Privacy and Data Protection Policy

1.This policy

1.1 SUB5 Ltd (we) are the data controller in relation to personal data we collect from you in connection with our provision of products and services. We are an event company specialising in the automotive sector. We operate automotive related events and portals, driving experiences and sell related merchandise globally.
This policy sets out how we'll use your personal data.

1.2 We are committed to protecting and respecting your privacy.

1.3 We are registered in England and Wales SUB5 Ltd under company number 14376307 and have our registered office at 31 Marford Road, Wheathampstead, St. Albans, England, AL4 8AY.
You can contact our data protection officer (DPO) at our registered office or by email to dpo@sub5.club

1.4 This policy (together with any terms and conditions that have been notified to you and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

2. Information we collect from you

2.1 We recognise the importance of protecting the information we collect from data subjects in our operation. To this end we will take all reasonable steps to maintain the security, integrity and privacy of any information provided to us.

2.2 We will ensure that any personal identifiable information (PII Data) we collect will be adequate, relevant and not excessive for the purposes required. It will be kept accurate and up-to-date based on information provided, and to the best of our ability thereafter.

2.3 Personal Data we collect may include;

Your name
Your address - for postal fulfilment
Your Car type make model and reg for event management.
Your email address - for email fulfilment
Confirmation you are over 16 years of age

Records of the information you have viewed on our portals, or events you have registered for or attended.

2.4 Collecting this Data is essential to us being able to provide you with our services. If we are not able to collect this personal data, our ability to provide a high level service to you may be limited. We will not collect any personal data from you that we do not need in order to provide services to you.

3. How we use your information

3.1 A key requirement of UK Data Protection law is that we have a lawful basis for processing your personal data. Where the data is collected for the purpose of fulfilling a contract with you, we will use your personal data on the basis that processing is necessary to fulfil that contract. Where the data is collected for all other purposes (outlined below), we will process your personal data on the basis that you have given consent via our consent form or that we have a legitimate interest to process the personal data.

3.2 We will use information you give to us and which we collect from you:

(a) To provide products and services that you request from us;

(b) To provide you with products you have ordered from us, or to provide you with tickets to access an event for which you have pre-registered to attend; and

3.3 It is necessary for us to process data in order to fulfil a contract with you as follows:

(a) We organise events, automotive trade shows and driving experiences around the world. When you register for these events via the portals we use, we will process your data to complete the registration process. You will receive an email confirming your order and tickets for the product you have registered for.

(b) There may be circumstances in which we will share your personal data with named sponsors of events in order to enable the smooth running of events for which you register for. A sponsor will only contact you if you have provided your explicit consent to doing so and for the purposes to which you have consented.

(c) Our main business is setting up and running automotive events and driving experiences. When you are on these events or experiences, you may share your contact details with other attendees and this is your personal liability and not covered by this policy.

(d) We run events and only information which you have granted access to will be shared with our sponsoring companies.

(e) Data we have collected from you may be transferred to other companies outside the UK and the European Economic Area in accordance with data protection law. We impose contractual obligations with these companies, and these are termed as processing agreements. We ensure that only the required amount of data is shared to fulfil the purpose for which the data has been transferred. One example of this transfer is where your data may be passed to our printer and fulfilment service for tickets or other materials deemed necessary for the contract we have with you. This company would then fulfil the delivery event attendance material or tickets. This fulfilment may be online via email only.

(i) EVENTBRITE UK LIMITED are the ticketing services we use to process and distribute our event tickets. Company number is 07644044 - eventbrite.co.uk

(ii) Google Analytics Google analytics is used for tracking the number of visits that our different web pages receive. We use IP tracking for this service, and data such as names and email address are not processed via this method. This processing of your IP address helps us determine how much of a regular visitor to our website you are, and which pages you visited. We use this information for analytical purposes only.

3.4 We may seek your consent to the following types of processing:

(a) To allow third party event sponsors to contact you by email, mail, SMS or phone in connection with the specific event which you are interested in;

(b) To contact you by email, mail, SMS or phone with updates, newsletters, promotions, technical news etc.

3.5 Where we have a legitimate interest (which you may object to at any time as set out in paragraph 5.1 below) to process personal data, we will use your data on the basis that we have legitimate interest to do so which is not overridden by your rights and freedoms. We consider that we have a legitimate interest to carry out the following processing:

(a) We may provide additional emails following an event to keep you updated with the news from the event. Awards etc may be offered at the events, and we may require these to be returned for engraving.

(b) Our objective is to provide our customers with access to relevant events we host and run. Clear opt-out availability for each and every correspondence we send will be present. We may process your information to make sure that the marketing you may receive is relevant to you. We may provide information that is tailored to your interests based on past interactions, such as, events booked or the type or automotive interest you have or an event you have registered for. We believe this communication will be of benefit to our customers. We also reserve the right to process your personal data for our legitimate interests of obtaining legal or other professional advice or transferring our business assets (including personal data) on reorganisation, sale or merger of any part of our business.

(c) We will, from time to time (and where we have a legitimate interest to do so), send you marketing materials from selected third parties, this can include marketing of new products related to your interests. The unsubscribe option is present on all these email communications, in line with the best practice marketing guidelines.

3.6 We will never sell your information to third parties. However we may disclose your personal information to third parties in the following circumstances:

(a) In the event that we sell any of our business or assets, in which case we may disclose your personal data to the prospective buyers of such business or assets and to their legal advisers;

(b) In the event that we appoint a third party data processor to process your personal data in accordance with our documented instructions and with the requirements of UK Data Protection law;

(d) If it is necessary to disclose your personal data to our professional advisers (for example, to our legal advisers or our accountants);

(e) If it is necessary to do so in order to enforce or apply our terms and conditions of supply (if applicable) or to protect the rights, property, or safety of SUB5 Ltd, our clients or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction and exchanging information with debt recovery agencies; and

(f) To licensed credit reference agencies, other suppliers and creditors to help us and others make credit decisions; to help prevent or detect fraud or other crimes; to trace debtors; to provide trade references on a confidential basis to our agents and sub-contractors; and to insurance companies for the purpose connected with insurance products that relate or might relate to the you.

4. How long we keep your personal data

4.1 We will keep any personal data for providing services or products or informing you of new products or services until such time as you notify us that you no longer require services or products and no longer wish to receive this information.

4.2 We will store any other personal data for no longer than is reasonably required. We consider this to be the amount of time that we need your personal data in order for us to fulfil our obligations to you under any contract we may enter into and in order for us to fulfil any legal obligations.

5. Your rights

5.1 You have the right to object to our use of your personal data for marketing purposes. You may object to our use of your personal data for marketing purposes by writing to us at our registered office, or by emailing dpo@sub5.club and informing us of your objection.

5.2 You have the right to withdraw your consent to our processing for specified purposes or at all at any time. You may withdraw consent by writing to us at our registered office, or by emailing dpo@sub5.club and informing us that you are withdrawing your consent for one or more of the purposes for which consent was given. If you do not wish your information to be shared to event sponsors, please use the opt out feature at each event registration.

5.3 You may request access to your information, to have any incorrect information corrected and to have your information deleted.

5.4 You have the right to request a copy of information held about you by us. Generally we will provide this information free of charge, however in certain circumstances we reserve the right to charge a reasonable fee to meet our costs in providing you with details of the information we hold about you in accordance with UK Data Protection law.

5.5 In certain circumstances, you have the right to require us (and our third party data processors) to erase your personal data without undue delay, although we reserve the right not to erase personal data (or to inform our third party data processors) where processing remains necessary for purposes which are permitted by UK Data Protection law.

5.6 You have the right to request that your personal data is made portable for the purposes of transferring personal data to another supplier in relation to:

(a) Personal data which you have provided to us;

(b) Personal data which is processed on the basis of your consent or the performance of a contract; and

6. Access to information

6.1 UK Data Protection law gives you the right to access information held about you by us. Generally we will provide this information free of charge, however in certain circumstances we reserve the right to charge a reasonable fee to meet our costs in providing you with details of the information we hold about you.

7. Right to lodge a complaint

7.1 While we will endeavour to only use personal data that is relevant to our purpose and ensure your personal data is kept secure, sometimes errors occur. If you wish to raise a complaint on how we have handled your personal data, you can contact our Data Protection Officer who will investigate the matter. If you are not satisfied with our response or believe we are not processing your personal data as required by law you can contact the Information Commissioner’s Office on 0303 123 1113.

Find out more on the GDPR - www.ico.org.uk

8. Changes to our privacy policy

8.1 Any changes we make to our privacy policy in the future will be posted on our website. Please check back frequently to see any updates or changes to our privacy policy. Your continued use of our website or services will be deemed conclusive acceptance of any modifications we make.

9. Cookie Policy

9.1 A 'cookie' is a text file that a website you visit and asks your browser to store on your computer or mobile devise. SUB5 Ltd uses cookies as follows:

(a) to record session information, such as items that you add to a shopping cart

(b) to record information on which pages a you access or visit on sites owned or operated by SUB5 LTD

9.2 It must be noted that the shopping cart needs cookies in order to work, i.e. remember what a customer has placed in their cart. However these cookies automatically delete themselves after the transaction is complete and cookies may be disabled at any time.

10. Additional policies

10.1 Links may be provided from the SUB5 portal to other websites. In using such links, users should be aware that each website will vary in terms of its privacy and data protection policies, and SUB5 Ltd does not take responsibility for the privacy policies of, and usage of, personal information collected by others including, without limitation, those of any partner or affiliate.

10.2 Anti-Spam Policy.

We use a third party emailing system which facilitates the broadcast of email communications. There are many issues surrounding unsolicited emails and spam, and we want to ensure that the communications we deliver are relevant to your interests. If you have a complaint about any email or post you receive from us, please get in touch so we can investigate fully. We strictly enforce our Anti-Spam policy. This is both a necessity and a requirement.

10.3 Reporting Spam
Please notify us immediately if you have received unwanted or unsolicited email. You can email us at dpo@sub5.club

10.4 Data Transmission
SUB5 Ltd hold no responsibility for the successful transmission of data via its portals and websites. Personal information transmitted across the internet is not 100% secure and users are advised to consider this upon completion of forms anywhere in the portals we operate.

11. Contact

Sub5 LTD can be contacted at;

31 Marford Road
Wheathampstead
St. Albans
Hertfordshire
AL4 8AY
United Kingdom

11.1 Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to our registered office or dpo@sub5.club