Data Protection

Introduction

We (Clubforce as a trading name of Net Beo Teoranta) routinely process information (“Personal Data“) regarding people who interact with us directly and others who are involved in our business (“you” or “your”).

As a business, personal data protection is one of our core values and we have summarised some key points in this Data Protection Notice (this “Notice“).

This includes obligations in dealing with personal data, in order to ensure that the organisation complies with the requirements of the relevant Irish legislation, namely the Irish and UK Data Protection Acts (2018) and The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679).

Reasons we process personal data

Mostly the reason you have a Clubforce account is because your club asked you to. Clubforce is an all-in-one sports club management platform, which reduces administrative work for a large number of clubs. Which is why, to join any of the growing list of clubs that we support, you will be asked to first create an account with us and then use that account to register with a club.

What Personal Data we control when you have a Clubforce account?

We only control your club(s) membership, e-mail address and password. This is to uniquely identify you and the club(s) you are in. For any other data shared such as your name, address, date of birth etc. your club is the data controller.

The lawful basis for processing this data is “contractual”, as it is necessary for us deliver our service to you.

Processing your Personal Data when you visit the Clubforce website.

When you browse to our website or use our apps we automatically receive and record device information such as the IP address, screen resolution, the browser software you are using, a unique device identifier, advertising identifiers, serial numbers, device motion information and mobile network information.

The lawful basis for processing this data is “legitimate interest”, as we use this data to monitor, protect and enhance our website and apps.

Processing your data for Marketing Purposes

We gather data from clubs about officers and members who are interested in our services. Clubs may spend lengthy periods of time evaluating our services and we periodically send information about events or other marketing communications which you may be interested in.

The lawful basis for processing this data is “consent”. Our intention is for this list to be subscription only, if your name has been entered in error please let us know.

Sharing and Disclosure of your Personal Data

At Clubforce we take your privacy and your information security very seriously. We will only disclose your personal information in the following circumstances:

• For operational and Service delivery purposes, we use a number of trusted third parties to process personal data. Please contact Clubforce for further details.
• We may share your personal information within our group, which means our subsidiaries, our ultimate holding company and its subsidiaries if that is required. If some, or all, of Clubforce is acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use (if applicable) and other agreements; or to protect the rights, property, or safety of Clubforce, our customers, or others.
• We may share or process your Personal Data as necessary, in order, for us to establish, investigate, exercise or defend a legal claim to which you are a party. For example: To file legal proceedings or to investigate, establish, exercise or defend a legal claim.

Data Retention

In accordance with our policy on data retention, we shall keep your Personal Data which we process on the basis of your involvement with Clubforce for a period of time after your engagement depending on why you have interacted with us. In relation to the submission of documents during our registration process, any submission documents are set for deletion 31 days post-registration, in line with GDPR guidelines. Please contact privacy@clubforce.com for further information about our retention periods. Please note that in certain circumstances, we may hold your Personal Data for a longer period, for example, if we are processing an ongoing claim or believe in good faith that the law or a relevant regulator may reasonably in our view expect or require us to preserve your Personal Data.

Third Party Sources

We may obtain Personal Data about you from social media platforms, such as Facebook, Twitter, LinkedIn and Instagram, when you interact with us via such platforms. This includes information which you provide to us or otherwise make available via such platforms.

Security and storage of your personal data

Your Personal Data may be stored and transferred inside or outside the European Economic Area (“EEA“). We only transfer your Personal Data outside the EEA where the EU Commission has decided that the third country in question ensures an adequate level of protection in line with EU data protection standards or if there are appropriate safeguards in place to protect your Personal Data.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will always do our best to protect your Personal Data, we cannot guarantee the security of any information you transmit to us; any transmission is at your own risk. Once we have received your information, we will endeavour to use strict procedures and security features to try to prevent unauthorised access.

Your rights and How to exercise them

This section sets out the rights which you have to address any concerns or queries with us about our processing of your Personal Data. Note that in certain circumstances, these rights may not be absolute:

Right of Access

You have the right to request a copy of the Personal Data held by us about you and to access the following information in relation to the processing of your Personal Data:

• The purposes of processing,
• The categories of Personal Data concerned;
• The recipients of your Personal Data;
• The period for which your Personal Data will be stored;
• The existence of your right to lodge a complaint with the Data Protection Commission, and
• The source of your Personal Data. Right to Rectification You have the right to request that we amend any inaccurate Personal Data that we have about you.

Right to Erasure

You have the right to ask us to erase your Personal Data where:

• It is no longer necessary to perform our contract with you,
• You withdraw your consent and there is no other legal basis permitting us to process your Personal Data,
• You object and we have no overriding legitimate interest,
• Your Personal Data has been unlawfully processed, or
• It must be erased to comply with a legal obligation. Please note that erasure may not be complete or immediate to the extent that some of your Personal Data is necessary for the purpose for which it was collected.

Right to Restriction of Processing

You have the right to ask us to restrict processing your Personal Data in the following situations:

• Where you contest the accuracy of your Personal Data,
• Where the processing is unlawful and you do not want us to delete your Personal Data,
• Where we no longer need your Personal Data for the purposes of processing but you require the data in relation to a legal claim, or
• Where you have objected to us processing your Personal Data pending verification as to whether or not our legitimate interests override your interests or in connection with legal proceedings. When you exercise this right we may only store your Personal Data and may not further process it unless you consent or the processing is necessary in relation to a legal claim or to protect the rights of another person or legal person or for reasons of important public interest.

Right to Data Portability

You may request us to provide you with your Personal Data which you have given us in a structured, commonly used and machine-readable format and you may request us to transmit your Personal Data directly to another data controller where this is technically feasible.

This right only arises where:

• We process your Personal Data with your consent or where it is necessary to perform our contract with you, and
• The processing is carried out by automated means.

Right to Object

You have a right to object at any time to our processing of your Personal Data where we process your Personal Data on the legal basis of pursuing our legitimate interests.

We will only charge you for making an access request where we feel your request is unjustified or excessive.

We will provide you with information on any action taken upon your request in relation to any of these rights without undue delay and at the latest within one month of receiving your request. We may extend this timeframe by one more month if necessary having regard to the circumstances of the request. However we will inform you if this arises.

You can exercise any of these rights by submitting a request to privacy@clubforce.com.

Questions and Complaints

If you have any concerns about the way your Personal Data are being used or processed by Clubforce, please contact our Data Protection Officer at privacy@clubforce.com. If you have any concern in relation to how your Personal Data is used or processed, you have the right to lodge a complaint with your national data protection regulator. For Ireland and the UK the details are below:

Data Protection Commission

21 Fitzwilliam Square

Dublin 2

D02 RD28

Ireland

Tel. +353 76 110 4800

email: info@dataprotection.ie

Website: http://www.dataprotection.ie/

The Information Commissioner’s Office

Water Lane, Wycliffe House

Wilmslow – Cheshire

SK9 5AF

United Kingdom

Tel. +44 1625 545 700

email: casework@ico.org.uk

Website: https://ico.org.uk