FOR EUROPEAN WEBSITE VISITORS AND PARTICIPANTS TRAVELING WITHIN THE EUROPEAN ECONOMIC AREA
GoPlay Sports Tours® is a trading name of the American Institute for Foreign Study, Inc (“AIFS US”). European travel and accommodation and other European elements of our tours are booked and managed through American Institute for Foreign Studies (UK) Limited (“AIFS UK”). AIFS UK also gives assistance to tour participants while they are in Europe. Contact details for AIFS UK (including details of its registration with the UK Information Commissioner’s Office) are at the end of this Policy (see HOW TO CONTACT GOPLAY below).
AIFS US and AIFS UK (collectively “AIFS”/“we”/“our”/“us”) take your privacy very seriously and are committed to protecting and respecting your privacy.
Where we refer to the “GoPlay Website” in this Policy, we mean the website which can be accessed at https://www.acis.com/goplay and any other “GoPlay” website operated by us (including any updates or supplements to them).
Please read this Policy carefully to understand our views and practices regarding your personal information and how we will treat it.
This Policy applies to:
This Policy refers to the following additional terms, which also apply to your use of the GoPlay Website and, if applicable, your participation in a tour:
TERMS AND CONDITIONS
The “Terms and Conditions” that you accept when booking your tour.
We collect the following personal information from and about you:
1. Information you give us. You may give us information about you:
When booking a tour, you:
when taking part or after taking part in a tour, you:
2. Information we collect when you visit the GoPlay Website. Each time you visit the GoPlay Website, we will automatically collect the following:
When taking part or after taking part in a tour:
We collect personal information so that we can operate effectively and provide you with the best possible service. The information we process depends on the context of your interactions with us, with our Tour Managers and with the GoPlay Website, and your involvement in a tour. It also depends on the choices you make, for example the consents you provide, the functions you use and the privacy settings you select. You may choose not to provide or allow us to collect certain information, but we may then not be able to consider you for a tour or enable you to participate in a tour (where that information is necessary for us to do so).
Learn more below about how we use your information and what our legal basis is for using it:
|Type(s) of personal information we process||Why we process this personal information||Our legal basis for processing this personal information|
||To help us to identify you and any account you hold with us.||To allow us to perform our obligations under our agreement with you, and/or to take steps at your request prior to entering into our agreement with you.|
||To allow us to book your tour/itinerary, to provide you with information and services that you request from us, and to ensure that you are insured while on your tour. AIFS US may share information with AIFS UK to enable it to book elements of your tour.
||To allow us to perform our obligations under our agreement with you, and/or to take steps at your request prior to entering into our agreement with you.|
||To support you with your participation in a tour, e.g. with:
To verify your visa eligibility and/or comply with visa regulations.
|To allow us to perform our obligations under our agreement with you, and/or to take steps at your request prior to entering into our agreement with you.|
||To deal with any enquiries, correspondence, concerns or complaints.
||To enable us to keep in touch with you after you have participated in a tour.
||To enable us to pursue our legitimate interests to:
||To enable us to send you information about other tours we offer, and/or other opportunities or services of ours and other companies in our group which may be of interest to you.||Your consent.|
To enable us or your Tour Managers to provide information to the emergency services if an emergency arises.
|To protect your vital interests|
||To enable us or your Tour Managers to provide information to organisations associated with your tour who reasonably need this information.||Your consent.|
||To enable us or your Tour Managers to get in touch with your emergency contact(s) if an emergency arises.||Your consent.|
||Please see “Why we process this personal information” in the table for Visitors below.||Please see “Our legal basis for processing this personal information” in the table for Visitors below.|
|Type(s) of personal information we process
||Why we process this personal information
||Our legal basis for processing this personal information|
||To conduct internal operations, including data analysis, testing, research, statistical purposes and troubleshooting.
To ensure that content on the GoPlay Website is presented in the most effective manner for you and for your device.
To analyse traffic to the GoPlay Website.
As part of our efforts to keep the GoPlay Website secure and to prevent fraud.
|To enable us to pursue our legitimate interests to:
More about the information we use and why
Where we have a legal basis to use your personal information without consent (as we have described above), this Policy fulfils our duty to process personal information transparently and helps us to do so fairly and lawfully and in a manner that you would expect given the nature of our relationship with you, by giving you appropriate notice and explanation of the way in which your personal information will be used.
Where consent is required for our use of your personal information, we will ask you to positively opt-in by ticking the appropriate consent box or otherwise communicating your consent.
Where you provide us with personal information relating to other individuals (for example, if you give us your emergency contact’s details), you must obtain the consent of those individuals before doing so.
If you have any questions or require any further information regarding our use of personal information, please contact our data protection officer (see HOW TO CONTACT GOPLAY).
We may share your personal information with your consent or as is necessary with selected third party service providers, and other companies within our group that support us in the performance of the activities set out in the tables above. See below for more details.
We expect all our third party service providers and all other companies within our group to take appropriate security measures to protect your personal information in line with our policies.
We may also need to share your personal information with a regulator or otherwise to comply with the law or to respond to valid legal process, including from law enforcement or other government agencies.
Why might you share my personal information with third parties?
We may share your personal information with third parties where it is necessary in connection with arranging your tour, where required by law (as above), or where we have another legitimate interest in doing so that is not overridden by your interests and fundamental rights (for example, to protect Tour Managers or other Participants, or to operate and maintain the security of our computer systems.)
Who will you share my personal information with?
We will share certain information about you as follows:
We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including to satisfy any legal, accounting, or reporting requirements. To decide the appropriate retention period, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorised use or disclosure of it, the purposes for which we process your information, and the applicable law.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Even if you request that we erase your information, we may still need to keep it (see YOUR RIGHTS) or may keep it in a form that does not identify you.
The following retention periods will apply, unless we inform you otherwise (or you request that we erase your information):
We may keep certain information for longer periods than those stated above if you have agreed to us using it, for example, for promotional purposes.
Please contact our data protection officer if you would like further details on how long we retain your information (see HOW TO CONTACT GOPLAY).
If you are a Participant, AIFS UK may transfer, process and store the information it collects from or about you to AIFS US and other relevant third parties based in the U.S. (i.e. outside of the EEA). AIFS UK does so as it is necessary for it to communicate with AIFS US in relation to your tour, and so that you can take part in your tour (i.e. necessary for the performance of our obligations under our agreement with you).
If you are a Visitor based in the EEA, we will transfer the information we collect from you to AIFS US and other relevant third parties based in the U.S. We do so because the GoPlay Website is operated out of, and accessed in, the U.S. and it is necessary for us to understand how it is used, so that we can improve it.
In each case, we will take all steps reasonably necessary to ensure that your personal information receives an adequate level of protection and is treated in a way consistent with EU laws on data protection.
We do not knowingly collect information from anyone under the age of 13 and you should not register your interest in or apply to take part in a tour if you are under the age of 13. If you are under 21 and wish to register your interest in a tour, then you must obtain the consent of your parent or legal guardian. If you become aware that your child or any child under your care has provided us with information without your consent, please contact our data protection officer (see HOW TO CONTACT GOPLAY).
All personal information that you provide to us is stored on secure servers. We have put in place (and require anyone who processes data on our before to put in place) appropriate measures to protect the security of your information.
In addition, we limit access to your information to those of our employees, agents, contractors and other third parties who have a business need to know.
You should be aware that the transmission of information via the internet is not completely secure. Although we will do our best to protect your information, we cannot guarantee the security of the information transmitted to the GoPlay Website or by email; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access or inadvertent disclosure.
You have the right under data protection laws to access personal information held about you, subject to certain conditions, and to request its rectification or deletion.
If you would like to access or amend the personal information which we hold about you or if you would like us to stop using your personal information, please contact our data protection officer (see HOW TO CONTACT GOPLAY).
To learn more about the rights you may have in relation to your personal information see YOUR RIGHTS.
By law you have the right to:
You should be aware that if you ask us to stop processing your personal information in a certain way or to erase your personal information, and this type of processing is necessary in order for you to participate in a tour, then we may not be able to continue to provide our tour services to you and you may need to leave the tour. This does not include your right to object to direct marketing, which can be exercised at any time without restriction.
If you want to exercise any of the rights listed above, please contact our data protection officer (see HOW TO CONTACT GOPLAY).
No fee usually required to access your personal information
You will not normally have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you
We may need to request specific information from you to confirm your identity and verify your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Right to withdraw consent
Where you have consented to the collection, use or transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact our data protection officer (see HOW TO CONTACT GOPLAY). Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
The GoPlay Website contains links to other websites, including Facebook, Twitter and Instagram. This Policy only applies to the GoPlay Website so when you link to other websites you should read their own privacy policies.
We keep this Policy under regular review and will post any updates on this webpage. This Policy was last updated in May 2018.
In the UK, AIFS UK is the data controller in respect of your personal information and is registered with the UK Information Commissioner’s Office with registration number Z6393161. AIFS UK’s address is 37 Queen’s Gate, London, SW7 5HR.
We have appointed Richard Howell as our data protection officer to oversee compliance with this Policy. If you have any questions about this Policy or how we handle your personal information please contact him at email@example.com, +44 20 7581 7300, 37 Queens Gate, London SW7 5HR, United Kingdom.
If for any reason you are not happy with the way that we have handled your personal information please contact us at firstname.lastname@example.org, +44 20 7581 7300, 37 Queens Gate, London SW7 5HR, United Kingdom. If you are still not happy, you have the right to make a make a complaint to the Information Commissioner’s Office see: https://ico.org.uk/global/contact-us/.