Safeguarding the privacy of our users and visitors
- 1. We are committed to safeguarding the privacy of our website visitors; in this policy we explain how we will treat your personal information.
- 3. Subsapp is considered by the data protection office to be a “Data Processor” while it considers a sports organisation using the platform as a ‘Data Controller’. Sports users using the Subsapp Software as a service platform must have their own terms and conditions, and are responsible for how they manage and share the data of their membership.
Collecting personal information.Subsapp does not share personal data or contact details.
1. We may collect, store and use the following kinds of personal
- 1. information about your computer and about your visits to and use of this website (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths);
- 2. information that you provide to us when registering with our website (including your email address);
- 3. information that you provide when completing your profile on our website (including your name, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details);
- 4. Any medical conditions or health information about you which you wish to disclose through the Website or Application to your coach or manager.
- 5. information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (including your name and email address);
- 6. information that you provide to us when using the services on our website, or that is generated in the course of the use of those services (including the timing, frequency and pattern of service use);
- 7. information relating to any purchases you make of our goods and/or services or any other transactions that you enter into through our website (including your name, address, telephone number, email address and card details);
- 8. information that you post to our website for publication on the internet (including your user name, your profile pictures and the content of your posts);
- 9. information contained in or relating to any communication that you send to us or send through our website (including the communication content and metadata associated with the communication);
- 10. any other personal information that you choose to send to us; and
- 2. Before you disclose to us the personal information of another person, you must obtain that person’s consent to both the disclosure and the processing of that personal information in accordance with this policy.
Using personal information
- 3. Personal information submitted to us through our website will be used for the purposes specified in this policy or on the relevant pages of the website.
4. We may use your personal information to:
- 1. administer our website and business;
- 2. personalise our website for you;
- 3. enable your use of the services available on our website;
- 4. send you goods purchased through our website;
- 5. supply to you services purchased through our website;
- 6. send statements, invoices and payment reminders to you, and collect payments from you;
- 7. send you non-marketing commercial communications;
- 8. send you email notifications that you have specifically requested;
- 9. send you our email newsletter, if you have requested it (you can inform us at any time if you no longer require the newsletter);
- 10. send you marketing communications relating to our business or the businesses of carefully-selected third parties which we think may be of interest to you, by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications);
- 11. provide third parties with statistical information about our users (but those third parties will not be able to identify any individual user from that information);
- 12. deal with enquiries and complaints made by or about you relating to our website;
- 13. keep our website secure and prevent fraud;
- 14. verify compliance with the terms and conditions governing the use of our website (including monitoring private messages sent through our website private messaging service).
- 5. If you submit personal information for publication on our website, we will publish and otherwise use that information in accordance with the licence you grant to us.
- 6. Your privacy settings can be used to limit the publication of your information on our website, and can be adjusted using privacy controls on the website.
- 7. We will not, without your express consent, supply your personal information to any third party for the purpose of their or any other third party’s direct marketing.
Disclosing personal information
- 9. We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this policy.
10. We may disclose your personal information:
- 1. to the extent that we are required to do so by law;
- 2. in connection with any ongoing or prospective legal proceedings;
- 3. in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
- 4. to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling; and
- 5. to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.
- 11. Except as provided in this policy, we will not provide your personal information to third parties.
International data transfers
- 1. Subsapp platform is hosted on Amazon Web Services (AWS). Our infrastructure is hosted in ISO 9000 compliant data centres in Europe (Ireland and Germany). Data is retained in the EU and not stored or transferred outside the EU. Subsapp does not share personal data or contact details.
- 2. Clients can formally request for Subsapp to store their data in their own country of origin. This is managed on a case by case basis.
- 3. Subsapp does not share personal data or contact details of our users but information such as results, scores, fixtures, (schedules) game stats that are in the public domain may be published to client websites, club websites, club portals, and social media.
- 4. Personal information that you publish on our website or submit for publication on our website may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.
- 5. Retaining personal information
- 1. Subsapp does not share personal data or contact details.
- 2. Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
3. We will retain documents (including electronic documents)
containing personal data:
- 1. to the extent that we are required to do so by law;
- 2. if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
- 3. in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
Security of personal information
- 1. We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
- 2. We will store all the personal information you provide on our secure (password- and firewall-protected) servers.
- 3. All electronic financial transactions entered into through our website will be protected by encryption technology.
- 4. You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
- 5. You are responsible for keeping the password you use for accessing our website confidential; we will not ask you for your password (except when you log in to our website).
- 6. Data managed by organisations using the Subsapp Software as a service must have their own terms and conditions, and they are responsible for how they manage and share the data of their membership.
- 1. We may update this policy from time to time by publishing a new version on our website.
- 2. You should check this page occasionally to ensure you are happy with any changes to this policy.
- 3. We may notify you of changes to this policy [by email or through the private messaging system on our website].
1. You may instruct us to provide you with any personal information we
hold about you; provision of such information will be subject to:
- 1. the supply of appropriate evidence of your identity will be necessary.
- 2. You may instruct us at any time not to process your personal information for marketing purposes.
- 3. In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.
Third party websites
- 1. Our website includes hyperlinks to, and details of, third party websites.
- 2. We have no control over, and are not responsible for, the privacy policies and practices of third parties.
- 1. Please let us know if the personal information that we hold about you needs to be corrected or updated.
Subsapp General Data Protection Policy updated February 2021