Introduction

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 and Conditions which sets out the terms governing the Services.

Club Locker is headquartered in Philadelphia, PA, USA, and our Services are provided to you by Global Squash Collaborative, LLC.

This policy was written in English. To the extent a translated version conflicts with the English version, the English version controls. Unless indicated otherwise, this Privacy Policy does not apply to our subsidiaries (which have their own privacy policies) or third-party products or services, including other companies you might interact with on or through the Services.

Questions or comments about this Privacy Policy may be submitted by mail or email using the contact information below.

Global Squash Collaborative, LLC
25 N 33rd St,

Philadelphia, PA 19104

Philadelphia, PA

Attn: Legal
support@clublocker.com

Information Club Locker Collects

Club Locker collects information about you, including information that directly or indirectly identifies you, if you or your other Club Locker users choose to share it with Club Locker. We receive information in a few different ways, including when you track, complete or upload results, activities, or media using the Services. Club Locker 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 Club Locker. For example:

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. We also use dates of birth to enhance safety and privacy for our younger users, to place you on age-group rankings and leaderboards, and to provide more accurate performance analysis.

Profile, activity and use information is collected about you when you choose to upload a picture, video, post, or activity, join an event, add your relationships, view others’ activities, or otherwise use the Services.

We use your contact information so we can contact you when needed. For example, to respond to your support requests.

Content You Share

We gather information from the content you share on the Services, including when you participate in partner events.

Payment Information

When you make a payment on Club Locker, you may provide payment information such as your payment card or other payment details. We use Payment Card Industry (PCI) compliant third-party payment services and we do not store your credit card information.

Third-Party Accounts

Club Locker allows you to sign up and log in to the Services using accounts you create with third-party products and services, such as Meta, 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 providers and is provided to Club Locker under their privacy policies. You should be able to control the information that we receive from these sources using the privacy controls in your Third-Party Account.

Technical Information and Log Files

We collect information from your browser, computer, or mobile device, which provides 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. Learn more about how we use cookies and manage your preferences by visiting the Cookie Policy.

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 user movement in total, and gather broad demographic information (e.g., country residence) for aggregate use. IP addresses may be linked to session IDs, athlete IDs and device identifiers.

Other Information

We may collect information directly from you or through our service providers, such as when we collect your feedback through surveys.

We may also collect information about you from other Club Locker users such as when they follow you or add you as a relationship.

How Club Locker Uses Information

Club Locker uses the information we collect and receive as described below.

To provide the Services

We use the information we collect and receive to provide the Services, including providing you with the ability to:

• Operate Club Locker (which includes sharing your personal data with GSC’s cloud service provider and IT contractors).
• Administer cross border rankings.
• Arrange and administer cross border tournaments.
• Administer the use of Club Locker by member organizations, such as Your Organization and other organizations with whom you may associate your account (this includes allocating license fees and allowing leagues, clubs, facilities, and governing bodies associated with your accounts to access your personal data, and to supply personal data about you (particularly in relation to your performance in competitive play)).
• Record your activities and analyze your performance.
• Interact with other users. For example, to manage competition, participate in clubs, challenges, or events, follow other users, message other users, and use features that help users interact with one another.
• Visualize your activities in new ways. For example, by ratings or network graphs and charts
• Share insights with the Club Locker community. For example, by sharing your publicly accessible photos or media captured at an event.
• Manage legal claims, compliance, regulatory and investigative activities as necessary (which would include disclosing personal data in connection with a legal process or litigation to law enforcement agencies or our professional advisers where we consider this is necessary).

Subject to your privacy settings, your information, including parts of your profile, username, photos/videos, users you follow and who follow you, clubs you belong to on Club Locker, and your activities, will be shared on Club Locker so that you may be able to participate in the Services, for example to show your place on a rankings list or tournament entrants list. Certain information e.g., your name, and some profile information) is also available to non-users on the web.

To customize your experience

We use the information we collect and receive to customize your experience. For example, we may suggest players to play tournaments, events, or clubs on Club Locker that may interest you, users that you may want to follow, or new features that you may want to try. For example, if we know that you play a variety of different players, we may tell you about new players in your area ready to play. Or if we see that you play in a certain area, we may suggest joining a nearby club or a tournament in that area.

To provide you with targeted promotions

We use the information we collect and receive to serve you with relevant promotions, subject to your notification and email preferences. For example, if we see you are an active user who has been on a monthly subscription plan for a long time, we may serve you a promotion to switch to a discounted annual plan. Or if you are an active user who has never subscribed, we may send you an offer for a free subscription trial.

To protect you and the Services

Club Locker reserves the right to review accounts and user actions on the Services to ensure compliance with our Terms.

To assist you with a support request

We use the information we collect and receive to provide support in response to your requests and comments. Depending on your request, this may require us to access your account, for example, to troubleshoot or replicate a reported issue.

To improve our Services

We also use the information we collect and receive to conduct research, and to analyze, develop, troubleshoot, and improve the Services. To do this, Club Locker may use third-party analytics providers to gain insights into how our Services are used, using aggregated data, and to help us improve the Services.

To communicate with you

We may also use the information we collect and receive to market and promote the Services, activities and events on Club Locker, and other commercial products or services, including using email and push notifications, in accordance with your preferences. We may also contact you for partnership opportunities, when investigating alleged violations of our terms, or to send proactive customer support messages.

To process your subscription

We use the information we collect to process your subscription, including using your location data to determine your country pricing.

How Information is Shared

We do not sell your personal information for monetary value. We may 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. In addition, we may sell or share aggregated data about our users, as described in more detail in the “Aggregate Information” section below.

Service Providers

We may share your information with third parties who provide services to Club Locker 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, to promote Club Locker or display information that may be relevant to your interests on the Services or other websites or services.

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 Club Locker to offer an integrated feature, such as media streaming or Single Sign On. You can choose to share your profile data and activity data (including private activities) with these third parties. Information collected by these third parties is subject to their terms and policies and may not provide you with the same privacy controls that are available on Club Locker.

Aggregate Information

Club Locker may deidentify and aggregate the information you and others make available in connection with the Services and post it publicly or share it with third parties. Examples include information about equipment, usage, demographics, routes, performance, and challenge participation and completion. Club Locker may use, sell, license, and share this aggregated information with third parties for research, business, or other purposes such as to improve access to or to help our partners understand more about users, including the people who use their products and services.

Legal Requirements

We may preserve and share your information with third parties, including law enforcement, public or governmental agencies, or private litigants, within or outside your country of residence, if we determine that such disclosure is allowed by the law or reasonably necessary to comply with the law, including to respond to court orders, warrants, subpoenas, or other legal or regulatory process. We may also retain, preserve or disclose your information if we determine that this is reasonably necessary or appropriate to: (1) prevent any person from death or serious bodily injury; (2) to address issues of national security or other issues of public importance; (3) to prevent or detect violations of our Terms and Conditions or fraud or abuse of Club Locker or its users (4) or to protect our operations or our property or other legal rights, including by disclosure to our legal counsel and other consultants and third parties in connection with actual or potential litigation.

Managing Your Settings

Updating Account Information

You may correct, amend, or update profile or account information at any time by adjusting that information in your account settings. If you need further assistance correcting inaccurate information, please contact Club Locker at support@clublocker.com

Children’s Privacy

Our services are not intended for, nor directed at, children under 13 years of age. We use technical measures to prevent children under 13 years of age from creating an account and therefore do not knowingly collect personal information from anybody under 13 years of age. If you are under 13 years of age, do not use the Services directly and have a parent or Guardian manage your play.

How We Protect Information

Club Locker implements technical, physical, and organizational measures and controls to safeguard and protect the transmission and storage of the data we collect. We employ reasonable protections for your information that are appropriate to its sensitivity.

Please be aware that despite our efforts, we cannot guarantee absolute security of your account or information. In addition, you can take steps to protect your account and information such as creating a unique password for Club Locker that is not easily guessed and that you do not use anywhere else, not sharing your password with others, and promptly reporting suspicious activity or unauthorized account access.

Your Rights and Our Legal Bases

We provide the same suite of privacy controls to all users worldwide. Particular rights may be available to you if you reside in certain locations, such as the EEA (European Economic Area), Brazil, or certain U.S. states such as California. Learn more about your rights and how to exercise them.

Your Legal Rights in the EEA

If you reside in the EEA, you have the right to access, rectify, download, or erase your information, and to restrict and object to certain processing of your information. Club Locker’s lead supervisory authority in the EEA is the Data Protection Commission of Ireland. Learn more.

Club Locker complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) as set forth by the U.S. Department of Commerce.  Club Locker has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF.  If there is any conflict between the terms in this privacy policy and the DPF Principles, the Principles shall govern.  To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

With respect to personal data received or transferred pursuant to the Data Privacy Frameworks, Club Locker is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.

We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your 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 support@clublocker.com.

Club Locker’s accountability for personal data that it receives in the United States under the DPF and subsequently transfers to a third party is described in the DPF Principles. In particular, Club Locker remains responsible and liable under the DPF Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with the DPF Principles, unless Club Locker proves that it is not responsible for the event giving rise to the damage.

In compliance with the DPF, Club Locker commits to resolve DPF Principles-related complaints about your privacy and our collection or use of your personal information. European Union individuals with inquiries or complaints regarding our handling of personal data in reliance on the DPF should first contact Club Locker at:  

support@clublocker.com

Club Locker has further committed to refer unresolved DPF Principles-related complaints to a U.S.-based independent dispute resolution mechanism, BBB NATIONAL PROGRAMS. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by us, please visit www.bbbprograms.org/dpf-complaints for more information and to file a complaint. This service is provided free of charge to you.

If your DPF 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  https://www.dataprivacyframework.gov/framework-article/ANNEX-I-introduction for more information on this process.

Our Legal Bases

Club Locker 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 fulfill 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 Club Locker’s or a third party’s legitimate interests, such as our interests in protecting our users, our partners’ interests in collaborating with our users, and our commercial interests in ensuring the sustainability of the Services.

Cross Border Data Transfers

The Services are operated from the United States. If you are located outside of the United States and choose to use the Services or provide information to us, you acknowledge and understand that your information will be transferred, processed, and stored in the United States, as it is necessary to provide the Services and perform the Terms of Service.

Whenever we transfer personal data internationally, we use legal mechanisms, such as Standard Contractual Clauses, to ensure data transfers comply with applicable law.

Retention of Information

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 be kept until it is no longer necessary to provide the Services or until your account is deleted or becomes inactive. In making these determinations, we consider the amount, nature, and sensitivity of personal information, the purposes for which the information is processed, whether we can achieve those purposes through other means, and applicable legal requirements.

Additionally, we may retain information to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, enforce the Terms of Service and take other actions permitted by law. The information we retain will be handled in accordance with this Privacy Policy.

Information connected to you that is no longer necessary and relevant to provide our Services to you may be de-identified or aggregated with other non-personal data to provide insights that are commercially valuable to Club Locker, such as statistics of the use of the Services. For example, we may retain publicly available results or ratings and other depersonalized geolocation information to continue to improve the Services. This information will be de-associated from your name and other identifiers.

Privacy Policy Updates

Club Locker reserves the right to modify this Privacy Policy at any time. Please review it occasionally. If Club Locker makes changes to this Privacy Policy, the updated Privacy Policy will be posted in a timely manner. If we make changes that we deem to be material, we will provide a prominent notice or message via email. If you object to any changes to this Privacy Policy, you should stop using the Services.