1. Our commitment to privacy
Counter Ruck Pte Ltd (Company No. 2021RC000498) (the “Drua”) (we, us, our) takes the protection of your privacy very seriously. We recognise that your personal information is valuable and we process it in accordance with applicable law, and to the extent that it applies to your personal information, with the European Data Protection Legislation.
Controller of Personal Information
If you have made a booking or purchase with a third party service provider, such as our ticketing partner, then that other entity will also separately be considered a “controller”. Please be careful to review privacy policies of such service providers separately, which you can access from them directly.
European Data Protection Legislation
2. Types of personal information we collect and hold
The types of information we collect and hold will vary depending on your use of the Drua Website, your dealings with the Drua and the products, services and benefits we (or our agents, contractors and third parties) provide to you, or a request or inquiry you may make in relation to such products, benefits and services. This information may include any or all of the following:
The Drua will generally not collect any sensitive personal information from you. However, where the Drua seeks to collect sensitive personal information from you, it will do so in accordance with all applicable privacy laws, for instance by obtaining your express consent for such a collection.
You can choose not to provide us with any of your personal information. However, if you choose not to provide us with your personal information in these circumstances, we will be unable to respond to your enquiry, engage in further communications with you and/or provide the requested services.
3. Why we collect and hold personal information
The Drua generally only collects, uses, discloses or holds personal information that is reasonably necessary for the Drua to perform one or more functions or activities as a club and to pursue its legitimate interests, including (without limitation):
4. How we collect information
Where it is reasonable and practicable to do so, the Drua will collect personal information directly from you as follows (without limitation):
In addition to collecting personal information directly from you, we may also collect personal information from third parties such as:
5. How we use and disclose personal information
We may use and disclose your personal information to conduct our business and to pursue our legitimate interests, including (without limitation):
Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above.
6. Website cookies
Information is also generated and collected whenever a page is accessed on our website that records information such as the time, date and specific page. We collect such information for statistical and maintenance purposes that enables us to continually evaluate our website performance. Some parts of our websites also use "cookies". A "cookie" is a small text file that is placed on your computer's hard drive by a web page server. Cookies store information about the use of our website and are used to identify new or previous visitors to the website and what pages have been accessed. Most web browsers are set to accept cookies, but this function can usually be disabled if you wish. Please note that if you do disable this, not all functionality on our websites will be available to you.
We use a web-tracking solution by Snowplow Analytics Limited (“Snowplow”) to collect information about your use of the Drua Website. We use data collected by Snowplow exclusively for statistical purposes. The Snowplow tool collects information such as how often users access the Drua Website, which pages they visit and at what times they visit the Drua Website. The Snowplow tool does not collect any personal information relating to users of the Drua Website and is used by the hosting service provider of the Drua Website to improve the Site and our products and services.
We also use Google Analytics features (including Google Remarketing, Google Display Network Impressions Reporting, the Double Click Campaign Manager and Google Analytics Demographics and Interest Reporting) on our website, which uses both first party and third party cookies to record standard internet traffic information. We, and some third parties (including Google), also use the information to optimise ad selection for groups of individuals based on age, gender, interests and past visits to our site. The cookies allow us and other third parties (including Google) to evaluate your interactions with ad services on our site and serve targeted advertising on sites across the Internet. We have enabled Google Analytics for Display Advertising which allows Google and other third parties to advertise to you on our site and across the Internet.
We also use (along with third parties including Google) first party cookies (such as Google Analytic cookies) and third party cookies (such as the DoubleClick cookie) to report how our ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our website. In addition, we use data from Google's Interest-based advertising or third party audience data (such as age, gender, and interests) with Google Analytics to help us understand how user activity varies based on these factors.
Importantly, we do not combine the anonymous information collected through Google Analytics with personally identifiable information.
In addition to Google Analytics, we use a range of web analytics tools (such as web beacons) to help us understand consumer behaviour and use of our website. In particular, these tools enable us to deliver cookies, count visits and understand usage and campaign effectiveness. This data helps us to stay connected and relevant to our members and fans.
7. Storage and protection of personal information
We store personal information in a combination of secure computer storage facilities and paper-based files and other records. In so doing, we have taken numerous steps to protect your personal information from misuse, interference and loss, and unauthorised access, modification or disclosure.
Additionally we take reasonable steps to destroy or permanently de-identify personal information when we no longer need it. We impose strict requirements of security and confidentiality on all third parties as to how they store, handle and deal with your personal information.
8. Retention of Personal Information
We will keep your information for as long as we need it for purpose it is being processed for. For example, where you purchase merchandise from us, we will keep the information related to your purchase so we can fulfil the specific purchasing request you have made, and after that we will keep the information for a period which enables us to handle or respond to your complaints, queries or concerns relating to the purchase. The information may also be retained so that we can continue to improve your experience with us.
We will actively review the information we hold and delete it securely, or in some cases anonymise it, when there is no longer a legal, business or customer need for it to be retained. We may retain a record of the existence of our relationship with you, to the extent that and for as long as we are required to do so by law.
9. Direct marketing
When you opt-in to receive communications from us, you are giving your consent for your personal information to be used by us to contact you by email and direct mail, and to deliver personalised website experiences, to share information about relevant products, services, news and events.
Where you no longer wish to receive direct marketing materials from us in the future, you may use the opt-out facility in marketing communication, or you may contact us at any time using contact details provided below.
Withdrawing your consent will not affect our use of personal information prior to you withdrawing that consent but it will mean that we will not be able to contact you about the services we may be able to offer you or your business in the future.
10. Overseas disclosure of personal information
Our website is hosted in the United Kingdom.
Subject to the two paragraphs below, the Drua will not transfer your personal information to an overseas recipient unless it has first taken steps reasonable in the circumstances to ensure that the personal information that it transfers will not be held, used or disclosed by the recipient of the information inconsistently with, or otherwise in breach of, applicable privacy laws. For example, the Drua may adopt appropriate contractual clauses with overseas recipients that ensure their compliance with applicable privacy laws.
We may disclose your personal information to overseas recipients for things such as processing membership, product orders and hosting services, although countries where such recipients are located may vary. This may include using outsourced services in countries outside the European Union from time to time. Accordingly, for residents based in the EEA, data obtained within the UK or any other country could be processed outside the European Union. For example, the processing of memberships may be undertaken by a third party services provider based in Australia.
The Drua may transfer personal information about you to someone who is in a foreign country if:
(a) the Drua reasonably believes that the recipient is subject to a law or binding scheme that has the effect of protecting the information in a way that is, overall, substantially similar to applicable privacy laws and there are mechanisms available to you to enforce that protection or scheme; and
(b) you expressly consent to the transfer after the Drua has informed you that the applicable privacy laws will no longer apply if you provide your express consent.
11. Advertising and third party links
12. Access to, and correction of, personal information
We will take reasonable steps to make sure that the personal information we collect, hold, use or disclose is accurate, complete and up to date. If your personal details change, such as your address or phone number, you can update them using the online portal on the Drua Website.
Following a request, we will provide you with a copy of any personal information which we hold about you in accordance with our obligations under applicable privacy law. We may charge a fee for retrieving this information, in which case we will inform you of the fee in advance of providing the information.
In certain circumstances, we may refuse to provide you access to your personal information. Where we refuse you access, we will provide you with a written explanation as to the reasons for the rejection (for instance, we may refuse to disclose personal information to you where such access would have an unreasonable impact on the privacy of other individuals).
13. Rights under the European Data Protection Legislation
With respect to the personal information that we collect about you, and to the extent that you are located in the EEA, under European Data Protection Legislation you have the right to:
Please contact us using the details below to exercise these rights or for additional information. If you have an online account with us, you may be able to log into your account to access and update the information you have provided to us.
14. Making a complaint
If you wish to complain about our handling of your personal information, please send a written complaint to the Privacy Officer in the first instance by using the contact details below. We undertake to promptly acknowledge and investigate any complaint about the way we manage personal information.
15. Contacting us
The Privacy Officer
Post: 35 Gordon St, Suva, FIJI
[Last updated November 2021]