What does this notice cover?
This notice describes how ATP Media Operations Limited (also referred to as "ATP Media", "we" or "us") will make use of your data when you subscribe to and use Tennis TV.
It also describes your data protection rights, including a right to object to some of the processing which ATP Media carries out. More information about your rights, and how to exercise them, is set out in the "What rights do I have?" section.
Summary of how we use your data
- ATP Media uses your personal data to provide you with Tennis TV, including providing you with personalised content, and to manage your subscription (including processing your payments).
- Data is shared with a number of data processors, who help provide us with the Tennis TV platform and with analytical services. Where you consent, we may share your information with ATP and ATP Tournaments, so that they can send you marketing about their products and tournaments. Again, you can withdraw this consent at any time.
- Where we rely on your consent, such as for sending you marketing communications, you can withdraw this consent at any time.
- We may, where you consent, share your information with ATP and ATP Tournaments, so that they can send you marketing about their products and tournaments. Again, you can withdraw this consent at any time.
- Where you are under the age of 13 - or where you are located in a member state that has set an age higher than this - we will not send you direct marketing or allow ATP or ATP Tournaments to send you marketing. We will need to obtain your age in order to ensure that we comply with this obligation.
What information do we collect?
We collect and process personal data about you when you interact with us and our websites and apps, and when you register and purchase a subscription from us. This will typically be provided directly by you, and may include information you provide on registration or in the process of your purchase, such as your name, address, email address, marketing preferences and payment details. The details being provided by you will be made clear in forms you complete or will be provided directly by you in surveys, in purchasing a subscription or in volunteering information in communications or content you provide us.
What information do we generate or receive from third parties?
We may generate or collect information about you ourselves. Much of this is set out in our Cookies Section below.
Sometimes, we receive information about you from third parties such as social media sites. For example, if you use a "like" or a "share" button for a feature on our sites or apps, then the third party site you share this on will share information with us. If you participate in activities on non-ATP Media sites or apps - such as participating in a Facebook application - you may allow us to have access to personal data held by Facebook, or other similar sites or app owners. We may also obtain information about you from third party analytics providers, which we may use to help us better understand our users and send them appropriate offers and information.
How do we use this information, and what is the legal basis for this use?
We process this personal data for the following purposes:
- To fulfil a contract, or take steps linked to a contract: this is relevant where you purchase a subscription from us or enter a competition we run. This includes:
- verifying your identity;
- taking payments;
- communicating with you; and
- providing customer services and arranging the delivery or other provision of products, prizes or services.
- As required by ATP Media to conduct our business and pursue our legitimate interests, in particular:
- we monitor and analyse use of our websites and online services, and use your information to help us monitor, improve and protect our products, content, services and websites - we may also share data with ATP and ATP Tournaments so that it can carry out similar analysis and improvement;
- we use information you provide to personalise our website, products or services for you;
- if you provide a credit or debit card as payment, we also use third parties to process that payment and check the validity of the card number you submit in order to prevent fraud (see data sharing below);
- we use information you provide to investigate any complaints received from you or from others, about our website or our products or services;
- we will use data in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation); and
- we use data of some individuals to invite them to take part in market research.
- Where you give us consent:
- we will send you direct marketing in relation to our relevant products and services;
- we will share your data with ATP and ATP Tournaments so that they may send you products and services;
- we place cookies and use similar technologies in accordance with our Cookies Policy and the information provided to you when those technologies are used; and
- on other occasions where we ask you for consent, we will use the data for the purpose which we explain at that time;
- For purposes which are required by law:
- we collect your age to ensure that we do not send marketing to individuals where we would be required to obtain parental consent;
- we will process information in order to comply with EU portability requirements; and
- we will provide data in response to requests by government or law enforcement authorities conducting an investigation.
Relying on our legitimate interests
We have carried out balancing tests for all the data processing we carry out on the basis of our legitimate interests, which we have described above. You can obtain information on any of our balancing tests by contacting us using the details set out later in this notice.
Withdrawing consent or otherwise objecting to direct marketing
Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests. You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by following the instructions in the communication where this is an electronic message, by making changes to your preferences on the logged-in sections of our sites and applications, or by contacting us using the details set out below.
What cookies and/or tracking technologies does ATP Media use?
When you visit one of our websites, we may also collect, process and use information about you and your use of the website, including any forums you visit and how you arrived at our site. Such information may be collected through "traffic data" and may entail the use of "cookies" or other tracking technologies, IP Addresses or other numeric codes used to identify your computer.
Apple iOS, Android and other mobile, gaming or smart devices
By accessing an ATP Media application from these devices you consent to cookies being stored to your device (and other tracking technologies being used to read data from your device) for the following purposes: keeping you logged in, ensuring that an appropriate version of content is presented, analytics and advertising. Many of these cookies and technologies are essential to the operation of the application. It is not currently possible to opt out or remove these cookies (or prevent use of these technologies) from the device without deleting the application.
For more information on Cookies please click on the link to our Cookies Policy.
Who will we share this data with, where and when?
We will share information with ATP and ATP Tournaments where you give consent to their processing of your data. We will also share data with ATP so that they can carry out analysis of their products and services based on the use of ATP Media's services - this sharing is carried out on the basis of our, and ATP's, legitimate interests.
We may, in order to provide Tennis TV on certain platforms you choose to use, be required to share certain limited information with the provider of that platform to ensure that the service can be loaded and provided.
Personal data may be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable laws.
Personal data will also be shared with third party service providers, who will process it on behalf of ATP Media for the purposes identified above. In particular, we use third party providers of website design and hosting, video delivery, maintenance and payment processing services. We also use third party analytical tools, which process your data to help us get better insights into our users and allow us to improve our services and promotions
In the event that the business is sold or integrated with another business, your details will be disclosed to our advisers and any prospective purchaser's adviser and will be passed to the new owners of the business.
Where information is shared with ATP, this is shared to the United States. ATP tournaments are located all over the world, including in countries outside the EEA. Some of our suppliers are also located in the United States. Where information is transferred outside the EEA, and where this is to a stakeholder or vendor in a country that is not subject to an adequacy decision by the EU Commission, data is adequately protected by EU Commission approved standard contractual clauses, an appropriate Privacy Shield certification or a vendor's Processor Binding Corporate Rules. A copy of the relevant mechanism can be provided for your review on request using the contact details set out below.
What rights do I have?
You have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us for a contract or with your consent in a structured, machine readable format , and to ask us to share (port) this data to another controller.
In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don't have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are included in both the GDPR and in local laws, such as the Data Protection Act 2018. We will inform you of relevant exemptions we rely upon when responding to any request you make.
To exercise any of these rights, or to obtain other information, such as a copy of a legitimate interests balancing test, you can get in touch with us - or our data protection officer - using the details set out below. If you have unresolved concerns, you have the right to complain to an EU data protection authority where you live, work or where you believe a breach may have occurred.
We indicate which data is mandatory when you first sign up for the service. If this information is not provided, we cannot provide our services. Other information is optional, such as details of your preferences, but if you do not provide this then we may not be able to provide you a fully personalised service.
How do I get in touch with you?
We hope that we can satisfy queries you may have about the way we process your data. If you have any concerns about how we process your data, orwould like to opt out of direct marketing, you can get in touch at firstname.lastname@example.org or by writing to Thames House, Portsmouth Road, Esher, KT10 9AD. Don't forget that you can also change your preferences by visiting the logged in sections of our website.
How long will you retain my data?
Where we process registration data, or otherwise in connection with performing a contract or processing for a competition, we do this for as long as you are an active user of our sites and for at least 6 years after this.
Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). Where you have not opened an email from us in two years, we will take you off our mailing lists. We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data indefinitely so that we can respect your request in future.
Effective Date: This Privacy Notice was updated 30th August 2018 and is effective as of that date.