top of page


ESA Privacy Policy



1.1 Important information and who we are


Welcome to Elite Skills Arena Ltd’s Privacy and Data Protection Policy (“Privacy Policy”).


At Elite Skills Arena Ltd (“we”, “us”, or “our”) we are committed to protecting and respecting

your privacy and Personal Data in compliance with the United Kingdom General Data

Protection Regulation (“GDPR”), the Data Protection Act 2018 and all other mandatory laws

and regulations of the United Kingdom.


This Privacy Policy explains how we collect, process and keep your data safe. The Privacy

Policy will tell you about your privacy rights, how the law protects you, and inform our

employees and staff members of all their obligations and protocols when processing data.


The individuals from which we may gather and use data can include:


  • Customers

  • Employees/Staff Members

  • Third parties connected to your customers

  • Individuals using the ESA Data Hub application or web service

and any other people that the organisation has a relationship with or may need to contact.


This Privacy Policy applies to all our employees and staff members and all Personal Data

processed at any time by us. 


1.2 Who is Your Data Controller


Elite Skills Arena Ltd is your Data Controller and responsible for your Personal Data. We are

not obliged by the GDPR to appoint a data protection officer and have not voluntarily

appointed one at this time. Therefore, any inquiries about your data should either be sent to

us on email at or sent in a letter to Unit C1B, Poole Retail Park,

Poole, BH12 1DN, United Kingdom.

You have the right to make a complaint at any time to the Information Commissioner’s Office

(ICO), the UK supervisory authority for data protection issues ( We would,

however, appreciate the chance to deal with your concerns before you approach the ICO so

please contact us in the first instance.

1.3 Processing Data on Behalf of a Controller and Processors’ responsibility to you


In discharging our responsibilities as a Data Controller we have employees who will deal with

your data on our behalf (known as “Processors”). Therefore, the responsibilities described

below may be assigned to an individual, or may be taken to apply to the organisation as a

whole. The Data Controller and our Processors have the following responsibilities:


  • Ensure that all processing of Personal Data is governed by one of the legal bases laid out in the GDPR (see 2.2 below for more information on those bases);

  • Ensure that Processors authorised to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality;

  • Implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk associated with the processing of Personal Data;

  • Obtain the prior specific or general authorisation of the Controller before engaging another Processor;

  • Assist the Controller in the fulfilment of the Controller’s obligation to respond to requests for exercising the data subject’s rights;

  • Make available to the Controller all information necessary to demonstrate compliance with the obligations laid down in the GDPR and allow for and contribute to audits, including inspections, conducted by the Controller or another auditor mandated by the Controller;

  • Maintain a record of all categories of processing activities carried out on behalf of a Controller;

  • Cooperate, on request, with the supervisory authority in the performance of its tasks;

  • Ensure that any person acting under the authority of the Processor who has access to Personal Data does not process Personal Data except on instructions from the Controller; and

  • Notify the Controller without undue delay after becoming aware of a Personal Data Breach;




2.1 Types of Data / Privacy Policy Scope


“Personal Data” 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).


We may collect, use, store and transfer different kinds of Personal Data about you which we

have grouped together below. Not all of the following types of data will necessarily be

collected from you but this is the full scope of data that we collect and when we collect it from



  • Profile/Identity Data: This is data relating to your first name, last name, gender, date of birth.

  • Contact Data: This is data relating to your phone number, addresses, email addresses, phone numbers.

  • Marketing and Communications Data: This is your preferences in receiving marketing information and other information from us.

  • Financial Data: These are your banking details e.g. your account number and sort code.

  • Transactional Data: This is information of details and records of all payments you have made for our services or products.

We also collect, use and share Aggregated Data such as overall product usage by age group,

average points scored. Aggregated Data could be derived from your Personal Data but is not

considered Personal Data in law as this data will not directly or indirectly reveal your identity.

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.


We may also aggregate data to enable research or analysis so that we can better understand

and serve you and others. For example, we may conduct research on your demographics and

usage. Although this aggregated data may be based in part on Personal Data, it does not

identify you personally. We may share this type of anonymous data with others, including

service providers, our affiliates, agents and current and prospective business partners.


We do not collect any Special Categories of Personal Data about you (this includes details

about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation,

political opinions, trade union membership, information about your health, and genetic and

biometric data). Nor do we collect any information about criminal convictions and offences.


2.2 The Legal Basis for Collecting That Data


There are a number of justifiable reasons under the GDPR that allow collection and processing

of Personal Data. The main avenues we rely on are:


  • “Consent”: Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy to receive email newsletters from us, or ‘opt in’ to a service.


  • “Contractual Obligations”: We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service.

  • “Legal Compliance”: We’re required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions.

  • “Legitimate Interest”: We might need to collect certain information from you to be able to meet our legitimate interests - this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests. Examples could be your address, so that we know where to deliver something to, or your name, so that we have a record of who to contact moving forwards.



3.1 Our Uses


We will only use your Personal Data when the law allows us to. Set out below is a table

containing the different types of Personal Data we collect and the lawful basis for processing

that data. Please refer to section 2.2 for more information on the lawful basis listed in the

table below.

Examples provided in the table below are indicative in nature and the purposes for which we

use your data may be broader than described but we will never process your data without a

legal basis for doing so and it is for a related purpose. For further inquiries please contact us.


3.2 Marketing and Content Updates


You will receive marketing and new content communications from us if you have created an

account and chosen to opt into receiving those communications. From time to time we may

make suggestions and recommendations to you about goods or services that may be of

interest to you.


3.3 Change of Purpose


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.


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.


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.





4.1 What Control Do I Have Over Elite Skills Arena Ltd’s Use Of My Personal Data?

You may delete your account at any time – this will remove your account page from our

systems and our related software.


We guarantee this will delete all stored data.


Your account information will be protected by a password for your privacy and security. You

need to prevent unauthorized access to your account and personal information by selecting

and protecting your password appropriately and limiting access to your computer or device

and by signing off after you have finished accessing your account.


You can access information associated with your account by logging into your account you

created with us.


Your account information will be protected by a password for your privacy and security. You

need to prevent unauthorized access to your account and personal information by selecting

and protecting your password appropriately and limiting access to your computer or device

and by signing off after you have finished accessing your account.


California Privacy Rights: Under California Civil Code sections 1798.83-1798.84, California

residents are entitled to ask us for a notice identifying the categories of personal customer

information which we share with our affiliates and/or third parties for marketing purposes,

and providing contact information for such affiliates and/or third parties. If you are a

California resident and would like a copy of this notice, please submit a written request to


4.2 How Does Elite Skills Arena Ltd Protect Customers’ Personal Data?


We are concerned with keeping your data secure and protecting it from inappropriate

disclosure. We implement a variety of security measures to ensure the security of your

Personal Data on our systems, including adopting a secure protocol and encrypting our

databases, including customer passwords. All customer data is organisation specific and

password protected.. Any Personal Data collected by us is only accessible by a limited number

of employees who have special access rights to such systems and are bound by obligations of

confidentiality. If and when we use subcontractors to store your data, we will not relinquish

control of your Personal Data or expose it to security risks that would not have arisen had the

data remained in our possession. However, unfortunately no transmission of data over the

internet is guaranteed to be completely secure. It may be possible for third parties not under

the control of Elite Skills Arena Ltd to intercept or access transmissions or private

communications unlawfully. While we strive to protect your Personal Data, we cannot ensure

or warrant the security of any Personal Data you transmit to us. Any such transmission is done

at your own risk. If you believe that your interaction with us is no longer secure, please contact



4.3 Opting Out Of Marketing Promotions


You can ask us to stop sending you marketing messages at any time by unsubscribing at the

bottom of marketing emails, or emailing

Where you opt out of receiving these marketing messages, we will continue to retain other

Personal Data provided to us as a result of interactions with us not related to your marketing



4.4 How to Request your Data and the Process for Obtaining it


You will not have to pay a fee to access your Personal Data (or to exercise any of the other

rights). However, if your request is clearly unfounded, we could refuse to comply with your



We may need to request specific information from you to help us confirm your identity and

ensure you have the 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.





5.1 Will We Share Your Data With Third Parties?


We may also share Personal Data with interested parties in the event that Elite Skills Arena Ltd

anticipates a change in control or the acquisition of all or part of our business or assets or with

interested parties in connection with the licensing of our technology.


If Elite Skills Arena Ltd is sold or makes a sale or transfer, we may, in our sole discretion,

transfer, sell or assign your Personal Data to a third party as part of or in connection with that

transaction. Upon such transfer, the Privacy Policy of the acquiring entity may govern the

further use of your Personal Data. In all other situations your data will still remain protected in

accordance with this Privacy Policy (as amended from time to time).


We may share your Personal Data at any time if required for legal reasons or in order to

enforce our terms or this Privacy Policy.





We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we

collected it for. We may retain your Personal Data for a longer period than usual in the event of a

complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship

with you.



You must not use Elite Skills Arena Ltd unless you are aged 16 or older. If you are under 16 and you

access Elite Skills Arena Ltd by lying about your age, you must immediately stop using Elite Skills

Arena Ltd.


This website is not intended for children and we do not knowingly collect data relating to children.





Your information may be stored and processed in the US or other countries or jurisdictions outside

the US where Elite Skills Arena Ltd has facilities. We are currently storing data in the EU and so, by

using Elite Skills Arena Ltd, you are permitting and consenting to the transfer of information,

including Personal Data, outside of the US.





We keep our Privacy Policy under review and will place any updates on this webpage. This version is

dated 1 June 2022. By using Elite Skills Arena Ltd, you consent to the collection and use of data by us

as set out in this Privacy Policy. Continued access or use of Elite Skills Arena Ltd will constitute your

express acceptance of any modifications to this Privacy Policy.





All uses of the word “including” mean “including but not limited to” and the enumerated examples

are not intended to in any way limit the term which they serve to illustrate. Any email addresses set

out in this policy may be used solely for the purpose for which they are stated to be provided, and

any unrelated correspondence will be ignored. Unless otherwise required by law, we reserve the

right to not respond to emails, even if they relate to a legitimate subject matter for which we have

provided an email address. As a matter of common sense, you are more likely to get a reply if your

request or question is polite, reasonable and there is no relatively obvious other way to deal with or

answer your concern or question (e.g. FAQs, other areas of our website etc.).


Our staff are not authorised to contract on behalf of Elite Skills Arena Ltd, waive rights or make

representations (whether contractual or otherwise). If anything contained in an email from a Elite

Skills Arena Ltd address contradicts anything in this policy, our terms or any official public

announcement on our website, or is inconsistent with or amounts to a waiver of any Elite Skills Arena

Ltd rights, the email content will be read down to grant precedence to the latter. The only exception

to this is genuine correspondence expressed to be from the Elite Skills Arena Ltd legal department.

SeedLegals - Website Privacy Policy - PYCP-1-2020-02-19T01:00Z 7

bottom of page