Privacy policy.
Last updated: 09/02/2022
We have presented this Privacy Notice to allow our users quick and easy access to the relevant areas of the Policy that they require, if you have any questions or queries please contact a member of the team: privacy@passionsports.co.uk
About Skilld
Skilld is an application designed for use with Android and iOS devices. It is Designed to be used by players and coaches wherever they are, at any time, and with whatever their level of technological competency is. Once a video has been submitted by a player for review, they can expect an answer fast. Quick turnaround is a critical KPI of the business. Coaches therefore need to be able to review and respond to videos on the spot with the equipment they have on them, namely, their smartphones.
Skilld’s in-app video review feature is key to supporting this business need. It is designed to simplify what has traditionally been a very complex piece of software requiring full PC hardware into a fluid experience that can be conducted with one thumb, without any training. Coaches can review, commentate on, annotate submitted videos and enter into a video-driven dialogue with the player. All of this is done in a way that works efficiently over mobile networks, and that protects the safety and privacy of children.
How To Contact Us & Our Data Controller
Passion Sports are the Data Controller for all personal information that we process unless stated otherwise.
Passion Sports Ltd is registered with the Information Commissioner's Office - registration number: ZB283233
Entry details can be found here:
https://ico.org.uk/ESDWebPages/Entry/ZB283233
You can contact our Data Controller directly using the following methods:
Email:
Post:
Data Controller
Passion Sports Ltd, 13a Vernon Yard, London, England, W11 2DX
We have conducted a Data Protection Impact Assessment on all our processing activities to ensure that individual rights of any individual are never knowingly infringed.
Our Legal Basis for Processing
Under the General Data Protection Regulations (GDPR) there are various legal bases for the processing of personal data.
The legal basis that Passion Sports Ltd relies on for users of the Skilld application is always Consent which is requested from the parent or guardian to allow their child or dependent to access Skilld.
This means that the Users of the Skilld application, who may be under the age of 16, have consented for their details to be Processed by Passion Sports Ltd via clear and specific opt-in of their parent or guardian.
Consent is always used for marketing communications from which you are able to withdraw at any time if you are subscribed. Marketing messages will only be sent via email to the Parent or Guardian whose email address is used to register the account.
Push notifications may be used where consent is provided specifically for them to be shown via the device used.
Privacy by Design
Skilld has been developed using a Privacy by Design approach, this means that the Privacy and Information Security of our users has been at the heart of the Skilld application through all areas of development and we do not request, hold nor process any data that is not essential to the delivery of the core service.
Different Ways in Which We Collect Personal Data
Personal Data means any information relating to natural persons who:
can be identified or who are identifiable, directly from the information in question; or
who can be indirectly identified from that information in combination with other information.
Personal Data is received by the Skilld application only by clear and affirmative input for the intended users by the parent or guardian.
For Users under 16, these details are re-confirmed by use of a verification email that is sent to the parent or guardian.
For Users over 16, these details are re-confirmed by use of a verification email that is sent to the Skilld account holder.
What Information do we Process?
In order to carry out our day-to-day operations and offer the benefits to Skilld users, we obtain information from the parent or guardian of the child user.
In order to access the Skilld application, firstly Skilld is downloaded from the relevant App store dependent on the user’s device.
Once the Skilld application is opened on the device the following information is retained by Skilld to create a unique profile prior to any registration process.
Child date of birth (Month and Year)
Trusted adult email address or Account holder email address if above the age of consent
‘Full Account’ Data Requirements
n order to access all features available in Skilld, the user is required to create an account. When an account is created, the following data is collected and retained:
Data Category (What data is obtained?): Email address.
Data Subject (Whose data is this?): Parent or Guardian.
Description of the data collected: Unique email of either the verifying adult or the user, if the user is above 16.
How is the data captured and how is it stored?: Provided by parent or guardian within the application, encrypted and stored securely.
Security if the data is transmitted to Skilld servers: Data is encrypted and sent over HTTPS using TLS, and stored securely in our database that is not publicly available.
Data Category (What data is obtained?): Display name.
Data Subject (Whose data is this?): User of the Skilld application (data field completed by Parent or Guardian).
Description of the data collected: Parent or guardian completes a display name free text entry field in the app account creation process.
How is the data captured and how is it stored? Provided by parent or guardian within the application, encrypted and stored securely.
Security if the data is transmitted to Skilld servers: Data is encrypted and sent over HTTPS using TLS, and stored securely in our database that is not publicly available.
Data Category (What data is obtained?): Marketing Consent.
Data Subject (Whose data is this?): Parent or Guardian.
Description of the data collected: Opt-in flag for marketing emails.
How is the data captured and how is it stored? Provided by parent or guardian within the application, encrypted and stored securely.
Security if the data is transmitted to Skilld servers: Data is encrypted and sent over HTTPS using TLS, and stored securely in our database that is not publicly available.
Data Category (What data is obtained?): Uploaded video
Data Subject (Whose data is this?): User of the Skilld application (data field completed by user).
Description of the Data collected: User uploads video of subject demonstrating their athletic skill.
How is the data captured and how is it stored? Provided by user within the application and stored securely.
Security if the data is transmitted to Skilld servers: Data is sent over HTTPS using TLS, and stored securely in our database that is not publicly available.
How We Process Your Personal Information
We will only use your personal data when the law allows us and only for the following purposes:
To the extent that is required for us to carry out the full services on behalf of our users based on the Agreement we have with them.
Where we need to comply with our legal and/or regulatory obligations
Skilld has been developed with your privacy in mind and we have taken appropriate technical and organisational measures to protect the confidentiality and integrity of your data during storage, transit and all processing activities.
Sharing Personal Information with Third Parties
We go through a stringent due diligence process when we select any third parties to work with to ensure their ethics, policies and processes are in line with our own.
These Third Parties include:
Type of Service: Parental consent service
Reason why we should share data with them: To gain full parental consent for data collection within the account creation process in the Skilld service.
Our selected partner, their Web address and Privacy Policy: Super Awesome Kids Web Services https://www.superawesome.com/kws-privacy-notice/
How we manage your data with them: Data is retained in accordance with our Data Retention Policy.
Type of Service: Email Service Provider (ESP) - Service Notifications.
Reason why we should share data with them: So that we can send service notifications that are critical to the operation of the Skilld service.
Our selected partner, their Web address and Privacy Policy: Mailgun email delivery service - https://www.mailgun.com/privacy-policy/
How we manage your data with them: Data is retained in accordance with our Data Retention Policy.
Type of Service: Email Service Provider (ESP) - Marketing.
Reason why we should share data with them: So that we can send marketing emails (where explicit consent exists).
Our selected partner, their Web address and Privacy Policy:
HubSpot https://www.hubspot.com/
MailChimp https://mailchimp.com
How we manage your data with them: Data is retained in accordance with our Data Retention Policy below.
Type of Service: Hosting Providers.
Reason why we should share data with them: So that we can provide our services to customers and that data can be held within a secure data centre.
Our selected partner, their Web address and Privacy Policy: Amazon Web Services https://aws.amazon.com/privacy/
How we manage your data with them: Data is retained in accordance with our Data Retention Policy.
Type of Service: Customer support.
Reason why we should share data with them: So that we can provide customer support emails to our customers.
Our selected partner, their Web address and Privacy Policy: Enchant customer support products https://www.enchant.com/privacy
How we manage your data with them: Data is retained in accordance with our Data Retention Policy.
Type of Service: Application analytics.
Reason why we should share data with them: So that we can improve the services that we are offering to our Users by understanding their behaviour in aggregate when using Skilld.
Our selected partner, their Web address and Privacy Policy:
Mixpanel
https://mixpanel.com/legal/privacy-policy/
Google Analytics
https://analytics.google.com/analytics/web/#/
https://policies.google.com/privacy
Apple Analytics
https://developer.apple.com/app-store-connect/analytics/
https://www.apple.com/legal/privacy/en-ww/
Firebase
https://firebase.google.com/support/privacy/
How we manage your data with them: Non personally-identifiable information is shared with Mixpanel, Google and Apple. This anonymous data is retained indefinitely.
Type of Service: Advertising attribution and analytics.
Reason why we should share data with them: So that we can attribute app installations to the relevant advertising campaign and improve their performance.
Our selected partner, their Web address and Privacy Policy:
https://www.facebook.com/about/privacy
How we manage your data with them: Non personally-identifiable information is shared with Facebook. This anonymous data is retained indefinitely.
We will only access your personal information where it is required to supply the services and we will always remain in control of any data that is being processed.
We will only disclose your information to parties not listed in this Privacy Policy in the following circumstances:
We have a legal obligation to do so, for example for law enforcement or regulatory bodies
To protect our interests and help us prevent fraud, detect crime or investigate any form of malicious or other activity which may be against our terms of service.
Where you give us specific permission to do so by providing consent
Your Rights
Under the GDPR you have rights we need to make you aware of, these are listed below.
Please contact our Data Protection Officer to discuss any of these rights and how we may assist: privacy@passionsports.co.uk
Your right of access:
You have the right to ask us for copies of your personal information.
Your right to rectification:
You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure:
You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing:
You have the right to ask us to restrict the processing of your information in certain circumstances.
Your right to data portability:
This only applies to information you have given us. You have the right to ask that we transfer the information you gave us from one organisation to another, or give it to you.
Data Retention and Erasure Policy
We will only retain information for as long as required to deliver the services to our customers safely and securely.
Our data retention policy is based on specific data types that we process:
Type of information collected & stored: Individuals who have completed the (above age of consent) full account process and have not logged in (engaged) with the application or any marketing collateral (emails etc).
Retention period (maximum): 4 months
Type of information collected & stored: Individuals who have completed the (above age of consent) full account process and have not logged in (engaged) with the application or any marketing collateral (emails etc).
Retention period (maximum): 12 months
Type of information collected & stored: Individuals who have completed the (under age of consent) full account process and have not logged in (engaged) with the application or any marketing collateral (emails etc).
Retention period (maximum): 4 months
Type of information collected & stored: Full account (under age of consent) registered users with parental consent who have not logged in (engaged) with the application or any marketing collateral (emails etc).
Retention period (maximum): 12 months
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.
When the purposes we collected the data for have ended we will retain and securely destroy your personal information in accordance with applicable laws and regulations.
Children’s Privacy
We recognise that children deserve added protections with regard to their personal information and privacy online.
Changes to our Privacy Policy
This Privacy Policy goes through regular reviews and is updated where appropriate; the revised version will be visible on our websites.
Contact Us
You can contact our Data Controller directly using the following methods:
Email:
Post:
Data Controller
Passion Sports Ltd
13a Vernon Yard,
London,
England