1.1 We are committed to safeguarding the privacy of Harrier Central users.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of Harrier Central users; in other words, where we determine the purposes and means of the processing of that personal data.
1.4 In this policy, “we”, “us” and “our” refer to InnoVet Europe. For more information about us, see Section 13.
2.1 This document was created using a template from SEQ Legal (https://seqlegal.com/free-legal-documents/privacy-policy).
3. How we use your personal data
3.1 In this Section 3 we have set out:
(a) the general categories of personal data that we may process;
(b) personal data provided to us with your consent from Facebook;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
3.2 We may process data about your use of our website and services (“usage data“). The usage data may include your geographical location, operating system, length of use, app usage statistics (e.g. navigation paths, as well as information about the timing, frequency and pattern of your service use). The source of the usage data is the Harrier Central mobile app. This usage data may be processed to allow us to improve our products and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our apps and services.
3.3 We may process your account data (“account data“). The account data may include your name, email address, Hash name, and profile photo. The source of the account data is you or the Hash groups who you run with that use Harrier Central for management purposes. The account data may be processed for the purposes of operating our apps, providing our services and communicating with you. The legal basis for this processing is our legitimate interest in providing you with features you find useful, namely the proper administration of our apps and services.
3.4 We may process your information included in your personal profile maintained within our back-end database (“profile data“). The profile data
may include your name, email address, profile pictures, gender, Hash House Harriers groups that you are a member of or you frequent, runs you attend, your friend list and RSVP information for events. The profile data may be processed for the purposes of enabling your use of our apps and services. The legal basis for this processing is your consent and our legitimate interest in providing you with features you find useful, namely the proper administration of our apps and services.
3.5 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
3.6 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
3.7 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process [any of your personal data] where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
3.8 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
4. Providing your personal data to others
4.1 We do not share your personal data with any other entity with the exception of data shared with Hash House Harriers groups regarding your past or future participation in Hash House Harriers related events.
4.6 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5. International transfers of your personal data
5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
5.2 We have offices in The Netherlands. The European Commission has made an “adequacy decision” with respect to the data protection laws of The Netherlands. Data held within The Netherlands will be protected by
appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.
5.3 The hosting facilities for our apps and services are situated in Ireland and The Netherlands. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.
5.4 You acknowledge that personal data that you submit through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
6. Retaining and deleting personal data
6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
6.3 We will retain your personal data as follows:
(a) Account data will be retained for a minimum period of one day following the date you request your personal information to be removed from our system, and for a maximum period of two weeks following the date you request your personal information to be removed from our system.
6.4 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
7.1 We may update this policy from time to time by publishing a new version on our website.
7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
7.3 We will notify you of significant changes to this policy by email or through the notification system on our mobile applications.
8. Your rights
8.1 In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
8.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
8.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
8.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
8.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
8.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
8.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
8.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
8.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
8.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
8.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
8.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
8.13 You may exercise any of your rights in relation to your personal data by written notice to us.
9. About cookies
9.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The
identifier is then sent back to the server each time the browser requests a page from the server.
9.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
9.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
10. Cookies that we use
11. Cookies used by our service providers
11.1 We do not share any of your personal data with external service providers either through structured data exchange or through cookies.
12. Managing cookies
12.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647 (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) https://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
12.2 Blocking all cookies will have a negative impact upon the usability of many websites.
12.3 If you block cookies, you will not be able to use all the features on our website.
13. Our details
13.1 The Harrier Central app, back-end data stores and associated web sites are owned and operated by InnoVet Europe.
13.2 We are registered in The Netherlands under KvK registration number 68759207, and our registered office is at Fluwelen Burgwal 58, 2511 CJ, Den Haag.
13.3 Our principal place of business is at Fluwelen Burgwal 58, 2511 CJ, Den Haag.
13.4 You can contact us:
(a) directly through the Harrier Central app, “Contact Us” form; or
(d) by email, using the email address published on our website.
14. Data protection officer
14.1 Our data protection officer’s contact details are:
James A. White email@example.com