SOUL BOWL PRIVACY POLICY
- INTRODUCTION
DATA WE COLLECT ABOUT YOU
HOW WE USE YOUR DATA
SHARING OF YOUR DATA
DELETION AND ACCESS OF YOUR PERSONAL DATA
ABOUT THIS WEBSITE’S SERVER & SECURITY
OUR THIRD PARTY DATA PROCESSORS
DATA BREACHES
GOVERNING LEGISLATION
INTRODUCTION
Thank you for visiting the Soul Bowl website, owned and provided by JET Ltd, Marine Road West, Morecambe LA4 4BU.
Who are we?
The company JET Ltd. has the following companies within it: Jump Rush, Soul Bowl and Vista.
Your privacy is a serious matter to us at JET and we have created this privacy policy to inform you of how we collect, use, share, and secure your personal information.
This policy applies to all information collected by us, or provided by you, on our website or in any other way (such by telephone or by email).
By accessing or using the website, you agree to the terms of this Privacy Policy. This Privacy Policy is incorporated into, and part of, the Soul Bowl Terms of Use, which governs your use of the website in general.
DATA WE COLLECT ABOUT YOU
Personal Information
When you visit our website or contact us by email or telephone you may choose to provide us with personal information. For example your name, company name, email address and phone number. You may provide us with information in a number of ways:
- By supplying us with the Information as listed above, on an individual basis by completing a form on our website, signing up to receive a newsletter, registering for an event or applying for a job; and
By corresponding with us by email, in which case we may retain the content of your email messages together with your email address and our responses.
Contact forms and email links
Should you choose to contact us using the contact form on our Contact us page or an email link like this one, the data will be transferred and stored securely within our email providers’ databases.
Email Newsletter
If you choose to join our email newsletter or hear about job updates, the email address that you submit to us will be automatically shared to our email service providers. This will usually be through the system of our booking engine provider, Brunswick. Details of their data use are below. We may also use third party provider MailChimp, who we use for email marketing services. We consider MailChimp to be a third party data processor (see third party data processors below). The email address that you submit will not be stored within this website’s own database or in any of our internal computer systems.
Your email address will remain within MailChimp’s database for as long as we continue to use MailChimp’s services for email marketing or until you specifically request removal from the list. You can do this by unsubscribing using the unsubscribe links contained in any email newsletters that we send you or by requesting removal via email. When requesting removal via email, please send your email to us using the email account that is subscribed to the mailing list.
If you are under 18 years of age you MUST obtain parental consent before joining our email newsletter.
While your email address remains within the MailChimp database, you will receive periodic (approximately one per month) newsletter-style emails from us.
Candidate Information
Should you apply for a job with Vista or any other JET Ltd. companies you may provide us with more sensitive information about yourself, including educational and employment background; job or career interest data; benefit choices; and other information by answering questions or tests.
Non-personal Information
Our website also collects non-personally identifiable information about you, such as the server your computer is logged onto and your browser type, including non-personally identifiable information such as:
Cookies
Like many other websites, our website uses cookies and similar technologies such as tags and pixels (which we will refer to collectively as “Cookies”). Please see our Cookie Policy for further details of the Cookies used on the Soul Bowl website and how you can block such Cookies.
Do we collect information about children?
We do not knowingly collect Personal Information from children under 13 years old on this Website or through our application.
HOW WE USE YOUR DATA
When you provide personal information to us, we will use it for the purposes for which it was provided to us as stated at the point of collection (or as is obvious from the context of collection).
We may use the Personal Information that you provide to us to operate and improve our business, including this website; to communicate with you; to provide you with information or services that you have requested; and for verification purposes. We may use and disclose any information that is aggregated or de-identified so that it does not identify you personally, at our discretion.
Examples of the types of use are given in the ‘data we collect about you’ section above. The legal basis for processing your data is based on our legitimate interest to do so in accordance with the context in which it was provided, or based on your consent, for example where you have signed up to receive Vista newsletters or to hear from our other companies such as Jump Rush or Soul Bowl.
We may also use your data to contact you with information about our business, services and events, and other information that may be of interest to you. You can let us know at any time if you no longer wish to receive these communications by contacting hey@soulbowl-uk.com or following the unsubscribe instructions contained in the communication.
Specifically, we may use your information:
- To provide our services, activities or online content, to provide you with information about them and to deal with your requests and enquiries
- To provide you with the most user-friendly online navigation experience;
- For “service administration purposes”, which means that we may contact you for reasons related to the service, activity or online content you have signed up for (e.g. to provide you with password reminders, to notify you that a particular service, activity or online content has been suspended for maintenance, to notify you of updates to our Privacy and Cookies Policy or Terms of Use, to let you know if your account has become dormant and to ask if you would like to use it again before we close it);
We may also show you relevant advertising on third party sites, as detailed below and within our cookie policy;
- To contact you about a submission you have made, including any content you provide. For additional information, please see the Terms of Use;
- To use IP addresses and device identifiers to identify the location of users, to block disruptive use, to establish the number of visits from different countries, and to determine whether you are accessing the services from the UK or not.
- We may also use and disclose information in aggregate (so that no individuals are identified) for marketing and strategic development purposes.
- Our website does not collect or compile personal information for dissemination or sale to outside parties for consumer marketing purposes, or host mailings on behalf of third parties.
As detailed in above, if you submit a comment to a blog post published on this website some personal information will be stored within this website’s database. This is currently the only occasion where personal data will be stored on this website. This data is currently stored in an identifiable fashion; a limitation of the content management system that this website is build on (WordPress). In the near future we aim to change the storage of this data to a pseudonymous fashion meaning that the data would require additional processing using a separately stored ‘key’ before it could be used to identify an individual.
Pseudonymisation is a recent requirement of the GDPR which many web application developers are currently working to fully implement. We are committed to keeping it as a high priority and will implement it on this website as soon as we are able to.
SHARING OF YOUR DATA
Generally, we will use your information within JET Ltd companies, which include Soul Bowl, Vista and Jump Rush and will only share it outside of JET Ltd. where you have requested it or given your consent. However, we may share with third party sites (e.g. Facebook, Google, Twitter and Mailchimp) some data, with appropriate security measures, to show you relevant advertising on third party sites, as set out in our section “third-party data processors.”
We may also share your data:
- To provide you with any information or services that you request;
- To respond to legal requests for information, court orders, and other legal process, or as otherwise required by law;
- To exercise Soul Bowl’s legal rights or defend ourselves against legal claims, to enforce our contracts, to investigate, respond to and resolve problems or inquiries (including governmental inquiries), or to permit us to pursue available remedies or limit the damages that we may sustain;
- In connection with an actual or potential merger, sale, acquisition, assignment, or transfer of all or part of our assets, affiliates, lines of business, or products, including bankruptcy;
- With your consent.
Will I be contacted for marketing purposes?
We will only send you marketing emails or contact you where you have agreed to this. We will do this via our third party data processors Mailchimp or Brunswick.
We may use information which we hold about you to show you relevant advertising on third party sites (e.g. Facebook, Google and Twitter). This is known as interest-based or remarketing targeting. You can view more about this or learn how to opt out by viewing our cookie policy.
How long will you keep my information?
We will hold your personal information on our systems for as long as is necessary for the relevant activity, or as long as is set out in any relevant contract. If you have an account and you delete this then your personal information is deleted immediately, and the remaining information is anonymised for analytical purposes.
DELETION AND ACCESS OF YOUR PERSONAL DATA
Can I delete my personal data?
If you hold an account then you can always delete this in your account settings. You can also email us to ask us to delete any personal information associated with you at hey@soulbowl-uk.com
Can I find out what personal information you hold about me?
Under the Data Protection Act you have the right to request a copy of the personal information we hold about you and to have any inaccuracies corrected. (We charge £10 for information requests and require you to prove your identity with 2 pieces of approved identification). We will use reasonable efforts consistent with our legal duty to supply, correct or delete personal information about you on our files. If you are within the UK, please address requests and questions to our Data Protection Officer, as listed below
We will need two copies of forms of identification, which can be Passport, Driving licence, Birth certificate, Utility bill (from last 3 months), Current vehicle registration document, Bank statement (from last 3 months), Rent book (from last 3 months).
ABOUT THIS WEBSITE’S SERVER & SECURITY
The security of our website and any data held within it is one of our key priorities. Although no site is entirely safe from security threats, we have taken the following key steps to enhance the security of our site to a level we can be proud of. Please note, any data you send over the internet should not be treated as secure due to the very nature of the online environment.
Our hosting
This website is hosted by WPEngine within servers located within the European Union. This files and databases on this site are backed up to the WP Engine servers. This may contain personal information. WP Engine are class as a data processor and are fully compliant with GDPR. You can view the security policy of WPEngine here https://wpengine.co.uk/support/wp-engines-security-environment/
HTTPS Protocol
All traffic (transferral of files) between this website and your browser is encrypted and delivered over HTTPS.
OUR THIRD PARTY DATA PROCESSORS
We use a select number of third parties to process personal data on our behalf. These third parties have been carefully chosen and they all comply with the legislation set out in section 2.0. All of these third parties are based in the EU or USA and are GDPR or EU-U.S Privacy Shield compliant.
Advertising & Analytics Cookies
We use Google and other third-party advertisers to provide us with web analytics and remarketing services. This allows us to understand more about how you are using our site and the products and pages you are interested in. We may then use Google’s services to show you adverts that you may find of interest. We do this using cookies. To view more information about this and how you can opt out of cookies, please view our full cookie policy.
Email
If you choose to join our email newsletter or hear about job updates, the email address that you submit to us will be automatically shared to our email service providers. This will usually be through the system of our booking engine provider, Brunswick. Details of their data use are below. We may also use third party provider MailChimp, who we use for email marketing services. We consider MailChimp to be a third party data processor (see third party data processors below). The email address that you submit will not be stored within this website’s own database or in any of our internal computer systems.
Your email address will remain within MailChimp’s database for as long as we continue to use MailChimp’s services for email marketing or until you specifically request removal from the list. You can do this by unsubscribing using the unsubscribe links contained in any email newsletters that we send you or by requesting removal via email. When requesting removal via email, please send your email to us using the email account that is subscribed to the mailing list. While your email address remains within the MailChimp database, you will receive periodic emails that we think may be of interest to you, including job updates and specific news.
If you are under 18 years of age you MUST obtain parental consent before joining our email newsletter.
Meriq and Brunswick
Our main booking engine provider is Brunswick, supported by online booking services from their partner company Meriq. When you enter any data during the process of booking, your data will be shared and stored with these providers. These providers will only process any personal data that are necessary for each specific purpose of processing your booking and enabling us to send you email communications where you have opted in to this. You can view their full privacy policies by reading these attachments. GDPR policy – Meriq SYNC Privacy Policy_2018.4.12
Adyen
We do not store or collect your payment card details. That information is provided directly to our third-party payment processor Adyen, whose use of your personal information is governed by their Privacy Policy.
DATA BREACHES
We will report any unlawful data breach of this website’s database or the database(s) of any of our third party data processors to any and all relevant persons and authorities within 72 hours of the breach if it is apparent that personal data stored in an identifiable manner has been stolen.
GOVERNING LEGISLATION
Along with our business and internal computer systems, this website is designed to comply with the following national and international legislation with regards to data protection and user privacy:
- UK Data Protection Act 1988 (DPA)
- EU Data Protection Directive 1995 (DPD)
- EU General Data Protection Regulation 2018 (GDPR)
- Australian Privacy Act 1988 (APA)
- Your consent
By using our website you consent to our collection and use of the Information as described in this Privacy Policy and in our Cookie Policy.
CHANGES TO OUR PRIVACY POLICY
This privacy policy may change from time to time inline with legislation or industry developments. We will not explicitly inform our clients or website users of these changes. Instead, we recommend that you check this page occasionally for any policy changes. Specific policy changes and updates are mentioned in the change log below.
Our website contains hyperlinks to websites owned and operated by third parties. These third party websites have their own privacy policies, and are also likely to use cookies, and we therefore urge you to review them. They will govern the use of personal information you submit when visiting these websites, which may also be collected by cookies. We do not accept any responsibility or liability for the privacy practices of such third party websites and your use of such websites is at your own risk.
DATA CONTROLLER
The data controller of this website is: JET Ltd
Whose registered office is:
Marine Road West
Morecambe
LA4 4BU
And whose operating office is:
Marine Road West
Morecambe
LA4 4BU
DATA PROTECTION OFFICER
Scott Robson
Director, JET Ltd.
Privacy Policy Change Log
10/7/18 – Privacy policy created