Information Security & Consent :: World Othello Federation

INFORMATION SECURITY & CONSENT

INFORMATION AND CONSENT 2016/679/EU
– GENERAL DATA PROTECTION REGULATION
– ART. 13 AND FOLLOWING

According to articles 13 and following of Regulation 2016/679/EU (following GDPR), the WOF informs you that when registering to certain events (tournament/seminar/course), some of your personal data such as name, WOF ID number, birthday, country, email address, gender and occupation will be collected and processed for the event communication and operation.

PLEASE NOTE: in case of refusal to consent the registration of your data, some of our services may not work. Thus, you are informed of the following:

1. Data controller – representatives – data protection officer.

The data controller is World Othello Federation Office – WOF, whose legal seat is in Lyckliga gatan 38, 178 90 Ekerö, Sweden.
Email address – office@worldothello.org.
The representative person is the Secretary Mr. Benkt Steentoft, c/o WOF' 's abovementioned legal seat.

UK REPRESENTIVE
As we are based outside of the UK, UK GDPR Article 27 required that we appoint an UK representative to handle certain data subject requests and queries. In compliance with this, we have appointed Guy Plowman to act as our representative. Any queries requiring the input of our representative, should please be directed to them as follows:
Our representative in the United Kingdom:
Name: Guy Plowman
Office: President WOF, Committee member of British Othello Federation, based in UK
E-mail: guy.plowman@gmail.com

The Data Protection Officer for the World Othello Federation is Mr. Benkt Steentoft c/o the WOF´s abovementioned legal seat.
The official email address of the D.P.O. is office@worldothello.org

Processor is WOF Fair Play Team, e-mail: contact.judge.committe@worldothello.org

2. Personal information and Purpose.

When you use our website, we collect and use the following categories of your personal data for the respective purposes on the respective lawful grounds as described below.

(1) Responding to your inquiries

When you make inquiries to us by email or over the phone, and we respond to them, we collect your personal data such as your contact details (e.g., your name, email address, telephone number), what information you requested from us and our response. We do so on the lawful ground that it is necessary for the performance of our contract with you or necessary to take steps at your request prior to entering into a contract, namely serving you by providing you with the information you request from us. If you do not provide them, it prevents us from giving you as appropriate and precise information as we can.

We store your personal data for as long as your questionnaire is active and for a reasonable time thereafter according to our standard procedures or as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

(2) Surveying on the Website usage

When you visit the website and interact with it, we collect your personal data, including your source IP address, browser type/version, operating system/version, the pages served, time, your approximate location (countries), the preceding page views (what web page you come from) and other technical data about your usage of the website, including unique identifiers ("Device Identifiers") by which we could identify the web browser you use to access the website. We collectively refer to the categories of data described above as the "Automatically Collected Data".

We analyze the Automatically Collected Data to obtain insights about the usage of the website, including the demographic composition of our audience and the popularity of each page, item, and article. These insights help us provide content that better fits the demand from our audience. Such processing of your personal data is based on your consent. You can withdraw your consent at any time. Such processing is by no means aimed at profiling you in order to personalize content shown to you on the website according to your profile.

Log data is deleted after 26 months.

(3) Improving the Website security

In addition to the purpose (2) above, we monitor the website and analyze the Automatically Collected Data in order to detect and prevent unlawful use and a security breach of the website, on the lawful ground that such processing is necessary for the purpose of our legitimate interest, namely, protecting you and the website from any security threat.

Log data is deleted after 365 days.

(4) Registering to WOF Events

When you register to WOF Events, we may collect personal data such as name, WOF ID number, birthday, country, email address, residential address, gender, etc. The personal data above is required to manage your account to register to WOF Events. The lawful basis of this processing is necessary for the performance of a contract. If you do not provide any of them, it prevents us from giving you as appropriate and precise information as we can and from delivering you the products you ordered.

We store your personal data until you withdraw your registration in our association or for the duration to show that we treated you fairly.

(5) Issuing press releases announcing the competition on news media

We may collect competition pictures or movies (which may include your facial images). For the avoidance of doubt. We may collect this personal information to issue a press release announcing the competition on our website or news media. Such processing of your personal data is based on your consent. You can withdraw your consent at any time.

We store your personal data for the duration we publish the press release on our website, or until you withdraw your consent.

The process is finalized to give you the services WOF provides through its official competitions, seminars, courses and other events.

Your data will also be processed in order to fulfil any law obligation, even on accountability and fiscal matters, imposed to WOF by either national or international Law and Regulations.

3. Data Processing

Your data will be processed by the following operations (one or more): Collect, registration, organization, conservation in a database, consultation, processing by automated algorithm or personal research, modification where necessary, selection, extraction, comparison, use, interconnection, and deletion of the data.
Such process is conducted with or without electronic devices, internet or offline based databases, automated archives, software, and computer programs.
The process is operated by WOF Fair Play Team and secretariat.

4. Safety.

The computer databases are protected by the following measures, which were found to be appropriate by the WOF Media and Web team:
Anti-virus and malware protector.
Passwords.
Locked servers.

5. Legal Basis.

The data process is made by legal agreement.
WOF processes your data in a fair and legitimate way only to provide you the required services.

6. Data Collecting.

Data collecting is necessary in order to achieve the purpose and complete the activities above indicated.

7. Refusal.

In case of refusal to let your data to be processed by WOF, providing one or more services might be impossible.

8. Storage.

Your personal data will be stored until your decision them to be deleted or communication of your death or unavailability or decision to delete your personal data from any archive. After this, your data will be completely erased from the WOF database.

9. Communication and recipient.

Your personal data can be known by the internal body of WOF such as the Office and WOF Fair Play Team and transferred as well to organizers of events in order to let them advertise tournaments in your neighbourhood.

Your data may also be communicated to any legal authority of the European Union requesting them for administrative and legal procedures.

10. Profile.

Your data may be used to profile your activity as a Othello player in order to provide you advertising on events and tournaments.

11. Diffusion.

Your data may be shared in all the WOF member countries.
In the event that we transfer your data to an entity located outside the EEA or countries where the European Commission has decided to ensure an adequate level of data protection, we protect your rights with personal data by virtue of a data transfer contract with the relevant recipient in accordance with the GDPR, which imposes on such recipients contractual obligations to ensure an adequate level of data protection equivalent to those laid down by the GDPR. When the European Commission has decided that recipient countries (such as Japan) ensure an adequate level of data protection (the "Adequacy Decisions"), we can lawfully transfer personal data to the recipient country without requiring any specific authorization.

WOF website servers are currently located in the Netherlands, WOF web domain is registered in Sweden.

We may disclose your personal data to our web hosting providers, our contractors to analyze web traffic data, the companies which cosponsor the competition, or the media in which we issue press releases.

12. Your rights.

You have the right to:
– Check the existence of your data in WOF databases.
– Request from WOF access to and rectification or erasure of personal data or restriction of processing concerning the data subject and to object to the processing as well as the right to data portability.
– Withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal;
– Lodge a complaint with a supervisory authority.
– Check the origin from which the personal data belong, and if applicable, whether it came from publicly accessible sources;
– Know the existence of automated decision-making, including profiling, referred to in Article 22(1) of the Regulation and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

13. Data Breach.

In case of a Data Breach WOF will notify immediately the fact and act according to the provision of the regulation.

14. Withdraw.

The already made process based on previous consent shall be legal and lawful after the withdraw.

FOR OUR VISITORS FROM THE STATE OF CALIFORNIA

This section of our privacy policy explains how we collect, use, share, and protect personally identifiable information of California residents and any information related to it ("personal information") and non-personal information.

1. RIGHT TO KNOW ABOUT PERSONAL INFORMATION COLLECTED, DISCLOSED, OR SOLD

a. The CCPA states that you have the right to request us to disclose what personal information we collect, use, disclose, and sell.

b. You can exercise your above-mentioned rights unless you have exercised the rights within the preceding 12 months. We endeavor to respond to you within 45 days of receiving a verifiable request from you. If you intend to exercise such rights, please refer to section 6.

c. We use your information (name, and email address) to verify your request. You may be asked to provide additional information so that we can verify your request.

d. The categories of personal information we collected, business or commercial purpose, sources, and category of third parties we shared within the preceding 12 months are as follows:

	CATEGORY(as stipulated in CCPA 1798.140(o))	DETAIL	BUSINESS OR COMMERCIAL PURPOSE FOR PROCESSING	SOURCES OF COLLECTED PERSONAL INFORMATION	CATEGORY OF THIRD PARTIES WE SELL (stipulated in CCPA 1798.140(w))　OR DISCLOSE
1	Identifiers	name, WOF ID number, birthday, email address, residential address, gender and country	To manage the Othello competition, we host	Direct from you	our web hosting providers and the companies which cosponsor the competition
2	categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	name, and residential address
3	Protected classification characteristics under California or federal law	birthday, gender and country
4	Identifiers	name, email address, and telephone number	To respond to your inquiries	Direct from you	our web hosting providers
5	categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	names	To respond to your inquiries	Direct from you	our web hosting providers
6	Identifiers	Winners' name	To issue a press release announcing the competition on our website or news media. For the avoidance of doubt, visual information is not used to identify you.	Direct from you	The media in which we issue press releases
7	Visual Information	competition pictures (which may include your facial images)		Direct from you	The media in which we issue press releases
8	Identifiers	Unique personal identifier (cookie(s)), Internet Protocol address	To analyze your use of our website and generate insight to improve our service and marketing	Your activity on our site	Our contractors that assist us in analyzing web traffic data
9	Identifiers Internet or other electronic network activity information	Internet Protocol address browsing history, information regarding a consumer's interactions with an Internet website, application	To protect your privacy and security, integrity and availability of our website	Your activity on our site	Our contractors that assist us in monitoring web access traffic

e. Disclosure or Sale of Personal Information

(1) We do not have actual knowledge that we sell personal information about residents who we know are younger than 16 years old.

Under the CCPA, "sell" means disclosing by electronic or other means a consumer's personal information to a third party for monetary or other valuable consideration.

2. RIGHT TO REQUEST DELETION OF PERSONAL INFORMATION

a. The CCPA states that you have the right to request us to delete your personal information collected by us.

b. You can exercise your above-mentioned right with your account with us unless you have exercised the rights within the preceding 12 months. We endeavor to respond to you within 45 days of receiving a verifiable request. If you intend to exercise such rights, please refer to section 6.

c. We use your information (name and email address) to verify your request. You may be asked to provide additional information so that we can verify your request.

3. RIGHT TO OPT-OUT OF THE SALES OF PERSONAL INFORMATION

a. The CCPA states that you have the right to opt-out of the sale of your personal information by us.

b. We do not sell your personal information and do not share information collected from cookies or email address with advertising agencies to manage our personalized advertising to those of you based on your preferences.

4. RIGHT TO NON-DISCRIMINATION FOR THE EXERCISE OF A CONSUMER'S PRIVACY RIGHT

a. The CCPA states that you have a right not to receive discriminatory treatment by us for the exercise of the privacy rights conferred by the CCPA.

5. AUTHORIZED AGENT

a. When you use an authorized agent to submit a request to know or a request to delete, we may require that you:

(1) Provide the authorized agent with written permission to do so; and

(2) Verify your own identity directly with us.

(3) Directly confirm with us that you provided the authorized agent with permission to submit the request

We may deny a request from an agent that does not submit proof that they have been authorized by you to act on your own behalf.

6. CONTACT US

Please contact us by email if you have any questions or concerns about this privacy policy or the information we hold about you.

Email-address office@worldothello.org

7. How does our site respond to "Do Not Track" Signals

Our site do not responds to the DNT signals.

8. CHILDREN'S PRIVACY

We do not collect and store personal information about Children (in this provision, we define Children as minors under 13 years of age) if this information is submitted by a Child without prior parental consent or by the parent or guardian of the Child.

If we discover that we've unintentionally collected information from a Child in a way that does not meet COPPA requirements, we will delete the information immediately.