Last updated May 2018

INTRODUCTION

Welcome to the privacy policy (the “Privacy Policy”) of The All England Lawn Tennis & Croquet Club which is made up of the following different legal entities:

THE ALL ENGLAND LAWN TENNIS & CROQUET CLUB LIMITED (company number 07546718) of The All England Lawn Tennis Club, Church Road, Wimbledon, London, SW19 5AE;

THE ALL ENGLAND LAWN TENNIS CLUB (CHAMPIONSHIPS) LIMITED (company number 07546773) of The All England Lawn Tennis Club, Church Road, Wimbledon, London, SW19 5AE;

THE ALL ENGLAND LAWN TENNIS GROUND PLC (company number 00168491) of Church Road, Wimbledon, London, SW19 5AE;

THE ALL ENGLAND LAWN TENNIS CLUB (WIMBLEDON) LIMITED (of company number 01429062) of All England Club Church Road, Wimbledon, London, SW19 5AE; and

THE WIMBLEDON FOUNDATION (of company number 08559364) of The All England Lawn Tennis Club, Church Road, Wimbledon, London, SW19 5AE,

(collectively, the “AELTC Group”).

This Privacy Policy is issued on behalf of the AELTC Group so when We refer to “We”, “Us” or “Our” in this Privacy Policy, We are referring to the relevant company in the AELTC Group responsible for processing your data.

We respect your privacy and are committed to protecting your personal data. This Privacy Policy will inform you as to how We look after your personal data when you visit Our websites at:

www.wimbledon.com

• players.wimbledon.com

• media.wimbledon.com

• roadtowimbledon.com

• shop.wimbledon.com

• aeltc.com/debentures

• aeltc.com/members

• aeltc.com/wjti

• aeltc.com/bbg

• hospitalityatwimbledon.com

• communitytennis.aeltc.com

• bookings.wimbledon.com

and/or any of the other websites we operate and the official The Championships, Wimbledon App (collectively the “Site”), regardless of where you visit it from, and tell you about your privacy rights and how the law protects you.

This Privacy Policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the GLOSSARY to understand the meaning of some of the terms used in this Privacy Policy.

1 IMPORTANT INFORMATION AND WHO WE ARE

2 THE DATA WE COLLECT ABOUT YOU

3 HOW IS YOUR PERSONAL DATA COLLECTED?

4 HOW WE USE YOUR PERSONAL DATA

5 DISCLOSURES OF YOUR PERSONAL DATA

6 INTERNATIONAL TRANSFERS

7 DATA SECURITY

8 DATA RETENTION

9 YOUR LEGAL RIGHTS

10 GLOSSARY



1 IMPORTANT INFORMATION AND WHO WE ARE

1.1 PURPOSE OF THIS PRIVACY POLICY

(a) This Privacy Policy aims to give you information on how We collect and process your personal data through your use of the Site, including any data you may provide as detailed in paragraph 3.1 below.

(b) We may collect data relating to children for the reasons detailed in paragraph 4.4 below. For more information on our policy on children’s personal data, please see paragraph 4.12.

(c) It is important that you read this Privacy Policy 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 Policy supplements the other notices and is not intended to override them.

1.2 CONTROLLERS

(a) Each of companies of the AELTC Group (as listed above) are joint controllers.

(b) THE ALL ENGLAND LAWN TENNIS CLUB (CHAMPIONSHIPS) LIMITED which is part of the AELTC Group is responsible for the Site.

(c) We have appointed a data protection officer (the “DPO”) 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 your legal rights, please contact the DPO using the following details:

Full name of legal entity: THE ALL ENGLAND LAWN TENNIS CLUB (CHAMPIONSHIPS) LTD
Name or title of DPO: Data Protection Officer
Email address: data.information@aeltc.com
Postal Address: AELTC, Church Road, Wimbledon, London, SW19 5AE

(d) You have the right to make a complaint at any time to the Information Commissioner’s Office (the “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.

1.3 CHANGES TO THE PRIVACY NOTICE AND CHANGES TO YOUR PERSONAL DATA

(a) The data protection law in the UK will change on 25 May 2018. Although this Privacy Policy sets out most of your rights under the new laws, We may not yet be able to respond to some of your requests (for example, a request for the transfer of your personal data) until 25 May 2018 as We are still working towards getting Our systems ready for some of these changes.

(b) 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. www.wimbledon.com/contact

1.4 THIRD - PARTY LINKS

The Site may include links to third-party websites, plug-ins and applications. Clicking on those links [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 tthe Site, We encourage you to read the privacy policy of every website you visit.

2 THE DATA WE COLLECT ABOUT YOU

2.1 Personal data, or personal information, means information relating to an identified or identifiable living individual. It does not include data where the identity of the individual to whom it relates has been removed (anonymous data).

2.2 As further detailed in the table at paragraph 4.4(a), We may collect, use, store and transfer different kinds of personal data about you which We have grouped together as follows:

(a) “Identity Data” includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, photographs, vehicle registration number(s), age and gender.

(b) “Contact Data” includes billing address, residential address, delivery address, email address, social media handles and telephone numbers.

(c) “Financial Data” includes bank account and payment card details. 4

(d) “Transaction Data” includes details about payments to and from you and other details of products and services you have purchased from us.

(e) “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, full 'Uniform Resource Locators' clickstream to, through and from the Site (including date and time) and other technology on the devices you use to access the Site.

(f) “Profile Data” includes your username and password, purchases or orders made by you, your interests, preferences, relationships held with other data subjects, feedback and survey responses, products you viewed or searched for; page response times; download errors; length of visits to certain pages; page interaction information (such as scrolling, clicks, mouse-overs and methods used to browse away from the page).

(g) “Usage Data” includes information about how you use the Site, products and services.

(h) “Marketing and Communications Data” includes your preferences in receiving marketing from us and Our third parties and your communication preferences.

2.3 As further detailed in the table at paragraph 4.4(a), We also 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 relate to an identified or identifiable living individual, in other words it is not possible to tie it to you. . For example, We may aggregate your Usage Data to calculate the percentage of users accessing a specific Site 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 Policy.

2.4 As further detailed in the table at paragraph 4.4(a), We may also collect personal data that includes “Sensitive Data” , such as dietary requirements and certain medical information (including whether or not you are a wheelchair user).

2.5 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?

3.1 As further detailed in the table at paragraph 4.4(a), We use different methods to collect data from and about you including through:

(a) Direct interactions. You may give Us your Identity Data, Contact Data 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:

(i) apply for and/or purchase Our products or services;

(ii) sign up to hear from Us via email, phone and mail;

(iii) create an account on the Site;

(iv) subscribe to Our service or publications;

(v) request marketing to be sent to you; 5

(vi) apply for and/or purchase tickets;

(vii) participate in some capacity at The Championships, Wimbledon and/or year-round at Our premises;

(viii) join MyWimbledon;

(ix) utilise membership services and benefits;

(x) sign up to Our educational programmes;

(xi) interact with the Wimbledon Foundation;

(xii) book tickets for our museum or tours;

(xiii) enter a competition, promotion or survey; or

(xiv) give us some feedback.

(b) Automated technologies or interactions. As you interact with the Site, 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. We may also receive Technical Data about you if you visit other websites employing Our cookies. Please see Our cookie policy (the “Cookie Policy”) for further details.

(c) Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources such as [analytics providers, advertising networks, technical, payment and delivery services, data brokers or aggregators] and publicly availably sources such as Companies House and the Electoral Register based inside the EU. Please Contact Us to find out more about the various third parties and public sources from which We may receive personal data about you.

4 HOW WE USE YOUR PERSONAL DATA

4.1 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:

(a) Where We need to perform a contract We are about to enter into or have entered into with you.

(b) 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.

(c) Where We need to Comply with a Legal Obligation.

4.2 Please Contact Us to find out more about the types of lawful basis that We will rely on to process your personal data.

4.3 Generally, We do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by Contacting Us.

4.4 PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

(a) 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.

(b) Note that We may process your personal data for more than one lawful ground depending on the specific activity for which We are using your data. In carrying out each activity, we may process your data for a number of different purposes. Please Contact Us if you need more detail about the specific legal ground We are relying on to process your personal data.

To manage Our relationship with you which will include: (a) Notifying you about changes to Our terms or Privacy Policy​(a) Performance of a Contract with you (b) Necessary to Comply with a Legal Obligation (c) Necessary for Our Legitimate​
Activity Type of data

Lawful basis for processing

including basis of Legitimate

interest

Retention Period
To apply for tickets to
The Championships,
Wimbledon

(a) Identity Data

(b) Contact Data

(c) Financial Data

(d) Transaction Data

(e) Marketing and Communications Data

(f) Sensitive Data

(a) Performance of a Contract with you

(b) Necessary for Our Legitimate Interests (to facilitate your application)

5 years from last application
To sign up to MyWimbledon and register you as a new customer (not otherwise dealt with in this table)

(a) Identity Data

(b) Contact Data

(c) Marketing and Communications Data

(a) Performance of a Contract with you

(b) Necessary for Our Legitimate Interests (to facilitate your registration with MyWimbledon)

5 years from last registration as a customer or last interaction with Us as a customer, whichever is later

To process and deliver your order (including tickets and food and drink at The Championships, Wimbledon) including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to Us

(a) Identity Data

(b) Contact Data

(c) Financial Data

(d) Transaction Data

(e) Marketing and Communications Data

(f) Sensitive Data

(a) Performance of a Contract with you

(b) Necessary for Our Legitimate Interests (to recover debts due to Us)

5 years from order completion

To manage Our relationship with you which will include:

(a) Notifying you about changes to Our terms or Privacy Policy

(b) Asking you to leave a review or take a survey

(a) Identity Data

(b) Contact Data

(c) Profile Data

(d) Marketing and Communications Data

(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)

5 years from last correspondence

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity Data

(b) Contact Data

(c) Profile Data

(d) Usage Data

(e) Marketing and Communications Data

(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)

5 years from prize draw, competition or survey

To administer and protect Our business and the Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity Data

(b) Contact Data

(c) Technical Data

(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

5 years from collection of data

To deliver relevant Site content and advertisements to you and measure or understand the effectiveness of the advertising We serve to you

(a) Identity Data

(b) Contact Data

(c) Profile Data

(d) Usage Data

(e) Marketing and Communications Data

(f) Technical Data

(a) 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)

5 years from collection of data

To use data analytics to improve the Site and Our products/services, marketing, customer relationships and experiences

(a) Technical Data

(b) Usage Data

(a) Necessary for Our Legitimate Interests (to define types of customers for Our products and services, to keep the Site updated and relevant, to develop Our business and to inform Our marketing strategy)

5 years from last interaction

To make suggestions and recommendations to you about goods or services (including debentures) that may be of interest to you

(a) Identity Data

(b) Contact Data

(c) Technical Data

(d) Usage Data

(e) Profile Data

(a) Consent (to send you information about Our products/services)

For more information about how we market to you, please see paragraphs 4.6 to 4.9 below.

5 years from last interaction

To facilitate and publish the results of Our events

(a) Identity Data

(b) Profile Data

(a) Legitimate Interests (We need the ability to publish and store the results, challenge results after the specific Event and keep a historic log of this data all for the purpose of staging the event(s) and for archival and historic research).

In perpetuity

To televise, film and/or otherwise record Our events and to take photographs and record footage of Our events

(a) Identity Data

(a) Legitimate Interests (We need the ability to publish, display, sell and distribute Our events by means of film, television, radio, print media, internet, publicity material or any other media now or in the future).

In perpetuity

To invite you to participate, and for you to participate, in Our Hospitality

(a) Identity Data

(b) Contact Data

(c) Marketing and Communications Data

(a) Performance of a Contract with you.

(b) Legitimate Interests (We need this data to be able to give you the option to attend, and to provide you with, high-quality hospitality).

5 years since the last invitation or purchase, whichever is later

To volunteer for Our events (including ball boys and girls)

(a) Identity Data

(b) Contact Data

(c) Profile Data

(d) Marketing and Communications Data

(e) Sensitive Data

(a) Performance of a Contract with you

(b) Legitimate Interests (We need this data to be able to allow you to participate in Our events and to stage Our events).

(c) Necessary to Comply with a Legal Obligation (including security and safety at Our events and tax purposes).

5 years since your last application to volunteer

To be included on Our media lists

(a) Identity Data

(b) Contact Data

(c) Marketing and Communications Data

(a) Legitimate Interests (We need this data to be able to enable Our events to be covered in the media).

5 years

To be a partner, sponsor or supplier or potential partner, sponsor or supplier of or to Us or Our events

(a) Identity Data

(b) Contact Data

(c) Financial Data

(d) Transaction Data

(e) Marketing and Communications Data

(a) Performance of a Contract with you (as Our partner, sponsor or supplier)

(b) Legitimate Interests (We need this data to be able to contact you about becoming a partner, sponsor or supplier to allow you to become officially associated with Us or Our event(s)).

(c) Necessary to Comply with a Legal Obligation (including for tax purposes).

5 years after the end of any contract (if any) or 6 years from the last correspondence about being a potential partner, sponsor or supplier

To be a medical professional including doctor, podiatrist and physiotherapist at one of Our events

(a) Identity Data

(b) Contact Data

(c) Marketing and Communications Data

(a) Performance of a Contract with you

(b) Legitimate Interests (We need this data to be able to allow you to provide your services at Our events, to ensure that you are adequately qualified and to ensure that We have the requisite number of medical professionals at Our events).

5 years from the date of the last event you assisted with

To attend one of Our events in any capacity that requires photographic accreditation (not otherwise dealt with in this table)

(a) Identity Data

(b) Contact Data

(c) Sensitive Data

(a) Legal Obligation

(b) Performance of a Contract with you

(c) Legitimate Interests (We need this for security reasons).

5 years after the last time you were accredited

To participate in our events if you are under 13 years of age

(a) Identity Data

(b) Contact Data

(a) Consent (parental consent either obtained by Us or via a third party, please see paragraph 4.12).

(b) Please note that we will rely on Legitimate Interests upon the individual turning 13 years of age (to allow such individual to participate in Our events)

5 years from last participation

For The Wimbledon Foundation to receive grant applications

(a) Identity Data

(b) Contact Data

(c) Transaction Data

(a) Legitimate Interests (We need this data to analyse the applicants (for example, by area and type of project), and to track an applicant’s record with Us since they may reapply).

5 years from last application

For The Wimbledon Foundation to allocate grants

(a) Identity Data

(b) Contact Data

(c) Financial Data

(d) Transaction Data

(a) Performance of a Contract with you

(b) Legitimate Interests (We need this data to ensure that each grantee continues to comply with the grant conditions and to analyse the applicants (for example, by area and type of project).

(c) Necessary to Comply with a Legal Obligation (charity laws and regulations concerning the grant)

5 years or until the conditions attached to any grant expire, whichever is later

To sign up to the Wimbledon Junior Tennis Initiative (“WJTI”)

(a) Identity Data

(b) Contact Data

(c) Transaction Data

(d) Marketing and Communications Data

(e) Profile Data

(a) Performance of a Contract with you

(b) Necessary for Our Legitimate Interests (to facilitate your application)

(c) Consent (parental consent if you are under the age of 13)

3 years from last registration / renewal with WJTI or last interaction with Us as a WJTI member, whichever is later

To sign up to the AELTC Community Sports Ground (“CSG”)

(a) Identity Data

(b) Contact Data

(c) Financial Data

(d) Transaction Data

(e) Marketing and Communications Data

(f) Profile Data

(a) Performance of a Contract with you

(b) Necessary for Our Legitimate Interests (to facilitate your application)

(c) Consent (parental consent if you are under the age of 13)

2 years from last booking or last interaction as a CSG member with Us as a WJTI member, whichever is later

To be a member of the All England Lawn Tennis Club

(a) Identity Data

(b) Contact Data

(c) Financial Data

(d) Transaction Data

(e) Marketing and Communications Data

(f) Profile Data

(a) Performance of a Contract with you

(b) Necessary for Our Legitimate Interests (to deliver the membership benefits to you)

5 years after expiry or termination of membership

To facilitate services for debenture holders

(a) Identity Data

(b) Contact Data

(c) Financial Data

(d) Marketing and Communications Data

(a) Performance of a Contract with you

(b) Necessary for Our Legitimate Interests (to deliver the debenture benefits and services to you)

(c) Necessary to Comply with a Legal Obligation (inheritance and tax purposes)

Until all payments have been made to the holder pursuant to the debenture or 10 years from the date that the individual last held the debenture, whichever is later.

To participate as a competitor in any of Our events

(a) Identity Data

(b) Contact Data

(c) Transaction Data

(d) Technical Data

(e) Profile Data

(f) Marketing and Communications Data

(g) Sensitive Data

(a) Performance of a Contract with you

(b) Legitimate Interests (We need this data to be able to allow you to participate in Our events and to stage Our events).

(c) Necessary to Comply with a Legal Obligation (prize money and tax purposes)

15 years from last competition in which the competitor took part

To allow you to use the Wi-Fi at Our premises

(a) Identity Data

(b) Contact Data

(c) Marketing and Communications Data

(d) Profile Data (e) Technical Data (f) Usage Data

(a) Performance of a Contract with you

(b) Legitimate Interests (We need this data to provide a Wi-Fi service to those who have signed up to MyWimbledon which includes storage of Identity Data so that individuals do not have to sign in multiple times throughout The Championships and to analyse and improve Wi-Fi for future Championships).

6 months from the last day of The Championships during which the individual accessed Wi-Fi

4.5 AUTOMATED DECISION MAKING

We use your personal data to make the following automated decisions:

(a) Ticket Ballots: All ticket applications received via one of Our ballots (including paper ballots received through the post) are processed electronically. Each application is uploaded to Our database (in the case of paper ballots, uploading is done manually), and Our database then automatically assigns a hidden, protected reference number. Each day a certain number of successful applications are automatically selected at random;

(b) MyWimbledon: If you sign-up for a MyWimbledon account, We use automated decision making to provide recommendations based on your chosen preferences and other information we know about you (including your age, gender, purchases and use of our Site); and

(c) Competitions: We may, from time to time, run competitions where each participant’s personal data is uploaded to Our database and a successful participant is automatically selected at random.

4.6 MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

4.7 PROMOTIONAL OFFERS FROM US

We will get your express opt-in consent before We use your Identity Data, Contact Data, Technical Data, Usage Data and/or Profile Data to contact you about goods or services that may be of interest to you (We call this marketing).

4.8 THIRD-PARTY MARKETING

We will get your express opt-in consent before We share your personal data with any company outside the AELTC Group for marketing purposes.

4.9 OPTING OUT

You can ask Us to stop sending you marketing messages at any time using the unsubscribe links in Our emails. You can check or uncheck relevant boxes to adjust your marketing and communications preferences by following the opt-out links on any marketing message sent to you or by Contacting Us at any time.

4.10 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 the Site may become inaccessible or not function properly. For more information about the cookies We use, please see Our Cookie Policy.

4.11 CHANGE OF PURPOSE

(a) 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.

(b) 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. 13

(c) 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.

4.12 CHILDREN’S DATA

(a) We may collect and process the personal data of children below the age of 13 for the purposes of administering the following areas of our business, in which case we will always ensure that consent is given or authorised by the holder of parental responsibility over that child:

(i) WJTI;

(ii) AELTC Junior Members; and

(iii) Community Sports Ground Junior Members.

5 DISCLOSURES OF YOUR PERSONAL DATA

5.1 We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4.4 above.

(a) Internal Third Parties

(b) External Third Parties

(c) Specific third parties listed in the table in paragraph 4.4 above.

(d) 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.

5.2 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 INTERNATIONAL TRANSFERS

6.1 Many of Our external third parties are based outside the European Economic Area (the “EEA”) so their processing of your personal data will involve a transfer of data outside the EEA. Such destinations may not have laws which protect your information to the same extent as in the EEA.

6.2 Whenever We, or a third party to whom we transfer your personal data, transfers your personal data out of the EEA, We ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

(a) your personal data is transferred to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries;

(b) specific contracts approved by the European Commission are put in place which give personal data the same protection it has in the EU. For further details, see European Commission: Model contracts for the transfer of personal data to third countries; or

(c) where your personal data is transferred to third party providers based in the US, data may be transferred to them if they have self-certified under the Privacy Shield framework in relation to the type of data being transferred, which requires them to provide similar protection to personal data 14 shared between the EU and the US. For further details, see European Commission: EU-US Privacy Shield.

6.3 Please Contact Us if you want further information on the countries to which personal data may be transferred and the specific mechanism used by Us when transferring your personal data out of the EEA.

7 DATA SECURITY

7.1 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 and who are subject to a duty of confidentiality. They will only process your personal data on Our written instructions.

7.2 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

8.1 HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

8.2 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.

8.3 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.

8.4 Details of retention periods for different aspects of your personal data are set out in the table in paragraph 4.4 above.

8.5 By law We have to keep basic information about Our customers (including Contact Data, Identity Data, Financial Data and Transaction Data) for seven years after they cease being customers for tax purposes.

8.6 In some circumstances you can ask Us to delete your data: see request erasure below for further information.

8.7 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.

9 YOUR LEGAL RIGHTS

9.1 Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

(a) Request access to your personal data

(b) Request correction of your personal data

(c) Request erasure of your personal data

(d) Object to processing of your personal data

(e) Request restriction of processing your personal data 15

(f) Request transfer of your personal data

(g) Right to withdraw consent

9.2 If you wish to exercise any of the rights set out in paragraph 9.1 above, please Contact Us.

9.3 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.

9.4 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.

9.5 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 necessary taking into account the complexity and number of requests. In this case, We will notify you within one month of receipt of your request and keep you updated.

10 GLOSSARY

10.1 LAWFUL BASIS

(a) “Legitimate Interest” means the interest of Our business in conducting and managing Our business to enable Us to give you the best service/product 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. Where we rely on the legitimate interests basis to process your personal data, We do not use your personal data for activities where Our interests are overridden by the impact on you. 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.

(b) “Performance of a 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.

(c) “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.

10.2 THIRD PARTIES

(a) INTERNAL THIRD PARTIES

Other companies in the AELTC Group acting as joint controllers who use your personal data and who are based in the United Kingdom.

(b) EXTERNAL THIRD PARTIES:

(i) Service providers using your personal data on our behalf provide various services such as event entry, entry management and supporting services, services with respect to the dissemination of photos and footage, facilitation services for graphical representation of 16 results, data analysis services, publication of race results services and IT and system administration services. Please Contact Us to find out more about the various third parties who may process your personal data.

(ii) Professional advisers, including lawyers, bankers, auditors and insurers based in the United Kingdom who use your personal data to provide consultancy, banking, legal, insurance and accounting services to us.

(iii) HM Revenue & Customs, regulators and other authorities based in the United Kingdom who use your personal data and require reporting of our use of your personal data in certain circumstances.

(iv) Third party tennis bodies and affiliations such as:

(A) The Tennis Integrity Unit to facilitate its role as the anti-corruption body covering all professional tennis around the world; and

(B) The LTA, WTA and ATP as governing bodies for tennis.

(v) Broadcasters such as the BBC to allow them to broadcast, and commentate on, Our events.

10.3 YOUR LEGAL RIGHTS

You have the right to:

(a) Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive certain information in relation to the processing of your personal data and a copy of the personal data We hold about you and to check that We are lawfully processing it.

(b) 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.

(c) 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.

(d) 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.

(e) 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. 17

(f) Request the transfer of your personal data to you or, where technically feasible, to a third party. We will provide to you, or a third party you have chosen, the personal data provided to us by you in a structured, commonly used, machine-readable format. Note that this right only applies where the personal data is processed using automated means and where the processing relies on your consent for Us to use your personal data or where the processing of the personal data is necessary to perform a contract with you.

(g) 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.