About This Policy
This Privacy Policy Policy (“Policy”) explains how SPORTS TIMING SOLUTIONS LLP
(“STS”,
“we”, “us” or “our”) collects, receives,
uses, stores, discloses, protects and otherwise processes personal data in
connection
with the STS website, applications,
event-photo services, participant profiles, search and matching features,
galleries,
downloads and related services
(collectively, the “Services”).
This Policy is intended to be read together with the STS Terms of Use & Platform
Protection. Where STS processes personal data
on behalf of an event organiser or another business customer, the relevant
contractual
arrangement may also govern that
processing.
STS is an Indian limited liability partnership. Our principal place of business
is
stated above. For privacy requests, use the
contact details published in the “Contact and Grievance” section of this Policy.
Scope And The Data We Handle
Depending on how you use the Services, STS may process the following categories
of
information:
- Account and profile information: name, email address, mobile number, profile photograph, age or date of birth where provided, location or city where provided, athletic/event information, achievements, preferences and other fields you choose to place in your profile.
- Event and participation information: event name, event date, bib number, category, timing/result information, registration identifiers and related event records supplied by you or by an event organiser or service partner.
- Photographs and media: photographs captured at sporting events, images uploaded by users, profile images, and other media submitted to or displayed through the Services.
- Search and matching information: search terms, bib/photo searches, uploaded selfie or reference image, matching requests and information generated while responding to those requests.
- Technical and security information: IP address, device and browser information, operating system, approximate location inferred from technical information, access times, session information, diagnostic data, logs and security events.
- Transaction information: payment status, order details, download or purchase information and limited payment-related identifiers received from payment service providers. STS does not intend to store full payment-card credentials unless expressly stated at the point of collection.
- Communications: messages, support requests, complaints, correspondence and information provided when you contact STS.
- Information received from others: participant or event information supplied by organisers, timing providers, photographers or other authorised partners.
Profiles And Information You Choose to Provide
STS allows individuals to create and maintain profiles. You remain responsible
for the
information you choose to publish or
submit, including ensuring that it is accurate and that you are authorised to
provide
information relating to another person.
Profile fields may have different visibility depending on the Service and the
controls
made available to you. Information
intended to be private will not be treated as public simply because it is stored
in the
same account. You should nevertheless
avoid placing passwords, financial credentials, government-issued identity
numbers or
other information that STS does not
request into free-text profile fields.
If you request deletion of a profile or other personal data, STS will process
the
request in accordance with applicable law,
contractual obligations, legitimate retention requirements and the technical
realities
of backups and security records.
Photographs, Selfies And Visual Matching
STS may provide features that allow a participant to search for event
photographs using
a photograph or selfie supplied by the
participant. Depending on the implementation of the feature, the uploaded image
may be
analysed to identify visual
characteristics and compare them against photographs available through the
relevant
event service.
STS will use such information for the purposes disclosed at collection,
including
providing the requested search or matching
service, maintaining security, preventing abuse and improving the reliability of
the
Services where legally permitted.
Where a technical process generates a facial feature representation, embedding
or
similar derived value for matching, STS will
treat that derived information as personal data where applicable and will apply
appropriate safeguards. STS will not treat an
uploaded selfie as a general-purpose licence to identify, track or profile the
person
outside the Services.
The exact retention period for a selfie, derived matching information or
temporary
processing artefact may depend on the
particular feature and implementation. Where the information is no longer
required for
the disclosed purpose or a legally
permitted purpose, STS will delete or anonymise it in accordance with its
retention
practices.
Why We Process Personal Data
STS processes personal data only for lawful purposes and, where required, on the
basis
of consent or another permitted basis
under applicable Indian law. Purposes may include:
- creating and managing user accounts and profiles;
- providing event photography, search, matching, gallery, download and sharing services;
- associating event photographs with participant or event records;
- communicating with users, organisers and photographers;
- processing payments and fulfilling purchases or other transactions;
- protecting the Services against fraud, scraping, abuse, unauthorised access and security incidents;
- maintaining audit trails, logs, backups and business records;
- meeting legal, regulatory, tax, accounting and law-enforcement requirements;
- responding to complaints, disputes, takedown requests and legal notices; and
- performing analytics, service measurement, troubleshooting and product improvement to the extent permitted by applicable law.
Consent, Notice And Withdrawal
Where STS relies on consent, the request for consent will be presented in a
manner
intended to be clear and reasonably
understandable for the relevant processing. You may withdraw consent where the
law
provides for such withdrawal.
Withdrawal will not affect processing that STS is required or otherwise
permitted to
continue under applicable law.
Withdrawal of consent may affect the availability of a feature. For example, if
a
matching feature requires a reference image or
particular profile information, STS may be unable to provide that feature after
the
relevant permission is withdrawn.
Sharing And Disclosure
STS does not sell personal data as a standalone data product. We may disclose or
make
available personal data where necessary
for the Services, where authorised by the individual or relevant customer, or
where
required or permitted by law. Recipients
may include:
- Event organisers and authorised event representatives;
- Photographers and photography partners;
- Timing, registration or other event technology providers;
- Hosting, cloud storage, database, communications, analytics, payment and security service providers acting under appropriate contractual arrangements;
- Professional advisers, auditors, insurers and service providers where reasonably necessary;
- Government authorities, courts, law-enforcement agencies or regulators where required or lawfully requested; and
- A successor entity or transaction counterparty in connection with a merger, restructuring, acquisition or transfer of business, subject to applicable law.
Security Measures
STS maintains technical and organisational safeguards appropriate to the nature
and
risks of the personal data processed.
Depending on the Service, these may include access controls, authentication,
encryption
or encryption-at-rest/in-transit where
appropriate, secure storage, logging, monitoring, rate limiting, backup
controls,
vulnerability management, segregation of
access, and incident-response procedures.
No internet-connected service can guarantee absolute security. STS does not
represent
that its systems are immune from every
attack, vulnerability, failure or act of a third party. If a personal data
breach
occurs, STS will take the measures required under
applicable law, including applicable notification and remediation obligations.
Retention And Deletion
STS retains personal data only for as long as reasonably necessary for the
purpose for
which it was collected or otherwise as
permitted or required by applicable law, contractual commitments, dispute
resolution,
fraud prevention, security,
tax/accounting requirements and the establishment, exercise or defence of legal
claims.
Different categories of information may therefore have different retention
periods.
Security and audit logs may be retained for
longer than ordinary profile information where required for security, legal
compliance
or incident investigation.
Your Rights And Requests
Subject to applicable Indian law and any conditions or exceptions prescribed
thereunder,
individuals may have rights relating to
access to information about processing, correction/update, erasure, withdrawal
of
consent where applicable, grievance
redressal and nomination or other rights recognised by law.
Requests should be made through the contact details below. STS may need to
verify the
requester’s identity and may ask for
additional information reasonably necessary to locate the relevant account or
data and
prevent unauthorised disclosure.
Children And Minors
STS does not knowingly seek to collect personal data from children except where
permitted by applicable law and with the
permissions or arrangements required by law. Where an event or Service involves
minors,
the relevant organiser or responsible
adult may have additional obligations concerning participation and data
submission.
If you believe that a child’s personal data has been submitted to STS without
the
required authority, please contact us promptly.
Cookies And Similar Technologies
STS may use cookies, local storage, pixels, analytics tools and similar
technologies for
login, security, preferences, measurement
and service functionality. Where required, STS will provide appropriate notice
and
controls. Blocking certain technologies may
affect parts of the Services.
International Processing And Service Providers
Some infrastructure or service providers used by STS may process information
outside
India. Where personal data is transferred
or made available outside India, STS will do so subject to applicable Indian law
and any
restrictions or requirements prescribed
by the Central Government or other competent authority.
Changes To This Policy
STS may update this Policy from time to time to reflect changes to the Services,
law,
regulatory requirements or business
practices. Material changes will be communicated through the Services or other
appropriate means where required. The revised
version will state its effective or last-updated date.
Applicable Law
This Policy is governed by the laws of India. Nothing in this Policy is intended
to
exclude, restrict or waive any right or obligation
that cannot lawfully be excluded, restricted or waived under applicable law.
This Policy is intended to operate with the Digital Personal Data Protection
Act, 2023
and applicable rules and notifications
made thereunder, together with other applicable Indian laws and regulatory
directions
relevant to STS's activities.