GAAGO Privacy Statement

PRIVACY STATEMENT

This statement covers the use of any personal data that GAAGO Media Limited (“GAAGO”) holds about you. GAAGO respects your privacy and is committed to protecting your personal data. This privacy statement will tell you how we use your personal data, about your privacy rights and how the law protects you.

1. IMPORTANT INFORMATION AND WHO WE ARE

1.1 Purpose of this privacy notice
This privacy notice aims to give you information on how GAAGO collects and processes your personal data. It is important that you read this privacy notice so that you are fully aware of how and why we are using your data. This privacy notice supplements other notices and is not intended to override them.

1.2 Controller
GAAGO has its registered office at Croke Park Stadium, Jones’ Road, Drumcondra, Dublin 3 and is the controller responsible for your personal data.

1.3 Changes to the privacy notice and your duty to inform us of changes
This privacy notice was last updated on 8 August 2019. We will notify you of any significant future changes via email. It is important that the personal data we hold about you is accurate and current, so please keep us informed if your personal data changes during your relationship with us.

2. THE DATA WE COLLECT ABOUT YOU

2.1 Personal Data
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 identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

2.1.1 Identity Data: we use your email address as a way to identify you as an individual customer.

2.1.2 Contact Data: includes postal address, email address and telephone numbers.

2.1.3 Financial Data: our website transfers payment card details to our payment partner Stripe. These details are not stored by or fully visible to us. [See section 5.2 for more detail].

2.1.4 Transaction Data: we keep a record of your transactions with us.

2.1.5 Technical Data: includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

2.1.6 Profile Data: includes your login information, your marketing and communications preferences and any other account information you may have submitted to us.

2.1.7 Usage Data: we keep a record of the content that you stream on the site, and any support tickets that you submit to us.

2.1.8 Marketing and Communications Data: we transfer your email address to our email marketing system, where it is held securely. A record is kept of your subscription preferences and activity.

2.2 Aggregated Data
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 in law as 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 website feature.

3. HOW YOUR DATA IS COLLECTED

3.1 We use different methods to collect data from and about you including through:

3.1.1 Direct interactions. You may give us your Identity, Contact and Financial Data by signing up for a GAAGO account, purchasing products, filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

3.1.1.1 create an account or profile on our website;

3.1.1.2 subscribe to a mailing list;

3.1.1.3 enter a competition, promotion or survey;

3.1.1.4 make a purchase;

3.1.1.5 email customer support;

3.1.1.6 give us feedback.

3.1.2 Automated technologies or interactions. As you interact with our website and app, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. Please see our cookie policy for further details.

3.1.3 Third parties. We may receive personal data about you from various third parties as set out below:

3.1.3.1 Facebook (account creation)

3.1.3.2 Roku (purchases via Roku Billing).

4. HOW WE USE YOUR PERSONAL DATA

We have set out a description of all the ways we use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

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 data.

Note that where consent is used as a legal basis for processing your data, for example if you sign up directly to the GAAGO mailing list without making a purchase, you have the right to withdraw consent at any time by contacting us.

The lawful bases of processing that we use are as follows:

4.1 Legitimate Interest means the interest of our business to conduct and manage it in a way that gives you the best service/product 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).

Why there’s a lawful basis for processing:

  • To allow you to avail of our services through our website and to process payment for our services.
  • To process and deliver your purchase including:
    1. Manage payments, fees and charges
    2. Collect and recover money owed to us
  • To manage our relationship with you which will include:
    1. Notifying you about changes to our terms or privacy policy
    2. Asking you to take a survey
  • To enable you to partake in a prize draw or competition.
  • To allow you to earn rewards by recommending GAAGO to friends and family.
  • To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
  • To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.
  • To use data analytics to improve our website, products/services, marketing, customer relationships and experiences.
  • To make suggestions and recommendations to you about goods or services that may be of interest to you.

4.2 Performance of Contract means processing your data where it is necessary to provide our services to you.

Why there’s a lawful basis for processing:

  • To allow you to avail of our services through our website and to process payment for our services.
  • To register you with a GAAGO Account.
  • To process and deliver your purchase including:
    1. Manage payments, fees and charges
    2. Collect and recover money owed to us
  • To manage our relationship with you which will include:
    1. Notifying you about changes to our terms or privacy policy
    2. Asking you to take a survey
  • To enable you to partake in a prize draw or competition.

4.3 Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation to which we are subject.

Why there’s a lawful basis for processing:

  • To manage our relationship with you, which will include notifying you about changes to our terms or privacy policy
  • To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

4.4 Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. 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 this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out above.

5.1 Service providers based inside and outside of the EEA who provide development and system administration services, consultancy services, accountancy services, customer service software, refer-a-friend services, cloud computing and surveys. Most data is held within the EEA, and some data is transferred to processors outside the EEA, and only to companies with Privacy Shield Certification.

Below is more detail on service providers we share your personal data with:

Customer Support Communications
All customer support emails are retained to keep track of specific user issues and are shared with our developers only to seek resolution to a particular user issue. We keep all communications in order to hold historical data on user issues or comments, to inform changes to the service and to improve the overall customer support experience. These communications are not shared for marketing purposes and are stored securely on our support software’s servers.

Cloud Computing
Our cloud computing service provides GAAGO with cloud storage, database management, web servers and deployment.

All data related to your account is processed and stored by our cloud computing provider in order to ensure that your experience is seamless and uninterrupted. This data is locked away behind-the-scenes, and ensures that the website functions properly for you. Specific details can be accessed by our developers when there is a technical issue, and only for the purposes of rectifying the problem.

This service also ensures that the GAAGO service stays up and running around the world, especially during busy game days, and that all data processed for this purpose is securely gathered and stored.

Refer-a-Friend Programme
Our referral scheme is powered by a third-party service. This software allows you to recommend GAAGO to potential new customers and you'll each earn rewards when a new customer makes a purchase based on your referral. You can share such offers with your friends and family in a number of ways, and that activity is governed by the privacy policies of these services. Full details of our referral scheme partner's privacy policy are displayed throughout the signup process.

5.2 Stripe, our payment processor for the purposes of payments and compiling financial reports.
Any data that is transferred to Stripe is transferred in accordance with all applicable data protection law. Visible personal data (email addresses) are currently being anonymised and the privacy policy will be updated to reflect completion of this process shortly.

Stripe data is used with all other data by GAAGO as a reference to see the current status of payments and for compiling financial reports. Full credit card details and IP addresses are stored securely by Stripe in order to ensure that your payments are processed correctly, but this information is inaccessible to GAAGO.

5.3 Revenue, governmental agencies, regulators, grant authorities, accreditation bodies and other authorities acting as processors or joint controllers based in Ireland who require reporting of processing activities in certain circumstances or to whom we are obliged to share information about our organisation and participation in it.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Third-Party Links
This website includes links 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.

6. ROKU

Our Roku app is currently available to US customers only. Your personal data is processed by Roku in accordance with the Roku Privacy Policy, with the exception of your email address which will be transferred by Roku to GAAGO Media for us to provide GAAGO Services to you, and will be processed by GAAGO Media in accordance with this Privacy Policy.

When you purchase Premium Content through Roku (which is based in the USA), your purchase is subject to the Roku Privacy Policy and you are providing your personal data to a company based outside of the EEA.

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business ‘need to know’. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Where possible we will anonymise 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.

9. SALE OF GAAGO BUSINESS

We reserve the right to transfer your details to a third party in the event of a sale, merger, liquidation, receivership or transfer of all or substantially all of the assets of GAAGO Media or to any successor organisation who may take over the operation of GAAGO in the future. Any such third parties will be required to adhere to the terms of this Privacy Statement.

10. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

You may:

10.1 Request access to your personal data. This is commonly known as a “data subject access request”. This enables you to receive a copy of the personal data we hold about you.

10.2 Request correction of your personal data. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

10.3 Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to 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 erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

10.4 Object to processing of your personal data. You may object where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights.

10.5 Request restriction of processing your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

10.6 Request transfer of your personal data to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

10.7 Right to withdraw consent. Where we are relying on consent to process your personal data, you have the right to withdraw this consent free of charge. 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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Opting Out
If you decide you no longer wish to receive marketing emails, you can follow the unsubscribe instructions at the bottom of our emails. Alternatively, you can opt out of marketing emails or customised marketing in the ‘Manage Account’ section of your My GAAGO account.

Complaints
You have the right to make a complaint at any time to the Data Protection Commissioner’s Office (www.dataprotection.ie) as they are the supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the Data Protection Commissioner’s Office, so please contact us in the first instance.

11. CONTACTING US

If you wish to exercise any of the rights set out above, or have a query in relation to any of the detail within the Privacy Statement, please contact us at [email protected].