Last updated September 2021
This privacy statement sets out how we collect and process your personal information through our Websites.
We need to collect, hold, use and disclose your personal information in order to provide our Website and associated services.
You can click through to find more detail on the areas that interest you below.
1. Who we are
2. What information we collect and how we collect it
3. The legal basis on which we collect and process your information
4. Who we share your information with
5. International transfers
6. How long we keep information for
7. Your rights
8. Third party Links
9. How we can change this policy
1. WHO WE ARE
1.1 We are Rugby Pass Limited, of Iconic Office - The Victorians, 15 - 18 Earlsfort Terrace, Saint Kevin's, Dublin 2, Dublin D02 HR23, Ireland. If you are based in the European Union, we are the "data controller" of your information. If you would like to contact us in connection with this Privacy Statement or have any questions about it, please contact us.
2. WHAT INFORMATION WE COLLECT AND HOW WE COLLECT IT
2.1 Information we collect directly: We collect information that you enter when you create an account or subscribe to our services on the Website, and we mainly use it to administer your subscription and provide you with services. The information we collect includes:
(a) your name (so we know who you are);
(b) your email (so we can contact you);
(c) password (for authentication purposes);
(d) username (so we can post your comments in the future); (Username will be visible, please create an anonymous name accordingly)
(e) payment information (so we can take payment);
(f) country of residence (to charge you in the right currency, and for tax reasons);
(g) details of your subscription (eg the start and finish dates, and what service you have subscribed to, so we can charge you the right amount at the right time and provide you with the right services);
(h) whether you have subscribed to receiving marketing emails from us (so we can send you marketing emails if you consent and content emails if you subscribe to one of our services);
(i) Details of how you use and interact with our services, including time and duration of visit, content accessed, offer conversion and/or interaction data (so that we can monitor the effectiveness of our services and customise your experience to suit your preferences);
Also, if you email us, or use other interactive functionality in our website like the "contact us" function, or you submit a comment through the comments functionality, we collect the information you submit and use it for the purpose of responding to your query, or publishing and moderating your comment, as applicable.
Where we collect information directly from you, we will make it clear whether provision of information is voluntary or mandatory. Generally, if you do not provide mandatory information where requested, we will not be able to provide the relevant service or functionality to you.
2.2 Information collected automatically: When you visit our website or use the Services, or interact with an email from us we automatically collect certain information, using cookies, analytics and other similar technologies (eg pixels). This information generally does not identify you personally, and is used to monitor the effectiveness of improve our website, communications and services, and to deliver personalised content to you (eg based on where in the world you are located). Please see our Cookies Policy for further information.
2.3 Information collected via third parties: We might collect certain information about you from our related companies, where it's relevant to your subscription. For example, a related company might tell us that you're entitled to a subscription at no charge because you already subscribe to a qualifying service from them. In addition, if you register via a third-party platform (eg Facebook or Google), we collect your name and address from them to help speed up the registration process.
3. THE LEGAL BASIS ON WHICH WE PROCESS YOUR INFORMATION
3.1 There are a number of legal reasons why we process your information:
(a) Consent: Some processing is carried out with your consent, for example where you have opted in to receiving marketing communications (and haven't subsequently opted out).
(b) Contract: Some processing is carried out to perform our contractual obligations to you – ie to provide you with our services, where you have subscribed.
(c) Legitimate interest: Some processing is necessary for a legitimate interest of ours that isn't overridden by your interests or fundamental rights and freedoms. For example, we might use your information:
(i) to monitor use of and improve our website and services;
(ii) to answer your queries;
(iii) to detect fraud, intellectual property infringement or other unlawful activity, or breaches of our terms and conditions;
(iv) to undertake internal management (such as training, and systems development, testing and support);
(v) in relation to a potential sale or purchase of business or assets.
(d) Legal requirement: Some processing is carried out where required by law. For example, to maintain appropriate billing and accounting records, and/or where we get a legally binding request from a governmental authority.
4. WHO WE SHARE YOUR INFORMATION WITH
4.1 Service providers: We might share your personal information with third parties that provide services that help us administer the Website and our services, provide our customer journey and help us manage subscriptions. If you would like to know more about these service providers please contact us.
4.2 Related entities: We may share your information with our parent company and related group entities for the purpose of improving our services to you. When you have given us your express consent to do so, we may also share your information so they may offer you new services.
4.3 Other: We may share your information where it is necessary to facilitate a sale or purchase of a business, or where we are required to do so by law or due to a legally binding request from a governmental authority.
5. INTERNATIONAL TRANSFERS
Because we are located in Ireland, with operations in New Zealand and other locations around the world and a global customer base, we may transfer your information outside the country in which you are located. When we do so, we will ensure that appropriate legal and technological safeguards are in place to protect your personal information. If you want to know more information about how your personal information is protected please contact us.
6. HOW LONG WE KEEP INFORMATION FOR
6.1 We only keep your personal data for as long as we need it to perform the purpose of collection. However, please be aware that if you cancel a subscription, we do keep your account open for a period of time in case you wish to restart a subscription in the future. We might also retain your information so that we know whether you are subscribed to our emailing list, whether you have already used your free trial entitlements, and for accounting and other legally required record keeping purposes.
7. YOUR RIGHTS
7.1 You have rights under applicable privacy and data protection laws in relation to your personal information. This includes:
(a) A right to access and correct/rectify your personal information;
(b) in some cases, a right to erasure (or a "right to be forgotten")
(c) in some cases, a right to restriction of processing, for example where you contest the accuracy of some information;
(d) in some cases, a right to data portability;
(e) in some cases, a right to object to processing;
(f) where we process your information on the basis of consent, a right to withdraw that consent.
To exercise these rights, please contact us.
7.2 If you think we have not complied with the law in relation to your personal information, you also have the right to complain to your local privacy or data protection authority.
8. THIRD PARTY LINKS
9. HOW WE CAN CHANGE THIS POLICY
9.1 We keep this Privacy Statement under regular review and will provide notice of changes to this Privacy Statement on our website and by sending an email to current account holders.
9.2 This Privacy Statement was last updated in September 2021. Historic versions are available by contacting us.