject; or (b) for the establishment, exercise or defence of legal claims.
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The right to ask us not to process your personal data for direct marketing purposes: to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. You can exercise your right to prevent such processing by contacting us at marketing@tmasport.com.
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The right not to be subject to automated individual decision-making, including profiling: to not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
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If the decision: (a) is necessary for entering into, or performance of, a contract between you and us; (b) is authorised by law to which we are subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests; or (c) is based on the data subject's explicit consent. In the cases referred to in points (a) and (c) we shall implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, at least the right to obtain human intervention on our part, to express his or her point of view and to contest the decision. |
Last updated: 17.07.24