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Privacy Policy

Proem Sports Analytics Pte. Ltd (PSA) is an off-field sports analytics company that works with sport bodies to provide them with insights about their operations. Part of the insights we provide include insights on fans (fans of that specific sports body) for which we collect and analyse fan data that fans have chosen to publicly share.

At Proem Sports Analytics, we are committed to protecting the fan data that we use to provide the fan data analytics application(s) that offer as well as the data of our customers who avail and use our applications. PSA complies with the GDPR framework that is set forth to regulate the use, and protection of personal data.

Fans and customers alike can reach out to us at info@proemsports.com for any queries regarding their data and how it is used, or if they want us to remove or modify (rectify) any data related to them.

Last Updated: 01-06-2018

Definitions

PSA: Proem Sports Analytics, a registered Private Limited Company

GDPR: means the General Data Protection Regulation.

Register of Systems: Fan Management System

Fans: Fans and Potential Fans of a Sports

Business User: Users from Customer Organisations

Data: Personal Data of Fans and Business Users

 

1. Data protection principles

 

PSA is committed to processing data in accordance with its responsibilities under the GDPR.

Article 5 of the GDPR requires that personal data shall be:

  1. processed lawfully, fairly and in a transparent manner in relation to individuals;

  2. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;

  3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;

  4. accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;

  5. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and

  6. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.”

2. General provisions

  1. This policy applies to all personal data processed by PSA.

  2. The Responsible Person shall take responsibility for PSA’s ongoing compliance with this policy.

  3. This policy shall be reviewed at least annually.

3. Lawful, fair and transparent processing

  1. To ensure its processing of data is lawful, fair and transparent, PSA shall maintain a Register of Systems.

  2. The Register of Systems shall be reviewed at least quarterly.

  3. Individuals have the right to access their personal data and any such requests made to PSA shall be dealt with in a timely manner.

4. Lawful purposes

  1. All data processed by PSA must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests

  2. PSA shall note the appropriate lawful basis in the Register of Systems.

  3. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in  consent shall be kept with the personal data.

  4. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in PSA’s systems.  

5. Data minimisation

  1. PSA shall ensure that all personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

  2. For the business users of its application, PSA shall ensure that all personal data collected is only used for, and adequate enough to, serve the purposes of authentication and prevent the misuse or unlawful access of any personal data.

6. Accuracy

  1. PSA shall take reasonable steps to ensure all personal data is accurate.

  2. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.

  3. PSA shall ensure that data in its Fan Management System is kept up to date and any inaccuracy is rectified promptly.

7. Removal

  1. PSA ensure that fan and business user data is not kept beyond the time it serves its necessary purpose and all processes and systems involved with data collection and processing will be reviewed quarterly.

  2. PSA shall ensure that personal data about the business users of its Fan Management System is removed once they stop using it.

  3. PSA shall ensure that Fan Data will be removed immediately should a fan opt-out of sharing information.

8. Security

  1. PSA shall ensure that personal data is stored securely using modern software that is kept-up-to-date.  

  2. Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.

  3. When personal data is deleted this should be done safely such that the data is irrecoverable.

  4. Appropriate back-up and disaster recovery solutions shall be in place.

9. Breach

In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, PSA shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the PDPC (https://www.pdpc.gov.sg).

 

END OF POLICY

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