TERMS AND CONDITIONS – SPOTLIGHT YOU COMPETITION

About Us

Jungle Creations Limited, trading as VT (“VT") and the Birmingham 2022 Commonwealth Games Organising Committee Limited (“Birmingham 2022")(collectively "we"/"us") take their responsibility to look after your personal information very seriously. VT and Birmingham 2022 are a ‘joint controllers’ for the purposes of the UK Data Protection Act 2018 and the UK General Data Protection Regulation (collectively the "Data Protection Laws"), in relation to the personal data processed under this Privacy Notice and we are responsible for, and control the processing of, any personal information you share with us in relation to the Spotlight You Competition ("Competition"). Separately the terms and conditions about the Competition can be found at Terms and Conditions.

This Privacy Notice contains important information about:

The personal information we collect about you;

Why we collect your information and what we do with it;

Who your information will be shared with; and

Your rights in relation to your personal data.

This notice relates to information collected from our Competition website [vt.co/spotlightyou] ("Website") via email and any forms or questionnaires which you may complete on the Website or otherwise, as well as any postal, telephone or email enquiries you may make to VT and any other information VT requests from you.

Our website contains links to other websites of interest operated by third parties, including social media sites such as Facebook and Twitter and websites such as the Information Commissioner’s Office. Please note that this Privacy Notice only applies to the personal information that we collect through our website and our social media channels, and we cannot be responsible for personal information that third parties may collect, store and use through their websites. You should exercise caution and always read the Privacy Notice of each website you visit carefully.

How to contact us

If you would like to contact us in relation to the any of the following:

Questions about this Privacy Notice or the information we hold about you;

Exercise any of your rights in relation to your personal data;

Make a complaint about how we have handled your personal data; or

Wish to have a copy of this Privacy Notice in another format (for example: audio, large print or braille),

please contact VT's Data Protection Officer at:

Data Protection Officer

Jungle Creations Limited

6 Batty Street

London

E1 1RH

Email: birmingham2022@junglecreations.com

Between us, VT is the joint controller primarily responsible for communicating with you in relation to our processing of your personal data.

What information do we collect and why do we need it?

We explain below the types of personal data processing, the purposes for processing and the lawful basis relied on to process the data (please see section "How is processing your data lawful" for further detail).

Applicant Data

If you are an Applicant (as defined in the Competition T&C), we need to collect the following data about you in order to register your application in the Competition:

Name

Age

Email Address

Phone Number

Where you are located (Your home city/towm)

Information about the nomination as set out in the Competition nomination form

Nominee Data

If you are a Nominee (as defined in the Competition T&C), we collect from the Applicant and you the following information about you in order to administer the Competition:

Name

Age

Email Address

Information about the nomination as set out in the Competition nomination form

Other information about you that we may request from you in relation to the Competition

Specifically in relation to the Selected Nominees, we will undertake background checks which involves collecting information about you available from public sources. The purpose of these checks is to ensure that all Selected Nominees will be a positive role model suited to the objectives of the Competition and would not adversely affect the reputation of VT and Birmingham 2022.

General Enquiries

When you contact us for general enquiries we collect your name, contact details and information regarding your query.

Regulatory Requirements and Legal Claims

We will process your personal data to comply with any procedures, laws and regulations which apply to us and to establish, exercise or defend our legal rights where it is necessary for our legitimate interests or the legitimate interests of others.

Who will have access to your personal information?

We use a third-party Klaviyo to store personal data as described in this Privacy Notice.

How is processing your personal data lawful?

We are allowed to process your personal data based on the following legal bases for the purposes explained in the previous section "What information do we collect and why do we need it":

Legitimate Interests - We are permitted to process your personal data if it is based on our ‘legitimate interests’ i.e. we have good, sensible, practical reasons for processing your personal data which is in our interests. To do so, we have considered the impact on your interests and rights, and have placed appropriate safeguards to ensure that the intrusion on your privacy is reduced as much as possible.

We process the Applicant Data, Nominee Data and General Enquiries under this lawful basis.

You can object to processing that we carry out on the grounds of legitimate interests. See the section headed "Your Rights" to find out how.

Contract - It is necessary for our performance of the contract you have agreed to enter with us. If you do not provide your personal data to us, we will not be able to carry out our obligations under the terms of your contract.

We process the Applicant Data and Nominee Data under this lawful basis.

Legal obligation - We are subject to legal obligations to process your personal data for the purposes of complying with applicable regulatory rules and to make mandatory disclosures to government bodies and law enforcement agencies.

We process data in relation to Regulatory Requirements and Legal Claims under this lawful basis.

Explicit Consent – In relation to our processing of more sensitive types of personal data such as information about the Nominee's physical or mental health or conditions, sexual life, racial or ethnic origin, political opinions, religious or similar beliefs or trade union membership (referred to as "special categories of data"), we rely on your explicit consent. You can withdraw this consent at any time by reaching out to us using the information in the "How to contact us" section

We process the Applicant Data and Nominee Data under this lawful basis.

How we protect your personal data

We employ comprehensive and appropriate security measures in order to protect your personal data against accidental or unlawful destruction, accidental loss or alteration, unauthorised disclosure or access, and any other unlawful forms of processing. We aim to ensure that the level of security and the measures adopted to protect your personal data are appropriate for the risks presented by the nature and use of your personal data. Our security measures include organisational security (passwords and access controls, staff training, information security and data protection policies), physical security (secure data centres, building security) and IT security (firewalls, encryption).

Personal data processed as described in this Privacy Notice will only be processed in the UK.

Although we will always treat the information you send us with the strictest confidence, we cannot guarantee the security of the Internet. No transmission over the Internet can ever be guaranteed secure and it is possible, though very unlikely, that someone other than ourselves could access and read information sent to us in this way. If you feel concerned about this, please use another form of contact, e.g. telephone or post.

How long do we keep your personal data?

The following categories of personal data will be kept for the following periods:

Applicant Data – For up to 7 months

Nominee Data - For up to 7 months

General Enquiries – 6 months from resolution of the enquiry.

Your data protection rights

Under the Data Protection Laws, you have certain rights in relation to your personal data that we hold.

If you have any comments, concerns or complaints about the use of your personal data, please contact VT's Data Protection Officer (please see ‘How to contact us’).

You are not normally required to pay a fee for exercising any of your rights. However, where we receive requests which are manifestly unfounded or excessive, for example because they are repetitive in nature, we may:

Charge a reasonable fee taking into account the administration costs of providing the information or taking the action requested; or

Refuse to act on the request.

We will respond to any rights that you exercise within a month of receiving your request, unless the request is particularly complex, in which case we will respond within three months, but we will notify you if we need to do this.

Please be aware that there are exceptions and exemptions that apply to some of the rights which we will apply in accordance with the Data Protection Legislation. More detailed information can be found on the Information Commissioner’s Office website at https://ico.org.uk/ .

Your rights in relation to your personal data are as follows:

The right to be informed

We are required to tell you what data we collect about you, how it is being used, how long it will be kept and whether it will be shared with any third parties. We meet this requirement by providing you with this Privacy Notice.

The right of access to personal data

You have the right to request a copy of the personal data that we hold about you. This is often referred to as a subject access request. We will provide you with:

Confirmation that we are processing your personal data;

The categories of personal data;

A copy of the personal data;

Details of the purpose for which it is being or is to be processed;

Details of the recipients or classes of recipients to whom it is or may be disclosed, including if they are overseas and what protections are used for those overseas transfers;

The period for which it is held (or the criteria we use to determine how long it is held);

Any information available about the source of that data;

Whether we carry out any automated decision-making, or profiling, and where we do, information about the logic involved and the envisaged outcome or consequences of that decision or profiling;

Information about your right to request rectification, erasure or restriction or to object to such processing; and

The right to lodge a complaint with the ICO or another supervisory authority.

To help us assist you, please provide us with as much information as possible about the type of information you would like to see.

The right to rectification

You have the right to ask us to rectify personal data that we hold about you if you think it is inaccurate. You also have the right to ask us to complete information we hold about you if you think it is incomplete. If you would like to do this, email, call or write to us (please see ‘How to contact us’). You will need to provide us with enough information to be able to identify you. You will also need to notify us what personal data we hold about you is incorrect and what it should be replaced with.

The right to erasure (also known as the right to be forgotten)

In certain circumstances, you can ask for the personal data we hold about you to be erased from our records, where:

You do not believe that we need your data in order to process it for the purposes set out in this Privacy Notice;

If you had given us consent to process your data, you withdraw that consent and we cannot otherwise legally process your data;

You object to our processing and we do not have any legitimate interests that mean we can continue to process your data; or

Your data has been processed unlawfully or have not been erased when it should have been.

The right to restrict or prevent your personal data being processed

You have the right to request that we restrict the processing of your personal data in certain circumstances. You may request that we stop processing your personal data temporarily if:

You do not think that your data is accurate. We will start processing again once we have checked whether or not it is accurate;

The processing is unlawful but you do not want us to erase your data;

We no longer need the personal data for our processing, but you need the data to establish, exercise or defend legal claims; or

You have objected to processing because you believe that your interests should override our legitimate interests.

The right to data portability

You have the right to receive personal information you have given to us in a structured, commonly used and machine-readable format. You also have the right to request that we transmit this information directly to another organisation.

The right to object

You have the right to object to the processing of your personal data in certain circumstances including processing based on our legitimate interests and processing for direct marketing..

Rights in relation to automated decision making

These rights are not applicable as we do not carry out any automated decision making.

Complaints

Please contact VT's Data Protection Officer (please see ‘How to contact us’) if you have any questions or complaints about this Privacy Notice or our processing of your personal data.

If you have made a complaint and are dissatisfied with how we have handled your complaint then you have the right to complain to the Information Commissioner’s Office (ICO). Contact details can be found at https://ico.org.uk/global/contact-us/

Changes to this privacy notice

We regularly review and, where necessary, update our privacy information. If we plan to use personal data for a new purpose, we will communicate the changes via this Privacy Notice. Please check our Website occasionally to ensure you are aware of the most recent version of this notice. This Privacy Notice is effective from March 2021.