Privacy Policy

Global Squash Collaborative and its U.S.-based subsidiary Reciprocitie LLC (“GSC”, “We” or “Us”) is committed to protecting the privacy of those who use clublocker.com (the “Website”) and the Club Locker software as provided to you on the Website or via a downloadable application (“Club Locker” or the “Software”).  Please take the time to read this Privacy Policy and learn how we collect, use and share your information, and what you can do to control your information and how we use it.

This Privacy Policy applies when you visit the Website or use the Software. By using the Software and accessing the Website, you agree to the terms of this Privacy Policy, Terms of Use and the End User License Agreement. Club Locker’s features require users to interact with other users, and so to use Club Locker and access its features, you are required to register for an account. Registering for an account will require you to submit certain information to us, described in more detail below.

Whenever you submit information via Club Locker or visit the Website, you consent to the collection, use and disclosure of that information in accordance with this Privacy Policy, Terms of Use and the End User License Agreement and any specific terms that may be presented at the time such information is collected. If you do not agree to this Privacy Policy for any reason, please do not use this Website, the Software or share your Personal Data (defined below) or other information with us by registering for an account on the Website. 

Limitations

Please note that this Privacy Policy applies only to the Software and the Website, and not to any other website that we link to or that links to our Website. We do not control the privacy policies or privacy practices of others. We encourage you to ask questions and read the privacy policies of other websites before you disclose any personal information to them.

Data Transfers

Your information, including Personal Data (as defined below), may be transferred to countries other than the one you reside in for storage or processing in accordance with this Privacy Policy, Terms of Use and the End User License Agreement. By using the Website or the Software, you consent to us transferring your data to these other countries. We comply with applicable laws with respect to transfer of information of European Union Residents outside of the European Union. For more information, please read our “EU-US Privacy Shield” section below.

Updates

If we update our Privacy Policy, we will post the updated Privacy Policy on the Website and notify our registered users. Any such changes will be effective upon posting. You should consult the “Privacy Policy” link on the Website each time you visit the Website. You agree that your exclusive remedy for disagreement with this Privacy Policy (and any updates to the Privacy Policy) is to discontinue use of the Software and Website.

What Information We Collect

We collect a variety of information about the users of Club Locker and the Website, including Personal Data, in a number of ways.  “Personal Data” is any information that personally identifies you, or one or more factors specific to you, either directly or indirectly, in particular by reference to an identifier such as your name, an identification number, telephone number, postal address, location data, email address, or online identifier (or other information that is associated by us with such information).  We may also collect other information that does not personally identify you.  Below is a more detailed explanation of the types of data we collect from you.

  • When you register on the Website or are otherwise using the Software, we will ask you to provide certain information such as a username, first and last name, birth date, phone number, email address, and other contact information. We may also ask for certain information like your name, email address and other contact information if you try to contact us using the Website.  This information is required so that registered users can properly interact with each other using the Software.
  • After you register, you may choose to add to your user profile by providing additional information such as your height, weight, photograph and/or video and other biographical or Personal Data, and information about your athletic performance or information relating to your team, league, facility or organization (“Profile Information”). We may also collect information that is provided by your team, league, facility or organization. For example, we collect information regarding your win and loss records and matches, which may be entered into the Software or through the Website, by you or your team, league, facility or organization. We also store and may analyze communications sent using the Software or through the Website.
  • We may receive information about you when you interact with our pages on various social media outlets, for example, by logging in through or liking us on Facebook or following us on Twitter. The data we receive from these outlets is dependent upon your privacy settings with the applicable social network. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to the Software. We do not control the privacy policies or settings of these third parties.
  • We automatically collect information about how you use our Website and Club Locker. For instance, when you visit the Website, we may send one or more cookies—a small text file containing a string of alphanumeric characters—to your computer that uniquely identifies your browser and lets us help you log in faster and enhance your navigation through the Website. A cookie, and other similar tracking technologies that we may use, may also convey information to us about how you use the Website and the Software (e.g., the pages you view, the links you click, how frequently you access Club Locker, and other actions you take on the Website and while using Club Locker), and allow us to track and analyze your use of the Website and Software over time. We may also collect log file information about your browser or mobile device each time you access Club Locker. Log file information may include information such as your web request, Internet Protocol (IP) address, browser type, information about your mobile device, referring/exit pages and URLs, number of clicks and how you interact with links on the Website and the Software, domain names, landing pages, pages viewed, and other such information. When you access Club Locker by or through a mobile device, we may receive or collect and store a unique identification number associated with your device, mobile carrier, device type and manufacturer, phone number, and, depending on your mobile device settings, your geographical location data, including GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of your mobile device.
  • We use Google Analytics to collect information about your use of the Website. Google Analytics collects information such as how often users visit the Website, what pages users visit, and what other sites they visited prior to or after coming to the Website. More information on how Google Analytics uses your data can be found at www.google.com/policies/privacy/partners/. We use the information we get from Google Analytics to improve the Website. By using the Website with your browser set to accepting cookies, you consent to our and Google Analytics’ use of cookies on the Website. We do not use Google Analytics’ user-specific behavior tracking function.
  • We use services provided by Intercom, Inc. (“Intercom”) to help understand your use of our Website and Club Locker so we can improve our service to you. In particular, we provide a limited amount of your information (such as your email address and sign-up date) to Intercom and utilize Intercom to collect data for analytics purposes when you visit our website or use our product. [We may also use Intercom as a medium for communications, either through email or messages within our product(s).] As part of our service agreements, Intercom collects publicly available contact and social information related to you, such as your email address, gender, company, job title, photos, website URLs, social network handles and physical addresses, to enhance your user experience. For more information on the privacy practices of Intercom, please visit https://www.intercom.com/terms-and-policies#privacy. Intercom’s services are governed by Intercom’s Terms of Use, which can be found at https://www.intercom.com/terms-and-policies#terms. [If you would like to opt out of having this information collected by or submitted to Intercom, please contact us at membership@clublocker.com.]

How We Use Your Information
We may use information you provide to improve the Website and/or Club Locker or for general purposes, such as managing Club Locker and its registered users; processing payments; furthering collaborative and competitive play amongst registered users; customizing the display of the Software and Website to your preferences; communicating information to you (if you have requested it or if it is a Club Locker-related email); for our marketing and research purposes; otherwise enhancing the Website, Club Locker and our services; diagnosing or fixing technology problems; monitoring aggregate metrics; and for other purposes specified in this Privacy Policy.

If you provide Personal Data to us, we may combine such information with other information we collect from you.

We may use your information for marketing or advertising purposes, or to allow third parties to contact you with information about products and services you may find useful with your consent.  You can always opt-out of e-mails from us by clicking the link at the bottom of your email or emailing us at membership@clublocker.com.  However, certain email communication may be required for your use of the Software, such as notifications about your account or updates to our policies – you cannot opt out of these emails as long as you are a registered user.

We also reserve the right to use any information we collect in any manner permitted or required by law.

We retain aggregate and de-identified data indefinitely. We maintain your Personal Data, Profile Information and other information so long as you have not cancelled your account through the provided mechanism on the Website or in the Software. We may maintain certain information after you cancel your account for reasonable purposes, such as to complete pending or outstanding payments, or as a part of the match history of other users.

Sharing Your Information

We do not disclose any of your information with non-affiliated companies, except to provide products or services you have requested, when we have your consent, or under the following circumstances:

  • We will use or disclose your information when we believe that such disclosures are required by law, regulation, legal process, subpoena, document request or governmental request. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
  • We may share your information when we believe it is necessary to investigate, prevent, or take any action regarding illegal activities or threats to the safety or property of any person (including that of property that belongs to you, us or third parties), or a potential breach of our Terms of Use, Privacy Policy or End User License Agreement.
  • We share your information, including Personal Data, with our affiliates and other trusted business partners and service providers for purposes of processing and storage, in connection with the operation of the Software and Website, including processing payments. These third parties may use your information to help us communicate with you about offers from us and our marketing partners, but these third parties do not have a right to otherwise share your information. These partners may include a league, club, or facility that you have associated with your account.
  • We may also share aggregate and other non-Personal Data with trusted third parties for purposes of marketing or advertising, to review the algorithmic efficacy for ratings and rankings, or to assist us with improving Club Locker.
  • In the event that we, or our assets, are acquired by or merged with another entity, whether an affiliate or a third party, your Profile Information, Personal Data and other information may be one of the transferred assets. We may transfer all such information to our acquirers or successors.
  • GSC’s accountability for personal data that it receives under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, GSC remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless GSC proves that it is not responsible for the event giving rise to the damage.

Security of the Information You Share with Us

The security of your information is important to us. We will take reasonable steps to protect your Personal Data and your other information from loss, misuse and unauthorized access, disclosure, alteration or destruction in accordance with this Privacy Policy, applicable laws, our Terms of Use, and the End User License Agreement. You should keep in mind that no Internet transmission is ever 100% secure or error-free. In particular, email sent to or from Club Locker may not be secure, and you should therefore take special care in deciding what information you send to us via email.

Moreover, you are solely responsible for maintaining the confidentiality of your passwords, account information, user names, and/or security questions and answers for the Website, and for logging off any protected areas of the Website when you finish a session. You should notify us immediately if you become aware of the unauthorized use of your user account, username or password. You are responsible for all use of your user account and/or user name. If you share your password with anyone, you assume all responsibility for that person’s activity related to the Website or Club Locker.

Children

The Website and Software may collect information that is reasonably necessary for children under the age of 13 to use the Website and Club Locker, only after they have obtained parental consent. We will not knowingly request information from persons under the age of 13 without parental consent. Please do not provide any information to us for any reason, or use the Website or Software, unless you are at least 13 years of age, or if you have parental consent (which is required to register for an account using the Website or Software). Parents should caution their children not to provide any information or use the Website or the Software unless they have received a parent’s express consent. A parent may revoke his or her consent, even once it has been given, at any time by sending an email to membership@clublocker.com.

Consistent with the Children’s Online Privacy Protection Act, if a child under 13 has provided personal information to us through the Website or Software without verifiable parental consent, a parent or guardian may inform us at membership@clublocker.com, and we will use commercially reasonable efforts to delete such information, subject to applicable law and this Privacy Policy. Parents of children under 13 who have registered with the Website and/or Software with parental permission may still request deletion of all or part of their child’s collected information by sending an email to membership@clublocker.com, upon which request we will promptly use commercially reasonable efforts to delete such information from our databases, subject to applicable law and this Privacy Policy. Further, we have enabled a function on the Website and Software that allows parents the option to “hide” all of their children’s information from being publicly published on the Website or Software and to stop future collection of their children’s data.

Please note that we consider the disclosure of any collected information to third-party analytics services (e.g. Google Analytics) to be integral to our services. Information that is collected will only be retained for as long as is necessary to fulfill the purpose for which it was collected before being deleted. If you do not consent to your child’s information being shared with third-party analytics services, you should not consent to your child’s use of the Website or Software. You can always change your mind and email us at membership@clublocker.com if you would like to withdraw your consent or have us use our commercially reasonable efforts to remove your child’s information from the Website and/or Software, subject to applicable law and this Privacy Policy.

Information submitted by children with proper parental consent will be used and shared pursuant to the other terms of this Privacy Policy.  Because Club Locker’s functionality is based upon sharing information amongst a network of users, parents that consent to their child’s use of the Software and Website also consent to sharing within the network; however, parents may at any time contact us at membership@clublocker.com and ask us to cancel their child’s account and delete their child’s information, subject to applicable law and this Privacy Policy.

Control and Access to Your Information

You can control your receipt of email and other messaging by visiting the “Settings” page on our Website. We may send you Club Locker related emails or messages (e.g., account verification, payment confirmations, change or updates to features of the Software, or technical and security notices). While you may opt out of certain emails, you may not opt-out of these Club Locker-related emails unless you cancel your Club Locker account.

You may close your account using the mechanism provided to you on the Website or the Software.

To request changes to or removal of any information, you may contact us at membership@clublocker.com.  We will comply with requests that we believe are reasonable, and in any case to the extent we are required to comply with such requests pursuant to applicable law or this Privacy Policy.

Our users who may request and obtain from us a list of what Personal Data (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made once a year and are free of charge.  Please email us at membership@clublocker.com for any such requests.

EU individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States.  Upon request, we will provide you with access to the personal information that we hold about you.  You may also may correct, amend, or delete the personal information we hold about you.  An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to  info@clublocker.com.  If requested to remove data, we will respond within a reasonable timeframe.

We will provide an individual opt-out or opt-in choice before we share their data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized.  To request to limit the use and disclosure of your personal information, please submit a written request to  info@clublocker.com.

Do Not Track Signals

We do not respond to Do Not Track (“DNT”) signals. This means we do not treat your information differently if you have activated a setting to send a DNT signal on your web browser.

Some third-party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser allows you to set the DNT signal so that third parties (particularly advertisers) know that you do not want to be tracked. You should consult the “help” page of your browser to learn how to set your preferences so that websites do not track you.

Other Terms
Your use of Club Locker and the Website is subject to the Terms of Use and End User License Agreement. If you choose to use the Website or the Software, your visit and any dispute over privacy and data collection is subject to this Privacy Policy, Terms of Use and our End User License Agreement, including limitations on damages and the application of the laws of the State of New York.

EU-U.S. Privacy Shield
GSC complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries transferred to the United States pursuant to Privacy Shield.  GSC has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, GSC is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.

In compliance with the Privacy Shield Principles, GSC commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union individuals with Privacy Shield inquiries or complaints should first contact support at info@clublocker.com.

GSC has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers  for more information and to file a complaint. This service is provided free of charge to you.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms.  See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction

How to Contact Us
If you have any questions, comments or concerns about this Privacy Policy or the information practices of the Website or Club Locker, please contact us as follows:

Reciprocitie, LLC
Attention: Ryan Rayfield
555 Eighth Avenue, Suite 1102
212.268.4090
ryan.rayfield@clublocker.com

This Privacy Policy was last updated: 5/21/18.