Last update: June 2023.

This policy sets out how SquashLevels Limited (registered number 09746300 whose registered office is at Glenavon Park, Bristol, United Kingdom, BS9 1RW) (“SquashLevels”, “we”, “us” or “our”) collects and uses any personal data we collect or receive about you, why we collect and use your personal data, who we might share this information with and your rights in relation to your personal data.

We are committed to protecting and respecting your privacy complying with our obligations under the general data protection regulation (“GDPR”) and all other laws relevant to the handling of your personal data. We are a data controller for the purposes of GDPR (meaning that we are responsible for deciding how your personal data is used).

When we refer to “personal data”, we are referring to any information which can directly or indirectly identify you, as explained more fully below.

The team behind SquashLevels has always taken data privacy very seriously with the following guiding principles:

WHAT PERSONAL DATA WE COLLECT ABOUT YOU OR RECEIVE FROM THIRD PARTIES

• Information that you provide to us – this may include any of the following types of personal data which you provide to us when you sign-up to be a SquashLevels subscriber, enquire about your rankings/ratings or otherwise when you communicate or interact directly with us:
  • Identity Data - first name, last name, gender, images of you, username or other user identifier, date of birth, nationality;
  • Contact Data – your phone numbers, email address and postal address;
  • Financial Data – bank or payment card details and details of any purchases you make through SquashLevels (note we use PayPal and Stripe and do not hold any card details on the SquashLevels servers); and
  • Profile Data – includes your squash performance information including match results to generate ratings and rankings, squash club, leagues and association information, T-shirt size;
  • Marketing and Communication Data – this includes your preferences in receiving marketing from us and our third parties and your communication preferences; and where you may also provide feedback to SquashLevels through surveys or feedback forms.
• Information that we collect about you – when you visit the SquashLevels website we automatically collect the following types of personal data, using usage tracking, cookies or other similar technologies. Please review our Cookies Policy for further information.
  • Technical Data – this might include your IP address, account log-in information, browser information, location information, operating system and system configuration, network and software identification and device information; and
  • Usage Data – this includes information about how you use the SquashLevels website, such as pages visited, click throughs, time spent on page, etc.
• Information that we receive about you from others – we may receive information about you when you use our connected platforms such as World or National Governing Bodies of Squash, operators of League/Tournament Management systems (see further below), or from other relevant third parties, including your squash club, your county or regional squash and racketball associations, and from other public and publicly-available sources (provided in each case that the collection, transfer to, and use by, SquashLevels is lawful). The information which we collect or receive from these third parties may include any or all of the above types of information. If we receive information from third parties we may combine this with information that we currently hold about you and process such combined information for the purposes set out below.

In addition to the above, please note that we may use and share aggregated data (such as demographic data). This may have originally generated from your personal data but is not treated as personal data under GDPR (as it doesn’t individually identify you). On such basis, we can use this data for any purpose. If this aggregated data is ever combined with other data in such a way that you can be personally identified, we will only use that data in accordance with this Privacy Policy.

It is important that the information we hold about you is accurate. Please keep us informed of any changes to your personal information.

Special category data - sometimes we may ask you to provide the following types of personal data, which are seen as more sensitive and are therefore afforded greater protection under GDPR. Prior to collecting and using any such data, we will obtain explicit consent from you (unless we have another legal basis for collecting and using this information) and will only use this data for the following purposes (or such other purposes as are explained to you at the time of collection):

• Injuries and other medical data - this may be collected by us directly from you or via your club or through your county, regional or national association e.g. through a tournament withdrawal form. It will be used to assist with tournament results and rankings information and (anonymously) for statistical and reporting purposes.
• Ethnicity data - this will be used to identify and keep under review equality of opportunity within SquashLevels and (anonymously) for statistical and reporting purposes.
• Disability data - this will be used to identify and keep under review equality of opportunity within SquashLevels and (anonymously) for statistical and reporting purposes.

WHY WE USE YOUR DATA

We have set out in the table below, the purposes for using your personal data and the legal basis for doing so:

Purpose	Types of Data	Lawful basis
To register you as a SquashLevels subscriber	Identity, Contact, Financial, Profile, Marketing and Communication	Performance of a contract with you
For internal administration and record keeping purposes	All	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (for effective business administration and service provision)
To perform any services you have requested (such as providing you with the benefits of SquashLevels subscription or providing you with information you have asked for)	Identity, Contact, Financial, Profile, Marketing and Communication	Performance of a contract with you Necessary for our legitimate interests (for effective business administration and service provision)
To notify you of changes to our Privacy Policy, our Terms and Conditions or other changes to our services or products	Identity, Contact, Profile, Marketing and Communication	Performance of a contract with you Necessary to comply with a legal obligation
To answer your enquiries which may involve contacting you by post, e-mail or phone	Identity, Contact, Profile, Marketing and Communication	Performance of a contract with you Necessary for our legitimate interests (to ensure our subscribers and users are informed and satisfied with our service)
To enable us to process payments which you make to us or our partners	Identity, Contact, Financial	Performance of a contract with you
To allow us to administer squash and racketball results and rankings information	Identity, Contact, Financial, Profile	Necessary for our legitimate interests (for efficiently administering squash rankings and ratings, and for the general development of the sports of squash and racketball) Performance of a contract with you
To provide you with access to certain National Governing Body rankings and ratings data provided to you through the SquashLevels website and accessible through your SquashLevels subscriber portal	Identity, Contact, Profile, Technical, Usage, Marketing and Communication	Necessary for our legitimate interests (to improve awareness and use of SquashLevels and develop our business generally) Performance of a contract with you
To provide you with access to rankings/ratings data at worldwide, national, regional, county, local, club or local age group levels directly or in partnership with national, regional or local associations.	Identity, Contact, Financial, Profile, Usage	Necessary for our legitimate interests (to improve awareness and use of SquashLevels and develop our business generally) Performance of a contract with you
To support the efficient management of squash tournaments and other competitive squash events, including local teams and box leagues for the benefit of individual subscribers and the general development of the sport of squash	Identity, Contact, Financial, Profile	Necessary for our legitimate interests (for efficiently administering squash rankings and ratings, and for the general development of the sports of squash and racketball) Performance of a contract with you
SquashLevels is collaborating with various League Software platforms (see our community). These collaborations will greatly improve the service that SquashLevels delivers to squash and rackets participants and SquashLevels subscribers. Such platforms offer various services and tools to players and clubs, including tournament and league management and rankings information. We may process in conjunction with these platforms, strictly for the purposes of delivering to you the services made available by us and for internal SquashLevels administrative purposes.	All	Necessary for our legitimate interests (namely to facilitate the effective administration of squash and racketball at worldwide, national, county and club level) Performance of a contract with you
To contact you about SquashLevels services, offers and opportunities available solely from us or in conjunction with (our partners). See the “disclosure of your personal information” section below for further details.	Identity, Contact, Profile, Usage, Marketing and Communication	Necessary for our legitimate interests (to develop our business, including our events, products and services and to increase the profile of SquashLevels) Consent
To contact you about third party products and services which we believe may be relevant to you (where you have indicated you would like to hear about these)	Identity, Contact, Profile, Usage, Marketing and Communication	Consent
To improve and personalise your experience of the SquashLevels website by delivering more relevant content and advertising and to ensure that the website is delivered to you in the most effective way possible	Identity, Contact, Profile, Technical, Usage	Necessary for our legitimate interests (to develop our business, improve our website and overall user experience and inform our marketing strategy)
To administer the SquashLevels website, including website trouble shooting, testing and analysis and to enable you to participate in interactive features of our website	Identity, Contact, Profile, Technical, Usage	Necessary for our legitimate interests (to develop our business, improve our website and overall user experience and inform our marketing strategy)
To administer the SquashLevels website, including website trouble shooting, testing and analysis and to enable you to participate in interactive features of our website	All	Necessary for our legitimate interests (to ensure that our website is fully functional and operating in the most effective way for you) Performance of a contract with you
To verify your identity and detect fraud and security issues	Identity, Contact, Profile, Technical, Usage	Necessary for our legitimate interests (to prevent and detect fraudulent activity, security incidents and criminal activity)
To enable you to participate in prize competitions, prize draws or complete a survey	Identity, Contact, Profile, Technical, Usage	Necessary for our legitimate interests (to develop our business, promote new products and services, obtain feedback from customers and users to improve our services)

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 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.

HOW LONG DO WE KEEP YOUR DATA FOR?

We will continue to process data to the extent necessary to maintain the SquashLevels rankings and ratings service, or for as long as you remain a SquashLevels subscriber and/or where you are still happy to hear from us about our latest products and services. Once you no longer wish to be a SquashLevels subscriber or do not elect to receive marketing from us we may still need to process your data if there is a legal reason for doing so (such as for tax purposes, in order to maintain our marketing unsubscribe lists, or where we need to resolve any disputes with you). In such circumstances, we will only retain the minimum amount of data necessary for such reason.

THIRD PARTY WEBSITE LINKS

Please note that the SquashLevels website may include links to third party websites. If you choose to click through to the relevant third party’s website, you will be subject to the terms and conditions of use and privacy policy of the relevant third party. SquashLevels does not accept any responsibility or liability for these policies of your use of such third-party websites. Please check the terms of these policies before using the relevant third party’s website.

THIRD PARTY MONETISATION TECHNOLOGIES (ads)

We use a third-party to provide monetisation technologies for our site. You can review their privacy and cookie policy here.

California Consumer Privacy Act (CCPA)

For California residents wanting to exercise their CCPA opt-out in relation to third-party monetization technologies, please use this link:

Do not share my Personal Information.

Note that this link only works if you are physically in California as determined by your IP address. It may not work correctly if you are using a VPN or other IP masking technology.

INTERNATIONAL TRANSFERS OF YOUR DATA

Please be aware that certain League Management platforms (referred to above) are based outside the UK/EEA and as such, personal data processed through such platforms may be transferred to, and processed on servers located overseas. SquashLevels will ensure that personal data shared by us through such platforms is treated fairly and lawfully in all respects (including putting in place all necessary safeguards for such transfer).

In the future, SquashLevels may need to transfer your personal information to other countries outside of the United Kingdom (“UK”) or European Economic Area ("EEA"). This may happen if any of our servers are from time to time located in a country outside of the UK or EEA or if any of our service providers are located in a country outside of the UK or EEA. Before we proceed with any such transfer, we will ensure that we have a legal ground for doing so and have made sure that all adequate protections are in place. These countries may not have similar data protection laws to the UK or EEA. If we transfer your information outside of the UK or EEA in this way, we will take the appropriate steps to ensure that your privacy rights continue to be protected and that we continue to process your data in a fair and lawful manner.

DISCLOSURE OF YOUR PERSONAL INFORMATION

We may disclose your personal information for the following purposes:

• Where we are working in partnership with National Governing Bodies to deliver services to you, we may share your personal information to enable them to contact you about the services provided and further develop the sport in their country. If this is the case, you will have been notified about such services partnership during the registration sign-up process when acknowledging your awareness of the privacy policy (this document).
• We may disclose your personal information to National Governing Bodies if we are working in partnership with them to allow them to contact you for the purpose of growing the sport in their country. If this is the case, the partnership and data share will be made very clear on the registration page when agreeing to the privacy policy (this document).
• We may disclose your personal information to world, national, regional or county associations, operators of league management systems, clubs, tournament organisers, agents, sub-contractors and consultants (including our consultant who manages referee appointments, marketing agencies, web developers, project consultants and finance agencies) who will process it strictly on our behalf for the purposes set out above.
• We may disclose your personal information to National Governing Bodies for the purpose of administering their National Senior and Masters rankings and providing you with access to the data.
• Details of your performance in events, including images and/or video of you, may be published on our website and shared with certain third parties and be available to view by the general public. This information may include your age category because this allows event organisers to ensure that you are eligible for certain events. In order to provide the SquashLevels service your name, age category, club and county will be publicly available for ranking purposes. If you wish to be masked from public view at any time please follow the process referred to below.
• Where you have explicitly consented to us doing so, we may disclose your personal data to third parties for marketing purposes. You can opt-out of any marketing preferences at any time by following the process referred to below.
• We may also be required to share your personal data with third parties if required by law or regulation. In such circumstances, we will make sure that the disclosure is only to the extent required by law or regulation.

If we share personal data with third parties, we will ensure that access is limited on a strictly need to know basis and is subject to suitable obligations relating to confidentiality and security.

WHERE WE STORE YOUR DATA

Save in circumstances where your data is being processed through certain League Management platform providers (as referred to above), we will store your data on UK servers and will ensure that such data is held securely in accordance with good industry standards. Access to parts of the SquashLevels website are password protected and your password is stored in encrypted form. You are responsible for keeping this password secure and confidential. Please do not share it with anyone else.

Please be aware that the transmission of data via the internet is not completely secure. Although SquashLevels uses its best endeavours to keep your data secure and uses encrypted transmission technologies, we cannot guarantee that information transmitted to us via the internet will be completely secure and any transmission is at your own risk.

CHANGES TO OUR PRIVACY POLICY

If we amend our Privacy Policy, it will be published on the SquashLevels website so please check the website regularly to see if there have been any changes. We may also email you to notify you of any substantial changes to this Privacy Policy.

YOUR RIGHTS

In certain situations, you are entitled to:

• access a copy of your personal data;
• correct your personal data;
• erase your personal data;
• object to the processing of your personal data where we are relying on a legitimate interest (as set out in the above table);
• restrict the processing of your personal data;
• request the transfer of your personal data to a third party; or
• where you have provided your consent to certain of our processing activities, in certain circumstances, you may withdraw your consent at any time (but please note that we may continue to process such personal data if we have legitimate legal grounds for doing so).

If you wish to exercise any of these rights, please contact us using the details set out in the “Contact Us” section below. You will not have to pay a fee to exercise any of these rights, unless your request is clearly unfounded, repetitive or excessive (in which case we can charge a reasonable fee). Alternatively, we may refuse to comply with your request in these circumstances.

In addition to the above, please note that you have the right to make a complaint at any time to the Information Commissioner’s Office if you are concerned about the way in which we are handling your personal data.

How to Unsubscribe / Be masked from public view

You can request that your data be masked from public view using the 'withhold player's name' option in your player details page or by contacting us via this form. We have a legitimate interest to retain your data for the processing of results, the calculation of levels and rankings and the operation of the website, but your data will not be visible to any third party.

You can opt-out of any third-party marketing that you have previously opted into from your membership registration page or by contacting us via this form.

CONTACT US

If at any time you wish to get in touch with us, whether that is to exercise your rights or otherwise, please contact us via this form, or

Email: info@squashlevels.com.