Privacy policy

ATHLON LONDON LIMITED (we/us/our) are committed to respecting people’s privacy and their personal data. We recognise that personal data does not belong to us; it has been loaned to us for specific purposes.

Unless otherwise required by law, the Information Commissioner’s Office (ICO) guidance or best practice, or in order to perform our contract with you, we will only process your personal data in the way we tell you or in the way you ask us to, and we will give it back to you at any time.

1. This policy

1.1 This policy, together with our terms and conditions on our website at www.weareathlon.com (our Website) and any other documents we provide to you as part of your trading relationship with us, sets out how we will process your personal data or the personal data of your staff.

1.2 This policy applies to our contract with you. You are therefore advised to read it carefully. Terms used within it shall have the meaning(s) given in the Data Protection Act 1998 (Act) and/or the General Data Protection Regulation (Regulation), as applicable.

1.3 By visiting our Website, or by providing your personal data to us, you understand, accept and consent to the practices described in this policy.

1.4 Any changes we make to this policy will be posted on this page. You are advised to check back frequently as, unless your consent is required, any changes will be binding on you when you continue to use the Website or work with us after the date of the relevant change.

1.5 For more information relating to your rights under this policy, please see section 9.

1.6 If you have any queries relating to this policy, please contact us at hello@weareathlon.com in the first instance.

2. Who we are

2.1 For the purposes of the Act, the data controller is Athlon London Limited, a UK registered company (number 07369965) with its registered address at 167–169 Great Portland St, London, W1W 5PF.

2.2 We are registered with the ICO to process your personal data for the purposes stated in this policy, and our registration number is ZA315001.

2.3 Any personal data we obtain may also be transferred to any of our affiliated companies for legitimate managerial, administrative or operational business purposes:

– Athlon NY LLC, 234 36th St, unit B429, Brooklyn, NY 11232, United States of America

– Athlon Toronto Ltd, 147 Liberty St, Unit 201, Toronto, Ontario M6K 3G3, Canada

– Athlon Sofia Ltd, 86 Knaiz Boris I Street, Sofia 1000, Bulgaria

– Athlon Perth Ltd, 45 St Georges Terrace, Perth, 6000 WA, Australia

2.4 Other than personal data relating to our staff, we only process limited amounts of personal data (that are not especially sensitive) for the purposes of maintaining our relationships with customers, clients and suppliers.

3. Your consent

3.1 We do not ordinarily rely on your consent to process your personal data. We process your personal data primarily to perform our contract with, and provide our services to, you. We consider the personal data we obtain is reasonable and necessary for these purposes. However, we review this intermittently and remove any inaccurate or obsolete data.

3.2 By using our Website, and/or engaging us to provide services to you, you expressly consent to the transfers of your personal data to those specifically listed third parties in this policy, for the reasons specified. You will be asked to consent to this as part of signing up to our terms and conditions of business.

4. What we collect

4.1 We only collect ordinary contact details that are, often, publicly available. This includes names, email addresses, telephone numbers (including Skype® and Facetime® addresses and mobile numbers) and other details available on social media profiles that are publicly uploaded and made available by data subjects.

4.2 Any bank details that we obtain are solely relating to businesses and are, therefore, not individual bank account details.

4.3 Where you are a current, potential or former employee, worker or other member of our staff, we may collect additional categories of your personal data for the purposes of providing you with the necessary benefits under our contract with you. In those circumstances, a separate privacy notice applies, and a copy is available on request.

4.4 When you use our Website, we will automatically collect technical information about the device you use to visit, including your IP address, browser type/version and related settings. We also monitor your use of our Website. This includes the full URLs, your clickstreams through our Website, the pages you view and how you interact with them and how you leave the Website.

5. How we collect your data

Data is simply collected when you correspond with us by phone or e-mail as part of our business with you. Technical information (see section 4.4) is obtained when you visit our Website.

6. How we store your data (non-EEA data transfers)

6.1 We disclose personal data to the following third parties, or we disclose it to them for the reasons listed:

– Google G Suite (by Google Cloud), is a storage solution hosted by Google LLC (Google) who are based in the USA (California) host our documents and emails;

– The Rocket Science Group LLC d/b/a Mailchimp®, a company registered in the USA (Georgia) with its registered office at 675 Ponce de Leon Avenue NE, Suite 5000, Atlanta GA 30308 store our marketing distribution lists on their secure servers located in the USA. We disclose your name and email address to them to distribute our marketing content to you (where we have your consent to do so). Their privacy policy is located at https://mailchimp.com/legal/privacy/;

– Files (which may contain personal data) may be shared with you through secure third-party data sharing providers, which include www.box.com (operated by Box, Inc and Box.com (UK) Limited);

– Where you apply for a job with us, any and all personal data contained on your application (including your CV) will, in most cases, be uploaded to www.workable.com (a website operated by Workable Software Limited) to enable us to improve and streamline our recruitment processes. Data may be stored and accessed by staff outside of the EEA (as per their privacy policy available at www.workable.com/privacy); and

– any personal data contained in conference communications with us may be recorded and retained by our appointed video conferencing software providers.

6.2 Any personal data contained on hardware operated by our staff is encrypted, and access to all hardware is password protected. All servers are protected behind appropriate anti-virus software and firewalls.

7. What we use it for

7.1 The personal data we need is to enable us to provide our services to you. This includes contacting you in relation to any enquiries or requests you raise with us.

7.2 We also use your personal data to send you information by email about us, our products and our services that are similar to those you have already purchased or enquired about. We only do this where you have given us permission to do so, and you can opt-out at any time. Where you opt out, we will no longer contact you until you ask us to, and we will not prompt you to do so.

7.3 Technical information we collect about your visit to our Website is used to enable us to:

– personalise and improve its functionality and security (to keep it safe and secure);

– administer and monitor traffic and behaviours on our Website for analysis, testing, research, statistical and survey purposes; and

– ensure that we can offer you the most effective and efficient browsing experience and make improvements where necessary.

7.4 Where we change our services, or any applicable terms and conditions, we will contact you.

7.5 Once collected, your personal data will be retained by us for as long as is necessary for us to provide you with the relevant goods and services (including any warranty you buy from us), to market our services to you (where requested) and to enable us to improve our Website. After this point, the data will be securely deleted, and we will not contact you unless you ask us to.

8. Cookies

8.1 The Website uses cookies to distinguish you from other users. This helps us provide you with a good experience whilst browsing and allows us to improve it. By continuing to use our Website, you agree to our use of cookies as set out in this section.

8.2 A cookie is a small file of letters and numbers that Condor stores on your browser or the hard drive of your computer (with your consent). Cookies contain information that is transferred to your computer’s hard drive. We use the following cookies on our Website:

– Targeting cookies – these cookies record your visit to our Website, the pages you have visited and the links you have followed. We will use this information to make it, and the advertising displayed on it, more relevant to your interests.

– Functionality cookies – these are used to recognise you when you return to the Website. This enables us to personalise its content for you, greet you by name and remember your preferences (for example, your choice of language or region).

– Analytical/performance cookies – they allow us to recognise and count the number of visitors and to see how visitors move around the Website when they are using it. This helps us to improve the way the Website works (for example, by ensuring that users are finding what they are looking for easily); and

8.3 You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Website

9. Your rights

9.1 You may exercise your rights under this section at any time.

9.2 In relation to all of your personal data, you have the following rights (in addition to any rights you may have under the Act or the Regulation) to ask us:

9.2.1 not to process your personal data for marketing purposes;

9.2.2 to clarify what data we hold about you, how it was obtained, to whom it has been disclosed and for how long it will be stored;

9.2.3 to amend any inaccurate data we hold about you;

9.2.4 to delete any of your data (where you no longer think we need to hold it, or you think we have obtained or processed it without your consent at any time); and

9.2.5 to only process your personal data in limited circumstances, for limited purposes.

9.3 We have the capacity to extract your personal data from our databases and provide it to you in a structured, commonly-used way (typically by .csv file).

9.4 If you wish to exercise any of your rights at any time, please contact us on the details contained at the beginning of this policy in the first instance. We will require you to verify your identity to us before we provide any personal data and reserve the right to ask you to specify the types of personal data to which your request relates.

9.5. Where you wish to exercise any of your rights, they may be subject to payment of a nominal administration fee (to cover our costs incurred in processing your request) and any clarification we may reasonably require in relation to your request. Such fees may be charged where we consider (acting reasonably) that your request is excessive, unfounded or repetitive.

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