# **URC MAIN PRIVACY POLICY** The URC is operated and administered by Pro Rugby Championship DAC Registered Office URC Pro Rugby Championship DAC 3rd Floor Millbank House Arkle Road, Sandyford Industrial Estate Dublin 18 D18 C6R3 Ireland. ## **What does this policy cover?** This policy describes how Pro Rugby Championship DAC (which own and operates URC) (collectively referred to as “we” or “us”) will make use of your data on the URC website and during your interaction with Pro Rugby Championship DAC online and offline, including purchasing tickets for URC games or hospitality, data we may process in connection with the running of competitions or online games, data we may process if you attend our games or events, data we may handle if you supply or partner with Pro Rugby Championship DAC or data we use to send you direct marketing. It also discusses how we make use of information that we may receive from third parties about you, such as our clubs, other rugby stakeholders, partner broadcasters or fantasy game partners. It also describes your data protection rights, including a right to object to some of the processing which Pro Rugby Championship DAC carries out. More information about your rights, and how to exercise them, is set out in the “What rights do I have?” section. ## **Summary of how we use your data** - Pro Rugby Championship DAC uses your personal data to allow you to use the features in URC content, to administer your online and offline relationships with Pro Rugby Championship DAC, to manage the safety and security of our events, to assess our engagement with our fans and offer them enhanced services and marketing, to comply with Pro Rugby Championship DAC’s legal obligations and to provide you with URC products, services and other offerings. Some of this information will be provided by you, and others will be generated by Pro Rugby Championship DAC or provided by third parties. - Our websites may provide interactive features that engage with social media sites, such as Facebook and Twitter. If you use these features, these sites will send us personal data about you. - We use cookies and other tracking technologies to personalise content and advertising and to make our content function better. More details of this are set out in our [Cookie Policy](https://unitedrugby.com/cookie-policy). - Where we rely on your consent, such as for some direct marketing purposes, or to place cookies, you can withdraw this consent at any time. - Our privacy policy sets out more details of this processing, including details of your data protection rights, including your right to object to certain processing. ## **What information do we collect?** We collect and process personal data about you when you interact with us and our websites, when you purchase goods and services from us, where you visit competition venues, when we carry out market research and when you enter our competitions or participate in our online games. This data will typically be provided directly by you and may include information you provide on registration or in the process of a purchase, such as your name, address, email address, and marketing preferences. The details being provided by you will be made clear in forms you complete or will be provided directly by you in surveys, in purchasing tickets, in entering competitions or in volunteering information in communications or content you provide us. ## **What information do we generate or receive from third parties?** We may generate or collect information about you ourselves. In an online context, much of this is set out in our [Cookie Policy](https://unitedrugby.com/cookie-policy). In an offline context, we may particularly collect information about you where you are an employee of a supplier, stakeholder or club with whom we communicate, or where you attend an event or game organised by Pro Rugby Championship DAC. Sometimes, we receive information about you from third parties. For example, if you login to a site or app using Facebook Connect you will be asked if you wish to share information from your Facebook account with us. If you use a “like” or a “share” button for a feature on our sites or apps, then the third party will share information with us. If you participate in activities on non-Pro Rugby Championship DAC sites or apps – such as participating in a Facebook application – you may allow us to have access to personal data held by Facebook, or other site or app owners. We sometimes will receive relevant information from third party ticketing sites, such as Ticketmaster, to manage your purchases. We may also obtain information about you from third party demographics providers, which we may use to help us better understand our users and send them appropriate offers and information. We also receive some information about our fans on the other ways they engage with URC content, or with other rugby stakeholders such as Unions or other rugby tournament hosts. This includes information from Clubs and other rugby stakeholders on how their fans purchase tickets or engage with their sites and services, from broadcasters on their engagement with premium services or from fantasy games where they have a team. This sharing is described in the sites and policies of those third parties. We typically collect information on your engagement, including details of your transactions although not about your payment details. We use this to better understand our own fans, and to help create more detailed profiles to help offer them more tailored products and marketing. If we provide online services to a child where we need parental consent for this, we may ask for a parent’s email address, in order to ask for consent. Where you are participating in a Pro Rugby Championship DAC event or competition, we may receive information about you from another team member or official responsible for entering you or your team into our competition. This will typically involve basic biographical information, including your contact email address. ## **How do we use this information, and what is the legal basis for this use?** We process this personal data for the following purposes: **To fulfil a contract, or take steps linked to a contract: this is relevant where you make a purchase from us or enter a competition or online game we run. This includes:** - verifying your identity; - receiving confirmation of payment; - communicating with you; - administering the competition or game (where relevant); and - providing customer services and arranging the delivery or other provision of products, prizes or services. **As required by Pro Rugby Championship DAC to conduct our business and pursue our legitimate interests, in particular:** - we will use your information to provide products and services you have requested and to respond to any comments or complaints you may send us; - we monitor use of our websites and online services, and receive information from our partners, Clubs and other rugby stakeholders, and use your information to help us monitor, improve and protect our products, content, services and websites, both online and offline; - we use information you provide – or provided by third parties about you - to personalise our website, games, products, services or marketing for you; - we use information we hold about you to send you direct marketing, such as online adverts, unless the law requires that we obtain your consent for that marketing; - we use information you provide as well as information which we have collected about you to investigate any complaints received from you or from others, about our website and competition venues or our products or services; - we will use data in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation); and - we use data of some individuals to invite them to take part in market research. ## **Where you give us consent:** - we will send you direct marketing in relation to our relevant products and services, or other products and services provided by us and carefully selected partners and sponsors; - we place cookies and use similar technologies in accordance with our [Cookie Policy](https://pro14.rugby/cookie-policy) and the information provided to you when those technologies are used; and - on other occasions where we ask you for consent, we will use the data for the purpose which we explain at that time. ## **For purposes which are required by law:** - where we are required to hold or collect personal data to meet legal requirements on us, such as keeping health and safety records, details of purchases or ensuring banned fans are not given access to our competition venues; - where we need parental consent to provide online services to children under 16. However, most of our websites are not designed for children under 16 and most of our services do not require consent; and - where in response to requests by government or law enforcement authorities conducting an investigation. ## **Withdrawing consent or otherwise objecting to direct marketing** Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests. You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by following the instructions in the communication where this is an electronic message, or by contacting us using the details set out below. ## **What cookies and/or tracking technologies does Pro Rugby Championship DAC use?** When you visit one of our websites, or the sites of our Clubs and partners, we may also collect, process and use information about you and your use of the website, including any forums you visit and how you arrived at our site. Such information may be collected through “traffic data” and may entail the use of “cookies” or other tracking technologies, IP addresses or other numeric codes used to identify your computer. For more information on Cookies please click on the link to our [Cookie Policy](https://unitedrugby.com/cookie-policy). ## **Apple iOS and Android Devices** By accessing a Pro Rugby Championship DAC application from these devices you consent to cookies being stored to your device (and other tracking technologies being used to read data from your device) for the following purposes: keeping you logged in, ensuring that an appropriate version of content is presented, analytics and advertising. Many of these cookies and technologies are essential to the operation of the application. It is not currently possible to opt out or remove these cookies (or prevent use of these technologies) from the device without deleting the application. ## **Who will we share this data with, where and when?** We share data of our fans with other rugby stakeholders, such as Clubs, Unions and other leagues, such as Premiership Rugby. We do this to allow us each to assess our fan base and improve our products and services. The use of your data by these other stakeholders is described in the privacy notices of the stakeholders with which you interact. We may also, where you have given a valid marketing consent, share your personal data with Clubs, partners or rugby stakeholders from whom you want to receive offers and updates. We will also share data with the owners of our competition venues as necessary to ensure that your attendance is appropriately managed and we will share appropriate data with third party ticketing providers as necessary to manage our ticketing processes. Personal data may be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable laws. Personal data will also be shared with third party service providers, who will process it on behalf of Pro Rugby Championship DAC for the purposes identified above. Such third parties include providers of website hosting, security services, maintenance, call centre operations and identity checking. Some of our suppliers may be separate data controllers, such as market research organisations, and may provide you with their own privacy notice where appropriate. Where information is transferred outside the EEA, and where this is to a stakeholder or vendor in a country that is not subject to an adequacy decision by the EU Commission, data is adequately protected by EU Commission approved standard contractual clauses, an appropriate Privacy Shield certification or a vendor’s Processor Binding Corporate Rules. A copy of the relevant mechanism can be provided for your review on request by contacting us using the details set out below. Where data is transferred outside the EEA due to your purchase of tickets to a game taking place outside the EEA, such as for events taking place in South Africa, this data is transferred as necessary to facilitate your travel and attendance and fulfill your contract. ## **What rights do I have?** You have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us for a contract or with your consent in a structured, machine readable format. In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing). These rights may be limited, for example if fulfilling your request would reveal personal data about another person, where it would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are included in both the GDPR and in the Data Protection Act 2018. We will inform you of relevant exemptions we rely upon when responding to any request you make. To exercise any of these rights, you can get in touch with us – or our data protection officer – using the details set out below. If you have unresolved concerns, you have the right to complain to an EU data protection authority where you live, work or where you believe a breach may have occurred. This likely to be the Information Commissioner’s Office in the UK. Data that is mandatory is indicated on relevant forms that you complete. Where provision of data is mandatory, if relevant data is not provided, then we will not be able to fulfil your requests to register, make a purchase or otherwise engage with Pro Rugby Championship DAC. All other provision of your information is optional. ## **How do I get in touch with you, or your data protection officer?** We hope that we can satisfy queries you may have about the way we process your data. If you have any concerns about how we process your data, or would like to opt out of direct marketing, you can get in touch at [privacy@unitedrugby.com](mailto:privacy@unitedrugby.com) or by writing to: Data Protection, URC, Third Floor, Millbank House, Arkle Road, Sandyford Industrial Estate, D18 C6R3, Ireland. ## **How long will you retain my data?** Where we process data in connection with your registration to use URC sites or services, such as our single sign-on solution, we do this for as long as you are a user of our sites – ie. until you choose to close your accounts or opt-out of our use of your data. Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data indefinitely so that we can respect your request in future. Where we process personal data in connection with performing a contract, online game or for a competition but have not created an account, we keep the data for 7 years from your last interaction with us or from when the contract ends. Where we process personal data to meet legal requirements, we hold this for as long as the law requires. Effective Date: This Privacy Policy was updated on 01 November 2022 and is effective as of that date.
