Last updated November 2022

Thank you for choosing to be part of our community at Steel City Interactive Ltd ("Company", "we", "us", "our").  This notice is provided for the current, existing and former visitors to steelcityinteractive.com (“Website”) (“you” and “your”) and applies to all information collected via the Website as well as any related services, sales, marketing or events.  This notice does not form part of any contract for supplies or services.

When you visit our Website, we appreciate that you are trusting us with your personal data.  In this privacy notice, we will explain to you how we process your personal data, including what data we collect, how we use and share it and what rights you have in relation to it.  We are responsible for deciding how we hold and use personal data about you.  We are required under Data Protection Legislation to notify you of the information contained in this notice. 

It is important that you read this notice, together with any other privacy notice we may provide to you, so that you are aware of how and why we are using it. If there are any terms in this privacy notice that you do not agree with, please discontinue visiting the Website immediately.

In this notice, we are going to use some words that are defined by law.  A “Controller” makes decisions about what personal data is used, what it is used for and how it is used. 

A “Processor” processes personal data on the written instructions of a Controller.  “Personal data” is any information that relates to an identifiable individual or which can be used to identity an individual.  Data Protection Legislation means the Data Protection Act 2018 and the UK GDPR.  Any reference to “use” of personal data has the same meaning as “processing” which means anything that is done in relation to personal data including all use of personal data from its creation or collection to its destruction. 

Your Controller

We are a controller in relation to your personal data.  Our address is Lydgate House, Lydgate Lane, Sheffield S10 5FH.  Our nominated Data Protection Representative is Laura Treanor If you have any questions or concerns about this privacy notice, or our practices with regards to your personal data, please contact us at info@steelcityinteractive.co.uk.

1. YOUR PERSONAL DATA

What personal data do we use about you?

In Short: we place cookies when you visit our website so that Google can detect your visit and then provide us with analytics information.  We also collect technical information which is available as an integral part of communications via the internet.

Google Analytics

We place a cookie when you visit our Website.  Google is able to find the cookie when you are using Google services on the same device, and may be able to identify you as a Google device or services user.  Google will use the personal data that is available to it to provide us with analytics reporting. 

Analytics is statistical information.  It tells us things like the age-range of the person who visited our website, but does not identify you.  We do not receive your personal data from Google.  We use analytics to review how effective our website and its different features and content are. 

We only control Google’s ability to be informed about your visit to our website, because we place the Google Analytics cookie.  We do not have control over Google or its use of your personal data, and are not responsible for its privacy notice.  We recommend that you read Google’s privacy notice (located at https://policies.google.com/technologies/partner-sites), as may be updated from time to time:

We expect that Google may collect, store, generate and use your personal data including the categories that we have listed below (more information can be found in Google’s privacy notice).

·  Email Address;

·  Age Group;

·  Location;

·  IP Address;

·  Device Characteristics;

·  Language Preferences;

·  The number of times that you have visited the Website and for how long; and

·  Any links that you may click on from our Website.

Where do we get your personal data?

We get your personal data from the following source:

·   From you: You may choose to provide to us your personal data and make available other information when you use the internet that is available to Google.

What choices do you have about the personal data that we collect?

You do not need to provide to us any personal data in order to use the Website.  If you prefer for us to use less of your personal data, you can choose to make less data available to us.

If you ask us to erase any of your personal data, we may be unable to comply with your previous instructions to us about your personal data.  For example, if we erase records of your instruction not to email you, you may receive an email from us if we then lawfully get your email address from a third party.

2. HOW DO WE USE YOUR DATA?

In Short: We process your personal data to understand when, where and by whom our Website is visited and to ensure functionality of the Website.

For as long as we have your personal data, we will use it for the purposes set out in the table below, unless you exercise your rights under the Data Protection Legislation.

3. WILL YOUR DATA BE SHARED WITH ANYONE?

In Short: For as long as we have access to your personal data, we may share any of it with other suppliers to the extent that they need to have access to your personal data in order to perform their role.

Who do we share your personal data with? 

We may process or share your personal data with the following:

· Other suppliers and service providers appointed by us and who we manage or give instructions to.

· Our staff who are appointed as consultants, agency staff, contractors, volunteers or on any other basis other than as employees.

· Our professional service providers, such as accountants, auditors, legal advisers and insurance brokers.

· External IT providers who provide support to us to manage the computers, multi-function devices, phones, systems or software that we use.

Third parties who use personal data for their own purposes

• Any employee or other member of staff within organisations who are our suppliers or service providers.

• Our regulated service providers, such as banks, auditors, professional advisers and financial services providers, who are required to carry out compliance monitoring and reporting.

• Our insurers for the purposes of us taking out or renewing insurance, notifying the insurers, and dealing with actual or potential claims.

• Courts, central Government departments, law enforcement authorities including HM Revenue and Customs, the Police, public bodies and authorities.

• Third party individuals, companies or groups that wish to evaluate or complete and effect the purchase or sale of, or merger with, us or our business or assets.

We may disclose your personal data to other third parties if we have lawful grounds to do so, or are under a legal obligation to disclose or share it with them, or in order to establish, exercise or defend our legal rights or to protect the rights or safety of our staff.  For example, we will disclose your personal data, if necessary, to your suppliers or service providers, contractors or sub-contractors, as well as to those appointed by us.

4. WHERE DO WE USE YOUR PERSONAL DATA?

We hold your personal data that we acquire via our website in the United Kingdom.  In some cases, however, we may transfer your personal data (particularly in electronic format) to a location that is outside the United Kingdom, and even outside the European Economic Area (“EEA”).

Google is a global company and if you consent to our website’s use of the Google Analytics cookies, Google is likely to transfer your personal data outside the UK and even outside the European Economic Area, to any country in the world where Google has data processing facilities.  Some of those countries may not protect your personal data as well as the UK, and some may not protect it at all.  Please review Google’s privacy documentation using the link above.  If you would like more information, such as information about the safeguards that Google has put in place to protect your personal data and your rights in the locations where Google uses your personal data, or if you would like a copy of the safeguards, please follow the instructions in Google’s privacy notice to ask Google for a copy of its safeguards.

5. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this privacy notice unless otherwise required by law.

As we set out above, the only personal data that we process is processed by Google on our behalf.  If we process your personal data, we will only keep your personal data for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).  Please refer to Google’s privacy notice using the above link to find out how long Google will keep your personal data.

In determining the appropriate period for the retention of your personal data, we consider the amount, nature and sensitivity of that data, the purposes for which we process your personal data and whether we can achieve these purposes by other means, as well as the applicable legal requirements.

When we have no ongoing legitimate business need to process your personal data, we will either delete or anonymize such data, or, if this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible.

6. WHAT ARE YOUR RIGHTS?

In Short: In some regions, such as the United Kingdom and European Economic Area, you have rights that allow you greater access to and control over your personal data. You may review, change, or terminate your account at any time.

What rights do you have?

In certain circumstances and by law, you have the right to:

· Withhold or withdraw consent: Where we have asked for consent, you may withdraw it at any time.

· Request access: to your personal data that we hold about you. This is commonly referred to as a “subject access request”.  This enables you to receive a copy of the personal data we hold about you and to check we are lawfully processing it.

· Request Correction: of your personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected.

· Request Erasure: of your personal data.  This enables you to ask us to delete or remove personal data where: (i) there is no good reason for us continuing to process it; (ii) you have withdrawn your consent, if any, to our processing; (iii) you have exercised your right to object to processing (see below) and no exception permits us to keep using it; (iv) it is established that we did not have the lawful right to process your personal data; or (v) the law requires us to erase your personal data.

· Object to processing: of your personal data where we are relying on a legitimate interest (or those of a third party) and where there is something about your particular situation which makes you want to object to the processing on this ground and there is no exception which applies to permit us to keep using it. 

· Request the restriction of processing of your personal data:  This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for our processing it or you consider we no longer need to use your personal data for the purposes for which it was collected or used (but you need it to be preserved for the purposes of legal claims).  You may also ask us to restrict processing if you have exercised your right to object to our use of your personal data and no exception applies to permit us to keep using it.

· 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 matters.

If you want to review, verify, correct, or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal data to another party, please contact us using the contact details set out at the beginning of this notice.

No fee is usually required

You will not 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 for access is clearly unfounded or excessive.  Alternatively, we may refuse to comply with your request in such cases.

What we may need from you

We may need specific information from you to help us to confirm your identity and ensure your right to access the information (or to exercise any other right).  This is another appropriate security measure to ensure that the personal data is not disclosed to someone who is not entitled to receive it.

7. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

8. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

 If you have questions or comments about this notice, you may email us at info@steelcityinteractive.co.uk or by post to:

Steel City Interactive Ltd.