Privacy Policy

At Sponsorwise, accessible from https://www.sponsorwise.net, one of our main priorities is the privacy of our visitors. This privacy policy describes the types of information that are collected and processed by Sponsorwise in relation to our Sponsorwise website platform (the “platform”) and your use of our website, in accordance with the General Data Protection Regulation (the “GDPR”).

If you have additional questions or require more information about our privacy policy, do not hesitate to contact us at info@sponsorwise.net.

Sponsorwise Ltd is the controller (as defined in the GDPR) and responsible for your personal data (referred to as “we”, “us”, “our” “Sponsorwise” in this privacy policy).

Our registered office is at 2nd Floor Beaumont House, 1b Lambton Road, London, SW20 0LW, and our company number is 12072688.

What personal data do we collect about you?

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 (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you. This data may be received from you, or it may be received from a third party (such as analytics providers), another user of the platform or a public source (to the extent permitted by law). We have grouped together the types of personal data we may collect about you as follows:

· Identity Data includes first name, last name, username or similar identifier and date of birth.

· Contact Data includes billing address, email address, contact address and telephone numbers including details of the organisation you work for.

· Financial Data includes bank account and payment card details and records of any transactions.

· Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the platform and our website.

· Usage Data includes information about how you use our website and the platform, and content that you share with other users through the platform.

· Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

· Location Data to identity the location that users interact with the platform.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political

opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Some of the personal data that you provide to us (e.g. data by which we can identify you) are required for you to create a profile on the platform and to comply with the Terms of Use. The provision of any other personal data is voluntary, but may be necessary for the use of the platform or for us to comply with our legal obligations.

For what purposes do we collect your personal data and what are the lawful bases for processing your personal data?

We have set out below a description of all the ways we plan to use your personal data.

Sponsorwise’s lawful bases for collecting and using the personal information described in this privacy policy depends on the personal information we collect and the specific context in which we collect the information. We will not share your personal information with any third parties except as set out in this policy.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

The purposes for which we may process your personal data and our lawful bases for doing so are:

· To register your profile and give you access to the platform.

· The provision of our services to you, including but not limited to creating and managing profiles and listings of associations, progressing and enabling sponsorship arrangements, arranging for invoices and payments to be made, providing and enhancing features such as payment processing, and ensuring the functionality of the platform and our website.

· To manage our relationship with you including enabling us to enforce our Terms of Use for the Sponsorwise platform and notifying you about changes to our Terms of Use or this privacy policy.

Our lawful basis for the activities above is, where we have a contract with you (or one is in prospect), where the processing is necessary for the performance of our contract with you, or in order to take steps at your request prior to entering into a contract, and in all other cases the pursuit of our legitimate interests of operating and expanding our business activities lawfully, running our business and for the purpose of the collaboration we have with our clients.

· To fix problems with your account for the platform, resolving of disputes, providing other services within the scope of customer service.

· To administer and protect our business, our website and the platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).

Our lawful basis for the activities above is the pursuit of our legitimate interests of operating and expanding our business activities lawfully or running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or

group restructuring exercise, and in all other circumstances, necessity to comply with our legal obligations.

· To provide you with personalised advertising and marketing communications.

· To use data analytics to improve our website, the platform, products/services, marketing, customer relationships and experiences.

Our lawful basis for the activities above is the pursuit of our legitimate interests of developing our platform and our products/services, growing and developing our business, to inform our marketing strategy and to keep our website updated.

Generally, we do not rely on consent as a lawful 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.

Who will see my personal data and who might it be shared with?

Your personal data may be seen or used by our staff in the course of their duties or others lawfully working with us in the ordinary course of our business.

We may need to share your data with relevant third parties such as external service providers (including our data processor who hosts the platform, bPolNet Sp. z o.o., based in Poland), professional advisors, regulators and other authorities, or where you ask us to share your data.

Without your opt-in consent, we will not pass on your personal data to third parties for their marketing or advertising purposes, nor will we sell or otherwise make it available to third parties for a fee.

You can ask us or third parties to stop sending you marketing messages at any time by checking or unchecking relevant boxes to adjust your marketing preferences by following the opt-out links on any marketing message sent to you or by contacting us at any time.

How long does Sponsorwise retain my personal data?

Sponsorwise will retain your personal information only for as long as is necessary for the purposes set out in this privacy policy. We will retain and use your information to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our policies.

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, regulatory, tax, accounting or other requirements.

Will my personal data be transferred internationally?

We do not transfer your personal data outside the European Economic Area.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Some of these rights are not automatic, and we reserve the right to discuss with you why we might not comply with a request from you to exercise them.

If you wish to be informed what personal information we hold about you and if you want to exercise any of the rights listed below, please contact us:

· The right to access, update or to delete the information we have on you.

· The right of rectification – this enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

· The right to object – this enables you to object to processing if you feel it impacts on your fundamental rights and freedoms and we are relying on a legitimate interest. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

· The right of restriction – this enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

· The right to data portability – we will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

· The right to withdraw consent, where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you believe that we have not complied with any of our obligations under data protection laws, please let us know. You also have the right to lodge a complaint with a supervisory authority. As a rule, you can contact the supervisory authority of your usual place of residence, your place of work or the registered office of the controller. The relevant supervisory authority in the UK is the Information Commissioner’s Office.

Log files

Sponsorwise follows a standard procedure of using log files. These files log visitors when they visit websites. All hosting companies do this and a part of hosting services' analytics. The information collected by log files include internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks. These are not linked to any information that is personally identifiable. The purpose of the information is for analysing trends, administering the site, tracking users' movement on the website, and gathering demographic information.

Third party privacy policies and cookies

Third-party ad servers or ad networks use technologies like cookies, JavaScript, or Web Beacons that are used in their respective advertisements and links that appear on Sponsorwise, which are sent directly to users’ browser. They automatically receive your IP address when this occurs. These technologies are used to measure the effectiveness of their advertising campaigns and/or to personalise the advertising content that you see on websites that you visit.

Note that Sponsorwise has no access to or control over these cookies that are used by third-party advertisers.

Sponsorwise's privacy policy does not apply to other advertisers or websites. We advise you to consult the respective privacy policies of these third-party ad servers for more detailed information. It may include their practices and instructions about how to opt-out of certain options.

You can choose to disable cookies through your individual browser options. For more information about how we use cookies, please see our Cookies Policy.

Children’s information

Another priority of ours is adding protection for children while using the internet. We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity.

This website is not intended for children and Sponsorwise does not knowingly collect data relating to children under the age of 13. If you think that your child has provided this kind of information on our website, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records.

Changes to this privacy notice

We reserve the right to update this privacy notice at any time for example if the law or regulatory requirements change, if technology changes or to make Sponsorwise’s operations and procedures more efficient. We will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

Acknowledgement

By using our website, applying for the platform or using the platform, you acknowledge and agree to the terms of this privacy policy.

Last updated: July 2020