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1 International Tennis Integrity Agency Privacy Policy INTERNATIONAL TENNIS INTEGRITY AGENCY PRIVACY POLICY WHO ARE THE ITIA AND WHAT DO WE DO? The International Tennis Integrity Agency Ltd ("ITIA", "we", "us", “our”) is the dedicated anti- corruption unit for professional tennis and is charged with enforcing the sport's zero tolerance policy towards gambling related corruption world-wide. The ITIA is a private limited company based in Roehampton, London and is operationally independent from the sport of tennis. The ITIA’s members are: ATP Tour, Inc. ("ATP"); the International Tennis Federation ("ITF"); the Women's Tennis Association ("WTA"); and the Grand Slam Board (being Australian Open, Roland-Garros, US Open and, in the case of Wimbledon, a joint Committee of Management consisting of AELTC) (the "Grand Slam Board") (together, the “Governing Bodies”). The ITIA reports to the Tennis Integrity Supervisory Board (“TISB”), which comprises a senior representative from each of the Governing Bodies and the Grand Slam Board, together with five independent directors. The ITIA liaises with the TISB in respect of its day to day functioning. This function was previously carried out by the Tennis Integrity Unit (“TIU”). The TIU has been subsumed within the ITIA (effective from 1 January 2021) but shall continue to operate only for the limited purpose of completing certain ongoing matters that commenced prior to 1 January 2021, primarily to investigate and prosecute active investigations and/or claims under the Tennis Anti- Corruption Program (“TACP”). All data previously held and used by the TIU has now transferred to the ITIA and will be used the same purposes, as set out herein. As well as the TISB, the TIU liaises (including by sharing personal data) with the Professional Tennis Integrity Officers (“PTIOs”) (who have been appointed by members of the TISB, although this role shall no longer exist in relation to new investigations commencing on or after 1 January 2021) in respect of its day to day functioning. For the purposes of the General Data Protection Regulation (EU) 2016/679 or “GDPR”, the UK GDPR and the Data Protection Act 2018 (and all other laws that apply from time to time relating to the use your personal data), the ITIA is the “controller”, meaning that we are responsible for deciding how your personal data is used and more importantly, for keeping your data safe and only using it for legitimate reasons. We are committed to protecting your privacy and will take all steps necessary to comply with our legal obligations when collecting and using your personal data. This Privacy Policy explains how we fulfil this commitment, so please read this carefully. 1 WHAT THIS PRIVACY POLICY TELLS YOU 1. Who we collect personal data about; 2. What types of personal data you provide to us when using the www.itia.tennis website (the “Website”), when you use our app or when you otherwise directly interact with us on other occasions. We also explain what types of personal data the ITIA may collect from you or receive about you from third parties; 3. How and why we use this data and the reasons we are legally allowed to do so; 4. Who we share your data with; 5. How long we keep your data for and how we keep it secure; 6. Information in relation to overseas transfers of your data; 7. Links to third party websites 8. Your rights over your data and how you can exercise those rights; 9. Who our European representative is in relation to data protection matters in the European Economic Area and how to contact them; and 10. How to contact us if you have any issues or want to find out more. When we refer to “personal data” in this Privacy Policy, this covers any information from which you can be personally identifiable (whether directly or indirectly). This might include things like your name, email, date of birth, address, phone numbers, online identifiers and device IDs, financial information, certain special categories of data (such as your religious beliefs, health related data, ethnicity, political opinions, sexual history etc.) and data relating to your criminal convictions and offences. If we update our Privacy Policy, we will post any changes on our Website and through our app. WHO DO WE COLLECT PERSONAL DATA ABOUT? We collect personal data about “Covered Persons” and “Related Persons” (as defined in the TACP), including tennis players, people transmitting data to facilitate betting (‘courtsiders’), gamblers and other people in the tennis community, including tournament officials, coaches, physiotherapists, match supervisors, umpires, media representatives and other individuals who have obtained accreditation for the purposes of attending a professional tennis match or other competition organised, sanctioned or recognised by any of the Governing Bodies as a player guest or as tournament support provider (“Event”); individuals who are connected with a “Covered Person” in respect of whom there are reasonable grounds to suspect they have breached, are breaching, and/or intend to breach the TACP, including people placing bets or wagering on an Event; and persons who may pose a threat to the integrity of the sport of tennis and/or an Event, may have knowledge concerning the corruption of an Event, or may have solicited or intends to solicit an individual bound by the TACP. 2 We may also collect information about other individuals who have directly interacted with us as part of an investigation (e.g. witnesses), people who have downloaded a copy of the TACP or who otherwise browse or use our Website or app and business contacts of the ITIA. WHAT PERSONAL DATA DO WE COLLECT AND HOW? Data which you provide directly to us: You may provide personal data directly to us: • When you sign-up to, access and use the Tennis Integrity Protection Programme (“TIPP”), which personal data may include your name, date of birth, nationality, email address, password, WTA, ITF or ATP player portal log-in details and International Player Identification Number (“IPIN”). • When you download a copy of the TACP, which personal data shall be your name and email address. • In the context of an anti-corruption investigation where we may request personal data from you, including (but not limited to) telephone records, bank details and credit card transactions. We will also obtain other personal data about you from a recorded interview with you. • If you communicate directly with us, whether that is by email, phone, the Website, our app or if you send us a letter. • If you make a complaint or grievance to the ITIA. • When you attend an education workshop, conference or seminar organised by the ITIA, which personal data may include registration information such as your name, address and other contact information. Data which the ITIA collects itself or receives from third parties: The ITIA collects and receives personal data about you through various different methods and third party sources including, without limitation: • Where you are subject to an investigation, we may extract information from your devices. • We may collect personal data from 'open source' media (e.g. Facebook, Twitter etc.) relating to players and other individuals of interest in the context of investigating alleged corruption. • Player information that is publicly available from Governing Body websites, for example player photographs and statistics. • Information about players' match performance, physical fitness and ability, which we may receive from tournament officials, open source information, tournament physiotherapists/doctors. • We may receive by email or other forms of communication, personal data relating to individuals who are the subject of an allegation of corruption, including from anonymous sources. 3 • Betting operators and betting regulators may share account and/or other personal data relating to gamblers exhibiting unusual or suspicious behaviour. • The International Betting Integrity Association (“IBIA”) (formerly the European Sports Security Association) may send us limited personal data relating to players who have been involved in a suspicious match. • The TIU may provide us with data relating to previous investigations and/or prosecutions, including where this is relevant to a new investigation, prosecution or an appeal against a sanction. • The ITF and/or ATP may provide us with scorecard/match related data (which includes certain personal data relating to players, Match Supervisors and Chair Umpires) to enable us to verify a betting alert receiving from a betting operator, betting regulator or IBIA. • Match Supervisors (and/or other tournament accredited personnel, including Chair Umpires) may provide names/contact details of players and match-related information requested by the ITIA, including information relating to: (i) the scorecard; (ii) any potentially significant acts such as injuries/illness; (iii) a break in play; (iv) the names of a player's medical team; and (v) details of any treatment provided. • The ITIA is provided with access to Governing Body portals through which it may access names and contact information of Match Supervisors and Chair Umpires and various personal data relating to players. • The ITF provides the ITIA with access to its database, to enable the ITIA to obtain various player data, including name, contact details, IPIN account information, IP address and device information, passport details and details of associated persons (such as friends, family and agent). • Tournament Officials provide the ITIA with various player data relevant to that particular tournament and photographs and other personal data relating to courtsiders. • Players and officials may provide the ITIA with personal data relating to individuals who have set up bogus social network pages in the name of a particular player, or who send abusive/threatening messages to a player or make a corrupt approach. • Tournament broadcasters may provide us with match recordings where relevant to our investigation. • The Governing Bodies may provide us with courtsider information, including name, date of birth, aliases, contact details and photographs and videos of their activity, any reasons for their exclusion from tournament grounds and information about their presence at a particular match.
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