Privacy Policy


Last updated November 28, 2023

 

Directors’ Box Limited (‘we’, ‘us’, or ‘our’) are committed to protecting your personal data and respecting your privacy. This privacy policy describes how and why we might collect, store, use, and/or share (‘process) your information when you use our services (‘Services’).

 

Questions or concerns? Reading this privacy policy will help you understand your privacy rights and choices. If you disagree with our policies and practices, please do not use our services. If you have any questions or concerns, please contact us at privacy@directorsbox.app.

 

INTRODUCTION

 

This policy, together with our Terms of Use applies to your use of:

  • Directors’ Box (which was last updated on November 28, 2023) mobile application software (App) once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device).

  • Any of the services accessible through the App (Services) that are available on the App. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

This policy is provided in a layered format so you can click through to the specific areas set out below.

 

1. IMPORTANT INFORMATION AND WHO WE ARE

2. THE DATA WE COLLECT ABOUT YOU

3. CHILDREN AND PERSONAL DATA

4. HOW IS YOUR PERSONAL DATA COLLECTED?

5. HOW WE USE YOUR PERSONAL DATA

6. DISCLOSURES OF YOUR PERSONAL DATA

7. INTERNATIONAL TRANSFERS

8. DATA SECURITY

9. THIRD-PARTY SERVICES AND ADVERTISEMENTS

10. DATA RETENTION

11. YOUR LEGAL RIGHTS

12. GLOSSARY

 

1. IMPORTANT INFORMATION AND WHO WE ARE

 

Directors’ Box Limited is the controller and is responsible for your personal data (collectively referred to as [“Company”], “we”, “us” or “our” in this policy).

 

We have appointed a data protection officer (DPO).

 

If you have any questions about this privacy policy, please contact them using the details set out below.

 

Our full details are:

  • Name of DPO: Tracy Jennifer Morgan

  • Email address: tracy@tracyjennifer.com

  • Telephone number: +44 7450 242 545

  • Postal address: 88a Main Street, Fulford, York, Yorkshire, YO10 4PS, United Kingdom

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues.

 

Changes to the privacy policy and your duty to inform us of changes.

We keep our privacy policy under regular review.

 

This version was last updated on November 28, 2023. It may change and if it does, these changes will be posted on this document.

 

The new policy may be displayed on-screen, and you may be required to read and accept the changes to continue your use of the App or the Services.

 

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

 

Third party links

Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.

 

2. THE DATA WE COLLECT ABOUT YOU

 

We may collect, use and store different kinds of personal data about you as follows:

  • Phone number

  • Your chosen men’s football team

  • Your chosen women’s football team

When necessary, with your consent, we process sensitive information. We want to reiterate that providing the following categories of sensitive information is completely optional, and you can still use the app without providing this data.

  • Demographic data (region of user – this is not entered via GPS)

  • Age Group

  • Gender.

    We collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific app feature.

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 offences.

 

3. CHILDREN AND PERSONAL DATA

 

Article 8 of the UK GDPR provides that:

  • Only children aged 13 years and over may lawfully provide their own consent for the processing of their personal data;

  • An adult with parental responsibility must provide consent for processing if the child is under 13.

In order to gain parental consent, before registering for the App, the user will be asked to insert their phone number, and if the user is under the age of 13, they will be asked to insert their legal guardian’s phone number.

 

When the legal guardian inserts their phone number, this will be used as a declaration of parental consent which will allow us to process the child’s personal data, which will therefore be solely the supported teams.

As the legal guardian’s phone number is used to create the account, this gives them access and control over the child’s account.

 

4. HOW IS YOUR PERSONAL DATA COLLECTED?

 

We will collect and process the following data about you:

  • Information you give us. This is information (including phone number, men’s football team you support and women’s football team you support) you consent to give us by filling in forms on the App, or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the App, enter a competition, promotion or survey, and when you report a problem with an App, our Services, or any of Our Sites. If you contact us, we will keep a record of that correspondence.

  • Sensitive information. This information (including demographic data, age and region) is provided voluntarily by filling in forms on the App when prompted.

  • Unique application numbers. When you want to install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.

5. HOW WE USE YOUR PERSONAL DATA

 

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

  • 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.

  • Where we need to comply with a legal or regulatory obligation.

Any data shared would not include any direct or indirect identifiers. Your phone number would never be shared to third parties, the only data which may be shared would be regional data, age, gender and/or football team supported. This data is anonymised and could never be linked back to you.

This aggregated data is shared for statistical reasons only.

 

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

Purpose/activity Data Used Lawful basis for processing
To install the App and register you as a new App user or to login as an existing user. Phone Number. Men’s football team supported. Women’s football team supported. Necessary for out legitimate interest. (Teams supported is used to create anonymised statistics and to deliver content; Phone number is used to create an account; however this will never be shared)
To manage our relationship with you including notifying you of changes to the App or any Services Phone number. Performance of a contract with you. Necessary for our legitimate interests. Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions.
To enable you to participate in polls, petitions, quizzes, and other in-app features Phone number. Men’s football team supported. Women’s football team supported. Performance of a contract with you. Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services).  
To deliver content and advertisements to you. To make recommendations to you about goods or services which may interest you. To measure and analyse the effectiveness of the advertising we serve you. To monitor trends so we can improve the App. Men’s football team supported. Women’s football team supported. Region Age group Gender     Necessary for our legitimate interests (to develop our products/Services and grow our business)
     

6. DISCLOSURES OF YOUR PERSONAL DATA

 

When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties. This is purely for statistical reasons and your identity will not be directly or indirectly revealed.

  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

7. INTERNATIONAL TRANSFERS

 

We do not transfer your personal data outside the UK.

 

8. DATA SECURITY

 

All information you provide to us is stored on our secure servers.

 

Where we have given you a password or a One Time Password that enables you to access certain parts of Our App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

 

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so. Despite our safeguards and efforts to secure your information, no electronic transmission can be guaranteed to be 100% secure, so we cannot guarantee that cybercriminals or other unauthorised parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

 

9. THIRD-PARTY SERVICES AND ADVERTISEMENTS

 

The Services may link to third-party websites, online services, or mobile applications and/or advertisements from third parties that are not affiliated with us and which may link to other websites, services, or applications.

 

Accordingly, we do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications. Any data collected by third parties is not covered by this privacy policy. You should review the policies of such third parties and contact them directly to respond to your questions.

 

9. DATA RETENTION

 

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy. No purpose in this policy will require us keep your personal information for longer than the period of time in which users have an account with us.

 

10. YOUR LEGAL RIGHTS

 

Under certain circumstances you have the following rights under data protection laws in relation to your personal data.

 

Please click on the links below to find out more about these rights:

As we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. You can do so by contacting us at privacy@directorsbox.app.

 

Alternatively, there is the option to delete your account from within the App, which will then allow us to erase your data.

 

11. GLOSSARY

 

LAWFUL BASIS

 

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you 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 obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

 

THIRD PARTIES

 

INTERNAL THIRD PARTIES

 

Other companies in the Directors’ Box Limited Group acting as joint controllers or processors and who are based in the United Kingdom and provide IT and system administration services and undertake leadership reporting.

 

EXTERNAL THIRD PARTIES

 

Service providers acting as processors who provide IT and system administration services.

Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue and Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.

 

YOUR LEGAL RIGHTS

 

You 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 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:

  1. if you want us to establish the data’s accuracy;

  2. where our use of the data is unlawful but you do not want us to erase it;

  3. where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or

  4. you have objected to our use of your 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 or where we used the information to perform a contract with 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.