Privacy Policy
- Last Updated: 13th March 2024
We are Trutactics Limited, a company incorporated in Scotland with company number SC793165 and having its registered office at 272 Bath Street, Glasgow, Scotland, G2 4JR (“we”, “us”, “our”). We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.
This version of our privacy policy is written primarily for adults, including parents and guardians of children who make use of our services. If you are under the age of 16 in the United Kingdom or under the age of majority in your territory, you are welcome to read this privacy policy if you find it useful, but we recommend you see our child-specific privacy policy at [https://trutactics.com/childrens-policy/] to see the key information in a form written for kids.
We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (“UK GDPR”). We are also subject to the EU General Data Protection Regulation (“EU GDPR”) in relation to goods and services we offer to individuals in the European Economic Area (“EEA”).
1. Information We Collect
Some of the key terms used in this policy are as follows:
Personal data: Any information relating to an identified or identifiable individual
Special category personal data: Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership, Genetic data, Biometric data (where used for identification purposes), Data concerning health, sex life or sexual orientation
Data subject: The individual who the personal data relates to
Player: The sportsperson who is receiving the benefit of the services we offer
Minor Player: The sportsperson who is receiving the benefit of the services we offer and who is under the age of 16 in the United Kingdom, or under the applicable age of majority in the territory from which such personal data is being collected.
2. About GDPR
Personal data we collect about you
The personal data we collect about you depends on the particular services we provide to you. We will collect and use the following personal data about you:
If you are a Player to whom we are providing our services:
• your name and contact information, including email address and telephone number;
• the sports club or organisation you belong to;
• your gender, if you choose to give this to us;
• your billing information, transaction and payment card information (if you are the person purchasing our services);
• your sporting career status (e.g. whether you play for an amateur or professional sports team);
• your contact history and purchase history;
• footage taken of you performing your sport at sporting events and/or in training.
If you are a Minor Player to whom we are providing our services:
• your name and contact information, including email address and telephone number;
• the sports club or organisation you belong to;
• your gender, if you choose to give this to us;
• your billing information, transaction and payment card information (if you are the person purchasing our services);
• your sporting career status (e.g. whether you play for an amateur or professional sports team);
• your contact history and purchase history;
• footage taken of you performing your sport at sporting events and/or in training;
• contact details of your parent or legal guardian.
Where a Minor Player provides us with personal data, we assume that all personal data provided by is provided with the consent of the Minor Player’s parent or legal guardian.
If you are an agency, sports organisation or club purchasing our services on behalf of a Player whom you represent:
• the name and contact information of the person(s) within your organisation who is responsible for managing your contract with us and/or our contract with the Player;
• your billing information, transaction and payment information, where you are paying for our services on a Player’s behalf;
How your personal data is collected
We collect most of this personal data from you directly, either in-person, by video call, telephone, text or email and/or via our website at https://www.trutactics.com. However, we may also collect personal data:
• from sports footage provided to us by you or obtained from our third party licensor(s) (where applicable);
• in the case of Players, from the sports club or organisation which you are a member of; and
• in the case of Minor Players, from their parents or legal guardians on the Minor Player’s behalf.
• from a third party with your consent (e.g. your bank when processing payments).
• from cookies on our website.
• via our IT systems, such as our communications systems including video call service providers, and our email systems.
As part of our services, we require footage of Players and Minor Players to be able to analyse their sports performance. This may be provided by you and will inevitably contain personal data about other players and attendees at the sporting event being filmed. If you provide this to us, you are considered to have obtained the consent of the Data Subjects in that footage to provide this footage of them to us. We will not use this for any reason other than for providing our services to the relevant Player or Minor Player.
How and why we use your personal data:
Under data protection laws, we can only use your personal data if we have a proper reason, e.g.:
• where you have given consent;
• to comply with our legal and regulatory obligations;
• for the performance of a contract with you or to take steps at your request before entering into a contract; or
• for our legitimate interests or those of a third party.
A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.
The table below explains what we use your personal data for and why:
Providing our services to you: To perform our contract with you or to take steps at your request before entering into a contract
Preventing and detecting fraud against you or us: For our legitimate interest, i.e. to minimise fraud that could be damaging for you and/or us
Conducting checks to identify our customers and verify their identity
Depending on the circumstances:
• to comply with our legal and regulatory obligations
• for our legitimate interests
To enforce legal rights or defend or undertake legal proceedings
Depending on the circumstances:
• to comply with our legal and regulatory obligations;
• in other cases, for our legitimate interests, i.e. to protect our business, interests and rights
Operational reasons, such as improving efficiency, training and quality control
For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price
Ensuring the confidentiality of commercially sensitive information
Depending on the circumstances:
• for our legitimate interests, i.e. to protect trade secrets and other commercially valuable information;
• to comply with our legal and regulatory obligations
Preventing unauthorised access and modifications to systems
Depending on the circumstances:
• for our legitimate interests, i.e. to prevent and detect criminal activity that could be damaging for you and/or us;
• to comply with our legal and regulatory obligations
Protecting the security of systems and data used to provide the services
To comply with our legal and regulatory obligations
We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, i.e. to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us
Updating and enhancing customer records
Depending on the circumstances:
• to perform our contract with you or to take steps at your request before entering into a contract;
• to comply with our legal and regulatory obligations;
• for our legitimate interests, e.g. making sure that we can keep in touch with our customers about existing orders and new products
Ensuring safe working practices, staff administration and assessments
Depending on the circumstances:
• to comply with our legal and regulatory obligations;
• for our legitimate interests, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you.
Marketing our services to:
• existing and former customers;
• third parties who have previously expressed an interest in our services;
• third parties with whom we have had no previous dealings.: For our legitimate interests, i.e. to promote our business to existing and former customers.
To share your personal data with third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency
In such cases information will be anonymised where possible and only shared where necessary
Depending on the circumstances:
• to comply with our legal and regulatory obligations;
• in other cases, for our legitimate interests, i.e. to protect, realise or grow the value in our business and assets
How and why we use your personal data—Special category personal data
Certain personal data we collect is treated as a special category to which additional protections apply under data protection law. For example, we may collect either directly or indirectly personal data relating to:
• a Player’s health where this is relevant to us providing our services (e.g. a Player tells us they are injured and the nature of their injury)
• a Player’s race or religion, where this is disclosed to us or is made apparent in footage of that Player provided to us.
Where we process special category personal data, we will also ensure that we are permitted to do so under data protection laws. Usually this will be on the basis of you giving your consent for us to do so, but may also include:
• where the processing is necessary to protect your (or someone else’s) vital interest here you are incapable of legally giving consent; or
• the processing is necessary to establish, exercise or defend legal rights or claims.
Marketing
We will use your personal data to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services.
We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.
You do, however, have the right to opt out of receiving marketing communications at any time by:
• contacting us using the details provided below (see ‘How to contact us’); or
• using the ‘unsubscribe’ link in emails.
We may ask you to confirm or update your marketing preferences if you ask us to provide further and services in the future, or if there are changes in the law, regulation, or the structure of our business.
We will always treat your personal data with the utmost respect and never sell it with other organisations for marketing purposes.
Who we share your personal data with
We routinely share personal data with:
• third parties we use to help deliver our services, e.g. external coaches, payment service providers, video call service providers;
• if you are a Player, the sports club or organisation of which you are a member, or the agency who is purchasing our services on your behalf;
• other third parties we use to help us run our business, e.g. marketing agencies or website hosts; and
• our banks.
We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.
We or the third parties mentioned above occasionally also share personal data with:
• our and their external auditors, e.g. in relation to the audit of our or their accounts, in which case the recipient of the information will be bound by confidentiality obligations;
• our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations;
• law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations;
• other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.
Who we share your personal data with – further information
Ordered by: Recipient; Processing operation (use) by recipient; Relevant categories of personal data transferred to recipient
Microsoft Limited, a company registered in England and Wales with company number 01624297 and having its registered office address at Microsoft Campus, Thames Valley Park, Reading, Berkshire, RG6 1WG
Video calling services: We use Microsoft Teams to deliver our online coaching sessions to you and we use Microsoft OneDrive to store footage provided by you
Your name as shown on team, your email address and any personal data which is readily available in the video footage processed through Microsoft Teams,
Data storage: We use Microsoft OneDrive to store footage you provide to us for our use as part of our services
Any of the personal data we collect about you which is readily available in the sports footage provided to us
In-Play Sports Ltd, a company incorporated in England and Wales with company number 10010527 and having its registered office address at Suite 2 & 3, Prime Business Centre Millfield Industrial Estate, Bentley, Doncaster, South Yorkshire, England, DN5 0SJ
Data hosting services: we use the In-Play Sports online platform to store footage of you playing your sport to allow us to take clips of the footage you provide in order to annotate this as part of the services we provide to you.
Any of the personal data we collect about you which is readily available in the sports footage provided to us
WeTransfer B.V., registered at the Dutch Chamber of Commerce under registered number 34380998 and having its main office address at Keizersgracht 281, 1016 ED Amsterdam, the Netherlands
File sharing services: We use WeTransfer’s file sharing service to enable you to send us footage of you playing your sport, and to send you your personal improvement plan and footage of you playing which we have annotated as part of our services
Your email address and name, to enable us to share files with you and enable you to share files with us
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
Where your personal data is held
Personal data may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal data with’).
Some of these third parties may be based outside the UK/EEA. For more information, including on how we safeguard your personal data when this happens, see below: ‘Transferring your personal data out of the UK and EEA’.
How long your personal data is kept
It is sometimes necessary for us to transfer your personal data to countries outside the UK and EEA. In those cases we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal data.
We may transfer your personal data to:
• where you are a Player being represented by an agency or a sports club or organisation outside of the UK, to the relevant body outside of the UK;
• our service providers outside of the UK, such as Microsoft, and our payment processing providers on our website.
We will also transfer your personal data from the EEA to the UK.
Under data protection laws, we can only transfer your personal data to a country outside the UK/EEA where:
• the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR. A list of countries the UK currently has adequacy regulations in relation to is available at https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/international-transfers/international-transfers-a-guide/#adequacy. We rely on adequacy regulations for transfers to the USA;
• in the case of transfers subject to EEA data protection laws, the European Commission has decided that the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy decision’) further to Article 45 of the EU GDPR. A list of countries the European Commission has currently made adequacy decisions in relation to is available at https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en;
• there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or
• a specific exception applies under relevant data protection law.
Where we transfer your personal data outside the UK or EEA, we do so on the basis of an adequacy regulation or (where this is not available) an alternative transfer mechanism, including but not limited to:
• your consent to the transfer;
• it is necessary to establish, exercise or defend legal claims;
• the transfer is necessary for the conclusion or performance of the contract; or
• there are important reasons of public interest.
In the event we cannot or choose not to continue to rely on any of those mechanisms at any time, we will not transfer your personal data outside the UK/EEA unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law and reflected in an update to this policy.
Any changes to the destinations to which we send personal data or in the transfer mechanisms we rely on to transfer personal data internationally will be notified to you in accordance with the section on ‘Changes to this privacy policy’ below.
If you would like further information about data transferred outside the UK/EEA, please contact us using the details below (see ‘How to contact us’ below.)
Your rights
Data subjects have the following rights, which can be exercised free of charge:
Access
The right to be provided with a copy of your personal data
Rectification
The right to require us to correct any mistakes in your personal data
Erasure (also known as the right to be forgotten)
The right to require us to delete your personal data—in certain situations
Restriction of processing
The right to require us to restrict processing of your personal data in certain circumstances, e.g. if you contest the accuracy of the data
Data portability
The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object
The right to object:
—at any time to your personal data being processed for direct marketing (including profiling);
—in certain other situations to our continued processing of your personal data, eg processing carried out for the purpose of our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims
Not to be subject to automated individual decision making
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
The right to withdraw consent
If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time
You may withdraw consent by:
• contacting us using the contact details below (see ‘How to contact us’ below); or
• in relation to marketing consent, using the ‘Unsubscribe’ link in emails form us, or contacting us.
Withdrawing consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being lost accidentally, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures 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.
How to complain
Please contact us if you have any queries or concerns about our use of your personal data (see ‘How to contact us’ below). We hope we will be able to resolve any issues you may have in the first instance.
You may also have the right to lodge a complaint with the Information Commissioner (the UK data protection regulator) and/or the relevant supervisory authority in your jurisdiction. Please contact us if you would like further information.
For a list of EEA data protection supervisory authorities and their contact details see https://www.edpb.europa.eu/about-edpb/about-edpb/members_en.
We may change this privacy notice from time to time — when we do we will endeavour to inform you via our website or other means of contact such as email.
Updating your personal data
We take reasonable steps to ensure your personal data remains accurate and up to date. To help us with this, please let us know if any of the personal data you have provided to us has changed, e.g. your surname or address—see below ‘How to contact us’.
How to contact us
You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection laws or to make a complaint.
Our contact details are:
Post: 272 Bath Street, Glasgow, Scotland, G2 4JR
info@trutactics.com
