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PRIVACY AND COOKIE POLICY

 (Last updated: February 20, 2020)

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This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

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We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

 

A. INTERPRETATION AND DEFINITIONS

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions.

The following definitions shall have the same meaning regardless of whether they appear in singular or in plural. 

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Definitions:

For the purposes of this Privacy Policy:

• You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.​ Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as you are the individual using the Service.

• Company (referred to as either "the Company", “RUGBY VAULT”, "We", "Us" or "Our" in this Agreement) refers to RUGBY VAULT UK Ltd. S. Yorkshire. For the purpose of the GDPR, the Company is the Data Controller.

• Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.

• Account means a unique account created for You to access our Service or parts of our Service.

• Websites refers to RUGBYVAULT, accessible from https://www.rugbyvault.com/ and Coaching Tools – RugbyVault, accessible from https://rugby.sportvaults.com/signup

• Service refers to the Websites.

• Country refers to: United Kingdom

• Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. *For the purpose of the GDPR, Service Providers are considered Data Processors.

• Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.

• Personal Data is any information that relates to an identified or identifiable individual.

*For the purposes for GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.

*For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.

• Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

• Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.

• Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.

• Business, for the purpose of the CCPA (California Consumer Privacy Act), refers to the Company as the legal entity that collects Consumers' personal information and determines the purposes and means of the processing of Consumers' personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' personal information, that does business in the State of California.

• Consumer, for the purpose of the CCPA (California Consumer Privacy Act), means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.

• Sale, for the purpose of the CCPA (California Consumer Privacy Act), means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer’s Personal information to another business or a third party for monetary or other valuable consideration.

 

B. COLLECTING AND USING YOUR PERSONAL DATA

Types of Data Collected

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Personal Data

We ask you for certain personal data to provide you with the products or services you request. For example, when you make purchases, contact our consumer services, request to receive communications, create an account, or use our Sites or Apps.

 

This personal data includes your:

• contact details including name, email, telephone number and shipping, billing address;

• login and account information, including screen name, password and unique user ID;

• personal details including gender, hometown, date of birth and purchase history;

• payment or credit card information;

• images, photos;

• data on physical characteristics, including weight, height, and body measurements;

• fitness activity data provided by you or generated through our Sites or Apps (time, duration, distance, location, calorie count, hydration, sleep); or

• personal preferences as well as marketing and cookie preferences.

 

We collect additional personal data from you to enable particular features within our Sites and Apps.  For example, we may request access to your contacts to allow you to interact with your friends, your calendar to schedule a training plan or your social network credentials to post content from an App to a social network.  This personal data includes your:

 

• photos, audio, contacts and calendar information; or

• social network information, including credentials and any information from your public posts about RUGBYVAULT or your communications with us.

• When interacting with our Sites and Apps, certain data is automatically collected from your device or web browser. More information about these practices is included in the “Cookies and Pixel Tags” section of this privacy policy below.  This data includes:

• Device IDs, call state, network access, storage information and battery information; and

• Cookies, IP addresses, referrer headers, data identifying your web browser and version, and web beacons and tags.

 

Usage Data

Usage Data is collected automatically when using the Service.

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Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

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When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

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We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

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Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service.

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You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service.

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Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close your web browser.

We use both session and persistent Cookies for the purposes set out below:

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• Necessary / Essential Cookies

Type: Session Cookies

Administered by: Us

Purpose: These Cookies are essential to provide You with services available through the Websites and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

• Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies identify if users have accepted the use of cookies on the Websites.

• Functionality Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies allow us to remember choices You make when You use the Websites, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Websites.

• Tracking and Performance Cookies

Type: Persistent Cookies

Administered by: Third Parties

Purpose: These Cookies are used to track information about traffic to the Websites and how users use the Websites. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Websites. We may also use these Cookies to test new advertisements, pages, features or new functionality of the Websites to see how our users react to them.

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Use of Your Personal Data

The Company may use Personal Data for the following purposes:

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To Provide the Features of the Sites, Apps, and Services You Request

When you use our Sites and Apps, we will use your personal data to provide the requested product or service.  For example, if you make a purchase on RUGBYVAULT.com or participate in anyway, we will use the contact information you give us to communicate with you about the purchase or participation. If you contact our customer services, we will use information about you, such as payment information, or the product you have purchased to help you resolve a problem or question.

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If you use our Apps to track your fitness activity or physical characteristics, we will collect this personal data and store it so that you can review it in the App.  Your fitness activity data may include data you enter about your activity or data collected by your device during your activity such as location data, and participation data.  We may use this activity data to calculate further information about your activity, such as distance run, or calories burned, so that the calculated information can be provided to you as part of the functionality of the App.

In many cases, to use particular features within our Sites and Apps you may need to provide RUGBYVAULT with additional data or additional consent to use particular data in a certain way.  For example, to share content on social media, you may be required to provide your social media account credentials to sign in.

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To Communicate Information about our Products, Services, Events and for Other Promotional Purposes

When you consent, we will send you marketing communications and news concerning RUGBYVAULT products, services, events and other promotions.  You can opt-out at any time after you have given your consent.

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If you are an existing customer of RUGBYVAULT (for example, if you have created an account with us), we may use the contact details you provided to send you marketing communications about similar RUGBYVAULT products or services where permitted by applicable law (unless you have opted-out). In other cases, we ask for your consent to send you marketing information. We may use the information that you provide to us as well as information from other RUGBYVAULT products or services - such as your use of RUGBYVAULT Sites and Apps, your visits to RUGBYVAULT, your participation in RUGBYVAULT to personalize communications on products and services that may be interesting for you.

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To Operate, Improve and Maintain our Business, Products and Services

We use the personal data you provide to us to operate our business.  For example, when you make a purchase, we use that information for accounting, audits and other internal functions.  We may use personal data about how you use our products and services to enhance your user experience and to help us diagnose technical and service problems and administer our Sites and Apps.

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To Protect Our or Others' Rights, Property or Safety

We may also use your personal data about how you use our Sites and Apps to prevent or detect fraud, abuse, illegal use, violations of our Terms of Use, and to comply with court orders, governmental requests or applicable law.

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For General Research and Analysis Purposes

We use data about how our visitors use our Sites, Apps and services to understand customer behaviour or preferences.  For example, we may use information about how visitors to RUGBYVAULT.com search for and find products to better understand the best ways to organize and present product offerings in our storefront.  

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Use (Processing) of Fitness Plan & Profile Info

As discussed above, RUGBYVAULT collects data about your fitness activity or your physical characteristics, together, “Profile & Fitness Plan Info”, to provide our Apps and other services.  Because of the personal nature of this data, we strive to provide you with clear information about how Profile & Fitness Plan Info will be used.  As this data may be considered sensitive in certain jurisdictions, we take appropriate measures in protecting and using this data

RUGBYVAULT uses the term “Profile & Fitness Plan Info” to refer to information generated by our Apps about your fitness activity combined with measurements of your physical characteristics.  Examples of data include the weights, reps, sleep results of your Daily Fitness plan.  Fitness Plan Info can also include measurements that are calculated from the data recorded while you do a fitness plan, for example, distance run, pace, and estimated calories burned.  Height, weight, and resting heart rate are examples of Fitness Plan Info that are precise measurements of your physical characteristics rather than your fitness activity.

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Because of the personal nature of this data, we strive to provide you with clear information about how Fitness Plan Info will be used. As this data may be considered sensitive in certain jurisdictions, we take appropriate measures in protecting and using this data and, where required by applicable law or under RUGBYVAULT internal policies, obtain your consent for use.

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How does RUGBYVAULT use Profile & Fitness Plan Info?

RUGBYVAULT collects Fitness Plan Info from you so that we can help you achieve your fitness goals while using our fitness apps, participating in events and with your social network and club affiliations, and when we provide you with products or services. 

 

Enabling Core Features of the Apps and Experiences

Our apps and experiences require that you permit RUGBYVAULT to process your Profile & Fitness Plan Info so that you can use the core features.  For example apps and experiences require height and weight to enable core features, such as calculating distance or calories. 

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RUGBYVAULT also maintains systems that store aggregated Fitness Plan Info from you and others so that we can deliver the apps and services to you and provide internal reports on metrics such as use and popularity. If you do not consent to the necessary processing, you will not be able to use the experience. 

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Enabling Personalization and Analysis Based on Profile & Fitness Plan Info

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RUGBYVAULT may analyse your Fitness Plan Info to provide custom training plans that change as you progress over time.  By analysing your recent and historic fitness plans, we can recommend the best program for your current activity level and goals. We will also compare your activity to millions of other athletes’ activity so that we can continuously improve our programs and deliver the best recommendations to you.

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If you allow RUGBYVAULT to use your Fitness Plan Info for these personalization purposes, your Fitness Plan Info will also be included from any aggregate information shared with others through the app. So, for example your overall fitness or participation will be included in the aggregate totals for all users of the RUGBYVAULT or your Fitness Plan Info would be included in any aggregate performance benchmarks (including those based on user segments) shown in the app or experience. 

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Other Purposes

We may also use your personal data in other ways and will provide specific notice at the time of collection and obtain your consent where necessary.

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Legal Grounds

To process your personal data, we rely on certain legal grounds, depending on how you interact with our Sites and Apps.

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When you purchase RUGBYVAULT products from our Sites and Apps, we need your personal data to fulfill our contract with you. For example, we need your payment and contact details to deliver your order.

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When you use our Apps, we rely on your consent for processing and for certain limited purposes to fulfill our contract with you (for example, for in-App purchases). 

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We also rely on other legal grounds, such as our legitimate interests as a business, to comply with a legal obligation, or to protect your vital interests.

We may share your personal information in the following situations:

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• With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to show advertisements to You to help support and maintain Our Service, to contact You, to advertise on third party websites to You after You visited our Service or for payment processing.

• For Business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company.​

• With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.

• With Business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.​

• With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile.

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Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

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Your personal information will be retained for as long as is necessary to carry out the purposes set out in this privacy policy (unless a longer retention period is required by applicable law). In general, this means that we will keep your personal data for as long as you keep your RUGBY VAULT account. For personal data related to product purchases, we retain this longer to comply with legal obligations (such as tax and sales laws and for warranty purposes).

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The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

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Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

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Disclosure of Your Personal Data

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Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

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Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

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Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation

• Protect and defend the rights or property of the Company

• Prevent or investigate possible wrongdoing in connection with the Service

• Protect the personal safety of Users of the Service or the public

• Protect against legal liability

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Encryption & Security of Your Personal Data

The security of Your Personal Data is important to Us. We use a variety of technical and organizational security measures, including encryption and authentication tools, to maintain the safety of your personal data but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

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C. DETAILED INFORMATION ON THE PROCESSING OF YOUR PERSONAL DATA

Service Providers have access to Your Personal Data only to perform their tasks on Our behalf and are obligated not to disclose or use it for any other purpose.

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Analytics

We may use third-party Service providers to monitor and analyze the use of our Service.

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Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network.

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To provide website visitors the ability to prevent their data from being used by Google Analytics, you can opt out by downloading and installing the add-on for your web browser. The Google Analytics opt-out add-on is designed to be compatible with Chrome, Internet Explorer 11, Safari, Firefox and Opera. In order to function, the opt-out add-on must be able to load and execute properly on your browser. For Internet Explorer, 3rd-party cookies must be enabled. Learn more about the opt-out and how to properly install the browser add-on here.

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Using the Google Analytics opt-out browser add-on will not prevent site owners from using other tools to measure site analytics. It does not prevent data from being sent to the websites themselves or in other ways to web analytics services.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

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Email Marketing

We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us at mail@rugbyvault.com

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We may use Email Marketing Service Providers to manage and send emails to You.

• Mailchimp is an email marketing sending service provided by The Rocket Science Group LLC.

For more information on the privacy practices of Mailchimp, please visit their Privacy policy: https://mailchimp.com/legal/privacy/

• Constant Contact

Constant Contact is an email marketing sending service provided by Constant Contact, Inc.

For more information on the privacy practices of Constant Contact, please visit their Privacy policy: https://endurance.clarip.com/privacycenter/?brand=ctct

 

Behavioral Remarketing

The Company uses remarketing services to advertise on third party websites to You after You visited our Service. We and Our third-party vendors use cookies to inform, optimize and serve ads based on Your past visits to our Service.

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• Twitter remarketing service is provided by Twitter Inc.

        You can opt-out from Twitter's interest-based ads by following their instructions:

        https://help.twitter.com/en/safety-and-security/privacy-controls-for-tailored-ads

        You can learn more about the privacy practices and policies of Twitter by visiting their Privacy Policy page: https://twitter.com/en/privacy​

• Facebook remarketing service is provided by Facebook Inc.

You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950

To opt-out from Facebook's interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217

Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA https://optout.aboutads.info/?c=2&lang=EN, the Digital Advertising Alliance of Canada in Canada https://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe https://www.youronlinechoices.com/, or opt-out using your mobile device settings.

 

For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation

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For a comprehensive and up-to-date summary of every third-party accessing your web browser (through RUGBY VAULT Sites or otherwise), we recommend installing a web browser plugin built for this purpose.  You can also choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings on each browser and device that you use. Each browser is a little different, so look at your browser Help menu to learn the correct way to modify your cookies. If you turn cookies off, you may not have access to many features that make our Sites and Apps more efficient and some of our services will not function properly.

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Payments

We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g. payment processors).

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We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

Stripe - Privacy Policy can be viewed at https://stripe.com/privacy

 

D. HOW CAN YOU OPT-OUT, REMOVE OR MODIFY INFORMATION YOU HAVE PROVIDED TO US?

To modify your subscription, please modify your preferences in the My Account Section.  Please note you may receive any emails already in process.  To delete all of your online account information from our database please delete/remove all of your billing, shipping and payment information from your account. Kindly note that we may maintain information about an individual sales transaction in order to service that transaction and for record keeping.

 

E. CHILDREN'S PRIVACY

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

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We also may limit how We collect, use, and store some of the information of Users between 13 and 18 years old. In some cases, this means We will be unable to provide certain functionality of the Service to these users.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

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F. GDPR PRIVACY Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

• Consent: You have given Your consent for processing Personal Data for one or more specific purposes.

• Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.

• Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.

• Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.

• Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.

• Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

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In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

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Your Rights under the GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are within the EU, to:

• Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.

• Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.

• Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your situation which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.

• Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.

• Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.

• Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.

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Exercising of Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

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G. CCPA PRIVACY

Your Rights under the CCPA

Under this Privacy Policy, and by law if You are a resident of California, You have the following rights:

• The right to notice. You must be properly notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.

• The right to access / the right to request. The CCPA permits You to request and obtain from the Company information regarding the disclosure of Your Personal Data that has been collected in the past 12 months by the Company or its subsidiaries to a third-party for the third party’s direct marketing purposes.

• The right to say no to the sale of Personal Data. You also have the right to ask the Company not to sell Your Personal Data to third parties. You can submit such a request by emailing your request to mail@rugbyvault.com

• The right to know about Your Personal Data. You have the right to request and obtain from the Company information regarding the disclosure of the following:

• The categories of Personal Data collected

• The sources from which the Personal Data was collected

• The business or commercial purpose for collecting or selling the Personal Data

• Categories of third parties with whom We share Personal Data

• The specific pieces of Personal Data we collected about You

• The right to delete Personal Data. You also have the right to request the deletion of Your Personal Data that have been collected in the past 12 months.

• The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your Consumer's rights, including by:

• Denying goods or services to You

• Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties

• Providing a different level or quality of goods or services to You

• Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services.

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Exercising Your CCPA Data Protection Rights

In order to exercise any of Your rights under the CCPA, and if you are a California resident, You can email or call us or visit our "Do Not Sell My Personal Information" section or web page.

The Company will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonable necessary and with prior notice.

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Do Not Sell My Personal Information

We do not sell personal information. However, the Service Providers we partner with (for example, our advertising partners) may use technology on the Service that "sells" personal information as defined by the CCPA law.

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If you wish to opt out of the use of your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by following the instructions below.

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Please note that any opt out is specific to the browser You use. You may need to opt out on every browser that you use.

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Websites

You can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Service:

• From Our "Cookie Consent" notice banner

• Or from Our "CCPA Opt-out" notice banner

• Or from Our "Do Not Sell My Personal Information" notice banner

• Or from Our "Do Not Sell My Personal Information" link

The opt out will place a cookie on Your computer that is unique to the browser You use to opt out. If you change browsers or delete the cookies saved by your browser, you will need to opt out again.

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Mobile Devices

Your mobile device may give you the ability to opt out of the use of information about the apps you use in order to serve you ads that are targeted to your interests:

• "Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on Android devices

• "Limit Ad Tracking" on iOS devices

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You can also stop the collection of location information from Your mobile device by changing the preferences on your mobile device.

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H. "DO NOT TRACK" POLICY (AS REQUIRED BY CALIFORNIA ONLINE PRIVACY PROTECTION ACT (CALOPPA))

Our Service does not respond to Do Not Track signals.

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However, some third-party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.

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I. YOUR CALIFORNIA PRIVACY RIGHTS  (CALIFORNIA BUSINESS AND PROFESSIONS CODE SECTION 22581)

California Business and Professions Code section 22581 allow California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.

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To request removal of such data, and if you are a California resident, You can contact Us using the contact information provided below, and include the email address associated with Your account.

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Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

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J. LINKS TO OTHER WEBSITES

Our Service may contain links to other websites that are not operated by Us. If You click on a third-party link, you will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

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We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

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K. CHANGES TO THIS PRIVACY POLICY

Applicable law and our practices change over time. If we decide to update our privacy policy, we will post the changes on our Sites and Apps. If we materially change the way in which we process your personal data, we will provide you with prior notice, or where legally required, request your consent prior to implementing such changes. We strongly encourage you to read our privacy policy and keep yourself informed of our practices.  This privacy policy was last modified in 2019.

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You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

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L. QUESTIONS AND FEEDBACK

We welcome questions, comments, and concerns about our privacy policy and privacy practices.

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If you wish to provide feedback or if you have questions or concerns or wish to exercise your rights related to your personal data, please contact mail@rugbyvault.com

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Our Data Protection Officer's contact details are: Privacy, RUGBY VAULT UK Ltd., 30 Moorfield Drive, Armthorpe Doncaster DN3 3LL. United Kingdom,

If you contact us with a privacy complaint it will be assessed with the aim of resolving the issue in a timely and effective manner. By email: mail@rugbyvault.com.

 

You also have the right to lodge a complaint with the relevant supervisory authority in the country in which you reside.