Effective Date: 28 September 2017
At SPay, Inc. (SPay) we understand that your privacy is important to you and we are committed to complying with the applicable privacy laws in relation to all Personal Information and Sensitive Information that we collect from you. This policy describes our Privacy and Information handling practices.
Definitions of specific terms referred to in this Policy can be found under the heading ‘Glossary’ at the end of this document.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request
This Policy outlines the following:
1. The types of Personal Information that we collect and hold.
2. How we collect Personal Information.
3. The purposes for which the information is collected.
4. The way in which we use and disclose Personal Information.
5. The steps we take to protect and keep secure the Personal Information we hold.
6. How individuals can access and correct their Personal Information held by us.
7. Mechanisms for complaint if you are unhappy about how we have dealt with or are dealing with your Personal Information.
1. The types of Personal Information that we collect and hold
In the normal course of business activities we will collect Personal Information from you and this may include collecting some Sensitive Information.
The following are the types of your Personal Information and Sensitive Information that we may collect and hold:
· We collect personal details such as name, postal and email addresses, phone numbers, date of birth, age, gender, height and rowing history.
This may also include copies of documents provided to us as proof of identity. It may also include Sensitive Information about individuals such as health information and information regarding racial or ethnic origin.
· If you order any products from our website, we also collect payment details such as credit card number and billing address.
· In registering for an event or program, you may provide Personal Information or Sensitive Information to us for the purpose of attending the event or program. We use that information for that purpose and may provide information to you regarding our other services.
2. How we collect Personal Information
We will only collect Personal Information by lawful and fair means. Personal Information may be collected directly from you or your authorised representative. We collect Personal Information and Sensitive Information via our website, email or other direct contact. You may also supply your Personal Information to us when communicating with us via social networks and other online channels, e.g. through your Facebook identity.
We do not collect Personal and Sensitive information unless the information is reasonably necessary for our business functions or activities. We will obtain your consent before collecting any Sensitive Information.
When you deal with us, you will need to identify yourself in order for us to provide our services to you, as such we do not accept the use of pseudonyms.
3. The purposes for which the information is collected
We collect, hold and use your Personal Information so that we can provide our services including to:
· assist you to register for events or programs with a local or international host organisation, governing body, club or event organiser for:
o rowing events, results or programs;
o camps or clinics;
o learn-to-row sessions;
o volunteer roles.
· assist us, the host organisations, governing bodies, clubs or event organisers in verifying your identity and/or eligibility;
· respond to you regarding the reason you contacted us or to answer your questions;
· manage our internal operations and registration processes necessary to provide our services.
4. The way in which we use and disclose Personal Information
We will use or disclose your Personal Information only for the purposes for which it was collected. If you register for a particular event or program, we will share your information with the applicable host organisation, governing body, club or event organiser for that event or program, and with any other party which furthers the purpose of your registration. These parties are authorized to use your Personal Information only as necessary to provide these services to us. We will use or disclose your information for a secondary purpose only if you have consented or if you would reasonably expect us to do so or if required by law, such as to comply with a subpoena, or similar legal process. In certain situations, SPay, Inc. may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. If SPay is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our website of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information.
We may use your Personal Information for the purposes of our own direct marketing, however we will ensure you have an ability to opt out of future such communications by following the unsubscribe instructions included in these emails or you can contact us at firstname.lastname@example.org.
We will also send you service related email announcements on rare occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email. You do not have an option to opt out of these emails, which are not promotional in nature.
Disclosure to overseas recipients
We may disclose your Personal Information to overseas recipients such as host organisations, governing bodies, clubs or event organisers which may be located in Australia, Canada, England, Germany, Belgium, Italy or the United States of America when you have sought our assistance to participate in an event or program or where disclosure is required for verification purposes. As such, the location of these overseas recipients will depend on the specific events or programs to which you apply or where such verification is required.
The information disclosed to overseas recipients consists of any information you have given to us to provide the relevant services. By accepting services from us, you consent to us providing your Personal Information to the relevant overseas recipient as mentioned above and acknowledge that we are not responsible for ensuring their compliance with the applicable privacy laws.
5. The steps we take to protect and keep secure the Personal Information we hold
We take reasonable steps to protect the Personal Information we hold against interference, loss, unauthorised access, use, modification or disclosure, and other misuse.
The steps we take include:
· maintenance of computer and network security measures such as including firewalls, use of password and other appropriate measures where information is held in electronic form;
· regular updates to security systems to protect our systems from malicious software;
· restriction of access to data to only those staff that need access to carry out our business activities;
· training and ensuring that all our employees are required, as a condition of employment, to treat Personal Information held by us as confidential;
· whenever we collect Sensitive information such as credit card data, that information is encrypted and transmitted to us in a secure way using secure socket layer technology (SSL). You can verify this by looking for a closed lock icon at the bottom of your web browser, or looking for ‘https’ at the beginning of the address of the web page.
You should however, be aware that if you submit information to us electronically the internet is not a secure environment. We take reasonable steps to provide a secure channel for receiving information but cannot absolutely protect Personal Information before it reaches us. If you have any questions about security on our website, you can contact us at email@example.com
We will retain your information for as long as your account is active or as needed to provide you services. When the Personal Information that we collect is no longer required, we will destroy, delete it in a secure manner, or ensure that the information is de-identified in accordance with our information destruction and de-identification policy, unless we are required by law to retain a copy of the Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
6. How individuals can access and correct their Personal Information held by us
You have the right to seek access to any of your Personal Information held by us unless there is a valid reason under an applicable privacy law for us to withhold the information.
Valid reasons include where:
· we have reason to suspect that unlawful activity or misconduct of a serious nature has been engaged in and giving access would be likely to prejudice the taking of appropriate action in relation to the matter; or
· giving access would reveal evaluative information generated within us in connection with a commercially sensitive process; or
· giving access would have an unreasonable impact on the privacy of other individuals; or
· giving access would be unlawful.
Upon request, SPay will provide you with information about whether we hold any of your personal information. If your personal details change, or you believe the information we hold about you is incorrect, incomplete or out-of-date, please contact us so that we can correct our records or you can make the change on your Account Information page.
Requests for access, deletion or correction to Personal Information should be addressed to the SPay Inc. Privacy Officer. All requests for access, deletion or correction to Personal Information will be responded to in writing within a reasonable period of time. As part of this process we will verify the identity of the individual requesting the information prior to providing access or making any changes. If access, deletion or correction to your Personal Information is refused we will provide reasons for our refusal.
7. Mechanisms for complaint if you are unhappy about how we have dealt with or are dealing with your Personal Information
We have procedures in place to deal with your inquiries or complaints.
If you have any questions about our policy or any complaint regarding the treatment of your privacy by us, please contact us at the respective addresses below.
Complaints to SPay Inc.
Attn: Privacy Officer
SPay, Inc. re: RegattaCentral
2029 Riverside Dr, Suite 201
Columbus, OH, 43221
United States of America
+1 (614) 360-2922
We will endeavour to respond to you within a reasonable time. If you are still not satisfied with the way your complaint is handled by us, you may be entitled to have your complaint reviewed under an applicable privacy law.
8. Additional Information
- Links to 3rd Party Sites
- Collection and Use of 3rd Party Personal Information
You may also provide Personal Information about other people, such as their name, date of birth and gender. This information is only used for the sole purpose of completing your request or for whatever reason it may have been provided. We do store this third party information. Individuals may request for us to delete their information by contacting us at firstname.lastname@example.org.
- Social Media Widgets
Updates to this Policy
We reserve the right to amend this Policy from time to time. Any revisions to the Policy will be posted on this website. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.
1. Personal Information means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not.
2. SPay means SPay, Inc. d/b/a Blue Star Sports
3. Sensitive Information includes information or an opinion about an individual’s racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, or criminal record that is also personal information, or health information about an individual, or genetic information about an individual that is not otherwise health information, or biometric information used for the purpose of automated biometric verification or identification, or biometric templates.
4. We, us and our refers to SPay.
We do not sell, rent or trade your Personal Information to any other third parties except if required by law or permitted under an applicable privacy law.
Cookies are small data files that are sent from a website and stored in a user’s web browser to improve the user’s web browsing experience. We do not link the information we store in cookies to any Personal Information you submit while on our website.
If you wish to disable the cookies on this website you will need to follow the steps required for your preferred browser but your ability to use some features or areas of our website may be limited.
Technologies such as: cookies, beacons, tags and scripts are used by SPay and our marketing partners, partners, affiliates, and analytics/monitoring service providers. These technologies are used in analyzing trends, administering the website, identifying the number of visitors and page views (or page impressions) that occur on our website and how visitors use the website (e.g. how long these visitors (on average) spend on our website and common entry and exit points to our website). We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
· Log Files
As is true of most websites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We do link this automatically collected data to other information we collect about you. We do this to improve services we offer, improve marketing and assist with analytics and site monitoring functinality.
· Behavioral Targeting/Re-Targeting