Privacy Policy

Last updated: 1 January 2025

Real Code Ltd ("we", "us", "our") is committed to protecting your personal data and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use the Club Term platform ("Platform") at clubterm.com. It applies to all users including sports facility owners, coaches, participants, and parents/guardians.

This policy is compliant with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

1. Data Controller

Real Code Ltd is the data controller for personal data processed in connection with your use of the Platform. For facility-specific data (participant records managed by a sports club using Club Term), the facility operator is the data controller and Real Code Ltd acts as a data processor on their behalf.

Contact: [email protected]

2. What Data We Collect

We collect the following categories of personal data:

Account & Identity Data

Name and email address
Organization name and type
Password (stored as a one-way hash, never in plain text)

Participant & Booking Data

Participant names, ages, and contact details
Parent/guardian names and contact information
Medical information and emergency contacts (collected on registration forms)
Booking history and program enrollments
Uploaded documents (waivers, medical certificates, photo permissions)

Financial Data

Subscription billing records and payment status
Billing details processed by Paddle (we do not store full card numbers)

Usage & Technical Data

IP address and browser/device type
Pages visited and features used (for platform improvement)
Session logs and error reports

3. How We Use Your Data

We use your personal data to:

Provide, operate, and maintain the Platform
Process bookings and issue invoices for them
Send service emails such as sign-in links, team invitations, and invoice notifications
Enable coaches to view session schedules and squad lists
Enable staff to manage participant and guardian records
Generate operational reports for club managers
Comply with legal obligations and resolve disputes
Improve the Platform based on usage analytics

4. Legal Basis for Processing

We process your personal data on the following legal bases:

Contract performance - processing necessary to provide the services you have subscribed to
Legitimate interests - improving the Platform, fraud prevention, and security
Legal obligation - retaining financial records for HMRC compliance
Consent - for optional communications such as newsletters (where applicable)

5. Data Sharing

We do not sell your personal data. We may share data with trusted third-party service providers who help us operate the Platform (such as cloud hosting, email delivery, and payment processing). These providers are contractually bound to process data only on our instructions and in accordance with UK GDPR.

We may disclose data if required by law, court order, or to protect the rights, property, or safety of Real Code Ltd, our users, or the public.

6. Data Retention

We retain personal data for as long as your account is active and for a reasonable period thereafter to comply with legal obligations (e.g., financial records are retained for 7 years as required by HMRC). When data is no longer required, it is securely deleted or anonymized.

7. Your Rights

Under UK GDPR, you have the right to:

Access - request a copy of your personal data
Rectification - request correction of inaccurate data
Erasure - request deletion of your data (subject to legal obligations)
Restriction - request that we limit processing of your data
Portability - receive your data in a structured, machine-readable format
Objection - object to processing based on legitimate interests
Withdraw consent - where processing is based on consent

To exercise any of these rights, email [email protected]. We will respond within 30 days.

8. Children's Data

Club Term is designed to be used by sports facilities that may manage data for children. All child participant data is collected and processed on behalf of the facility operator (data controller). Parents and guardians can request access to, correction of, or deletion of their child's data by contacting the facility directly or by emailing us at [email protected].

9. Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These include encryption at rest and in transit, access controls, and regular security reviews.

10. Cookies

We use cookies to operate the Platform and improve your experience. For full details, see our Cookie Policy.

11. Changes to This Policy

We may update this Privacy Policy periodically. We will notify you of significant changes by email or via an in-app notice. The "Last updated" date at the top of this page reflects the most recent revision.

12. Complaints

If you are unhappy with how we handle your personal data, you have the right to lodge a complaint with the UK Information Commissioner's Office (ICO) at ico.org.uk.

13. Company Details

The data controller responsible for your personal data under this Privacy Policy is Real Code Ltd, 86-90 Paul Street, London, EC2A 4NE. Registered in England and Wales, company number 08919593. ICO registration number ZB939242.