This policy applies to Dirtyboyz and our website www.dirtyboyz.org operated by 15Heroes Limited.
15Heroes Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website and tell you about your privacy rights and how the law protects you.
1. IMPORTANT INFORMATION AND WHO WE ARE
Purpose of this privacy notice
This privacy notice aims to give you information on how 15Heroes Limited collects and processes
your personal data through your use of this website, including any data you may provide through this
website.
It is important that you read this privacy notice together with any other privacy notice
or fair processing notice we may provide on specific occasions when we are collecting or processing
personal data about you so that you are fully aware of how and why we are using your data.
This privacy notice supplements the other notices and is not intended to override them.
Controller
15Heroes Limited is the controller and responsible for your personal data (collectively referred
to as “15Heroes Limited“, “we”, “us” or “our” in
this privacy notice.)
We have appointed a data privacy manager who is responsible for overseeing
questions in relation to this privacy notice. If you have any questions about this privacy notice,
including any requests to exercise your legal rights, please contact the data privacy manager using the
details set out below.
Contact details
Our full details are:
Full name of legal entity: 15Heroes Limited
Name and title of
data protection officer: Kelvin Sollis, data protection officer.
Email address:
kelvin@dirtyboyz.org, info@dirtyboyz.org
Postal address: 15Heroes Limited, The White House, 164 Bridge Road, Sarisbury Green, Southampton, SO31 7EH.
Telephone number: 020 3633 2200
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO),
the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate
the chance to deal with your concerns before you approach the ICO so please contact us in the first
instance.
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 your relationship with us.
Third-party links
Our websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our websites, we encourage you to read the privacy notice of every website you visit.
2. 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 our users.
Identity Data includes first name, last name and gender.
Contact
Data includes billing address, delivery address, email address and telephone numbers.
Financial
Data includes credit card numbers.
Photo Data includes photographs and videos contributed by our
users.
Marketing and Communications Data includes your preferences in receiving marketing from us
and your communication preferences.
Technical Data
Website Usage
We may collect, use and share Aggregated Data such as statistical or demographic data
for any purpose. Aggregated Data may be derived from your personal data but is not considered personal
data in law as this data does 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 notice.
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
goods or services). 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.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you
including through:
Direct interactions. You may give us your Identity, Contact, Financial and Photo
Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes
personal data you provide when you:
– first join the Dirtyboyz site.
–
subscribe to the Dirtyboyz site.
– request marketing to be sent to you.
–
communicate with us, for example, on a social media platform or by sending us an email.
Automated
technologies or interactions.
As you interact with our website, we may automatically collect
Technical Data about your equipment, browsing actions and patterns. We collect this personal data by
using cookies, server logs and other similar technologies.
Contact, Financial and Transaction Data
from providers of technical, payment and delivery services such as Barclaycard, American Express,
Cashflows and Paypal for card payments based inside and outside of the EU.
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:
Where we need to
perform the contract we are about to enter into or have entered into with you.
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.
Where we need to comply with a legal or regulatory
obligation.
Purposes for which we will use your personal data
We have set out a description of
all the ways we plan to use your personal data.
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.
Purpose/Activity: To register you as a new user
Type of data:
(a)
Identity
(b) Contact
Purpose/Activity: To process and deliver your subscription
Type of
data
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(c)
Financial
(d) Transaction
(e) Marketing and Communications
Purpose/Activity: To manage
our relationship with you as a member of Dirtyboyz
Type of data
(a) If you join
or subscribe to Dirtyboyz you will provide your name, address, gender and email address.
Our legal basis for processing your personal data in this way is your consent to such processing which
shall be requested as part of your compliance with the terms and conditions applicable to membership.
(b)
If you sign up to a feature on our website, you will generally provide your name and contact information
and any other information necessary to access the feature. Our legal basis for processing your personal
data in this way is your consent to such processing which shall be requested as part of your compliance
with the terms and conditions applicable to the feature;
Purpose/Activity: To administer and
protect our business and our websites including troubleshooting, data analysis, testing, system
maintenance, support, reporting and hosting of data.
Type of data
(a) Identity
(b)
Contact
(c) Technical
(d) Usage
(e) Marketing and Communications
(f) Technical
Purpose/Activity:
To use data analytics to improve our website, products/services, marketing, customer relationships and
experiences.
Type of data
(a) Technical
(b) Usage
Promotional offers from us
We
may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you
may want or need, or what may be of interest to you. This is how we decide which products, services and
offers may be relevant for you (we call this marketing).
You will receive marketing communications
from us if you have requested information from us and you have not opted out of receiving that
marketing.
Third-party marketing
We will not share your personal data with any company outside
15Heroes Limited for marketing purposes.
Cookies
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 this website may become inaccessible or not function
properly.
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.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set
out below for the purposes set out above.
Specific third parties such as:
Barclaycard,
American Express, Cashflows and Paypal who process payments on our behalf.
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 privacy notice.
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.
6. 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.
7. DATA RETENTION
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.
In some circumstances you can ask us to delete your data.
In some circumstances
we may 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.
8. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in
relation to your personal data to .
If you are located in the European Economic Area
(“EEA”) or Switzerland, you may have the following rights in relation to personal data that
we hold about you:
To request confirmation of whether we process personal data relating to you, and
if so, to request a copy of that personal data.
To request that we rectify or update your personal
data that is inaccurate, incomplete or outdated.
To request that we erase your personal data in
certain circumstances, such as where we collected personal data on the basis of your consent and you
withdraw your consent.
To request that we restrict the use of your personal data in certain
circumstances, such as while we consider another request that you have submitted, for example a request
that we update your personal data.
Where you have given us consent to process your personal data,
to withdraw your consent.
To request that we provide a copy of your personal data to you in a
structured, commonly used and machine readable format in certain circumstances.
You may contact us
by e-mail or as described in the Contact Details section to exercise your rights described above.
No
fee usually required
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 may refuse to comply with your request in these
circumstances.
What we may need from you
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.
Time limit to respond
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.
9. LAWFUL BASIS
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.
We process your data where it is necessary for the performance of
a contract to which you are a party or to take steps at your request before entering into such a
contract.
We process your personal data where it is necessary for compliance with a legal or
regulatory obligation that we are subject to.
10. YOUR LEGAL RIGHTS
You have the right to:
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 the personal data that we hold about you. 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, 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 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 of your personal data. 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.
Request the transfer of your personal data to you or to a third
party. 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.
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 products or services to
you. We will advise you if this is the case at the time you withdraw your consent.
15Heroes Limited, The White House, 164 Bridge Road, Sarisbury Green, Southampton, SO31 7EH.
Last Updated: 21st Feb, 2023