Let’s Do This Privacy Policy
Last updated: December 2023BACKGROUND:
Let’s Do This! SBAR Endurance Inc, SBAR Endurance Ltd, and its affiliates, properties, and property owners (collectively, “Let’s Do This”, “Our”, “Us”, or “We”) understand that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits Our Site and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.
This Policy applies to Our use of any and all data collected by us in relation to your use of this website, Our mobile application, and any other platforms that We may develop (collectively Our “Site”). Please read this Privacy Policy carefully and ensure that you understand it.
Table of Contents:- Definitions and Interpretation
- Scope – What Does This Policy Cover?
- Why do we collect your information?
- What Data Do We Collect and How Do We Collect It?
- How Do We Use Your Data?
- How and Where Do We Store Your Data?
- How Do We Share Your Data?
- What Happens If Our Business Changes Hands?
- How Can You Control Your Data?
- EU Members’ Rights
- Rights Available to Certain Residents of the United States
- California Residents
- Cookies
- Contacting Us
- Children
- Changes to Our Privacy Policy
- Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
“Account” means an account required to access and/or use certain areas and features of Our Site; “Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. This also includes web beacons, pixels, scripts, or other similar tracking technologies. Details of the Cookies used by Our Site are set out in section 14, below; “Data Protection Laws” means all data protection laws which are relevant to us and Our Site (including UK and EU Privacy and Cookie Laws); “UK and EU Privacy and Cookie Laws” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015; and the General Data Protection Regulation 2018 (“GDPR”), and in each case, the laws which incorporate such laws into the national laws of the United Kingdom since the UK’s departure from the EU. “We/Us/Our” means SBAR Endurance Incorporated. Our registered office in the United States is 548 Market Street, PMB 40664, San Francisco, CA 94104-5401. We are also registered as a limited company in England and Wales and our registered office is at Orion House, 5 Upper St Martins Lane, London, WC2 9EA, United Kingdom. - Scope – What Does This Policy Cover?
This Privacy Policy does not extend to any websites that are linked to from Our Site (whether We provide those links or whether they are shared by other users). We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.
- Why do we collect your information?
There are a number of legal bases on which We rely to collect, share, use or otherwise process your data, including:
- where you have consented to the processing. You can revoke consent at any time by following the instructions in the Contacting Us section, located near the end of this privacy policy.
- as is necessary to perform our contractual agreement to provide Our services.
- where necessary to comply with a legal obligation, a court order, or to exercise and defend legal claims;
- to protect your vital interests, or those of others, such as in the case of emergencies;
- where the information has been made public by you;
- where necessary in the public interest; and
- where necessary for the purposes of Our or a third party’s legitimate interests, such as those of visitors, members or partners.
- What Data Do We Collect and How Do We Collect It?
Depending upon your use of Our Site, We may collect some or all of the following data:
Type of Data Examples How We Collect Data Contact information Full name, postal address, phone number, email address. This also includes the name and phone number of individuals you list as your emergency contact. This also includes the name and email address of individuals that you invite to use Our Site. Directly from you. Demographic data Date of birth, gender Directly from you. Login credentials Username and password Directly from you if you create an Account with Us. Social Media data Profile, username, profile picture, bio, email address, phone number We may collect this information from social media platforms, data analytics providers, or advertising partners.
If you chose to login to Our Site using, for example, your Facebook account, we collect this data from Facebook.
Preferences Which events you like or want to attend, for example, half marathons or obstacle runs Directly from you.
We may also collect this data, or other data about your purchasing or browsing preferences from our data analytics and advertising providers.
Any feedback you may provide to us This includes your reviews of our Site, events that you attend, or other services about which we solicit your feedback Directly from you.
We may also collect this data from third-party providers, such as Trustpilot.
Messages that you send through Our Site You may be able to chat with your friends through Our Site to, for example, coordinate training or day-of planning Directly from you if you use the chat services on Our Site. Geolocation City, State, Region, or Country We collect geolocation if you provide it directly to us or otherwise give us permission to collect this data. Health data Medical conditions We collect this data if you chose to provide it to us when booking an event. Photograph Profile images or other pictures or videos of you participating in events You have the option to add a profile picture when you create an Account with us.
We may also collect pictures or videos from event photographers that document events that you attend.
Device Data IP address, device model, device type, operating system and version, browser type and version, network information, and unique identifiers Automatically from your device and also from third-party partners, such as advertising networks, data analytics providers, internet service providers, and advertising partners. Online Activity Data Your interactions with Our Site, as well as the website you came from and the website you exit to Automatically from your device and also from third-party partners, such as advertising networks, data analytics providers, internet service providers, and advertising partners. We process photographs using facial recognition technology so that you can find and potentially purchase pictures of yourself competing at events. Some jurisdictions may interpret the use of facial recognition technology as creating biometric identifiers or information. We retain this data for as long as necessary for the specific purpose for which it was collected or a shorter period if a shorter period is required by law.
- How Do We Use Your Data?
- All personal data is stored securely in accordance with the principles of the Data Protection Laws. For more details on security see section 6, below.
- We use your data to provide the best possible products and services to you. In some cases we process your data as a data controller within the meaning of Data Protection Laws, where we process your data for our own means and purposes. This includes:
- Providing and managing your Account;
- Providing and managing your access to Our Site;
- Personalising and tailoring your experience on Our Site;
- Supplying Our products and services to you;
- Personalising and tailoring Our products and services for you;
- Responding to communications from you;
- Supplying you with notices about this privacy policy, information about or affecting your Account, marketing email alerts and newsletters that you have subscribed to (you may unsubscribe or opt-out of our marketing messages at any time using the unsubscribe link at the bottom of those emails);
- Conducting market research;
- Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site, your user experience, and future products or services that We may offer;
- Maintaining and enhancing the security and integrity of our Site
- On other circumstances we process your data as a data processor, in particular when process your data in collaboration with our event partners and where we process data about you as an event participant. In those circumstances we enter into agreements prescribed by Data Protection Laws which regulate our processing of data in accordance with the requirements of our partners.
- With your permission and/or where permitted by law, We may also use your data for marketing purposes, which may include contacting you by email, telephone, or post with information, news, and offers on Our products and services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the U.S. Telephone Consumer Protection Act, and UK and EU Privacy and Cookie Laws.
- Advertizers whose content appears on Our Site may engage in what is known as “behavioural advertising” – advertising which is tailored to your preferences, based on your activity on Our Site and other websites and online platforms. Your activity is monitored using Cookies, as detailed below in section 14. Please note that this practice may constitute a “sale” of data under some U.S. state laws. If you do not want Cookies to collect data about your activity on Our Site, you can adjust your web browser’s privacy settings or opt out of the practice by following the instructions in the Contacting Us section, located near the end of this privacy policy.
- With your consent, We may also use your data to:
- analyse user cohorts and behaviours across our Site; we build aggregated audiences around key attributes and behaviours
- facilitate targeted advertising Our SIte to provide relevant advertisements to you and to make effective use of advertising inventory
- We facilitate the above functions by using the advertising technology provider LOTAME, a data management platform, which we use for the purpose of gaining audience insights and enabling consented audience data to be activated through our advertising platforms. Lotame uses cookies and other identifiers to track online behavioural, demographic and technographic data; they don’t receive information such as your name and email. Lotame can also receive anonymous data segments that we send, such as user IDs associated with people who have been registered members for a certain length of time. Lotame stores data on average for 9 months, and in special cases for up to 18 months. Please note that we are not responsible for Lotame’s privacy practices. You can find Lotame’s privacy policy here.
- How and Where Do We Store Your Data?
- We only keep your data for as long as reasonably necessary to fulfill the purposes described above, and/or for as long as We have your permission to keep it.
- Some or all of the data we process about you, including data collected automatically via cookies and tracking technologies may be stored or transferred outside of the UK and the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein). If We do store or transfer data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under UK and EU Privacy and Cookie Laws. Such steps may include, but not be limited to, the use of legally binding contractual terms between Us and any third parties We engage and the use of the EU-approved Model Contractual Arrangements.
- Data security is of great importance to Us, and to protect your data, We have put in place suitable physical, electronic, and managerial procedures to safeguard and secure data collected through Our Site.
- Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.
- How Do We Share Your Data?
The following table illustrates how, why, and with whom we share your data.
Who Do We Share Your Data With? Why Do We Share Your Data? Event organizers, coordinators, hosts, charities, charity fundraising platforms,and other business partners To facilitate your booking.
To suggest new experiences, products, or services for you.
Where we sell an event entry to you, we may share certain information we collect from you on our SIte with an event organiser, if that information is required by the event organiser to allow you to participate in an event, for example if the event organiser needs that information for insurance purposes.
When you opt in to fundraise for a charity, we may share certain information we collect from you on our Site with that charity and/or a charity fundraising platform to enable you to collect donations for that charity.
Service providers To help us manage Our Site and provide you with Our products and services.
This includes service providers that help us with things like data hosting, customer support, data analytics, payment processing (including third party payment providers), and email and messaging delivery. Please note that we are not responsible for the privacy practices of third parties to which you are linked in connection with providing the services on our Site. You can find out more information about their privacy practices from their websites.
Advertising providers To better serve you with content, news, and offers that may be of interest to you. Professional advisors To assess, assert, and defend our own legal interests and obligations, and as appropriate to protect others’ rights, property, or safety.
This includes parties like our attorneys, consultants, auditors, and insurers.
Government authorities and other parties to comply with the law To assess, assert, and defend our own legal interests and obligations, and as appropriate to protect others’ rights, property, or safety.
This includes government agencies, investigatory bodies, law enforcement, and other third parties in response to a subpoena or court order.
Third parties within the context of a merger or acquisition, whether as part of an asset sale, corporate reorganization, or other change of control, including bankruptcy (collectively, “Merger Event”) To evaluate, assess, or effectuate any Merger Event
For more information about Merger Events, please see section 8, below.
- What Happens If Our Business Changes Hands?
- We may, from time to time, expand or reduce Our business as part of a Merger Event. Data provided by users will, where it is relevant to any part of Our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the data for the purposes for which it was originally collected by Us.
- In the event that any of your data is to be transferred as part of a Merger Event, you will be contacted in advance and informed of the changes. When contacted, you will not, however, be given the choice to have your data deleted or withheld from the new owner or controller.
- How Can You Control Your Data?
- When you submit information via Our Site, you may be given options to restrict Our use of your data, including the ability to opt-out of receiving emails from Us. To do so, you may unsubscribe using the links provided in Our emails or by following the instructions in the Contacting Us section, located near the end of this privacy policy.
- Depending on where you live, you may have additional rights with respect to your data. Please see sections 11 and 12 below for more information.
- EU Members’ Rights
Individuals who are habitually located in the EU and the UK have the right to access, rectify, receive a copy in portable form and to erase their information, as well as the right to restrict and object to certain processing of their information. While some of these rights apply generally, certain exclusions apply to these rights in certain limited circumstances. If you are habitually located in the EU or the UK, these rights apply to you. To exercise any of the following rights, you may contact us via the instructions in the section titled Contacting Us, below.
These rights are described below:
- Access and Porting: You have the right to ask for a copy of any of your personal data held by Us (where such data is held). You can access much of your information by logging into your account, but you may also access your data if you are not a registered member.
- Object: In certain cases you can object to Our processing of your personal data. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing (as outlined in section 4) or where it is needed for legal reasons.
- Rectify, Limit, Restrict, Delete: You can also rectify, limit, restrict or delete much of your information.
- Withdraw consent: Where you have previously provided your consent for the processing of your information, you have the right to revoke your consent at any time. In certain cases, We may continue to process your information after you have withdrawn consent if We have a legal basis to do so or if your withdrawal of consent was limited to certain processing activities.
- Complain: Should you wish to raise a concern about our processing of your information (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority. In the UK this is the Information Commissioner’s Office: https://ico.org.uk.
- Rights Available to Certain Residents of the United States
Depending on your state of residence (including California, Virginia, Colorado, Utah, Connecticut, Nevada, and potentially other states), you may have certain rights with respect to your data. We will strive to honour these rights no matter your place of residence, but we reserve our ability to fulfil your requests as legally required.
To exercise any of the following rights, you or your authorized agent may contact us via the instructions in Contacting Us, below.
We may request additional information to verify the authenticity of your request, including confirming data or other information that you have already provided to us, or potentially requesting additional data.
- Right to Know and Access. You may request that we confirm whether we are processing your data. Furthermore, you may request that we provide you with a copy of your data. You may also request that we disclose the categories of third parties with whom we share data, including identifying the categories of disclosed data.
- Right to Correct. You may request that we correct your data.
- Right to Delete. You may request that we delete the data that you have provided to us.
- Right to Opt Out of Targeted Advertising (also referred to as behavioural advertising). As described above, “behavioural advertising” is tailored to your preferences, based on your activity on Our Site and other websites and online platforms. Please note that this practice may constitute a “sale” of data under some U.S. state laws. If you do not want Cookies to collect data about your activity on Our Site, you can adjust your web browser’s privacy settings or opt out of the practice by following the instructions in the Contacting Us section, located near the end of this privacy policy.
- Right to Opt Out of the Sale of Data. You may request that we not “sell” your data, as defined under applicable U.S. state law. As described above, behavioural advertising may constitute a sale of data under some U.S. state laws.
- Right to Restrict Certain Processing. You have the right to limit or opt out of other processing activities, such as those involving automated decision-making or “sensitive” data, as defined by applicable U.S. state law.
- Right to Nondiscrimination. We will not discriminate against you for exercising these rights. However, where permitted by law, we may charge a reasonable fee in fulfilling certain requests.
In addition to these rights, you can always manage your communication preferences. If at any time you would like to unsubscribe from receiving future emails, you can follow the unsubscribe instructions included in the email communication or by following the instructions in the Contacting Us section, located near the end of this privacy policy.
If we deny any of the above rights, you may have the right to appeal the decision with us. If you would like to appeal a prior decision, please include ‘Appeal’ in your subject line, along with the prior request and related communications. Please send this to us following the instructions located below, in Contacting Us. Additionally, you may have the ability to contact your state’s attorney general (see information listed below) if you have concerns about the results of the appeal, by using the links below:
Virginia: https://www.oag.state.va.us/contact-us/contact-info
Colorado: https://coag.gov/about-us/contact-colorado-office-attorney-general/
Notice to Nevada Residents
We do not currently “sell” data according to Nevada law. If you would like to request that we not sell your data in the future, please follow the instructions in the Contacting Us section, located near the end of this privacy policy.
- California Residents
The following statements are made in compliance with the California Consumer Privacy Act (CCPA), as amended.
Because we engage in behavioural advertising, we may “sell” or “share” data as defined by CCPA. If you would like to opt out of this practice, please follow the instructions in the Contacting Us section, located near the end of this privacy policy.
he below categories of data marked with an asterisk (*) are considered ‘sensitive’ data according to CCPA. We do not process ‘sensitive’ data for purposes other than those specified in Cal. Code Regs. tit. 11, § 7027(l).
In the past 12 months, we have collected data described above, under What Data Do We Collect and How Do We Collect It? from the sources listed in the same section. This data falls into the following categories of data under the CCPA:
- Identifiers*
- Categories listed in California Civil Code 1798.80(e)
- Characteristics of protected classifications under California or federal law*
- Health information*
- Messages that you send through Our Site*
- Internet or electronic network activity information
In the past 12 months, We disclosed or shared the data described above under What Data Do We Collect and How Do We Collect It? with third parties described in How Do We Share Your Data?. This data falls into the following categories of data under the CCPA:
- Identifiers*
- Categories listed in California Civil Code 1798.80(e)
- Characteristics of protected classifications under California or federal law*
- Health information*
- Messages that you send through Our Site*
- Internet or electronic network activity information
- Cookies
Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our products and services.
By using Our Site, you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. This includes third party cookies that we use for behavioural advertising. In addition, Our Site uses analytics services provided by Google Analytics which also use Cookies. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling Us to better understand how people use Our Site. For a full list of the third-party cookies that we use, please refer to our cookie banner, available here
We are committed to providing you choices to manage your privacy and sharing. To manage the collection of information through cookies or other equivalent technology you can use the settings on your browser or mobile device or follow the instructions in the Contacting Us section, located near the end of this privacy policy. Please note that not accepting cookies may make certain features unavailable to you. We may also continue to use some data gathered through Cookies, such as your IP address, to identify you, to administer our services, and to assist in diagnosing problems with our servers.
- Contacting Us
If you have any questions about Our Site or this Privacy Policy, please contact Us by email at privacy@letsdothis.com, or by post at 548 Market Street, PMB 40664, San Francisco, CA 94104-5401 or at Aviation House, 125 Kingsway, London, WC2B 6NH. Please ensure that your query is clear, particularly if it is a request for information about or relating to the data We hold about you (as under sections 12 and 13, above).
- Children
Our Site is not directed at children under the age of 18. Although some of our events may offer participation options for minors, a parent or legal guardian must complete registration so that the minor may participate in the event. Additionally, event registration requires payment via credit card or other payment method, which requires the permission of the parent or legal guardian to complete.
- Changes to Our Privacy Policy
We may change this Privacy Policy as we may deem necessary from time to time, or as may be required by law. Any changes will be immediately posted on Our Site and any major changes will be emailed to our mailing list. We recommend that you check this page regularly to keep up-to-date.