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Privacy Policy

Please read the Policy carefully before using the Service.

We are Turnstile. We help clients by providing definitive valuations of sponsorship deals. We use actual prices being paid for rights globally to determine real-world market values of the three key components of a sponsorship deal - Benefits, Exposure and Intellectual Property.

This policy provides information about the types of personal information we collect about you, including via our website www.turnstilegroup.com and our social media accounts. It also provides information about how we will use your personal information and your rights over your personal information. If we start a new project or activity, we may provide you with new privacy policies with more information.

Please click on the links below for more information about the different types of personal information we collect and how it is used.

For information about how we use cookies, please see our Cookies Notice

  • Who we are and how to get in touch

    We are the Turnstile Group Limited, a subsidiary of the Gemba group of companies. We are based in England. Our company number is: 12094407. Our registered address is: 49 Greek Street, London, United Kingdom, W1D 4EG.

    If you want to know more about what personal information we have about you, how we use it, or if you just want to ask us a question, please email us at: info@turnstilegroup.com

  • What is personal information?

    Personal information means any information that could be used to identify you. At its simplest, this could just be your name and your email address. Personal information will also include your CV (if you apply for a job with us) and any correspondence you have with us.

  • Whose personal information do we use?

    We collect and use personal information about people who are, or may be, interested in Turnstile. For example:

    • Clients

    • Business contacts

    • Website visitors

    • Employees at rights holders and brands (who are named in the contracts on our database)

    • Job applicants (see section 8 for more information about the personal information we collect and how it is used)

    If you are an employee of Turnstile, we have a different privacy policy for you. This is available by contacting your manager.

    You are not under any requirement to provide us with your personal information. But if you do not do so, then we may not be able to respond to your query or provide you with services.

  • Where do we get your personal information?

    We will collect your personal information from three sources:

    • Directly from you
      For example, when you submit a query via our website or send us an email.
    • Indirectly from another source
      For example, when you are referred to us by a business partner because they believe your organisation may be interested in Turnstile.
    • When it is available publicly
      For example, if you Tweet about Turnstile, we may keep a record of this.

  • What personal information do we collect?

    The personal information that we collect and use about individuals includes, but is not restricted to:

    • name

    • job title

    • contact details (email, phone and address)

    • social media handles

    • information about your background relevant to Turnstile (for example, your experience in the sports and entertainment sector and any particular team allegiances)

    • your communication preferences (for example, whether or not you wish to be contacted by email)

    • any other information you may give us (for example, if you submit a query via our website)

    Certain types of personal information are sensitive and need more protection. For example, information about your race or ethnic origins, political opinions, sex life or sexual orientation, religious beliefs, health information, biometric and genetic data. There are also special rules about the use of criminal information (information about criminal convictions or allegations about criminal convictions).

    We will not usually collect these types of personal information about you. We will only process these types of personal information about you if we have a valid reason for doing so and only if the law allows us to do so.

    See section 8 below for specific details about personal information of job applicants.

  • What do we do with your personal information?

    We use your personal information to help us run our business. Specifically, we use your personal information to:

    • send you information you requested about Turnstile (for example, if you’ve asked for more information about our services)

    • provide our services to you and your organisation

    • update you about Turnstile’s activities and services

    • develop our internal business strategy

    • develop content (blogs, news articles, social media posts) promoting the Turnstile and our sector

    • handle any concerns or queries which are raised to us

    • work with partners to promote Turnstile at our events, online and in the media

    Lawful basis

    We can only use your personal information if we have a valid reason. This is known as a “lawful basis of processing”. Different lawful bases of processing will apply to the different ways in which we use your personal information. Below we explain the lawful bases which we think apply to our use of your personal information:

    • Legitimate interests

      This is a flexible lawful basis. It allows us to use your personal information, provided that:

      • We have a good reason to do so. For example, we may wish to reach out to individuals in the sports and entertainment sector to produce a study on the sale of rights.
      • You can reasonably expect we would use your personal information in this way. In other words, the way in which we use your personal information should not be a surprise.
      • It fits with your rights, and does not unfairly affect you. Your rights are explained in section 13 below.

      When we rely on legitimate interests as a lawful basis our use of your personal information must be fair and balanced, and we need to consider the points above.

    • Consent

      This is where we ask your permission to use your personal information for a specific purpose. For example, we will ask to use a photo of you to promote Turnstile before putting it on our website. You always have the right to withdraw your consent. Just send us an email or call us using the details set out in section 1.

    • Legal obligation

      This is where we need to process your information to comply with a legal obligation. For example, we are under a legal obligation to report to HRMC about our financial activities.

      We handle personal information about those who apply to work with us slightly differently than we have discussed above, so we have included a separate section on job applicants. See section 8 below for specific details.

  • When will we get in touch?

    When you give us your contact details you will receive follow up information from us directly, including news about Turnstile, as well as about any specific information about which you’ve enquired. Some of these communications are administrative (for example to confirm details about your query) but others will promote Turnstile, and our services.

    If we consider that you may be interested in Turnstile and our services, we will send promotional materials via email to your work email address. We will only send promotional materials to your personal email address where you’ve agreed to receive it such communications.

    You can opt out of receiving promotional materials at any time. To opt out of emails, click on the unsubscribe link at the bottom of our messages

    If at any time you wish to stop or change how we communicate with you, or update the information we hold, please do get in touch, using any of the options set out in section 1.

  • Job applicants.

    When you apply to work with Turnstile, we will collect and use your information for the purposes of evaluating your application as part of our recruitment process.

    We will collect the following types of personal information:

    • Information you provide in your CV and any covering letter/email

    • Information you provide during the course of the recruitment process (for example, during the interview phase)

    • Information provided by third parties about you, including former employers and other named references

    • Any other information you provide to us as part of the recruitment process

    We will use the personal information we collect about you to:

    • Assess your skills, qualifications and suitability for the role

    • Carry out background checks and reference checks (where applicable)

    • Communicate with you about the recruitment process

    • Keep records of our hiring processes

    • Comply with other legal or regulatory requirements

    • If successful, to enter into a contract of employment with you

    It is in our legitimate interests to decide whether to appoint you to the role since recruitment helps Turnstile function as a business.

    Please note that if you fail to provide us with the relevant details that we request, we will not be able to process your application successfully.

    If you are successful in your application, we will transfer the personal information collected as part of the recruitment process to your employment record. We will also provide you with an employee-specific privacy policy.

    If you are unsuccessful in your application, we will usually retain the personal information collected about you for six months after when we communicated our decision to you.

  • Do we share your personal information?

    We are members of the wider Gemba Group (http://thegembagroup.com/), a high-end consultancy providing insight and strategy to the global sport & entertainment industry. Gemba is based in Australia, with offices in New Zealand and Shanghai. We share personal information within the Gemba Group, but only when the sharing of such information is reasonably required for our business purposes.

    We use suppliers to help us operate. For example, we have a company that provides us with technical support to keep our systems up and running. We have written agreements with our suppliers that require them to keep your personal information safe, and only use any personal information in line with our instructions.

    There are other circumstances where we may need to share your personal information, for example:

    • if we sell or transfer the running of Turnstile to another organisation;

    • with our professional advisors e.g. lawyers, where necessary to protect our or a third party’s interests;

    • if we are under any legal or regulatory obligation to do so; and

    • in connection with any legal proceedings or prospective legal proceedings, in order to establish, exercise or defend our legal rights.

    If we share your information with any other third party, we will let you know in advance where reasonably possible.

  • Links to other websites and social media plug-ins

    Sometimes we include links to other websites. This policy only covers how Turnstile uses personal information, and does not cover these other websites. We encourage you to read the privacy policy on other websites you visit.

    We have provided social media plug-ins to allow you to easily get in touch and share content from our website. If you do so, your personal information will be disclosed to these social media platforms. When you share content using these buttons, a new page will pop up from the relevant social media platform. If you’re already logged into your account on that social media platform, then you will probably be automatically logged into this pop-up page, so that you don’t have to log in again. If, however, you are not logged in (or if you are not registered with the social media platform), the page will ask you for your information.

    We have no control over how social media platforms use your personal information. We encourage you to read the privacy policies on the various social media platforms you use.

    Find out more about how these social media platforms use your personal information:

  • How we keep your information safe and international transfers

    It’s our job to keep your personal information safe and secure. We have security measures in place to protect your personal information, and we provide training to our staff about how to keep personal information safe.

    While we are based in the UK, Turnstile’s part of a global group of companies and we do use suppliers that operate around the world. This means that it is possible that personal information we collect from you may be transferred to and stored in a location outside of the UK or the EEA. 

    Certain countries outside of the UK or the EEA have a lower standard of protection for personal information, including lower security protections. Where your personal information is transferred outside the UK or EEA to a country which does not offer a similar level of protection to the UK or EEA, we will take all reasonable steps necessary to ensure that the recipient appropriately protects your personal information by, for instance, entering into contracts that have been approved by EU authorities. If you have any questions about data transfers, please do get in touch, using any of the options set out in section 1.

  • How long do we keep your personal information?

    We keep your personal information for as long as we reasonably need to use it for the reasons we set out in section 6 and section 8 (for job applicants). We will keep client contacts for at least 6 years following the end of the project. We may keep business and marketing contacts for a shorter period of time. We will carefully consider what information we need and whether any of your personal information can be deleted before that time.

    We may also retain personal information for longer periods where we are required to do so for legal or regulatory reasons, such as tax and accounting.

    If you would like further information about this, please contact us using the details at section 1.

  • Your rights

    When we use your personal information you have the right to:

    • Ask for a copy of your personal information. We may ask you for proof of your identity (for example, a copy of your passport). If we are happy that this is the case, we will give you a copy of your personal information, unless an exemption applies. If you want to know more about how to request your personal information, the Information Commissioner’s Office (or “ICO” for short) has useful guidance: https://ico.org.uk/your-data-matters/your-right-of-access/

    • Ask that we erase the personal information we hold about you. We may not be able to erase your personal information (for example, we may need to keep your personal information for a legal reason), but we will consider your request and let you know.

    • Ask that we correct any personal information that we hold about you which you believe to be wrong.

    • Ask that we restrict the use of your personal information if you believe that the information we hold is wrong, or that we don’t have a valid reason for using your personal information.

    • To change your mind and withdraw your consent.

    • Ask us to stop using your personal information, if we are using it for legitimate interests.

    We may not need to stop, but we will need to show a good reason to continue to use personal information.

    There are other rights, which will not obviously apply to the way in which we are using your personal information. For example, the right to port (or transfer) your personal information to a third party in certain circumstances. But if you want to learn more about the rights discussed above or your other rights, the ICO has useful guidance on these rights and when they apply: https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the- general-data-protection-regulation-gdpr/individual-rights/

    If you have any concerns about the way we are handling your personal information, or if you’ve asked a question or raised a complaint that we haven’t dealt with, you can contact the ICO directly: https://ico.org.uk/make-a-complaint/

  • Updates to this privacy policy

    We may update this policy. If we update this policy in a way that significantly changes how we use your personal information, we will bring these changes to your attention where reasonably possible. Otherwise, you can access the latest version of this policy on our website.

    Version: 1.0

    Dated: October 2019

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