Privacy Statement

This Privacy Policy is effective from 15 November 2022



1. Our commitment to privacy

Counter Ruck Pte Ltd (Company No. 2021RC000498) (the “Drua”) (we, us, our) takes the protection of your privacy very seriously. We recognise that your personal information is valuable and we process it in accordance with applicable law, and to the extent that it applies to your personal information, with the European Data Protection Legislation.

This Privacy Policy sets out how we collect, use, store and disclose your personal information. It applies to all personal information that we collect or you disclose during your use of the Drua’s website located at https://drua.rugby/ (the “Drua Website”), the Drua’s official shop website located at https://shop.drua.rugby/ (the “Drua Shop”) and the Drua’s official ticket website located at https://drua.flicket.io/ (the “Drua Ticket Website”) (collectively known as the “Websites”), and the provision of any other services from us to you.

By using the Websites, or by providing personal information to us, you consent to the collection, use, storage and disclosure of your personal information as set out in this Privacy Policy.

We may update this Privacy Policy from time to time. The most current version will always be located on the Drua Website and is also available by contacting our Privacy Officer by email or at the address detailed below.

Your continued use of the Websites and our services following the effective date of a change to this Privacy Policy signifies your acceptance and agreement to the terms of the revised Privacy Policy. We encourage you to check this page periodically to determine the current terms.

Controller of Personal Information

Any personal information processed by us in connection with this Privacy Policy is controlled by the Drua, which is considered to be the “controller” of your personal information under European Data Protection Legislation, to the extent it applies to personal information collected about you, and other applicable laws.

If you have made a booking or purchase with a third-party service provider, such as our Drua Shop, then that other entity will also separately be considered a “controller”. Please be careful to review privacy policies of such service providers separately, which you can access from them directly.

European Data Protection Legislation

For the purposes of this Privacy Policy, “European Data Protection Legislation” means all applicable legislation relating to data protection in the European Economic Area (“EEA”), including the EU General Data Protection Regulation 2016/679 (“GDPR”) and all pieces of legislation implementing or made under, or pursuant to, or replacing or superseding, the GDPR. Where this Privacy Policy uses terms which are defined in the GDPR, the definitions set out in the GDPR will apply.



2. Types of personal information we collect and hold

The types of information we collect and hold will vary depending on your use of the Websites, your dealings with the Drua and the products, services and benefits we (or our agents, contractors and third-parties) provide to you, or a request or inquiry you may make in relation to such products, benefits and services. This information may include any or all of the following:

• name, address(es), telephone number(s) and other contact details;
• electronic address(es);
• date of birth;
• gender;
• occupation;
• billing details;
• credit card information;
• details of items ordered or purchased from us;
• information about your use of our products or services;
• information collected in response to our user surveys;
• information about the webpages, content, functions and links you visit or interact with when on the Websites;
• memberships, subscriptions and attendance history at Fijian Drua matches (whether you have used your membership to purchase tickets, or as a casual ticket purchaser); and
• purchasing preferences and financial details which we collect when you buy tickets, purchase merchandise and/or participate in competitions and promotions being run by the Drua;
• location information; and
• information relating to your rugby preferences, including, for example, information regarding your favourite player/s and team/s.

The Drua will generally not collect any sensitive personal information from you. However, where the Drua seeks to collect sensitive personal information from you, it will do so in accordance with all applicable privacy laws, for instance by obtaining your express consent for such a collection.

You can choose not to provide us with any of your personal information. However, if you choose not to provide us with your personal information in these circumstances, we will be unable to respond to your enquiry, engage in further communications with you and/or provide the requested services.



3. Why we collect and hold personal information

The Drua generally only collects, uses, discloses or holds personal information that is reasonably necessary for the Drua to perform one or more functions or activities as a club and to pursue its legitimate interests, including (without limitation):

• direct communication with you by the Drua;
• to analyse your use of the Websites (and to assist us to better serve you, such as providing our products and services to you more effectively);
• organisation, conduct and promotion of matches involving the Fijian Drua (for instance, providing you with information about upcoming ticket offers and deals for the next home matches);
• promotions and competitions being run by the Drua;
• promotion and sale of the Fijian Drua merchandise; and
• direct marketing of the Fijian Drua and their sponsors’ products or services.

We only use, disclose or hold your personal information for the primary purpose for which it was collected, and a related secondary purpose, in accordance with any express consent you grant us or as otherwise required by law (e.g. where your personal information is requested by a law enforcement agency).



4. How we collect information

Where it is reasonable and practicable to do so, the Drua will collect personal information directly from you as follows (without limitation):

• when you apply for a ticket, membership or hospitality for the Fijian Drua through the Drua Ticket Website;
• when you order merchandise through the Drua Shop;
• when you participate in Drua promotional activities and competitions through the Drua Website or elsewhere;
• when you make inquiries with the Drua or subscribe to receive emails from the Drua; and
• through your use of the Websites generally.

In addition to collecting personal information directly from you, we may also collect personal information from third parties such as:

• our service providers;
• our ticketing and merchandising partners; and
• the third-party host of any of the Websites.



5. How we use and disclose personal information

We may use and disclose your personal information to conduct our business and to pursue our legitimate interests, including (without limitation):

• to respond to your queries regarding any of the Websites, our products or services;
• to process and administer your tickets, membership or hospitality purchases, or dealings with us as a user, including processing of payments, refunds or exchanges;
• to inform you of important event-related information, for example time or event changes, transport information or related events;
• to other organisations that we have appointed to carry out administration, processing and other services on our behalf;
• to provide you with the products or services you have requested from us;
• to carry out marketing, promotional and publicity activities (including direct marketing), market research and surveys;
• to track and analyse activity on the Websites;
• to delivery, courier and postal organisations in order to deliver merchandise you order using the Drua Shop;
• to law enforcement and emergency services agencies where required or authorised to do so by law;
• to understand and respect your preferences and to provide details of relevant offers and opportunities where you have agreed to receive them; and
• for any other purpose which is stated to you at the time of collection or that you otherwise authorise.

Withdrawing consent

Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for disclosing or processing your data for other purposes, such as those set out above.



6. Website cookies

Information is also generated and collected whenever a page is accessed on the Websites that records information such as the time, date and specific page. We collect such information for statistical and maintenance purposes that enables us to continually evaluate the performance of the Websites. Some parts of the Websites also use "cookies". A "cookie" is a small text file that is placed on your computer's hard drive by a web page server. Cookies store information about the use of each of the Websites and are used to identify new or previous visitors to the Websites and what pages have been accessed. Most web browsers are set to accept cookies, but this function can usually be disabled if you wish. Please note that if you do disable this, not all functionality on the Websites will be available to you.

By way of example, we use a web-tracking solution by Snowplow Analytics Limited (“Snowplow”) to collect information about your use of the Drua Website. We use data collected by Snowplow exclusively for statistical purposes. The Snowplow tool collects information such as how often users access the Drua Website, which pages they visit and at what times they visit the Drua Website. The Snowplow tool does not collect any personal information relating to users of the Drua Website and is used by the hosting service provider of the Drua Website to improve the site and our products and services.

We also use Google Analytics features (including Google Remarketing, Google Display Network Impressions Reporting, the Double Click Campaign Manager and Google Analytics Demographics and Interest Reporting) on the Websites, which uses both first party and third-party cookies to record standard internet traffic information. We, and some third parties (including Google), also use the information to optimise ad selection for groups of individuals based on age, gender, interests and past visits to our site. The cookies allow us and other third-parties (including Google) to evaluate your interactions with ad services on our site and serve targeted advertising on sites across the Internet. We have enabled Google Analytics for Display Advertising which allows Google and other third parties to advertise to you on the Drua Website and across the Internet.

We also use (along with third-parties including Google) first-party cookies (such as Google Analytic cookies) and third-party cookies (such as the DoubleClick cookie) to report how our ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to the Websites. In addition, we use data from Google's Interest-based advertising or third-party audience data (such as age, gender, and interests) with Google Analytics to help us understand how user activity varies based on these factors.

By using Google Ads Settings (www.google.com/settings/ads), you can opt out of these features at any time and customise your Google Display Network Ads. Alternatively, you can opt out of a third-party's vendor's use of cookies by visiting the Network Advertising Initiative opt-out page (see http://www.networkadvertising.org/choices/#completed).

Importantly, we do not combine the anonymous information collected through Google Analytics with personally identifiable information.

In addition to Google Analytics, we use a range of web analytics tools (such as web beacons) to help us understand consumer behaviour and use of our website. In particular, these tools enable us to deliver cookies, count visits and understand usage and campaign effectiveness. This data helps us to stay connected and relevant to our members and fans.

If you do not wish to receive any cookies you may set your browser to refuse cookies. However, this will mean that we will not be able to personalise your visit to any of the Websites each time you visit.



7. Storage and protection of personal information

We store personal information in a combination of secure computer storage facilities and paper-based files and other records. In so doing, we have taken numerous steps to protect your personal information from misuse, interference and loss, and unauthorised access, modification, or disclosure.

Additionally, we take reasonable steps to destroy or permanently de-identify personal information when we no longer need it. We impose strict requirements of security and confidentiality on all third parties as to how they store, handle and deal with your personal information.



8. Retention of Personal Information

We will keep your information for as long as we need it for the purpose it is being processed for. For example, where you purchase merchandise from us, we will keep the information related to your purchase so we can fulfil the specific purchasing request you have made, and after that we will keep the information for a period which enables us to handle or respond to your complaints, queries or concerns relating to the purchase. The information may also be retained so that we can continue to improve your experience with us.

We will actively review the information we hold and delete it securely, or in some cases anonymise it, when there is no longer a legal, business or customer need for it to be retained. We may retain a record of the existence of our relationship with you, to the extent that and for as long as we are required to do so by the applicable law.



9. Direct marketing

When you opt-in to receive communications from us, you are giving your consent for your personal information to be used by us to contact you by email and direct mail, and to deliver personalised experiences for each of the Websites, to share information about relevant products, services, news, and events.

Where you no longer wish to receive direct marketing materials from us in the future, you may use the opt-out facility in marketing communication, or you may contact us at any time using contact details provided below.

Withdrawing your consent will not affect our use of personal information prior to you withdrawing that consent but it will mean that we will not be able to contact you about the services we may be able to offer you or your business in the future.



10. Overseas disclosure of personal information

The Drua Website is hosted in the United Kingdom, the Drua Shop website is hosted in Australia and the Drua Ticket Website is hosted in New Zealand.

Subject to the two paragraphs below, the Drua will not transfer your personal information to an overseas recipient unless it has first taken steps reasonable in the circumstances to ensure that the personal information that it transfers will not be held, used, or disclosed by the recipient of the information inconsistently with, or otherwise in breach of, applicable privacy laws. For example, the Drua may adopt appropriate contractual clauses with overseas recipients that ensure their compliance with applicable privacy laws.

We may disclose your personal information to overseas recipients for things such as processing membership, product orders and hosting services, although countries where such recipients are located may vary. This may include using outsourced services in countries outside the European Union from time to time. Accordingly, for residents based in the EEA, data obtained within the United Kingdom or any other country could be processed outside the European Union.

The Drua may transfer personal information about you to someone who is in a foreign country if:

• the Drua reasonably believes that the recipient is subject to a law or binding scheme that has the effect of protecting the information in a way that is, overall, substantially similar to applicable privacy laws and there are mechanisms available to you to enforce that protection or scheme; and
• you expressly consent to the transfer after the Drua has informed you that the applicable privacy laws will no longer apply if you provide your express consent.



11. Advertising and third-party links

The Websites may contain links to a variety of advertising and third-party website sources. Some of these links may request and/or record information from users or use cookies or other methods to collect information from you. We have no control over the content or privacy policy practices of those sites and encourage our users to review the privacy policies of those sites before engaging in any activity with them.



12. Access to, and correction of, personal information

We will take reasonable steps to make sure that the personal information we collect, hold, use, or disclose is accurate, complete, and up to date. If your personal details change, such as your address or phone number, you can update them using the online portal on each of the Websites.

Following a request, we will provide you with a copy of any personal information which we hold about you in accordance with our obligations under applicable privacy law. We may charge a fee for retrieving this information, in which case we will inform you of the fee in advance of providing the information.

In certain circumstances, we may refuse to provide you access to your personal information. Where we refuse you access, we will provide you with a written explanation as to the reasons for the rejection (for instance, we may refuse to disclose personal information to you where such access would have an unreasonable impact on the privacy of other individuals).



13. Rights under the European Data Protection Legislation

With respect to the personal information that we collect about you, and to the extent that you are located in the EEA, under European Data Protection Legislation you have the right to:

• request access to that personal information;
• receive a copy of the personal information that you have provided to us in a structured commonly used format so that you can share it with others;
• where personal information is inaccurate or incomplete, ask for personal information to be rectified or completed;
• request the transfer of your personal information to another party;
• ask that personal information be erased;
• object to us processing your personal information by asking for the processing of that personal information to be restricted or stopped (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing); and
• make a complaint to the European data protection authority about the manner in which we process your personal information.

Please contact us using the details below to exercise these rights or for additional information. If you have an online account with us, you may be able to log into your account to access and update the information you have provided to us.



14. Making a complaint

If you wish to complain about our handling of your personal information, please send a written complaint to the Privacy Officer in the first instance by using the contact details below. We undertake to promptly acknowledge and investigate any complaint about the way we manage personal information.



15. Contacting us

If you have any questions about this Privacy Policy, if you wish to update information we hold about you or if you wish to make a complaint, please write to the Drua’s Privacy Officer:

The Privacy Officer

Email: privacyofficer@drua.rugby

Post: Lot 51 Voivoi Road, Legalega, Nadi, FIJI



[Last updated November 2022]