Privacy Policy
1. Introduction
1.1 We are committed to safeguarding the privacy of PlayFitNow visitors and service users.
1.2 This policy applies where we act as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of processing that personal data.
1.3 We use cookies on our website. If these cookies are not strictly necessary for the provision of our website and services, we will ask for your consent to use them when you first visit our website.
1.4 Our website incorporates privacy controls that affect how we process your personal data. Using these privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information. You can access the privacy controls by emailing our data controller, Thomas Watson, at [email protected]
1.5 In this policy, “we”, “us”, and “our” refer to Saco Inc. For more information about us, see Section 13.
2. How We Use Your Personal Data
2.1 In this Section, we outline:
(a) the general categories of personal data that we may process;
(b) the purposes for which we may process personal data; and
(c) the legal bases for the processing.
2.2 We may process data about your use of our website and services (“usage data”). This may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views, website navigation paths, as well as information about the timing, frequency, and pattern of your service use. The source of the usage data is Google Analytics. This data may be processed to analyze the use of our website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
2.3 We may process your account data (“account data”). This may include your email address. The source of the account data is you. The account data may be processed for operating our website, providing our services, ensuring the security of our website and services, maintaining backups of our databases, and communicating with you. The legal basis for this processing is consent.
2.4 We may process your email address (“profile data”). This data may be processed for enabling and monitoring your use of our website and services. The legal basis for this processing is consent.
2.5 We may process information that you post for publication on our website or through our services (“publication data”). This data may be processed to enable such publication and administer our website and services. The legal basis for this processing is consent.
2.6 We may process information contained in any enquiry you submit regarding goods and/or services (“enquiry data”). This data may be processed for offering, marketing, and selling relevant goods and/or services to you. The legal basis for this processing is consent.
2.7 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“transaction data”). This data may include your contact details, card details, and transaction details. This data may be processed for supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract, as well as our legitimate interests, namely the proper administration of our website and business.
2.8 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”). This data may be processed for sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
2.9 We may process information contained in or relating to any communication that you send to us (“correspondence data”). This data may include the communication content and metadata associated with the communication. Our website will generate metadata associated with communications made using the website contact forms. This data may be processed for communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
2.10 We may process any of your personal data identified in this policy where necessary for the establishment, exercise, or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights, and the legal rights of others.
2.11 We may process any of your personal data identified in this policy where necessary for obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
2.12 In addition to the specific purposes for which we may process your personal data set out in this Section, we may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or to protect your vital interests or the vital interests of another natural person.
2.13 Please do not supply any other person’s personal data to us unless we prompt you to do so.
3. Providing Your Personal Data to Others
3.1 We may disclose your personal data to our insurers and/or professional advisers as reasonably necessary for obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise, or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3.2 Financial transactions relating to our website and services may be handled by our payment service providers. We will share transaction data with our payment service providers only to the extent necessary for processing your payments, refunding such payments, and dealing with complaints and queries related to such payments and refunds.
3.3 We may disclose your enquiry data to one or more of the selected third-party suppliers of goods and services identified on our website for the purpose of enabling them to contact you to offer, market, and sell relevant goods and/or services. Each such third party will act as a data controller concerning the enquiry data that we supply to it; and upon contacting you, each such third party will provide you with a copy of its own privacy policy, which will govern that third party’s use of your personal data.
3.4 In addition to the specific disclosures of personal data set out in this Section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4. International Transfers of Your Personal Data
4.1 In this Section, we provide information about the circumstances under which your personal data may be transferred to countries outside the European Economic Area (EEA).
4.2 The hosting facilities for our website are situated in the UK and USA. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries.
4.3 You acknowledge that personal data you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
5. Retaining and Deleting Personal Data
5.1 This Section sets out our data retention policies and procedures, which are designed to help ensure compliance with our legal obligations in relation to the retention and deletion of personal data.
5.2 Personal data that we process for any purpose or purposes shall not be kept longer than is necessary for that purpose or those purposes.
5.3 We will retain your personal data as follows:
(a) Email addresses will be retained for a minimum period of 1 year following the date of submission and for a maximum period of 20 years following May 25, 2018.
5.4 In some cases, it is not possible to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
(a) The period of retention of your email address will be determined based on best available practices.
5.5 Notwithstanding other provisions of this Section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject or to protect your vital interests or the vital interests of another natural person.
6. Amendments
6.1 We may update this policy from time to time by publishing a new version on our website.
6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
6.3 We may notify you of changes or significant changes to this policy by email or through the private messaging system on our website.
7. Your Rights
7.1 In this Section, we summarize the rights you have under data protection law. Some of the rights are complex, and not all details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from regulatory authorities for a full explanation of these rights.
7.2 Your principal rights under data protection law are:
(a) The right to access;
(b) The right to rectification;
(c) The right to erasure;
(d) The right to restrict processing;
(e) The right to object to processing;
(f) The right to data portability;
(g) The right to complain to a supervisory authority; and
(h) The right to withdraw consent.
7.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, along with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned, and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply you with a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access your personal data by requesting a copy from [email protected]
7.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
7.5 In some circumstances, you have the right to the erasure of your personal data without undue delay. These circumstances include: the personal data are no longer necessary for the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions to the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise, or defense of legal claims.
7.6 In some circumstances, you have the right to restrict the processing of your personal data. These circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise, or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise, or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
7.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms, or the processing is for the establishment, exercise, or defense of legal claims.
7.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
7.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
7.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used, and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
7.11 If you consider that our processing of your personal data infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work, or the place of the alleged infringement.
7.12 To the extent that the legal basis for our processing of your personal data is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
7.13 You may exercise any of your rights in relation to your personal data by written notice to us in addition to the other methods specified in this Section.
8. About Cookies
8.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
8.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session when the web browser is closed.
8.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
9. Cookies We Use
9.1 We use cookies for the following purposes:
(a) Authentication – we use cookies to identify you when you visit our website and as you navigate our website;
(b) Analysis – we use cookies to help us analyze the use and performance of our website and services;
(c) Cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally.
10. Cookies Used by Our Service Providers
10.1 Our service providers use cookies, and those cookies may be stored on your computer when you visit our website.
10.2 We use Google Analytics to analyze the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.
10.3 We may publish Google AdSense interest-based advertisements on our website. These are tailored by Google to reflect your interests. To determine your interests, Google will track your behavior on our website and on other websites across the web using cookies. This behavior tracking allows Google to tailor the advertisements that you see on other websites to reflect your interests (but we do not publish interest-based advertisements on our website). You can view, delete, or add interest categories associated with your browser by visiting: https://adssettings.google.com. You can also opt out of the AdSense partner network cookie using those settings or the Network Advertising Initiative’s multi-cookie opt-out mechanism at: http://optout.networkadvertising.org. However, these opt-out mechanisms themselves use cookies, and if you clear the cookies from your browser, your opt-out will not be maintained. To ensure that an opt-out is maintained for a particular browser, you may wish to consider using the Google browser plug-ins available at: https://support.google.com/ads/answer/7395996.
11. Managing Cookies
11.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser and version to version. You can obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
11.2 Blocking all cookies will negatively impact the usability of many websites.
11.3 If you block cookies, you will not be able to use all the features on our website.
12. Data Protection Officer
12.1 Our data protection officer’s contact details are:
Name Company: Saco Inc
Email: [email protected]
13. Contact Us
For any questions or concerns regarding this privacy policy, please contact us at [email protected]