Data Processing Agreement

This agreement is between your club (the controller) and ClubCP, Unit 1202, Conington Road, London SE13 7GX, United Kingdom (the processor). It forms part of the Terms and Conditions and takes effect when your club starts using ClubCP.

It covers the personal data your club collects from and about its members through ClubCP. It does not cover the data we hold as a controller in our own right, which is our relationship with an individual account holder and is described in the privacy notice. Where this agreement and the Terms conflict on data protection, this agreement wins.

Subject matter and purpose. Running your club: memberships, events, tickets, attendance, payments, posts and messages.

Duration. For as long as your club uses ClubCP, and then as set out in clause 9.

Types of personal data. Name, email address, year of birth and where you ask for it full date of birth, profile details, phone number, emergency contact, membership and event records, attendance, payment records, and the content of posts and messages.

Categories of data subject. Your club's members, its administrators, and guests who buy a ticket without an account.

Special category data. ClubCP does not ask for it. If you use a custom field to collect health information such as a medical note or a dietary requirement, you are responsible for having an Article 9 condition for it, and you should tell us so we can advise on whether the field is appropriate.

We process your members' personal data only on your documented instructions, including on any transfer of that data to another country. Your instructions are: the Terms, this agreement, the settings you choose in the product, and anything you ask us in writing at support@clubcp.app.

We will tell you if we think an instruction breaches data protection law, and we may decline to follow it until it is resolved.

We will not use your members' personal data for our own purposes. We do not sell it, we do not use it to train AI models, we do not use it for advertising, and we do not use one club's data to benefit another.

If we are required by law to process the data beyond your instructions, we will tell you before we do unless the law prohibits us from telling you.

Everyone we allow to access your members' personal data is bound by a duty of confidentiality, and access is limited to those who need it to run or support the platform.

We maintain technical and organisational measures appropriate to the risk, including: encryption in transit, passwords stored only as one-way hashes, role-based access control within each club, rate limiting and anti-bot checks on authentication, error monitoring, and daily database backups that are tested by restore.

We review these as the platform changes. No online service can promise absolute security, and this clause is a commitment to a standard of care rather than a guarantee of outcome.

You give us general authorisation to appoint the sub-processors below. Each is bound by written terms that impose data protection obligations no less protective than these, and we remain fully liable to you for what they do.

We will give you at least 30 days notice by email before adding or replacing a sub-processor. If you object on reasonable data protection grounds, tell us within those 30 days and we will work with you to find an alternative. If we cannot, you may close your club without penalty and export your data first.

Most member requests you can handle yourself in the product: members edit their own profiles, and you can view, correct, export and remove member records from your club's admin screens.

Where a request needs us, we will help you meet your deadline. If a member contacts us directly about data you control, we will not answer for you; we will tell them to contact you and let you know it happened.

If we become aware of a personal data breach affecting your members' data, we will notify you without undue delay and in any event within 48 hours of becoming aware, so that you can meet your own 72 hour deadline to the regulator. We will tell you what we know, what we are doing, and what we recommend you do.

We will also give you reasonable help with data protection impact assessments and with any prior consultation with a regulator, so far as the assistance relates to our processing and to information only we hold.

When your club stops using ClubCP, you can export your members', events and payment data. Tell us within 30 days whether you want the data returned or deleted.

By default we delete it after 90 days. We keep only what we are required to keep, principally payment and transaction records for seven years for tax and financial-record purposes, and anything still needed to resolve a live dispute. Backups are overwritten on their normal cycle rather than edited, so data can persist in a backup for a short period after deletion from the live system.

We will give you the information you reasonably need to show that we are meeting these obligations, on request to support@clubcp.app.

You may audit our compliance, or appoint an independent auditor to do so, once in any 12 month period and on 30 days notice, or sooner if a regulator requires it or after a breach affecting your data. Audits happen during business hours, must not compromise other clubs' data or the security of the platform, and you cover your own costs. We will answer a written questionnaire instead where that reasonably satisfies you, and in practice it usually will.

Our servers are in Germany. If your club is in Australia, your members' data is stored overseas, and you should say so in whatever privacy information you give your members. Australian Privacy Principle 8 makes that your disclosure to make, not ours, and this clause is the information you need to make it.

Where a sub-processor puts personal data outside the UK or the EU, we rely on that organisation's standard contractual clauses or on an adequacy decision, whichever applies.

You must have a lawful basis for collecting what you collect, tell your members what you do with it, ask only for what you actually need, keep it accurate, and answer your members' requests about it.

Do not use ClubCP to collect data you have no reason to hold. A custom field is easy to add and hard to justify later; if you cannot say why your club needs something, do not ask for it.

You are responsible for who you make an administrator. An admin can see your members' contact details, and removing someone who has left is your job, not ours.

This agreement is governed by the law of England and Wales. Liability under it is subject to the limits in the Terms and Conditions.

We will update this page as the platform changes, and will give notice of a material change in the same way as for the Terms. Questions go to support@clubcp.app.