Best Coast Pairings LLC
Effective: May 25, 2018
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”)
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).
PURPOSE OF THIS PRIVACY NOTICE
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
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.
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.
“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:
We collect several types of Personal Data from and about users of our Services, including the following:
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:
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.
We use different methods to collect this information from you and about you including:
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.
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.
As permitted by law, we use information that we collect about you or that you provide to us, including your Personal Data:
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:
Type of Data
Lawful basis for processing including the basis of legitimate interest if applicable
To register you as a new customer
Performance of a contract with you
To process and deliver your order including: (1) manage payments, fees, and charges; and (2) collect and recover money owed to us
(d) Marketing and Communications
(1) Performance of a contract with you
(2) Necessary for our legitimate interests (to recover debts due to us)
(e) Marketing and Communications
(1) Performance of a contract with you
(2) Necessary to comply with a legal obligation
(3) Necessary for our legitimate interests (to keep our records updated and to study how customers use our Services)
To administer and protect our business, Website, and Services (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data)
(1) Performance of a contract with you
(2) Necessary for our legitimate interests (to study how customers use our Services, to develop them and grow our business.
To deliver relevant content via the Services and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.
(e) Marketing and Communications
Necessary for our legitimate interests (to study how customers use our Services, to develop them, to grow our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods and services that may be of interest to you.
Necessary for our legitimate interests (to develop our Services and grow our business)
*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.
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.
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.
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.
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.
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:
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.
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:
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.
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.
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.
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.
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:
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:
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.
To ask questions or comment about this Policy and our privacy practices, please email us at: email@example.com