Privacy & GDPR Policy: Smart Club Cloud User Agreement  

New Data Protection Regulations  May 2018

 You may have heard of the new General Data Protection Regulation (GDPR) which applies from 25th  May 2018.  The new regulation impacts greater on the responsibilities of your club than it does on Smart Club Solutions, and to this end our solutions can assist your club in meeting its GDPR requirements.  We are providing the tools for the club to effectively manage their data and carry out and use the database and related solutions in a professional manner.  

However, there are occasions where we process data or facilitate the processing of data so we are providing you with some additional information below.  This policy aims to clearly outline how and why we collect, manage and process data in fulfilment of the GDPR Accountability Principle.  Our solutions span a range of areas and implementations vary from club to club so some of the points below may not apply to your club.  

What member data do we hold in our Smart Club Cloud?  

Our Smart Club Cloud enables members to carry out a range of secure financial transactions online.  Such transactions are processed by other reputable third party payment processors, so the only sensitive member information actually held in our Cloud is the following: Firstname, Surname, Date of Birth and Email address.  This information is required to assist login verification and to match transactions with the relevant member in the club database.  It has either been entered by you as part of an online registration process in our Cloud, or it has been provided to us by the club.  No bank account or card details are stored in the Cloud.  Indeed, such information is only entered and live for the period of the transaction by the payment processor.   You may consult our full Business Privacy Policy and Security Policy for further technical information.  

How and why we process data in our Cloud with Third Parties  

While we may host and/or may backup club data, Smart Club Solutions does not access (unless requested by the club) or share data with any other party.  However, elements of our Smart Club Cloud solution involve third party processing of members data or club data:  

• Cloud 1: Stripe Payments Platform:  One of our Cloud options whereby members can carry out club-related transactions online.  Members complete their transaction on a secure site and we do not have access to their bank information which is processed via Stripe Payments.    
• Cloud 2: Realex Payments / Bank Internet Merchant Account: Similar to the previous point, ocessed via the secure Realex Payments portal and we do not have access to such information.
• ClubManager365.com: From time-to-time we also integrate with relevant providers of complementary software in order to enhance the overall solution for our clubs and members.  One such integration at present is with ClubManager365.com for online booking at our tennis clubs.  online booking partner so the data management is covered by    
• Other third party solutions: We will update this document with any additional third party integrations at the appropriate time.  

We will review any contracts which from time to time we may have in place which involve sharing data with other companies and we will generate appropriate documentation to demonstrate accountability and compliance.

No Smart Club Solutions opt-in or consent needed!  

We have an agreement with your Club, under which we agree to deliver an effective membership management solution.  It is very likely that you will have had to agree to club policies and terms and conditions as part of your membership application/procedure.  Our Smart Membership program and Smart Club Cloud, enables clubs to gain required consents from their members by uploading the relevant policies and asking members to indicate their agreement.  

So, your agreement and consent is between you and the club.  Your club may seek explicit consent from you to opt-in to certain communications and services, or it may be implied that that you agree to such services by virtue of becoming a Club member and in line with the successful delivery of club services  it is part of their contract with you and it is in your interest.  Y solution which we provide and deliver.        

General  

• Again, while much of the onus for policy development and implementation under GDPR falls on your club, Smart Club Solutions will continue to deliver the products and services to help your club meet these requirements.
• We aim to design and deliver solutions which have data protection as a core guiding principle.
• We communicate with our clubs and members to make you aware of any relevant changes to our solutions which impact on GDPR, privacy and data protection.
• We continually monitor our systems for security purposes and in the event of any breach we will inform relevant parties
• There are instances when we may have database but it is the responsibility of your club to cover such instances in its own privacy and data protection policy.  Further information is in our Business Privacy & Data Protection Policy.
• You have certain rights under GDPR in relation requesting access to, removal of and complain about data your club may hold.  You may also contact us to ask what data we hold on you but as outlined above this will be minimal if any.  Your club controls your data and you should contact them if you wish it to be verified, amended or removed.  You can also view and amend some of your preferences and personal data by logging into our Cloud.  
• Each club will have its own rules in relation to age verification and policies re. parental consent for data processing, communications, etc.  Our solutions assist in such data management.   Other Policies:

Our updated Business Privacy Privacy & Data Protection Policy, Website User Policy and Security Policy will also soon be added to our website at www.SmartClubSolutions.com.