Racquet Privacy Policy

Why and how do we process your personal data?

We at Racquet care about your privacy and want you to feel safe when we process your personal data. In order for you to use, and for us to provide, our online booking system and Racket services including our competition tool Padelboard, we need to process your personal data for different purposes.

We will process your personal data for the following purposes:

To administer your Racket account registration, including verifying that you are not a robot with the help of services provided by Google.

To administer the use of your Racquet account, which means we process your personal data to:
- organize your login to
Racquet, your bookings, rentals and purchases,
- allows you to create a personal profile,
- show your previous and upcoming bookings and statistics based on these,
- suggests relevant activities for you based on your usage of Racket,
- allows you to find partners and places near you,
- display information about tournaments and matches if you follow the competition.

To provide customer service and handle any questions, complaints or requests.

To comply with our legal obligations.

We do not sell your personal data, but we may need to share it with, for example our partners and connected venues, affiliated companies, our IT suppliers and suppliers of the analytics services we use (especially Google and Amplitude). In certain situations, but only if we can ensure an appropriate level of protection for your personal data.

What are your rights?

When we process your personal data, you have certain rights. This means that you, for example, have the right to information and access to your personal data, a right to request that we delete your personal data, a right to withdraw your consent or object to our processing and a right to lodge a complaint with a supervisory authority.

Who is responsible for the processing of your personal data?

Racquet, is responsible for the processing of your personal data. We also process personal data as processors on behalf of our connected partners and venues in order to facilitate your bookings and purchases.

If you want to know more about our processing of your personal data or if you want to exercise any of your rights, please contact us and we will help you. Our email address is (isi alamat email).

You can read our full privacy policy below.

Privacy Policy

Who is responsible for processing your personal data?

Racquet, is responsible for the processing of your personal data.

Please note that we also process data on behalf of our partners and venues. Should you have any questions regarding this or if you wish to exercise any of your rights under data protection legislation, please contact us via our e-mail address (isi alamat email).

From where do we collect your personal data?

We collect your personal data directly from you when you register a Racquet account or when you use Racquet, for example when you make a booking on our website or in one of our Apps or if you choose to up-date or add to your account information.

The personal data you need to provide to us

In general, you are not required to provide personal data to us, but certain information needs to be provided in order to use Racquet or any of the Apps. In which situations you need to provide personal data to us is described in the below charts where the legal basis is stated as “Performance of a contract” or “Legal obligation”. If you do not provide such personal data to us, we will not, for example, be able to make Racquet or the Apps available for you.

Who can gain access to your personal data and why?

Your personal data is primarily processed by Racquet. This means that your personal data will be handled by our employees and representatives, but only to the extent it is needed for them to conduct their work.

Certain information about you may be visible to others. Whether information is public or not is clearly noted within the system and you can control this via your accounts privacy settings or by the choices you make when using Racquet or the Apps, opting for the visibility you prefer.

Sometimes our partners or venues use Racquet as administrators. They can then process your personal data if you are affiliated with them through your membership or because you are their customer. They might also show information about activities or events on screens displayed at the venue and such displays can include information entered into Racquet.

In certain cases, we need to share your personal data with our suppliers, partners and subsidiaries in order to conduct our business efficiently. We are responsible for any sharing of your personal data to such suppliers, partners or subsidiaries and to make sure your personal data is safe when shared with third parties.

We will share your personal data with the following recipients:

Our IT-suppliers that will process your personal data on our behalf as our processors in order for us to have a functioning IT system and conduct our business efficiently. Your personal data is only shared to the extent necessary for our suppliers to fulfil their obligations in the contract they have with us and according to our instructions. This is applicable to all detailed schedules listed below.

If you receive our newsletters or surveys, we will share your personal data with the company that provides a system for sending newsletters or conducting surveys.

Our connected partners and venues to e.g. enable you to enter a competition or make use of the booking you have made through MATCHi with the partner or venue. Your personal data is only shared to the extent necessary for our connected partners and venues to fulfil their obligations in the contract they have with us or directly with You. The venues will process your personal data as controllers because You are also a customer of the venue. In some regards there is an overlap between the information we process and control about you and the information the venue process and control.

Our payment service providers in order to administrate your payments.

In order to store information that we are required to store according to bookkeeping, accounting and other mandatory law, we will in some cases use a company that helps us archive such information. The information contains personal data but will only be processed on our behalf and on our instructions.

Where is your personal data processed?

We, as well as our processors, process your personal data within the Indonesia. In some instances, we will transfer your personal data outside of the Indonesia to our IT-suppliers that process personal data as our data processors and according to our instructions. Such transfer only takes place in accordance with applicable data protection legislation, meaning that we will transfer your personal data outside the Indonesia when we can ensure an appropriate level of protection of your personal data.

Detailed description of how we process your personal data

The below charts describe in detail why we process your personal data, which categories of personal data we process, our legal basis for the processing and for how long we process your personal data.

This is partly such information we have a legal obligation to provide and might feel a bit long and complicated – do not hesitate to contact us if you have any questions regarding our processing of your personal data. Our contact (isi alamat email) can be found in the beginning of this privacy policy.

Processing which we are solely responsible for

If you use Racquet

To administrate your Racquet account

Purpose with our processing:

Registration of yourRacquetaccount

Enter into an agreement with you regarding your use of Racquet

Enable you to log in to your account on our website, in our app or on a website/application with bookings powered by Racquet

Send you an e-mail to explain how to change your password if you have requested a new password

Communicate with you as necessary to fulfil our contractual obligations, such as to send you updates of Racquet or the Apps

Storage period: We will process your personal data for this purpose until you choose to delete your Racquet account.
The personal data we process to verify that you are not a robot when you register an account will only be processed until your account is registered.

What personal data we process:

Name

E-mail address

Password

Our legal basis for the processing:

Performance of a contract. The processing is necessary in order for us to enter into and fulfil the contract we have with you concerning your use of racquet. If the data is not provided to us, we will not be able to administrate your registration and your account.

To provide you with the features of your Racquet account

Purpose with our processing	What personal data we process	Our legal basis for the processing
• Enable you to create a personal profile • Show you your previous and upcoming bookings • Send you booking information and possibly entry codes and to allow you to share information about a booking with invited players • Produce and show you statistics, for example based on your previous bookings	• Name • E-mail address • Booking information (e.g. which partner or venue you booked and which court, day and time the booking is for and if the invitation feature is used, you can see who is invited to play.) • Social security number We also process information that you choose to register, such as: ◦ Birthday ◦ Gender ◦ Location ◦ Nationality ◦ Phone number ◦ Address ◦ Profile picture ◦ Personal description and sports profile ◦ Any information you may choose to add in comment fields provided	Performance of a contractThe processing is necessary in order for us to fulfil the contract we have with you to provide the features of your Racquet account. Legitimate interest The personal data that you choose to register on your profile will be processed based on our legitimate interest to enable a personalised profile at Racquet.
• The mobile application will not store or access any pictures in your device but only use the camera to scan QR-codes. • It is always your choice whether to allow access or not but please note that if you decline you will not be able to use the apps QR-scanning capabilities and thereto connected functions.	• QR-codes	Consent We will only process your data for this purpose if you have consented to our processing. You can withdraw your consent at any time by disabling this function in your settings.
• Enable you to find a partner and venue near you if you choose to. Please note that you can deactivate this in your device, should you not wish to make use of this feature.	• Location	Legitimate interest The personal data that you choose to register on your profile will be processed based on our legitimate interest to help you find partners and venues near you.
Storage period: We will process your personal data for this purpose until you choose to unregister/delete your account.

To collect information from our connected partners and venues

Purpose with our processing	What personal data we process	Our legal basis for the processing
• Collect data about you from our connected partners and venues and compile such statistics.	• Previous booking, activity or competition information • Name • Information about your membership?	Legitimate interest The personal data will be processed based on our legitimate interest to compile statistics.
Storage period: We will process your personal data related to statistics until you choose to delete your Racquet account.

To provide customer service and support

Purpose with our processing	What personal data we process	Our legal basis for the processing
• Provide customer service and answer any question you may have in relation to your use of Racquet and/or any of the Apps	• Name • Phone number • E-mail address • Information about the support matter	Legitimate interestThe personal data will be processed based on our legitimate interest to provide customer service. Performance of a contract The processing might also be necessary in order for us to fulfil the contract we have with you concerning your use of *Racquet*. If the data is not provided to us, we will not be able to help you.
Storage period: We will process your personal data related to customer service and support matters until you choose to unregister/delete your Racquet account.

To analyse how Racquet is used

Purpose with our processing	What personal data we process	Our legal basis for the processing
• Analyse how you use Racquet and/or our Apps to improve our website and services. To do this we use the analytic service from Amplitude and Google Analytics. • The analytic service means that we place a random ID on your device to distinguish your device from other visitors and to acknowledge patterns in how our website is used. We will however not know who you are • The personal data we gather will be used e.g. to optimize functions and to adapt the websites to suit our visitors • We will gather personal data by using cookies.	• An encrypted version of your IP address • Information about your device/browser and if you use more than one device (which area in the country you use our website from and which screen resolution you have) • Information about your activities on the website, for example what you click on and how many times you have visited the website • Other information Google has about you, e.g. information about from which site you found us • The above is an overview of the most relevant information, but this is very technical and there could be details related to the above which will be processed.	Legitimate interest The personal data will be processed based on our legitimate interest to provide and improve our customer service. You can prevent Google Analytics from using your personal data by downloading and installing this browser add on. From time to time, different cookies may be used. If these cookies are not essential to the service, we process the data based on your consent, when this is the case you can withdraw your consent at any time.
Storage period: We will store your personal data until you delete your account at the latest, but some date may be deleted earlier. Google will continue to store your personal data for their own purposes and Google will inform you separately about such storing.

To send newsletters, surveys and keep you informed

Purpose with our processing	What personal data we process	Our legal basis for the processing
• Send information about news, marketing, offers and invitations (“newsletters”) • Send surveys with enquiries related to aspects of our service, the wider market which we cater to or potential future developments.	• E-mail address • Telephone number • Information as to whether you wish to receive such communications. • The results from surveys are anonymous so we do not process any answers from you as personal data.	Legitimate interest The personal data will be processed based on our legitimate interest to send marketing, wider information and obtain survey results to improve our service and decision making.
Storage period: We will process your personal data for this purpose as long as you have a Racquet account. You can always choose to unsubscribe or object to receiving newsletters, surveys and marketing at any time. If you object to receiving marketing from us, we keep track of this in our “unsubscribe-list” to avoid sending you any further such material. You can also at any time make an active choice in your account settings letting us know if you wish to receive newsletters and or if you wish to partake in surveys.

If you have any questions or queries

We always strive to keep a good relationship with you and answer all questions you may have. If you have any questions, would want to make a complaint regarding Racquet or if we would have a claim against you as a user, we will process your personal data as described below. We will collect your personal data from you or provide the information ourselves.

Note that an ongoing matter may mean that we cannot delete all your personal data after your request.

To handle any cancellations, complaints or claims

Purpose with our processing	What personal data we process	Our legal basis for the processing
• Handle any cancellations, complaints or claims • Initiate possible claims or defend ourselves against a possible complaint or claim	• Name • Contact details you have chosen to use, e.g. e-mail address and/or phone number • Information from our communication with you in relation to the claim	Legal obligation The processing is necessary to comply with legal obligations to which we are subject, i.e. consumer law. In these cases, you need to provide your personal data to us since we otherwise will not be able to comply with your consumer rights. Performance of a contract The processing might also be necessary in order for us to fulfil the contract we have with you concerning your use of *Racquet*. If the data is not provided to us, we will not be able to assess and fulfil contractual obligations. Legitimate interest We also have a legitimate interest to process your personal data to defend ourselves against a possible complaint or claim.
Storage period: We will store your personal data from the time the complaint or claim was initiated and for the duration of such complaint or claim and if you have a Racquet-account, we store the information for as long as you have an account.

If you object to receiving marketing from us

We will store information about you who have chosen to object to receiving marketing from us – see the below chart for information about this. We have received the personal data from you.

To comply with bookkeeping, accounting and transaction related obligations

Purpose with our processing	What personal data we process	Our legal basis for the processing
• Store information in bookkeeping and accounting • Document information to know our customers, if required under the law.	• Name • History regarding payments made and other information that constitutes accounting records • So called ‘know your customer’ information, if required	Legal obligation The processing is necessary to comply with legal obligations to which we are subject, i.e. bookkeeping and accounting legislation or other transaction related legislation to counter money laundering, terrorism or comply with sanctions.
Storage period: We will store any document constituting bookkeeping material and personal data included therein for seven to eight years according to bookkeeping and accounting legislation. The regulation means that we store bookkeeping material until and including the seventh year after the end of the calendar year for the fiscal year to which the personal data relates.

Processing which we and our partners & venues each have its own responsibility for

For certain processing of your personal data, we act as processor to our partners and venues where they include some of your personal data in Racquet. In many cases, this personal data overlap with the data that we ourselves control and sometimes it might contain more information, often such as membership status. This means that if you are a Racquet user and make a purchase or booking at a venue or enter an activity or competition, we will forward your information to the venue as you are their customer or member and they are responsible for how they process your data independently of us.

If you have a request regarding the data we process on behalf of our partners or venues, we will always have to consult the controller before we take any action. If you want information about how the respective venue or partner processes your data, we direct you towards the venue and you can always find contact details to the responsible partner or venue in Racquet and in your booking information or receipt. If you are a member or customer of a particular venue, other venues which are not affiliated with your venue will not be able to access your personal data that is processed by us on behalf of a particular venue.

To administrate your bookings, purchases, activities, applications and memberships

Purpose with our processing	What personal data we process	Our legal basis for the processing
• Receive and register your bookings, purchases and applications • Administrate your purchases and payments • Share your payment information with payment service providers	• Name • Contact information • Booking information (e.g. which partner or venue you booked and which court, day and time the booking is for) • Information about your purchase or application • Competition information • Payment information	Performance of a contractThe processing is necessary in order for us to fulfil the contract we have with you concerning your use of Racquet. If the data is not provided to us, we will not be able to administrate your bookings and purchases at venues.
• Share information to and from our connected partners and venues	• Name and contact information, such as e-mail address or phone number • Booking information e.g. which court or which day and time the booking is for and who are participating • Membership purchases, detailing contact information, social security number, birthday, gender and other information you choose to supply and required by venues.	Legitimate interestThe personal data will be processed based on our legitimate interest to fulfil our contractual obligations in relation to our connected partners and venues and in order for them to perform their obligations in the contract they have with us an in the contract they have with you as we only act as a mediator when providing the booking service, selling vouchers or memberships.
Storage period: We will store your personal data as long as necessary to administrate your booking and purchase We will process your personal data after this for purposes stated in the charts above, e.g. to administrate your account and provide you with its features or for bookkeeping purposes etc. In addition to the above, our connected partners and venues are themselves also responsible for your bookings, activities, applications and purchases. They will store your information in accordance with their own privacy rules and to the extent the venue's information is stored by Racquet, we process this personal data on behalf of the venue and in accordance with our data processing agreement with the venue.
Sharing: When you accept an invitation to a booking, make a booking, application, purchase or take part in activities or competitions at a venue, we will forward your information to the venue as you are their customer and/or member and they are responsible for how they process your data independently of us.

What are your rights when we process your personal data?

A detailed description.

You have certain rights regarding your personal data and we outline them below.

If you want to know more or if you want to exercise any of your rights, please contact us and we will do our best as we are happy to help. Our contact information can be found at the beginning of this privacy policy.

Right to information and access

You have the right to obtain confirmation as to whether we are processing personal data about you or not.

In detail: Information we provide include the following:

the purpose of the processing;

categories of processed personal data;

recipients or categories of recipients to whom personal data can be shared;

expected retention times for storage or the criteria used to establish such time;

information about your rights to have personal data corrected, deleted or limit the processing thereof or your right to object to such processing;

You also have the right to obtain a copy of the personal data processed by us. Should you request more copies we may choose to charge a reasonable fee to cover administrative costs. If the information is requested via e-mail, you will receive the information in a common electronic format.

Right to rectification

You have a right to correct any inaccurate personal data concerning you that we may be processing and to ask us to have incomplete personal data completed.

In detail: With consideration of the purpose you have a right to complete any non-complete personal data. If possible and within reasonable efforts, we will inform each recipient with whom the personal data has been shared in case of any rectification. If you want more information about such recipients you are welcome to contact us. Our contact information can be found at the beginning of this policy.

Right to erasure (“the right to be forgotten”)

Under certain circumstances, you have a right to request that we delete your personal data. In addition to our own processing of personal data, we also process data on behalf of venues as data processors. If you request that Racquet delete your personal data, we will handle your request as related to our own processing but should you also want a venue to stop processing your personal data, you must contact the venue directly.

In detail: You have the right and we have the obligation to delete your personal data without undue delay if any of the following applies:

personal data are no longer necessary for purposes which they were collected or processed,

you object to the processing pursuant

personal data has been non lawfully processed, or

personal data must be deleted in order to fulfil a legal national law to which we are subject.

In the event that we have made public the personal data and are required to delete it as above, we will, taking into account available technology and the cost of implementation, take reasonable steps including technical measures, to notify the controllers of your request and that you wish they delete any links to, or copies or reproductions of specific personal data.

Please note that our obligation to delete and notify does not apply to the extent processing is necessary for the following reasons:

to exercise the right to freedom of expression and information,

to fulfill legal obligations to which we are subject, or

to be able to establish, assert or defend legal claims.

We delete your personal data at your request, provided that we do not have an obligation to save the personal data in accordance with applicable laws and regulations.

We will notify each recipient to whom the personal data has been shared of any deletion that has taken place as described above, unless this proves to be impossible or entails a disproportionate effort. If you want information about these recipients, you are welcome to contact us.

Right to restrict processing

Under certain circumstances, you also have a right to request that we restrict our processing of your personal data.

In detail: The right applies if:

you dispute the accuracy of the information (but only for such time that allows us to verify),

the processing is illegal and you oppose the deletion of personal data and instead request a restriction on the use of the data,

you need the personal data to assert or defend legal claims even though we no longer need the data for our purposes, or

you have objected to the processing

If the processing referred to above is restricted, such personal data (with the exception of storage) may only be processed with your consent or to establish, assert or defend legal claims or to protect the rights of any other persons or for reasons of public interest. Furthermore, we will notify you before ceasing to restrict any processing.

We will notify each recipient to whom the personal data has been disclosed of any restriction on processing taken place as described above, unless impossible or if it entails a disproportionate effort. If you want information about these recipients, you are welcome to contact us.

Right to data portability

Under certain circumstances, you have a right to receive your personal data from us in a structured, commonly used and machine-readable format and, where technically feasible, have your personal data transferred to another company (“data portability”).

In detail: The right to data portability applies to personal data that you have provided to us in a structured, widely used and machine-readable format, and the processing is automated.

Your right to data portability must not adversely affect the rights and freedoms of others.

Right to withdraw your consent and object to processing

You always have a right to withdraw any consent you have given us, partly or completely. For example you can always withdraw consent to use your data for marketing and profiling purposes, such as sending newsletters, surveys or giving you customised suggestions. You can read more about this in the charts above.

In detail: If you object, we may no longer process your personal data as long as we can not demonstrate compelling legitimate reasons for the processing that outweigh your interests, rights, and freedoms or whether it is for the determination, exercise, or defence of legal claims.

Balancing of interests assessments when processing personal data based on the legal basis “legitimate interests”

As we state above, for some purposes, we process your personal data based on our “legitimate interest”. By carrying out a balancing of interests assessment concerning our processing of your personal data, we have concluded that our legitimate interest for the processing outweighs other concerns. This assessment is done with caution and we strive to strike a fair balance.

If you want more information about any aspect of how we process your data or if you want to exercise any of your rights, you are very welcome to contact us.