Surf Europe (the “Business”) is a trading name of Internet Fusion Limited (the “Company”, “IF”, “we”, “us”, “our”).
Important information and who we are
This privacy notice provides information about how IF collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, submit a video or take part in a competition and where your personal data (for example images and videos of you) is submitted to us by users of this website. We are committed to ensuring that your privacy is protected.
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 notice 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 notice supplements the other notices and is not intended to override them.
The Internet Fusion group is made up of different legal entities, details of which can be found here. Internet Fusion Limited (company no. 06012780) (“IFL”) is the data controller for any personal information provided to or to be collected by this website, the Business and any other operating companies in the IF Group. This privacy notice is issued on behalf of the IF Group, including the current Business and website.
Please contact our Data Privacy Manager using the information below.
Email address: [email protected]
Postal address: Internet Fusion Limited Data Privacy Manager, 2 Stone Buildings, Lincoln’s Inn, London, England, WC2A 3TH.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (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.
Changes to the privacy notice and your duty to inform us of changes
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.
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 notice of every website you visit.
Personal information collected by us
We will need to ask you for certain personal information to give you the best possible experience when you visit our website or otherwise engage with us (via leaving a comment, emailing us or otherwise).
The personal data we collect from you might include your:
- Date of birth;
- Email address;
- Mobile phone number;
- Address, including postcode;
- Image (when you submit a video featuring you or where a video featuring you is submitted by another person)
- IP address and other device information;
- Sports interests and your feedback and survey responses;
- Activity on our website;
- Your preferences in receiving marketing from us and our third parties and your communication preferences.
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 services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
If any of the information you have provided to us changes, for example if you change your email address or name, or if you wish to cancel your registration, please email your new details to [email protected]
How we collect your personal information
INFORMATION THAT YOU PROVIDE US
We collect personal information when you:
- Post messages in our forums or the video comments section;
- Create blogs;
- Upload pictures and/or videos (or when a picture or video featuring you is uploaded by someone else);
- Post material on your profile;
- Participate in surveys;
- Enter competitions;
- Take advantage of promotions;
- Subscribe to newsletters or other mailing lists or
- Contact us through email, or otherwise communicate with us or provide information to us.
INFORMATION COLLECTED BY AUTOMATED MEANS
- We also obtain some of your personal information by automated means when you visit our website, such as the IP address of the device you use, the geographical location of your device, the browser you are using, the URL you came from, the web pages you access, and your usage of the website. We may also receive such data if you visit other website employing our cookies. Please see our section on Cookies below for further details.
INFORMATION WE RECEIVE FROM THIRD PARTIES
- We may receive the following personal data from you from various third parties as set out below :
- Any personal data you provide through our social media channels (for example, your name and photos in Facebook comments);
- Images of you or videos featuring you where these are submitted by a third party; and
- Your 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 from analytics such as Google based outside the UK.
How we use your personal information
PERFORMANCE OF A CONTRACT
- To take the necessary steps to sign you up as a member
- To communicate with and manage our relationship with you regarding your use of our website
- To administer and run competitions which you enter
- To use your image or video on our website or more generally where your image or a video featuring you is submitted or uploaded by you as part of a competition.
- To deal with any enquiries or requests you make of us
- To enable you to access our website
OUR LEGITIMATE INTERESTS
- To confirm your identity and authenticate the information you provide for security purposes.
- To administer and run competitions where your image or a video featuring you is submitted or loaded by someone else.
- To show your image or video on our website or more generally where your image or a video featuring you is submitted or uploaded by someone else.
- For our own reporting and analytical purposes to enable us to improve our services and support our users, including through the use of email performance and click-through tracking.
- For our own record-keeping and general administrative purposes regarding our handling of your personal data and other operational activities.
- To provide you with customer support and resolve any complaints.
- To effectively handle any legal claims or regulatory enforcement actions taken against IF, or take appropriate legal action against third parties who have committed criminal acts or are in breach of legal obligations to us.
- To assist with our internal training purposes.
COMPLYING WITH OUR LEGAL OBLIGATIONS
- To comply with our legal and regulatory obligations (including under applicable Data protection laws).
- For preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies.
- To fulfil our duties to our members, colleagues and other stakeholders.
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 or text message. You have the right to withdraw consent to marketing at any time by contacting us.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
PROMOTIONAL OFFERS FROM US
We may use your personal 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 made a booking with us and you have not opted out of receiving that marketing.
You can ask us or third parties to stop sending you marketing messages at any time by logging into your profile and unselecting the unwanted marketing email or following instructions on the bottom of any marketing email received to unsubscribe
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a booking made or other transactions.
A cookie is a small file and holds a certain amount of data, which the website can send to your browser. It may then be stored on your computer’s hard drive and can be accessed by our web server. This cookie data can then be retrieved and can allow us to customise our web pages and services accordingly. It’s important to clarify that cookies do not collect any personal data stored on your hard drive or computer.
You can find out all about cookies from this website AllAboutCookies.org.
Our website uses both persistent and session cookies:
Persistent cookies are used to allow the website to recognise users when they return to the site and to remember certain information about their preferences. These cookies are cookies which stay on your computer permanently, until you “manually” delete them.
Session cookies are used in order to allow customers to carry information across pages of the website, without having to re-enter such information. These cookies delete themselves automatically when you leave a website and go to another, or when you shut down your browser.
We have also developed relationships with carefully selected and monitored partners, to assist in the delivery of a high quality website. Some of these partners may also set cookies during your visit to support customisation of adverts that you may see elsewhere on the Internet, and/or in order to meet contractual obligations with us.
HOW TO CONTROL AND DELETE COOKIES
Should you choose to disable, reject or block our cookies, some parts of our website will not function fully, or in some cases, our website will not be accessible at all. Our cookies do not contain any personally identifying information, but they do enable us to provide features such as personalising our content to your tastes based upon information that you have provided to us (such as an interest in a particular sport). Most web browsers automatically accept cookies, but you can usually change your browser settings to prevent this. It is not possible to make a purchase unless you have cookies turned on and we recommend that you leave them turned on.
For more information on how to control your cookie settings and browser settings, or how to delete cookies on your hard drive, please visit AllAboutCookies.org.
The “help” portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Disabling cookies may result in loss of functionality of the website.
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.
The internet is not a secure medium. We have, however, put in place appropriate security measures to prevent your personal information from being 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.
Disclosures of your personal information
We may disclose your personal information to the following recipients or categories of recipients:
- Other IF Group companies;
- Our service providers and suppliers, who process such information on our behalf;
- Our service providers and suppliers, who process such information on our behalf (such as website or database hosting companies, address list hosting companies, email service providers, analytics companies, search engine providers, distribution companies, fulfilment companies, and other similar entities that help us to operate the website and/or provide functionality, content and services). Our service providers include (but are not limited to) Amazon Web Services, who provide hosting and storage services in Ireland;
- As required by law, or to provide information as required by local law enforcement agencies, other local government authorities, or otherwise as required by law;
- Any third parties with whom we are required to share your personal data in order to comply with our legal obligations, to enforce our terms and conditions or to protect the rights, property, or safety of IFL or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction; and
- 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.
We do not generally transfer your data outside the UK or European Economic Area (“EEA”)..
If we do need to transfer your personal data out of the UK or EEA (for example to certain service providers located abroad), 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 by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or EEA.
At the date of this policy the position in respect of transfers of data between the UK and EEA is constantly changing, but we will ensure that such transfers are made subject to appropriate safeguards as may be required by any applicable data protection laws from time to time. These will include the use of the above safeguards, as far as possible.
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.
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.
By law we have to keep basic information about our customers (including, but not limited to, name, address and email address) for six years after they cease being customers for tax purposes.
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.
Your legal rights
Under the privacy regulations you have rights under data protection laws in relation to your personal data (See “your Legal Rights” section below for more information):
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us preferably by this email [email protected] or the address listed towards the top of this policy.
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.
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.
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 your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
YOUR LEGAL RIGHTS
You have the right to:
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: (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.
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. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the 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 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.