Club Capital Privacy Notice

We respect your privacy and are committed to protecting your personal information and enabling you to access your individual rights in accordance with the General Data Protection Regulation and the Data Protection Act 2018 (“DP Legislation”).

It is important that you read this privacy notice as it explains how we collect and use (“process”) your personal information when you express an interest in or make an application to Club Capital.

The Club Capital privacy notice supplements the British Gymnastics and Sporting Assets privacy notices which can be found by following the links below:

British Gymnastics

Sporting Assets

About Club Capital

Club Capital is a fund that sources investment to enable British Gymnastics registered clubs to enable clubs to move into new, or expand or safeguard existing, dedicated gymnastics facilities. Initial investment has been provided by British Gymnastics, Sport England, Big Society Capital and Bank Workers Charity.

Club Capital was established by Amateur British Gymnastics Investments Limited, British Gymnastics and Sporting Assets, who are joint data controllers and responsible for your personal data (collectively referred to as ‘we’, ‘us’ or ‘our’ in this privacy notice).

Each organisation will only have access to your personal data where it is necessary to undertake their relevant role:

Amateur British Gymnastics Investments Limited (“BGI”):

BGI has been established to oversee and approve matters relating to the management of the fund
BGI Directors will be provided with information relating to your application if it is necessary to assist them in making decisions regarding the overall management of the fund
A BGI Director will approve and sign official documentation relating to any Club Capital investment and therefore will be given information relating to specific investments

Sporting Assets (“SA”):

SA is the Fund Manager, and will assess and undertake all due diligence on applications and present these applications for consideration
SA will be provided with all information which the club submits as part of the application process

British Gymnastics (“BG”):

BG is the governing body for gymnastics and provides capacity building support to applicants
BG will be provided with all information which the club submits as part of the online application, and where necessary additional information obtained throughout the process

Your Rights

You have the following rights in respect of your personal data we are processing:

To access the information we hold about you.
To correct any inaccuracies in the information we hold about you.

You also have the right to:

Request the erasure of your personal data
Object to the processing of your personal data

If you are concerned about the way we are processing your personal information, you can complain to the Information Commissioner’s Office (ICO). Please visit the ICO website for further details (www.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.

Duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please let us know if your personal data changes during your relationship with us.

Contact Details

To exercise any of your rights or if you have any questions about our privacy notice, or the way that we are using your personal data or need to update the information we hold about you, you can contact us by the following methods:

	Sporting Assets/BGI	British Gymnastics
Email:	enquiries@clubcapital.co.uk	data.protection@british-gymnastics.org
Phone:	020 8191 9563	0345 1297 129
Post:	W106 Vox Studios 1-45 Durham Street London SE11 5JH	Lilleshall National Sports Centre Newport Shropshire TF10 9AT

Your Personal Data – What we collect, how & why we collect it and the applicable Legal basis

If you complete an Expression of Interest form, we will use the information you provide to contact you about an investment opportunity. If you apply for investment we will collect the following information:

Name and Job/Role Title
Contact information: For you and other key organisation representatives which we will use to contact you about the application, for due diligence and to seek feedback from you about our services.
Information on key people: As part of our due diligence on the investment, the personal information we may also collect includes CVs, biographies, salary information and references for key people in your organisation. The majority of this will be information provided by you or someone at your organisation but in some instances information will be provided by third parties such as references.
Details ID documents: If you are successful in securing investment, we will ask ID document details for your directors or trustees, such as passport details. This is necessary so we can carry out Know Your Customer (KYC) checks on club directors or trustees for money laundering purposes.

Other sources of your Data

Although most information we process about you will be provided in your Expression of Interest Form and during the application process, we may also obtain your information from the following other sources:

Club Capital investment team: The Club Capital investment team is employed by Sporting Assets. If you meet one of the team, for example at an event, and give them your contact details so they can send you information about Club Capital.
British Gymnastics: British Gymnastics may share information to contribute to an application, for example they may provide information about key individuals role and involvement with the club, and they may also provide membership information. As part of the loan application process we may pass your Contact information and Information on key people to British Gymnastics in order to help us assess your application and conduct due diligence.
Publicly available sources: When undertaking due diligence on any application the Club Capital investment team may use sources such as Companies House or your organisation’s website to obtain further information regarding the organisations and individuals involved.

Club Capital website

You do not need to provide any information about yourself to view the Club Capital website. When you access the website, our webserver logs your Internet Protocol (IP) address (a unique set of numbers that identifies one or more devices on a computer network), browser identifier and the time of access. We would not attempt to use this information to identify individuals who visit our website unless it was necessary for fraud purposes.

Click here for information on the cookies we use on our website.

Legal basis

Under DP Legislation, we must have a legal basis for processing your personal information. The primary legal basis is that it is necessary for the purposes of our legitimate interests or those of a third party, except where these interests are overridden by your own interests, rights and freedoms.

Our legitimate interests are as follows:

Communicating with you about an expression of interest, your application or loan.
Undertaking due diligence checks to verify the accuracy of the information you have provided in your loan application, assess affordability and ensuring that the club and its representatives comply with any relevant funding conditions e.g. British Gymnastics membership rules.
Preventing fraud and other criminal activities e.g. website security or fraud in relation to the use of funds.
Researching the impact of the fund and monitoring the return on our investments.
Publishing information about the fund and its impact – we may publicise information about the fund and its impact to increase engagement. We will always try to achieve this purpose by publishing only aggregated, anonymised data but would inform you in advance if we consider it would it necessary to include information that could identify you.
Responding to complaints and feedback.
Monitoring the effectiveness of our website and communications.

Where the processing of your personal data is based solely on legitimate interests, you have the right to object to that processing based on your particular situation. If you object, we can no longer process your information unless we can demonstrate that we have compelling legitimate grounds to continue to process your data, which override your individual interests, rights and freedoms, or if the processing is for the establishment, exercise or defence of legal claims.

Marketing

We will not use your information for marketing purposes unless we have your prior consent. We will never provide or sell your information to third parties for their marketing purposes.

Sharing your Data

In addition to our Board members, staff and representatives e.g. the Club Capital Investment Team, we may also share your data with the following:

Our funding partners e.g. Sport England and other investors
Our legal and other professional advisors
Statutory Authorities e.g. for fraud prevention purposes
Service providers

We rely on some external services providers, for example our loan management system which holds data on all in progress and approved loans is provided by Form Assembly, and our electronic signing service is provided by Conga. We also use external providers for IT services and cloud storage and to collect direct debits.

We limit the personal data that we share to the minimum necessary to provide the service, and the provider will only be able to use personal data for the specific purposes for which it was shared. If we stop using the service, we ensure your data is deleted or securely returned to us.

Transferring Data to other Countries

We use some US-based companies that provide services such as cloud storage and data collection which involve the transfer your data to countries outside the UK.

To ensure your personal data and fundamental rights are protected, we rely on Standard Contractual Clauses together with the following additional safeguards:

FormAssembly

FormAssembly follows the NIST CyberSecurity Framework, which is a voluntary Framework consisting of standards, guidelines, and best practices to manage cybersecurity-related risks.

Further information is available at: https://www.formassembly.com/security/

We will not transfer your information to any other countries unless there is a UK-applicable adequacy decision for the specific country to which the data is transferred or where we can be certain that there are adequate safeguards provided for your information and individual rights standards.

Data Retention

Personal data is retained as follows:

Contact information

Expression of interest forms that do not lead to a loan application.
Applications which are unsuccessful and do not result in a loan being deployed will be deleted from all systems after 3 years, being the length of time during which the Investment Team will need to cross reference any new applications from the same club.
Applications which are successful and result in a loan being deployed will be held on all systems until 6 years after the loan has been fully repaid or written off, being the length of time following a breach of contract in which either party is entitled to make a legal claim.

Information on key people

Applications which are unsuccessful and do not result in a loan being deployed will be deleted from all systems after 3 years, being the length of time during which the Investment Team will need to cross reference any new applications from the same club.
Applications which are successful and result in a loan being deployed will be held on all systems until 6 years after the loan has been fully repaid or written off, being the length of time following a breach of contract in which either party is entitled to make a legal claim.

Proof of ID

Held for 6 years after the loan is repaid in full or written off, being the length of time following a breach of contract in which either party is entitled to make a legal claim.

Changes to this Privacy Notice

We keep our privacy notice under regular review. This privacy notice was last updated on 14th March 2023 and previous versions can be obtained by contacting us.