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 information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

This privacy policy relates to your use of our website, www.obohockey.co.uk. Throughout our website we may link to other websites owned and operated by certain trusted third parties. These other third party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other third party websites, please consult their privacy policies as appropriate.

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).

Key terms

It would be helpful to start by explaining some key terms used in this policy:

We, us, our	Baseline Sports International Limited
Personal information	Any information relating to an identified or identifiable individual
Special category personal information	Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership Genetic and biometric data Data concerning health, sex life or sexual orientation

Personal information we collect about you

We may collect and use the following personal information about you:

• your title, name and contact information, including email address and telephone number;
• browser information and online identifiers (such as your browser types, browser version host operating system, browser language and your IP address);
• information about your visit to our website (such as full Uniform Resource Locators (URL) clickstream to, through and from our website, whether your visit was directly from a marketing email we have sent, products viewed or searched for, page response times, download errors, lengths of visits to certain pages, page interaction information (such as scrolling, clicks and mouse overs) and methods used to browse away from the page);
• information from third parties such as digital marketing networks and social media networks such as Facebook, Instagram, Pinterest and Google to help manage your account, improve your shopping experience and get relevant marketing message across to you;
• aggregated information (such aggregate traffic information collected from your visit to our website);
• your purchasing history including saved items and payment information (encrypted), such as payment methods, billing address details and other information related to payment;
• your personal interests. We store preferences for mailing/email advertising;
• information to enable us to undertake address verification checks you;
• your responses to our surveys, polls, focus groups, interviews, ethnography studies, user testing, competitions and promotions;
• details of any agreement or objection to receiving marketing information from us; and
• details of any contact with our customer services teams such as a record of your correspondence with us or any calls that you make to us.

This personal information is required to provide products to you and for us to complete the transactions for you. If you do not provide personal information we ask for, it may delay or prevent us from providing products to you.

How your personal information is collected

We collect most of this personal information directly from you—in person, by telephone, text or email, post, social media, and/or via our website. However, we may also collect information:

• about you from third parties where we carry out identity verification credit checks against your name using third party databases;
• about you from third parties for marketing where you have provided your express consent to the third party for your information to be shared for such purpose;
• we may work with third party information providers such who specialise in consumer profiling and provide demographic or other data to help better understand you, your purchasing behaviour and preferences;
• about you from online advertising and marketing companies to help us display the advertising content most relevant to you and to analyse our campaigns;
• we may collect information about you from third parties who we have partnered with to run competitions;
• we may collect information about you from cookies on our website - for more information on our use of cookies, please see our cookies policy in this link.

How and why we use your personal information

Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:

• to comply with our legal and regulatory obligations;
• for the performance of our contract with you or to take steps at your request before entering into a contract;
• for our legitimate interests or those of a third party; or
• where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal information for and our reasons for doing so:

What we use your personal information for	Our reasons
To provide products to you	For the performance of our contract with you or to take steps at your request before entering into a contract
To prevent and detect fraud against you or us	For our legitimate interests or those of a third party, i.e. to minimize fraud that could be damaging for us and for you
Conducting checks to identify our customers and verify their identity Screening for financial and other sanctions or embargoes Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under health and safety regulation or rules issued by our professional regulator)-	To comply with our legal and regulatory obligations
Gathering and providing information required by for relating to audits, enquiries or investigations by regulatory bodies	To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g. policies covering security and internet use	For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training and quality control	For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information	For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations
Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measure	For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
Preventing unauthorized access and modifications to systems	For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you To comply with our legal and regulatory obligations
Updating and enhancing customer records	For the performance of 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 or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products
Statutory returns	To comply with our legal and regulatory obligations
Ensuring safe working practices staff administration and assessments	To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, 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 and those of selected third parties 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 or those of a third party, i.e. to promote our business to existing and former customers. We will use email addresses to market to existing customers who are not opening our emails to find them on Facebook and show appropriate adverts.
Profiling and building our social demographic profile - external of our customer base	To profile our existing customer base to ensure the marketing is going to the highest propensity to response. For our legitimate interests or those of a third party, i.e. to ensure our prospecting marketing reaches our intended audience
Credit reference checks via external credit reference agencies	For our legitimate interests or those of a third party, to confirm the authenticity and validity of your mailing address.
External audits and quality checks, e.g. for ISO or Investors in People accreditation and the audit of our accounts	For our legitimate interests or a those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards. To comply with our legal and regulatory obligations

The above table does not apply to special category personal information, which we will only process with your explicit consent.

Promotional communications

We may use your personal information to send you updates (by email, social media, Boldchat, text message, telephone or post) about our products including exclusive offers, promotions or new products.

We have a legitimate interest in processing your personal information for promotional purposes (see above 'How and why we use your personal information'). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal information with the utmost respect You have the right to opt out of receiving promotional communications at any time by:

• contacting us at info@baselinehockey.com;
• using the 'unsubscribe' link in emails;
• self-removal from the applicable Social Media group;
• using the function on electronic adverts to remove them.

We may ask you to confirm or update your marketing preferences if you instruct us to provide further products in the future, or if there are changes in the law, regulation, or the structure of our business.

Who we share your personal information with

We routinely share personal information with:

• third parties we use to help deliver our products to you, e.g. payment service providers, warehouses and delivery companies such as Shopify;
• other third parties we use to help us run our business, e.g. marketing agencies, profiling agencies, website hosts; email and social media platforms and applications; print marketing and postal suppliers; repair and alteration providers;
• third parties approved by you, e.g. social media sites you choose to link your account to or third party payment providers.

We only allow our service providers to handle your personal information if we are satisfied, they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g. in relation to ISO accreditation and the audit of our accounts.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all our business or during a re-structuring. Usually, information will be anonymised, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

Where your personal information is held

Information may be held at our offices, third party agencies, service providers, representatives and agents as described above (see above: 'Who we share your personal information with').

Some of these third parties may be based outside the United Kingdom and the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: 'Transferring your personal information out of the UK or the EEA'.

How long your personal information will be kept

We will keep your personal information while you have an account with us, or we are providing products to you. Thereafter, we will keep your personal information for as long as is necessary:

• to respond to any questions, complaints or claims made by you or on your behalf;
• to show that we treated you fairly;
• to keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy.

When it is no longer necessary to retain your personal information, we will delete or anonymise it

Transferring your personal information out of the UK or the EEA

To deliver services to you, it is sometimes necessary for us to share your personal information outside the United Kingdom or the European Economic Area (EEA), e.g.:

• with your service providers if you or they are based outside the UK or the EEA.
• with our service providers located outside the UK or the EEA

These transfers are subject to special rules under UK data protection law.

Whenever we transfer your personal data out of the UK or the EEA, 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 by the UK government.
• There are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects; or
• A specific exception applies under data protection law

These are explained below.

Adequacy decision

We may transfer your personal data to certain countries, on the basis of an adequacy decision. These include:

• all European Union countries, plus Iceland, Liechtenstein and Norway (collectively known as the 'EEA');
• Gibraltar; and
• Andorra, Argentina, Canada, Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Switzerland and Uruguay.

The list of countries that benefit from adequacy decisions will change from time to time. We will always seek to rely on an adequacy decision, where one exists.

Other countries or international organisations we are likely to transfer personal data to do not have the benefit of an adequacy decision. This does not necessarily mean they provide poor protection for personal data, but we must look at alternative grounds for transferring the personal data, such as ensuring appropriate safeguards are in place or relying on an exception, as explained below.

Transfers with appropriate safeguards

Where there is no adequacy decision, we may transfer your personal data to another country or international organisation if we are satisfied the transfer complies with data protection law, appropriate safeguards are in place, and enforceable rights and effective legal remedies are available for data subjects.

The safeguards will usually include using legally-approved standard data protection contract clauses.

To obtain a copy of the standard data protection contract clauses and further information about relevant safeguards, please contact us (see 'How to contact us' below).

Transfers under an exception

In the absence of an adequacy decision or appropriate safeguards, we may transfer personal data to a third country or international organisation where an exception applies under relevant data protection law, e.g.:

• you have explicitly consented to the proposed transfer after having been informed of the possible risks;
• the transfer is necessary for the performance of a contract between us or to take pre-contract measures at your request;
• the transfer is necessary for a contract in your interests, between us and another person; or
• the transfer is necessary to establish, exercise or defend legal claims.

We may also transfer information for the purpose of our compelling legitimate interests, so long as those interests are not overridden by your interests, rights and freedoms. Specific conditions apply to such transfers and we will provide relevant information if and when we seek to transfer your personal data on this ground.

Further information

If you would like further information about data transferred outside the UK/EEA, please contact us (see ‘How to contact us’ below).

Your rights

You have the following rights, which you can exercise free of charge:

Access	The right to be provided with a copy of your personal information (the right of access)
Rectification	The right to require us to correct any mistakes in your personal information
To be forgotten	The right to require us to delete your personal information—in certain situations
Restriction of processing	The right to require us to restrict processing of your personal information in certain circumstances, e.g. if you contest the accuracy of the data
Data portability	The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to third a party—in certain situations
To object	The right to object: —     at any time to your personal information being processed for direct marketing (including profiling); —     in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.
Not to be subject to decision making automated individual	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

For further information on each of those rights, including the circumstances in which they apply, please contact us or review the guidance provided by the UK Information Commissioner's Office (ICO) on individuals' rights under the UK General Data Protection Regulation.

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

• email, call or write to us see below: 'How to contact us'; and
• let us have enough information to identify you (e.g. your full name, address and customer reference number);
• 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 what right you want to exercise and the information to which your request relates.

Keeping your personal information secure

We have appropriate security measures to prevent personal information from being accidentally lost or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access 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.

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.orq Get Safe Online is supported by HM Government and leading businesses.

How to complain

Please contact us if you have any query or concern about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with the Information Commissioner. The Information Commissioner may be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113.

Changes to this privacy policy

This privacy notice was published on 09/03/2021 and last updated on 09/03/2021.

We may change this privacy notice from time to time—when we do, we will inform you via our website or other means of contact such as email.

How to contact us

Please contact us by post, email or telephone if you have any questions about this privacy policy or the information, we hold about you.

Our contact details are shown below:

Baseline Sports International Limited Spindle Mill Spindle Street Congleton CW12 1QN   info@baselinehockey.com 01260 277999