How we will protect your privacy
This Policy explains what personal information AP Race Plus, Sailfish Systems and its group companies (known in this Policy as "we" or “us”) collect and how we use it. Please read it carefully. Consumers and third parties using our Services are all referred to in these Terms collectively as "Users", "you" or "your". Any information provided to AP Race Plus and Sailfish Systems will be referred to in this policy as “Personal Data”.
Generally, we collect information about you if you create an account, from your purchase of services, when you email or call us and when you use our websites, apps and social media. We use that and other information to provide better services, marketing and support to you and our other customers (including by analysing your information to provide you with a personalised experience).
When you, for example, create an account, purchase a subscription, download one of our apps or contact us on the phone, we may ask your consent to use your information for certain purposes. Your choices about how we use information are described here.
We are responsible for the processing of your personal information in accordance with the Data Protection Act 2018 and GDPR regulation.
We collect your information in different ways
Directly from you. For example, if you register for a subscription, create an account, enter a competition or free prize draw, download an app, post a comment on our websites, ask us a question or email us.
From third parties. For example, if you choose to use an integrated social media feature on our websites or apps, the third-party social media site will give us certain information about you. This could include your name and email address. Your activities on our sites and apps may be posted to the social media platforms.
Information we may hold about you
We use the following information for the purposes described in this Policy:
Your contact and account information. We will hold contact information you provide to us (e.g. name, address, phone number, email, country of residence, preferred language and other associated information) when you create an account or purchase a subscription.
Your payment and billing information. We will hold payment and billing information you provide to us (e.g. credit card) in connection with the handling of your purchases. We store payment information in order to take re-occurring payments from you.
Information you post online. For example, we hold information you post on our website or on a third-party social media site to which we have access (including reviews you post or surveys you complete). When you post information online, you must not infringe the rights of others (including privacy rights) and you should be aware that others may use, tag and/or re-publish your information in ways that you might not expect (including in ways that are unlawful). You understand that we and others (including our Partners) may use and re-publish any data you post online publicly, on our website or when using apps or social media tools.
Information on your preferences. We may collect information about most viewed articles and what content you prefer in order to provide a better user experience.
Website usage information. If you use our websites, we may collect information about the browser and device you're using and your IP address (this is a number that identifies a specific network device on the internet and is required for your device to communicate with websites). We might look at what site you came from, what you did and didn't use our site for, or what site you visit when you leave us.
App(s) usage information. If you use our app(s), we may collect your GPS location or your device's unique identifier. We might also collect the type of device you are using, or the version of the operating system your computer or device is running. We might look at, for example, how often you use the app and where you downloaded it.
Other information about your interactions with us. For example, if you interact with us via email, telephone or social media (e.g. Facebook).
We may use your information in the following ways and for the following purposes
If you provide Personal Data in order to obtain access to or use of the Services or any functionality thereof, we will use your Personal Data to provide you with access to or use of the Services or functionality and to analyse your use of such Services or functionality. For instance, if you supply Personal Data relating to your identity or qualifications to use certain portions of the Services, we will use that information to make a decision as to granting you access to use such Services and to assess your ongoing qualification to use such Services.
To provide you with products, services, account information and support.
To send you communications in connection with your transaction. For example, we might send you emails about your account or a purchase. We might also contact you about this Policy or any of our other policies or terms.
To identify trends and interests. We use your information to get to know what your preferences might be so we can improve our offering to you and so that your experience with us is more relevant and personal. We may combine information we get from you with information about you we get from third parties, including to analyse customer behaviour.
To monitor and improve our products, services, and websites. We analyse your information to improve our understanding of you and our customer base in general. We do this so that we can make better decisions about our services, advertising, products and content, based on a more informed picture of how our customers use our current services, and to provide you with a more customised experience.
For security purposes. We may use your information to protect the security of our company, employees, our customers, third parties and/or our/their property (including any events you may attend and our websites) as permitted by law.
For market research purposes. We may contact you as part of market research we are carrying out. You may choose not to participate.
For marketing purposes. Where you've agreed, you may be contacted by us by email, text message, telephone or other means with information or offers regarding our upcoming events, products or services (including newsletters). We may also send you information or offers on behalf of other businesses or other partners in the Sailfish Systems Limited and AP Race Plus Limited family, but when we do this, we do not give those businesses your name and address.
As otherwise permitted by law. In limited circumstances, we may also use your information for other purposes where permitted by law.
You have certain choices about how we use your information
When you create an account, purchase subscriptions or download our apps, we may ask for your consent in order to collect, process or use your personal information for specified purposes.
If you wish to withdraw any consent you have provided to us for such use of your personal information, contact us or log in and tell us about your preferences in your user settings.
You understand that if you choose not to give us consents, or if you withdraw consents, you may not be able to take advantage of one or more features we offer.
In addition to contacting us, you can opt in or out in the following ways:
You can opt in or out of receiving marketing communications including newsletters. To stop receiving marketing communications, you can follow the instructions in any promotional message you get. It may take about ten days to process your request. Don't worry! Even if you opt out of getting marketing messages, we will still be sure to send you transactional messages. For example, we may still contact you about your orders.
How You Can Access, Update, Correct or Delete Your Personal Data.
You can request access to some of your Personal Data being stored by us. You can also ask us to correct, update or delete any inaccurate Personal Data that we process about them.
If you are a registered User, you can exercise these rights by logging in and visiting the My Account page. Both registered and unregistered Users may also exercise these rights by contacting us directly by email.
If a Consumer initiates a data deletion request, AP Race Plus is authorised to delete or anonymise Personal Data of the requesting Consumer from the Services.
You can control and opt out of us using tools on your devices. For example, you can turn off the GPS locator or push notifications by using the settings on your phone.
How Long We Retain Your Personal Data.
We may retain your Personal Data as long as you are registered to use the Services. You may close your account by contacting us. However, we may retain Personal Data for an additional period as is permitted or required under applicable laws. Even if we delete your Personal Data it may persist on backup or archival media for an additional period of time for legal, tax or regulatory reasons or for legitimate and lawful business purposes.
How We Disclose And Transfer Your Personal Data.
We are not in the business of selling your Personal Data. We consider this information to be a vital part of our relationship with you. Therefore, we will not give nor sell your Personal Data to third parties, including third party advertisers. There are, however, certain circumstances in which we may disclose, transfer or share your Personal Data with certain third parties without further notice to you, as set forth below.
Parent Companies, Subsidiaries and Affiliates.
Agents, Consultants and Service Providers.
We may disclose your Personal Data if required to do so by law in order to (for example) respond to a subpoena or request from law enforcement, a court or a government agency (including in response to public authorities to meet national security or law enforcement requirements), or in the good faith belief that such action is necessary to (a) comply with a legal obligation, (b) protect or defend our rights, interests or property or that of third parties, (c) prevent or investigate possible wrongdoing in connection with the Services, (d) act in urgent circumstances to protect the personal safety of Users of the Services or the public, or (e) protect against legal liability.
How We Store Your Personal Data
We will not transfer any Personal Data outside of the European Economic Area unless the prior written consent of the Customer has been obtained and the following conditions are fulfilled:
- the Customer or AP Race Plus has provided appropriate safeguards in relation to the transfer;
- the data subject has enforceable rights and effective legal remedies;
- AP Race Plus complies with its obligations under the Data Protection Legislation by providing an adequate level of protection to any Personal Data that is transferred; and
- AP Race Plus complies with reasonable instructions notified to it in advance by the Customer with respect to the processing of the Personal Data;
We will ensure that all personnel who have access to and/or process Personal Data are obliged to keep the Personal Data confidential.
We will ensure that we have in place appropriate technical and organisational measures designed to protect against unauthorised or unlawful processing of Personal Data and against accidental loss or destruction of, or damage to, Personal Data, appropriate to the harm that might result from the unauthorised or unlawful processing or accidental loss, destruction or damage and the nature of the data to be protected, having regard to the state of technological development and the cost of implementing any measures (those measures may include, where appropriate, pseudonymising and encrypting Personal Data, ensuring confidentiality, integrity, availability and resilience of its systems and services, ensuring that availability of and access to Personal Data can be restored in a timely manner after an incident, and regularly assessing and evaluating the effectiveness of the technical and organisational measures adopted by it).
You can deal with us anonymously in certain circumstances
When creating an account we ask you to provide your name, an email addresses and a password. To create an account you do not have to provide us with your real name or an email address that identifies you but if you wish to use that account to subscribe we will need to know your real name and billing details so we can process your transaction.
If you contact us with a general query you can also do so anonymously but if you wish to discuss your account with us we will ask for information to identify and verify your account.
Personal Data Provided to Others.
We may link to third party sites or services we don't control
The EU General Data Protection Regulation (GDPR)
In May 2018, a new data privacy law known as the EU General Data Protection Regulation (or the "GDPR") becomes effective. The GDPR requires AP Race Plus and Sailfish Systems to provide Users with more information about the processing of their Personal Data.
Here is what you need to know:
Legal grounds for processing your Personal Data
The GDPR requires us to tell you about the legal ground we're relying on to process any Personal Data about you. The legal grounds for us processing your Personal Data for the purposes set out above will typically be because:
- you provided your consent;
- it is necessary for our contractual relationship;
- the processing is necessary for us to comply with our legal or regulatory obligations; and/or
- the processing is in our legitimate interest as an educational platform (for example, to protect the security and integrity of our systems and to provide you with customer service, etc.).
Personal Data retention
We retain your Personal Data for as long as necessary to provide you with our Services, or for other important purposes such as complying with legal obligations, resolving disputes, and enforcing our agreements.
If you have an account with us, we will typically retain your Personal Data for a period of 90 days after you have requested that your account is closed or if it's been inactive for 7 years.
Data protection law provides you with rights in respect of Personal Data that we hold about you, including the right to request a copy of the Personal Data, request that we rectify, restrict or delete your Personal Data, object to profiling and unsubscribe from marketing communications.
For the most part, you can you can exercise these rights by logging in and visiting the My Account page or changing the "cookie settings" in your browser (see our Cookies Policy for more information). If you can't find what you're looking for in the My Account page, please contact us. Please note that requests to exercise data protection rights will be assessed by us on a case-by-case basis. There may be circumstances where we are not legally required to comply with your request because of the laws in your jurisdiction or because of exemptions provided for in data protection legislation.
If you have a complaint about how we handle your Personal Data, please get in touch with us to explain. If you are not happy with how we have attempted to resolve your complaint, you may contact the relevant data protection authority.
AP Race Plus as a data controller and a data processor
EU data protection law makes a distinction between organisations that process Personal Data for their own purposes (known as "data controllers") and organisations that process personal data on behalf of other organisations (known as "data processors"). If you have a question or complaint about how your Personal Data is handled, these should always be directed to the relevant data controller since they are the ones with primary responsibility for your Personal Data.
AP Race Plus is the data controller and Sailfish Systems is a data processor in respect of your Personal Data.
Feel free to contact us if you have any questions, complaints or require a copy of information we hold about you.
If you have any questions or complaints about this Policy or any privacy concerns, or would like to request copies of the information we hold about you, please contact us. Please do not include your credit card number or other financial or sensitive information in your email.
To correct, amend or update information you have given us, or in order to withdraw a consent you have given us you can contact us or log into your account.
What we will do if there is an update to this policy
From time to time we may change our privacy practices. We will notify you of any material changes to this Policy as required by law. We will also post an updated copy on our website. It will have a different date and version number from the one set out below. Please check our site periodically for updates.