The Elms Cookie Policy

This site uses cookies. Some of these cookies are essential, while others help us to improve your experience by providing insights into how the site is being used. For more detailed information on the cookies we use, please check our Privacy and Cookie Policy.

Necessary cookies enable core functionality. The website cannot function properly without these cookies, and can only be disabled by changing your browser preferences.

Analytical cookies help us to improve our website by collecting and reporting information on its usage, all of which is done anonymously.

You can review and update your preferences within the Cookies section of our Privacy and Cookie Policy page.

Privacy and Cookie Policy

This Privacy Policy was last reviewed August 2023. There were no changes.

All historic versions can be obtained by contacting us at data@theelms.co.uk

Introduction

Sport in Schools Limited (”SiS“ or “The Elms“, “we“, “our“, “us“), a company incorporated under the laws of England and Wales with reg. no. 05828791 and registered office address at 35 Ballards Lane, London, England N3 1XW, operates the website https://www.theelms.co.uk (the “Website“) and its services (the “Services“).

Important information

We are committed to protecting the privacy of our users (e.g. Players, Parents/Guardians, Schools and Coaches) and website visitors. This Privacy and Cookie Policy (”Privacy Policy“) informs you of our policy regarding the collection, use, disclosure and protection of your personally identifiable information. Please read this Privacy Policy carefully before using the Services provided through the Website.

All children (those aged 13 and under) are required to get parental consent before using this Website. Parents/Guardians play an important role in our Website, by monitoring their child’s progress and helping to keep their child safe and secure online. It’s important to us that they, and their children, understand this Privacy Policy and we hope that Parents/Guardians will take time to explain it to and discuss it with their children.

It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them.

The data protection law in the UK changed on 25 May 2018. When you register or use the Website you will be asked to “opt in” to our Privacy Policy i.e. to confirm that you agree to our use of any personal data that we may collect from you as a user of the Website as set out in this Privacy Policy. If you do not give your consent, you will not be able to use the Website as we will be unable to provide our services and facilities to you. You can withdraw your consent to our use of your personal data at any time (see Your Rights).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact Details

Gill Rabbett data@theelms.co.uk

Third-Party Links

This Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy notice of every website you visit.

For ease of reading, we have divided this Privacy Policy into several sections:

1. What information do we collect about you?

What is personal data?

Where this Privacy Policy refers to ‘personal data’ it is referring to data about you (or other living people) from which you could be identified – such as your name, your contact details and even your IP address.

Data we collect from you

Depending on how you interact with us, SiS 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, title.
  • Coach Data: includes Identity Data and Contact Data and DBS certificate, Safeguarding Children Certificates, photo, CV, details of qualifications and references.
  • Contact Data: includes e-mail address, postal address, telephone number; and mobile number.
  • Financial Data: includes [bank account and payment card details].
  • Transactional Data: includes [details about payments to and from you and other details of Services you have purchased from us].
  • Technical Data: includes IP address, 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.
  • Profile Data: includes your username and password, skill scores, your interests, preferences and feedback.
  • Usage Data: includes information about how you use our Website and services.
  • Relevant Medical Data: Allergies, Asthma, Hayfever, Mobility Problems etc.
  • 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 used in accordance with this Privacy Policy.

We may collect Special Categories of Personal Data in relation to a child’s health, if provided to us. This may be to ensure that our staff are aware of any allergies or underlying health conditions when a child is registered.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with Services). In this case, we may have to cancel a Service you have with us but we will notify you if this is the case at the time.

Updating your information

If you want to update the information you have previously given to us (e.g. if you have recently moved office or changed your email address), you can contact SiS by:

  • e-mailing data@theelms.co.uk or
  • writing to us at Sport in Schools Ltd, The Elms, 12 Pynnacles Close, Stanmore, Middlesex HA7 4AF;
  • telephoning us on 020 8954 8787;
  • submitting the contact form.

2. 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 and Contact Data by filling in forms or by corresponding with us by post, phone, e-mail, or otherwise. This includes personal data you provide when you:
    • create on account on our Website;
    • request marketing to be sent to you;
    • give us feedback.
  • Automated technologies or interaction. As you interact with our Website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see the section on cookies for further details.
  • Third parties. We may receive personal data about you from various third parties as set out below:
    • Technical Data from analytical providers, such as Google based outside the UK.

3. 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 we need to perform the contract we are about to enter into or have entered into with you.
  • 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.
  • Where we have your consent as a legal basis for processing to send you any direct marketing from us or third parties via e-mail. You have the right to withdraw consent to marketing at any time by contacting us at data@theelms.co.uk.

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 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, in compliance with the above rules, where this is required or permitted by law.

4. Disclosures of your personal data

Depending on how and why you provide us with your personal data. We may share it in the following ways:

  • We may analyse and disclose aggregated statistics about our Website visitors and users of our Service in order to describe our Services to prospective partners and other reputable third parties and for other lawful purposes, but these statistics will include no personally identifying information.
  • We may disclose personal data if required to do so by law or if we believe that such action is necessary to protect and defend the rights, property or personal safety of the Website or its visitors.
  • We may share your personal data with 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.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

5. International transfers

We do not transfer your personal data outside the UK.

6. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7. Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data: see Your Rights below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Please contact us if you would like a copy of our data retention policy.

8. Cookies

A cookie is a text-only string of information that a website transfers to the cookie file of the browser on your computer’s hard disk so that the website can remember who you are.

A cookie will typically contain the name of the domain from which the cookie has come, the ‘lifetime’ of the cookie, and a value, usually a randomly generated unique number.

A cookie can be classified by its lifespan and the domain to which it belongs. By lifespan, a cookie is either a:

  • Session cookie. Temporary cookie that remains in the cookie file of your browser until you leave the website.
  • Persistent cookie. This remains in the cookie file of your browser for much longer (though how long will depend on the lifetime of the specific cookie).

As for the domain to which it belongs, there are either:

  • First-party cookies. These cookies are issued from the website you have accessed and often serve to give memory about your data and preferences.
  • Third-party cookies. These are stored by a different domain to the visited page’s domain.

Find out more about cookies by contacting us at data@theelms.co.uk or visit www.allaboutcookies.org.

How we use cookies on our Website and what information we collect

  • Strictly necessary cookies. These are cookies that are required for the operation of our Website. They include, for example, cookies that enable you to log into secure areas of our Website or make use of e-billing services.
  • Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.
  • Functionality cookies. These are used to recognise you when you return to our Website. This enables us to personalise our content for you and remember your preferences (for example, your choice of language or region).
  • Targeting cookies. These cookies record your visit to our Website, the pages you have visited and the links you have followed.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Cookie Name Type Purpose Expiry
PHPSESSID HTTP Preserves user session state across page requests Session
GDPRConsent HTTP Remembers your decision regarding opting in or out of analytical cookies 1 year
_utma HTTP Collects data on the number of times a user has visited the website as well as dates for the first and most recent visit. Used by Google Analytics 2 years
_utmb HTTP Registers a timestamp with the exact time of when the user accessed the website. Used by Google Analytics to calculate the duration of a website visit Session
_utmc HTTP Registers a timestamp with the exact time of when the user leaves the website. Used by Google Analytics to calculate the duration of a website visit Session
_utmt HTTP Used to throttle the speed of requests to the server. Used by Google Analytics Session
_utmz HTTP Collects data on where the user came from, what search engine was used, what link was clicked and what search term was used. Used by Google Analytics 6 months

As noted in the table above, we use Google Analytics to collect information about you in aggregated form to help SiS understand how the Website is being use and to help SiS customise the Website for you. For more information about Google’s privacy policy, please visit http://www.google.com/intl/en/policies/. If you do not wish to allow the use of Google Analytics cookies at all, Google provides an opt-out plug-in for most common website browsers http://tools.google.com/dlpage/gaoptout.

Disabling or enabling cookies

You have the ability to accept or decline cookies by modifying the settings in your browser. However, you may not be able to use all the interactive features of our Website if cookies are disabled.

You may also enable/disable the use of non-essential cookie types using the form below:

Cookie Preferences

9. Your Rights

As a data subject you have a number of rights in relation to your personal data. Below, we have described the various rights that you have, as well as how you can exercise them.

Right of Access

You may, at any time, request access to the personal data that we hold which relates to you (you may have heard of this right being described as a “subject access request“).

Please note that this right entitles you to receive a copy of the personal data that we hold about you in order to enable you to check that it is correct and to ensure that we are processing that personal data lawfully. It is not a right that allows you to request personal data about other people, or a right to request specific documents from us that do not relate to your personal data.

You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a subject access request. You do not have to fill in a specific form to make this kind of request.

Your Right to Rectification and Erasure

You may, at any time, request that we correct personal data that we hold about you which you believe is incorrect or inaccurate. You may also ask us to erase personal data if you do not believe that we need to continue retaining it (you may have heard of this right described as the “right to be forgotten”).

Please note that we may ask you to verify any new data that you provide to us and may take our own steps to check that the new data you have supplied us with is right. Further, we are not always obliged to erase personal data when asked to do so; if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to erase we will tell you what that reason is at the time we respond to your request.

You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a request to have your personal data rectified or erased and on what basis you are making that request. If you want us to replace inaccurate data with new data, you should tell us what that new data is. You do not have to fill in a specific form to make this kind of request.

Your Right to Restrict Processing

Where we process your personal data on the basis of a legitimate interest (see the section of this Privacy Policy which explains why we use your personal data) you are entitled to ask us to stop processing it in that way if you feel that our continuing to do so impacts on your fundamental rights and freedoms or if you feel that those legitimate interests are not valid.

You may also ask us to stop processing your personal data: (a) if you dispute the accuracy of that personal data and want us verify that data’s accuracy; (b) where it has been established that our use of the data is unlawful but you do not want us to erase it; © where we no longer need to process your personal data (and would otherwise dispose of it) but you wish for us to continue storing it in order to enable you to establish, exercise or defend legal claims.

Please note that if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to stop processing, we will tell you what that reason is, either at the time we first respond to your request or after we have had the opportunity to consider and investigate it.

You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a request to have us stop processing the relevant aspect of your personal data and describing which of the above conditions you believe is relevant to that request. You do not have to fill in a specific form to make this kind of request.

Your Right to Portability

Where you wish to transfer certain personal data that we hold about you, which is processed by automated means, to a third party you may write to us and ask us to provide it to you in a commonly used machine-readable format.

Because of the kind of work that we do and the systems that we use, we do not envisage this right being particularly relevant to the majority of individuals with whom we interact. However, if you wish to transfer your data from us to a third party we are happy to consider such requests.

Your Right to stop receiving communications

For details on your rights to ask us to stop sending you various kinds of communications, please contact us.

Your Right to object to automated decision making and profiling

You have the right to be informed about the existence of any automated decision making and profiling of your personal data, and where appropriate, be provided with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing that affects you.

Exercising your rights

When you write to us making a request to exercise your rights we are entitled to ask you to prove that you are who you say you are. We may ask you to provide copies of relevant ID documents to help us to verify your identity.

It will help us to process your request if you clearly state which right you wish to exercise and, where relevant, why it is that you are exercising it. The clearer and more specific you can be the faster and more efficiently we can deal with your request. If you do not provide us with sufficient information then we may delay actioning your request until you have provided us with additional information (and where this is the case we will tell you).

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

For our contact details, please see here.