Your privacy is of the utmost importance to us. Please read this Privacy Notice carefully to understand our views and practices regarding your personal data and how we will treat it.
Whenever you provide personal information, we are legally obliged to use it in accordance with the laws concerning the protection of personal information.
Who we are: Turnstile Group Limited is managed by Gemba, a high end consultancy providing insight and strategy to the global sport & entertainment industry.
Turnstile Group Limited, a company registered in England whose registered address is at 49, Greek Street, London, W1D 4EGF or the purposes of the Data Protection Act 1998, the General Data Protection Regulations and any other applicable data protection and privacy laws and regulations (“Data Protection Legislation”), Turnstile Group Limited will be the ‘data controller’ for all personal information we determine the means and purpose of processing and has registered with the Information Commissioners Office under registration number ZB194796.
Our registration with the ICO and all of our data protection practices are aimed at ensuring we provide all of the protection required under Data Protection Legislation to Your Personal Information. This Privacy Notice is designed to inform you how we do that in a clear and concise fashion. If you have any questions about our data handling practices, please contact us at the address below.
By “Personal Data” we refer to information collected or held by Turnstile Group Limited, that identifies and relates to you as an individual.
Information we may collect
We may collect personal information about you when you request our services, including:
- Your name;
- Postal address;
- Invoicing details/address;
- Information regarding the services you request;
- Supplementary information you provide us about yourself when contacting us;
- Email address; and
- Telephone numbers (including mobile).
We may also collect technical information about you when you visit the Website. This information may include the Internet protocol (IP) address used to connect your computer to the Internet, your browser type and version, time zone setting, operating system and platform, browser plug-in types and version, the full URL clickstream to, through and from the Website, page response times, download errors, length of visits to certain pages, page interaction (such as scrolling, clicks and mouse-overs) and methods used to browse away from the page.
The collected information is used to provide an overview of how people are accessing and using the Website. It is not used for any additional purpose, such as to profile those who access the Website.
If you fail to provide us with Personal Information: You always reserve the right to withhold your personal information but this may affect how we provide our services
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you .In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
We will use your personal information for a number of purposes including:
- internal record keeping;
- to carry out any obligations owed to you through the use of our Website and in respect of any contracts entered into between you and us;
- to give you information that you request from us and to improve our services;
- to notify you about changes to our services;
- to allow us to operate the Website efficiently;
- to ensure that the content from our Website is presented in the most effective manner for you and your computer;
- any relevant troubleshooting, testing or statistical analysis as appropriate; and
- to keep the Website secure.
- Where we have your permission to do so, we may also use the information collected to:
- provide you with information about our services that we offer via promotional communications; and
- keep you up to date with features on the Website.
However, you can opt-out of any of these data uses at any time by emailing email@example.com. We will only keep your information for as long as reasonably required or as stated in the contract you have with us.
Data retention: How long we will retain your Personal Information for.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Legal basis of processing: we always ensure that a Lawful basis exists for all of the Personal Information we process at Turnstile.
We will only process your information for as long as we have a relevant legal basis to do so. This is usually in order to provide you with the contractual services you have requested from Turnstile Group Limited or if you have provided us with adequate consent to process your information for other purposes.
If we choose to process your information under the legal basis of legitimate interests, we will always inform you of our legitimate business interest and your right to object.
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. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at firstname.lastname@example.org.
Protecting your information: We take our security obligations very seriously and constantly monitor for breaches and potential weaknesses.
We are committed to ensuring that your information is secure and we have procedures in place to try and prevent any unauthorised access or disclosures and to safeguard and keep secure the information that we collect online.
All the Personal Data collected by us and stored electronically is held on a secure server in the EEA only. Where required, this information is encrypted for additional security. We use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our buildings and files, and we authorise access to Personal Data only for those employees who require it to fulfil their job responsibilities.
However, you should be aware that providing information over the internet can never be guaranteed as being completely safe and if you choose to send such information to us via the internet, you do so at your own risk.
Transfer of data outside of the EU: If we are required to store or process your data outside of the European Economic Area
We shall not transfer any personal data to any country outside of the European Economic Area unless we ensure that such personal data is subject to an adequate level of protection and appropriate legal safeguards in accordance with Data Protection Legislation.
If you wish to access your Personal Information, we will inform you of the transfers we make (if any) and the legal safeguards we have employed to ensure the ongoing security and protection of your data.
Sharing your information with others: If and when we share your data, we always do so under a written agreement governing how your data must be protected
Please be assured that we will not share your information for any other reason unless we are required by law or permitted to do so under this Privacy Notice. The main circumstances in which we will be permitted or required to disclose this is by law will be by court order, to government bodies and law enforcement agencies. However, sometimes we may share your information with third parties in the following ways:
- we may use carefully selected sub-processors to help us collect, store or manage your information. This will always be managed under the terms of a written data processing agreement;
- analytics and search engine providers that assist us in the improvement and optimisation of the Website; and
- if Turnstile Group Limited is acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets. We process your personal information for this purpose because we have a legitimate interest to ensure our business can be continued by the buyer. If you object to our use of your personal information in this way, the relevant seller or buyer of our business may not be able to provide services to you.
- Access to your Personal Data: Our obligations under Data protection Law and your options to control your Personal Information
You have rights in relation to any Personal Data that we hold about you. If you wish to access your Personal Data you may make a formal subject access request by contacting Turnstile Group Limited.
The information you request must relate to you or another person that you have authority to act on their behalf. Turnstile Group Limited will require a confirmation of your ID prior to providing any information about the data we hold. If you are unable to provide sufficient information to prove your ID, Turnstile Group Limited reserves the right to refuse your request for access to Personal Data. The rights you have in relation to the Personal Data we hold regarding you are:
- the right to rectify any inaccuracies in the information we hold;
- the right to erasure of information in specific circumstances;
- the right to request transfer of your information to another controller; and
- the right to object to processing in certain circumstances.
If you have provided us with consent to process your information, you always reserve the right to withdraw this consent via the method detailed in the paragraph below. We are committed to ensuring that your wishes are respected and upon notification that you wish to withdraw your consent, Turnstile Group Limited will immediately cease processing the information in question.
Please send your request to Turnstile Group Limited by emailing email@example.com. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Changes to this Privacy Notice: We may change this Privacy Notice at any time to ensure it always accurately reflects the way we collect, use and safeguard your Personal Information.
Please check this notice from time to time to ensure you are aware of any updates we may have made to our Personal Data handling practices. The date of the changes will be listed in the ‘Last updated’ section below. We will endeavour to notify all of our current clients of any updates to this notice via email and we will post the relevant announcement on our website homepage.
We recommend that you print a copy of this page for your reference.
How can you make a complaint?
Please note that if you are not satisfied with the processing of your personal data as set out in this Privacy Notice, please contact us at firstname.lastname@example.org.
You have the right to issue a complaint directly with the Information Commissioners Office, the data protection supervisory authority for England and Wales (https://ico.org.uk/concerns/).
Please contact us at email@example.com if you have any questions, comments or requests regarding this Privacy Notice.