COPA90 PRIVACY NOTICE

COPA90 respects the privacy of every person who interacts with COPA90 and we are committed to ensuring high standards of data protection compliance in everything we do.

  1. What is the purpose of this Notice?
    1. This privacy notice applies to all services and activities we provide across the web, social media, apps and elsewhere (the “COPA90 Services”). It explains our approach to how we use any personal information that is provided to or collected by us in connection with your use of the COPA90 Services or any other interaction you have with COPA90.
    2. This privacy notice also sets out the legal basis on which we are permitted to process your personal information, your rights in respect of our use of your personal information, how you can verify what personal information is collected by us, and how you can request that we delete, update or transfer it.
    3. This privacy notice is intended to assist you in making informed decisions when using the COPA90 Services. Please read it thoroughly and note that it should be read in conjunction with our Terms and Conditions.
  2. Who are we?
    1. The COPA90 Services are operated by COPA90 Limited (“COPA90”, “we” “us” or “our”).
    2. COPA90 Limited is the data controller responsible for your personal information. COPA90 Limited is registered at the UK Information Commissioner’s Office with registration number: ZA114883
    3. COPA90 Limited is an English company with registered company number: 09125906 and whose registered address is 6th Floor One London Wall London EC2Y 5EB.
  3. How to contact us?
    1. If you have any questions about this privacy notice or want to exercise your rights, please contact us by:
    • sending an email to info@copa90.com; or
    • writing to us at COPA90 Exmouth House, 3-11 Pine St, Clerkenwell, London, EC1R 0JH, UK.
  4. What personal information do we collect about users and viewers of copa90 and how do we collect it?
    1. Personal information may be collected from you in the following ways (see in the follow section for information on how and why we use the information):
    • Information you voluntarily provide to us directly.
       
    We collect and maintain personal information that you voluntarily submit to us during your use of the COPA90 Services or other contact with us. For example when you register, sign up for a newsletter, enter a survey or competition, submit content contributions, post comments or buy merchandise through our sites. This may include:
    • Name;
    • Email Address;
    • Address;
    • City or Country;
    • Date of Birth;
    • Gender;
    • favourite teams etc;
       
    And may include information in the content you submit:
    • Your image or likeness (or that of others who also appear) in the content you submit;
    • Other information about yourself (or that of others who also appear) in the content you submit;
    • Other information about yourself (or that of others who are also mentioned) in the messages you send to us.
       
    Information you voluntarily provide to us through social media log in.We collect and maintain personal information from you social media profile that you voluntarily agree to be provided to us when you register or sign up, or take part in a survey etc using our social media (such as Facebook) login functionality.This may include:
    • Name;
    • Date of Birth;
    • Gender;
    • Social media ID;
       
    Information we collect through your use of the COPA90 Service.We collect, through our use of cookies or other technologies, information about your use of and navigation around the COPA90 Services including the emails we send you, including information regarding your mobile device or the computer hardware and software used to access the COPA90 Services. This may include the following:
    • IP address of device(s) used;
    • browser type;
    • operating system and device type;
    • approximate location (e.g. London);
    • access times and dates;
    • referring website addresses;
    • navigation around the site;
    • links followed, including in emails;
    • time spent on pages or viewing content;
    • types of content viewed and shared.
       
    Please see the Data Analytics, Insight and Profiles section below and our Cookie Section below for further information.

    Information we receive from third party data sources and brand partners.

    We may also combine information that we hold about you with information that we obtain from third parties including brand partners and data aggregators. This information may be used to indicate your likely interests so we can provide a more relevant service to you. We will always ensure that the provider of the information has relevant permission and legal basis to share such information with COPA90. Please see the Data Analytics, Insight and Profiles section below for further information.

    Information we receive from third party service provider partners.

    We may use third parties to provide additional services such as ecommerce, ticketing or other retail or merchandise functionality. Normally you will be interacting and contracting directly with such third parties in this situation. We will enable you to link to their services and any personal information or data will be supplied by you directly to them. As part of this subcontracted solution we will receive information back from our partners relating to your purchases. This will include your name and email address and other information such as the category of item purchased or club, brand or event to which it relates. This information will be by used by us to indicate your likely interests so we can provide a more relevant service to you. Please see the Data Analytics, Insight and Profiles section below for further information.
     
  5. How do we use the personal information of users and viewers of copa90?
    1. We use the personal information we collect from or about you for the following purposes:
    Provision of the COPA90 Service
    We need to use your information to log you in, verify who you are, ensure you get the service that you have registered for and otherwise to provide you with our services.

    What is our legal basis for this?
    It is necessary for the performance and fulfilment of the contract between us to provide you with services for which you have registered.

    Sending you newsletters or other communications (from COPA90) for which you have subscribed
    Where you have given your consent we use your personal information to send you newsletters and other marketing materials about COPA90 products and services which we think you might be of interest to you.

    What is our legal basis for this?
    We rely on your consent to be able to do this – given at the time that you request the newsletter or other marketing.

    Running surveys, competitions and/or promotions.
    We may collect and use your personal information in connection with any survey, competition and/or promotion that you enter.

    What is our legal basis for this?
    It is in our legitimate interest to use your personal information in such a way to operate the survey, promotion and/or competition. Please note that we will only send you marketing communications promoting a competition or survey with your consent.

    Data Analytics, Insight and Profiles.
    We analyse your personal information including that which we observe about you from your interactions with our COPA90 Service, our email communications to you and/or the products and services you may have purchased or viewed, including any third party information we have sourced as detailed above. This information is used to create profiles and insights about viewing and usage habits across our services. By using this information, we are able to measure the effectiveness of our content and how visitors use COPA90 Services. This allows us to learn for example what content and pages are most attractive to our users, which parts of our services are the most interesting and what kind of information our users like to see. We also use this information to help us with the selection and creation of future content and services. We also use this information to help us with the selection and presentation of relevant advertising messages to you. We also use this information for social media marketing purposes (see the sections below for further details).

    What is our legal basis for this?
    Where your personal information is completely anonymised, we do not require a legal basis to use it as the information will not constitute “personal information” that is regulated under data protection laws. However, our collection and use of such anonymised personal information may still be subject to other laws where your consent is required. Please see our Cookie Section below for further details. Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best content and services to you and our other users.

    Social media remarketing.
    We use information that we observe about you from your interactions with COPA90 Services, our email communications to you and/or with our content and services (see the Data Analytics, Insight and Profiles section above for more details of the information collected and how it is collected) to provide you with personalised content or advertising on social media channels operated by Facebook and/or Google where you are a registered user of such services. We do this using Facebook Custom Audiences and/or Google Customer Match respectively. Please note that such activity is also subject to the privacy choices you have elected to make on such services.To do this we share your encrypted email address with Facebook and/or Google under the terms of their Facebook Custom Audiences and/or Google Customer Match services respectively. We do not permit them to use your information for any other purposes.

    What is our legal basis for this?
    Where your personal information is completely anonymised, we do not require a legal basis to use it as the information will no longer constitute “personal information” that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Section below for further details.Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for these marketing purposes.

    Social media insight.
    Where you are a registered user of Facebook, or of a Google service, we will use your email address in an encrypted format to enable Facebook and Google to find other registered users of their services (to whom to serve adverts) that share similar interests to you based on:
    • information that we observe about you from your interactions with our services, our email communications to you and/or with our content and services see the Data Analytics, Insight and Profiles section above for more details of the information collected and how it is collected); and
    • the information Facebook and/or Google hold about you.
       
    We do this using Facebook Custom Audiences and/or Google Customer Match respectively. Please note that such activity is subject to the privacy choices you have elected to make on such services. Please note that Facebook and Google do not use your information for anything other than suggesting to us similar types of users on their services to whom to serve adverts; and we do not use your information to make any decision about you.

    What is our legal basis for this?
    Where your personal information is completely anonymised, we do not require a legal basis to use it as the information will no longer constitute “personal information” that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Section below for further details. Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for these lead generation purposes

    Publishing content you provide.
    If you provide us with any content (e.g. photos or videos) that you wish to feature on our services, we will collect certain personal information from you when you provide the content and will use it in connection with sharing the content you have provided. The content may also contain your personal information, or that of others who also appear or are mentioned, in the form of images or other information that may identify you or them.What is our legal basis for doing this?It is necessary for the performance and fulfilment of the contract between us to provide you with services for which you have registered.When you submit your content for these purposes we will also take that as consent to use your content and the personal information in this way and confirmation that you have the consent of any others appearing in the content. It is also in our legitimate interest to use your personal information in such a way to operate the service. 

    Service Administration.
    We may also use your personal information to:
    • help improve the COPA90 Services; and
    • contact you to answer any queries you may have sent to us.

    What is our legal basis for doing this?
    It is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best service we can to you.

    Sharing information with third party processors.
    We may share your personal information with third party processors in order to provide the COPA90 Services and associated products and services to you. This includes companies that for example that host our servers or manage or databases for us. They have no independent rights to use your data and are strictly controlled by us under contract.

    What is our legal basis for doing this?
    It is in our legitimate interests to share your personal information in such a way to ensure that we provide the very best service we can to you.

    Sharing information with third brands
    We may share your personal information with third party brands on an anonymised basis. e.g. details on the type of audience that engaged with our campaigns. We will not share an information that is not anonymised, nor allow them to market to you without your consent.

    What is our legal basis for doing this?
    It is in our legitimate interests to share your personal information in such a way to ensure that we provide the very best service we can to you.

    Business administration, record keeping and legal compliance.
    We use your personal information for the following business administration and legal compliance purposes:
    • to comply with our legal obligations;
    • to enforce our legal rights;
    • protect rights of third parties; and
    • in connection with a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets.
    Use in this way may involve us sharing your personal information with professional advisers such as lawyers and accountants and/or governmental or regulatory authorities.

    What is our legal basis for doing this?
    It is in our legitimate interest to ensure that we keep our records up-to-date and use them in connection with a business transition, enforce our legal rights, or to protect the rights of third parties. Otherwise, it is our legal obligation to use your personal information to comply with any legal obligations imposed upon us or other laws regulations that we are subject to.
     
  6. What personal information do we collect about other people, how do we collect it, and how do we use it?

    Creator Network
    We collect and maintain personal information about potential and current members of our Creator Network.Initially we source this information from research of social media and following your activity and posts. We may keep a record of your name, social media handle and a description of your activity and posts. We do this to assess if we might be interested in contacting you to join our network.If you join our network we collect and maintain any other information that you give us and details about the activity we may work on together.It is in our legitimate interest to collect and process your information in this way to improve our service and grow our network, once in our network, it is necessary for the performance and fulfilment of the contract between us.

    Distribution Network
    We collect and maintain personal information about potential and current distributors of our content.Initially we source this information from research of social media and following your activity and posts.We may keep a record of your name, social media handle and a description of your activity and posts. We do this to assess if we might be interested in contacting you to distribute our content.We further collect and maintain any other information that you give us for the purposes of distributing our content, and details about the activity we may work on together.It is in our legitimate interest to collect and process your information in this way to improve our service and grow our distribution activity, once in our team, it is necessary for the performance and fulfilment of the contract between us.
     
  7. How do we obtain your consent?
    1. Where use of your personal information by us requires your consent, you may provide such consent:
    • at the time we collect your personal information by following the instructions we give; or
    • by informing us using the contact details set out in this privacy notice.
       
  8. Use of cookies
    1. The COPA90 Services may use certain cookies and other technologies of which you should be aware.
       
    WHAT ARE COOKIES?
    Cookies and similar technologies are very small text documents or pieces of code, which often include an anonymous unique identifier. When you visit a website or use a mobile application, a computer asks your computer or mobile device for permission to store this file on your computer or mobile device and access information from it. Information gathered through cookies and similar technologies may include the date and time of visits, preferred country of residence and how you are using the particular website or mobile application. Cookies are used by us as part of our website and they are also used by some of our third party partners.For more details on cookies and similar technologies please visit All About Cookies. For the purposes of the remaining sections of this Cookie Policy we will refer to all technologies using the above features as “cookies”.

    CONSENT TO OUR USE OF COOKIES
    By using the website you acknowledge that we may store and access cookies on your computer or other device including consenting to certain cookies that are not essential to the operation of our website but allow us to provide additional functionality or to gather additional information about your use of our website. You are not obliged to give consent to our use of non-essential cookies.If you wish to block or delete cookies, or you would like to withdraw consent to our use of non-essential cookies, you can find out how to do so below.

    WHAT DO WE DO WITH COOKIES?
    Essential Cookies
    We use cookies where they are essential for the operation of the website, for example to remember that you are signed in to the website.
    Session Cookies
    We use cookies to allow the website to uniquely identify your browsing session on our website, which allows us to coordinate this information with data from our website server.
    Analytics Cookies
    We use “analytics” cookies. These, along with other information, allow us to calculate the aggregate number of people using the website and which features of our website are most popular.We use this information to improve the website. We do not generally store any information that you provide to us in a cookie.
    Social Media
    We use cookies to personalise your interaction with social media, such as Twitter, Facebook, Tumblr and YouTube. Such cookies recognise users of those social media sites when you view social media content on our website. They also allow you to quickly share content across social media, through the use of simple ‘sharing’ buttons.Our website also contains features that enable you to use your Facebook account to sign in and create/maintain an account with us and to enable us to store your content. This involves the use of cookies.

    WHAT HAPPENS WHEN YOU REFUSE, BLOCK OR DELETE COOKIES?
    In order to use some parts of our website you will need to accept cookies. If you choose to withhold consent to our use of cookies, or you subsequently block or delete cookies, some aspects of our website may not work properly and you may not be able to access all or part of our website.

    CAN YOU BLOCK COOKIES?
    You can block the use of cookies altogether by activating the relevant settings in your browser or by following the link below. For more information on cookie management and blocking or deleting cookies for a wide variety of browsers, visit All About Cookies.
     
  9. Third Party Links and Services
    1. The COPA90 Services may contain links to third party websites and services. Please remember that when you use a link to go from the COPA90 Services to another website or you request a service from a third party, this privacy notice no longer applies.
    2. Your browsing and interaction on any other website, or your dealings with any other third party service provider, is subject to that website’s or third party service provider’s own rules and policies.
    3. We do not monitor, control, or endorse the privacy practices of any third parties. We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you deal with and to contact them if you have any questions about their respective privacy policies and practices.
       
  10. Transfers outside the EEA
    1. We may transfer your personal data outside the EEA to processors outside the EEA including in the USA, in connection with our business or for legal reasons. We will ensure that the transfer is lawful and that there are appropriate security arrangements.
    2. If the European Commission has decided that a country does not provide an adequate level of protection in relation to data that is transferred there, we will enter into an agreement ensuring appropriate and suitable safeguards with our group member, processors or other transferee. This may be via binding corporate rules or on standard terms adopted by the Information Commissioner and approved by the European Commission.
       
  11. How long do we keep your personal information for?
    1. We do not keep your personal data for any specific period but will not keep it for longer than is necessary for our purposes.
    In considering how long to keep it, we will take into account its relevance to our business and our legal and regulatory obligations.
     
  12. Confidentiality and security of your personal information
    1. We are committed to keeping the personal information you provide us secure and we will take reasonable precautions to protect it from loss, misuse or alteration.
    2. We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:
      • unauthorised access;
      • improper use or disclosure;
      • unauthorised modification; and
      • unlawful destruction or accidental loss.
    3. All our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all users of the COPA90 Services.
       
  13. How to access your information and your other rights?
    1. You have the following rights in relation to the personal information we hold about you:
    • Your right of access.If you ask us, we’ll confirm whether we’re processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
    • Your right to rectification.If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
    • Your right to erasure.You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or you withdraw your consent (where applicable). If we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
    • Your right to restrict processing.You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or object to us processing it. It won’t stop us from storing your personal information though. We’ll tell you before we lift any restriction. If we’ve shared your personal information with others, we’ll let them know about the restriction where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
    • Your right to data portability.With effect from 25 May 2018, you have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or ask us to transfer this to a third party of your choice.
    • Your right to object.You can ask us to stop processing your personal information, and we will do so, if we’re:
      • relying on our own or someone else’s legitimate interests to process your personal information except if we can demonstrate compelling legal grounds for the processing;
      • processing your personal information for direct marketing; or
      • processing your personal information for research unless such processing is necessary for the performance of a task carried out in the public interest.
    • Your rights in relation to automated decision-making and profiling.You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, and it produces a legal effect or similarly significantly affects you unless such profiling in necessary for entering into, or the performance of, a contract between you and us.
    • Your right to withdraw consent.If we rely on your consent (or explicit consent) as our legal basis for processing your personal information for certain uses, you have the right to withdraw that consent at any time for those uses.
    • Your right to lodge a complaint with the supervisory authority.If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the UK Information Commissioner’s Office (ICO). You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.
       
  14. Change to this privacy notice
    1. We may make changes to this privacy notice from time to time
    2. To ensure that you are always aware of how we use your personal information we will update this privacy notice from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We may notify you by email of any significant changes. However, we encourage you to review this privacy notice periodically to be informed of how we use your personal information.

Last updated: May 2018