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Privacy Policy for RugbyPass Ltd. Websites

Data Protection Statement

RugbyPass Website (the “Website”)

1. Statement and Purpose 

RugbyPass Limited (“RugbyPass”), of World Rugby House, 8-10 Pembroke Street Lower, Dublin 2, Ireland, has developed this Data Protection Statement to demonstrate its commitment to the protection of the privacy and personal data of data subjects who interact with the Website.  

This Data Protection Statement is relevant to you if you are an individual who interacts with this Website, or whose data is managed by RugbyPass (e.g. if you are a fan, follower or subscriber of this Website or our newsletters, enter our competitions, participate in any of our on-line or face-to-face seminars or courses, etc).

The purpose of this Data Protection Statement is to give you a better understanding of:

  • the types of your personal data which we collect;
  • how we use, store and share that information;
  • how we protect your data protection rights;
  • how you can find out more about how we use your information; and
  • other details relevant to how we give effect to the privacy of individuals.

In some situations where we are collecting and processing your personal data, we will provide you with further information about the data we are collecting, the purposes for which we are using and sharing that information as well as any other information which is particularly relevant to such situations (e.g. online competitions, online rugby-related games, etc). When we do so, we may also refer back to this Data Protection Statement and the general principles set out here.

2. Who We Are

This Website is controlled and operated by RugbyPass Limited. RugbyPass is part of the World Rugby group of companies, which includes World Rugby, the world governing body of the sport of rugby union, and its group of operating companies (including World Rugby Limited, Rugby World Cup Limited and World Rugby Tournaments Limited). 

3. Controller and DPO Contact Details 

RugbyPass is the data controller for the personal data it processes via the Website. 

We have appointed a Data Protection Officer (DPO), Liam McKenna (dataprotection@worldrugby.org) to underpin our commitment to privacy. 

If you a) have any queries in relation to this Data Protection Statement, b) wish to contact the DPO or c), if you would like to contact RugbyPass in relation to your data protection rights, please feel free to contact us using the contact information contained in the Contact Details section below (see Section 13). 

4. Processing Activities

RugbyPass, via the Website, carries out a range of activities which may involve the processing of your personal data. 

In general, you can visit the RugbyPass Website without you providing personal data but we may still collect aggregated and anonymised statistical data (as described below). However, your interactions with us via this Website may involve you providing us with personal data, or us collecting your personal data, as outlined below. 

The personal data that we process about you may vary depending on which of our activities we are carrying out.

Set out below are further details on the personal data we collect in connection with the relevant activities, the purposes for which personal data is processed in connection with those activities, the third parties to whom your data may be disclosed, and the lawful basis of the relevant data processing. 

We may use your personal data for the following purposes:

  • To enable you to create an account or profile with us or to subscribe to our newsletter(s) or mailing list(s);
  • To respond to your enquiries or otherwise correspond with you;
  • To provide you with content on or relating to our Website, apps and other digital and social channels and to continuously improve the performance of the Website, or such platforms and channels;
  • To enable you participate in certain activities, functions or services available on our Website, apps and channels (such as competitions, score/match predictors, fantasy rugby games, etc.);
  • To give effect to any preferences you share with us or that we observe from your use of our sites, apps and channels, so that we can make available to you information which most interests you (e.g. in order to personalise and improve your experience on our digital platforms, to personalise and/or tailor any communications that we may send you or for profiling purposes to enable us to personalise and/or tailor any marketing communications that you may consent to receive from us);
  • to track your activity on our Website for the purpose of improving Website performance;
  • to send information to you about RugbyPass, its platforms and websites, its activities and/or its commercial partners as may be requested by you;
  • to fulfil any contract that we may enter into with you;
  • to send marketing information to you in ways set out in this Data Protection Statement;
  • to pursue our legitimate interests in a way that you might reasonably expect in relation to the operations of our company and which does not significantly impact your data protection interests, freedoms and rights. 

For ease, the table below describes the main purposes for which we process your personal data, the categories of the data involved and our lawful basis for being able to do so: 

1.
Purpose 

Create and administer any account(s) you have or create with us, manage our relationship and communications with you, and provide you with access to information you request on our platforms

Personal Data Processed

All contact and account profile details that you provide to us (which may include your name, age, email, country of residence, and your confirmation that you have read and agree with policies applicable to the Website), your professional details, records of your interactions with us, and marketing preferences.

Lawful Basis

This is necessary to enable us to properly manage and administer your agreement with us to create and manage your account profiles on our Website. 

2.
Purpose 

To send you marketing information we think you might find useful or which you have requested from us, including our news items, information about events, information about our commercial partners, special offers or promotions (including such offers or promotions from our commercial partners)

Personal Data Processed

All contact and account profile details and marketing preferences.

Lawful Basis

Where you have given us your explicit consent to do so.

3.
Purpose 

To allow you to participate in competitions, games and other activities, facilities or services available on the Website.

Personal Data Processed

All contact and account profile details, together with any other personal information you submit as part of your participation in the relevant competition, game or other services or activities (such as your answers to competition questions, your predictions as to the score of a match or your team selection and points in a fantasy rugby game)

Lawful Basis

This is necessary to enable us to properly manage and administer your participation in the relevant competition, game or other service or function in which you participate. 

4.
Purpose 

To track your activity on our platforms via the use of cookies in accordance with our Cookies Consents and Cookies Policy

Personal Data Processed

Activity tracking cookies which may contain information that relates to you.

Lawful Basis

Where you have consented to us using such cookies in accordance with our Cookies Consents and Cookies Policy.

5.
Purpose 

To answer your queries, complaints or other correspondence with you. We have a legitimate interest to provide complaint handling services to you

Personal Data Processed

Contact details and records of your interactions with us

Lawful Basis

We have a legitimate interest in providing you with a complaint handling services and otherwise responding to your queries.

6.
Purpose 

We may collect information about your interaction with Website and the services on the Website. This may include information about your computer and, where available, your IP address operating system and browser type. We may perform statistical analysis of user behaviour and characteristics in order to measure interest in and use of the various areas of the Website and to ascertain the number of users that have visited particular web pages. (“statistical data”). In performing statistical analysis, parts of the sites use Google Analytics (a web analytics service provided by Google, Inc.) to capture and analyze Website statistics

Personal Data Processed

Information collected via statistical/analytical Cookies

Lawful Basis

Where you have consented to us using such cookies in accordance with our Cookies Consents and Cookies Policy. 

7.
Purpose 

Online retargeting is another form of online advertising that allows us and some of our advertising partners to show you advertising based on your browsing patterns and interactions on the sites. We share and receive online data collected through cookies and similar technology with our advertising partners. This means that when you are on another website, you may be shown advertising based on your browsing patterns on our Website.

Personal Data Processed

IP address, URL of the webpage you are visiting and activity tracking cookies which may contain information that relates to you.

Lawful Basis

Where you have consented to us using such cookies in accordance with our Cookies Consents and Cookies Policy. 

5. Sharing of Personal Data

We may share your personal data with companies, organisations or individuals in one or more of the following situations:

  • RugbyPass may share your personal data with other entities within the World Rugby Group (which includes World Rugby, the world governing body of the sport of rugby union, and its group of operating companies (including World Rugby Limited, Rugby World Cup Limited and World Rugby Tournaments Limited) and with the organisers of any World Rugby tournaments where you have requested that we do so and/or where it is necessary in order to provide you with information that you have requested (e.g. in relation to information regarding World Rugby tournaments);

  • Certain associated organisations and companies, where you have consented to us doing so. The associated organisations and companies to which, with your permission (in both cases), we will release your personal data are limited to:

- our commercial partners, official partners/sponsors, official suppliers;

- any third parties noted in our Cookies Policy (where you have consented to the use of relevant cookies).

- Certain activities which may be available on the Website (such as competitions or fantasy rugby games) may involve the sharing of some of your personal data (as noted above) with other individuals participating in that activity with other players.  

6. Right to Withdraw Consent and Contract Performance

If you have given us your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not impact or negate the lawfulness of  any processing of your data based on your consent before your withdrawal). This includes your right to withdraw consent to us using your personal data for marketing purposes. You may withdraw your consent to receiving marketing communications from us by contacting us using the details below, or by using the unsubscribe option available to you in each communication. 

If you have opted in to receive any information from any third-party organisations (including our commercial partners) and you wish to unsubscribe from their communications, please note that you will need to contact those third-party organisations directly or use the unsubscribe option available to you in their communications. 

In circumstances indicated above, we may also process your personal data for the purposes of performing a contract with you (e.g. in relation to you accessing features on our Website, platforms or channels). Our ability to perform such contracts depends on your providing such information. Failure on your part to provide the personal data which we have requested in these circumstances will result in the contract being rendered impossible (with the potential consequences, for example, that you will not be able to participate in a particular activity or access a Website, platform, channel or system to which you are seeking access).

7. Disclosure of your Data to Entities within the World Rugby Group

RugbyPass is part of the World Rugby group of companies, which includes World Rugby, the world governing body of the sport of rugby union, and its group of operating companies (including World Rugby Limited, Rugby World Cup Limited and World Rugby Tournaments Limited). As the activities of World Rugby are international in scope, the World Rugby group has a number of separate and distinct legal entities across various countries. 

As such, we may share and disclose your personal data to other entities within the World Rugby Group, including to such entities and/or countries that are located outside the European Union (EU). Where we do engage in such transfers, we will put in place relevant agreements with such World Rugby Group entity to ensure the proper and adequate protection of your personal data. 

8. Other Disclosures of your Data

In addition to the specific disclosures of your data already referenced, detailed or set out above in this Data Protection Statement, we will also share your personal data with third parties in the following circumstances:

  • We may need to provide our trusted third party service providers with access to your information to enable us to perform maintenance, administrative or technical support for this Website, or where such third parties perform functions on our behalf or provide services to us, which includes, professional advisors, website provider technology/IT providers, servers/hosts or cloud service providers; advertising providers and advertising exchanges; e-marketing providers, analytics companies; recruitment providers, payment providers, fraud and credit checking companies. These service providers are not authorised by us to use or disclose personal data except as necessary to perform services for which they are engaged on our behalf or comply with legal requirements; 
  • Where we need to share your personal data to provide a product or service you have requested;
  • We may also share your personal data with third parties when required by law or in response to legal process;
  • in response to a request from law enforcement relating to a criminal investigation;
  • to protect our rights, privacy, safety or property, or that of the public;
  • to analyse our data, conduct mobile analytics services or to maintain and improve our services (subject to confidentiality agreements as appropriate);
  • to permit us to pursue available remedies or limit damage that we may sustain;
  • if the rights or safety of another individual might be violated or in threat; and
  • where you otherwise consent to us doing so.

9. International transfers of your data

In some of the circumstances described above, your personal data may be transferred, accessible or visible to individuals and/or entities located outside of the European Union. Countries outside the European Union may not provide a level of legal protection for your information as strong as the level of protection provided in Ireland or your home country. Where we transfer your personal data to a recipient based outside the European Union, we will put in place standard contractual clauses with the overseas recipient of the information, protecting the information, in the appropriate standard form approved for this purpose by the European Commission. 

The exceptions to the above are where we transfer information to member states of the European Economic Area or to countries outside the European Union which have been determined to provide an adequate level of protection by the European Commission, such as an adequacy decision or certification or corporate binding rules, or where the transfer is legally justified on another basis.

10. Cookies

This Website uses Cookies. Cookies help us to provide you with the very best experience when you use our website and help us to make improvements, including in relation to performance, to the Website. 

You can accept, reject or manage cookies by clicking on the Cookie Consent Banner or the Cookies Pop-Up on the Website. 

For detailed information on the Cookies that we use and the reasons why we use them, please feel free to consult our Cookie Policy. 

11. How long do we keep your information?

The duration for which we retain your personal data will differ depending on the type of information and the reason why we collected it from you. We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. To determine the appropriate retention period for personal data, we take into account the following criteria and considerations:

  • 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;
  • our contractual obligations and rights in relation to the personal data involved; and
  • applicable legal requirements (including prescribed retention periods and statutes of limitations).

In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you.

12. Your rights to access, correct, modify and/or remove your personal data

In addition to your right to withdraw consent referenced above, you have the following rights under applicable data protection law: 

  • The right to be informed about the processing of your personal data; 
  • The right to access your personal data; 
  • The right to rectification of your personal data; 
  • The right to erasure of your personal data;
  • The right to data portability;
  • The right to object to processing of your personal data; 
  • The right to restrict processing of your personal data;
  • Rights in relation to automated decision making, including profiling. 

The ability of a data subject to exercise any of the above rights may be restricted or subject to specific conditions depending on certain circumstances. 

13. Contact Details

If you have any questions about this Data Protection Statement, the practices of this Website or your dealings with this Website, you can contact us at the contact details set out directly below:

Please feel free to write to us at dataprotection@worldrugby.org or World Rugby House, 8 – 10 Lower Pembroke Street, Dublin 2. 

You can also contact our Data Protection Officer by emailing dataprotection@worldrugby.org. 

14. Complaints

If you are not happy with the way that we have used your information or addressed your data protection rights, you have the right to make a complaint to the Irish Data Protection Commission by using the following link: https://forms.dataprotection.ie/contact 

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