Privacy Policy
Spine Privacy Policy Contents
- Important information and who we are.
- The data we collect about you.
- How is your personal data collected?
- How we use your personal data.
- Disclosures of your personal data.
- International transfers.
- Data security.
- Data retention.
- Your legal rights.
Privacy Policy
Welcome to Ultra Endurance Series limited (trading as “SPINE”)’s privacy policy.
Ultra Endurance Series limited (trading as “SPINE”) respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.
1. Important information and who we are
This privacy policy aims to give you information on how Ultra Endurance Series limited (trading as “SPINE”) (“Spine”, “we”, “us” or “our” in this privacy policy) collects and processes your personal data however that is provided to us, including any data you may provide through this website, when you sign up or agree to receive marketing or provide other personal data should you take part in our races or events.
This website is not intended for children, and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy 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 policy supplements other notices and privacy policies and is not intended to override them.
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise any of your legal rights in respect of your personal data, please contact the data privacy manager, at this email address theinfo@spinerace.com or at this postal address 68 West Street, Barnsley, South Yorkshire, S70 5DJ, UK.
While you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk), we would appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy policy and your Personal data
We keep our privacy policy under regular review. 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
This website 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 website, we encourage you to read the privacy policy 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 you which we have grouped together as follows:
- Identity Data includes first name, last name, username or similar identifier, title, date of birth and gender.
- Contact Data includes billing address, home address, email address and telephone numbers.
- Health Data includes all medical and health data you may provide at any time during your communications with us and any participation in a race, which may include (without limitation) copy documents, letters, diagnoses or medication prescriptions. This is “special category personal data” and we will comply with all requirements of the data protection legislation in relation to our collection and/or processing of special category personal data.
- Medical Research Data includes all Health Data, details of your previous experience in our races or similar events, the training you carry out before a race, any illnesses or injuries you sustain prior to or during a race, and your performance in a race. This is “special category personal data” and we will comply with all requirements of the data protection legislation in relation to our collection and/or processing of special category personal data.
- Transaction Data includes details about payments to and from you and other details relating to race entries you have paid for in part or whole, including any staged payment arrangements.
- Technical Data includes internet protocol (IP) address, your login data, 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.
- Profile Data includes your username and password, races entered by you, your interests, preferences, information about how you use our website, products and services and any feedback you provide.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Special Category Personal Data: While we do not target collection of personal data relating to your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, genetic or biometric data, we may during our interactions with you incidentally collect or process such “special category personal data”. If we do so, we will comply with the additional requirements under data protection legislation which includes additional protection for special category personal data, as we must in relation to all Health Data we collect and process about you.
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.
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 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, Health and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
Create an account on our website;
Enter a race;
subscribe to our service or publications;
request marketing to be sent to you;
give us feedback or contact us.
Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs or other similar technologies. Please see our cookie policy for further details.
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. Performance of Contract means processing 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
- Where we have your consent to the use of your personal data (or your express consent for certain uses of special category personal data). Consent is when you have given your express consent to a proposed sharing or processing of your personal data.
- Where it is necessary for your (or a third party’s) vital interests. Vital interests means that there is a threat to life, or serious threat to the safety, of one or more individuals.
- 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 the interest of our business in conducting and managing our business to enable us to give you the best service and the best and 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.
- Where we need to comply with a legal obligation. Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
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 including basis of legitimate interest |
| To register you as a new customer | (a) Identity (b) Contact | Performance of a contract with you or in preparation of a contract |
| To process and deliver your race entry including: (a) Register you for the race and update you about requirements or information relating to the race (b) Manage payments, fees and charges, set up payment plan and collect and recover money owed to us | (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
| To manage our relationship with you which will include: (a) Notifying you about changes to the race information about the race you have entered , our terms or privacy policy (b) Asking you to leave a review or take a survey | (a) Identity (b) Contact (c) Profile (d) Marketing and 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 customers use our products/services) |
| To manage, support and supervise the race event, to prepare and plan the race event, to support the safety, health and wellbeing of participants in a race. To provide the medical support/ first aid /emergency support required at a race event/ administer medical treatment | Identity Contact Health and other special category personal data | Performance of a contract legitimate interests (to ensure our race event is compliant and prepared) To comply with a legal requirement. Consent Vital interests |
| To enable you to partake in a competition or complete a survey | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical | (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 deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications (f) Technical | Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | (a) Technical (b) Profile | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
| To carry out research and development to: support and improve the safety, health and wellbeing of participants in our races, improve our website, products/services and marketing. | Identity Health Medical Research and other special category data (which may be pseudonimised) | Consent (explicit consent) Necessary for our legitimate interests (to improve health and safety and to inform our marketing strategy) Vital interests |
| To make suggestions and recommendations to you about goods or services that may be of interest to you | (a) Identity (b) Contact (c) Technical (d) Profile (e) Marketing and Communications | Necessary for our legitimate interests (to develop our products/services and grow our business) |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your Identity, Contact, Technical 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 or entered a race with us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any by following the opt-out links on any marketing message sent to you or by contacting us at any time on our email.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product or service purchase and experience, or other transactions.
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 share your personal data with the parties set out below for the purposes set out in the table above.
- Medical staff who are not our employees but who provide emergency or first aid or other medical support services before, during or after a race you have entered.
- Third-party payment providers such as but not limited to Stripe
- Our professional advisors for legal or tax reasons, where this is required for the management and compliance of our business.
- 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 policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law and enter into data processing or data sharing agreements with these third parties as required by law. As a result, 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. International Transfers
When you participate in a race that is held overseas, we will have to share your personal data with certain third parties (most likely to be our own medical support staff and doctors supporting the race). As these individuals or service providers are not our own employees, this involves the processing of your personal data (and in some instances your Health Data and perhaps some additional special category data) by a third party (the medical staff or doctors providing the support, for example).
Usually the personal and special category data will be provided as a matter of course, to certain services of individuals on a need to know only basis and will be provided on hard copy format (print outs of the records we hold in the UK about you in relation to your participation in the race). We will provide the print outs in a file for reference by the medical staff and other support staff when it is relevant and necessary and will request the return of the documents when they are no longer in use. Only where they are in use on the basis of “vital interest” of you or a third party might, will the documents be made freely available to any other third parties (although only third parties directly involved or where there is a legal justification for the processing of the personal data and the special category data (including Health Data).
It is unlikely that we will provide the personal data or the special category personal data to any third parties outside of the UK or EEA in electronic format. In the event of change, this privacy policy will be updated and in the event of a change affecting your race, we will notify you of the change.
7. 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.
8. Data retention
How long will you use my personal data for?
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. Usually, we retain personal data records for up to seven years after our last contact with you (in order to meet legal and accounting requirements).
In some circumstances you can ask us to delete your data and 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.
9.Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
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 (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 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:
- 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.
- 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. Not that this right only applies to automated 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 you 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.
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 could 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.