Clubzap Ltd. is a private company limited by shares incorporated in Ireland with company number 588710 and having a registered office at Cloughoolia, Sixmilebridge, Co. Clare, Ireland (“we”/ “us”/ “our”/ “Clubify”/”Clubzap”). We provide a mobile communications & payments platform for sports clubs to engage their community, grow membership and increase fundraising.
Under this Policy, and unless the circumstances otherwise require, we will be what’s known under the General Data Protection Regulation (EU) 2016/679 (the “GDPR”) as the “controller” of the personal data you provide to us.
The information we collect
We will collect and process the following data about you for the following purposes:
Information you give us
Your Data. This is information about you that you give us by filling in forms on our Site or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you use our Site, register for, subscribe to or use the Services, search for a product, place an order on our Site, participate in discussion boards or other social media functions on our Site and/or when you participate in and respond to our sign-up or other surveys or report a problem with our Site and/or the Services.
The information you give us may include:
- Identity Data: your full name, address, e-mail address, phone number, address, age, title and personal description.
- Financial Data: your financial and credit card information, including bank account and payment card details, billing contact email address and VAT number.
The information we collect about you
Automatically Collected Information. With regard to each of your visits to our Site we will automatically collect the following information:
- Technical Data: technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, how often you use the application and other performance data which may be subject to analytics software such as Fabric.io (“Fabric”) and New Relic Inc (“New Relic”);
- Usage Data: information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call us; and
- No special categories of personal data: We do not require or collect any personal data that is your sensitive personal data or any special category of personal data under the GDPR, unless you decide to provide this information to us.
What are cookies and why we use them
What we do with your information
We will only use your personal information when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interest (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at email@example.com. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with this Policy, where this is required or permitted by law.
How long we keep your information
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. This means that the period of time for which we store your personal data may depend on the type of data we hold. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. For example, we may hold personal data as needed for our accounting or tax compliance purposes for a period of 6 years or for 5 years where needed for our compliance with anti-money laundering regulations. For more information about our data retention policies please contact us at firstname.lastname@example.org
Disclosure of your information
We do not sell your personal information (or Your End Customer Data) to third parties for marketing purposes. We may disclose information to third parties if you consent to us doing so as well as in the following circumstances:
You agree that we have the right to share your personal information with the following recipients or categories of recipients.
- Any department or authorized person within our company or any member company within our group, which means any subsidiary or holding company within the meaning of sections 7 and 8 of the Companies Act 2014.
- Selected third parties including: business partners, suppliers, and sub-contractors for the performance of any contract we enter into with them or you in relation to the Services, including but not limited to:
- to to Stripe for payment and delivery services;
- to to Amazon Web services for hosting and maintaining ClubZap applications
- Where we have your consent to do so, email marketing service providers, including MailChimp, to send information to you from time to time by email about promotions, competitions, updates and new products or services that may be of interest to you;
- Analytics and search engine providers that assist us in the improvement and optimization of our Site such as to Fabric, New Relic, and Sentry;
We will disclose your personal information to third-party recipients.
- In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of our business or assets.
- If Clubzap or substantially all of its assets are 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 law, legal obligation or court order, or in order to enforce rights under the GDPR or to apply our Terms of Service and other agreements.
- To protect our rights, property or safety, our customers, or others. This includes exchanging information with other companies and organizations for the maintenance and security of the Site and Services.
Your Personal Data and Your Rights
Accessing your Personal Data
We will need to verify your identity in such circumstances and may request more information or clarifications from you if needed to help us locate and provide you with the personal data requested. There is usually no charge applied to access your personal data (or to exercise any of the other rights). However, if your request is clearly unfounded, repetitive or excessive, we may charge a reasonable fee. Alternatively, we may refuse to comply with your request in these circumstances.
Right of Restriction
You may restrict us from processing your personal data in any of the following circumstances:
- You have contested the accuracy of the personal data we hold on record in relation to you or for a period of time to enable us to verify the accuracy of the personal data;
- The processing of your personal data is unlawful and you request the restriction of the use of personal data instead of its erasure;
- Where you have contested the processing (under Article 21(1) of the GDPR) pending the verification of our legitimate grounds.
Corrections or Erasure (Right to Rectification and Right to Be Forgotten)
If we hold personal data concerning you which are no longer necessary for the purposes for which they were collected or if you withdraw consent for us to process your personal data, you can request the deletion of this personal data. This right, however, will not apply where we are required to process personal data in order to comply with a legal obligation or where the processing of this information is carried out for reasons of public interest in the area of public health. If the personal information we hold about you is inaccurate, you may request to have your personal information updated and corrected. To do so at any time, please contact us by email at email@example.com
Your Right to Object
You have the right to object to the processing of your personal data at any time:
- For direct marketing purposes
- Where we process your personal data for the purposes of legitimate interests pursued by us, except where we can demonstrate compelling legitimate grounds for this processing which would override your interests, rights, and freedoms or in connection with the enforcement or defence of a legal claim
Should this occur, we will no longer process your personal data for these purposes unless doing so is justified by a compelling legitimate ground as described above. For more information about our marketing practices, please see the Marketing Communications section below.
Where we process your personal data by automated means (i.e., not on paper) and this processing is based on your consent or required for the performance of a contract between us, you have the right to request from us a copy of your personal data in a structured, commonly used machine-readable format and, where technically feasible, to request that we transmit your personal data in this format to another controller.
The rights described in this section are personal rights and are exercisable only by the individual person (or data subject) concerned. If we receive any such request or communication directly from your customers and/or in relation to Your End Customer Data, we will refer the matter to you and cooperate in providing such reasonable assistance as may be required to enable you, as a controller, to respond to the matter. This will be described in more detailed in the Terms of Service or the other relevant contract between us.
We will not use your data to send marketing communications to you about promotions, competitions, updates and new products or services that may be of interest to you, unless we have your permission to do so.
Your Right to Object
You have the right to object to the processing of your personal data for our marketing purposes. To object or if you change your mind at any later time, you can withdraw your consent to the processing of your personal data for such marketing purposes by contacting us at firstname.lastname@example.org
You may also opt out of receiving marketing communications at any time by selecting the unsubscribe option when you receive an electronic marketing communication from us. The withdrawal of your consent will not impact upon the lawfulness of processing based on your consent prior to the withdrawal.
We use MailChimp and other email marketing service providers
Acknowledgement and Disclaimer
We take our security responsibilities seriously, using the most appropriate physical and technical measures and require our hosting partner to use the same standard of care. 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 your data transmitted to our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access. These are described in more detail below.
Location of Servers and Accessibility
The Services are a SaaS based CRM (Customer Relationship Management) system and, as such, your personal data is not stored locally but on a secure server. No installs are required on your PC or laptop. Our web application is only accessible via HTTPS, which helps ensure your interactions with our app are secure and private.
Live instances of your personal data is stored on secure servers hosted on Amazon Web Services (AWS), a service provided by Amazon.com. These servers are located in the Dublin, Ireland, Europe. Backups are encrypted and stored in a data centre on the US East Coast. Amazon Web Services participates in and has certified its compliance with the EU-US Privacy Shield Framework. You can read more about Amazon’s security policy on AWS Cloud Security.
Your personal data is encrypted and backed up on a nightly basis. The Amazon server data centres are protected by physical barriers and guarded 24/7.
Data is encrypted using SSL Certification when transmitted from our servers to your browser. In the "security test" page we are graded A+. In addition to this, the connection from us to the server is secured using a 256 BIT ENCRYPTION key.
Our servers in Amazon's data centre are run in an isolated private network (Amazon Virtual Private Cloud Service). Access to the production environment where your personal data is stored is limited and is held by us. Only our authorized staff from the have access to our servers and this is on a 'need to access' basis. Access to personal data is limited to specific IP address.
Development and Operations
New features and updates are developed and released on development servers prior to being pushed live to the main production environment. Extensive testing is undertaken by our Quality Team to ensure all new features are working correctly and the performance of the Site and Services is maintained.
Performance Monitoring Applications
The overall performance of the Site and Services is very important. NewRelic is a performance management solution used for tracking and monitoring the Site and Services. We also use Fabric and Sentry to analyze the Site’s and Services’ performance. To help avoid or minimize service interruptions, our servers are constantly monitored and a dedicated team are alerted immediately in case of any service disruptions.
Passwords and Authentication
Connection to the Services environment is via TLS cryptographic protocols, using global step-up certificates, ensuring that our users have a secure connection from their browsers to our service. Individual user sessions are identified verified using a unique token created at login. Email address is the unique identifier in the Services
Changes to this policy
Any changes made to this Policy from time to time will be published at the Site.
Any material or other change to the data processing operations described in this Policy which is relevant to or impacts on you or your personal data will be notified to you in advance by email. In this way, you will have an opportunity to consider the nature and impact of the change and exercise your rights under the GDPR in relation to that change (e.g., to withdraw consent or to object to the processing) as you see fit.
Questions or Complaints