Privacy Policy

1.2Your Data Controller

Rinquest Ltd is your Data Controller and responsible for your Personal Data. We are not obliged by the GDPR to appoint a data protection officer and have not voluntarily appointed one at this time. Therefore, any inquiries about your data should either be sent to us by email to saaket@rinquest.com or by post to Ranmore House, Hook Heath Road, Woking, GU22 0DT, United Kingdom.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

1.3Children and Young People

Rinquest is a grassroots sports discovery and recruitment platform and may be used by children and young people under the age of 18 to create or participate in player profiles and to identify suitable sports teams, clubs and opportunities.

We recognise that children require additional protection when their Personal Data is collected and used. We therefore apply additional safeguards to the processing of Personal Data relating to children and young people.

Age and parental involvement

Rinquest uses age information to determine the appropriate safeguards and permissions applicable to a user.

Our current approach is:

• Users under 13: a parent or person with parental responsibility must create or authorise the child's Rinquest account and provide the required permissions before the child's Personal Data is used to provide the service.
• Users aged 13 to 15: Rinquest requires involvement and validation from a parent or person with parental responsibility before the young person can use the service.
• Users aged 16 and 17: the young person may use Rinquest in their own right, although Rinquest may involve or request a parent or guardian where appropriate to the circumstances, the user's safety or our safeguarding processes.
• Users aged 18 or over: the user may create and manage their own account.

These arrangements are intended to provide additional protection for younger users and may be updated where our service, risk assessment or applicable law changes.

Where parental authorisation is required, Rinquest may collect and retain information necessary to establish the identity and contact details of the parent or person with parental responsibility and to maintain a record of the authorisation provided.

Information relating to children

Depending on how Rinquest is used, information relating to a child may include:

• name and date of birth;
• contact details;
• age and age group;
• playing position and preferred position;
• playing level, ability and playing history;
• availability and location information necessary to identify suitable sporting opportunities;
• player profile information and photographs where provided;
• communications made through the Rinquest platform;
• matching and recruitment information;
• information relating to parental or guardian permissions; and
• technical and usage information required to operate and secure the service.

We only collect information that is reasonably necessary for the purposes described in this Privacy Policy.

Why we use children's Personal Data

We use children's Personal Data primarily to provide Rinquest's sports discovery and recruitment services, including:

• creating and maintaining player profiles;
• helping players identify suitable teams and clubs;
• helping teams and clubs identify suitable players;
• matching players with relevant sporting opportunities based on information such as age, position, location and playing level;
• enabling appropriate communication relating to sports recruitment and opportunities;
• administering parental permissions and age-related safeguards;
• maintaining the security and integrity of the platform; and
• complying with applicable legal and regulatory requirements.

We will not use children's Personal Data for a purpose that is incompatible with the purpose for which it was collected.

Lawful basis

Rinquest will identify and document an appropriate lawful basis under UK data protection law for each relevant processing activity.

Where Rinquest relies on consent as the lawful basis for providing an online service directly to a child, the additional requirements applying to children under 13 will be followed, including obtaining appropriate parental authorisation and making reasonable efforts to verify that authorisation.

Where another lawful basis is relied upon, Rinquest will ensure that the basis is appropriate to the particular processing activity and the rights and interests of the child.

Privacy and visibility

Rinquest will apply privacy and safety measures appropriate to the age and circumstances of child users.

We will seek to ensure that children's Personal Data is not made publicly available more widely than is reasonably necessary for the operation of the service.

Where appropriate, Rinquest may use age-related settings, access controls, parental controls and other technical or organisational measures to reduce unnecessary exposure of children's Personal Data.

We will not knowingly encourage children to make their Personal Data more widely available than is necessary to participate in the service.

Children's best interests

When processing children's Personal Data, Rinquest will consider the best interests of the child as an important consideration in the design and operation of the service.

We will consider the differing needs and levels of understanding of children at different ages and will seek to provide privacy information and controls that are understandable and appropriate to those users.

Parents and guardians

Parents and persons with parental responsibility may contact Rinquest at saaket@rinquest.com regarding a child's use of the service or the Personal Data we hold about the child.

Subject to applicable data protection law and appropriate verification of identity and parental responsibility, a parent or guardian may request information about the child's Personal Data and may exercise applicable data protection rights on the child's behalf where legally permitted.

Where a parent or guardian has provided authorisation for a child to use Rinquest, they may also contact us regarding that authorisation.

Rinquest may need to verify the identity of the person making a request before disclosing or changing Personal Data.

Age assurance and parental verification

Rinquest may use proportionate measures to establish or verify a user's age and, where required, to establish or verify parental authorisation.

The nature of any verification will depend on the risks associated with the relevant processing and the information reasonably required to establish that the appropriate person has provided authorisation.

We will seek to minimise the amount of Personal Data collected for age or parental verification and will not retain verification information for longer than reasonably necessary for the purpose for which it was collected, subject to legal or regulatory requirements.

Children's privacy information

Rinquest will seek to provide privacy information in clear and accessible language and, where appropriate, provide additional explanations or notices designed to help younger users understand how their Personal Data is used.

Parents and guardians should read this Privacy Policy with the child where appropriate and discuss with them how their Personal Data will be used on Rinquest.

1.4Processing data on behalf of a Controller and processors' responsibility to you

In discharging our responsibilities as a Data Controller we have employees who will deal with your data on our behalf (known as “Processors”). The responsibilities below may be assigned to an individual or may be taken to apply to the organisation as a whole. The Data Controller and our Processors have the following responsibilities:

• Ensure that all processing of Personal Data is governed by one of the legal bases laid out in the GDPR (see 2.2 below for more information);
• Ensure that Processors authorised to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality;
• Implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk associated with the processing of Personal Data;
• Obtain the prior specific or general authorisation of the Controller before engaging another Processor;
• Assist the Controller in the fulfilment of the Controller's obligation to respond to requests for exercising the data subject's rights;
• Make available to the Controller all information necessary to demonstrate compliance with the obligations laid down in the GDPR and allow for and contribute to audits, including inspections, conducted by the Controller or another auditor mandated by the Controller;
• Maintain a record of all categories of processing activities carried out on behalf of a Controller;
• Cooperate, on request, with the supervisory authority in the performance of its tasks;
• Ensure that any person acting under the authority of the Processor who has access to Personal Data does not process Personal Data except on instructions from the Controller; and
• Notify the Controller without undue delay after becoming aware of a Personal Data Breach.

2.2The Legal Basis for Collecting That Data

There are a number of justifiable reasons under the GDPR that allow collection and processing of Personal Data. The main avenues we rely on are:

• “Consent”: Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy to receive email newsletters from us, or 'opt in' to a service.
• “Contractual Obligations”: We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service.
• “Legal Compliance”: We're required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions.
• “Legitimate Interest”: We might need to collect certain information from you to be able to meet our legitimate interests - this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests. Examples could be your address, so that we know where to deliver something to, or your name, so that we have a record of who to contact moving forwards.

3.2Marketing and content updates

You will receive marketing and new content communications from us if you have created an account and chosen to opt into receiving those communications. From time to time we may make suggestions and recommendations to you about goods or services that may be of interest to you.

3.3Change of purpose

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

4.2Your control over Rinquest Ltd's use of your Personal Data

You may delete your account at any time – this will remove your account page from our systems and our related software.

We do not guarantee the ability to delete all stored data. If you would like us to delete/correct personally identifiable data, let us know and we will action your request as soon as practicable.

You can access information associated with your account by logging into your account you created with us.

Your account information will be protected by a password for your privacy and security. You need to prevent unauthorized access to your account and personal information by selecting and protecting your password appropriately and limiting access to your computer or device and by signing off after you have finished accessing your account.

California Privacy Rights: Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to saaket@rinquest.com.

4.3How Rinquest Ltd protects customers' Personal Data

We are concerned with keeping your data secure and protecting it from inappropriate disclosure. We implement certain security measures to ensure the security of your Personal Data on our systems, including using HTTPS/TLS to encrypt data transmitted between users and our services, restricting access to our servers and databases through firewall and access-control measures, implementing authentication and authorisation controls, applying security updates and patches, and monitoring our systems for unauthorised access and malicious activity. Any Personal Data collected by us is only accessible by a limited number of employees who have special access rights to such systems and are bound by obligations of confidentiality. If and when we use subcontractors to store your data, we will not relinquish control of your Personal Data or expose it to security risks that would not have arisen had the data remained in our possession. However, unfortunately no transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under the control of Rinquest Ltd to intercept or access transmissions or private communications unlawfully. While we strive to protect your Personal Data, we cannot ensure or warrant the security of any Personal Data you transmit to us. Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us.

4.4Opting out of marketing promotions

You can ask us to stop sending you marketing messages at any time by changing your marketing preferences in your Rinquest profile, using the unsubscribe link included in our marketing communications, or by contacting us at support@rinquest.com.

Where you opt out of receiving these marketing messages, we will continue to retain other Personal Data provided to us as a result of interactions with us not related to your marketing preferences.

4.5How to request your data and the process for obtaining it

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, if your request is clearly unfounded, we could refuse to comply with your request.

We may need to request specific information from you to help us confirm your identity and ensure you have the 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.

5.2Third-Party Links

This Site 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 Site, we encourage you to read the privacy policy of every website you visit.