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* Privacy Policy
PRIVACY POLICY
Last updated on 9 May 2023.
Welcome to the privacy policy (the "Privacy Policy") of:
* LONDON MARATHON EVENTS LIMITED (company number 01528489) of 190 Great Dover
Street, London, England, SE1 4YB; and
* LONDON MARATHON FOUNDATION (the operating name of THE LONDON MARATHON
CHARITABLE TRUST LIMITED, company number 01550741, charity number 283813) of
190 Great Dover Street, London, England, SE1 4YB,
(collectively, the "London Marathon Group").
This Privacy Policy is issued on behalf of the London Marathon Group so when We
refer to "We", "Us" or "Our" in this Privacy Policy, We are referring to the
relevant company in the London Marathon Group responsible for processing your
data.
We respect your privacy and are committed to protecting your personal data. This
Privacy Policy will inform you as to how We look after your personal data when
you visit Us at:
* www.tcslondonmarathon.com;
* www.londonmarathonfoundation.org;
* www.thebighalf.co.uk;
* www.vitalitywestminstermile.co.uk;
* www.vitalitylondon10000.co.uk;
* www.cityrace.co.uk;
* www.ridelondon.co.uk;
* www.swimserpentine.co.uk;
* www.brightonmarathonweekend.co.uk;
and/or
* any of the other websites and/or mobile applications that are operated by the
London Marathon Group,
(collectively, the "Site"),
regardless of where you visit it from, and tell you about your privacy rights
and how the law protects you.
This Privacy Policy is provided in a layered format so you can click through to
the specific areas set out below. Please also use the Glossary to understand the
meaning of some of the terms used in this Privacy Policy.
1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED?
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. GLOSSARY
1. IMPORTANT INFORMATION AND WHO WE ARE
1. PURPOSE OF THIS PRIVACY POLICY
1. This Privacy Policy aims to give you information on how We collect
and process your personal data through your use of the Site,
including any data you may provide through the Site for the reasons
specified in paragraph 3.1 below.
2. We may collect data relating to children for the reasons detailed in
paragraph 4.4 below. For more information on Our policy on children’s
personal data, please see paragraph 4.12.
3. It is important that you read this Privacy Policy 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 Policy supplements the other notices and is
not intended to override them.
2. CONTROLLER
1. LONDON MARATHON EVENTS LIMITED which is part of the London Marathon
Group is generally the controller (except in the context of grants,
where it acts as joint controller with The Trust – please see
paragraph 10.2.1.1.1 for more information) and responsible for the
Site.
2. We have appointed a data protection officer (the "DPO") who is
responsible for overseeing questions in relation to this Privacy
Policy. If you have any questions about this Privacy Policy,
including any requests to exercise your legal rights, please contact
the DPO using the following details:
Full name of legal entity LONDON MARATHON EVENTS LIMITED Name or
title of DPO: David McConnell Email address:
privacy@londonmarathonevents.co.uk Postal address: 190 Great Dover
Street, London, England, SE1 4YB Telephone number: 0207 902 0200
3. You have the right to make a complaint at any time to the Information
Commissioner’s Office (the "ICO"), the UK supervisory authority for
data protection issues (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.
3. CHANGES TO YOUR PERSONAL DATA
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.
4. THIRD-PARTY LINKS
The Site 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 the Site, We encourage you to read
the privacy policy of every website you visit.
2. THE DATA WE COLLECT ABOUT YOU
1. Personal data, or personal information, means any information about an
individual from which that person can be identified. It does not include
data where the identity has been removed (anonymous data).
2. As further detailed in the table at paragraph 4.4, We may collect, use,
store and transfer different kinds of personal data about you which We
have grouped together as follows:
1. "Identity Data" includes first name, maiden name, last name, username
or similar identifier, marital status, title, date of birth,
photographs, vehicle registration number(s), bib/race number, age,
gender, qualifications, professional membership details and insurance
details.
2. "Contact Data" includes billing address, residential address,
delivery address, email address, social media handles and telephone
numbers.
3. "Financial Data" includes bank account and payment card details.
4. "Transaction Data" includes details about payments to and from you
and other details of products and services you have purchased from
Us.
5. "Technical Data" includes internet protocol (IP) address, your login
data, browser type and version, time zone setting and location,
browser plug-in types and versions, operating system and platform,
full 'Uniform Resource Locators clickstream to, through and from the
Site (including date and time) and other technology on the devices
you use to access the Site.
6. "Profile Data" includes your username and password, purchases or
orders made by you, your interests, preferences, feedback and survey
responses, performance, results and times at Our events, products you
viewed or searched for, page response times, download errors, length
of visits to certain pages, page interaction information (such as
scrolling, clicks, mouse-overs and methods used to browse away from
the page).
7. "Usage Data" includes information about how you use the Site,
products and services.
8. "Marketing and Communications Data" includes your preferences in
receiving marketing from Us and Our third parties and your
communication preferences.
3. We also collect, use and share "Aggregated Data" such as statistical or
demographic data for any purpose. Aggregated Data may be derived from
your personal data but is not considered personal data in law as this
data does not directly or indirectly reveal your identity. For example,
We may aggregate your Usage Data to calculate the percentage of users
accessing a specific Site feature. However, if We combine or connect
Aggregated Data with your personal data so that it can directly or
indirectly identify you, We treat the combined data as personal data
which will be used in accordance with this Privacy Policy.
4. As further detailed in the table at paragraph 4.4, We may also collect
personal data that includes "Sensitive" or "Special Categories" of
personal data (also known as "Special Category Data"), such as dietary
requirements, details about your race or ethnicity, information about
your health, genetic and biometric data and certain medical and health
information (including whether or not you are a wheelchair user) and
where required to ensure a safe environment and adherence to government
instructions and guidelines.
5. 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 goods or
services). In this case, We may have to cancel a product or service you
have with Us but We will notify you if this is the case at the time.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
1. We use different methods to collect data from and about you including
through:
1. Direct interactions. You may give Us your Identity Data, Contact
Data, Financial Data and personal data listed in paragraph 2 by
filling in forms, attending Our premises or events or by
corresponding with Us by post, phone, email or otherwise. This
includes personal data you provide when you:
1. apply for Our products or services;
2. create an account on the Site;
3. subscribe to Our service or publications;
4. request marketing to be sent to you;
5. apply to participate in one of Our Events;
6. volunteer in some capacity at one of Our events;
7. sign up to Our educational or charitable programmes;
8. enter a competition, promotion or survey;
9. attend Our premises or events; or
10. give Us some feedback.
2. Automated technologies or interactions. As you interact with the
Site, We may automatically collect Technical Data about your
equipment, browsing actions and patterns. We collect this personal
data by using cookies, server logs and other similar technologies. We
may also receive Technical Data about you if you visit other
websites. Please see Our cookie policy (the "Cookie Policy") for
further details.
3. Third parties or publicly available sources. We may receive personal
data about you from various third parties and public sources such as
analytics providers, advertising networks, technical, payment and
delivery services, data brokers or aggregators and publicly availably
sources such as Companies House and the Electoral Register based
inside the UK. Please contact us to find out more about the various
third parties and public sources from which We may receive personal
data about you.
4. HOW WE USE YOUR PERSONAL DATA
1. We will only use your personal data when the law allows Us to. Most
commonly, We will use your personal data in the following
circumstances:
1. Where We need to perform the contract We are about to enter into or
have entered into with you.
2. Where it is necessary for Our Legitimate Interests (or those of a
third party) and your interests and fundamental rights do not
override those interests.
3. Where We need to Comply with a Legal or Regulatory Obligation.
2. Please contact us to find out more about the types of lawful basis that
We will rely on to process your personal data.
3. Unless you are under the age of 13 (for more information, please see
paragraph 4.12) or unless otherwise provided in the table at paragraph
4.4 below, We do not generally rely on consent as a legal basis for
processing your personal data other than in relation to 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.
4. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
1. We have set out below, in a table format, a description of all the
ways We plan to use your personal data, and which of the legal bases
We rely on to do so. We have also identified what Our Legitimate
Interests are where appropriate and the period for which we retain
your personal data. For the avoidance of doubt, please be aware that
where we use a specific type of personal data for more than one
reason and there is a conflict between the retention period for each
such use in the table below, the longest retention period shall
prevail.
2. Note that We may process your personal data for more than one lawful
ground depending on the specific purpose for which We are using your
data. Please contact us if you need details about the specific legal
ground We are relying on to process your personal data where more
than one ground has been set out in the table below.
Purpose/Activity Type of data Lawful basis for processing including
basis of Legitimate Interest Retention period (not exceeding) To
enable you to apply to participate, or participate, or to organise a
team, in any of Our events (a) Identity Data
(b) Contact Data
(c) Transaction Data
(d) Technical Data
(e) Profile Data
(f) Marketing and Communications Data (a) Performance of a Contract
with you
(b) Necessary for Our Legitimate Interests (We need this data to be
able to allow you to participate in Our events and to stage Our
events) Five years from last application to participate To allow the
administration of medical attention or treatment either from the
event medical staff, St John Ambulance, other medical services
providers to the event as contracted by LMEL, or any doctor or
hospital, and to provide details (including details of medical
treatment) to the Medical Director of the applicable event or others
authorised by her/him. a) Identity Data (b) Contact Data (c )
Special Category Data (a) Performance of a Contract with you
(b) Necessary for Our Legitimate Interests (We need this data to be
able to allow you to participate in Our events and to stage Our
events and to provide and procure the provision of medical
assistance and/or medical care in the case of illness, injury or an
emergency situation). Six years from the date of the applicable
event To facilitate and publish the results of Our events (a)
Identity Data
(b) Profile Data (a) Necessary for Our Legitimate Interests (We need
the ability to publish and store the results, rank individuals,
challenge results after the specific event and keep a historic log
of this data all for the purpose of staging the event(s) and for
archival and historic research. This also allows participants to
rank themselves against other participants) In perpetuity To
televise, film, photograph and/or otherwise record Our events (a)
Identity Data (a) Necessary for Our Legitimate Interests (We need
the ability to publish, display, sell and distribute Our events by
means of film, television, radio, print media, internet, publicity
material or any other media now or in the future) In perpetuity
To provide the official London Marathon application(s) and enable
the functions and features within any such official London Marathon
application(s).
(a) Identity Data
(b) Contact Data(c) Transaction Data
(d) Technical Data
(a) Performance of a Contract with you (the provision of the
application in accordance with its terms of use)
(b) Consent (for the function that allows your location in the
relevant London Marathon to be known by your safety supporter(s))
Subject to the other rows of this table in relation to a
participant’s participation at the London Marathon, with respect
solely to Our provision of any application(s), 90 days from the date
of the relevant London Marathon. To invite you to participate, and
for you to participate, in Our hospitality (a) Identity Data
(b) Contact Data
(c) Marketing and Communications Data (a) Performance of a Contract
with you
(b) Necessary for Our Legitimate Interests (We need this data to be
able to give you the option to attend, and to provide you with,
high-quality hospitality) Three years since the last invitation or
purchase, whichever is later To enable you to volunteer at Our
events (a) Identity Data
(b) Contact Data
(c) Profile Data
(d) Marketing and Communications Data (a) Performance of a Contract
with you
(b) Necessary for Our Legitimate Interests (We need this data to be
able to allow you to participate in Our events as a volunteer)
(c) Necessary to Comply with a Legal or Regulatory Obligation
(including security and safety at Our events and for tax purposes)
Three years since your last application to volunteer To enable you
to provide your services on a casual labour basis to Us (a) Identity
Data
(b) Contact Data
(c) Financial Data
(d) Transaction Data
(e) Profile Data
(f) Marketing and Communications Data (a) Performance of a Contract
with you
(b) Necessary for Our Legitimate Interests (We need this data to be
able to contact you about becoming a service provider to Our
event(s))
(c) Necessary to Comply with a Legal or Regulatory Obligation
(including security and safety at Our events and tax purposes) Seven
years since you applied for your last role To enable you to be
included on Our media lists (a) Identity Data
(b) Contact Data
(c) Marketing and Communications Data Necessary for Our Legitimate
Interests (We need this data to be able to enable Our events to be
covered in the media) Three years To enable you to be a partner,
sponsor or supplier or potential partner, sponsor or supplier of or
to Us or Our events (a) Identity Data
(b) Contact Data
(c) Financial Data
(d) Transaction Data
(e) Marketing and Communications Data (a) Performance of a Contract
with you (as Our partner, sponsor or supplier)
(b) Necessary for Our Legitimate Interests (We need this data to be
able to contact you about becoming a partner, sponsor or supplier to
allow you to become officially associated with Us or Our event(s))
(c) Necessary to Comply with a Legal or Regulatory Obligation
(including for tax purposes) Six years after the end of any contract
(if any) or six years from the last correspondence about being a
potential partner, sponsor or supplier To enable you to be a medical
professional including doctor, podiatrist and physiotherapist at one
of Our events (a) Identity Data
(b) Contact Data
(c) Marketing and Communications Data (a) Performance of a Contract
with you
(b) Necessary for Our Legitimate Interests (We need this data to be
able to allow you to provide your services at Our events, to ensure
that you are adequately qualified and to ensure that We have the
requisite number of medical professionals at Our events)
(c) Necessary to Comply with a Legal or Regulatory Obligation
(including for tax and insurance purposes) Six years from the date
of the last event you assisted with To enable you to be a Golden
Bond, Silver Bond or other Charity contact or to apply to be part of
Our charity ballots (a) Identity Data
(b) Contact Data
(c) Financial Data
(d) Transaction Data
(e) Marketing and Communications Data (a) Performance of a Contract
with you
(b) Necessary for Our Legitimate Interests (We need this data to be
able to provide you with the benefits of being a Bond holder or
charity contact and to ensure that you remain on the waiting list if
you are on such list) Six years after the expiry of your Bond or
last application to be an official charity; or
For as long as those remaining on the waiting list wish to remain
there To enable you to attend one of Our events in any capacity that
requires photographic accreditation (not otherwise dealt with in
this table) (a) Identity Data
(b) Contact Data (a) Necessary to Comply with a Legal or Regulatory
Obligation
(b) Performance of a Contract with you
(c) Necessary for Our Legitimate Interests (We need this for
security reasons) Six years after the last time you were accredited
To enable you to apply to participate in Our events if you are under
13 years of age (a) Identity Data
(b) Contact Data (a) Consent (parental consent either obtained by Us
or via a third party)
(b) Necessary for Our Legitimate Interests (to allow minors to
participate in Our events, please see paragraph 4.12 below for more
information) Five years from last application to participate or
until you reach the age of 13, whichever occurs sooner To register
you as a new customer (not otherwise dealt with in this table) (a)
Identity Data
(b) Contact Data (a) Performance of a Contract with you
(b) Necessary for Our Legitimate Interests (to provide you with
customer services) Three years from last registration as a customer
or last interaction with Us as a customer, whichever is later To
process and deliver your order including:
(a) Managing payments, fees and charges; and
(b) Collecting and recover money owed to Us (a) Identity Data
(b) Contact Data
(c) Financial Data
(d) Transaction Data
(e) Marketing and Communications Data (a) Performance of a Contract
with you
(b) Necessary for Our Legitimate Interests (to recover debts due to
Us)
(c) Necessary to Comply with a Legal or Regulatory Obligation
(including for tax and consumer protection purposes) Six years from
order completion To manage Our relationship with you which will
include:
(a) Notifying you about changes to Our terms or Privacy Policy
(b) Asking you to leave a review or take a survey; and
(c) dealing with any complaints and responding to feedback (a)
Identity Data
(b) Contact Data
(c) Profile Data
(d) Marketing and Communications Data (a) Performance of a Contract
with you
(b) Necessary to Comply with a Legal or Regulatory Obligation
(c) Necessary for Our Legitimate Interests (to keep Our records
updated and to study how customers use Our products/services) Six
years from last correspondence To enable you to partake in a prize
draw, competition or complete a survey (a) Identity Data
(b) Contact Data
(c) Profile Data
(d) Usage Data
(e) Marketing and Communications Data (a) Performance of a Contract
with you
(b) Necessary for Our Legitimate Interests (to study how customers
use Our products/services, to develop them and grow Our business)
Three years from prize draw, competition or survey To administer and
protect Our business and the Site (including troubleshooting, data
analysis, testing, system maintenance, support, reporting and
hosting of data) (a) Identity Data
(b) Contact Data
(c) Technical Data (a) Necessary for Our Legitimate Interests (for
running Our business, provision of administration and IT services,
network security, to prevent fraud and in the context of a business
reorganisation or group restructuring exercise)
(b) Necessary to Comply with a Legal or Regulatory Obligation Three
years from collection of data To deliver relevant Site content and
advertisements to you and measure or understand the effectiveness of
the advertising We serve to you (a) Identity Data
(b) Contact Data
(c) Profile Data
(d) Usage Data
(e) Marketing and Communications Data
(f) Technical Data (a) Necessary for Our Legitimate Interests (to
study how customers use Our products/services, to develop them, to
grow Our business and to inform Our marketing strategy) Three years
from collection of data To use data analytics to improve the Site
and Our products/services, marketing, customer relationships and
experiences (a) Technical Data
(b) Usage Data (a) Necessary for Our Legitimate Interests (to define
types of customers for Our products and services, to keep the Site
updated and relevant, to develop Our business and to inform Our
marketing strategy) Three years from collection of data To make
suggestions and recommendations to you about goods or services that
may be of interest to you (including where you have applied via the
ballot for a place at one of Our events or where your image is
captured by our official photographer at one of Our events) (a)
Identity Data
(b) Contact Data
(c) Technical Data
(d) Usage Data
(e) Profile Data (a) Necessary for Our Legitimate Interests (to
develop Our products/services and grow Our business and to provide
you with the opportunity to purchase goods that commemorate your
participation in one of Our events (such as an official photograph))
Three years from last unsuccessful ballot application or three years
from last participation in one of Our events, whichever is later For
event logistics and operational purposes (including emergency
service access routes, personal care plans, safety and security and
public access routes) (a) Identity Data
(b) Contact Data (a) Necessary for Our Legitimate Interests (for
ensuring that the event logistics are in place and safety and
security is maintained to ensure successful staging of Our events)
(b) Necessary to Comply with a Legal or Regulatory Obligation
(safety and security and insurance) Three years from the event to
which the data relates To enable you to access and/or remain in Our
premises or events or ensuring the safety of you and others with the
aim of:
(a) creating a safe environment (including observing protocols
around limiting the number of visitors and staff within Our spaces,
and other measures which have the aim of keeping people safe;
(b) adhering to the most up-to-date government instructions and
guidelines; and
(c) maintaining and monitoring facilities for health and safety
purposes (a) Identity Data
(b) Contact Data
(c) Special Category Data (a) Necessary to Comply with a Legal or
Regulatory Obligation
(b) Necessary for Our Legitimate Interests (to keep Our records
updated and to keep people and premises safe) For as long as
necessary to fulfil the purposes We collected it for, including for
the purposes of satisfying any legal requirements For The Trust to
receive grant applications (a) Identity Data
(b) Contact Data
(c) Transaction Data
(d) Financial Data Necessary for Our Legitimate Interests (We need
this data to analyse the applicants (for example, by area and type
of project), to assess applications and to track an applicant's
record with Us since they may re-apply) Five years from last
application For The Trust to allocate grants (a) Identity Data
(b) Contact Data
(c) Financial Data
(d) Transaction Data (a) Performance of a Contract with you
(b) Necessary for Our Legitimate Interests (We need this data to
ensure that each grantee continues to comply with the grant
conditions and to analyse the applicants (for example, by area and
type of project)
(c) Necessary to Comply with a Legal or Regulatory Obligation
(charity laws and regulations concerning the grant) In perpetuity
For The Trust to work with grant funders (a) Identity Data
(b) Contact Data
(c) Financial Data
(d) Transaction Data (a) Performance of a Contract with you (as a
grant funder)
(b) Necessary for Our Legitimate Interests (We need this data to be
able to work with you as a grant funder)
(c) Necessary to Comply with a Legal or Regulatory Obligation
(including for tax purposes) Six years after the end of any contract
(if any) or six years from the last correspondence To allow Us to
become affiliated to selected membership organisations (such as
London Funders, World Marathon Majors and the World Association of
Cycling Events) (a) Identity Data
(b) Contact Data
(c) Financial Data
(d) Transaction Data (a) Performance of a Contract with you
(membership rules and regulations)
(b) Necessary for Our Legitimate Interests (We need this data to be
able to utilise the membership benefits) Six years after the
affiliation terminates
5. AUTOMATED DECISION MAKING
We use your personal data to make the following automated decisions:
1. Event entries ballot. All applications for an entry to one of Our
events received via one of Our ballots are processed electronically.
Each application is uploaded to Our database, and Our database then
automatically assigns a hidden, protected reference number;
2. Competitions. We may, from time to time, run competitions where each
participant's personal data is uploaded to Our database and a
successful participant is automatically selected at random;
3. Selection procedures. Entry to Our events may be dependent upon
times achieved at other events. In this case each applicant's
personal data is uploaded to Our database and a successful
participant is selected by automated means;
4. Seeding. Start times or start positions at Our events may be
dependent upon estimated finishing time. In this case each
participant's personal data is uploaded to Our database and a
participant's staring place/group is selected by automated means.
6. MARKETING
We strive to provide you with choices regarding certain personal data
uses, particularly around marketing and advertising.
7. PROMOTIONAL OFFERS FROM US
1. We may use your Identity Data, Contact Data, Technical Data, Usage
Data and Profile 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).
2. You will receive marketing communications from Us if you have
requested information from Us or purchased goods or services from Us
or if you provided Us with your details when you entered a
competition or registered for a promotion and, in each case, you
have not opted out of receiving that marketing.
8. THIRD-PARTY MARKETING
We will get your express opt-in consent before We share your personal
data with any company outside the London Marathon Group for marketing
purposes.
9. OPTING OUT
1. You can ask Us or third parties to stop sending you marketing
messages at any time by logging into the Site and checking or
unchecking relevant boxes to adjust your marketing preferences or by
following the opt-out links on any marketing message sent to you or
by contacting us at any time.
2. Where you opt out of receiving these marketing messages, this will
not apply to personal data provided to us as a result of
product/service purchase, product/service experience or other
transactions.
10. COOKIES
You can set your browser to refuse all or some browser cookies, or to
alert you when websites set or access cookies. If you disable or refuse
cookies, please note that some parts of the Site may become
inaccessible or not function properly. For more information about the
cookies We use, please see Our Cookie Policy.
11. CHANGE OF PURPOSE
1. 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.
2. 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.
3. 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.
12. CHILDREN'S DATA
1. We may collect and process the personal data of children below the
age of 13 for the purposes of administering the following areas of
our business, in which case we will always ensure that consent is
given or authorised by the holder of parental responsibility over
that child:
1. Events in which children may participate. We require the child's
details in order for them to participate;
2. To televise, film and/or otherwise record Our events and to take
photographs and record footage of Our events; and
3. To facilitate and publish the results of Our events.
5. DISCLOSURES OF YOUR PERSONAL DATA
1. We may have to share your personal data with the parties set out below
for the purposes set out in the table in paragraph 4.4 above.
1. Internal third parties as set out in paragraph 10.2.1 below.
2. External third parties as set out in paragraph 10.2.2 below.
3. Specific third parties listed in the table in paragraph 4.4 above.
4. Third parties to whom We may choose to sell, transfer, or merge parts
of Our business or Our assets. Alternatively, We may seek to acquire
other businesses or merge with them. If a change happens to Our
business, then the new owners may use your personal data in the same
way as set out in this Privacy Policy.
2. 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.
6. INTERNATIONAL TRANSFERS
1. Many of Our external third parties are based outside the UK so their
processing of your personal data will involve a transfer of data outside
the UK. Such destinations may not have laws which protect your
information to the same extent as in the UK.
2. Whenever We, or a third party to whom We transfer your personal data,
transfers your personal data out of the UK, We ensure a similar degree
of protection is afforded to it by ensuring at least one of the
following safeguards is implemented:
1. Your personal data is transferred to countries that are deemed to
provide an adequate level of protection for personal data under UK
data protection laws. For further details, see the section headed “Is
the restricted transfer covered by ‘adequacy regulations’?” on
International transfers after the UK exit from the EU Implementation
Period;
2. Where We use certain service providers: entering into specific
contracts approved by the ICO, which give personal data the same
protection it has in the UK. For further details, see appropriate
safeguard no.6 under the section headed “Is the restricted transfer
covered by appropriate safeguards?” on International transfers after
the UK exit from the EU Implementation Period; or
3. Use of either:
1. The international data transfer agreement; or
2. The international data transfer addendum to the European
Commission’s standard contractual clauses for international data
transfers,
both issued by the ICO under section 119A(1) of the Data
Protection Act 2018. For further details, see
International data transfer agreement and guidance
.
3. Please contact us if you want further information on the specific
mechanism used by Us when transferring your personal data out of the UK.
7. DATA SECURITY
1. We have put in place appropriate security measures to prevent your
personal data from being accidentally 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.
2. 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.
8. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
1. 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.
2. 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.
3. Details of retention periods for different aspects of your personal data
are set out in the table in paragraph 4.4 above.
4. By law, We have to keep basic information about Our customers (including
Contact Data, Identity Data, Financial Data and Transaction Data) for
six years from the end of the company financial year in which they cease
being customers, for tax purposes.
5. In some circumstances, you can ask Us to delete your data: see paragraph
9.1.3 below for further information.
6. 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.
9. YOUR LEGAL RIGHTS
1. Under certain circumstances, you have rights under data protection laws
in relation to your personal data. Please click on the links below to
find out more about these rights:
1. Request access to your personal data.
2. Request correction of your personal data.
3. Request erasure of your personal data.
4. Object to processing of your personal data.
5. Request restriction of processing your personal data.
6. Request transfer of your personal data.
7. Right to withdraw consent.
2. If you wish to exercise any of the rights set out in paragraph 9.1
above, please contact us.
3. 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.
4. 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.
5. 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.
10. GLOSSARY
1. LAWFUL BASIS
1. "Legitimate Interest" means the interest of Our business in
conducting and managing Our business to enable Us to give you the
best service/product and the best and most secure experience. We make
sure We consider and balance any potential impact on you (both
positive and negative) and your rights before We process your
personal data for Our Legitimate Interests. We do not use your
personal data for activities where Our interests are overridden by
the impact on you (unless We have your consent or are otherwise
required or permitted to by law). You can obtain further information
about how We assess Our Legitimate Interests against any potential
impact on you in respect of specific activities by contacting us.
2. "Performance of a Contract" means processing your data where it is
necessary for the performance of a contract to which you are a party
or to take steps at your request before entering into such a
contract.
3. "Comply with a Legal or Regulatory Obligation" means processing your
personal data where it is necessary for compliance with a legal or
regulatory obligation that We are subject to.
2. THIRD PARTIES
1. INTERNAL THIRD PARTIES
Other companies in the London Marathon Group from time to time, and
which are based in the UK, including:
1. The Trust, whose main function is to award grants to inspire
children and adults across the UK to be active. We may share
personal data with The Trust for any purpose concerning:
(A) the administration of the London Marathon Group (such reporting
obligations and preparation of group accounts);
(B) the promotion of the work of The Trust and the London Marathon
Group;
(C) dealings with sponsors and suppliers of Our events;
(D) dealings with participants in Our events; and
(E) the receipt by The Trust of grant applications, the allocations
of grants and any work The Trust undertakes with grant funders. The
Trust acts as a joint controller in this regard.
2. EXTERNAL THIRD PARTIES
1. Service providers acting as processors, who provide various
services such as event entry, entry management and supporting
services, grant management services, timing services, services
with respect to the dissemination of photos, videos and other
memorabilia, facilitation services for graphical representation of
results, data analysis services, publication of race results
services and IT and system administration services. Please contact
us to find out more about the various third parties who may
process your personal data.
2. Professional advisers acting as processors or joint controllers,
including lawyers, bankers, auditors and insurers based in the UK
who provide consultancy, banking, legal, insurance and accounting
services.
3. HM Revenue & Customs, regulators and other authorities acting as
processors or joint controllers based in the UK who require
reporting of processing activities in certain circumstances.
4. Third party athletic bodies and affiliations such as:
1. World Marathon Majors LLC, to allow them to:
(A) validate anyone who is entitled to Six Star Finisher status
(or equivalent) or where runners are on the journey to such
achievement; and
(B) operate the Age Group World Championships and Rankings;
2. UK Athletics, to allow them to populate the Power of 10 ranking
system.
5. Broadcasters such as the BBC, to allow them to commentate on Our
events.
6. Where you have consented to pass your personal data to third
parties (for example, hotel groups about accommodation in relation
to Our events or charities where you have initially been
unsuccessful in your event application).
7. Where you have provided consent to a third party to receive your
information from LMEL (for example, where you consent to such a
transfer during the sign-up process for a fundraising page).
8. Media, where We deem that there is a human-interest story about
your participation at one of Our events.
3. YOUR LEGAL RIGHTS
You have the right to:
1. 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.
2. 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.
3. 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.
4. 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.
5. 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.
6. 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.
7. 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.
London Marathon Events is committed to inspiring activity. Find out more about
our vision, values and aims here.
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