PRIVACY POLICY
Privacy Policy Introduction
Welcome to Clublink Ltd’s Privacy Policy. Your privacy matters to us, and we are dedicated to safeguarding your personal information. Within this policy, we will detail our procedures for handling your data when you use our application. When we process your data, it’s important to know that you possess certain rights, and we are committed to adhering to the relevant laws that protect those rights. This policy will outline these procedures, your rights, and the importance we place on responsibly managing your data.
Section 1: Who We Are
Purpose
Clublink is not intended for individuals under the age of 18, and we do not knowingly collect information related to children. We urge you to read this privacy notice in conjunction with any other privacy notices or fair processing notices provided on specific occasions when we gather or process your personal data. By doing so, you’ll gain a comprehensive understanding of how and why we utilise your data. This privacy notice complements other notices and is not meant to supersede them.
Controller
In this privacy policy, “Clublink Ltd,” “Clublink,” “we,” “us,” “the Company,” or “our” refer to Clublink Ltd, which is responsible for your personal data. We have designated a data privacy manager to oversee inquiries related to this privacy notice. If you have questions concerning this notice, including requests to exercise your legal rights, please reach out to our data privacy manager using the contact details provided below.
Contact
Our contact details are as follows:
– Full name of legal entity: Clublink Ltd
– Email address: info@clublinkapp.com
– Postal address: 123 Merrylee Road, Glasgow, Scotland, G32 2RB
You retain the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK’s data protection supervisory authority (www.ico.org.uk), at any time. However, we kindly request that you contact us initially to address any concerns before approaching the ICO.
This version of our policy was last updated on September 23, 2023. We emphasise the importance of maintaining accurate and up-to-date personal data. Please inform us of any changes to your personal data through the profile edit page. As discussed later in this policy, you have the right to access and rectify any inaccuracies in your personal data, and we are happy to assist with this.
Third-Party Links
Our website may contain links to third-party websites, plugins, and applications. Clicking on these links or enabling these connections may allow third parties to collect or share information about you. We do not govern these third-party websites and are not responsible for their privacy statements. When you leave our websites, we encourage you to review the privacy notices of every site you visit.
Section 2: Data Collection
Personal data, or information about individuals that can identify them, is what we refer to as personal information. Excluded from this definition is data from which the identity has been removed (anonymous data). We may collect, utilise, store, and transmit various types of personal data about you, which we have categorised as follows:
– Identity Data: This includes your first name, maiden name, last name, marital status, title, date of birth, personal photograph, and gender.
– Contact Data: This encompasses your billing address, delivery address, residential address, email address, and telephone numbers.
– Financial Data: This consists of bank account information and the last four digits and expiry date of your payment card details.
– Transaction Data: This contains details about payments to and from you, as well as other information regarding products and services you have acquired from us.
– Technical Data: This covers your internet protocol (IP) address, browser type and version, time zone setting and location, browser plugin types and versions, operating system and platform, and other technological information from the devices you use to access our website.
– Profile Data: This includes your password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.
– Usage Data: This comprises information about your interactions and usage patterns on our websites and/or other websites, mobile apps, products, and services. It also includes the frequency of your interactions with our websites and/or other websites, mobile apps, products, and services.
– Marketing and Communications Data: This pertains to your preferences regarding marketing communications from us and third parties, as well as your communication preferences.
– Aggregated Data: We also collect, use, and share Aggregated Data, which is statistical or demographic data for various purposes. Aggregated Data may be derived from your personal data but is not considered personal data under the law, as it does not directly or indirectly reveal your identity. However, if we combine or associate Aggregated Data with your personal data in a manner that allows your identification, we treat the combined data as personal data, and it will be handled in accordance with this privacy notice.
We do not gather Special Categories of Personal Data about you, which includes information about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health information, genetic or biometric data, or details about criminal convictions and offenses.
Failure to Provide Personal Data
If we are legally required to collect personal data or if the data is necessary for a contract we have with you, and you do not provide this requested data, it may prevent us from fulfilling the contract or service you have with us. For example, if you need to place an order to purchase event tickets, we may need certain information from you. In such cases, we will notify you if non-provision of data will result in the cancellation of a product or service.
Section 3: Collecting your personal data
Direct interactions
Most of the personal information we process is provided to us directly by you. This is data that is collected through the direct filling in of forms or similar. This may include information relating to identity, contact information, or financial data. This includes information provided when you order through our app, give information on our website, request marketing to be sent, enter a competition, promotion or survey, give us feedback, or when promoters use our manager service.
Automated collection
Throughout the use of the product, we may automatically collect personal information. This may include information about your equipment, browsing actions and patterns. This is collected through cookies and other similar technologies. We may receive data about you if you visit other websites employing our cookies. We may receive further information if you consent to providing us with your preferences on third party websites or platforms.
Other
We also receive personal information indirectly. We may use web beacons. When we send emails to individuals, we may monitor who opens the emails and/or clicks on links within the email. Information including IP addresses, browser types and email clients may be collected when opening an email from us.
When you use our mobile app, Technical Data may be collected. This includes information about your device or operating system. You can opt-in to receive push notifications regarding your account. We may collect and utilise your location data to enhance and offer customised services. You can enable or disable location-based services through your device settings. We may use mobile analytics software to collect Usage Data.
We may receive personal information about you from third-party sources and publicly available databases. Some examples of what we may collect includes:
– Identity Data from sources like Facebook and other ticket agents.
– Contact Data from sources like Facebook.
– Profile Data from sources like Facebook and Spotify.
– Technical data from:
o Analytic providers (e.g. Google Analytics based outside the EU to track and report website traffic). Your Technical Data is used to monitor the use of our service and is shared with other Google services. This can be opted-out of by installing the Google Analytics opt-out browser add-on. For more information on this, please see Google’s privacy policy.
o Advertising networks, including Google AdSense based outside the EU and DoubleClick Cookie based outside the EU, to support and maintain our services. The DoubleClick Cookie is used for interest-based advertising, and you can opt out through the Google Ads Settings web page.
o Behavioural re-marketing services, such as Google AdWords by Google Inc. and Facebook by Facebook Inc. (both based outside the EU). We may advertise on third-party websites to individuals who have visited our websites or used our services. Your Technical and Identity Data is collected using cookies to optimize and serve advertisements based on your past interactions with our services. You can opt out of Google Analytics for display advertising and customize Google Display Network ads by visiting the Google Ads Settings page. You can also use the Google Analytics Opt-out Browser Add-on to prevent data collection by Google Analytics.
o For Facebook’s interest-based advertising information, visit Facebook’s help page, and to opt out.
o Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance.
o For Facebook’s privacy practices, refer to Facebook’s Data Policy.
o Payments providers, including Apple Store In-App Payments, Google Play In-App Payments, Stripe, PayPal, and Braintree (all based outside the EU). We collect your Contact, Financial, Transaction, and Technical Data to provide technical, payment, and delivery services for products and services you order and to track IP addresses.
o Search information providers, including Experian Limited and/or Companies House (both based inside the EU), for evaluating certain promoter deals.
o Identity and Contact Data from data brokers or aggregators like Experian Limited.
o Identity and Contact Data from publicly available sources such as Companies House based inside the EU.
Why we collect this information and what we do with it
We use the information that you have given us in order to:
– A
We may share this information with:
– Whomever you consent to this information being shared with.
– A
Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing this information are:
a) Your consent. You are able to remove your consent at any time. You can do this by contacting us at info@clublinkapp.com.
b) We have a contractual obligation.
c) We have a legal obligation.
d) We have a vital interest
e) We need it to perform a public task
f) We have a legitimate interest
Section 4: Storing your personal information
Your information is securely stored.
We keep your personal information for […]. We will then dispose of your personal information by […]
Section 5: Your data protection rights
Under data protection law, you have rights including:
Your right of access – You have the right to ask us for copies of your personal information.
Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.
Your right to object to processing – You have the the right to object to the processing of your personal information in certain circumstances.
Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
Please contact us at [insert email address, phone number and or postal address] if you wish to make a request.
Section 6: How to complain
If you have any concerns about our use of your personal information, you can make a complaint to us at info@clublinkapp.com. We would ask you to contact us about any concerns before contacting the ICO.
You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk