Privacy NoticeLast modified 25th May 2018
Tifosy Limited (“Tifosy”) is committed to safeguarding the privacy of its users’ personal data. Tifosy is the controller and responsible for your personal data. Throughout this privacy notice Tifosy will be referred to as “we” or “us”.
This privacy notice aims to give you information on how Tifosy collects and processes your personal data through your use of the Tifosy website, including any data you may provide through the website when you sign up, enter into a transaction or contact Tifosy by email, phone, post, live chat or otherwise. This privacy notice also tells you about your rights and how the law protects you.
It is important that you read this privacy notice in full. By using the services offered by Tifosy you are acknowledging that you have read, understood and agreed to its contents.
PERSONAL DATA WE COLLECT FROM YOU
Personal data, or personal information, means any information about an individual from which that person can be identified (“Personal Data”). It does not include data where the identity has been removed (anonymous or pseudonymised data).
We may collect, use, store and process different kinds of Personal Data about you which we have grouped together as follows:
- “Identity Data” which includes first name, last name, username or similar identifier, title, date of birth and gender.
- “Contact Data” which includes postal address, email address and telephone numbers.
- “Financial Data” which includes bank account details, tax information and credit or debit card details (which we collect for immediate processing via our payment partners but do not store).
- “Transaction Data” which includes details about investments made by you through Tifosy and details of any other services provided to you by Tifosy.
- “Technical Data” which 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 the Tifosy website.
- “Profile Data” which includes your username and password, investments made by you, feedback and survey responses.
- “Usage Data” which includes information about how you use our website, products and services.
- “Marketing and Communications Data” which includes your preferences in receiving marketing from us and your communication preferences.
- “Third Party Data” which includes information from third parties or publicly available sources.
We also collect, use and share aggregated data such as statistical or demographic data for any purpose (“Aggregated Data”). 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 notice.
We do not collect any special categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect Personal Data by law and you fail to provide that data when requested, we may not be able to allow you to complete the contract you are trying to enter into (for example, to invest in a professional sports club through the Tifosy website). In this case, we may have to cancel a product or service you have applied for but we will notify you if this is the case at the time.
HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by email, phone, post, live chat or otherwise. This includes Personal Data you provide when you:
- create an account on our website;
- request marketing to be sent to you;
- apply for our products or services through our website;
- certify as a prospective investor;
- make an investment on Tifosy;
- enter a competition, promotion or survey; and/or
- 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 and other similar technologies.
- Third parties or publicly available sources. We may receive Personal Data about you from various third parties and public sources.
HOW WE USE YOUR PERSONAL DATA
Tifosy 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 comply with a legal or regulatory obligation such as:
- to verify your identity in order to create your account and ensure that you are eligible to use the services provided on the Tifosy website;
- to conduct required anti-money laundering checks on you and associated financial crime and fraud monitoring in connection with transactions you may conduct through the Tifosy website;
- in the case of investors, to confirm that you are eligible to make investments through the Tifosy website in accordance with relevant legislation; and
- to enable us to comply with our obligations as a regulated financial services business, including transaction recording, updates on your investment and fundraising activity on the Tifosy website, other compliance responsibilities, and reporting to regulators and governmental authorities.
- Where we need to perform the contract we have with you or others including:
- to process and administer payments and investments in connection with the services provided on the Tifosy website;
- in the case of investors, to facilitate any investments you may make, and to provide fundraising sports clubs with information about the progress of their raise and your investments in their businesses;
- in the case of investors who have completed an investment, to provide those sports clubs with your details for them to fulfil obligations to you, and ensure compliance with their corporate or regulatory requirements, such as tax and company reporting;
- to provide you with information about your account, including any investments or payments you have made or have indicated an interest in making; and
- to inform you of important or legal changes that may impact you or a contract you have entered into with or via Tifosy.
- Where we have a legitimate interest and your interests and fundamental rights do not override those interests. This includes ensuring that the Tifosy website and our services operate effectively so that we can:
- present you with the best and most suitable website experience;
- administer our site and services;
- analyse site usage and improve our online experience, products and services; and
- keep your account secure and protect our website and services.
In certain other circumstances we may seek your consent to use your Personal Data. In this case we will ask you to confirm your agreement to your Personal Data being processed for a specific purpose, either through the Tifosy website or by another means. If you are in any doubt, please contact us about the specific legal ground we are relying on to process your Personal Data.
Tifosy will only ever share your Personal Data in ways that are set out in this privacy notice. Tifosy will never sell your Personal Data. Tifosy will only direct trusted third parties to process your Personal Data in order to administer, provide, improve or promote our services (as outlined above). Tifosy may also share anonymised information in a way that does not directly identify you.
Tifosy’s website may from time to time include links to and from websites of our partners, suppliers or other third parties. If you follow a link to any such website, please be aware that these websites will have their own privacy policies and Tifosy will not accept any responsibility or liability for those policies or operation of said websites. You should read and agree to the privacy notice and terms of any website before disclosing any Personal Data.
DISCLOSURE OF YOUR PERSONAL DATA
Personal Data that we collect will not be disclosed to any third parties except as set out below. In circumstances where we have to share your Personal Data, we will take reasonable precautions to ensure that the third parties keep your Personal Data secure and confidential, in compliance with relevant legal requirements.
- Tifosy may disclose your Personal Data to the relevant contract party if you complete a transaction on the Tifosy website (for example, you make an investment in a professional sports club);
- Tifosy may disclose certain Personal Data to third party service providers solely in the course of their provision of services to Tifosy;
- Tifosy may disclose your Personal Data in order to comply with any legal or regulatory bligation (including, but not limited to, disclosure to the Financial Conduct Authority or HM Revenue & Customs) or in order to enforce this privacy notice, the Tifosy website terms or to detect, prevent, or otherwise address fraud, security or technical issues;
- Tifosy may disclose your Personal Data as part of a major corporate transaction such as a sale of the Tifosy business; and
- Tifosy may disclose your Personal Data to a member of its group, which means its subsidiaries, ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
Tifosy’s website includes certain social media functions for Facebook, Twitter, Instagram, LinkedIn and YouTube. These features may collect certain information, including your IP address or which page you are visiting and may set a cookie (or other technology) to enable this function to work accordingly. Any such feature will be hosted by a third party or directly on our website, and any interaction with these will be governed by the privacy notice of the company providing it.
Certain social media services may also allow you to post information about your activities on www.tifosy.com to your respective social media account/profile. Tifosy will never post anything to any of your social media accounts/profiles.
Our website enables users to create/register a Tifosy profile via their Facebook, Twitter or Google accounts. If you have chosen this method of registration, the functionality will enable the authentication of your identity and allow you to share certain Personal Data with Tifosy in order to complete your registration.
As Tifosy’s main base is within the EU, you are entitled to certain rights regarding your Personal Data including the right to:
- request access to your Personal Data;
- request correction of the Personal Data that we hold about you;
- request erasure of your Personal Data;
- object to the processing of your Personal Data;
- request restriction of the processing of your Personal Data;
- request the transfer of your Personal Data to you or a third party; and
- withdraw your consent at any time where we are relying on consent to process your Personal Data.
To correct or change any Personal Data held by Tifosy, or amend your marketing permissions, simply login to your account at www.tifosy.com. To exercise any other individual rights, as outlined above, please contact the Data Protection Officer via firstname.lastname@example.org or +44 (0) 207 349 0622. We try to respond to all legitimate requests within one month. As a security measure 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). 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.
Please note that, despite a request on your behalf, in certain circumstances there may be legal, regulatory or legitimate business reasons for Tifosy to continue to retain or process your Personal Data. Should this be the case in response to a request, we will notify you of this and explain the lawful basis for us to do so.
If you are dissatisfied with our response, 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 contact us in the first instance.
HOW LONG WE WILL RETAIN YOUR PERSONAL DATA
Tifosy will only retain your Personal Data and information for the duration of your active account or for as long as is necessary to fulfil the purposes for which it was collected.
In some circumstances, we will retain and use your Personal Data and information to satisfy our legal and regulatory requirements, enforce agreements or protect Tifosy’s legal rights. Personal Data may be stored for a period of six years (or longer if necessary) to comply with any of these obligations.
Tifosy may also collect and retain aggregated, anonymised or pseudonymised information indefinitely, in order to protect the safety and security of our website, improve our services or comply with any mandatory obligations. Aggregated, anonymised or pseudonymised information will not directly identify you.
The security of your Personal Data is highly important to us. All information and Personal Data provided to Tifosy is stored securely. Tifosy follows industry-standard best practices to ensure any information we capture and hold is done so securely and encrypted or protected by ‘data protection by design’ wherever possible. No method of electronic transmission or storage is 100% secure, so neither Tifosy nor any other website may guarantee its absolute security. Your account information is protected by password, so you should choose this carefully and we would ask you not to share this with anyone. Tifosy will never ask for your password, should you receive a request to do so, please notify us at or forward to email@example.com.
CHANGES TO OUR PRIVACY NOTICE
From time to time, Tifosy may update this privacy notice to reflect changes to the law or Personal Data practices. Our current privacy notice will always be available via our website and should we make material changes to this privacy notice, we will notify you via email or by means of notice via our website. Should a conflict arise between two privacy notices you have agreed to, the most recent of the two will be seen to take precedence.
Questions, comments and requests regarding this privacy notice may be directed to the Data Protection Officer at:
+44 (0) 20 7349 0622