Adventure Lough Derg – Privacy Policy
Version 1 25.05.21
Elite Sports Tech Ltd, trading as Hotfoot.
1. Introduction
1.1 Our privacy policy (the “Privacy Policy”) explains the information we collect, how we use and share it, how to manage your privacy controls and your rights in connection with our websites and the related mobile applications and services (collectively, the “Services”). Please also read our terms of service which sets out the terms governing the Services.
Hotfoot is headquartered in the Republic of Ireland and our Services are provided to you by Elite sports Tech Limited. If you are a resident of the European Economic Area (“EEA”), Hotfoot, is the controller of your personal data for the purposes of EEA data protection law.
1.2 This privacy notice aims to give you information on how Hotfoot collects and processes your personal data through your use of this platform, including any data you may provide through this platform when you sign up to our platform and/or use the website.
1.3 This platform is not intended for children and we do not knowingly collect data relating to children.
1.4 It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
2. Controller
Hotfoot is the controller and responsible for your personal data (collectively referred to as “Hotfoot”, “we”, “us” or “our” in this privacy policy).
3. Contact details
Our full details are:
Full name of legal entity: ELITE SPORTS TECH LIMITED,
Name or title of data privacy manager: Oliver Kirwan
Email address: info@eliteevents.ie
Postal address: Rockfield, Tralee Road, Killarney, Co. Kerry, Ireland, Companies
Telephone number: 00353 64 6635512 (9am-5pm Mon-Fri)
Complaints: You have the right to make a complaint at any time to the Data Protection Commissioner’s Office (DPC), the Irish supervisory authority for data protection issues (www.dataprotection.ie). We would, however, appreciate the chance to deal with your concerns before you approach the DPC so please contact us in the first instance info@eliteevents.ie
4. Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 22 June 2021
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
5. Information Hotfoot Collects
Overview: Hotfoot collects information about you, including information that directly or indirectly identifies you, if you or your other members choose to share it with Hotfoot. We receive information in a few different ways, including when you track, complete or upload activities using the Services. Hotfoot also collects information about how you use the Services. There are also several opportunities for you to share information about yourself, your friends, and your activities with Hotfoot.
5.1 Account, Profile, Activity, and Use Information: We collect basic account information such as your name, email address, date of birth, gender, username and password that helps secure and provide you with access to our Services.
5.2 Profile, activity and use information is collected about you when you choose to upload a picture, activity (including date, time and geo-location information as well as your speed and pace) or post, view others’ activities, or otherwise use the Services.
We use your contact information so we can respond to your support requests and comments.
5.3 Location Information: We collect and process location information when you sign up for and use the Services. We do not track your device location while you are not using Hotfoot, but in order to provide Hotfoot’s core Services, it is necessary for us to track your device location while you use Hotfoot. If you would like to stop the device location tracking, you may do so at any time by adjusting your device settings.
5.4 Content You Share: We gather information from the photos, posts, comments, ratings, reviews, and other content you share on the Services, including when you participate in partner events or create routes.
5.5 Connected Devices and Apps: Hotfoot collects information from devices and apps you connect to Hotfoot.
5.6 Payment Information: When you make a payment on Hotfoot, you may provide payment information such as your payment card or other payment details. We use Payment Card Industry compliant third-party payment services and we do not store your credit card information.
5.7 Third-Party Accounts: Hotfoot allows you to sign up and log in to the Services using accounts you create with third-party products and services, such as Facebook, Google, or Apple (collectively, “Third-Party Accounts”). If you access the Services with Third-Party Accounts we will collect information that you have agreed to make available such as your name, email address, profile information and preferences. This information is collected by the Third-Party Account provider and is provided to Hotfoot under their privacy policies. You can generally control the information that we receive from these sources using the privacy controls in your Third-Party Account.
5.8 Technical Information and Log Files: We collect information from your browser, computer, or mobile device, which provide us with technical information when you access or use the Services. This technical information includes device and network information, cookies, log files and analytics information. The Services use log files. The information stored in those files includes IP addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks. This information is used to analyze trends, administer, protect and secure the Services, track member movement in the aggregate, and gather broad demographic information for aggregate use. IP addresses may be linked to session IDs, athlete IDs and device identifiers.
5.9 Other Information: We may collect information from you through third parties, such as when we collect your feedback through surveys.
6. How Hotfoot Uses Information: Hotfoot uses the information we collect and receive as described below.
6.1 To provide the Services: We use the information we collect and receive to provide the Services, including providing you with the ability to:
Record your activities.
Interact with other Users.
Explore new places to go.
For example, to discover routes where you can run or cycle.
Subject to your privacy controls your information, including parts of your profile, username, photos, your activities, the devices you use, and comments you give and receive will be shared on Hotfoot so that you may be able to participate in the Services, for example to show your place on a leader board.
6.2 To customize your experience: We use the information we collect about you, your followers, and your activities to customize your experience. For example, we may suggest routes that may interest you, or new features that you may want to try. If we see that you run in a certain area, we may suggest a race in that area.
6.3 To improve our Services: We also use the information we collect to analyze, develop and improve the Services. To do this, Hotfoot may use third-party analytics providers to gain insights into how our Services are used and to help us improve the Services.
6.4 To communicate with you: We use the information we collect to provide support in response to your requests and comments. We may also use the information we collect to market and promote the Services, activities and events on Hotfoot, and other commercial products or services. This includes marketing and push communications, where you have not opted out of receiving such messages and notifications.
6.5 To process your subscription: We use the information we collect to process your subscription.
7. Aggregate Information
7.1 We do not sell your personal information. Hotfoot may aggregate the information you and others make available in connection with the Services and post it publicly or share it with third parties, including the Metadata pursuant to our Terms.
8. How Information is Shared: In addition to sharing aggregated data about our members as described above, we also share personal information in accordance with your preferences, as needed to run our business and provide the Services, and where required for legal purposes, as set forth below.
8.1 Service Providers: We may share your information with third parties who provide services to Hotfoot such as supporting, improving, promoting and securing the Services, processing payments, or fulfilling orders. These service providers only have access to the information necessary to perform these limited functions on our behalf and are required to protect and secure your information. We may also engage service providers to collect information about your use of the Services over time on our behalf, so that we or they may promote Hotfoot or display information that may be relevant to your interests on the Services or other websites or services.
8.2 Publicly Available Information: When you join the Hotfoot community, your profile and your activities are set to be viewable by everyone by default. Your name and other profile information is viewable by other Hotfoot members and the public and, subject to your privacy controls, additional information and content you share may also be viewable. For example, your photos and routes may be accessed by other Hotfoot members and non-members or viewable on publicly accessible Hotfoot pages or in search engine results.
8.3 Third Party Business via API or Other Integrations: We enable you to share your information and content with third party apps, plugins, or websites that integrate with the Services, as well as with third parties who work with Hotfoot to offer an integrated feature, such as a challenge sponsor or tracking watch. You can choose to share your profile data and activity data (including private activities). Information collected by these third parties is subject to their terms and policies. Hotfoot is not responsible for the terms or policies of third parties.
9. How We Protect Information: We take several measures to safeguard the collection, transmission and storage of the data we collect. We employ reasonable protections for your information that are appropriate to its sensitivity. The Services use industry standard Secure Sockets Layer (SSL) technology to allow for the encryption of personal information and credit card numbers. Hotfoot engages providers that are industry leaders in online security, including Services verification, to strengthen the security of our Services. The Services are registered with site identification authorities so that your browser can confirm Hotfoot’s identity before any personal information is sent. In addition, Hotfoot’s secure servers protect this information using advanced firewall technology.
10. Managing Your Settings
10.1 Privacy Controls: Hotfoot offers several features and settings to help you manage your privacy and share your activities.
10.2 Updating Account Information: You may correct, amend or update profile or account information at any time by adjusting that information in your account settings.
10.3 Deleting Information and Accounts and Downloading Your Data: After you make a deletion request, we permanently and irreversibly delete your personal data from our systems, including backups. Once deleted, your data, including your account, activities and place on leaderboards cannot be reinstated. Following your deletion of your account, it may take up to 90 days to delete your personal information and system logs from our systems.
Note that content you have shared with others, such as photos, or that others have copied may also remain visible after you have deleted your account or deleted specific information from your own profile. Your public profile may be displayed in search engine results until the search engine refreshes its cache.
Hotfoot also provides you the option to remove individual activities you have posted without deleting your account. Once removed, the activities may remain on Hotfoot’s systems until you delete your account.
11. Your Legal Rights in the EEA: If you are habitually located in the EEA, you have the right to access, rectify, download or erase your information, as well as the right to restrict and object to certain processing of your information.
11.1 Our Legal Bases: Hotfoot relies on a number of legal bases to collect, use, share, and otherwise process the information we have about you for the purposes described in this Privacy Policy, including:
as necessary to provide the Services and fulfil our obligations pursuant to the terms of service;
where you have consented to the processing;
where necessary to comply with a legal obligation, a court order, or to exercise and defend legal claims;
to protect your vital interests, or those of others, such as in the case of emergencies; and
where necessary for the purposes of Hotfoot’s or a third party’s legitimate interests, such as our interests in protecting our members, our partners’ interests in collaborating with our members, and our commercial interests in ensuring the sustainability of the Services.
12. Retention of Information:
12.1 We retain information as long as it is necessary to provide the Services to you and others, subject to any legal obligations to further retain such information. Information associated with your account will generally be kept until it is no longer necessary to provide the Services or until your account is deleted. In addition, you can delete some items of information (e.g., profile information) and you can remove individual activities from view on the Services without deleting your account.
12.2 Information connected to you that is no longer necessary and relevant to provide our Services may be de-identified or aggregated with other non-personal data to provide insights which are commercially valuable to Hotfoot, such as statistics of the use of the Services.
13. Privacy Policy Information: Hotfoot reserves the right to modify this Privacy Policy at any time. Please review it occasionally. If Hotfoot makes changes to this Privacy Policy, the updated Privacy Policy will be posted on the Services in a timely manner and, if we make material changes, we will provide a prominent notice. If you object to any of the changes to this Privacy Policy, you should stop using the Services and delete your account.
14. Third-party links: This platform may include 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. When you leave our platform, we encourage you to read the privacy notice of every website you visit.
15. Marketing: We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
15.1 Promotional offers from us: We may use your Identity, Contact, Technical, 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 including our tools and information, routes, offers and other Services. This is how we decide which content, products, and services may be relevant for you (we call this marketing). You will receive marketing communications from us if you have registered on the Platform or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing you will receive content from our business partners (push notifications and email – you will still see banner advertising).
15.2 Third-party marketing
a) We will get your express opt-in consent before we share your personal data with any company outside Hotfoot.
b) You will receive marketing communications from our business partners if you have registered with Hotfoot or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing (push notifications and emails – you will still see banner advertising).
15.3 Opting out: You can ask us or third parties to stop sending you marketing messages at any time by logging into the platform and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on emails sent to you or by contacting us at any time at the contact details above or via the platform. This relates to push notifications or emails, but you will continue to see banner advertising within the Platform.
15.4 Cookies: You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Platform may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy for more information
16. 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.
· Internal Third Parties (other companies in the Hotfoot group acting as joint controllers or processors and who are based in the USA or elsewhere and provide IT and system administration services.
· External Third Parties (Service providers acting as processors based in the USA and elsewhere, who provide IT and system administration services).
· Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
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.
17. International transfers
17.1 We share your personal data within Hotfoot group. This will involve transferring your data outside the European Economic Area (EEA).
17.2 Our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
17.3 Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
17.4 Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details.
17.5 Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
18. Your legal rights: Under certain circumstances, you have rights under data protection laws in relation to your personal data.
18.1 No fee usually required: 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 these circumstances.
18.2 What we may need from you: 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.
18.3 Time limit to respond: We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
18.4 California Residents: This Privacy Policy complies with the California Consumer Privacy Act (CCPA), which requires that Hotfoot provide California residents with notice that you have the right to: opt-out of the sale of personal information; know about personal information collected, disclosed or sold; to request the deletion of personal information; and to be treated without discrimination should you exercise these rights. More information regarding the sources from which we collect personal information can be found in this section and the Privacy Policy; business and commercial purposes for which we collect your personal information can be found in this section and in the Privacy Policy; and categories of recipients with whom personal information is shared or sold can be found in this Agreement and the Privacy Policy. To make a request under the CCPA, or for any questions or concerns about this Privacy Policy or practices, please contact Hotfoot at info@eliteevents.ie