Privacy notice

DRAFT for review by an Irish-qualified solicitor. Not yet legally reviewed. Placeholders in [SQUARE BRACKETS] must be completed before publication.

Last updated: [DATE]

Who is responsible for your data

[TRADER NAME], [GEOGRAPHIC ADDRESS], Ireland, is the data controller. Contact: [PRIVACY EMAIL]. [If a Data Protection Officer is appointed, name and contact here; a DPO is probably not mandatory for this service, but confirm.]

What we collect and why

WhatWhyLegal basis (GDPR Art. 6)Kept for
Email addressSign-in links, service messages, receiptsContractUntil you delete your account
Confirmation that you're 18+ (date and time)To restrict accounts and purchases to adults. We use your date of birth only to check this and do not store itLegitimate interests / legal obligation [SOLICITOR TO CONFIRM]Until you delete your account
Display name, stadium theme, badgeYour profile and the public league tableContractUntil you delete your account
Game data: answers, guesses, scores, timings, disputesTo run the game, score fairly, handle disputes, and work out how rare each answer isContract; legitimate interests (fair scoring, anti-cheat)Until you delete your account; aggregated counts kept without your identity
Guest game cookie (random ID)To keep a guest's game and streak without an accountStrictly necessary (ePrivacy Regulations 2011, reg. 5(5))Up to 13 months
Orders, subscriptions, payment statusTo provide what you bought and meet tax obligationsContract; legal obligation6 years after the transaction [ACCOUNTANT TO CONFIRM]
Private leagues: league names you create, which leagues you're in, and your display name, crowd and streak shown to other membersTo run the leagues you choose to joinContractUntil you leave or delete the league or your account
Bug reports: your message, the page, your browser type, and an email address if you choose to give oneTo find and fix problems you reportLegitimate interests (keeping the service working)Until the problem is resolved, then [90] days; deleted with your account
IP address and request logsSecurity, rate limiting, fraud preventionLegitimate interests[30] days

We do not use advertising, tracking or analytics cookies, and we do not sell your data. Aggregate statistics we show (such as how many players gave an answer) don't identify anyone.

Who we share it with

  • Stripe Payments Europe Ltd (Ireland) processes payments. Your card details go directly to Stripe; we never see them. Stripe acts as a separate controller for some purposes; see Stripe's privacy policy.
  • [HOSTING PROVIDER] hosts the app and database in [REGION].
  • Resend (or another email provider) sends sign-in links and order confirmations.
  • Professional advisers and authorities where the law requires.

Where a processor is outside the EEA, we rely on an adequacy decision or Standard Contractual Clauses. [COMPLETE once providers are chosen; sign data processing agreements with each.]

Your rights

You can access, download, correct or delete your data, object to processing based on legitimate interests, restrict processing, and complain to a supervisory authority. Download and delete are available any time on your Account page. For anything else, email [PRIVACY EMAIL]; we reply within one month.

You can complain to the Data Protection Commission (dataprotection.ie) or the authority where you live.

Children

Pack the Stand accounts are for adults. If we learn an account belongs to someone under 18 we will delete it.

Changes

We'll post updates here and tell account holders about significant changes by email.