Privacy Policy

Overview – the key information you should be aware of

(A)               Who we are. We are Groop Limited, a web-based management platform which provides a range of online tools to assist clubs and societies.  If you need it, our company number is 07529352 and our registered office is: Head Office, Pye Corner, Devizes Road, Box, Wiltshire, SN13 8DY. Run A Club Limited is the controller of your personal information, and is responsible for your personal information.  All references in this policy to “Groop”, “our”, “us” or “we” refer to Run A Club Limited  All references in this policy to “our website”, refer to the website owned by Groop at www.groop.com.

(B)               Our values and what this policy is for. We value your privacy and want to be accountable and fair to you as well as transparent with you in the way that we collect and use your personal information.  We also want you to know your rights in relation to your information which you can find here.

In line with these values, this privacy policy tells you how your information is collected and used by us and shared with others, how we keep it safe and the rights you have to access and control its use. We have tried to make it easy for you to navigate so you can find the information that is most relevant to you and our relationship with you.

(C)               Who this policy applies to.  This policy applies to:

1.   Visitors to our website

2.   Customers

3.   Prospective customers (who we send marketing communications to)

4.   People who contact us with enquiries

5.   Our suppliers and employees of our suppliers

Depending on our relationship, we will collect and use your information in different ways.  Please click on the links above to find out the information that we collect about you and how we use this information.

(D)           What this policy contains: This privacy policy describes the following important topics relating to your information (you can click on the links to find out more):

1.   How we obtain your personal information

2.   What information we collect about you and how we use it

3.   Legal basis for using your personal information

4.   How and why we share your personal information with others

5.   How long we store your personal information

6.   Your rights

7.   Children

8.   Marketing

9.   Where we may transfer your personal information

10. Risks and how we keep your personal information secure

11. Links to other websites

12. Changes to this privacy policy

13. Further questions and how to make a complaint

(E)               You have rights to object. You may ask to us stop using your personal information for direct marketing and where we use of your personal information on the basis of our, or another person’s, legitimate interest.  You can find out more information in section 6 .

(F)               What you need to do and your confirmation to us. Please read this privacy policy carefully to understand how we handle your personal information. By engaging with us in the ways set out in this privacy policy, you confirm that you have read and understood the entirety of this privacy policy, as it applies to you.

The detail – the key information you should be aware of

 

1.           How we obtain your personal information

 

1.1           You may provide us with your personal information voluntarily.  However, we may also receive information about you from third parties such as marketing agencies, market research companies, our suppliers, contractors and consultants, group companies, business partners, public websites and public agencies, which we refer to as “third party sources” or “suppliers” throughout this policy.  We may also collect personal information from you using a variety of technologies that automatically and passively collect information when you use our websites (usage data).

1.2           You may give us personal information about yourself by registering for an account with us, using bulletin boards or forums on our website, or by contacting us by phone, email or other means. This includes, for example, where you provide your personal information to us in order to receive products, deliveries, information or services from us. If you are a supplier, you may also give us personal information about you when you are offering or providing services to us.

2.          What information we collect about you and how we use it

 

Please go to the section or sections below that best describes our relationship with you to find out the information that we collect about you and how we use this information.  We refer to this as “personal information” throughout this policy.

2.1           Visitors to our website

 

(a)            What personal information we collect about you

We, or third parties on our behalf, may collect and use any of the following information about you:

(i)              your name;

(ii)             your postal address;

(iii)            your email address;

(iv)           your telephone number;

(v)            information provided when you correspond with us;

(vi)           any updates to information provided to us;

(vii)          personal information we collect about you or that we obtain from our third party sources;

(viii)         the following information created and recorded automatically when you visit our website:

(A)            Technical information. This includes: the Internet protocol (IP) address used to connect your computer to the internet address or other unique identifier for the computer or other electronic device that you use to access our websites; the website address and country from which you access information; the files requested;, browser type and version; browser plug-in types and versions; operating system and platform.

(B)            Information about your visit and your behaviour on our website (for example, the pages that you click on).  This may include the website you visit before and after visiting our website (including date and time), time and length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, traffic data, location data, weblogs and other communication data and information provided when requesting further service or downloads; and

(b)            How we use your personal information

We will collect, use and store the personal information listed above for the following reasons:

(i) to allow you to access and use our websites and products;

(ii) to receive enquiries from you through our websites about our products and business;

(iii) to ensure that content from our websites is presented in the most effective manner for you and for your computer or other electronic device;

(iv) to understand how you access and use our websites;

(v) to understand the impact and reach of our website;

(vi) to understand you better and tailor our websites’ content and services to your needs and interests;

(vii) to allow you to take part in interactive features we may provide from time to time, including competitions;

(viii) to administer and improve our websites and products, to measure the efficiency of our systems; and

(ix) to undertake an analysis on the locations from which people access our webpages.

(c)            A word about cookies

(i)              Some pages on our websites use cookies, which are small files placed on your internet browser when you visit our websites. We use cookies in order to distinguish you from other users of our websites and services and improve your user experience by understanding and remembering key information that you have provided to us.

(ii)             Where we use cookies on our websites, you may block these at any time. To do so, you can activate the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of our websites or to use all the functionality provided through our websites.  In addition we may not be able to tailor the services as well as we would be able to if you had not blocked the cookies.

(iii)            For detailed information on the cookies we use and the purposes for which we use them, please refer to our cookie policy here.

3.            Customers

(a)            What personal information we may collect about you

We, or third parties on our behalf, may collect and use any of the following information about you:

(i)              your name;

(ii)             your postal address;

(iii)            your email address;

(iv)           your telephone number;

(v)            your age/date of birth;

(vi)           your gender;

(vii)          Your ethnicity;

(viii)         your emergency contact information and next of kin;

(ix)           information provided when you correspond with us;

(x)            any updates to information provided to us;

(xi)           information needed to provide the services to you (including information on joining forms, order details, order history and payment details);

(xii)          customer services information, customer relationship management and marketing information; and

(xiii)         information you provide to help us provide you with improved service, for example if we ask you to fill in a survey or questionnaire; and

(xiv)         Appropriate notes tags or labels that support the provision and services of our clubs and organisations.

(b)            How we use your personal information

We will collect, use and store the personal information listed above for the following reasons:

(i)              to deal with any enquiries or issues you have about our products and/ or services;

(ii)             to send you certain communications (including by email or post) about our products and services such as administrative messages (for example, setting out changes to our terms and conditions and keeping you informed about our fees and charges);

(iii)            to carry out statistical analysis and market research on people who may be interested in our products and/ or services; and

(iv)           if you have consented or, otherwise, it is in our legitimate interests for marketing purposes, to contact you (including by email or post) with information about our products and services which either you request, or which we feel will be of interest to you (including newsletters); and

(v)            if you are a sole trader or a non-limited liability partnership and if you have consented, to contact you by email with information about our products and services or the products and services of our suppliers which either you request, or which we feel will be of interest to you.

(vi)           Where a club is attached to one or more organisations or umbrella bodies these organisations/bodies may have access to club/group members’ and staff personal information for a variety of purposes. Groop advise that such organisations ensure they have the agreement of their clubs and groups. We provide access based on that agreement. Otherwise only aggregated and anonymised data will ever be provided by ourselves.

Please see sections 2.6 and 2.7 for more details about how we use your personal information.

(c)            Special categories of data. Some of the personal information that we collect about you or which you provide to us about you or your family members may be special categories of data. Special categories of data include information about physical and mental health, sexual orientation, racial or ethnic origin, political opinions, philosophical belief, trade union membership and biometric data.

(d)            Information we need to provide services to you.  We need certain types of personal information so that we can provide services to you and perform contractual and other legal obligations that we have to you. If you do not provide us with such personal information, or if you ask us to delete it, you may no longer be able to access the Groop platform.

3.2  Prospective customers to whom we send marketing communications

 

(a)            We, or third parties on our behalf, may collect and use any of the following information about you:

(i)         your name;

(ii)        your postal address;

(iii)        your email address;

(iv)       your telephone number; and

(v)        information about your preferences.

(b)       How we use your personal information

We will collect, use and store the personal information listed above, if you have consented or, otherwise, if it is in our legitimate interests, for marketing purposes, to contact you (including by email or by post) with information about our products and services which either you request, or which we feel will be of interest to you.

Please see sections 2.6 and 2.7 for more details about how we use your personal information.

(c)            Source of personal information. We may receive some of your personal information from third parties, such as marketing agencies.

3.3 People who contact us with enquiries or that we contact in relation to our services and/ or products

 

(a)            We, or third parties on our behalf, may collect and use any of the following information about you:

(i)         your name including your title;

(ii)        your postal address;

(iii)        your email address;

(iv)       your telephone number;

(v)        information provided when you correspond with us; and

(vi)       any updates to information provided to us.

(b)            How we use your personal information

We will collect, use and store the personal information listed above to deal with any enquiries or issues you have about our products and services, including any questions you may have about how we collect, store and use your personal information, or any requests made by you for a copy of the information we hold about you.  If we do not have a contract with you, we may process your personal information for these purposes where it is in our legitimate interests for customer services purposes, for the carrying on of our business or to meet our customer and future customer demand.

Please see sections 2.6 and 2.7 for more details about how we use your personal information.

3.4 Our suppliers and employees of our suppliers who work for us

 

(a)            We, or third parties on our behalf, may collect and use any of the following information about you:

(i)              your name;

(ii)             work contact information (phone number, postal address, mailing address, email address);

(iii)            your job title;

(iv)           your gender;

(v)            your date of birth;

(vi)           proof of identification and address;

(vii)          your emergency contact information;

(viii)         information provided when you correspond with us;

(ix)           details of compensation, expense claims and bank details;

(x)            any updates to information provided to us; and

(xi)           personal information we collect about you from third party sources such as LinkedIn; and

(b)            How we use your personal information

We will collect, use and store the personal information listed above for the following reasons:

(i)              to enable us to receive and manage products and/ or services from you (including supplier due diligence, payment and expense reporting and financial audits);

(ii)             to deal with enquiries from you;

(iii)            to contact your next of kin in an emergency; and

(iv)           for security vetting and criminal records checks (where applicable and allowed by law).

Please see sections 2.6 and 2.7 for more details about how we use your personal information.

(c)            Source of personal information.  We may receive some of your personal information from third party sources, such as your employer or your employer’s company website. We may also collect this personal information from publicly-available sources, such as LinkedIn.

(d)           Special categories of data. Some of the personal information that we collect about you or which you provide to us about you or your employees may be special categories of data. Special categories of data include information about your physical and mental health, sexual orientation, racial or ethnic origin, political opinions, philosophical belief, trade union membership and biometric data.

3.5           Whatever our relationship with you is, we may also collect, use and store your personal information for the following additional reasons:

(a)            to deal with any enquiries or issues you have about how we collect, store and use your personal information, or any requests made by you for a copy of the information we hold about you.  If we do not have a contract with you, we may process your personal information for these purposes where it is in our legitimate interests.

(b)            for internal corporate reporting, business administration, ensuring adequate insurance coverage for our business, ensuring the security of company facilities, research and development, and to identify and implement business efficiencies.  We may process your personal information for these purposes where it is in our legitimate interests to do so;

(c)            to comply with any procedures, laws and regulations which apply to us – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others to comply, as well as where we are legally required to do so; and

(d)            to establish, exercise or defend our legal rights – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others, as well as where we are legally required to do so.

3.6           Further processing

We will not use your personal information in any way that is incompatible with the purposes set out in this section 2.  Please contact us using the details in section 13, if you want further information on the analysis we will undertake to establish if a new use of your personal information is compatible with these purposes.

3.7           Aggregated and anonymous information

We may use your personal information and combine it with the personal information of others to identify trends and share or provide this trend information in an aggregated and anonymous form with third parties.  For example, we may use information about your browsing habits as part of an aggregated number to identify which are our most popular website pages.

4.1           We consider that the legal bases for using your personal information as set out in this privacy policy are as follows:

(a)            our use of your personal information is necessary to perform our obligations under any contract with you (for example, to sell and provide you with our products, to fulfil an order which you place with us, to comply with the terms of use of our website which you accept by browsing our website and/or to comply with our contract to provide services to or receive services from you or your employer); or

(b)            our use of your personal information is necessary for complying with our legal obligations (for example, for if you contact us requesting access to personal data we hold about you); or

(c)            where neither (a) nor (b) apply, use of your personal information is necessary for our legitimate interests or the legitimate interests of others (for example, to ensure the security of our website). Our legitimate interests are to:

(i)              run, grow and develop our business;

(ii)             operate our websites;

(iii)            select appropriately skilled and qualified suppliers;

(iv)           carry out marketing, market research and business development;

(v)            provide services and/ or products to our customers, make and receive payment and provide customer services;

(vi)           invest in and roll out new products to benefit the communities in which we operate;

(vii)          place, track and ensure fulfilment of orders with our suppliers; and

(viii)         for internal group administrative purposes.

(ix)

If we rely on our (or another person’s) legitimate interests for using your personal information, we will undertake a balancing test to ensure that our (or the other person’s) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the personal information.

4.2           We may process your personal information in some cases for marketing purposes on the basis of your consent or if you are a child under the age of 13, on the basis of your parent’s or guardian’s consent (which you may withdraw at any time after giving it, as described below).

4.3           If we rely on your consent for us to use your personal information in a particular way, but you later change your mind, you may withdraw your consent by contacting us at help@groop.com and we will stop doing so. However, if you withdraw your consent, this may impact the ability for us to be able to provide you access to the Groop platform and associated services to you.

5.          How and why we share your personal information with others

5.1           We will share your personal information with the following third parties or categories of third parties:

(a)            suppliers who provide information technology and office services, including software and website development, website hosting, management and evaluation, exchange and cross referencing;

(b)            local authorities or other organisations where you have been referred to Groop by that local authority or organisation;

(c)            organisations and governing bodies of which your club/group is a part and there is appropriate agreement made;

(d)           our other service providers and sub-contractors, including payment processors, utility providers, suppliers of technical and support services, insurers, logistic providers, and cloud service providers;

(e)            companies that assist us in our marketing, advertising and promotional activities, including partnerships and teaming efforts with other companies whose products or services we think you might enjoy; and

(f)             analytics and search engine providers that assist us in the improvement and optimisation of our website.

5.2           Any third parties with whom we share your personal information are limited (by law and by contract) in their ability to use your personal information for any purpose other than to provide services for us. We will always ensure that any third parties with whom we share your personal information are subject to privacy and security obligations consistent with this privacy policy and applicable laws.

5.3           We will also disclose your personal information to third parties:

(a)            where it is in our legitimate interests to do so to run, grow and develop our business:

(i)              if we sell or buy any business or assets, we may disclose your personal information to the prospective seller or buyer of such business or assets;

(ii)             if substantially all of Groop’s or any of our affiliates’ assets are acquired by a third party, in which case personal information held by us will be one of the transferred assets;

(b)            if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, any lawful request from government or law enforcement officials and as may be required to meet national security or law enforcement requirements or prevent illegal activity;

(c)            in order to enforce or apply our terms of use, our terms and conditions for customers or any other agreement or to respond to any claims, to protect our rights or the rights of a third party, to protect the safety of any person or to prevent any illegal activity; or

(d)            to protect the rights, property, or safety of Groop, our staff, our customers or other persons. This may include exchanging personal information with other organisations for the purposes of fraud protection.

5.4           We may also disclose and use anonymised, aggregated reporting and statistics about users of our website or our goods and services for the purpose of internal reporting or other third parties, and for our marketing and promotion purposes. None of these anonymised, aggregated reports or statistics will enable our users to be personally identified.

5.5           Save as expressly detailed above, we will never share, sell or rent any of your personal information to any third party without notifying you and, where necessary, obtaining your consent. If you have given your consent for us to use your personal information in a particular way, but later change your mind, you should contact us and we will stop doing so.

6.              How long we store your personal information

We keep your personal information for no longer than necessary for the purposes for which the personal information is processed. The length of time we retain personal information for depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.

7.              Your rights

7.1           You have certain rights in relation to your personal information. If you would like further information in relation to these or would like to exercise any of them, please contact us via email at help@groop.com at any time. You have the following rights:

(a)            Right of access.  You have a right of access to any personal information we hold about you.  You can ask us for a copy of your personal information; confirmation whether your personal information is being used by us; details about how and why it is being used; and details of what safeguards which are in place if we transfer your information outside of the United Kingdom.

(b)            Right to update your information.  You have a right to request an update to any of your personal information which is out of date or incorrect.

(c)            Right to delete your information.  You have a right to ask us to delete any personal information which we are holding about you in certain specific circumstances.  You can ask us for further information on these specific circumstances by contacting us using the details in section 13.

We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort.  You can ask us who the recipients are, using the contact details in section 13.

(d)            Right to restrict use of your information. You have a right to ask us to restrict the way that we process your personal information in certain specific circumstances.  You can ask us for further information on these specific circumstances by contacting us using the details in section 13.

We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort.  You can ask us who the recipients are using the contact details in section 13.

(e)            Right to stop marketing: You have a right to ask us to stop using your personal information for direct marketing purposes.  If you exercise this right, we will stop using your personal information for this purpose.

(f)             Right to data portability: You have a right to ask us to provide your personal information to a third party provider of services.

(g)            Right to object.  You have a right to ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our or another person’s legitimate interest.

7.2           We will consider all such requests and provide our response within a reasonable period (and in any event within one month of your request unless we tell you we are entitled to a longer period allowed by applicable law). Please note, however, that certain personal information may be exempt from such requests in certain circumstances, for example if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims.

7.3           If an exception applies, we will tell you this when responding to your request.  We may request you provide us with information necessary to confirm your identity before responding to any request you make.

8.              Children

8.1           We require the consent of a parent or guardian before a child under the age of 13 uses our website including any of our products and/ or services.

8.2           If you are under the age of 13 and we learn that we have inadvertently obtained personal information from you from our websites, or from any other source, without the consent of your parent or guardian then we will delete that information as soon as possible.

8.3           Please contact us at help@groop.com if you are aware that we may have inadvertently collected personal information from a child under the age of 13.

9.              Marketing

9.1           We may collect and use your personal information for undertaking marketing by email telephone and post.

9.2           We may send you certain marketing communications (including electronic marketing communications) if it is in our legitimate interests to do so for marketing and business development purposes or, if you are a sole trader or a non-limited liability partnership if you have consented to receive such electronic marketing information.

9.3           However, we will always obtain your consent to direct marketing communications where we are required to do so by law and if we intend to disclose your personal information to any third party for such marketing.

9.4           If you wish to stop receiving marketing communications, you can contact us by email at info@groop.com.

10.           Where we may transfer your personal information

10.1          We do not envisage transferring your personal information outside of the EEA. However, if in the future we provide any personal information about you to non-EEA suppliers, we will take appropriate measures to ensure that the recipient protects your personal information adequately in accordance with this privacy policy.

11.           Risks and how we keep your personal information secure

11.1         The main risk of our processing of your personal information is if it is lost, stolen or misused.  This could lead to your personal information being in the hands of someone else who may use it fraudulently or make public, information that you would prefer to keep private.

11.2         For this reason, Groop is committed to protecting your personal information from loss, theft and misuse.  We take all reasonable precautions to safeguard the confidentiality of your personal information, including through use of appropriate organisational and technical measures. For example, our servers are hosted in the UK by UKCloud who meet all current security legislation and guidelines.

11.3         In the course of provision of your personal information to us, your personal information may be transferred over the internet.  Although we make every effort to protect the personal information which you provide to us, the transmission of information over the internet is not completely secure. As such, you acknowledge and accept that we cannot guarantee the security of your personal information transmitted to our website and that any such transmission is at your own risk. Once we have received your personal information, we will use strict procedures and security features to prevent unauthorised access to it.

11.4         Where we have given you (or where you have chosen) a password which enables you to access your online account, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Our website may contain hyperlinks to websites that are not operated by us. These hyperlinks are provided for your reference and convenience only and do not imply any endorsement of the activities of such third-party websites or any association with their operators. This privacy policy only applies to the personal information that we collect or which we receive from third party sources, and we cannot be responsible for personal information about you that is collected and stored by third parties. Third party websites have their own terms and conditions and privacy policies, and you should read these carefully before you submit any personal information to these websites. We do not endorse or otherwise accept any responsibility or liability for the content of such third party websites or third party terms and conditions or policies.

13.           Changes to our privacy policy

We may update our privacy policy from time to time. Any changes we make to our privacy policy in the future will be posted on this page and we may notify you of the change by post or email. Please check back frequently to see any updates or changes to our privacy policy.

14.           Further questions and how to make a complaint

14.1         If you have any queries or complaints about our collection, use or storage of your personal information, or if you wish to exercise any of your rights in relation to your personal information, please contact help@groop.com. We will investigate and attempt to resolve any such complaint or dispute regarding the use or disclosure of your personal information.

14.2         You may also make a complaint to the Information Commissioner’s Office, or the data protection regulator in the country where you usually live or work, or where an alleged infringement of the General Data Protection Regulation has taken place.  Alternatively, you may seek a remedy through the courts if you believe your rights have been breached.  Please talk to us first though so we can do what we can to alleviate any concerns you have.

The practices described in this privacy policy statement are current as of 24th January 2019.