Privacy Policy

/Privacy Policy
Privacy Policy2019-01-24T13:23:35+00:00

Section 1

Section 2

Section 3

As you would reasonably expect, D.U.F.C. has a legitimate interest in obtaining and holding certain of members’ and employees’ personal data, processing it and sharing it with other members, coaches, club management, Trinity College entities and the IRFU (and affiliates including the Leinster Branch IRFU and the Irish Universities Rugby Union)  for the purpose of maintaining a sustainable, effective and successful College rugby club.

We respect and value your privacy and this statement is, therefore, your guide to the principles of privacy and confidentiality which govern the collection, use, strategic disclosure and retention of your Personal Data by the Club.

Personal Data

Personal Data is data that identifies you or can be used to identify or contact you.

We may collect, store and process personal data about you which we may obtain either directly from you, from Trinity College or from public information sources.

This may include Personal Data about you such as your name, address, contact details, gender, date of birth, occupation, nationality, image and your next of kin or any other information the Club might reasonably be expected to need for its effective management.

We may collect and process some special categories of Personal Data about you with regard to health and fitness. This may include any information relating to injuries you receive while playing rugby at any level, general fitness information, information on any pre-existing medical conditions you may have, information obtained in the course of anti-doping measures and information on any disability or mobility requirements you may have.

Legal Basis for Collecting, Storing and Processing your Personal Data

Legitimate interest

It is in our legitimate interest to collect and process your Personal Data for a range of operational, business and organizational purposes as you would reasonably expect of a rugby club:

  • Administration of Rugby

Tracking statistics and performance details across all rugby union matches played in the club; maintaining records of those involved with rugby at all levels, including referees, coaches, volunteers and others engaged in the running of the club, including preparing public facing directories of certain of this information.

Recording injury data for the management of player welfare and reporting serious injuries to the IRFU.

Preparing handbooks of contact information of committee members and others involved in the administration of rugby at a provincial and national level.

To register you as a player, member or volunteer with the club; and to maintain your registration within the database of registered players.

  • Business and Operational
  • To develop and maintain our relationship and engagement with you or your organization
  • To utilize your personal data for the purposes of communicating with you and others about club news as well as activities and fundraising, all via social media, email or website platforms.
  • To invite you to and host you at our events and meetings;
  • To facilitate purchase, subscription and marketing activities:
  • To process and respond to any inquiries, requests, and complaints

When we process your Personal Data, based on our legitimate interests, we make sure to consider and balance any potential impact on you and your data protection rights. We will not process your Personal Data for activities where our interests are overridden by the impact on you.

Compliance with a Legal Obligation

We may process your Personal Data where it is necessary:

(1) to comply with legal obligations to which we are subject:

  • To comply with our obligations under Irish and EU laws, including but not limited to safeguarding and complying with law enforcement requests; and
  • in particular, to comply with our obligations under the National Vetting Bureau (Children and Vulnerable Persons) Acts 2012-2016.

(2) To Defend, Establish or be a Party to Legal Claims

We may process your Personal Data as necessary in order for us to establish, investigate, institute or defend a legal claim to which you are a party.

Sharing and Disclosure of Your Personal Data

We may disclose your personal data to the Leinster Branch, the IRFU, IURU, relevant entities of Trinity College and, as required for the effective running of the Club, to coaches, management, volunteers of the Club and any outside agency as necessary to facilitate support services for the club.

We may share your Personal Data to facilitate rugby games and competitions at the provincial and national level.

We will only disclose your personal information to Regulatory Authorities, Law Enforcement Agencies, Public Bodies, and third-party Companies to comply with any applicable legal obligation, court order, summons, search warrants, or any other legal or regulatory obligation or request to which D.U.F.C. is subject.

Data Retention

In accordance with our policy on data retention, we shall keep your Personal Data which we process on the basis of your involvement with D.U.F.C. for a period of time after your engagement with the Club and depending on why you have interacted with us. Please note that in certain circumstances, we may hold your Personal Data for a longer period if we believe in good faith that the law or a relevant regulator may reasonably in our view expect or require us to preserve your Personal Data. Where you have registered as a rugby player, we may also retain some of your Personal Data within our player registration database unless you request us to delete such information. We may also continue to hold your Personal Data if we understand that you wish to receive ongoing communications concerning D.U.F.C., such as through receipt of the Mailchimp E-Bulletin.

Processing your Personal Data for Purchase, Subscription and Marketing purposes

How we process your Personal Data for Purchase, Subscription and Marketing Purposes

We may process your Personal Data in connection with a purchase, subscription and marketing purposes whenever you purchase match tickets, merchandise or other products from the Club or our authorized sellers or when you subscribe to the Mailchimp E-Bulletin.

You may opt out of receiving the Mailchimp E-Bulletin by following the unsubscribe instructions therein.

We may process your payments through our third-party payment providers

What Personal Data we process for Purchase, Subscription and Marketing Purposes

We may collect and process the following Personal Data about you to:

  • enter you into competitions and contests
  • conduct surveys, which you can opt-out of;
  • gain insight into the preferences and behavior of our members
  • better understand where we can make improvements; and
  • invite you to give feedback and to analyze same

Individual Details: This may include general Personal Data as described above

Customer Account Information: This is information that you provide to us when creating an account with the club and subsequently make purchases. This information may include your name, date of birth, phone number, email address, billing address, shipping address, phone number, and credit card information.

If you choose to purchase any items from the club shop for a third party beneficiary, you need to provide us with information about the beneficiary during the purchase process. In such circumstances, it is your responsibility to make sure the beneficiary or beneficiaries would have no objection to you sharing their Personal Data for the purposes set out in this Notice.

Storing of and Transfer of Your Personal Data

Your Personal data may be stored and transferred inside or outside the European Economic Area (“EEA”). We only transfer your Personal Data outside the EEA where the EU Commission has decided that the third country in question ensures an adequate level of protection in line with EU data protection standards or if there are appropriate safeguards in place to protect your data.

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 any information you transmit to us; any transmission is at your own risk. Once we have received your information, we will endeavor to use strict procedures and security features to try to prevent unauthorized access.

Your Rights and How to Exercise Them

You have a number of rights regarding access to and control of your personal data, including:

Right of Access

Right to Complain

Right of Erasure

Right to Object

Right to Portability

Right to Rectification

Right to Restriction

You can exercise any of these rights by submitting a request to the Club Chairman whose contact details are set out at the bottom of this statement.

If you have any concern in relation to how your Personal data is being used or processed please contact the Club Chairman as above. If you have continuing concerns with regard to how your Personal Data is used or processed you have the right to lodge a complaint with the Data Protection Regulator.

John Boyd

Chairman,

Executive Management Committee, D.U.F.C.

Email: [email protected]       Phone: 00447703188860

  • ·

To Defend, Establish or be
a Party to Legal Claims
We may process your Personal Data as necessary in order for us to establish, investigate, exercise or defend a legal claim to which you are a party.

  • ·  To file legal proceedings; and
  • ·  to investigate, establish, exercise or defend a

legal claim.

1.2.4 Sharing and Disclosure of your Personal Data

We will disclose your Personal Data to other members of the OW community such as the Leinster Branch and the IRFU.

We will only disclose your personal information to third parties outside the above organisations in the following circumstances:

Recipient(s)

Purpose(s)

· to assist OW in providing you products and services;
  • ·  for logistical and IT service purposes;
  • ·  to send you promotional or direct marketing

material (in circumstances where you expressly consented to receiving any such material from third party partners);

  • ·  to allow for access to matches and other events; and
  • ·  to send you surveys or polls.

OW subcontractors, service providers, ticketing providers and third party partners.

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Regulatory Authorities, Law Enforcement Agencies, Public Bodies and Third Party Companies
  • ·  To comply with any applicable legal obligation, court order, summons, search warrants, or any other legal or regulatory obligation or request to which OW is subject;
  • ·  to protect the rights, property or safety of OW, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction; and
  • ·  to enforce or apply the Terms and other agreements or to investigate potential breaches.

1.2.5 Data Retention

In accordance with our policy on data retention we shall keep your Personal Data which we process on the basis of your involvement with OW for a period of time after your engagement with OW which depends on why you have interacted with us. Please contact [email protected] for further information about our retention periods.

Please note that in certain circumstances, we may hold your Personal Data for a longer period, for example, if we are processing an ongoing claim or believe in good faith that the law or a relevant regulator may reasonably in our view expect or require us to preserve your Personal Data.

1.2.6 Third Party Sources

We may obtain Personal Data about you from the following third parties:

Social Media Information

We may receive information about you from social media platforms, such as Facebook, Twitter, LinkedIn and Instagram, when you interact with us via such platforms. This includes information which you provide to us or otherwise make available via such platforms.

Marketing Information

We may receive information about you from other third parties where we offer co-branded services or engage in joint-marketing activities.

Ticket Sellers

When you buy match tickets we may be provided with your Personal Data.

Event Organisers

We will often engage the services of third parties to assist us

in running and operating events. When you attend or express an interest in such an event we will often be provided with your Personal Data.

We may receive your Personal Data from licensees of our brand such as retail outlets, sponsors and vendors where you opt-in to receive information from us.

Licensees of our Brand

Stadia and Match Venues

We may receive your Personal Data from stadiums and match venues when you attend matches.

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1.3 Processing your personal data when you use our Website

1.3.1 How we process your Personal Data when you use our Website

For information about how we collect your Personal Data when you visit our Website, please see our Cookie Policy.

1.3.2 What Personal Data we Process when you visit our Website

We may collect and process the following Personal Data about you when you use our Website:

  • ·  When using our Website and availing of services through our Website, we may collect Personal Data about you from you and by using cookies and web analytics technology. This includes information about:
  • ·  your device type, operating system, browser, IP address

Technical Information

  • We also collect information in the course of providing you with OW E-Bulletin and any marketing material you subscribe to, or consent to receiving, on the Website.

and other information derived from cookies used on the Website. Please see our Cookies Policy for further information on our use of cookies; and

  • ·details of your visits to the Website such as traffic data, location data and the resources, advertisements and linked websites that you access through the Website.

Customer Account Information

  • ·  This is information that you provide to us when creating a customer account and subsequently using it to make purchases. This information may include your name, date of birth, phone number, email address, billing address, shipping address, phone number and credit card information.
  • ·  If you choose to purchase an item on the Website shop for a third party beneficiary, you need to provide us with information about the beneficiary during the purchase process. In such circumstances, it is your responsibility to make sure the beneficiary or beneficiaries would have no objection to you sharing their Personal Data for the purposes set out in this Notice.

Payment Information

  • This includes your payment card details plus any other information necessary for billing purposes such as your billing address or your bank account information.

Subscription Information

  • Information you provide in the course of subscribing to OW E-Bulletin. This information may include your email address, your name, your age range and your address.

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1.3.3 Legal Basis

The following table details the legal bases under which (“Legal Basis”) and the reasons why (“Purposes”) we collect, obtain and process your Personal Data:

Purpose(s)
Legal Basis
Contract

It is necessary to process this Personal Data to enter into and perform our contract(s) with you.

This could be a contract for tickets or

Fulfilling your Orders and Requests

  • ·  To provide you with information and items that you request from us and to fulfil orders you place with us;
  • ·  to process your purchases;
  • ·  to process your payments through our third party payment providers;
  • ·  to process your purchase of tickets to matches;
  • ·  to enter you into competitions and contests;

and

  • ·  to prevent the fraudulent use of gift vouchers.

Customer Account

  • ·  To create your online customer account;
  • ·  to process your purchases through this

account; and

  • ·  to otherwise manage and administer your

customer account.

Payment

  • ·  To receive payment in exchange for the products, services and tickets you purchase from us;
  • ·  to refund you any sums that may be owed to you; and
  • ·  to resolve any issues that may arise if an order is lost, processed incorrectly or otherwise encounters difficulty.
products that you purchase from us, for access to our Website, for setting up a customer account or for becoming a member according to the applicable terms, etc.

If you do not wish to provide us with your Personal Data for these purposes, we will not be able to enter into or perform our contract(s) with you.

Legitimate Interests

It is in our legitimate interests to collect and process your Personal Data for a

Improving Website Functionality & Efficiency

· To provide, improve, test and monitor the effectiveness of the Website;

range of operational, business and organisational purposes. When we process your Personal Data based on our legitimate interests, we make sure to consider and balance any potential impact on you and your data protection rights. We will not process your Personal Data for activities where our interests are overridden by the impact on you.
  • ·  to monitor metrics such as total number of visitors, traffic data and demographic patterns;
  • ·  to personalise and improve your experience on our digital platforms; and
  • ·  to ensure the content on the Website is presented in the most effective manner for you and to enhance your use of the Website.

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1.3.4 Sharing and Disclosure of your Personal Data

We will disclose your Personal Data to other members of the OW community such as the Leinster Branch and the IRFU

We will only disclose your personal information to third parties outside the above organisations in the following circumstances:

Recipient(s)

Purpose(s)

OW subcontractors, service providers and third party partners

  • For logistical and IT service purposes.
  • To comply with any applicable legal obligation, court order, summons, search warrants, or any

Regulatory Authorities, Law Enforcement Agencies, Public Bodies

other legal or regulatory obligation or request to

which OW is subject;

  • ·  to protect the rights, property or safety of OW,

our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction; and

  • ·  to enforce or apply our website terms and other agreements or to investigate potential breaches.

and third party Companies

1.3.5 Data Retention

For information about how long we retain Personal Data collected when you visit our Website for, please see our Cookie Policy. In accordance with our policy on data retention we shall keep your Personal Data which we process on the basis of your involvement with OW for a period of time after your engagement with OW which depends on why you have interacted with us. Please contact [email protected]ley.ie for further information about our retention periods.

Please note that in certain circumstances, we may hold your data for a longer period, for example, if we are processing an ongoing claim or believe in good faith that the law or a relevant regulator may reasonably in our view expect or require us to preserve your data.

  1. IF YOU ARE UNDER 16 OR A PARENT/LEGAL GUARDIAN

If you are under the age of 16, you should always speak to your parent or legal guardian before you send us an email or information, ask us to send you any information, subscribe to our Newsletter, purchase anything from us or provide us Personal Data in any other way. We will need the consent of your parent or legal guardian.

If you are a parent or legal guardian of a child whose Personal Data we are processing, then you may at any time request that we stop processing the Personal Data of your child in so far as we are able, or exercise the rights listed below at Section 4 over your child’s Personal Data by emailing us at [email protected] Please note that before we disclose or otherwise process a child’s Personal Data on the basis of such a request we may first request that you provide reasonable information about yourself and your child for identification purposes.

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  1. STORING OF AND TRANSFERS OF YOUR PERSONAL DATA

Your Personal Data may be stored and transferred inside or outside the European Economic Area (“EEA”). We only transfer your Personal Data outside the EEA where the EU Commission has decided that the third country in question ensures an adequate level of protection in line with EU data protection standards or if there are appropriate safeguards in place to protect your Personal Data. Where we transfer Personal Data to a third country, we may do so on the basis of Standard Contractual Clauses which are a form of data processing contract approved by the European Commission. You can find a copy of these clauses here.

If you would like to find out more about the appropriate safeguards that we have in place to govern the transfer of your Personal Data you can contact us at the club office.

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 any information you transmit to us; any transmission is at your own risk. Once we have received your information, we will endeavour to use strict procedures and security features to try to prevent unauthorised access.

  1. YOUR RIGHTS AND HOW TO EXERCISE THEM

This Section sets out the rights which you have to address any concerns or queries with us about our processing of your Personal Data.

Note that in certain circumstances, these rights may not be absolute:

Right Further Information
· You have the right to request a copy of the Personal Data held by us about you and to access the following information in relation to the processing of your Personal Data:

  1. 1)  the purposes of processing;
  2. 2)  the categories of Personal Data concerned;
  3. 3)  the recipients of your Personal Data;
  4. 4)  the period for which your Personal Data will be

stored;

  1. 5)  the existence of your right to lodge a complaint

with the Data Protection Commission; and

  1. 6)  the source of your Personal Data.
Right of Access
· We will only charge you for making an access request where we feel your request is unjustified or excessive.
· You have the right to request that we amend any inaccurate Personal Data that we have about you.
Right to Rectification

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Right to Erasure

  • You have the right to ask us to erase your Personal Data where:
  1. 1)  it is no longer necessary to perform our contract

with you;

  1. 2)  you withdraw your consent and there is no other

legal basis permitting us to process your

Personal Data;

  1. 3)  you object and we have no overriding legitimate

interest;

  1. 4)  your Personal Data has been unlawfully

processed; or

  1. 5)  it must be erased to comply with a legal

obligation.

  • Please note that erasure may not be complete or immediate to the extent that some of your Personal Data is necessary for the purpose for which it was collected.

Right to Restriction of Processing

  • ·  You have the right to ask us to restrict processing your Personal Data in the following situations:
    1. 1)  where you contest the accuracy of your Personal Data;
    2. 2)  where the processing is unlawful and you do not want us to delete your Personal Data;
    3. 3)  where we no longer need your Personal Data for the purposes of processing but you require the data in relation to a legal claim; or
    4. 4)  where you have objected to us processing your Personal Data pending verification as to whether or not our legitimate interests override your interests or in connection with legal proceedings.
  • ·  When you exercise this right we may only store your Personal Data and may not further process it unless you consent or the processing is necessary in relation to a legal claim or to protect the rights of another person or legal person or for reasons of important public interest.

Right to Data Portability

  • ·  You may request us to provide you with your Personal Data which you have given us in a structured, commonly used and machine-readable format and you may request us to transmit your Personal Data directly to another data controller where this is technically feasible.
  • ·  This right only arises where:

1) we process your Personal Data with your

consent or where it is necessary to perform our contract with you; and

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2) the processing is carried out by automated means.
Right to Object · You have a right to object at any time to our processing of your Personal Data where we process your Personal Data on the legal basis of pursuing our legitimate interests.

You can exercise any of these rights by submitting a request to our Data Protection Executive whose contact details are set out in Section 5 of this Notice.

We will provide you with information on any action taken upon your request in relation to any of these rights without undue delay and at the latest within one month of receiving your request. We may extend this timeframe by one more month if necessary having regard to the circumstances of the request. However, we will inform you if this arises.

  1. QUESTIONS AND COMPLAINTS

If you have any concerns about the way your Personal Data are being used or processed by OW, please contact [email protected]

If you have any concern in relation to how your Personal Data is used or processed, you have the right to lodge a complaint with the Data Protection Regulator. For further information and to find the data protection regulator, please see here.

  1. CHANGES TO THE NOTICE

If we amend this notice, in whole or part, at our sole discretion, any changes will be effective immediately upon communicating the revised notice to you.

If at any time we decide to use your Personal Data in a manner significantly different from that stated in this notice, or otherwise disclosed to you at the time it was collected, we will notify you and you will have a choice as to whether or not we use your information in the new manner.

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Responding to Queries and Complaints

  • To process and respond to any queries, requests and complaints you may submit to us.

Market Research

  • ·  To gain an insight into the preferences and behaviour of our members;
  • ·  to conduct surveys, which you can opt-out of;
  • ·  to better understand where we can make

improvements; and

  • ·  to invite you to give feedback and to analyse

same.

Compliance with a Legal Obligation

We may process your Personal Data where it is necessary to comply with legal obligations to which we are subject.

  • To comply with our obligations under Irish and EU laws, including but not limited to safeguarding and complying with law enforcement requests.

To Defend, Establish or be
a Party to Legal Claims
We may process your Personal Data as necessary in order for us to establish, investigate, exercise or defend a legal claim to which you are a party.

  • ·  To file legal proceedings; and
  • ·  to investigate, establish, exercise or defend a

legal claim.

1.2.4 Sharing and Disclosure of your Personal Data

We will disclose your Personal Data to other members of the OW community such as the Leinster Branch and the IRFU.

We will only disclose your personal information to third parties outside the above organisations in the following circumstances:

Recipient(s)

Purpose(s)

· to assist OW in providing you products and services;
  • ·  for logistical and IT service purposes;
  • ·  to send you promotional or direct marketing

material (in circumstances where you expressly consented to receiving any such material from third party partners);

  • ·  to allow for access to matches and other events; and
  • ·  to send you surveys or polls.

OW subcontractors, service providers, ticketing providers and third party partners.

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Regulatory Authorities, Law Enforcement Agencies, Public Bodies and Third Party Companies
  • ·  To comply with any applicable legal obligation, court order, summons, search warrants, or any other legal or regulatory obligation or request to which OW is subject;
  • ·  to protect the rights, property or safety of OW, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction; and
  • ·  to enforce or apply the Terms and other agreements or to investigate potential breaches.

1.2.5 Data Retention

In accordance with our policy on data retention we shall keep your Personal Data which we process on the basis of your involvement with OW for a period of time after your engagement with OW which depends on why you have interacted with us. Please contact [email protected] for further information about our retention periods.

Please note that in certain circumstances, we may hold your Personal Data for a longer period, for example, if we are processing an ongoing claim or believe in good faith that the law or a relevant regulator may reasonably in our view expect or require us to preserve your Personal Data.

1.2.6 Third Party Sources

We may obtain Personal Data about you from the following third parties:

Social Media Information

We may receive information about you from social media platforms, such as Facebook, Twitter, LinkedIn and Instagram, when you interact with us via such platforms. This includes information which you provide to us or otherwise make available via such platforms.

Marketing Information

We may receive information about you from other third parties where we offer co-branded services or engage in joint-marketing activities.

Ticket Sellers

When you buy match tickets we may be provided with your Personal Data.

Event Organisers

We will often engage the services of third parties to assist us

in running and operating events. When you attend or express an interest in such an event we will often be provided with your Personal Data.

We may receive your Personal Data from licensees of our brand such as retail outlets, sponsors and vendors where you opt-in to receive information from us.

Licensees of our Brand

Stadia and Match Venues

We may receive your Personal Data from stadiums and match venues when you attend matches.

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1.3 Processing your personal data when you use our Website

1.3.1 How we process your Personal Data when you use our Website

For information about how we collect your Personal Data when you visit our Website, please see our Cookie Policy.

1.3.2 What Personal Data we Process when you visit our Website

We may collect and process the following Personal Data about you when you use our Website:

  • ·  When using our Website and availing of services through our Website, we may collect Personal Data about you from you and by using cookies and web analytics technology. This includes information about:
  • ·  your device type, operating system, browser, IP address

Technical Information

  • We also collect information in the course of providing you with OW E-Bulletin and any marketing material you subscribe to, or consent to receiving, on the Website.

and other information derived from cookies used on the Website. Please see our Cookies Policy for further information on our use of cookies; and

  • ·details of your visits to the Website such as traffic data, location data and the resources, advertisements and linked websites that you access through the Website.

Customer Account Information

  • ·  This is information that you provide to us when creating a customer account and subsequently using it to make purchases. This information may include your name, date of birth, phone number, email address, billing address, shipping address, phone number and credit card information.
  • ·  If you choose to purchase an item on the Website shop for a third party beneficiary, you need to provide us with information about the beneficiary during the purchase process. In such circumstances, it is your responsibility to make sure the beneficiary or beneficiaries would have no objection to you sharing their Personal Data for the purposes set out in this Notice.

Payment Information

  • This includes your payment card details plus any other information necessary for billing purposes such as your billing address or your bank account information.

Subscription Information

  • Information you provide in the course of subscribing to OW E-Bulletin. This information may include your email address, your name, your age range and your address.

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1.3.3 Legal Basis

The following table details the legal bases under which (“Legal Basis”) and the reasons why (“Purposes”) we collect, obtain and process your Personal Data:

Purpose(s)
Legal Basis
Contract

It is necessary to process this Personal Data to enter into and perform our contract(s) with you.

This could be a contract for tickets or

Fulfilling your Orders and Requests

  • ·  To provide you with information and items that you request from us and to fulfil orders you place with us;
  • ·  to process your purchases;
  • ·  to process your payments through our third party payment providers;
  • ·  to process your purchase of tickets to matches;
  • ·  to enter you into competitions and contests;

and

  • ·  to prevent the fraudulent use of gift vouchers.

Customer Account

  • ·  To create your online customer account;
  • ·  to process your purchases through this

account; and

  • ·  to otherwise manage and administer your

customer account.

Payment

  • ·  To receive payment in exchange for the products, services and tickets you purchase from us;
  • ·  to refund you any sums that may be owed to you; and
  • ·  to resolve any issues that may arise if an order is lost, processed incorrectly or otherwise encounters difficulty.
products that you purchase from us, for access to our Website, for setting up a customer account or for becoming a member according to the applicable terms, etc.

If you do not wish to provide us with your Personal Data for these purposes, we will not be able to enter into or perform our contract(s) with you.

Legitimate Interests

It is in our legitimate interests to collect and process your Personal Data for a

Improving Website Functionality & Efficiency

· To provide, improve, test and monitor the effectiveness of the Website;

range of operational, business and organisational purposes. When we process your Personal Data based on our legitimate interests, we make sure to consider and balance any potential impact on you and your data protection rights. We will not process your Personal Data for activities where our interests are overridden by the impact on you.
  • ·  to monitor metrics such as total number of visitors, traffic data and demographic patterns;
  • ·  to personalise and improve your experience on our digital platforms; and
  • ·  to ensure the content on the Website is presented in the most effective manner for you and to enhance your use of the Website.

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1.3.4 Sharing and Disclosure of your Personal Data

We will disclose your Personal Data to other members of the OW community such as the Leinster Branch and the IRFU

We will only disclose your personal information to third parties outside the above organisations in the following circumstances:

Recipient(s)

Purpose(s)

OW subcontractors, service providers and third party partners

  • For logistical and IT service purposes.
  • To comply with any applicable legal obligation, court order, summons, search warrants, or any

Regulatory Authorities, Law Enforcement Agencies, Public Bodies

other legal or regulatory obligation or request to

which OW is subject;

  • ·  to protect the rights, property or safety of OW,

our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction; and

  • ·  to enforce or apply our website terms and other agreements or to investigate potential breaches.

and third party Companies

1.3.5 Data Retention

For information about how long we retain Personal Data collected when you visit our Website for, please see our Cookie Policy. In accordance with our policy on data retention we shall keep your Personal Data which we process on the basis of your involvement with OW for a period of time after your engagement with OW which depends on why you have interacted with us. Please contact [email protected] for further information about our retention periods.

Please note that in certain circumstances, we may hold your data for a longer period, for example, if we are processing an ongoing claim or believe in good faith that the law or a relevant regulator may reasonably in our view expect or require us to preserve your data.

  1. IF YOU ARE UNDER 16 OR A PARENT/LEGAL GUARDIAN

If you are under the age of 16, you should always speak to your parent or legal guardian before you send us an email or information, ask us to send you any information, subscribe to our Newsletter, purchase anything from us or provide us Personal Data in any other way. We will need the consent of your parent or legal guardian.

If you are a parent or legal guardian of a child whose Personal Data we are processing, then you may at any time request that we stop processing the Personal Data of your child in so far as we are able, or exercise the rights listed below at Section 4 over your child’s Personal Data by emailing us at [email protected] Please note that before we disclose or otherwise process a child’s Personal Data on the basis of such a request we may first request that you provide reasonable information about yourself and your child for identification purposes.

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  1. STORING OF AND TRANSFERS OF YOUR PERSONAL DATA

Your Personal Data may be stored and transferred inside or outside the European Economic Area (“EEA”). We only transfer your Personal Data outside the EEA where the EU Commission has decided that the third country in question ensures an adequate level of protection in line with EU data protection standards or if there are appropriate safeguards in place to protect your Personal Data. Where we transfer Personal Data to a third country, we may do so on the basis of Standard Contractual Clauses which are a form of data processing contract approved by the European Commission. You can find a copy of these clauses here.

If you would like to find out more about the appropriate safeguards that we have in place to govern the transfer of your Personal Data you can contact us at the club office.

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 any information you transmit to us; any transmission is at your own risk. Once we have received your information, we will endeavour to use strict procedures and security features to try to prevent unauthorised access.

  1. YOUR RIGHTS AND HOW TO EXERCISE THEM

This Section sets out the rights which you have to address any concerns or queries with us about our processing of your Personal Data.

Note that in certain circumstances, these rights may not be absolute:

Right Further Information
· You have the right to request a copy of the Personal Data held by us about you and to access the following information in relation to the processing of your Personal Data:

  1. 1)  the purposes of processing;
  2. 2)  the categories of Personal Data concerned;
  3. 3)  the recipients of your Personal Data;
  4. 4)  the period for which your Personal Data will be

stored;

  1. 5)  the existence of your right to lodge a complaint

with the Data Protection Commission; and

  1. 6)  the source of your Personal Data.
Right of Access
· We will only charge you for making an access request where we feel your request is unjustified or excessive.
· You have the right to request that we amend any inaccurate Personal Data that we have about you.
Right to Rectification

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Right to Erasure

  • You have the right to ask us to erase your Personal Data where:
  1. 1)  it is no longer necessary to perform our contract

with you;

  1. 2)  you withdraw your consent and there is no other

legal basis permitting us to process your

Personal Data;

  1. 3)  you object and we have no overriding legitimate

interest;

  1. 4)  your Personal Data has been unlawfully

processed; or

  1. 5)  it must be erased to comply with a legal

obligation.

  • Please note that erasure may not be complete or immediate to the extent that some of your Personal Data is necessary for the purpose for which it was collected.

Right to Restriction of Processing

  • ·  You have the right to ask us to restrict processing your Personal Data in the following situations:
    1. 1)  where you contest the accuracy of your Personal Data;
    2. 2)  where the processing is unlawful and you do not want us to delete your Personal Data;
    3. 3)  where we no longer need your Personal Data for the purposes of processing but you require the data in relation to a legal claim; or
    4. 4)  where you have objected to us processing your Personal Data pending verification as to whether or not our legitimate interests override your interests or in connection with legal proceedings.
  • ·  When you exercise this right we may only store your Personal Data and may not further process it unless you consent or the processing is necessary in relation to a legal claim or to protect the rights of another person or legal person or for reasons of important public interest.

Right to Data Portability

  • ·  You may request us to provide you with your Personal Data which you have given us in a structured, commonly used and machine-readable format and you may request us to transmit your Personal Data directly to another data controller where this is technically feasible.
  • ·  This right only arises where:

1) we process your Personal Data with your

consent or where it is necessary to perform our contract with you; and

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2) the processing is carried out by automated means.
Right to Object · You have a right to object at any time to our processing of your Personal Data where we process your Personal Data on the legal basis of pursuing our legitimate interests.

You can exercise any of these rights by submitting a request to our Data Protection Executive whose contact details are set out in Section 5 of this Notice.

We will provide you with information on any action taken upon your request in relation to any of these rights without undue delay and at the latest within one month of receiving your request. We may extend this timeframe by one more month if necessary having regard to the circumstances of the request. However, we will inform you if this arises.

  1. QUESTIONS AND COMPLAINTS

If you have any concerns about the way your Personal Data are being used or processed by OW, please contact [email protected]

If you have any concern in relation to how your Personal Data is used or processed, you have the right to lodge a complaint with the Data Protection Regulator. For further information and to find the data protection regulator, please see here.

  1. CHANGES TO THE NOTICE

If we amend this notice, in whole or part, at our sole discretion, any changes will be effective immediately upon communicating the revised notice to you.

If at any time we decide to use your Personal Data in a manner significantly different from that stated in this notice, or otherwise disclosed to you at the time it was collected, we will notify you and you will have a choice as to whether or not we use your information in the new manner.

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