VLAST Privacy Policy (UK)

Your privacy is important to us. It is our policy to respect your privacy regarding any personal data we may collect from you across our website, https://govlast.com/ , the VLAST Platform and other sites we own and operate.

VLAST is owned operated by the Pickstar Group. For the UK, the relevant entity is Pickstar Active Pathways Limited (Company Number 12676833). We may share your personal data with other companies in the Group. The PickStar Privacy Policy can be viewed here [■LINK TO PICKSTAR PRIVACY POLICY].

Pickstar Active Pathways Limited is registered as a data controller at the ICO, registration number ZA928888.

If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us via email privacy@govlast.com

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.

  1. PERSONAL DATA COLLECTED

We may collect personal data about you as part of our business of providing our website to connect our customers with current or former elite athletes for events, marketing opportunities or other engagements. The type of personal data collected will depend on how you have communicated and/or interacted with us. For example, you may provide information to us when you:

  • register an account and your profile on the VLAST Platform;
  • order services from us;
  • register engagements via our platform;
  • fill in forms on our website or make an enquiry;
  • visit or use our website;
  • tweet about us on Twitter, or like us, connect with us or contact us on Facebook or LinkedIn;
  • report an incident, make a complaint or provide other feedback to us;
  • share information with another party via our platform chat service; or
  • opt in to receiving marketing from us.

When we collect information from you, we generally do so ourselves. However, in some cases we may collect information through a third party, such as through a number of contractors who provide services to us. See section 5 for more information about our third parties providers.

The types of personal data we may collect depends upon the reason for and manner in which that information was provided by you. The types of personal data that we collect may include:

  • Account Data- your name, password, profile picture, organisation, gender.
  • Contact Data – phone number, email address.
  • Location Data- event address, location region, timezone.
  • Payment Data – Bank account details or credit card details in order to provide services to you.
  • User Generated Content – Booking request descriptions and attachments, user profiles, user reviews, user messages and any other information that you provide to us.
  • Transaction Data- details about payments to and from you.
  • Technical Data- 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 our website.
  • Usage Data-information about how you use our website and platform.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We do not collect any Special Categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

  1. HOW DO WE COLLECT YOUR DATA?

You directly provide us with most of the data we collect. We collect data and process data when you:

  • visit our website
  • fill in forms on our website or make an enquiry
  • subscribe and consent to receiving our marketing
  • use the VLAST platform as a Manager/Agent
  • use the VLAST platform as a Talent
  • as a Manager upload information on a Talent’s behalf on the VLAST platform
  • submit a booking request on our platform in draft or final format
  • voluntarily complete a lead generation form in order to enter a competition, download a whitepaper, gain access to information etc.
  • provide your details via our chat service intercom
  • request access to gated content e.g. protected sponsors

Where your personal data is processed on the basis of your consent which is then withdrawn or if you otherwise choose not to provide certain information to us, we may not be able to provide you with certain services or functionalities on the VLAST platform, or you may not be able to use certain parts of our website.

  1. HOW WE USE YOUR PERSONAL DATA

We may use the information that we collect about you for a number of purposes, depending upon the reason for and manner in which it was collected. Such purposes may include:

  • verifying your identity;
  • providing you with our services;
  • publishing and displaying your name, trademark, logo and profile on our website to enable our customers and former or current athletes registered with us to assess the suitability of any potential engagement;
  • releasing subscriber customers’ contact details to former or current athletes registered with us, and their Agents or Managers (if applicable), if the customer selects the former or current athlete to attend an engagement for the customer;
  • to respond to your questions or comments;
  • meeting our legal and regulatory obligations;
  • reporting any incidents or obtaining advice in relation thereto;
  • to help us improve or adapt our website;
  • to market and promote the VLAST platform, website and services;
  • ensuring the website and platform operate smoothly and dealing with any technical issues; and
  • to carry out market analysis and research.

We will only use your personal data in accordance with UK data protection law. 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 obligation.

Please note the personal data held by PickStar in operating the VLAST Platform will also be accessible to the partner organisation of the relevant VLAST platform.  This information may be collected and used by this partner organisation for the purposes of arranging engagements and otherwise operating its business.

For more information about the manner in which the relevant partner organisation collects, holds, uses and discloses personal data, please refer to their Privacy Policy.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us.

  1. 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.

The below table sets out some examples of our data processing activities and the lawful basis under the UK data protection laws for doing so:

Purpose/activity Type of data Lawful basis for processing
To process your VLAST Registration Account Data
Contact Data
Technical Data
User Generated Content
Your consent

Necessary for our legitimate interests (for running our business and providing our services)

To provide you with the VLAST  website and platform including the chat function Contact Data
Location Data
Your consent including when you manually input this data yourself.

Necessary for our legitimate interests (for running our business and providing our services)

Marketing, including keeping you up to date on our services or other information we think you would like to hear about Contact Data
Location Data
Marketing and Communications Data
Your consent
To manage our relationship with you including:

(a)  notifying you of changes to the VLAST platform, our terms or this Privacy Policy

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

Contact Data
Location Data
Account Data
Payment Data
User Generated Content
Transaction Data
Your consent

Performance of a contract with you

Necessary for our legitimate interests (to keep records updated and to analyse how customers use our Services).

Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)

To administer and protect our business and the platform including troubleshooting, data analysis and system testing Account Data
Contact Data
Technical Data
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)
To process purchases, bookings and delivery of our services including managing payments and collecting money owed to us

To provide a service you have requested, as a Talent, Manger or Agent.

Account Data
Contact Details
Payment Data
Technical Data
User Generated Content
Performance of a contract with you

Necessary for our legitimate interests (to recover debts due to us)

To deliver content to you

To monitor trends so we can improve the platform and our website.

Account Data
Contact Data
Technical Data
Transaction Data
Necessary for our legitimate interests (to develop our products/services and grow our business)
  1. DISCLOSURE OF PERSONAL DATA COLLECTED

We may share your personal data with the parties set out below for the purposes set out in the table above.

We may share your personal data with:

  • Our holding company Active Pathways PTY Ltd;
  • Any of our Users (see section 7) below;
  • If we are under a duty to disclose or share it in order to comply with any legal obligations (for example our auditors, legal advisors, other professional advisors, our insurers and HMRC or the relevant tax authority).
  • With third parties that may assist us in providing our services and platform;
  • With Service providers who provide IT and system administration services and software
  • our agents or contractors who provide information management or other services to us (i.e. payment facilities, security, or marketing services);
  • our professional advisers, where required for them to advise us;
  • subscriber customers, to enable them to assess the suitability of a former or current athlete registered with us, for an engagement;
  • current and former athletes registered with us, to enable them to assess the suitability of engagements offered by a subscriber customer and if the customer selects the former or current athlete to attend an engagement for the customer;
  • investors or prospective investors in our company; and
  • our staff who require the information for any of the purposes set out above.

Our third party service providers include:

  • providers who help us deliver our platform and services (Pusher, Sentry)
  • Cloud hosting, storage, networking and related providers (including One Signal)
  • SMS providers (Nexmo)

We will not sell your personal data to any third party.

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.

  1. TRANSFERS OUTSIDE THE UK

Your personal data may be held, transmitted to or processed on our behalf outside your place of residence including ‘in the cloud’, by our third party service providers in accordance with applicable law.

Whenever we transfer your personal data out of the UK and/or the EU, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
  • Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data internationally.

  1. DATA SHARING

 

Sharing between Users .

To help facilitate bookings or other interactions between Clients and Talent/Talent Managers/Agents on our platform and website, we may need to share certain information, including personal data with other users of the website and platform (“Users”), as it is necessary for the adequate performance of the contract between you and us, as follows:

  • When you as a Client submit a booking request, certain information to allow for decision making about you is shared with the Talent (and Manager/Booking Agent, if applicable), including the request details, date, approximate location, and your full name.
  • When your booking is confirmed, we will disclose additional information to assist with coordinating the event such as your Name, Email, Business name and Phone Number.
  • When you as a Talent confirm a booking, certain information is shared with the Client in order to assist with the booking process such as your profile and access to your marketing images.
  • When you as a Manager/Agent confirm a booking on behalf of your Talent, certain information is shared with the client in order to assist with the booking process such as the Talent’s profile and marketing images.

We do not share your billing and payment information with other Users.

Profiles, Listings, and other public information

The VLAST Platform lets you choose to publish information if you choose to, including personal data, that is visible to the general public. For example:

  • Parts of your public profile page, such as your first name, your bio description, and state location, are publicly visible to others.
  • Profile photo, social media followings (if you allow), and any other additional information you choose to share on your profile.

After completing a booking, Clients may write reviews for both VLAST and the Talent involved in the booking. Reviews are part of your public profile and may also be surfaced elsewhere on the VLAST platform (such as listing pages, blogs, case studies or landing pages).

Information you choose to share publicly on the VLAST Platform may be indexed through third party  search engines. In some cases, you may opt-out of this feature by contacting us. If you change your settings or your public-facing content, these search engines may not update their databases. We do not control and are not responsible for the practices of third party search engines, and they may use caches containing your outdated information.

Messaging/Chat services

Talent, Managers, Admin and Clients may communicate with each other through our messaging service which is activated upon a booking and accessed within our Platform. For example, Clients may want to discuss details of the booking with the Talent or Agent/Manager. We may review, scan, or analyse your communications on the VLAST Platform for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, analytics and customer support services. For example as part of our fraud prevention efforts, we scan and analyse messages to mask contact information and references to other websites. In some case, we may also scan, review, or analyse messages to debug, improve, and expand our product offerings, and where possible will ensure that your personal data is deidentified or anonymised for these purposes.

We will not send third party marketing messages to you, and will not sell reviews or analyses of these communications.

These activities are carried out based on our legitimate interest in ensuring compliance with applicable laws and our Terms, promoting safety and providing and improving our services and performance.

  1. SECURITY OF PERSONAL DATA COLLECTED

Your information is held in secure electronic databases.

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.

  1. HOW DO WE STORE YOUR PERSONAL DATA?

We secure stores your data in electronic databases located in secure remote data centers. Access to these databases is allowed only to select senior members of staff that require access in order to debug and solve programming issues. The servers that store this information are on a private network, ensuring no external access is possible outside of the senior staff mentioned above.

We will keep personally identifiable data relating to your account and the actions you undertake for the lifetime of your account. If you decide to shut down your account, all personally identifiable data that we store will be permanently deleted immediately. Logs and debugging information are kept on servers for 6 months before automatic removal by the services that store them. Please see section 10 on Data Retention below for further information.

  1. RETAINING YOUR PERSONAL DATA

We will retain information about you only for as long as is necessary for the purposes set out in this Privacy Policy or as described to you, including for as long as your account is active (i.e., for the lifetime of your VLAST account), or as needed to provide the Services to you. If you no longer want us to use information about you to provide the Services to you, you may cancel your account. We will retain and use such information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your information to comply with applicable tax/revenue laws or to demonstrate our compliance with applicable laws governing our interaction with you), resolve disputes and enforce our agreements. We also retain log files for internal analysis purposes. These log files are generally retained for a limited period of time, except in cases where they are used for the safety and security of the Services, to improve functionality of the Services or we are legally obligated to retain them for longer time periods.

Examples of how long we retain your personal data for are set out in the below table.

Circumstances in which personal data was provided How long do we keep it?
You register an account with us; If you decide to shut down your account, all personally identifiable data that we store will be permanently deleted immediately. Logs and debugging information are kept on servers for 6 months before automatic removal by the services that store them. Other data such a chat logs and details of the bookings themselves may be kept for 7 years from termination of your account with us, or earlier as part of our annual review
You use our services and platform, whether as a Manager, Talent or Agent; If you decide to shut down your account, all personally identifiable data that we store will be permanently deleted immediately. Logs and debugging information are kept on servers for 6 months before automatic removal by the services that store them. Other data such a chat logs and details of the bookings themselves may be kept for 7 years from termination of your account with us, or earlier as part of our annual review
You fill in forms on our website or make an enquiry; 2 years from date of the enquiry or our engagement with you, or earlier as part of our annual review.
You visit or use our website 2 years or earlier as part of our annual review.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for technical, research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

  1. MARKETING

We would like to send you information about products and services of ours that we think you might like, as well as those of our partner companies

If you have opted in and consented to receive marketing, you may always opt out at a later date through the unsubscribe link on all marketing email communications. You can also opt out by emailing privacy@pickstar.pro

You have the right at any time to stop us from contacting you for marketing purposes or giving your data to other members of our Group.

  1. WHAT ARE YOUR DATA PROTECTION RIGHTS?

Under certain circumstances, you have rights under UK data protection laws in relation to your personal data

  • The right to access – You have the right to request copies of your personal data.
  • The right to rectification – You have the right to request that we complete or correct any information you believe is inaccurate.
  • The right to erasure – you have the right to request that we erase your personal data, under certain conditions
  • The right to restrict processing – you have the right to request that we restrict the processing of your personal data, under certain conditions
  • The right to object to processing — You have the right to object to we processing your personal data, under certain conditions
  • The right to data portability – You have the right to request that we transfer the data that we have collected to another organisation, or directly to you, under certain conditions.
  • The right to withdraw consent- You have the right to withdraw your 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.

We have one calendar month to respond to you, although time frames may vary depending on your place of residence. If you would like to exercise these rights you can email us at privacy@govlast.com

Occasionally it could 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.

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.

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.

  1. COOKIES

Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit our websites, we may collect information from you automatically through cookies or similar technology.

For further information, visit allaboutcookies.org

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. For more information about the cookies we use and to view our full cookie policy, please see https://www.iubenda.com/privacy-policy/63603662/cookie-policy

Third party websites

We might include links on this website to other websites that we do not own. We do not control those websites or their privacy practices so you should read their privacy information before sharing your personal data with them. We are not responsible for any third party’s privacy policies or practices even if we provide a link to their website.

  1. CHANGES TO OUR PRIVACY POLICY

We keep our Privacy Policy under regular review. We may change this Privacy Policy from to time to time to take account of new laws and technology, or changes to our services, operations or practices. Any revisions to this Privacy Policy will be published on our website.

This Privacy Policy was last updated March 2021. 

To contact our Privacy Officer

If you have an enquiry or a complaint about the way we handle your personal data or to seek to exercise your privacy rights in relation to the personal data we hold about you, you may contact our Privacy Officer as follows:

By Email: privacy@govlast.com

For the purposes of the UK data protection laws, our Privacy Officer is also our Data Protection Officer (DPO).

While we endeavour to resolve complaints quickly and informally, if you wish to proceed to a formal privacy complaint, we request that you make your complaint in writing to our Privacy Officer, by email as above. We will acknowledge your formal complaint within 10 working days of receipt.

If you are based in the UK 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).

If you are in the European Union, you can choose to instead lodge a complaint with your local Data Protection Authority (DPA). The list of DPAs is at http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.