Privacy Policy

1. About This Notice

1.1 Raise Your Game Ltd is committed to protecting the privacy and security of your personal information. This privacy notice describes how we collect and use personal information about you in accordance with data protection law. Please read it carefully.

1.2 Data protection law says that the personal information we hold about you must be:

Used lawfully, fairly and in a transparent way.
Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
Relevant to the purposes we have told you about and limited only to those purposes.
Accurate and kept up to date.
Kept only as long as necessary for the purposes we have told you about.
Kept securely.

1.3 If you have any questions about this notice or how we collect and use personal information about you, please contact us.

2. Information About Us

2.1 We are Raise Your Game Ltd. Our registered office is at Leasing.Com Stadium, London Road, Macclesfield, England, SK11 7SP. Our registered company number is 16023811 (referred to “we”, “us”, “our” throughout this privacy notice).

2.2 If you have any questions, contact us as follows:

Post: Leasing.Com Stadium, London Road, Macclesfield, England, SK11 7SP
Email and Phone: The contact details displayed on our website at Raise Your Game

3. Data We Collect About You

3.1 We will collect personal data about you.

3.2 Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed, which is anonymous data.

3.3 We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data: Title, first name, maiden name, last name, username or similar identifier, date of birth, and gender.
Contact Data: Billing address, delivery address, email address, and telephone numbers.
Financial Data: Bank account and payment card details.
Transaction Data: Details about transactions (completed or in process), payment amounts/dates to and from you, and other details of products and services you have purchased from us.
Technical Data: IP address, login data, browser type/version, time zone setting/location, browser plug-in types/versions, operating system/platform, and other technology on the devices you use to access our website.
Profile Data: Username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.
Usage Data: Information about how you use our website, services, and prize draws.
Marketing and Communications Data: Preferences in receiving marketing from us and third parties and your communication preferences.

3.4 We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.

3.5 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 policy.

3.6 We do not collect any Special Categories of Personal Data, including details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health, genetic, and biometric data. Nor do we collect any information about criminal convictions and offences.

4. How Is Your Personal Data Collected?

4.1 We use different methods to collect data from and about you, including through:

Direct interactions: You may give us your Identity and Contact Data by making purchases on our website or by telephone or by corresponding with us by email, telephone, post, or otherwise. This includes personal data you provide when you:
- Purchase our products or services;
- Create an account on our website;
- Subscribe or request marketing to be sent to you;
- Complete a survey; or
- Give us feedback or contact us.
Automated technologies or interactions: As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy for further details.
Third parties or publicly available sources: We may receive Technical Data from analytics providers (e.g., Google Analytics), advertising networks (e.g., Meta, Google, Pinterest), and search information providers (e.g., Google Adwords).

5. How We Use Your Personal Data

5.1 We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Performance of a contract: Where we need to perform the contract we are about to enter into or have entered into with you.
Legitimate Interest: Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Legal Obligation: Where we need to comply with a legal obligation.
Consent: Where we have obtained your active agreement to use your personal data for a specified purpose (e.g., you subscribe to marketing).

5.2 Generally, we do not rely on consent as a legal basis for processing your personal data, although we will get your consent before sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

6. Purposes for Which We Will Use Your Personal Data

6.1 Below is a description of the ways we plan to use your personal data, along with the legal bases we rely on to do so:

Purpose/Activity	Type of Data	Lawful Basis for Processing
Register you as a new customer	(a) Identity (b) Contact	Performance of a contract with you
Process and deliver your orders, including managing payments and recovering money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction	Performance of a contract with you Necessary for our legitimate interests (to recover debts due to us)
Notify you of prize wins	(a) Identity (b) Contact (c) Transaction	Performance of a contract with you Necessary for our legitimate interests
Manage our relationship with you, including notifying you about changes to our terms or privacy policy	(a) Identity (b) Contact (c) Profile	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests

7. Marketing

7.1 We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional Offers from Us

7.2 We may use your Identity, Contact, Technical, Usage, and Profile Data to form a view on what we think you may want or need, or what may be of interest to you.

7.3 You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

Third-Party Marketing

7.4 We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting Out

7.5 You can ask us or third parties to stop sending you marketing messages at any time by:

Following the opt-out links on any marketing message sent to you;
Contacting us at any time via email; or
Logging into the website and adjusting your marketing preferences.

8. Change of Purpose

8.1 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.

8.2 If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.

9. Disclosures of Your Personal Data

9.1 We may share your personal data with the following:

Group companies for operational management purposes.
External third parties, including service providers, professional advisers, regulators, and payment providers.
Third parties to whom we may sell, transfer, or merge parts of our business or assets.

9.2 We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

10. Data Security

10.1 We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed.

10.2 We have procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

11. Your Rights

11.1 Data protection law gives you several rights regarding your personal data. These include:

The right to access, correct, or request erasure of your data.
The right to object to processing or request a restriction of processing.
The right to withdraw consent or request the transfer of your data.

11.2 To exercise your rights, please contact us. We aim to respond to all legitimate requests within one month.

12. Changes to This Privacy Policy

12.1 We keep our privacy policy under regular review. Please check back frequently for updates.

Tottenham Hotspur Foundation Privacy Policy

Introduction

Tottenham Hotspur Foundation takes your privacy seriously. This privacy policy sets out what personal information we process about you, how we use your personal information and your rights regarding the personal information we hold about you.

This policy applies to personal information we process when you access our websites, when you engage with us on social media platforms, when you enrol on our programmes and when you communicate with us generally.

About us

Tottenham Hotspur Foundation is registered as a data controller in the United Kingdom and our registration number is Z1034030. Our registered office is Percy House, 796 High Road, Tottenham, London N17 0DH.

Legal notice

This policy has been prepared in line with the data protection laws applicable in the United Kingdom, including the General Data Protection Regulation (GDPR) and any subsequent amendment or legislation passed to enact GDPR into UK Law.

How to contact us about this Privacy Policy

We have staff who oversee our data processing activities and they have access to a dedicated Data Protection Officer appointed to Tottenham Hotspur Football Club. If you have any questions or concerns about this Privacy Policy or about your personal data in general, please let us know by emailing foundation.personaldata@tottenhamhotspur.com.

Personal information we process and what we use it for

We must process personal information about you so that we can provide you with our services. We collect most of this information from you directly, but we may also receive data from third parties such as schools, partner organisations and funding partners. The table below outlines the personal information we collect about you, what we use it for and our legal reason, also known as the lawful basis, for processing it.

Purpose/activity Personal data types Lawful basis To register you as a course participant and keep in touch with you during the programme you have registered for • Your name, postal address, email address and phone number (contact details) • Our legitimate interest as a provider of services and activities in the community To register you as the parent or legal guardian of a course participant who is under the age of 16 and for emergency contact • Name, contact details, relationship to the participant • Legal obligation (Safeguarding and Vulnerable Groups Act 2006) To make reasonable service adjustments to make sure that you can access our services safely if you have a disability or health condition • Name, contact details
• Type of adjustment required and details of why the adjustment is required
• Health condition and precautions required • Legal obligation (Equality Act 2010)
• With your explicit consent To register you as a volunteer on one of our programmes • Name, contact details, date of birth
• Results of disclosure checks from the Disclosure and Barring Service (DBS) if you are working with children under 16 or adults receiving health or personal care • Our legitimate interest as a provider of services and activities in the community
• Legal obligation (Safeguarding and Vulnerable Groups Act 2006) To assess your suitability as a job applicant for the role you have applied for • Name, contact details, previous work, education, referees and answers relevant to the role • Performance of a contract with you Purpose/activity Personal data types Lawful basis To provide feedback to the organisation who has referred you to one of our programmes • Name, contact details,
• Your health conditions and any improvements if these are related to the purpose of the course you have registered for • Our legitimate interest as a provider of services and activities in the community
• After anonymisation To allow Tottenham Hotspur Football Club to contact you about latest news, competitions, tickets, merchandise and offers • Name, contact details • With your explicit consent To produce case studies which can be included in publications and other forms of publicity • Photographs
• Details of activities • With your explicit consent To enable us to anonymously monitor the fairness, equality and inclusion of our programmes • Racial and ethnic origin
• Age
• Gender
• Disability • With your explicit consent To allow you to contribute towards fundraising and donations for the Foundation • Name
• Email address and/or Address
• Card Details • Performance of a contract with you

Our commitment

We commit to only processing your personal information for the purposes outlined in the table above. If these purposes change over time, or we want to use the data for a new purpose that we did not originally anticipate, we will only go ahead if the new purpose is compatible with the original purpose. If the new purpose is not compatible with the original purpose, we will ask for your specific consent for the new purpose. If the law changes so that we must process your data for a new purpose, we will inform you before making the change.

At the point when we collect your personal data, we will always remind you of why we need it and how we plan to use it.

Automated decision-making and profiling

We do not conduct any automated decision-making such as profiling. If this changes, we will update this privacy notice and update you accordingly.

Sharing your information with third parties

We may share your personal information with third parties as part of our service to you. The list below shows who we may share information with and the situations where we might do so.

Service providers: In order to provide our services effectively we may need to appoint data processors to carry out some of the data processing on our behalf. These include, for example, Tottenham Hotspur Football Club, who provide us with our IT service, and other software suppliers. We have agreements in place with our data processors which means they cannot do anything with your personal information unless we instruct them to do so.
Funding partners: We may share your personal data with the organisations we work in partnership to deliver our community activities. These include schools, local authorities and charities who are all also registered data controllers. We have agreements in place with them to acknowledge that we are both responsible for preserving your privacy and processing your data in accordance with the law. The data may or may not be shared anonymously, but we will let you know which is the case when you register.
Publicity and Media: From time to time we may wish to publicise the work we are doing through publications or the media, including social media. We may ask you to be a part of this but we will only disclose your personal information, such as your photograph, with your explicit consent, or that of your guardian if you are under 16.
Tottenham Hotspur Football Club: If you give your explicit consent, we will pass on your contact details to the Club so that they can inform you about their latest news, competitions, ticket and merchandise updates and offers. When you set up a user account with the Club you will have the opportunity to express your preferences for the way your data is used.
Legal and other obligations: We may also share your personal data with third parties in the following circumstances:
- If we are under a legal or regulatory requirement to do so
- To lawfully assist the police or security services with the prevention and detection of crime or terrorist activity
- Where disclosure is necessary to protect the safety or security of any persons

International Data Transfers

We do not currently transfer your personal information outside of the European Economic Area. If this changes in the future, we will update this Privacy Policy and put in place measures to ensure your information is given the appropriate level of protection.

Keeping your information

We retain your personal information for the minimum reasonable time period to allow us to fulfil the purposes that we collected it for. Our retention schedule is as follows:

If you are a participant on a course, we will keep your personal data for the length of the programme you have signed up for and a limited period afterwards to allow follow-up. The follow-up period varies from course to course and we will let you know what it is when you sign up for the course.
If you apply for a job and are successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment and for 7 years afterwards as required by law.
If you apply for a job and are unsuccessful, we will retain your personal details for a period of 6 months after your application. If you give us your explicit consent, we may hold your data on file for a further 6 months for consideration for future employment opportunities.
If you apply to be a volunteer and are successful, we will retain your personal data for as long as you remain a volunteer with us and for 6 months afterwards to enable us to deal with any queries that may arise. If you give us your explicit consent, we may hold your data on file for a further 6 months for consideration for future volunteering opportunities.
If you apply to be a volunteer and are unsuccessful, we will retain your personal data for 6 months after your application. If you give us your explicit consent, we may hold your data on file for a further 6 months for consideration for future volunteering opportunities.

At the end of the retention period we will delete or destroy your personal information except where we need to keep it to comply with our legal obligations, resolve ongoing disputes or defend ourselves against future legal claims, or enforce our agreements.

We may continue to use data without further notice to you to help us ensure the fairness of our services and activities. If we do this, we will anonymise the data first so that you cannot be identified as being associated with it.

Your Rights

You have certain rights in relation to your personal information. If you wish to exercise any of the following rights, please contact foundation@tottenhamhotspur.com.

Right of access. You have the right to access the data that we hold on you. We provide you with access to as much of your personal information as possible on our electronic system Waves. However, if you require access to other information, you should make a subject access request in writing.

Right to rectification. You can request that we update any of your personal information, which is out of date or incorrect. We may not always be able to change or remove that information but we’ll correct factual inaccuracies and may include your comments in the record to show that you disagree with it.

Right to erasure: In some circumstances you can ask for your personal information to be deleted. You should be aware however that this is not an absolute right and there are situations where legally, we will not be able to comply with your request. If we cannot comply with your request, we will clearly explain our reasons.

Right to object. You can object to our processing of your personal information where we do so in our legitimate interests or in the public interests. If you do object, you should provide specific reasons why you are objecting to the processing of your data. You should be aware that this is not an absolute right, and we can continue processing if we can demonstrate compelling legitimate grounds for the processing or if the processing is for the establishment, exercise or defence of legal claims. If we cannot comply with your request, we will clearly explain our reasons.

Right to restrict processing. In some circumstances, you have the right to ask us to restrict the processing of your personal data. This may be because you have issues with the content or accuracy of the information we hold and want us to restrict processing whilst these issues are addressed. Alternatively, it could be because you have objected to our processing of your data for the purposes of our legitimate interests, and you want us to restrict processing whilst we considering our response. Where we comply with these requests, we will always inform you before lifting the restriction.

Consent withdrawal. Where you have given clear consent for us to process your personal data for a specific purpose, you have the right to withdraw your consent at any time.

Changes to this policy

As our work at the Foundation develops in the future, it may be necessary for this Privacy Policy to change with it. We reserve the right to amend this Privacy Policy at any time, for any reason, without notice to you, other than the posting of the amended Privacy Policy on our websites. We will let you know, however, if any of these changes are likely to affect you materially. You should check our website from time to time for any changes to the Privacy Policy.

More information and complaints

If you have any questions or require further information, please contact us by emailing: foundation.personaldata@tottenhamhotspur.com.

If you are not satisfied with how we have handled your query or your personal data in general, you can contact the Foundation's Protection Officer by emailing: foundation.personaldata@tottenhamhotspur.com.

Or, if you are not satisfied with how the Data Protection Officer has handled your query or your complaint, you can contact the Information Commissioner’s Office in any of the following ways:

In writing: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
By phone: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number.
By email: casework@ico.org.uk.
On line: ico.org.uk