Privacy Policy (App)

In this Policy, unless specified otherwise, words and phrases shall have the same meanings as specified in our Terms and Conditions which can be viewed here.

CAM Solutions Ltd. a company registered in Scotland under registration number SC405805 whose registered office is at 9-10 St Andrews Square, Edinburgh EH2 2AF understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of Customers and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. You will be required to read and accept this Privacy Policy when signing up for an Account. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

1. Definitions and Interpretation

“Account” means an account required to access and/or use Services;

“Cookie” means a small text file placed on your computer or device by Our Services when you visit certain parts of Our Services and/or when you use certain features of Our Services. Details of the Cookies used by Our Services are set out in section 12, below;

“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;

“Personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and

“We/Us/Our” means the said CAM Solutions Ltd. (as above).

2. Information About Us

2.1  Our VAT number is 124846215.

2.2  Our Data Protection Officer is Rūta Mankevičienė, and can be contacted by email at ruta@coach-logic.com, by telephone on 0131 718 3561 or by post at 9-10 St Andrews Square, Edinburgh EH2 2AF.

2.3  We are regulated by UK’s supervisory authority, the Information Commissioner’s Office.

3. What Does This Policy Cover?

This Privacy Policy applies only to our use of data gathered by Us in your use of the Services.

4. Your Rights

This Privacy Policy applies only to our use of data gathered by Us in your use of the Services.

4.1 As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:

  4.1.1 The right to be informed about Our collection and use of personal data;

  4.1.2 The right of access to the personal data We hold about you or your team members. (see section 11);

  4.1.3 The right to rectification if any personal data We hold about you or your team members is inaccurate or incomplete (please contact Us using the details in section 13);

  4.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you or your employees [or customers] (We only hold personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 13). Please note that deletion of certain personal data may prevent the Services from functioning;

  4.1.5 The right to restrict (i.e. prevent) the processing of personal data;

  4.1.6 The right to data portability (obtaining a copy of personal data to re-use with another service or organisation);

  4.1.7 The right to object to Us using personal data for particular purposes; and

  4.1.8 Rights with respect to automated decision making and profiling.

4.2 If you have any cause for complaint about Our use of personal data, please contact Us using the details provided in section 13 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office details of which can be found here https://ico.org.uk/

5. What Data Do We Collect?

We may collect some or all of the following personal and non-personal data:
5.1  name;
5.2  date of birth;
5.3  gender;
5.4  business/company name;
5.5  job title;
5.6  profession;
5.7  contact information such as email addresses and telephone numbers;
5.8  demographic information such as post code, preferences, and interests;
5.9  financial information such as credit / debit card numbers;
5.10  IP address;
5.11  web browser type and version;
5.12  operating system;
5.13  a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;
5.14  profile picture;
5.15  sport or sports played;
5.16  team history;
5.17  weight;
5.18  height;
5.19  equipment brands used;
5.20  clothing brands used;
5.21  sporting performance level.

6. How Do We Use Your Data?

6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.

6.2 Our use of personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of personal data (e.g. by subscribing to emails or for delivery of the Services), or because it is in Our legitimate interests. Specifically, We may use personal data for the following purposes:

  6.2.1 Providing and managing your Account;

  6.2.2 Providing and managing your access to the Services;

  6.2.3 Personalising and tailoring your experience in the Services;

  6.2.4 Supplying Our products and services to you (please note that We require your personal data in order to enter into a contract with you);

  6.2.5 Personalising and tailoring Our products and services for you;

  6.2.6 Replying to emails from you;

  6.2.7 Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by clicking unsubscribe link in Our emails, by managing My Account Settings Notification Preferences or contacting us by emailing info@coach-logic.com;

  6.2.8 Market research;

  6.2.9 Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience.

6.3 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email and/or telephone and/or text message and/or post with information, news and offers on Our products and/or services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.

6.4 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it; however this may adversely affect the delivery, use and function of the Services.

6.5 We do not keep personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):

  6.5.1 We only keep your data for as long as We need to in order to use it as described in section 6.2 and/or for as long as We have your permission to keep it. Your data will be deleted if we no longer need it in accordance with the terms of our Data Retention Policy.

  6.5.2 Our account holder data – continuous until such time your subscription is terminated and then will be held in archives for two years.

  6.5.3 Data of subscribers to our direct marketing will be kept within our email marketing database until you choose to Unsubscribe.

  6.5.4 Analytics data set to expire after 26 months.

  6.5.5 Data for financial purposes will be retained for the legal period of seven years.

7. How and Where Do We Store Your Data?

7.1 We only keep personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.

7.2 Some or all of your data may be stored or transferred outside of the EEA. You are deemed to accept and agree to this by using the App and submitting information to Us. If We do store or transfer data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the GDPR. Such steps may include, but not be limited to, the use of legally binding contractual terms between Us and any third parties We engage and the use of the EU-approved Model Contractual Arrangements or in the United States of America, Privacy Shield. Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data.

7.3 Steps We take to secure and protect your data include but not limited to:

  7.3.1 All the personal data you provide to Us over https://app.coach-logic.com is transferred and protected over a secure SSL connection;

  7.3.2 Password protected;

  7.3.3 Role based access and admin roles to prevent unauthorized access to personal data;

  7.3.4 Dual factor authentication;

  7.3.5 Regular back-ups;

  7.3.6 Data minimisation;

  7.3.7 Anonymisation;

  7.3.8 Pseudonymisation;

  7.3.9 Written agreements with third-party data processors;

  7.3.10 Dashboards and alerts to enhance system control and monitoring;

  7.3.11 Systems, devices and software are kept up to date.

7.4 Notwithstanding the security measures that We take, it is important to note that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the Internet.

8. Do We Share Your Data?

8.1 We may share your data with other companies in Our group for administrative and internal management. This includes Our subsidiaries and/or Our holding company and its subsidiaries.

8.2 We may sometimes contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.

8.3 We may compile statistics about the use of products and services including the Services including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you or your employees [or customers]. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.

8.4 The third-party data processors used by Us and listed below are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where We transfer any personal data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR:
  8.4.1 Active Campaign (US servers);
  8.4.2 Amazon Web Services (EU servers, unless chosen different servers by you for video storage, video clips, playlists);
  8.4.3 Microsoft Azure (EU servers, based in US);
  8.4.4 Zendesk (US, EU);
  8.4.5 Google Inc. (US servers).
  8.4.6 Xero (New Zealand);
  8.4.7 Stripe Inc. (US, EU).

8.5 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.

9. What Happens If Our Business Changes Hands?

9.1 We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Any personal data that you have provided will, where it is relevant to any part of Our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which it was originally collected by Us.

9.2 In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes. When contacted you will not be given the choice to have your data deleted or withheld from the new owner or controller.

10. How Can You Control Your Data?

10.1 When you submit personal data to us, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details and by managing your Account).

10.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

11. How Can You Access Your Data?

You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact Us for more details at ruta@coach-logic.com or using the contact details below in section 13.

11. Our Use and control of Cookies

12.1 Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our products and services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

12.2 By using Our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. Third party Cookies are used on Our Site for video embed services, analytics. For more details, please refer to section 6, above, and to section 12.6 below. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.

12.3 All Cookies used by and on Our Site are used in accordance with current Cookie Law.

12.4 Before Cookies are placed on your computer or device, you will be shown a Pop up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.

12.5 Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in section 12.6. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 12.10, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.

12.6 The following first party Cookies may be placed on your computer or device:

Name of CookiePurposeStrictly Necessary
.ASPXAUTHThe ASPXAUTH cookie is used to determine if a user is authenticated to the Coach Logic’s Web App.Yes
ARRAffinityUser to ensure subsequent requests from a user are routed back to the web site instance that the user initially connected to.Yes
ASP.NET_SessionIdUsed to identify the user’s session on the server.Yes
__stripe_midThese cookies are set and used by our payment gateway Stripe for handling payment transactions.Yes
__stripe_sidThese cookies are set and used by our payment gateway Stripe for handling payment transactions.Yes

and the following third-party Cookies may be placed on your computer or device:

Name of CookieProvidorPurpose
nsrStripeThese cookies are set and used by our payment gateway Stripe for handling payment transactions.
CONSENTYouTubeEnable users to view video.
PREFYouTubeGoogle "Preferences" Cookie.
VISITOR_INFO1_LIVEYouTubeYouTube Bandwidth Measurement.
YSCVimeoThis cookie is used when watching embedded YouTube videos.
_ceg.sVimeoWeb analytics that tracks how visitors interact with pages.
_ceg.uVimeoWeb analytics that tracks how visitors interact with pages.
_gaVimeoUsed to distinguish users for Google Analytics.
_gidVimeoUsed to distinguish users for Google Analytics.
_uetsidVimeoUsed to collect analytical information.
continuous_play_v3VimeoUsed to keep track of whether continuous play is on or not for a user.
vuidVimeoVimeo Analytics unique id.
playerVimeoUsed for Vimeo video player.
__gadsVimeoUsed by Google DoubleClick for Publishers to advertise on the site.
__qcaVimeoQuantcast cookie created to allow reporting and anonymous data collection.
__utmaVimeoGoogle Analytics cookie. It it used to calculate new and returning visitor statistics.
__utmzVimeoThis cookie identifies the source of traffic to the site - so Google Analytics can tell site owners where visitors came from when arriving on the site.

12.7 Our Site uses analytics services provided by Google Analytics, Microsoft Azure Application Insights. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how Our Site is used. This, in turn, enables Us to improve Our Site and the products and services offered through it. You do not have to allow Us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.

To opt-out of Google Analytics cookies visit:
https://tools.google.com/dlpage/gaoptout

12.8 The analytics service(s) used by Our Site use(s) Cookies to gather the required information.

12.9 The analytics service(s) used by Our Site use(s) the following Cookies:

Name of CookiefirstProviderPurpose
_gafirstGoogle AnalyticsThis cookie is used to distinguish unique users by assigning a randomly generated number as a client identifier.
_gidfirstGoogle AnalyticsUsed to distinguish users for Google Analytics.
ai_userfirstMicrosoft Azure Application InsightsThis is a unique user identifier cookie enabling counting of the number of users accessing the application over time for Application Insights.
ai_sessionfirstMicrosoft Azure Application InsightsThis is a unique user identifier cookie enabling counting of the number of users accessing the application over time for Application Insights.

12.10 You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third-party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device or follow these links to find out how to manage cookies on the most popular browsers:

Google Chrome

Mozilla Firefox

Microsoft Internet Explorer

Microsoft Edge

Apple Safari

Opera

12.11 You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.

12.12 It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

13. Contacting Us

If you have any questions about Our Site or this Privacy Policy, please contact Us by email at info@coach-logic.com, by telephone on 0131 718 3561, or by post at 9-10 St Andrews Square, Edinburgh EH2 2AF. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 11, above).

14. Changes to Our Privacy Policy

We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.

END OF POLICY

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