KlubPro PRIVACY POLICY – NOVEMBER 2018

This web site and the “KlubPro Platform” is owned and operated by KlubPro Pty Ltd and will be referred to as "We", "our" and "us" in this Internet Privacy Policy. By using our site and platform, you agree to this Privacy Policy. The Privacy Policy relates to the collection and use of personal information you may supply to us through your conduct on the web site and platform. We reserve the right, at our discretion, to modify or remove portions of this Privacy Policy at any time. This Privacy Policy is in addition to any other terms and conditions applicable to the web site or platform. We do not make any representations about third party web sites that may be linked to the web site. Clicking on third party web site links or enabling the connections may allow third parties to collect or share data about you.

In this policy, KlubPro Platform means our website, our web application, any KlubPro mobile application, or any other means by which KlubPro provides services to you.

We recognise the importance of protecting the privacy of information collected about visitors to our website and platform, in particular information that is capable of identifying an individual ("personal information"). It does not include data where the identity has been removed (anonymous data).

We are the controller of your data and it is important that you read this Privacy Policy together with any other privacy policy or fair processing policy 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 governs the manner in which your personal information, obtained through the web site and platform, will be dealt with.

This Privacy Policy should be reviewed periodically so that you are updated on any changes. We welcome your comments and feedback.

If you have any questions about this Internet Privacy Policy or our privacy practices, please contact our Data Protection Officer (DPO) in the following ways:

Email address:            info@klubpro.com

Postal address:           PO Box 8500, South Perth, Western Australia, 6151. Australia

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.

Personal Information

1.          Personal information about visitors to our site and platform is collected only when knowingly and voluntarily submitted. For example, we may need to collect such information to provide you with further services or to answer or forward any requests or enquiries. It is our intention that this policy will protect your personal information from being dealt with in any way that is inconsistent with applicable privacy laws in Australia or in the European Economic Area (EEA). 

2.          The KlubPro Platform and services provided by KlubPro Pty Ltd are intended for use by, or in relation to, sporting clubs, sporting associations and their members, and are not intended for personal, domestic or household use. Nevertheless, personal information may still be collected, for example in relation to accounts opened by sporting clubs, their administrative officers and the members of the club.

3.          This Privacy Policy applies only to the extent that personal information is collected.

What information do we collect?

4.          The types of personal information we collect include:

a.     Identity Data - first name, surname, identification number or similar identifier, social media account details, title, date of birth and gender.

b.     Contact Data - billing address, email address and telephone numbers.

c.     Financial Data - none.

d.     Transaction Data - details about payments to and from you and other details of products and services you have purchased from us.

e.      Technical Data - records of your communications and interactions with us and the KlubPro Platform including internet protocol address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

f.      Usage Data - details/history of preferences and behaviour in relation to your interactions with our digital services.

g.     Marketing and Communications Data – your preferences in receiving marketing from us and our third parties and your communication preferences.

5.     We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. 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. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website 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.

6.     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.

7.          We may not be able to provide our services without your personal information. For example, the quality of team selection generated through the KlubPro Platform, and our ability to communicate with you via social media platforms, will be affected by the quality and detail of the information that is uploaded to it.

Use of Information

8.          Personal information that visitors submit to our site is used only for the purpose for which it is submitted or for such other secondary purposes that are related to the primary purpose, unless we disclose other uses in this Internet Privacy Policy or at the time of collection. Copies of correspondence sent from the web site or platform, that may contain personal information, are stored as archives for record-keeping and back-up purposes only.

9.          We will only use your personal data when the law allows us to. Most commonly, we will use your data in the following circumstances:

a.     Where we need to perform the contract we are about to enter into or have entered into with you.

b.     Where it is necessary for our legitimate interests (or those if a third party) and your interests and fundamental rights do not override those interests.

c.     Where we need to comply with a legal obligation.

Lawful basis

10.  Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

11.  Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

12.  Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

How do we collect your personal information?

13.       We collect information from you when you register on or use the KlubPro Platform. When registering for or using our services, you may be asked to enter personal information.

14.       We may collect your personal information from your interactions and transactions with us, or the KlubPro Platform. This includes: making payments through the KlubPro Platform, generating team and team sheets; submitting a form; providing information through various chatbot services, or otherwise using or interacting with the KlubPro Platform. We may monitor and record your communications with us (including social media, email and telephone) for security, dispute resolution, and training purposes. We may also collect personal information from third parties including your members, agents or representatives, public sources, information service providers, anyone authorised to act on your behalf, and related bodies corporate of KlubPro.

15.       We hold personal information electronically and in hard copy form, both at our own premises and with the assistance of our service providers. We implement a range of measures to protect the security of that personal information.

What do we use your information for?

16.  We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

17.  Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

 Type of data

(a) Identity

(b) Contact

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(a) Identity

(b) Contact

(c) Technical

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

(a) Technical

(b) Usage

(a) Identity

(b) Contact (c) Technical

(d) Usage

(e) Profile

(f) Marketing and Communications

18.     We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

19.     You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

20.     You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, warranty registration, product/service experience or other transactions.

Credit Card and Bank Account Details

21.          Credit Card and Bank Account details are never stored in in the KlubPro Platform. Any financial information which may be required will be stored by one of our PCI Data Security Standards compliant trusted third parties.

Disclosure 

22.          Apart from where you have consented or disclosure is necessary to achieve the purpose for which it was submitted, personal information may be disclosed in special situations where we have reason to believe that doing so is necessary to identify, contact or bring legal action against anyone damaging, injuring, or interfering (intentionally or unintentionally) with our rights or property, users, or anyone else who could be harmed by such activities. Also, we may disclose personal information when we believe in good faith that the law requires disclosure.

23.          We may engage third parties to provide you with goods or services on our behalf. In that circumstance, we may disclose your personal information to those third parties in order to meet your request for goods or services.

24.          We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third party service providers to use your personal data for their own purposes and will only permit them to process your personal data for specified purposes and in accordance with our instructions.

Security

25.          We strive to ensure the security, integrity and privacy of personal information submitted to our sites, and we review and update our security measures in light of current technologies. Unfortunately, no data transmission over the Internet can be guaranteed to be totally secure.

26.          However, we will endeavour to take all reasonable steps to protect the personal information you may transmit to us or from our online products and services. Once we do receive your transmission, we will also make our best efforts to ensure its security on our systems.

27.       In addition, our employees and the contractors who provide services related to our information systems are obliged to respect the confidentiality of any personal information held by us. However, we will not be held responsible for events arising from unauthorised access to your personal information.

28.       Whenever we transfer your personal data to another country, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

a.     We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

b.     Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries. 

c.     Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Collecting Information from Users

29.       IP Addresses

Our web servers gather your IP address to assist with the diagnosis of problems or support issues with our services. Again, information is gathered in aggregate only and cannot be traced to an individual user.

30.       Cookies and Applets

We may use cookies to provide you with a better experience. These cookies allow us to increase your security by storing your session ID and are a way of monitoring single user access. This aggregate, non-personal information is collated and provided to us to assist in analysing the usage of the site.

Data Retention

31.  By law we have to keep basic information about our users (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers. In some circumstances you can ask us to delete your data.

32.  In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Access to Information

33.       We will endeavour to take all reasonable steps to keep secure any information which we hold about you, and to keep this information accurate and up to date. If, at any time, you discover that information held about you is incorrect, you may contact us to have the information corrected.

34.       In addition, our employees and the contractors who provide services related to our information systems are obliged to respect the confidentiality of any personal information held by us.

Links to other sites

35.       We provide links to Web sites outside of our web sites, as well as to third party Web sites. These linked sites are not under our control, and we cannot accept responsibility for the conduct of companies linked to our website. Before disclosing your personal information on any other website, we advise you to examine the terms and conditions of using that Website and its privacy statement.

Your consen 

36.       By using any part of the KlubPro Platform including by providing information for uploading to the Platform, or any other services provided by KlubPro Pty Ltd, you consent to our Privacy Policy.

Changes to our privacy policy

37.       We reserve the right to change our Privacy Policy from time to time at our complete discretion as we see fit. If we decide to change our privacy policy, we will post those changes on this page and they will become effective immediately.

a.     Your legal rights Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to: Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

b.     Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

c.     Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

d.     Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

e.     Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

·    If you want us to establish the data's accuracy.

·      Where our use of the data is unlawful but you do not want us to erase it.

·      Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

·      You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

f.      Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

g.     Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

38.  If you wish to exercise any of the rights set out above, please contact us.

39.  You will not have to pay a fee to access your personal data (or to exercise any of the other rights); however, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

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

41.  We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Contact us

42.       If you have any questions regarding privacy, you can contact us using info@klubpro.com and we will endeavour to promptly respond. You can alternatively contact us in writing at the following address.

KlubPro Pty Ltd
PO Box 8500, South Perth, Western Australia, 6151. Australia