POLICY STATEMENT

It is the policy of Sporting Legacies Limited (the Company) to conduct business honestly and ethically. As part of that, the Company takes a zero-tolerance approach to bribery and corruption and is committed to acting professionally, fairly, and with integrity in all its business dealings and relationships, wherever it operates, and implementing and enforcing effective systems to counter bribery.

PURPOSE

The Company will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which it conducts business.

SCOPE AND APPLICABILITY

This policy applies to all individuals working for or on behalf of the Company at all levels and grades, whether permanent, fixed-term or temporary and wherever located, including consultants, contractors, seconded staff, casual staff, agency staff, volunteers, agents, sponsors and any other person who performs services for or on behalf of the Company, (collectively referred to as Workers in this policy).

In this policy, Third Party means any individual or organization that Workers come into contact with during the course of work and the running of the Company’s business and includes actual and potential clients, intermediaries, referrers of work, suppliers, distributors, business contacts, agents, advisers, government and public bodies (including their advisers, representatives and officials), politicians and political parties.

WHAT IS BRIBERY?

A bribe is an inducement or reward offered, promised, or provided to improperly gain any commercial, contractual, regulatory, or personal advantage, which may constitute an offence

, namely:

• giving or offering a bribe.
• receiving or requesting a bribe; or
• bribing a foreign public official.

The Company may also be liable if it fails to prevent bribery by an associated person (including, but not limited to Workers) for the Company’s benefit.

GIFTS AND HOSPITALITY

This policy does not prohibit normal and appropriate gifts and hospitality (given and received) to or from Third Parties unless otherwise specifically stated. However, we have specific internal policies and procedures which guide Workers as to what is to be regarded as normal and appropriate gifts and hospitality in terms of financial limits, subject to the principles set out below, namely that any gift or hospitality:

must not be made with the intention of improperly influencing a Third Party or Worker to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits;

• must comply with local law in all relevant countries;
• must be given in the name of the organization, not in an individual’s name;
• must not include cash or a cash equivalent;
• must be appropriate in the circumstances;
• must be of an appropriate type and value and given at an appropriate time taking into account the reason for the gift;
• must be given openly, not secretly; and

The Company appreciates that the practice of giving business gifts varies between countries and regions and what may be normal and acceptable in one region may not be in another. The test to be applied is whether in all the circumstances the gift or hospitality is reasonable and justifiable. The intention behind the gift should always be considered.

WHAT IS NOT ACCEPTABLE?

It is not acceptable for any Worker (or someone on their behalf) to:

• give, promise to give, or offer, a payment, gift, or hospitality with the expectation or hope that they or the Company will improperly be given a business advantage, or as a reward for a business advantage already improperly given;
• give, promise to give, or offer, a payment, gift, or hospitality to a government official, agent, or representative to facilitate or expedite a routine procedure;
• accept payment from a Third Party where it is known or suspected that it is offered or given with the expectation that the Third Party will improperly obtain a business advantage;
• accept a gift or hospitality from a Third Party where it is known or suspected that it is offered or provided with an expectation that a business advantage will be improperly provided by the Company in return;
• threaten or retaliate against another Worker who has refused to commit a bribery offence or who has raised concerns under this policy; or
• engage in any activity that might lead to a breach of this policy.

FACILITATION PAYMENTS AND “KICKBACKS”

We do not make, and will not accept, facilitation payments or “kickbacks” of any kind, such as small, unofficial payments made to secure or expedite a routine government action by a government official, or payments made in return for a business favour or advantage.

CHARITABLE DONATIONS AND SPONSORSHIP

The Company only makes charitable donations and provides sponsorship that are legal and ethical under local laws and practices and which are per the Company’s internal policies and procedures.

RECORD KEEPING

We keep appropriate financial records and have appropriate internal controls in place which evidence the business reason for gifts, hospitality and payments made and received.

RESPONSIBILITIES AND RAISING CONCERNS

The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control. All Workers are required to avoid any activity that might lead to, or suggest, a breach of this policy.

Workers are required to notify the Company as soon as possible if it is believed or suspected that a conflict with this policy has occurred, or may occur in the future, or if they are offered a bribe, are asked to make one, suspect that this may happen in the future, or believe that they are a victim of another form of unlawful activity.

Any employee who breaches this policy may face disciplinary action, which could result in dismissal for gross misconduct. We reserve our right to terminate our contract with any such employees.

MONITORING AND REVIEW

The Company monitors the effectiveness and reviews the implementation of this policy at appropriate intervals, considering its suitability, adequacy, and effectiveness. Any improvements identified are made as soon as possible. Internal control systems and procedures are also subject to regular review to ensure that they are effective in countering any risks of bribery and corruption.

All Workers are aware that they are responsible for the success of this policy and should ensure they use it to disclose any suspected danger or wrongdoing.

POLICY STATEMENT

Sporting Legacies Limited recognises that it has a responsibility to the environment beyond legal and regulatory requirements. We are committed to reducing our environmental impact and continually improving our environmental performance as an integral part of our business strategy and operating methods. We will encourage customers, suppliers, and other stakeholders to do the same.

RESPONSIBILITY:

Jim O’Toole , Company Director, is responsible for ensuring that this environmental policy is implemented, however, all employees have a responsibility in their area to ensure that the aims and objectives of this policy are met.

POLICY AIMS:
WE ENDEAVOR TO:

• Comply with all relevant regulatory requirements.
• Continually improve and monitor environmental performance.
• Continually improve and reduce environmental impacts.
• Increase employee awareness and training.

PAPER
WE WILL:

• Minimize the use of paper in the office.
• Reduce packaging as much as possible.
• Seek to buy recycled and recyclable paper products.
• Reuse and recycle all paper where possible.

ENERGY & WATER
WE WILL SEEK TO:

• Reduce the amount of energy used as much as possible.

OFFICE SUPPLIERS
WE WILL:

• Reuse and recycle everything we can.

TRANSPORTATION
WE WILL:

• Promote the use of travel alternatives such as email or video/phone conferencing.

MAINTENANCE AND CLEANING
WE WILL:

• Use cleaning materials that are as environmentally friendly as possible.
• Use materials in any office refurbishment that are as environmentally friendly as possible.
•  

MONITORING AND IMPROVEMENT
WE WILL:

• Comply with all relevant regulatory requirements.
• Continually improve and monitor environment performance.
• Continually improve and reduce environmental impacts.
• Increase employee awareness through training.

CULTURE
WE WILL:

• Update this policy at least once annually in consultation with staff and other stakeholders where necessary.
• Involve staff in the implementation of this policy, for greater commitment and improved performance.
• Provide staff with relevant environmental training.

Work with suppliers, contractors, and subcontractors to improve their environmental performance.

• Use local labour and materials where available to reduce CO2 and help the community.

POLICY MONITORING AND REVIEW

The Company Health and Safety Policy will be continuously monitored and updated, particularly when the scale and nature of operations change or there is a change to legislation.

It is Sporting Legacies  Limited’s duty to maintain safe working conditions and so far as is reasonably practicable the health, safety, and welfare at work of all employees. This requires that regard is paid in particular to:

• Adhering to all relevant health & safety legislation, regulations, and codes of practice;
• Maintaining a healthy and safe premise and working environment;
• Providing and maintaining safe equipment and systems at work and considering health & safety when procuring equipment, obtaining new services, and changing work patterns;
• Ensuring adequate funds and resources to maintain health & safety standards;
• Ensuring that all workers have the necessary experience and capability to carry out the tasks allocated to them;
• Ensuring safety in the use of articles and substances;
• Conducting a risk assessment for all staff and a special risk assessment for expectant, new mothers, and young people;
• Investigating accidents and dangerous occurrences, take any internal action necessary, and comply with statutory external reporting duties (RIDDOR);
• Providing such information, training, instruction, and supervision as is necessary to ensure the health and safety at work of all employees and visitors;
• Publishing and regularly updating the Company Health & Safety Policy.

The Company is also under a duty to ensure that any people not employed by it are not exposed to risk to their health and safety. This includes visitors to the Company’s premises or the premises of our clients.

The company’s policy covers the following in detail:

• Accident reporting (RIDDOR) and accident investigation and prevention;
• Specific hazards;
• Electrical testing – PAT (Portable Appliance Testing);
• Fire & Emergency (including fire safety service and test records);
• Risk assessment;
• Personal protective equipment (PPE);
• Health & safety with regard to new and expectant mothers and young people;
• First aid;
• Drug misuse, alcohol, and smoking;
• Use of display screen equipment;
• Posture and manual handling;
• Control of substances hazardous to health (COSHH);
• Policies relating to lone and mobile workers;
• Health & safety information and training.

MONITORING AND REVIEW

The Company Health and Safety Policy will be continuously monitored and updated, particularly when the scale and nature of operations change or there is a change to legislation.

This is the privacy notice of Sporting Legacies Limited In this document, “we”, “our”, or “us” refer to Sporting Legacies Limited

Our registered office is Sporting Legacies Limited, Unit 14, Elgar Business Centre, Moseley Road, Hallow  Worcester , England WR2 6NJ

INTRODUCTION

This privacy notice aims to inform you about how we collect and process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use, or otherwise act on information. It tells you about your privacy rights and how the law protects you.

We are committed to protecting your privacy and the confidentiality of your personal information. Our policy is not just an exercise in complying with the law, but a continuation of our respect for you and your personal information.

We undertake to preserve the confidentiality of all information you provide to us and hope that you reciprocate.

Our policy complies with the Data Protection Act 2018 (Act) accordingly incorporating the EU General Data Protection Regulation (GDPR).

The law requires us to tell you about your rights and our obligations to you regarding the processing and control of your personal data. We do this now, by requesting that you read the information provided at  https://ico.org.uk/for-the-public/the-right-to-object-to-the-use-of-your-data/

Except as set out below, we do not share, sell, or disclose to a third party, any information collected through our website.

1. DATA PROTECTION OFFICER

We have appointed a data protection officer (DPO) who is responsible for ensuring that our policy is followed.

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact our DPO, Jim O’Toole at  jim@sportlegacies.com

2. DATA WE PROCESS

We may collect, use, store, and transfer different kinds of personal data about you. We have collated these into groups as follows:

Your identity includes information such as first name, last name, title, date of birth, and other identifiers that you may have provided at some time.

Your contact information includes information such as billing address, delivery address, email address, telephone numbers, and any other information you have given to us for the purpose of communication or meeting.

Your financial data includes information such as your bank account and payment card details.

Transaction data includes details about payments or communications to and from you and information about products and services you have purchased from us.

Technical data includes your internet protocol (IP) address, 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 this website.

Your profile includes information such as your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.

Marketing data includes your preferences in receiving marketing from us; communication preferences; responses and actions in relation to your use of our services.

We may aggregate anonymous data such as statistical or demographic data for any purpose. Anonymous data is data that does not identify you as an individual. Aggregated data may be derived from your personal data but is not considered personal information in law because it does not reveal your identity.

For example, we may aggregate profile data to assess interest in a product or service.

However, if we combine or connect aggregated data with your personal information so that it can identify you in any way, we treat the combined data as personal information and it will be used in accordance with this privacy notice.

3. SPECIAL PERSONAL INFORMATION

Special personal information is data 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.

It also includes information about criminal convictions and offences.

We may collect special personal information about you if there is a lawful basis on which to do so.

4. IF YOU DO NOT PROVIDE THE PERSONAL INFORMATION THAT WE NEED

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 that contract. In that case, we may have to stop providing a service to you. If so, we will notify you of this at that time.

The law requires us to determine under which of six defined bases we process different categories of your personal information and to notify you of the basis for each category.

If the basis on which we process your personal information is no longer relevant, then we shall immediately stop processing your data.

If the basis changes then if required by law, we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.

5. INFORMATION WE PROCESS BECAUSE WE HAVE A CONTRACTUAL OBLIGATION TO YOU

When you create an account on our website, buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us.

In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.

We may use it in order to:

• verify your identity for security purposes
• sell products to you
• provide you with our services
• provide you with suggestions and advice on products, services, and how to obtain the most from using our website

We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.

We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.

6. INFORMATION WE PROCESS WITH YOUR CONSENT

Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you with more information about our business, including our products and services, you provide your consent to us to process information that may be personal.

Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to agree to our use of cookies.

If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.

We continue to process your information on this basis until you withdraw your consent, or it can be reasonably assumed that your consent no longer exists.

You may withdraw your consent at any time by instructing us at jim@legacyofsport.io. However, if you do so, you may not be able to use our website or our services further.

7. INFORMATION WE PROCESS FOR THE PURPOSES OF LEGITIMATE INTERESTS

We may process information on the basis there is a legitimate interest, either to you or to us, in doing so.

Where we process your information on this basis, we do so after having given careful consideration to:

• whether the same objective could be achieved through other means
• whether processing (or not processing) might cause you harm
• whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so

For example, we may process your data on this basis for the purposes of:

• record-keeping for the proper and necessary administration of our business
• responding to unsolicited communication from you to which we believe you would expect a response
• protecting and asserting the legal rights of any party
• insuring against or obtaining professional advice that is required to manage Sporting Legacies Limited’s risk
• protecting your interests where we believe we have to do so

8. INFORMATION WE PROCESS BECAUSE WE HAVE A LEGAL OBLIGATION

Sometimes, we must process your information to comply with a statutory obligation.

For example, we may be required to give information to legal authorities if they so request or if they have the proper authorization such as a search warrant or court order.

This may include your personal information.

SPECIFIC USES OF INFORMATION YOU PROVIDE TO US

9. INFORMATION RELATING TO YOUR METHOD OF PAYMENT

Payment information is never taken by us or transferred to us either through our website or otherwise. Our employees and contractors never have access to it.

At the point of payment, you are transferred to a secure page on the website of Stripe or some other reputable payment service provider. That page may be branded to look like a page on our website, but it is not controlled by us.

10. JOB APPLICATION AND EMPLOYMENT

If you send us information in connection with a job application, we may keep it for up to three years in case we decide to contact you at a later date.

If we employ you, we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment. After your employment has ended, we will keep your file for six years before destroying or deleting it.

11. COMMUNICATING WITH US

When you contact us, whether by telephone, through our website, or by e-mail, we collect the data you have given to us in order to reply with the information you need.

We record your request and our reply in order to increase the efficiency of our business.

We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high-quality service.

12. COMPLAINING

When we receive a complaint, we record all the information you have given to us.

We use that information to resolve your complaint.

If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter of our sole discretion as to whether we do give information, and if we do, what that information is.

We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.

13. AFFILIATE AND BUSINESS PARTNER INFORMATION

This is information given to us by you in your capacity as an affiliate of us or as a business partner.

It allows us to recognize visitors that you have referred to us, and to credit you the commission due for such referrals. It also includes information that allows us to transfer the commission to you.

The information is not used for any other purpose.

We undertake to preserve the confidentiality of the information and of the terms of our relationship.

We expect any affiliate or partner to agree to reciprocate this policy.

USE OF INFORMATION WE COLLECT THROUGH AUTOMATED SYSTEMS WHEN YOU VISIT OUR WEBSITE

14. COOKIES

Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalized experience and the website owner with statistics about how you use the website so that it can be improved.

Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.

Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.

Our website uses cookies. They are placed by software that operates on our servers, and by software operated by third parties whose services we use.

When you first visit our website, we ask you whether you wish us to use cookies. If you choose not to accept them, we shall not use them for your visit except to record that you have not consented to their use for any other purpose.

If you choose not to use cookies or you prevent their use through your browser settings, you will not be able to use all the functionality of our website.

We use cookies in the following ways:

• to track how you use our website
• to record whether you have seen specific messages we display on our website
• to keep you signed in on our site
• to record your answers to surveys and questionnaires on our site while you complete them
• to record the conversation thread during a live chat with our support team

15. PERSONAL IDENTIFIERS FROM YOUR BROWSING ACTIVITY

Requests by your web browser to our servers for web pages and other content on our website are recorded.

We record information such as your geographical location, your Internet service provider, and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.

We use this information in the aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.

If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed into our website.

16. OUR USE OF RE-MARKETING

Re-marketing involves placing a cookie on your computer when you browse our website in order to be able to serve you an advert for our products or services when you visit some other website.

We may use a third party to provide us with re-marketing services from time to time. If so, then if you have consented to our use of cookies, you may see advertisements for our products and services on other websites.

DISCLOSURE AND SHARING OF YOUR INFORMATION

17. INFORMATION WE OBTAIN FROM THIRD PARTIES

Although we do not disclose your personal information to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up of your personal information from third parties whose services we use.

No such information is personally identifiable to you.

18. CREDIT REFERENCE

To assist in combating fraud, we share information with credit reference agencies, so far as it relates to clients or customers who instruct their credit card issuer to cancel payment to us without having first provided an acceptable reason to us and given us the opportunity to refund their money.

19. DATA MAY BE PROCESSED OUTSIDE THE EUROPEAN UNION

Our websites are hosted in the UK.

We may also use outsourced services in countries outside the European Union from time to time in other aspects of our business.

Accordingly, data obtained within The UK or any other country could be processed outside the European Union.

For example, some of the software our website uses may have been developed in the United States of America or in Australia.

We use the following safeguards concerning data transferred outside the European Union:

• the processor is within the same corporate group as our business or organization and abides by the same binding corporate rules regarding data processing.
• the data protection clauses in our contracts with data processors include transfer clauses written by or approved by a supervisory authority in the European Union.
• we comply with a code of conduct approved by a supervisory authority in the European Union.
• we are certified under an approved certification mechanism as provided for in the Act.
• both our organisation and the processor are public authorities between whom there is either a legally binding agreement or administrative
• arrangements approved by a supervisory authority in the European Union relating to the protection of your information.

20. YOUR DUTY TO INFORM US OF CHANGES

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

21. ACCESS TO YOUR PERSONAL INFORMATION

At any time, you may review or update personally identifiable information that we hold about you, by signing into your account on our website.

To obtain a copy of any information that is not provided on our website you should contact us to make that request.

After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.

22. REMOVAL OF YOUR INFORMATION

If you wish us to remove personally identifiable information from our website, you should contact us to make your request.

This may limit the service we can provide to you.

23. VERIFICATION OF YOUR INFORMATION

When we receive any request to access, edit or delete personally identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

OTHER MATTERS

24. USE OF THE SITE BY CHILDREN

We do not sell products or provide services for purchase by children, nor do we market to children.

If you are under 18, you may use our website only with consent from a parent or guardian.

25. ENCRYPTION OF DATA SENT BETWEEN US

We use Secure Sockets Layer (SSL) certificates to verify our identity in your browser and to encrypt any data you give us.

Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust marks in your browser’s URL bar or toolbar.

26. HOW YOU CAN COMPLAIN

If you are in any way dissatisfied with how we process your personal information, you have a right to complain to the Information Commissioner’s Office

https://ico.org.uk/for-the-public/the-right-to-object-to-the-use-of-your-data/

We would, however, appreciate the opportunity to talk to you about your concern before you approach the IC,  at the following address

Sporting Legacies Limited, Unit 14, Elgar Business Centre, Moseley Road, Hallow  Worcester, England WR2 6NJ

27. RETENTION PERIOD FOR PERSONAL DATA

Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:

• to provide you with the services you have requested;
• to comply with other laws, including for the period demanded by our tax authorities;
• to support a claim or defence in court.

28. COMPLIANCE WITH THE LAW

Our privacy policy has been compiled to comply with the law of every country or legal jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your jurisdiction, we would like to hear from you.

However, ultimately it is your choice as to whether you wish to use our website.

29. REVIEW OF THIS PRIVACY POLICY

We may update this privacy notice from time to time, as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.

If you have any questions regarding our privacy policy, please contact us.

Cookie Policy

Effective Date: 06-Dec-2023
Last Updated: 06-Dec-2023

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