Privacy Policy

This privacy notice is designed to help you understand what we do with information we get about our members referred to as “personal information”.

We are committed to protecting the privacy and security of your personal information. This privacy notice describes how we collect and use personal information about you during the course of your membership with us, in accordance with data protection law.

We have summarised what we do and how we use your personal information below:

  1. Who Are We?

Schools and Universities Polo Association Limited (SUPA) is a registered company and charity that organises national and international polo matches and tournaments for members who are students in school or university.

  1. What information do we collect, store and use?

We collect information when you register with us. We will collect your name, age and contact details. We will also collect your medical information, payment details from whoever pays for your membership and photographs of members who are over 16.

  1. Why do we collect, store and use your information?

We collect, store and use your personal information to set you up as a member, arrange national and international polo matches and tournaments, invite you to events, add you to our insurance cover, deal with any medical emergencies at our events and run our member services including promoting our events and telling you about offers from our sponsors. We will not make any automated decisions based on your personal information.

  1. Legal Grounds for collecting storing and using your information

We collect your:

  • name, age and contact details on the basis of legitimate interests;
  • payment details for the performance of a contract or where your parent/guardian or your school/university pays, we do so on the basis of legitimate interests;
  • image or likeness, personal interests, career ambitions and medical information on the basis of consent.
  1. Children’s information

Due to the fact that we are a schools and university association we will collect personal information from children. We will either collect the information from the child (where they understand what is being asked) or their parent/guardian.

  1. Where do we receive information about you from?

We will collect personal information direct from you, your parent/guardian or your school/university. We will only collect information from a child where they understand what is being asked.

  1. What if you do not provide information to us?

If you do not provide your information, you would be unable to register as a member of SUPA and will not have access to our events.

  1. Who do we share information with?

Your information is only shared with your consent, if permitted by law or if a third party is working on behalf of SUPA, for example our travel and accommodation providers.

  1. International Transfers

We may transfer your personal information outside the UK or EEA where you are travelling with us to an event or on a tour overseas.  We will only do this where we need to in order to arrange or run the overseas tour or event.

  1. How long do we keep your information?

Your information is kept for 5 years.

  1. What rights do you have?

Your rights may include access to, correcting or deleting your personal information.

If you have given us your consent to use your personal information, you can withdraw this at any time. Please see the detailed section below called ‘What Rights Do I Have Over My Personal Information?’ for a full explanation of your rights.

  1. Who can you contact if you have a question or a complaint?

You have the right to make a complaint at any time to the UK regulator for data protection issues, the ICO (see www.ico.org.uk). We would like to deal with your concerns before you approach the ICO and so, if you are happy to do so, please contact our Chairman at chairman@supa.org.uk. You can also contact our chairman if you have a question about this privacy notice.

Detailed Privacy Notice:

WHO ARE WE AND HOW TO CONTACT US

“We”, “our” or “us” means Schools and Universities Polo Association Limited. Our Company Number is 0549150. Our registered charity number is 1150236. Our registered office is at 11 Church Farm Courtyard, High Street, Chalfont St. Giles, Buckinghamshire, England, HP8 4QH.

We are the controller of your personal information. This privacy notice provides an overview of what personal information we collect and store and how we use the personal information of our members. This privacy notice also tells you what your rights are over your personal information and how to exercise those rights. 

If you have any questions or concerns about the information in this notice, or about our handling of personal information more generally, or if you would like more detailed information on a particular point, you should contact our Chairman who can be contacted as follows: Charles Betz, chairman@supa.org.uk.

HOW WE USE PERSONAL INFORMATION THAT WE COLLECT FROM YOUR USE OF OUR WEBSITE AND OUR LEGAL BASIS FOR THAT 

  1. What personal information do we collect and how do we use it?

Information you give us: If you fill in a form on our website, request information through an application or contact us via email, telephone or social media channels, we will collect the information you include on the form or which you provide to us when you contact us, such as your name and contact details. We will use this information to:

  • send you the information you have requested;
  • respond to the forms you complete;
  • respond to your query.

Information we collect about you from browsing our website: We use cookies on our website. If you would like details about what cookies we use please see our cookie policy [include link to cookie policy].

Information publicly available: if you contact us via social media channels, we may collect the information which is publicly available on those channels about you.

  1. What is our legal basis for using your personal information?

Under data protection law we must have a legal basis to use your personal information. We have set these out below.

Information you give us: Where you fill in a form on our website, request information via an application or contact us via email, telephone or social media channels, the legal basis for this use is that it is in our legitimate interests to be able to respond to enquiries that we get. We have considered our legitimate interests carefully and have balanced our legitimate interests against your rights under data protection law. We consider that this use is proportionate because we will only use the information we get from you to respond to your enquiry and it is in your reasonable expectations that we would need to use your personal information to be able to respond to you.

Information we collect about you from your use of our website: Where we collect personal information through cookies you have accepted on our website (which are not essential for our website to work), the legal basis for this use is that you have given your consent to this. You can, of course, withdraw your consent at any time by deleting our cookies by managing your browser’s cookie preferences. For further details on how to manage your preferences please see aboutcookies.org or www.allaboutcookies.org.

When we collect information about you from our website using essential cookies, we will use your personal information on the basis that it is in our legitimate interests to do so. We have considered our legitimate interests carefully and have balanced our legitimate interests against your rights under data protection law. We consider that this use is proportionate because the website will not work without them.

WHAT PERSONAL INFORMATION DO WE COLLECT AND USE WHEN YOU BECOME A MEMBER?

  1. What personal information do we collect and how do we use it?

If you apply to be a member or are a member we will collect information from you, or if you are not old enough to give us the information we need, from your parent/guardian or your school/university.

Information you, your parent/guardian or your school/university give us may include:

  • your name;
  • initials and date of birth; are required for insurance identification only
  • your address and contact details;
  • your school or university;
  • your medical information relating to [please insert] if participating internationally;
  • Your next of kin details and if you are under the age of 18 your parent’s names and contact details; and
  • Details of who is paying for your membership such as their name, bank account, card number and sort code.

We will use this information to:

  • set up and administer your membership;
  • organise events including any associated tours or travel;
  • send out communications regarding the timing, rules and conditions for participation for our events;
  • bring or defend legal proceedings;
  • arrange the payment of your membership; and
  • arrange necessary public liability and personal accident insurance.

If you are aged 16 or over  and participate in a SUPA or SUPA Sanctioned Event we may take photographs of you and write match reports which may name you and your performance.

  1. What is our legal basis for using your personal information?

Under data protection law we must have a legal basis to use your personal information. We have set these out below.

Information you give us:

If we collect your name, address, telephone number, age and school/university direct from you to use it as set out above then our legal basis for doing this is because it is necessary for the performance of our contract we have with you when you agree to become a member.

If you give us your payment details in order to pay for your membership, our legal basis for doing this is because it is necessary for the performance of our contract we have with you when you agree to become a member.

Our legal basis for using your medical information is consent which you or your parent/guardian (where they need to give consent) gave to us. This consent can be withdrawn at any time by contacting our Chairman (see contact details above). If you withdraw your consent the consequence will be you are unable to participate in our events for your safety.

Our legal basis for taking photos and writing match reports on your performance is that you have provided us with your consent or your parent/guardian have provided consent where they need to give consent. This can be withdrawn at any time by contacting our Chairman (see contact details above). If you do so the consequence will be that you will not be included in any photos or named as a participant.

Information your parent/guardian or school/university gives us:

If your parent/guardian or school/university gives us your name, address, telephone number, age and school/university then our legal basis for doing this is that it is in our legitimate interests to do this and use it as set out above because it is something we think you would expect us to do.

If your parent/guardian or school/university gives us payment details in order to administer and pay for your membership, our legal basis for doing this is that it is in our legitimate interests to do this and use it as set out above because it is something we think you would expect us to do.

If we take personal information relating to your parent/guardian, anyone at your school/university or your next of kin details then our legal basis for doing this is that it is in our legitimate interests to do this and use it as set out above.

We have considered our legitimate interests carefully and have balanced our legitimate interests against rights you or these other people have under data protection law. We consider that this use is proportionate because we need to do these things to set up your membership, administer it and arrange tours and events. It is something we think you and these other people would expect us to do.

WHAT PERSONAL INFORMATION DO WE COLLECT AND USE WHEN YOU REQUEST TO PARTICIPATE IN INTERNATIONAL EVENTS AS A MEMBER

  1. What personal information do we collect and how do we use it?

If you are a member we will collect information from you, your university or if you are not old enough to give us the information we need, from your parent/guardian or your school/university.

Information you or your parent/guardian may give to us include:

  • your personal information when you became a member;
  • payment details of the person making the payment such as their name, bank account, card number and sort code;
  • your passport details;
  • your gender;

We will use this information to:

  • arrange your participation with international event providers;
  • check you attend a member school or university;
  • check you are of British nationality (if you are playing for the British team);
  • arrange necessary travel, travel visas, travel documents and travel insurance; and
  • arrange necessary accommodation.
  1. What is our legal basis for using your personal information?

 If you give us the personal information set out above to use it as also set out above then our legal basis for doing this is because it is necessary for the performance of our contract we have with you as a member and in relation to arranging travel and participation in international events.

If a parent, or school/university is responsible for providing the above personal information, our legal basis for collecting, storing and using it is that it is in our legitimate interests to use your personal information as set out above.

We have considered our legitimate interests carefully and have balanced our legitimate interests against your rights under data protection law. We consider that this use is proportionate because we need to do these things to organise international visas, administer it and arrange tours and events to ensure the safety of members. It is something we think you would expect us to do.

Our legal basis for using your medical information is that you provided us with your consent or your parent/guardian has provided consent where they need to give consent. This consent can be withdrawn at any time by contacting our Chairman (see contact details above). If you do so the consequence will be you are unable to participate in our events for your safety.

WILL WE CHANGE THE WAY WE USE YOUR PERSONAL INFORMATION?

We will only use your personal information for the purpose we have set out in this notice. We can only change the purpose we use it for without telling you where we need to use it for another reason and that reason is compatible with those set out in this notice. If we need to use your personal information for any other purpose, we will notify you and we will explain the legal basis which allows us to do so in a similar way to how we have done it in this notice.

WHAT HAPPENS IF I DON’T PROVIDE THE PERSONAL INFORMATION YOU HAVE ASKED FOR?

If you don’t provide the personal information we need when we ask for it, we may not be able to set you up as a member or tell you about or permit entry to our events. Where we process your personal information on consent you have the right to withdraw your consent at any time by contacting our Chairman (see contact details above). If you withdraw your consent for us to use collect, store and use your medical information, you will not be allowed to participate in any of our events, for your personal safety. If you have any concerns about whether you need to provide the personal information please contact our Chairman (see contact details above).

 DO WE USE YOUR PERSONAL INFORMATION TO MAKE AUTOMATED DECISIONS?

 We will not use your personal information to make decisions that will have a significant impact on you based solely on automated decision making (i.e. one without human intervention).

HOW LONG WILL WE KEEP YOUR PERSONAL INFORMATION?

We will not keep your personal information for longer than we need it for the purposes we have explained in this privacy notice. We will keep your personal information used when you participate in international events for 5 years after the event date, and we keep match records indefinitely.

[We will also keep your personal information used for the other purposes outlined above for [INSERT] after your membership expires.]

WHO WILL WE SHARE YOUR PERSONAL INFORMATION WITH?

We may share your personal information with the people set out below. We will not, however, share your personal information with a third party for them to market to you unless we have your consent to do this.

  • Travel/Accommodation Providers: We may share your personal information with travel/accommodation providers, where SUPA organises travel/accommodation for events you are taking part in. We are sharing it with them on the basis that it is in our legitimate interests as a business to arrange travel/accommodation for our members on a SUPA tour or for an event we are taking part in. It is something we think you would expect us to do.
  • Event Organisers: We will share your personal information with event organisers for events you are intending to participate in as a member. They may access your personal information to the extent they need in order for you to participate. We are sharing it with them on the basis that it is in our legitimate interests as a business to ensure we have a successful event in accordance with the rules of the sport. It is something we think you would expect us to do.
  • Legal and Regulatory Requirements: We will share your personal information with organisations or individuals where this is necessary to comply with any law, rule, regulation, legal procedure or governmental request that applies to us. The legal basis for this is that sharing your personal information in this way is necessary in order for us to comply with our legal obligations.
  • Professional Advisors: We may share your personal information with our professional advisors (including lawyers, insurers and/or insurance brokers) to take advice e.g. with any complaint or claim which you make. The legal basis for this is that it is in our legitimate interests as a business to be able to obtain professional advice from our external advisors about issues that may arise whilst you are with us. It is something we think you would expect us to do.
  • Sponsors: We may share your personal information with our sponsors so they can market to you their products. As outlined above, we will only do this with your consent, which you can withdraw at any time.

We will only disclose the personal information that we need to, to any of these third parties so that they can do what they need to do in relation to the purpose we disclose it to them for.

WILL YOU TRANSFER MY PERSONAL INFORMATION OUTSIDE THE UK OR EEA?

European Economic Area (“EEA”) countries are all EU Member countries together with Iceland, Liechtenstein and Norway. At the present time we store your personal information in the United Kingdom or in countries within the EEA. We may transfer your personal information outside the UK or EEA where you are travelling with us to an event or on a tour overseas. We will only do this where we need to meet our contractual obligations with you (e.g. to arrange the overseas tour or event) or where it is in our legitimate interests to arrange the tour or event. It is something we think you would expect us to do.

If we transfer your personal information outside the UK or EEA we will only do this where we can do it legally and have your consent.

If you would like further details about our transfer of your personal information outside the EEA or details of the safeguards put in place in relation to your personal information please contact our Chairman (see contact details above).

HOW DO WE ENSURE THAT YOUR PERSONAL INFORMATION IS SECURE?

 We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

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

WHAT RIGHTS DO I HAVE OVER MY PERSONAL INFORMATION?

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), (the UK regulator for data protection issues. See www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO and so, if you are happy to do so, please contact our Chairman at chairman@supa.org.uk.

You also have a number of additional rights over your personal information, which are:

  • the right to ask us what personal information we have about you and to have a copy of your personal information from us;
  • the right to ask us to correct any errors in your personal information;
  • the right to object to our legitimate interests, profiling activities and marketing communications;
  • the right to ask us to provide you with a copy of the personal information you have provided to us, in a structured, commonly used and machine-readable format and the right to transmit that personal information to another entity where: (i) we are using your personal information on the basis of your consent or on the basis that it is necessary to perform a contract with you; and (ii) the use we are making of your personal information is carried out by automated means;
  • the right to ask us to delete your personal information where: (i) we don’t need your personal information anymore; (ii) you withdraw your consent to our use of your personal information and we have no other legal basis to keep your personal information; (iii) you have asked us to review and explain our legitimate interests to you and we don’t actually have a valid legitimate interest to do what we are doing; (iv) our use of your personal information is illegal; (v) we have to delete your personal information to comply with our legal obligations;
  • the right to ask us to restrict the use that we are making of your personal information where: (i) you don’t think the personal information we have about you is correct, so that we can check if it is correct; (ii) what we are doing with your personal information is illegal but you would rather we stop using your personal information rather than delete it; (iii) we don’t need your personal information anymore, but you need us to keep it so that you can exercise any legal rights; and (iv) you have asked us to review and explain our legitimate interests to you, so that we can check whether we actually have a valid legitimate interest to do what we are doing; and
  • where our use of your personal information is based on your consent, the right to withdraw your consent at any time by contacting our Chairman (see contact details above).

If you want to exercise the rights set out above please contact our Chairman (see contact details above).

HOW WILL YOU TELL ME ABOUT CHANGES TO THIS PRIVACY NOTICE?

We keep our privacy notice under regular review. Any changes we make to our privacy notice in the future will be posted on this page and if the changes will have an effect on you or the way we use your personal information we will bring them to your attention by email if we have your email address.

HOW YOU CAN CONTACT US

If you have any questions about this privacy notice or about the ways we use your personal information, please contact our Chairman (see contact details above).