PRIVACY

1.0 INTRODUCTION

The Isle of Man Government Department for Enterprise (DfE) is the Race Promoter for the Isle of Man TT Races and Classic TT.

iomttraces.com is the official website for the Isle of Man TT Races and Classic TT and is owned and operated by the Isle of Man Government Department for Enterprise Motorsport Team.

This Privacy Policy is issued on behalf of the DfE operating as the Isle of Man TT Races and Classic TT, so when We refer to “We”, “Us” or “Our” in this Privacy Policy, We are referring to the relevant team within the Department for Enterprise 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 after We collect it via various channels, including when you visit:

- any of Our official websites which we operate from time to time (collectively, the “TT websites”), including but not limited to:

- iomttraces.com;
- shop.iomttraces.com;
- timing.iomttraces.com;
- ttplus.iomttraces.com
- any of Our mobile applications which we operate including but not limited to the official TT+ app, as periodically updated.

The TT Websites and the TT+ Apps are hereinafter referred to as the “TT Digital Platforms”.

Other Isle of Man Government Websites

DfE also has a sub-site on The Isle of Man Government website, gov.im/enterprise; this website is owned by the Cabinet Office. Their Privacy Notice in relation to how you use gov.im can be found at the top of each page next to the Terms and Conditions or following this link: https://www.gov.im/about-this-site/privacy-notice/.

TT Races has a sub-site on DfE's Visit Isle of Man website, visitisleofman.com/whats-on/motorsports-events however, Motorsport does not directly collect or process any personal information from this site. The website is owned by Visit Isle of Man. Any personal information collected from this sub-site will be processed by Visit Isle of Man; their Privacy notice can be found here: visitisleofman.com/visitor-information/privacy-notice.

Licenced Partners and Products

We also have a number of Official Travel Partners and Products. Whilst they are licenced partners or products We are not responsible and do not control the information on these websites, nor does We collect or share personal information with these sites.

Unless listed within this Privacy Policy, We are not responsible for the privacy policies of other websites or applications, and encourage you to read all applicable terms, conditions and privacy policies when using other websites and applications.

2.0 AGREEING TO OUR PRIVACY POLICY

By using our TT Digital Platforms, you agree to us using your data in accordance with this Privacy Policy. There are certain services that we may not be able to provide if you do not choose to provide relevant information.

By using our TT Digital Platforms, you agree to us collecting and using personal information about you in accordance with this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use our TT Digital Platforms.

You have choices about the data we collect. When asked to provide certain personal information you may decline, but where such is necessary to provide a service or feature, your use of that service or feature may be restricted as a result.

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 that includes but is not limited to; TT+ Privacy Notice and Official Ticketing Privacy Notice and is not intended to override them.

We will hold your personal information for as long as reasonably necessary for the relevant purpose.

3.0 WHAT INFORMATION IS COLLECTED?

Personal data, or personal information, means information relating to an identified or identifiable living individual. It does not include data where the identity of the individual to whom it relates has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which We have grouped together as follows:

“Identity Data” includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, photographs, age and gender.

“Contact Data” includes billing address, residential address, delivery address, email address, social media handles and telephone numbers.

“Financial Data” includes bank account and payment card details.

“Transaction Data” includes details about payments and donations to and from you and other details of products and services you have purchased from Us or other transactions between you and Us.

“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.

“Profile Data” includes your username and password, purchases or orders made by you, your interests, preferences, relationships held with other data subjects, feedback and survey responses, products you viewed or searched for, page response times, download errors, length of visits to certain pages and page interaction information (such as scrolling, clicks, mouse-overs and methods used to browse away from the page).

“Usage Data” includes information about how you use the TT Digital Platforms, products and services.

“Marketing and Communications Data” includes your preferences in receiving marketing from Us and Our third parties and your communication preferences.

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 relate to an identified or identifiable living individual, in other words it is not possible to tie it to you. For example, We may aggregate your Usage Data to calculate the percentage of users accessing a specific TT Digital Platform 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.

Furthermore, when purchasing Official Grandstand Tickets We may also collect personal data via our customer services team that includes “Sensitive Data” (also known as “Special Category Data”). This may include certain health and medical information (including whether or not you are a wheelchair user to ensure accessibility needs are met).

Our TT Digital Platforms use cookies and similar technologies.

4.0 HOW DO WE USE YOUR INFORMATION?

We may use your information in a number of ways, including to provide the TT Digital Platforms, to personalise and improve the services We offer, to carry out Our obligations, to communicate with you, to analyse use of Our TT Digital Platforms and in other ways that you agree to.

We may share your information with our contracted providers, service providers, people who operate or take over Our TT Digital Platforms and third parties that you agree that we can share it with.

We may use your Information:

to communicate with you (including by post, phone, email and/or mobile messaging), such as to let you know about new features, offerings (including goods and services) on Our TT Digital Platforms where you have consented for Us to do so;
to carry out Our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
to create an individual profile for you so that We can understand and respect your preferences;
for record keeping purposes;
to administer and provide services you request;
to carry out market research so that We can improve the products and service we offer;
to improve the quality of our service and security of Our TT Digital Platforms;
to understand your preferences so that We can improve the products and services We offer;
in connection with targeting/advertising activities;
to track activity on the Site and our TT Digital Platforms;
in conjunction with personal data legally obtained from third party sources;
in such way as you may otherwise expressly consent to;
to comply with legal and regulatory requirements; and/or
for any other purpose that We may notify you from time to time.

You agree that We will share your Information with:

carefully selected third party organisations to carry out certain processing activities on our behalf where such parties have the necessary protections in place to comply with applicable data protection law;
anyone who may take over the running of our TT Digital Platforms, or any subcontractors who operate a part of our TT Digital Platforms on our behalf. Any other organisations who access your information in the course of providing services on our behalf will be governed by strict contractual restrictions to make sure that they protect your Information and comply with applicable data protection and privacy laws

We use your personal data to make the following automated decisions:

Marketing Emails (TT Account?): If you sign up for to receive TT Marketing communications, We use automated decision making to provide recommendations based on your chosen preferences and other information we know about you (including your age, gender, purchases and use of the TT Digital Platforms);
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.

There may be circumstances in which you choose to contact Us with an enquiry. For completeness here is the information use you may be asked to provide:

Contact us by email, in person or over the phone or via Webform; We will only ask for your name and postal or email contact details. You may choose to provide extra information if you are making an enquiry.
Sending us a private message on social media; In addition to the TT Digital Platforms, the Isle of Man TT Races and Classic TT also have Official social media profiles. We include them in this notice for completeness: You may choose to provide us with personal information on our social media platforms; we ask that you also check the platform's privacy policy and terms of service prior to sending us anything.
- Social media message boxes are accessed by the relevant team who have responsibility for managing the Official social media platforms. Such messages will only be shared outside the relevant team with your knowing, and only in order to address your enquiry or request. The relevant team may at certain times require a subcontractor to manage the official social media channels. Social media messages will only be kept for a month after the conclusion of the enquiry.

5.0 HOW DO WE PROCESS YOUR INFORMATION SECURELY?

We securely store personal information electronically and manually:

All personal information is kept with the highest standards and safeguards in place. This includes technical security, preventing unauthorised access, undertaking audits and maintaining backups.

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 and who are subject to a duty of confidentiality. They will only process your personal data on Our written instructions.

Emails - Email communications are stored on our Isle of Man Government email system, Microsoft Outlook, We encrypt and protect all our emails in line with government standards. If your email service does not support this encryption, you should be aware that any emails we send or receive may not be protected in transit. We will also monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send is within the bounds of the law

Isle of Man Government Secure Network - There are strict access controls in place meaning that only those within specific Divisions can access team folders; in addition, only the teams within the Divisions who are able to access personal information, are those that have a business need to do so. The administration of the IOMG Secure Network is undertaken by Government Technology Services in the Cabinet Office; however, they are unable to access the content of any records and so will not be able to access your personal information

Manual records - We do not routinely store manual records, however, those that are already in storage and any new records we are required to hold manually are either stored onsite or in a third party storage facility with whom we have a data protection agreement in place.

The use of 3rd Party Sub-Processors

To provide certain services on our websites, we may engage trusted third-party sub-processors. These sub-processors assist us in providing hosting, email marketing, advertising, analytics and other services. We complete a Data Protection Impact Assessment on a 3rd party before using their services, to ensure they are compliant with all applicable data protection regulations.

Third-Party Service providers we use

Amazon Web Services (AWS) - We use AWS to host iomttraces.com, who provide a reliable and secure hosting infrastructure for our website and all data stored with AWS is protected by industry-standard encryption measures. The hosting services we use are located in the Ireland Region, however being a global company, your data may be transferred to other jurisdictions according to their internal processes.

The Live Timing System and Event Management System is hosted on AWS.

Shopify - We use Shopify to host shop.iomttraces.com, which is a best in class service ecommerce platform that provides a friendly user interface, while utilising best practices in terms of data protection and online payment processing.

Vimeo - The TT’s digital streaming channel is hosted in the Vimeo OTT platform and is free to subscribe, however you can also access live coverage of the TT by purchasing a Live Pass. Learn more: https://ttplus.iomttraces.com/privacy

Paypal - Payments processed via the Vimeo OTT platform are processed by Paypal.

Google Firebase - The live timing website is hosted on Google Firebase to deliver real-time data from the Live Timing System to the public.

Google SSO Login - On the live timing website you are able to login to access the free service using your Google account for authentication. In this instance your Google login is used and processed by Google, rather than entering a username and password directly on the live timing website.

Facebook SSO Login - On the live timing website you are able to login using your Facebook account for authentication, where your login credentials are processed by Facebook.

Klaviyo - We use Klaviyo for email marketing and communication with our users. This service helps us manage email subscriptions, send promotional emails, and analyse engagement with our content. Klaviyo may process personal data such as email addresses and names and receive user behaviour information in order to send targeted communications.

Google Analytics - We use Google Analytics, to track user behaviour and demographic data to understand who is using our websites, how they use them and the effectiveness of our marketing campaigns.

Google Ads - We use Google Ads to advertise our products and services. We use Remarketing to deliver the most relevant advertising to our customers.

Facebook Ads - We use Facebook Ads to advertise our products and services and Remarketing features to deliver the most relevant advertising to our customers.

LinkedIn - We may use Linkedin to share content and to advertise our products and services via LinkedIn Advertising.

StackAdapt - We use StackAdapt - a multi-platform programmatic advertising platform, to deliver the most relevant advertising to our customers and increase value for our advertising budgets. To use StackAdapt we may track and share user interests so the most relevant advertising is served to our website visitors.

X (formerly Twitter) - We may use X to share content and post event updates.

YouTube - we use YouTube to share video content.

Data Sharing with Sub-processors

When We share your personal data with third-party service providers, We only share the information necessary for them to perform their services on our behalf. Each subprocessor has been vetted to establish that they comply with data protection laws and has implemented the appropriate technical and organisational measures to safeguard your data.

We may add or remove 3rd party service providers from our websites at any time so please review our Privacy Policy periodically which is kept up to date as the sub-processors we use changes.

Your Rights - Data Sharing with Sub-Processors

You have the right to know which 3rd Party Services handle your data and to ask for more information regarding how they use your data. If you have any questions or would like more details on our sub-processors, please contact us for more information.

Retention period

We only use personal information for as long as it is needed and will store it for the shortest amount of time possible, in accordance with the law.

Processing special category (sensitive) data and the data of children (under 16s)

We have to put additional measures in place if we plan to process any special category personal data , including ethnic origin or religion; however, We do not process any special category personal information using this website. In order to process the personal information of children, we would have to put additional measures in place because they may be less aware of the risks involved . We do not target any services to children and do not process the personal information of children for marketing purposes, competitions or registering for services or user profiles.

5.0 MARKETING AND UNSUBSCRIBING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We will obtain your express opt-in consent before We use your Identity Data, Contact Data, Technical Data, Usage Data and/or Profile Data to contact you about goods or services that may be of interest to you (We call this marketing).

You can ask Us to stop sending you marketing messages at any time using the unsubscribe links in Our emails. You can check or uncheck relevant boxes to adjust your marketing and communications preferences by following the opt-out links on any marketing message sent to you or you may Contact Us at any time.

Consenting to the use of Cookies and Passive Technologies on your Browser

The first time you visit our websites, you will be provided with an option to approve (or "opt-in") the use of cookies on the website with a pop up. We have no way of knowing whether you allow cookies or not, and no way to trace your selection back to you. Instead, your own internet browser remembers the selection so it will treat that cookie the same each time (until you change your cookie settings).

Withdrawing consent to cookie and passive technology use

At any point in time you can amend your Cookie Opt-in preferences using a cookie link in the bottom left of the page when viewing any of the iomttraces.com websites. You are able to change the categories of cookie you are willing to accept or even opt out of cookies being created at all. However we do need to create Strictly Necessary Cookies for the protection of any personal data you provide and to protect the systems we use to host our websites.

What cookies do we create?

We maintain a full audit of the cookies we create on our Cookie Policy, which is reviewed periodically to ensure it is kept up to date.

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.

6.0 YOUR LEGAL RIGHTS IN RELATION TO YOUR DATA

Under the Data Protection Act, you have rights as an individual which you can exercise in relation to the information we hold about you. At any point while we are in possession of or processing your personal information, you, the data subject, have the following rights:

Access You have the right to request a copy of the information that we hold about you

Rectification You have a right to correct data that we hold about you that is inaccurate or incomplete

Erasure In certain circumstances you can ask for the data we hold about you to be erased from our records

Restriction of processing Where certain conditions apply, you have a right to restrict the processing of your data

Portability You have the right to have the data we hold about you transferred to another organisation

Objection You have the right to object to certain types of processing such as direct marketing

Objection to automated processing You also have the right to be subject to the legal effects of automated processing including profiling

Judicial review In the event that the Department for Enterprise refuses your request under rights of access, we will provide you with a reason as to why. You then have the right to complain as outlined in Complaints

You can find out more about these rights here or by contacting our Data Protection Officer using the details at the end of this notice.

7.0 CHANGES

Privacy laws and practice are constantly developing. Our policies and procedures are therefore under continual review. We may, from time to time, update our Privacy Notice.

8.0 COMPLAINTS

In the event that you wish to make a complaint about how your personal information is being processed by TT Races (or third parties), or how your complaint has been handled, you have the right to lodge a complaint directly with our Data Protection Officer in the first instance; as well as the Isle of Man Information Commissioner.

This privacy notice was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of TT Races collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to the address below.