TransferRoom - Privacy Policy Notice
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Website privacy notice

Who we are

Transferroom.com is a site operated by TransferRoom Ltd ("We"). We are a company incorporated and registered in England and Wales with company number 10380336 whose registered office is at 24 Old Queen Street, London, United Kingdom, SW1H 9HP UNITED KINGDOM. To contact us, please email support@transferroom.com.

TransferRoom is the responsible data controller under data protection law in respect of the processing of your personal data described in this Website Privacy Notice. If you have any questions or would like to exercise your rights, please contact TransferRoom to discuss this.

The data we collect about users of our website and service

Personal data, means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic mental, economic, cultural or social identity of that natural person.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, last name, username or similar identifier, football club you work for.
  • Contact Data includes job title, email address and telephone numbers.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Usage Data includes information about how you use our website including logs of all your interactions with the TransferRoom service.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be processed in accordance with required data protection law and used in accordance with this privacy notice.


We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.

How is your personal data collected?

We use different methods to collect data from and about you including through:
  • Direct interactions. You may give us your Identity Data and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • enquire about our service;
    • create an account on the TransferRoom service;
    • request marketing to be sent to you; or
    • give us some feedback.
  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources including technical Data and Usage Data from analytics providers such as Google based outside the EU.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
  • where you have provided your consent to such use
  • where it is necessary for our legitimate interests (or those of a third party,) and your interests and fundamental rights do not override those interests; or
  • where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Check our Glossary below to find out more about the types of lawful basis that we will rely on to process your personal data.

Purposes for which we will use your personal data

We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data
Lawful basis for
processing including basis
of legitimate interest
To register you as a new customer (a) Identity
(b) Contact
Necessary for our legitimate interests (to help us provide our service to our users)
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
Necessary to comply with a legal obligation
Necessary for our legitimate interests (to keep our records updated and to study how customers use our service)
To administer and protect our service, business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity details
(b) Contact details
(c) Technical details
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
Necessary to comply with a legal obligation.
To use data analytics to improve our website, service, marketing, customer relationships and experiences (a) Technical
(b) Usage
Consent
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
Consent

Marketing

We will get your express opt-in consent before we market to you, including (if applicable) consent to share your personal data with a third parties for marketing purposes.

If you have given your consent, we will use your email address to send you interesting information about our company, products services and offerings and those of third parties you have chosen to receive marketing from.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.

Cookies

For information on how we use cookies, please visit our cookies policy

International Transfers

We may need to transfer your personal data to other companies within the TransferRoom group for their use of the personal data. TransferRoom and the TransferRoom group may also need to engage third parties providing services to them as a data processor. Such parties may be established in countries outside of your country. TransferRoom shall ensure adequate contractual terms are in place with such other companies within the TransferRoom group and third parties in order to ensure an adequate level of data protection, including Standard Contractual Clauses where necessary.

How we store your information

TransferRoom will only retain personal data for as long as necessary to fulfil the purposes it was collected for, including compliance with any applicable legal, accounting or reporting requirements.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will normally notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.

Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give our clients/users the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Special category personal data means any personal data relating to your health, genetic or biometric data, criminal convictions, sex life, sexual orientation, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership.

THIRD PARTIES

Internal Third Parties

Other companies in our group of companies who may provide support in respect of the operation of the TransferRoom service.

External Third Parties

  • service providers acting as processors who provide hosting and email management services in respect of the TransferRoom service.
  • professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  •  regulators and other who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS

You may have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the absolute right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the personal data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your personal data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use.

Right not to be subject to automated decisions which is based on automated processing where the decision will produce a legal effect or a similarly significant effect on you

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

You may raise any concerns you have or complain to your local data protection authority directly, without going through TransferRoom. However, we encourage you to contact us in the first instance as we aim to promptly, efficiently and satisfactorily resolve any concerns or complaints you may have in relation to our processing of your personal data.

© Copyright TransferRoom Limited 2021