We are Summus Sports Group Limited, a company registered in England and Wales with number 11988905 and registered office at 27 Knowles Wharf, 38 St Pancras Way, London, NW1 0QW, United Kingdom (“we”, “us”, “our” and “Summus”). We provide the Summus College platform and the content and services included therein, which is available here: www.summuscollege.com (the “Platform”).

We respect your privacy and are committed to protecting your personal data. This Policy is aimed at informing you how we look after your personal data when you use our Platform. The Policy also tells you about your privacy rights and how the law protects you and your personal data.

It is important that you read this Policy together with any other privacy policy or fair processing policy we may provide on specific occasions so that you are fully aware of how and why we are using your data. This Policy supplements other notices and privacy policies and is not intended to override them.

The Platform is not intended for children, and we do not knowingly collect data relating to children.

We keep our Privacy Policy under regular review. This version was last updated on 27th February 2023. If you have any questions about this Policy, please contact us at info@summuscollege.com.

SECTION 1: THE DATA 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 which we have grouped together as follows:

Identity Data	includes first name, last name and individual username or similar identifier, gender and date of birth.
Physical Data	includes your height, weight, and any other information about your physique and appearance.
Contact Data	includes your home address, work address, billing address, email address and telephone numbers.
Financial Data	includes bank account and payment card details and details relating to fees charged to or paid by you.
Sport Data	includes your sporting occupation and information relating to your expertise, level, abilities, qualifications, awards, certificates, National Collegiate Athletic Association tier/division, and professional goals.
Education Data	includes your current school and education, education history and any qualifications, awards, and certificates.
Employment Data	includes your current job title and employer, and employment history.
CV Data	includes any information which may be included in a sporting resume or CV, including Identity Data, Physical Data, Contact Data, Education Data, Employment Data, and Sport Data.
Social Media Data	includes information from your LinkedIn, Instagram, Facebook and any other social media profiles or accounts which you choose to link to the Platform.
Image Data	includes the pictures and videos you upload to the Platform and/or from your social media accounts if you link these to the Platform.
Location Data	includes your device and/or browser location, your location, your education or employment locations, and any additional location data stored within any accounts you choose to link to the Platform.
Account Data	includes your password, username and your preferences, feedback and survey responses.
Technical Data	includes internet protocol address, login data, browser type and version, time zone setting, browser plug-in types and versions, and operating system.
Usage Data	includes information about how and when you use our website, services and the Platform.
Communications Data	includes your communication preferences.

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. 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.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

Section 2: How your personal data IS collected

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

Direct Interactions

You may give us your Identity, Physical, Contact, Financial, Sport, Education, Employment, CV, Social Media, Image, Location, Account, and Communication Data by:

filling in forms on the Platform (for example when you register for an account with us or give us feedback);

linking your social media or other accounts with the Platform;

completing surveys that we use for research purposes;

making payments to us; or

corresponding with us by post, phone, email or otherwise.

Automated Technologies or Interactions

As you interact with the Platform, we will automatically collect Technical, Location and Usage Data. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy for further details. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Platform may become inaccessible or not function properly.

Third Parties or Publicly Available Sources

We will receive Technical and/or Social Media Data about you from various third parties based inside or outside the UK such as analytics providers like Google, Meta and LinkedIn.

We will receive and share Contact and Financial Data from providers of technical, payment and delivery services, such as Stripe.

Section 3: If you fail to provide personal data

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 (for example, to provide you with access to the Platform). In this case, we may have to cancel a service or account you have with us, but we will notify you if this is the case at the time.

Section 4: How we use your personal data

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 Contract

We will process your personal data where we need to in order to perform the contract we are about to enter into or have entered into with you (i.e. our Summus College Platform Terms and Conditions).

Legitimate Interests

We will process your personal data 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.

“Legitimate Interest” means our interest in conducting and managing our business to enable us to give you the best service and the most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Legal Obligations

We will process your personal data where it is necessary for compliance with a legal obligation in the UK or EU that we are subject to.

Section 5: Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our Legitimate Interests are where appropriate.

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. Please contact us if you need details about the specific legal ground we are relying on to process your personal data. Where more than one ground has been set out in the table below.

Purpose/Activity	Type of Data	Lawful Basis for Processing
To register you as a new user as an Athlete	(a) Identity (b) Contact (c) Account (d) Physical (e) Sport (f) Location	Performance of a contract with you
To register you as a new user as a Coach	(a) Identity (b) Contact (c) Account (d) Physical (e) Sport (f) Location (g) Employment	Performance of a contract with you
To provide the Platform to you	(a) Identity (b) Contact (c) Account (d) Usage (e) Technical (f) Employment (g) Location (h) Sport (i) Physical	Performance of a contract with you
To allow you to populate your account on the Platform and use the Platform	(a) Identity (b) Contact (c) Account (d) Usage (e) Technical (f) Employment (g) Location (h) Sport (i) Physical (j) Education (k) CV (l) Social Media (m) Image	(a) Performance of a contract with you (b) Legitimate Interests (to allow optimum operation of the Platform and to provide you with an enjoyable user experience)
To deliver relevant website content to you and measure or understand the effectiveness of the content we provide to you	(a) Identity (b) Contact (c) Account (d) Usage (e) Technical (f) Employment (g) Location (h) Sport (i) Physical	Necessary for our legitimate interests (to study how users use our services, to develop them, to grow our business and to inform our business strategy)
To process and manage payments, fees and charges and collect or recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Account (e) Location	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us and ensure the proper functioning of the Platform)
To manage our relationship with you which will include notifying you about changes to our Summus College Platform Terms and Conditions or Privacy Policy, and/or asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Account (d) Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how users use our services)
To administer and protect our business and the Platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical (d) Usage (e) Account	(a) Necessary for our legitimate interests (for 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) (b) Necessary to comply with a legal obligation
To use data analytics to improve our website, services, and user relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of users for our services, to keep our website updated and relevant, to develop our business and to inform our business strategy)
To deliver any additional services that you have purchased or are considering purchasing.	(a) Identity (b) Contact (c) Account (d) Location (e) CV (f) Employment (g) Social Media (h) Sport (i) Physical (j) Education	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (for the running and development of our business and to define types of users for our services)

Section 6: Change of purpose

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.

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

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Section 7: Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes explained in Sections 4 and 5 above:

External Third Parties

Service providers acting as processors based within the UK, the EEA, and the USA who provide services to allow the development, hosting and functioning of the Platform or otherwise to store Personal Data on our behalf, including for example Stripe, Pixel, Cloudinary, Amazon AWS, Send in Blue, Google Cloud, MongoDB, Digital Ocean.

Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.

Regulatory authorities located in the UK, EEA and/or the USA as applicable from time to time.

We may also share personal data with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We, and many of our external third parties, are based outside the UK so our processing of your personal data will involve a transfer of data outside the UK. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by:

ensuring we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; or

putting in place specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

Section 8: Data security

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

We have put in place 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.

Section 9: Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

In some circumstances you can ask us to delete your data: see Section 10 below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Section 10: Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. We have summarised these below. For more information, please see the ICO website here: https://ico.org.uk/your-data-matters/

Request access to your personal data (commonly known as a "data subject access request")	This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of your personal data	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.
Request erasure of your personal data	This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data	You can object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing your personal data	Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: if you want us to establish the data's accuracy; where our use of the data is unlawful but you do not want us to erase it; 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 you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request transfer of your personal data	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.
Right to withdraw consent	You can withdraw consent at any time 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 services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us. We try to respond to all legitimate requests within one month. Occasionally it could 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.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.