SiEntries Privacy Policy

• Important Information and Who We Are
  • Introduction

    • SiEntries respects your privacy and is committed to protecting your personal data. This Privacy Policy will inform you about how we look after your personal data, tell you about your privacy rights and how the law protects you. It applies to information we collect in relation to:

      • Users of our website;
      • People who register to use the SiEntries system;
      • People who use our online system to enter an event, create a membership or make a purchase with an Organisation;
      • Employees or representatives of organisations who use our services or supply us with goods or services;
      • People who contact us via any medium (e.g. by post, email, telephone or social media).

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

      This Privacy Policy is provided in a layered format so you can click through to the specific areas set out below. Alternatively you can download a PDF version of the full policy here.

      This Privacy Policy was last updated on Monday 17th January 2022.

  • Controller and contact information

    • SiEntries Limited is the controller and responsible for your personal data (collectively referred to as “SiEntries”, "we", "us" or "our" in this Privacy Policy).

      We have appointed a data privacy manager who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, please email us on admin@sientries.co.uk.

  • Complaints

    • You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please email us on admin@sientries.co.uk in the first instance.

  • Changes to the Privacy Policy and your duty to inform us of changes

    • We reserve the right to update this Privacy Policy at any time.

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

  • Third-party links

    • Our 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 Policy of every website you visit.

• The Data we Collect About You
  • Types of Date we Collect

    • Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

      We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

      • Identity Data includes first name, last name, date of birth and gender.
      • Contact Data includes contact address, email address, social media account information and telephone numbers.
      • Financial Data includes details about payments to and from you. If you choose to pay by credit or debit card we will also ask you for your credit/debit card details. Full card details are only held by one of our payment providers, either Global Payments or Axcess Merchant Services, not by SiEntries. SiEntries will only hold the card type, expiry date, the first 6 and last 4 digits of your card number, as well as a unique reference to your card as it is known by the payment provider, allowing us to issue refunds to a card where necessary. If you set up a Direct Debit instruction in favour of SiEntries Limited then your bank account details will be stored on the SiEntries database.
      • Transaction Data includes, information required by any events you have entered or memberships you have joined and other details of goods or services you have purchased through us.
      • Technical Data includes internet protocol (IP) address, your 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, purchases or orders made by you, saved responses to commonly asked event / membership questions, your interests, preferences, feedback and survey responses.
      • Usage Data includes information about how you use our website, products and services.
      • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
      • Membership Data includes details of any clubs, organisations or associations for which you are a current member.
      • Performance Data includes, in addition to your Identity Data, your ranking and time in respect of any event in which you have participated.
      • Medical Data includes information about your health, medical history and fitness to participate in the activities you may enter.
      • Ethnicity Data includes information about your racial or ethnic origin.
      • Religious Data includes information about your religious or philosophical beliefs.
      • Sexual Orientation Data includes information about your sex life and sexual orientation.

      We may 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.

      For your personal safety, when entering an event, we may be required by the event organiser to obtain additional information from you in relation to your health and medical history (Medical Data). Additionally, to help monitor and increase diversity some events may ask for information about your racial or ethnic origin (Ethnicity Data), religious or philosophical beliefs (Religious Data) or sex life and sexual orientation (Sexual Orientation Data). This Medical, Ethnicity, Religious and Sexual Orientation information, which are special categories of personal data, will be obtained from you by your completion and submission of separate sections on the entry form where applicable and you will be asked specifically to consent to the processing by us of such Data (including the passing of such data to the Organisation holding the event).

  • 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. 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.

      If you fail to provide the Medical Data that are requested by an Organisation in relation to a particular event, the Organisation may not permit you to be entered by us for that event. If this is the case, we will notify you of this at the time.

      The provision of Ethnicity, Religious and Sexual Orientation Data will always be optional.

• How is your Personal Data Collected?
  • Methods of Data Collection

    • We use different methods to collect data from and about you including through:

      • Direct interactions. You will give us your Identity, Contact, Financial, Transaction, Profile, Membership and Performance Data and, where applicable, your Medical, Ethnicity, Religious and Sexual Orientation Data by completing and submitting a form through our website or by corresponding with us by email, phone or post. This includes personal data you provide when you:
        1. apply for our services;
        2. create an account on our website;
        3. subscribe to our service or publications;
        4. submit a paper-based Direct Debit Mandate form;
        5. request marketing to be sent to you; or
        6. give us some feedback.
      • Automated technologies or interactions. 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, server logs and other similar technologies. Please see our Cookie Policy for further details.
      • Third parties. We may receive personal data about you from various third parties as set out below:
        • Technical Data from the following parties:
          1. Organisations who use SiEntries for as an online portal for their Event, Membership or Purchases, based inside the EU
          2. analytics providers such as Google based outside the EU;
        • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Global Payments based outside the EU, Axcess Merchant Services based inside the EU and BACS based inside the EU.
        • Clubs, Organisations or Associations with whom you may have membership, to allow us to validate your Membership data. Such as:
          1. British Orienteering, based inside the EU
          2. Fell Runners Association, based inside the EU
          3. Long Distance Walkers Association, based inside the EU
• How we Use your Personal Data
  • 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) by which we mean the interest of our business in conducting and managing our business to enable us to give you the best service 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 emailing us on admin@sientries.co.uk.
      • Where we need to comply with a legal or regulatory obligation we are subject to.
  • Consent and withdrawal of consent

    • Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to Medical, Ethnicity, Religious and Sexual Orientation Data or to sending third party direct marketing communications to you via email or text message.

      You have the right to withdraw consent to marketing at any time by:

      • changing your marketing preferences via your SiEntries Account;
      • making use of the “unsubscribe” link in emails; and/or
      • emailing us at admin@sientries.co.uk.

      You have the right to withdraw consent to our processing of Medical, Ethnicity, Religious and Sexual Orientation Data at any time by emailing us on admin@sientries.co.uk. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent for Medical Data provided in relation to a particular event, we will inform the event organiser and the event organiser may not:

      1. permit you to be entered by us for that event. We will inform you of this at that time; or
      2. where you have been entered for that event, to participate in that event. The event organiser will inform you of this at that time.
  • Purposes for which we will use your personal data

    • We have set out below, in a table format, a description of all the ways we may use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

      Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please email us on admin@sientries.co.uk if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

      Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
      To register you as a new customer	(a) Identity (b) Contact	Performance of a contract with you
      To process and deliver your request including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications (f) Membership (g) Performance	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
      To manage our relationship with you which will include: (a) Notifying you about changes to our Terms of Use or Privacy Policy (b) Contacting you with regard to a contract between you (or your organisation) and us	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)
      To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
      To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
      To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
      To pass on your data to the Organisation supplying the event, the purchased goods or the membership	(a) Identity (b) Contact (c) Transaction (d) Membership (e) Performance (f) Medical Data (g) Ethnicity Data (h) Religious Data (i) Sexual Orientation Data	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to keep our records updated and to study how customers use our services) (c) Necessary for our legitimate interests in performing a contract between ourselves and the Organisation on whose behalf we provide our services to you as agent (d) In relation to Medical Data, for your personal safety and with your consent. (e) In relation to Ethnicity, Religious and Sexual Orientation Data, for monitoring and increasing diversity and with your consent.
      To pass on your data to Just Giving where you choose to register with them through SiEntries	(a) Identity (b) Contact	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to keep our records updated)
      To pass on your data to the Protect Group or to XCover where you choose to purchase refund protection	(a) Identity (b) Contact	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to keep our records updated)
      To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile	Necessary for our legitimate interests (to develop our services and grow our business)
      To publish information on the public entry lists for participants of an event or public membership lists for members of a club or association (please see our "Safeguarding" section below for exceptions)	(a) Identity (b) Transaction (c) Contact (country and social media account information only)	(a) Performance of a contract with you
      To pass information to results providers in relation to events for publication post event	(a) Identity (b) Transaction (c) Contact (country and social media account information only)	(a) Performance of a contract with you

  • Promotional offers from us

    • We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

      We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

      You will receive marketing communications from us if you have requested information or purchased services from us or if you provided us with your details when you registered with us and, in each case, you have not opted out of receiving that marketing.

  • Third-party marketing

    • We will get your express opt-in consent before we share your personal data with any company for marketing purposes.

  • Opting out

    • You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by emailing us on admin@sientries.co.uk at any time.

      Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase or other transactions.

  • Safeguarding

    • To use SiEntries you must provide full and accurate information for any event you enter or membership you apply for. In certain exceptional circumstances however it may be necessary to hide a vulnerable individual’s Identity Data from being published on any public entry or membership lists. If you or somebody you are entering has any safeguarding issues associated with publishing your Identity or Social Media Data on any such lists then please contact us at admin@sientries.co.uk to request we hide this data from these lists before entering.

      In these circumstances we would also recommend that before entering you first talk to the event / membership organiser to ensure that they are aware of any issues and that their procedures will not affect your safe participation in the event or membership.

  • Cookies

    • You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

  • 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 email us on admin@sientries.co.uk.

      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.

• Disclosures of your Personal Data
  • Disclosures of your Personal Data

    • We require all third parties to whom we disclose your data in accordance with this policy to respect the security of your personal data and to treat it in accordance with the law.

  • Specific Third Parties

    • We will pass on your Identity, Contact, Transaction and, where applicable, Medical, Ethnicity, Religious and Sexual Orientation Data, to the Organisation supplying the event or providing the purchased goods.

      If you choose to register for JustGiving via SiEntries then your Identity and Contact Data may be passed to JustGiving as a part of the entries process.

      If you choose to purchase refund protection then your Identity and Contact Data may be passed to XCover as a part of the entries process.

      If you pay for a transaction by credit or debit card we pass your Identity, Contact and Financial details to one of our payment providers, either Global Payments or Axcess Merchant Services, to process your card payment. If you choose to pay for a transaction by Direct Debit we will pass your Identity and Financial details to BACS to set up and process your Direct Debit instruction.

      We will pass Identity, Transaction and Membership data onto SPORTident UK Ltd. or any other third-party results service nominated by the Organisation to provide a results service on their behalf.

      Please check their own Privacy Policy/Terms & Conditions to see how they will use this data to manage your activity / purchase.

  • Third Party Service Providers

    • We will transfer your personal data to the following specific processors:

      • SPORTident UK Limited - which provides sales and marketing, daily administration and general customer facing services to SiEntries.
      • MKH Computer Services Limited - which provides software development and technical support services to SiEntries.

      We may also have to share your personal data with the parties set out below for the purposes set out in the "Purposes for which we will use your personal data" section above.

      • Service providers acting as processors based within the EU who provide webhosting, back-up and other IT and system administration services.
      • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
      • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
      • 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 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.

• International Transfers
  • International Transfers

    • Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

      Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

      • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
      • Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
      • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the UK and the US.

      Please email us on admin@sientries.co.uk if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

• Data Security
  • 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.

• Data Retention
  • How long will you use my personal data for?

    • 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.

      By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

      We retain your Medical, Ethnicity, Religious and Sexual Orientation Data for 3 months following the event in respect of which it was provided.

      Any data we are not required to hold for tax or other legal purposes will be held for no more than 3 years following the event or membership for which it was gathered, unless we have been specifically requested to retain it for longer by the organisation hosting the event / membership.

      In some circumstances you can ask us to delete your data: see Request erasure 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.

• Your Legal Rights
  • Your Legal Rights

    • Under certain circumstances, you have rights under data protection laws in relation to your personal data. 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: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) 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 services to you. We will advise you if this is the case at the time you withdraw your consent.

      If you wish to exercise any of the rights set out above, please email us on admin@sientries.co.uk.

  • No fee usually required

    • You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

  • What we may need from you

    • We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

  • Time limit to respond

    • 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.