Privacy Policy

1. INTRODUCTION

​

This Privacy Policy ("Privacy Policy") is part of the Lokkaroom Service Terms URL ("Lokkaroom Service Terms") for the use of:

​

1. the Lokkaroom software application or any related software application (“Apps”);

2. the Lokkaroom website https://lokkaroom.com and/or any sub-website and/or associated domains (and/or sub-domains) of https://www.lokkaroom.com (the "Site");

3. the services available via the Apps and the Site ("Services").

​

The Apps, Site and Services are provided in or from the United Kingdom ("UK") by TMA Sports Management Limited and its subsidiaries, whether direct or indirect (hereinafter collectively referred to as "We", "Us", "Our", "Lokkaroom" and/or "TMA Sport"), to each of our customers ("You", "Your" and "User").

We decide the purposes and means of processing of personal data that is collected about you when you deal with us. We are committed to protecting and respecting your privacy and we have legal obligations to do so as the ‘controller’ of your personal data under the Data Protection Act 2018 (the "Act").

This Privacy Policy explains the types of personal data collected, the purposes for which it is collected and processed, the legal basis for that, the organisations or types of organisations with whom we may share your personal data, and detailed information about Your various rights relating to your personal data and how to exercise them.

We are committed to protecting Your privacy and handling your information in an open and transparent manner.

We strongly encourage You to read this Privacy Policy with care.

It is necessary for you to agree to the "Lokkaroom Service Terms", including this Privacy Policy, and for us to collect, process, share and store the personal data as described, in order for us to be able to transact and communicate with you, and interact with you via the Apps and the Site and provide the Service.

The Apps and Site may from time to time contain links to and from the websites of partner networks, advertisers and affiliates. If you follow a link to any of those websites, please note that those websites have their own privacy policies and we do not accept any responsibility or liability for those policies. Please check those policies and any relevant service terms and conditions before you submit any personal data to those websites. We are not responsible for the content of any other websites or services. Please contact us  for any clarification You may need.

​

​

​

2. PERSONAL DATA WE COLLECT

 

We may collect, store and use the personal data described in the table in Annex A to this Privacy Policy, and process it for the purposes and on the legal basis specified in that table. We explain the purposes of processing further in Clause 3 below. You will see in that table that we most commonly use your personal data on the following legal grounds:

​

• Where we need to perform an obligation under a contract with you, such as the Lokkaroom Service Terms, or take steps at your request before agreeing a contract with you;

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights that require the protection of personal data do not override those interests;

• Where we need to comply with a legal or regulatory obligation; and

• Where you have consented before the processing.

​

Personal data will be stored in accordance with Clause 5 of this Privacy Policy. We aim to keep your personal information up-to-date, so you must promptly tell us by contacting us if you change your name, residential address or contact details.

​

​

​

3. WHAT WE USE YOUR PERSONAL DATA FOR (PURPOSE OF PROCESSING)

 

We explain the purposes for which we use each type of your personal data in the middle column of the table in Annex A to this Privacy Policy.

Should We need to process Your data for a new purpose in the future, which is entirely unrelated to the above, We will inform You of such processing in advance and You may exercise Your applicable rights (as explained below) in relation to such processing. Finally, do note that without certain Personal Data relating to You, We may not be in the position to provide some or all of the services You expect from Us or even to guarantee the full functionality of Our Site and/or Apps.

​

​

4. ACCURACY OF PERSONAL DATA

​

All reasonable efforts are made to keep any Personal Data We may hold about You up-to-date and as accurate as possible. You must ensure that the information you give Us is always accurate and up to date. We may ask You at any time to confirm the accuracy of Your information or to provide documents or other evidence verifying such information. You can check the information that We hold about You at any time by contacting Us in the manner explained below. If You find any inaccuracies, We will correct them and where required, delete them as necessary. Please see below for a detailed list of Your legal rights in terms of any applicable Data Protection Laws.

​

​

5. MARKETING AND ADVERTISING

 

We give you choices about what marketing and advertising you see on the Site. We will give you a choice to opt-in to receiving marketing and advertising specifically tailored for you.

We use personal data you have provided to us, and responses to our survey questions, for our loyalty programme and to work out if certain advertising and marketing will be of interest to you. We may use an automated process to create a profile for you.

You can ask us to stop profiling you and sending you any targeted marketing or advertising messages on the Site or via the Apps at any time by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us. Further information on your rights and how to exercise them is included in clause 14 and the table in Annex B.

​

​

6. TRANSFERS TO THIRD COUNTRIES

 

As a general principle, the Personal Data We process about You (collected via any of our Sites or Apps or otherwise) will be stored and processed within the UK.

In some cases, it may be necessary for Us to transfer Your Personal Data to (EU)/European Economic Area (EEA) or any other non-EEA country deemed by the Information Commissioner’s Office (ICO) to offer an adequate level of protection.

In some cases, it may be necessary for Us to transfer Your Personal Data to a non-EEA country not considered by the ICO to offer an adequate level of protection. In such cases, apart from all appropriate safeguards that We implement, in any case, to protect Your Personal Data, We have put in place additional adequate measures. For example, We will ensure that the recipient is bound by the UK Standard Contractual Clauses designed to protect Your Personal Data. You are welcome to contact Us for more information regarding the adequate safeguards we have in place in relation to such data transfers.

​

​

7. INTERNET COMMUNICATIONS

 

You will be aware that data sent via the Internet may be transmitted across international borders even where the sender and receiver of information are located in the same country. We cannot be held responsible for anything done or omitted to be done by You or any third party in connection with any Personal Data prior to Our receiving it including but not limited to any transfers of Personal Data from You to Us via a country having a lower level of data protection than that in place in the UK, and this, by any technological means whatsoever. Moreover, We shall accept no responsibility or liability whatsoever for the security of Your data while in transit through the internet unless Our responsibility results explicitly from a law having effect in UK.

​

​

8. SHARING OF PERSONAL DATA WITH OTHER CATEGORIES OF RECIPIENTS

 

We will not disclose your personal data to any third party, except as explained in the table in Annex A to this Privacy Policy. If some or all of our business is bought by a third party, personal data held by us will be transferred and may be disclosed to the prospective seller or buyer of such business under the same conditions as this Privacy Policy. This is necessary for the purposes of the legitimate interests pursued by us and the third party, and would not be overridden by your interests or fundamental rights and freedoms which require protection of personal data.

​

​

9. DATA STORAGE AND SECURITY

 

All information you provide to us is stored on our secure servers, located in the United Kingdom. We use all reasonable endeavours to ensure that appropriate technical and organisational measures are in place to protect your personal data from unauthorised or unlawful processing and against accidental loss, destruction or damage. Your personal data will be stored for as long as you use the Site and Apps; and for such time afterwards as required by law or six years from when you stop using the Site and Apps (which is the legal limitation period).

Please note that using the internet or mobile networks is not completely secure, so we cannot guarantee the security of your data transmitted between your device(s) and the Apps or Site. Any such transmission is at your own risk.

Where Your Personal Data is no longer required by Us, We will either securely delete or anonymize the Personal Data in question.

​

​

10. COOKIES

 

When You visit Our Site or use our Apps, We will collect certain categories of Personal Data automatically through the use of cookies and similar technologies, as detailed in Annex A.

A cookie is a small file of letters and numbers that we store on your browser, computer, or device. Cookies send information back to the originating website on each subsequent visit, or to another website which recognises that cookie. We may use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of the Site. They include, for example, cookies that enable you to log into secure accounts, use interactive features and Site.

• Analytical/performance cookies. These allow us to recognise and count the number of visitors and users and see how they use the Site. This helps us to improve the way our Site works, for example, by ensuring that users are finding what they are looking for easily.

• Functionality cookies. These are used to recognise you when you return to our Site. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

• Targeting cookies. These cookies record your visit to our Site, the pages you have visited and the links you have followed. We will use this information to make our Site and the information displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Specific Cookies Used by Lokkaroom:

• Essential Cookies;

  1. Lokkaroom will store data required to provide Site and Apps functionality, e.g. language preference.

  2. Any other services we use to establish continuity of service

• Non-Essential Cookies;

  1. Google Analytics will use statistical cookies to collect aggregated statistical data about user visits.

​

Please note that third parties (including, for example, providers of external services like web traffic analysis services) may also use cookies, over which we have no control. You should refer to their privacy policies or cookie policies for the relevant information about those cookies. You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. All browsers provide tools that allow you to control how you handle cookies by accepting, rejecting or deleting them. These settings are normally accessed via the ‘settings’, 'preferences' or 'options' menu of the browser you are using, but you could also look for a ‘help’ function or contact the browser provider. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the Site.

​

​

11. MINORS

 

Our Site, App and services are not intended to be used by any person under the age of sixteen (16) and therefore We will never intentionally collect any Personal Data from such persons. If You are under the age of consent, please consult and get Your parent’s or legal guardian’s permission to use the Site, Apps and any of Our other services. We shall consider that any Personal Data of any persons under the age of sixteen (16) received by Us, shall be sent with the proper authority from the holder of parental responsibility over the child and that the sender can demonstrate such authority at any time, upon Our request.

​

​

12. YOUR RIGHTS UNDER THE DATA PROTECTION LAWS

 

Under the Act, you have a number of rights. The first right is to receive confirmation as to whether or not any of your personal data is being processed and certain other information, as we have set out in this Privacy Policy.

The table in Annex B at the end of this Privacy Policy explains the following rights which the Act gives you in relation to your personal data, and any exceptions to those rights:

1. Right of access

2. Right to rectification

3. Right to erasure

4. Right to request the restriction of processing concerning you

5. Right to data portability

6. Right to object to processing

7. Right to ask us not to process your personal data for direct marketing purposes

8. Right not to be subject to automated individual decision-making, including profiling

​

Please note that you may exercise these rights (subject to any applicable exceptions) by contacting us.

​

WHAT WE MAY REQUIRE FROM YOU

We may need to request specific information from You to help us verify your identity and understand the nature of Your complaint or request, to confirm Your identity and ensure Your right to access the information (or to exercise any of Your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Should your requests in exercising your rights be manifestly unfounded or excessive, in particular because of their repetitive nature, We reserve the right to charge You a reasonable fee which shall be determined at Our sole discretion, taking into account the administrative costs incurred by us to provide the information or communication or taking the action requested by You. We shall communicate to you in advance the fee amount that will be charged in the given circumstances.

​

HOW QUICKLY WILL WE RESPOND TO YOUR REQUEST?

In all cases, We will try to act on your requests as soon as reasonably possible, within a maximum of one month of receipt of the request, which period may be extended by two (2) more months where necessary, taking into account the complexity and number of the requests. We shall inform You of any such extension within one (1) month of receipt of the request, together with the reasons for the delay.

​

​

13. TMA SPORTS MANAGEMENT LIMITED – COMPANY DETAILS

 

TMA Sports Management Limited, a company registered in England and Wales, with company registration number 12744600 and whose registered office address is at Thrive Hubs Ltd, 25, The Crescent, Plymouth, Devon, UK, PL1 3AD, is the data controller responsible for processing Your Personal Data that takes place via the Site, our Apps or in the manner explained above.

If you have any questions/comments about privacy or should You wish to exercise any of Your individual rights, please contact Us by sending an email to the following address: info@tmasport.com with the subject "PRIVACY REQUEST" or by writing to:

‘DATA PROTECTION OFFICER
TMA SPORTS MANAGEMENT LIMITED,
THRIVE HUBS LTD, 25 THE CRESCENT,
PYLMOUTH, DEVON
UNITED KINGDOM,
PL1 3AD

​

​

14. UPDATES

 

We may amend this Privacy Policy. Any changes we may make to our Privacy Policy in the future will be posted on this page and made in accordance with Clause [xx] of changing the Lokkaroom Service Terms.

We reserve the right to unilaterally modify this Privacy Policy at any time, particularly if statutory obligations so mandate or the interest of our users’ security so requires. To let You know when we make changes to this Privacy Policy, We will amend the revision date at the top of this page. The modified Privacy Policy will apply from such revision date. We will not officially notify you about such changes, and it is therefore in Your own interest to check this Privacy Policy page from time to time so as to familiarise yourself with any changes.

​

​

15. Complaints

 

If You think that We are using Your information in a way which breaches Data Protection Laws, You have the right to lodge a complaint with the appropriate Data Protection Supervisory Authority, in the UK, this will be the Information Commissioner’s Office (IOC) which may be accessed by clicking this linkhttps://ico.org.uk. We kindly ask that You please attempt to resolve any issues You may have with Us first.

​

​

16. General

 

This Privacy Policy is governed by English law and either of us can bring legal proceedings in the courts of England and Wales in relation to any dispute arising out of or in connection with these Lokkaroom Service Terms, except that you may bring proceedings in Northern Ireland or Scotland if you are resident there.

​