Best Coast Pairings LLC

Privacy Policy

Date Privacy Policy Last Modified: May 25, 2018

Effective: May 25, 2018

INTRODUCTION

Best Coast Pairings LLC (“Company” or “We”) respects your privacy and are committed to protecting your personal data through our compliance with this Privacy Policy.  

This Policy will inform you as to how we look after your personal data, your privacy rights, how the law protects you, and our practices for collecting, using, maintaining, protecting and disclosing your personal data when you visit our website BestCoastPairings.com (our “Website”) or use any of the Company’s services (including, without limitation, any desktop or mobile applications, products or other services) (collectively, the Website and services are referred to as the “Services”)

This Policy is provided in a layered format so you can click through the specific areas set out below.  Alternatively, you can view a full version of the Privacy Policy.  Please also refer to the Definitions section to understand the meaning of some of the terms used in this Policy.

Please read this Policy carefully to understand our policies and practices regarding your personal data and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Services because we will not be able to perform the contract we have or are trying to enter with you (for example, to provide you with services).  

By accessing or using our Services, you agree to this Privacy Policy, and if you are under age 16, you have your parent or legal guardian’s permission to use our Services and your parent/legal guardian has agreed to this Privacy Policy.

1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. CHILDREN AND PRIVACY
7. INTERNATIONAL TRANSFERS
8. DATA SECURITY
9. DATA RETENTION
10. YOUR LEGAL RIGHTS
11. DEFINITIONS
12. CONTACT INFORMATION

1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY NOTICE

This Privacy Policy aims to give you information on how Best Coast Pairings LLC collects and processes your personal data through your use of the Services, including any data you may provide through the Services when you purchase a subscription or participate in an Event.

CONTROLLER

For purposes of the European Union’s (“EU”) General Data Protection Regulation 2016/679 (“GDPR”), Best Coast Pairings LLC (the “Company”) is the controller and responsible for this Website.  In some instances the Company may act as a processor on behalf of another controller, for example, when the Company’s Services are used to power the ranking system of another company (e.g., Frontline, etc.).  

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this Policy and the GDPR.  If you have any questions about this Policy, including any requests to exercise your legal rights, please contact the Company’s data privacy manager using the details set out below.

Best Coast Pairings LLC

Garrett Mulroney

support@bestcoastpairings.com

Individuals located in the EU have the right to make a complaint at any time to ___supervisory authority___, the [EU Country] supervisory authority for data protection issues.  We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Website home page, banner within the mobile application, or by sending an email to the email address you provided to us.

You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting our Services and this privacy policy to check for any changes.

The date the privacy policy was last revised is identified at the top of this page.  Historic versions are available by emailing support@bestocoastpairings.com and requesting copies..

The data protection law will change with respect to individuals in the EU on May 25, 2018.  Although this Policy sets out most of your rights under the new laws, we may not be able to respond to some of your requests (for example, a request for the transfer of your personal data) until May 2018 as we are still working towards getting our systems ready for some of these changes.

It is important that the personal information, and importantly, the contact information we hold about you is accurate and current.  Please keep us informed if your personal data changes during your relationship with us.

THIRD PARTY LINKS

The Services may include links (and advertisements) to third-party websites, plug-ins, and applications.  Clicking on those links or enabling those connections may allow third parties to collect or share data about you.  We do not control these third party websites and are not responsible for their privacy statements/notices.  When you leave our Services (including the Website), we encourage you to read the privacy notice of every website you visit and application you use.

2. THE DATA WE COLLECT ABOUT YOU

“Personal Data” (or personal information) means any information about an individual from which that person can be identified.  It does not include data where the person’s identity has been removed.

This Policy applies to Personal Data we collect:

• On this Website;
• In e-mail, text and other electronic messages between you and this Website;
• Through the Company’s mobile and/or desktop applications you download from this Website, through the Company’s mobile and/or desktop applications that are available for download from other third-party sources, or through such applications made available for your use through an authorized third party (e.g., a tournament) which provide dedicated non-browser-based interaction between you and the Company and/or this Website; and
• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

We collect several types of Personal Data from and about users of our Services, including the following:

1. Identity Data includes: first name and last name

1. Contact Data includes: email address.
2. Technical Data includes: internet protocol (IP) addresses, your login data, your internet connection, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and information about the equipment (computer or mobile device) you use to access our Services.
3. Transaction Data includes details about transactions with you and other details of Services you have purchased from us.
4. Profile Data includes: event scores (including by round) and rankings, army lists, and table assignments.
5. Usage Data includes: information about how you use our Services.
6. Marketing and Communications Data includes: your preferences in receiving marketing from us and any third parties, and your communication preferences.

We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose.  Aggregated Data may be derived from your Personal Data but is not considered Personal Data because this data does not directly or indirectly reveal your identity.  For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Service.  However, if we combine or connect Aggregated Data with your information so that it can directly or indirectly identify you, we will treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.

We also use a third party payment processor, Stripe, Inc., to handle all payment processing transaction data, and we, therefore, do not have access to any Financial Data, such as details about payments, billing addresses, or debit/credit card information.

We do collect Technical Data includes: internet protocol (IP) address, your login data, browser type and version, time zone settings and location, browser plug-in types and versions, traffic data, logs and other communication data and the resources that you access and use on the Services, operating system and platform, and other technology on the devices you use to access our Services. As you navigate through and interact with our Services, we may use automatic data collection technologies to collect certain Technical Data about your equipment, browsing actions and patterns.  We do not use automated technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).

We do not maintain or associate the Technical Data we collect with your Personal Data.  The Technical Data helps us to improve our Services and to deliver a better and more personalized service, including by enabling us to:

1. Estimate our audience size and usage patterns.

1. Store information about your preferences, allowing us to customize our Services according to your individual interests.

1. Speed up your searches.

1. Recognize you when you return to our Services.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, or genetic and biometric data).  Nor do we collect any information about criminal convictions or offenses.

3. HOW IS YOUR PERSONAL DATA COLLECTED

We use different methods to collect this information from you and about you including:

1. Direct interactions.  You may give us your Personal Data by filling in forms or by corresponding with us by mail, phone, email or otherwise.  This includes Personal Data you provide when  you:
2. Register and use our Services (such as entering event scores, Army Lists, etc.)
3. Create an account on our Website or Services;
4. Subscribe to our Services;
5. Request marketing be sent to you; or
6. Give us some feedback or report a problem with our Services.

1. Automated technologies or interactions.  As you interact with our Website and/or Services, we may automatically collect Technical Data about your equipment, browsing actions and patters as you navigate through the Services. Information collected automatically may include usage details, IP addresses and information collected through cookies.

1. Third parties or publicly available sources.  We may receive Personal Data about you from various third parties and public sources as set out below:
2. Technical Data from the following parties:
3. Analytics providers (such as, Google, based outside the EU);
4. Advertising networks, such as NAME based inside or outside the EU; and
5. Search information providers, such as NAME based inside or outside the EU.
6. Contact, Financial or Transaction Data from providers of payment services, such as Stripe Inc. based inside or outside the EU submitted by you detailing the transactions you carry out through our Services and of the fulfillment of your orders.
7. Identity, Contact and registration Data from our business partners, such as Frontline Gaming, based outside the EU for event registration purposes.

The Website does not have the functionality for a forum when users submit contributions directly, but you may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Services, or transmitted to other users of the Services or third parties, such as event scores, army lists (collectively, “User Contributions”). User Contributions will be posted on and transmitted to others at your own risk.  Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

The technologies we use for this automatic data collection of Technical Data may include Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.  

THIRD-PARTY USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES.

Some content or applications, including advertisements, on our Services are served by third-parties, including advertisers, ad networks and servers, content providers and application providers. These third parties may use cookies or other tracking technologies to collect information about you when you use our Services. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

4. HOW WE USE YOUR PERSONAL DATA

As permitted by law, we use information that we collect about you or that you provide to us, including your Personal Data:

1. To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including without limitation to: provide our Services and content, and any information you request from us, to you; allow you to participate in interactive features of our Services; for billing and collection purposes, provide notices to you about your account and/or subscription, including expiration and renewal notices; provide notices to you about changes to our Services or any products or services we offer; and to provide notices to you of updates to the Privacy Policy or other terms of service.
2. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
3. Where we need to comply with legal or regulatory obligations.

We generally do not rely on consent as the legal basis for processing your Personal Data other than in relation to sending third party or direct marketing communications to you via email about our own and third-parties’ goods and services that may be of interest to you.  You have the right to withdraw consent to such marketing by emailing the address provided in the Contact Information section below.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We set out below, in table format, a description of all the ways we plan to use your Personal Data, and which of the legal bases we rely on to do so.  Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your Personal Data.  Please contact us if you need details about the specific legal ground we are relying on to process your Personal Data where more than one ground has been set out in the table below:

*Legitimate Interest means the interest of the Company’s business in conducting and managing our business to give you the best service/products and the best and most secure experience.  We make sure we consider and balance any potential impact on you, both positive and negative, and your rights before we process your Personal Data for our legitimate interests.  We do not use your Personal Data for activities where our interests are overridden by the impact on you, unless we have your consent or are otherwise required or permitted to by law.  You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at the address listed in the Contact Information section below.

MARKETING

We strive to provide you with choices regarding certain uses of your Personal Data, particularly around marketing and advertising.

PROMOTIONAL OFFERS FROM BEST COAST PAIRINGS

We may use your Identity, Contact, Usage, and Profile Data to form a view on what we think you may want or need, or what may be of interest to you.  This is how we decide which products, services, and offers may be relevant for you.  We call this marketing.

You will receive marketing communications from us if you have requested information from us or purchased Services from us, and in each case, if you have not opted out of receiving that marketing.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your Personal Data with any company outside of Best Coast Pairings LLC for marketing purposes.

OPTING OUT

You can us or third parties to stop sending you marketing messages at any time by contacting us at the email address provided in the Contact Information section below.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies.  If you disable or refuse cookies, please note that some parts of this Website may become inaccessible or not function properly.  For more information about the cookies we use, please see Google Analytics

CHANGE OF PURPOSE

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably determine that we need to use it for another reason compatible with the original purpose.  If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at the email address provided in the Contact Information section below.  

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where such processing is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose Personal Data that we collect or you provide as described in this Policy with the parties described below for the purposes set forth in the table in Section 4 above:

1. Internal Third Parties:
2. To our subsidiaries and affiliates.

1. External Third Parties:
2. To contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.

1. To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Best Coast Pairings LLC’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by Best Coast Pairings LLC about our Services’ users is among the assets transferred.

1. To third parties to market their products or services to you if you have consented to or not opted out of these disclosures.
2. To third parties (e.g., shops) for estimating attendance, ticket verification purpose.

6. CHILDREN AND PRIVACY

Please see the Company’s policy [Insert Link] for more information on how the Company handles Personal Data of users who are children located in the EU who are under age 16, and children located in the US who are under age 13.  

7. INTERNATIONAL TRANSFER

If you are located in a province, country, or other government jurisdiction outside of the United States, and if you choose to provide your personal information to Best Coast Pairings LLC through our Services, please be aware that your personal information will be transferred to and maintained on computers located in the United States and the applicable US privacy laws may not be as protective as those in your jurisdiction.  

Whenever we transfer your personal data to countries outside of the European Economic Area (“EEA”), we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the EU and the US.

Please contact us if you would like further information on the specific mechanism used by us when transferring your personal data out of the EEA.

8. DATA SECURITY

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure.  We also limit access to Personal Data to those employees, agents, contractors, and other third parties who have a business need to know.  These individuals will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to or through our Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.

All Financial Data is securely processed by Stripe, Inc. which is certified under the EU-U.S. and the Swiss-U.S. Privacy-Shield Framework and Stripe’s privacy policy is available here (https://stripe.com/us/privacy).  

We have put in place procedures to deal with any suspected incident involving Personal Data and will notify you and any applicable regulator of an incident involving Personal Data where we are legally required to do so.

9. DATA RETENTION

We maintain one or more databases to store your Personal Data and may keep such information indefinitely in order to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.  In some circumstances you may ask us to delete your Personal Data.  See the section below regarding Requesting Erasure for more information.  In some circumstances we may anonymize your Personal Data so that it can no longer be associated with you for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Financial Data is collected and maintained by our third party payment processor, Stripe, Inc., and is subject to Stripe, Inc.’s data retention policy.

10. YOUR LEGAL RIGHTS

CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION  

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

1. Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

1. Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by sending an email to the email address provided in the Contact Information section below.

1. Promotional Offers from the Company. If you do not wish to have your e-mail address used by the Company to promote our own or third parties’ products or services, you can opt-out by sending us an e-mail stating your request to the e-mail address provided below in the Contact Information section. If we have sent you a promotional e-mail, you may send us a return e-mail asking to be omitted from future e-mail distributions. This opt out does not apply to communications with the Company as a result of a product or subscription purchase, product service experience or other transactions.
2. Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by sending us an e-mail stating your request to the e-mail address provided below in the Contact Information section.

1. We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (”NAI”) on the NAI’s website.

YOUR RIGHTS UNDER THE EUROPEAN UNION’S GDPR

Under certain circumstances, you have rights under the EU’s GDPR regarding your Personal Data.  Each of the rights is summarized below:

• Request access to your Personal Data.  You have the right to be informed of the Personal Data we hold about you, and why and how we have it.  
• Request correction of your Personal Data.  You have the right to request correction of inaccurate or incomplete Personal Data although we will need to verify the accuracy of the new data you provide to us.  We may not be able to accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
• Request erasure of your Personal Data.  You have the right to have your Personal Data erased if there is no good reason for us to continue to process it.  You also have the right to ask us to delete/erase your Personal Data where you have successfully exercised your right to object to its processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law.  Note, however, that we may not always be able to comply with your request of erase for specific legal reasons which will be be provided to you, if applicable, when evaluating your request. By requesting that we delete your Personal Data, we may keep the statistical data (including, without limitation, your tournament score information), however such data will not be connected to your name or other Personal Data.
• Object to processing of your Personal Data.  You have the right to object to the processing of your Personal Data where we have justified the data processing on the basis of our legitimate interests and there is something about your particular situation which makes you feel the processing impacts your fundamental rights and freedoms.  You also have the right to object where we are processing your Personal Data for direct marketing purposes.
• Request restriction of processing your Personal Data.  You have the right to restrict the processing of your Personal Data if: the accuracy of the data is being contested for as long as it takes to verify that accuracy; the processing is unlawful and you request restriction of processing (rather than erasure of the data); we no longer need the data for its original purpose but you would like us to hold the data because you need it to establish, exercise, or defend legal rights; or you have objected to our use of your Personal Data but we need to verify whether we have overriding legitimate interests to use it.
• Request transfer of your Personal Data.  You have the right to request the transfer of your Personal Data to you or to a third party.  We will provide to you, or a third party you designate, your Personal Data in a structured, commonly used, machine-readable format.  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.
• Right to withdraw consent.  You have the right to withdraw your consent to the processing of your Personal Data where we were are relying on consent to process your Personal Data.  However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.  If you withdraw your consent, we may not be able to provide certain services to you.  We will advise you if this is the case when reviewing your request to withdraw your consent.

You may exercise any of these rights by e-mailing us at the address listed in the Contact Information section below.  You will not have to pay a fee to access your Personal Data or to exercise any of the other rights.  However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive.  Alternatively, we may refuse to comply with your request in such circumstances.  Also, the exercise of some rights will prevent our ability to provide Services to you, and if this is the case, we will explain this to when you submit your request to us.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data or to exercise any of your other rights.  This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it.  We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month after the request is received.  Occasionally it may take us longer than a month if your request is particularly complex or you have submitted several requests.  In this case, we will notify you and keep you updated.

YOUR CALIFORNIA PRIVACY RIGHTS 

California Civil Code Section § 1798.83 permits users of our Services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please e-mail us at the address listed in the Contact Information section below.

11. CONTACT INFORMATION

To ask questions or comment about this Policy and our privacy practices, please email us at: support@bestcoastpairings.com