1. Who we are
1.1 Letsportpeople Services
Letsportpeople is the trading name of P/E Aliaksei Niachai, reg no 305485506 (“Letsportpeople,” “us,” “we” or “our”). Letsportpeople is registered in Georgia, with its postal address at Kazbegi av. 2, 157 Tbilisi. Letsportpeople promotes various running races and other sport Events (each an “Event”), such services are below referred to as the “Services”.
1.2 Who’s who
2. Our Privacy Statement
3. Personal Data that we collect
When you use or interact with us through the Site, we may collect Personal Data. Sometimes this will be on our own behalf (Letsportpeople is in such situation acting as a data controller) and other times this will be on behalf of an Event Organizer using our Services to run an Event (Letsportpeople is in such situation acting as a data processor). This is an important distinction for EU data protection law purposes and is explained in more detail in section 18 below.
3.1 All Users
Information you provide to us: For all Users we collect Personal Data when you voluntarily provide such information to us, such as when you create a membership account, contact us with inquiries, respond to one of our surveys or browse the Site or use certain parts of the Services. The Personal Data we collect is your name and your email address. Please note that Event Organizers can ask for other information, among other things; your personal identity number and identifying photograph. We advise you to check the Event Organizers websites in this respect.
When you create a membership account or otherwise submit Personal Data to us, we may associate other Non-Personal Data (including Non-Personal Data we collect from third parties) with your Personal Data. At such instance, we will treat any such combined data as your Personal Data until such time as it can no longer be associated with you or used to identify you.
3.2 Data from Event Organizers
Event Organizers may import personal data concerning participants and results to the Company’s back end application. The information shows previous results and enables the display of historical track records.
4. Payment related data
Information you provide via the Site: If you register for an Event, you will provide financial information (e.g. your credit card number and expiration date, billing address) some of which may constitute Personal Data. This information is not collected by us but by a third-party payment provider.
In addition, Event Organizers can set up Event registration pages to collect virtually any information they wish from participants in connection with registration for an Event Organizer’s Event listed on the Site. Letsportpeople does not control an Event Organizer’s registration process nor the Personal Data that they collect. Personal Data collected on behalf of Event Organizers is provided to the Event Organizer of the applicable Event in accordance with “How We Disclose and Transfer Your Personal Data” in section 6 below.
5. How we use your Personal Data
5.1 Specific reason
If you provide Personal Data for a certain purpose, we may use the Personal Data in connection with the purpose for which it was provided. For instance, if you contact us by e-mail, we will use the Personal Data you provide to answer your question or resolve your problem and will respond to the email address from which the contact came.
5.2 Access and use
If you provide Personal Data in order to obtain access to or use of the Services or any functionality thereof, we will use your Personal Data to provide you with access to or use of the Services or functionality and to analyze your use of such Services or functionality. For instance, if you supply Personal Data relating to your identity or qualifications to use certain portions of the Services, we will use that information to make a decision as to granting you access to use such Services and to assess your ongoing qualification to use such Services.
5.3 Internal business purposes
We may use your Personal Data for internal business purposes, including without limitation, to help us improve the content and functionality of the Site, to better understand our Users, to improve the Site, to protect against, identify or address wrongdoing, to enforce our Terms of Service, to manage your account and provide you with customer service, and to generally manage the Site and our business.
5.4 Letsportpeople marketing communications
In accordance with your marketing preferences, we may use your Personal Data to contact you for our marketing and advertising purposes. This includes without limitation, to inform you about services or Events we believe might be of interest to you, to develop promotional or marketing materials and provide those materials to you, and to display content and advertising on or off the Site that we believe might be of interest to you. See “Opt Out from Electronic Communications” below on how to opt out of Letsportpeople Marketing Communications.
5.5 Event Organizer emails
We allow Event Organizers to use our email tools to contact Participants for their current and past Events, so you may receive emails from our system that originate with such Event Organizers and that we send on their behalf. If you registered for an Event on the Site, your email address is available to that Event Organizer. The Event Organizer and not Letsportpeople is responsible for sending these emails.
5.6 Aggregated Personal Data
6. How we disclose and transfer your personal data
6.1 No sale
We are not in the business of selling your Personal Data. We consider this information to be a vital part of our relationship with you. Therefore, we will not sell your Personal Data to third parties, including third party advertisers. There are, however, certain circumstances in which we may disclose, transfer or share your Personal Data with certain third parties without further notice to you, as set forth below.
6.2 Business transfers
6.3 Parent Companies, Subsidiaries and Affiliates
6.4 Agents, Consultants and Service Providers
We may share your Personal Data with our contractors and service providers who process Personal Data on behalf of Letsportpeople to perform certain business-related functions. These companies include our marketing agencies, database service providers, backup and disaster recovery service providers, email service providers and others. When we engage another company to perform such functions, we may provide them with information, including Personal Data, in connection with their performance of such functions. We enter into a written data processor agreement with such companies in accordance with the requirements of the GDPR.
6.5 Facebook and other third-party connections
6.6 Legal requirements
We may disclose your Personal Data if required to do so by law in order to (for example) respond to a subpoena or request from law enforcement, a court or a government agency (including in response to public authorities to meet national security or law enforcement requirements), or in the good faith belief that such action is necessary to (a) comply with a legal obligation, (b) protect or defend our rights, interests or property or that of third parties, (c) prevent or investigate possible wrongdoing in connection with the Services, (d) act in urgent circumstances to protect the personal safety of Users of the Services or the public, or (e) protect against legal liability.
7. How we store your Personal Data
8. Your rights
Data protection laws provides you with rights in respect of Personal Data that we hold about you, including the right to request a copy of the Personal Data, request that we rectify, restrict or delete your Personal Data, object to profiling and unsubscribe from marketing communications. You also have the right to receive the Personal Data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another data controller without hindrance from us where the processing is based on consent or on a contract or the processing is carried out by automated means.
If you have a complaint about how we handle your Personal Data, please get in touch with us as set forth in section 19 to explain. If you are not happy with how we have attempted to resolve your complaint, you may contact the relevant data protection authority.
9. Legal grounds for processing your Personal Data
The GDPR requires us to tell you about the legal ground we’re relying on to process any Personal Data about you. The legal grounds for us processing your Personal Data for the purposes set out in section 5 above will typically be because: (1) it is necessary for our contractual relationship, (2) the processing is necessary for us to comply with our legal or regulatory obligations; and/or (3) the processing is in our legitimate interest as a market place for race Events (for example, to protect the security and integrity of our systems and to provide you with customer service, etc.).
10. How long we retain your personal data
We only store Personal Data as long as it is necessary for the purpose/s for which the Personal Data is processed. We may retain your Personal Data as long as you are registered to use the Services. You may close your account by contacting us. If you have an account with us, we will typically retain your Personal Data for a period of 90 days after that you have requested, you’re your account is closed or if it has been inactive for a longer period. However, we may retain Personal Data for an additional period as is permitted or required under applicable laws, resolving disputes and enforcing our agreements. Even if we delete your Personal Data it may persist on backup or archival media for an additional period of time for legal, tax or regulatory reasons or for legitimate and lawful business purposes.
11. Cookies, pixels tags, local shared objects, web storage and similar technologies
12. Your choices
You have several choices available when it comes to your Personal Data:
12.1 Limit the Personal Data you provide
You can browse the Site without providing any Personal Data (other than Automatic Data to the extent it is considered Personal Data under applicable laws) or with limiting the Personal Data you provide. If you choose not to provide any Personal Data or limit the Personal Data you provide, you may not be able to use certain functionality of the Site. For instance, register to an Event.
12.2 Opt Out from Electronic Communications
(a) Letsportpeople marketing communications
Where it is in accordance with your marketing preferences, Letsportpeople may send you electronic communications marketing or advertising the Site itself or Events on the Site, to the extent you have registered for the Services or purchased a ticket and/or registration to an Event listed on the Site. You can also “opt out” of receiving these electronic communications by clicking on the “Unsubscribe” link at the bottom of any such electronic communication. In addition, you may also manage your email preferences at any time by logging in (or signing up and then logging in), clicking on “Profile” and then “Settings”.
(b) Event Organizer initiated communications
Event Organizers may use our email tools to send electronic communications to those on their email subscription lists, including Participants who have registered for their Events on the Site in the past. Although these electronic communications are sent through our system, Letsportpeople does not determine the content or the recipients of these electronic communications.
(c) Transactional or responsive communications
Certain electronic communications from Letsportpeople are responsive to your requests. For instance, if you are a Participant and sign up to an Event, we email you your registration confirmation on behalf of the Event Organizer. As a further example, if you email our customer support department, we will answer your email.
13.1 Personal Data Provided to Others
13.2 Third-Party Links
15. Server location and transfer of Personal Data
17. Transfers of Personal Data to third countries
As Letsportpeople is a global company, we may need to transfer your Personal Data outside of the country from which it was originally provided. This may be intra-group or to third parties that we work with who may be located in jurisdictions outside the EEA and Switzerland, which might not have any data protection laws or have laws which are less strict than those in Europe.
Whenever we transfer Personal Data outside of the EEA or Switzerland, we take legally required steps to make sure that appropriate safeguards are in place to protect your Personal Data. For example, Letsportpeople is Privacy Shield certified which means that it self-certifies to protect Personal Data from the EEA and Switzerland in accordance with established data privacy principles. Feel free to contact us as set forth in section 19 for more information about the safeguards we have put in place to protect your Personal Data and privacy rights in these circumstances.
18. Letsportpeople as a data controller and a data processor
EU data protection law makes a distinction between organizations that process Personal Data for their own purposes (known as “data controllers”) and organizations that process personal data on behalf of other organizations (known as “data processors”). If you have a question or complaint about how your Personal Data is handled, these should always be directed to the relevant data controller since they are the ones with primary responsibility for your Personal Data.
Letsportpeople may act as either a data controller or a data processor in respect of your Personal Data, depending on the circumstances.
For example, if you create a membership account with us, Letsportpeople will be a data controller in respect of the Personal Data that you provide. We will also be a data controller of the Personal Data that we have obtained about the use of the Site, which could relate to Event Organizers’ Participants. We use this to conduct research and analysis to help better understand and serve Users of the Site as well as to improve our platform and provide you with more targeted recommendations about Events we think may be of interest to you.
However, if you register for an Event, we will process your Personal Data to help administer that Event on behalf of the Event Organizer (for example, sending confirmation, promotional and feedback emails, processing payments, etc.) and to help the Event Organizer target, and understand the success of, their Event and Event planning (for example, providing Event reports, using analytics to gain insights into the effectiveness of various sales channels, etc.).
In these circumstances, Letsportpeople merely provides the “tools” for Event Organizers; Letsportpeople does not decide what Personal Data to request on registration forms, nor is it responsible for the continued accuracy any Personal Data provided. Any questions that you may have relating to your Personal Data and your rights under data protection laws should therefore be directed to the Event Organizer as the data controller, not to Letsportpeople.
19. Contact us
If you have any questions or concerns at any time, please do not hesitate to contact us at the address in section 1.1 above or at email@example.com.