Platform Privacy Notice
The Mokuso platform (Mokuso) is a self-service platform provided by Nexteam Limited (Nexteam or we/us) to combat sports clubs (clubs).
This privacy notice describes how we use personal data in providing Mokuso.
This includes personal data relating to our contacts at combat sports clubs, admin users, and student users (you).
We may update this notice from time to time. It was last updated on 26 September 2023.
This notice has the following sections:
- The quick read (a summary)
- Who we are (including our contact details)
- Use of data in managing our relationship with clubs (and our lawful basis under data protection law)
- Use of data in managing user accounts (as a processor on behalf of clubs)
- Data analysis (anonymous data)
- Use of cookies
- Other uses and sharing of your data
- International data transfers
- Retaining your information
- Your data protection rights
1. THE QUICK READ
- Contacting us: You can contact Nexteam at: support@mokuso.app
- Managing our relationship with clubs: Nexteam holds personal data of club contacts to register a club on Mokuso, and to manage its relationship with clubs in relation to its provision of Mokuso. This may include names and contact details, support requests and other communications relating to use of Mokuso.
- Managing user accounts: Nexteam hold information about student users and admin users of Mokuso as processor on behalf of clubs (the controllers). This includes details used to set up your account, and other information which you input into your account. It includes any health data you provide. The clubs have access to all this information, and we act on the clubs' instructions in relation to our use of this data. You should contact the relevant club with any queries.
- Payment details: Payment processing for club subscriptions within Mokuso is provided by third party payment processors. We do not hold payment details for student users.
- Data analysis: Nexteam may collect and use anonymous user data for conducting data analysis for product development and improvement.
- Sharing your data: Data may be shared with relevant clubs and service providers, such as payment providers and technology providers.
- International data transfers: Nexteam does not generally transfer your data outside the UK.
- Your rights: You have rights in relation to Nexteam's use of your data as a controller, including the right to access a copy of the data it holds about you and, in certain circumstances, to object to its use of your data or request that it erase your data. You may also complain to the ICO: www.ico.org.uk.
2. WHO WE ARE
Nexteam Limited is a company registered in England and Wales with company number 11698058 and registered office at 20-22 Wenlock Road, London, N1 7GU.
We act as a 'controller' for the purposes of data protection laws in our use of your data for our own business purposes.
This means that we determine how and why your data is collected and used, for example in managing our relationship with clubs who have registered with Mokuso.
This notice is primarily about our activities as a controller, and more information is provided in section 3, and sections 5 to 10 below.
You may contact us with any queries or concerns about our use of your personal data as a controller, and to exercise your data protection rights using the following contact details.
- Email: support@mokuso.app
In providing Mokuso, we also hold personal data about student users and admin users as a 'processor' on behalf of clubs (who act as controllers) who have registered with Mokuso. See section 4 below.
3. MANAGING OUR RELATIONSHIP WITH CLUBS
We hold personal data of our individual contacts at clubs in order to:
- register the club on Mokuso, using an admin (owner) account within the management console;
- manage our relationship with clubs in relation to the provision of Mokuso; and
- communicate with you for customer care purposes, or to let you know about changes to the Mokuso platform or service.
Personal data may include names and contact details of club contacts, support requests and other communications relating to use of Mokuso. To the extent the club operates as a sole trader or partnership, your personal data may include details of payments made to us, and other information about the club collected by us.
We may share your personal data with the club, as may be relevant to managing our relationship with them.
Our lawful basis under data protection law for using your personal data in these ways is that it is necessary for our legitimate interests in managing our relationship with clubs and providing our services (or, if you are the contracting party for a club, that it is necessary for the performance of our contract with you in providing Mokuso).
4. MANAGING USER ACCOUNTS
You may set up a user account on Mokuso, as either an adult user of the student app (a student user), or a sensei or club staff member using the management console on behalf of a club (an admin user). You may provide personal data in setting up and using your account.
This may include details your name and contact details, login details, information about your (or your childâs) membership, subscriptions and classes, and any health or childrenâs details which you provide.
Your personal data may also be inputted into Mokuso by other users (for example where an admin (owner) user inputs details of its senseis.
We hold and process this personal data as a 'processor' on behalf of the relevant clubs (who act as controllers). This means that such data is collected and used for purposes determined by the clubs. All such data may be accessed by clubs, and we act on their instructions in using your data as part of our services to them. The clubs are primarily responsible for how such data is used.
Note also that payments made over Mokuso are facilitated by a third party payment provider, and we do not hold payment details on behalf of clubs. You should contact the relevant club for more information about use of this data.
5. DATA ANALYSIS
We may collect and use anonymous user data for conducting data analysis for product development and improvement.
This may include information about how users interact with Mokuso, which particular features are used and when, and other performance metrics. These are collected and used in a way that does not identify any individual user.
6. USE OF COOKIES
Except to the extent they are necessary for the operation of Mokuso, cookies will only be used if we obtain your consent. You can remove cookies at any time using the privacy settings of your web browser.
7. OTHER USES AND SHARING OF YOUR DATA
7.1. Other uses of your data
Your personal data may also be used by us:
- to maintain appropriate records of our business communications and relationships (in our legitimate interests); and
- to protect or enforce legal rights (including in relation to compliance with Mokuso acceptable use terms), or for other purposes permitted or required by law, including data protection law (in our legitimate interests, or as needed to comply with a legal obligation).
7.2. Our service providers
Our service providers may handle your data, and data may be shared between us and them. This may include providers of our email and accounting systems, and individual contractors who work for us.
We share such data in line with the purposes and legitimate interests identified in section 2 above.
7.3. Other recipients of your data
We may also share your data, where relevant, with the following parties:
- legal authorities or regulatory bodies;
- our legal or other professional advisers;
- prospective or actual purchasers of our company or business; and
- other parties where we are otherwise required or permitted by law to do so (including by data protection law).
Our lawful basis for such data sharing is, as appropriate, our (or the recipient's) legitimate interests in the relevant activity, or compliance with a legal obligation.
8. INTERNATIONAL DATA TRANSFERS
We are a UK business, and we do not generally transfer your data outside the UK and the EU. As at the date of this notice, the data centres for Mokuso are also within the UK.
9. RETAINING YOUR INFORMATION
We will retain your personal data for as long as we need it for the relevant purposes specified above, in accordance with our records retention procedures. Where we act as a processor on behalf of clubs, we follow the clubs' instructions in relation to the retention of your data.
Our retention periods may be changed in appropriate circumstances, for example we may need to retain your details for longer if there is a dispute in relation to our services.
Please contact us (using the contact details at section 2 above) for further information about retention of your data.
10. YOUR DATA PROTECTION RIGHTS
In accordance with data protection laws, you have certain rights in relation to our use of your personal data. These rights include the following:
- to obtain a copy of the personal data we hold about you, together with other information about how we process it (known as a subject access request);
- to withdraw any consent which you have given relating to the use of your data;
- to request rectification of inaccurate or incomplete data;
- in some circumstances, to request us to erase or restrict our use of your data;
- to object to our processing of your data for direct marketing purposes, or for reasons relating to your particular situation (where our lawful basis is legitimate interests);
- where our lawful basis for use of your data is your consent or necessity for our contract with you, to exercise a right to data portability, in order to transfer sets of data provided by you and held electronically to another organisation; and
- not to be subject to a decision based solely on automated processing, which significantly affects you, unless additional legal requirements are met (although we do not make any such decisions as at the date of this notice).
Please contact us (see section 2 above) to send us requests to exercise these rights (specifying what you are requesting), or if you would like further information about them. There are certain limitations and exemptions to these rights which we may apply depending on the circumstances.
Admin users and student users should contact the relevant club to exercise their rights in relation to our use of your data on behalf of clubs in managing user accounts (see section 4, above).
You may also make a complaint about how we handle your data to the UK Information Commissioner's Office. Please visit ico.org.uk for further information about how to do this (and further guidance on your rights).