Privacy policy.
Introduction
This document provides you with information about how we are handling, or are intending to handle, your personal information.
If you are under the age of 18, please get your parent/guardian’s permission before you provide any personal information to us.
Off The Streets is committed to protecting and respecting your privacy and complying with the principles of applicable data protection laws. This notice sets out how any personal data we collect from or about you will be handled by us. Please read the following carefully to understand our practices regarding your personal data.
Off The Streets Website
Off The Streets holds information provided at the time of registering to use our website, becoming a registered user of Off The Streets, subscribing to our communications, posting material, booking onto rides, entering, attending and volunteering at events, joining clubs or requesting further services. This includes:
Information from your social media accounts but only where you have given us permission to use it. For example, posts, pictures and video footage you share on social media platforms such as Facebook.
We may also ask you for information when you report a problem, make a complaint or share a concern and, if you contact us, we may keep a record of that correspondence.
We may also ask you to complete optional surveys that we use for research and insight purposes (including case studies) and to provide you with a more relevant customer experience.
Details of when you digitally interact with Off The Streets via our websites and other digital channels and the resources that you access which may include the use of cookies.
Information about emails and other communications we have sent to you and your interaction with them.
Information from third parties where there is a clear lawful basis for sharing your information (for example, because you have consented to them sharing your personal data with Off The Streets).
How we use (process) your personal information
Off The Streets may collect and process the following data about you where applicable:
Information about you that you provide by filling in forms while registering for activities and making purchases (such as Off The Streets event entry) on our website;
Information about you that you provide when completing optional surveys;
Information about you provided through general correspondence with Off The Streets;
Information that you provide as well as information that we have collected about you to investigate any complaints or concerns reported by you or others.
Off The Streets will use your personal information to:
Ensure that content from our websites is presented in the most effective manner;
Authenticate you when you register;
Carry out our obligations arising from any contracts entered into between you and Off The Streets;
Provide you with information, products or services that you request from Off The Streets or which we feel may interest you, where we are legally entitled to do so;
Enable people to join events, rides, clubs and groups and communicate with each other via the Off The Streets system as part of that activity;
Allow you to participate in interactive features of Off The Streets’ service, when you choose to do so;
Notify you about changes to any of our services;
To segment your personal data to make sure that you only receive information that is relevant to you;
Off The Streets will not use any of the personal information we collect from you to make automated business decisions.
The legal basis on which we collect and process the personal data described above depends on the personal information concerned and the specific context in which we collect it. However, we will only use your personal information where we:
Have your consent to do so;
Need the personal data to perform a contract with you;
Need to process your personal information for our legitimate interests and only where our legitimate interests are not overridden by your data protection interests or fundamental rights and freedoms;
Have a legal obligation to collect personal information from you; or
Need the personal information protect your vital interests or those of another person.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time, and advise you whether the provision of your personal information is mandatory or not (as well as the possible consequences if you do not provide your personal information).
When and how we share information with others
We will share information about you with some of our suppliers who process data on our behalf to help us to provide services to you. We may also share your personal data with third parties that we work with where it is lawful for us to do so.
Categories of organisation and purpose
Marketing agencies - to provide relevant digital content to our customers (including prospective customers where applicable).
Database hosting companies - to host Off The Streets digital platforms (e.g. Off The Streets website) and associated databases to enable customers to log in and interact with the website.
Email broadcasting companies - to send emails to our customers.
SMS broadcasting companies - to send SMS and text messages to our customers.
Printing and/or mailing houses - to send products and benefits to our customers that are not directly produced by Off The Streets (e.g. publications).
Research partners (market research companies, academic institutions and analytics companies) - to undertake cycling-related research.
Social media companies (e.g. Facebook) - to provide you with relevant social media posts. We may also use your email address to create ‘lookalike audiences’ on Facebook in order to reach people who may be interested in Off The Streets. More information (including how to manage your preferences) can be found at https://www.facebook.com/about/basics/advertising.
Online learning hosting companies - to enable our customers to take part in online training and learning.
Off The Streets registered event organisers, ride leaders and officials - to enable event organisers, ride leaders and officials to manage Off The Streets registered activities and communicate with participants and appointed volunteers.
Sports results agencies - to collate results and reports for the Off The Streets website on behalf of Off The Streets.
Organisations involved in event management (security, hospitality, venues) – as necessary to ensure the efficient management of events.
Commercial partners – to send marketing communications to you where we have your consent to do so and to effectively deal with any concerns or complaints.
Third party partnerships (Local Authorities, CSPs, Combined Authorities and transport partners) – to enable the local delivery of cycling programmes and initiatives.
Insurers and legal advisors – to advise and effectively manage any legal and insurance claims.
Government agencies – where we have a legal basis for doing so (including for compliance with Covid-related laws and guidance such as NHS Test and Trace).
Transferring personal data outside of the EU
We do not envisage transferring any information about or relating to individuals to anyone who is located outside of the European Economic Area.
However, on some occasions, the information we collect may be transferred to organisations who may store and use such data at premises in other countries. Where we allow an organisation to process your personal information outside of the European Economic Area, we will ensure that we create and maintain appropriate safeguards with those organisations so that your personal information is subject to the same standards and protections as when we are processing your personal information inside the European Economic Area.
Security of your information
Off The Streets will take all steps reasonably necessary including policies, procedures and security features to ensure that your data is treated securely and protected from unauthorised and unlawful access and/or use, and in accordance with this notice. Unfortunately, the transmission of information via the internet is not completely secure and, although we will do our best to protect your personal data transmitted to us via the internet, we cannot guarantee the security of your data transmitted to our website from your device. Any transmission is at your own risk.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of the website, you are responsible for keeping this password confidential. We ask you not to share such a password with anyone.
Where any payments are being collected on our behalf, we require our payment providers to be compliant with the Payment Card Industry’s Data Security standards (PCI-DSS).
Data storage and retention
We will hold information about you in our data systems only for as long as we need it for the purpose for which we collected it. In particular:
Any data relating to the obligations of Off The Streets to maintain a comprehensive, published index of results as a National Governing Body for sport will be retained. This would not include more than name, age category and gender alongside details of the event in which an individual took part.
Personal data linked to the processing of insurance claims, subject access requests, disputes, safeguarding investigations, disciplinary or police matters, and Off The Streets governance will only be kept for as long as it necessary for those purposes, as each is applicable.
Your rights
Data protection laws grant you, as a Data Subject, certain ‘information rights’, which are summarised below:
Right of access - You have the right to obtain a copy of information we hold about you.
Right of rectification or erasure - If you feel that any data that we hold about you is inaccurate, you have the right to ask us to correct or rectify it. You also have a right to ask us to erase information about you where you can demonstrate that the data we hold is no longer needed by us, or if you withdraw the consent upon which our processing is based, or if you feel that we are unlawfully processing your data. Please note that we may be entitled to retain your personal data despite your request, for example if we are under a separate legal obligation to retain it. Your right of rectification and erasure extends to anyone we have disclosed your personal information to and we will take all reasonable steps to inform those with whom we have shared their data about your request for erasure.
Right to restriction of processing - You have a right to request that we refrain from processing your data where you contest its accuracy, or the processing is unlawful and you have opposed its erasure, or where we do not need to hold your data any longer but you need us to in order to establish, exercise or defend any legal claims, or we are in dispute about the legality of our processing your personal data.
Right to Portability - You have a right to receive any personal data that you have provided to us in order to transfer it onto another data controller where the processing is based on consent and is carried out by automated means. This is called a data portability request.
Right to Object - You have a right to object to our processing your personal data where the basis of the processing is our legitimate interests including but not limited to direct marketing and profiling.
Right to Withdraw Consent - You have the right to withdraw your consent for the processing of your personal data where the processing is based on consent.
Right of Complaint - You also have the right to lodge a complaint about any aspect of how we are handling your data with the ICO, who can be contacted at www.ico.org.uk.
Right to Opt-out of Marketing Communications - You have the right to opt-out of marketing communications we send to you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you. To opt out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided below.