We ask that you read this privacy policy carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.

This privacy policy is divided into the following sections:

• Who we are
• Our product
• Our collection and use of your personal information
• Transfer of your information out of the United Kingdom (UK)
• Cookies and similar technologies
• Your rights
• Keeping your personal information secure
• How to complain

Who we are

We are Kairos Sports Tech Ltd (NI650105) (Kairos).  Our registered office address is 18 Ormeau Avenue, Belfast, Northern Ireland, BT2 8HS.  

Our data protection officer is Gareth Quinn (Data Protection Officer).  You can contact our Data Protection Officer by email at DPO@kairostech.io

We collect, use and are responsible for certain personal information about you. When we do so, we are regulated under the data protection laws of the UK and we are responsible as ‘processor’ of that personal information for the purposes of those laws.

Our product

Our product is a platform for professional sports units to streamline planning and optimise performance (Product).  

This privacy policy relates to the use of our Product.

Our collection and use of your personal information

We collect personal information about you when you use our Product.

We collect this personal information from you either directly, such as when you input information relating to you, or indirectly, such as when others input information relating to you and through your activity while on our Product and/or Website (see ‘Cookies’ below).

The personal information we collect about you depends on the activities carried out through our Product. Such information includes:

• your name, address and contact details;
• your position / role within your club;
• your photos / likeness (avatars);
• passport and travel details;
• date of birth;
• body measurements;
• medical details (including, inter alia, details of injuries, rehabilitation plans and inoculations);
• your training, strength and conditioning and skills plans and information;
• your performance statistics;
• information about the services we provide to you; and
• your account details, such as username (we do not have access to your password).

We use this personal information to:

• create and manage your account with us;
• verify your identity;
• provide our Product to you;
• customise our Product and its content to you and / or your club’s requirements;
• notify you of any changes to our Product that may affect you;
• further insight into our customers’ sports;
• identify trends in sport; and
• improve our Product and offering.

Our legal basis for processing your personal information

When we use your personal information, we are required to have a legal basis for doing so. There are various legal bases upon which we may rely, depending on what personal information we process and why.

The legal basis on which we process your personal data is primarily to support our legitimate interests as a business which provides the Product and other related services in relation to sport. 

Other legal bases we may rely on include:

• consent: where you have given us clear consent for us to process your personal information for a specific purpose;
• contract: where our use of your personal information is necessary for a contract we have with you or your club;
• legal obligation: where our use of your personal information is necessary for us to comply with the law (not including contractual obligations); and
• legitimate interests: where our use of your personal information is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal information, which overrides our legitimate interests).

Who we share your personal information with

Your personal data in its non-anonymised form

With your or your club’s written consent, through our Product we may share your data in its non-anonymised form with or link to other products owned and operated by certain trusted third parties to make additional services available to you.  These other third party products may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other third party products, please consult their privacy policies as appropriate.

Through our Product we may share your non-anonymised data with your club and its representatives.

We will share personal information with law enforcement or other authorities if required by applicable law.

We will not share your personal information with any other third party unless authorised to do so by you or your club.

Your personal data anonymised

We may also share your data in anonymised form to enable us to identify and share insight into our customers’ sports, trends in sport and to improve our Product and offering.

Transfer of your information out of the UK

Your data will be securely transferred to and stored in the United States of America (US) as part of the hosting services required for our Product.

Data retention and destruction

Data protection laws require us to retain personal data for no longer than is necessary for the purposes for which it is processed (principle of storage limitation).  When making decisions in relation to the retention/destruction of your personal data, we will take into account the principle of storage limitation and balance this against our requirements to retain the data, including, inter alia, for the purpose of exercising our rights contained in our terms and conditions for the supply of our Product. 

Our Data Protection Officer is responsible for the continuing process of identifying the data that has met its required retention period and supervising its destruction.

Cookies and similar technologies

A cookie is a small text file which is placed onto your device (e.g. smartphone or other electronic device) when you use our Product. We use cookies and other similar tracking technologies in our Product. These help us recognise you and your device and store some information about your preferences or past actions.

Your rights

You have the right, in accordance with data protection law, to:

• access and information – you have the right to request details and a copy of the personal data that we hold about you and information as to how we process it;
• rectification – you have the right to request that any inaccurate or incomplete data that we hold about you is corrected or updated;
• erasure – you have the right to request that we delete the personal data that we hold about you.  This is also known as ‘the right to be forgotten’.  Please note that this is not an absolute right.  This means that it only applies in certain circumstances.  We will notify you if we are unable to comply with your request;
• restriction of processing or to object to processing – you have the right to request that we no longer process your personal data for a particular purpose or to object to such processing;
• data portability – you have the right to request that we provide you with a copy of your personal data in a form which ensures that it is easily transferable from one IT environment to another in a safe and secure manner; and
• withdraw consent – if we are processing your personal data on the basis of your consent, you may withdraw that consent at any time.

If you would like to exercise any of those rights, please:

• email our Data Protection Officer;
• let us have enough information to identify you;
• let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
• let us know the information to which your request relates.

Complaints

You have the right to submit a complaint to the supervisory authority for data protection in the United Kingdom, if you feel that we are not processing your personal data in accordance with the law.  The relevant body is the Information Commissioner’s Office (ICO).  Its contact details are:

The Information Commissioner’s Office – Northern Ireland
3rd Floor
14 Cromac Place,
Belfast
BT7 2JB

Telephone: 028 9027 8757
Email: ni@ico.org.uk

We would, however, be grateful for the opportunity to address your concerns before an approach is made to the ICO.  Please, therefore, contact our Data Protection Officer in the first instance.

Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

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