Privacy policy #

Last updated: February 3, 2021

The privacy of your data — and it is your data, not ours! — is a big deal to us. In this policy, we lay out: what data we collect and why; how your data is handled; and your rights to your data. We promise we never sell your data: never have, never will.

What we collect and why #

Our guiding principle is to collect only what we need. Here’s what that means in practice:

Identity & access #

When you sign up for Outer Circle, we typically ask for identifying information such as your name, email address, and maybe a company name. That’s just so you can personalize your new account, and we can send you invoices, updates, or other essential information. We’ll never sell your personal info to third parties, and we won’t use your name or company in marketing statements without your permission either.

Event Organisers #

If you run an event via Outer Circle, you will need to provide information about that event including the time and location, your ABN and billing details, a link to your Stripe account, and other such practical details. You will also provide publicly-available information about your Event so that your customers can learn about you.

When you pay for an Outer Circle Service, we collect our service fee from each payment processed. That means we do not need to collect your credit card details. That's how we can charge you for service, calculate taxes due, and send you invoices.

Event Entrants #

If you enter an event via Outer Circle, you will need to provide personal information including your name and address, date of birth, email address, gender, and medical history. This is to facilitate the safe and fair running of that event. Details you provide are shared with the organiser of that event - your permission for this transfer is part of your event entry process.

We do not access that information unless it is in the course of assisting you or the event organiser with a support issue, for service maintenance and troublehsooting purposes, or if required by law enforcement.

We do not share your personal information with any other party unless required by law enforcement.

Your credit card is passed directly to our payment processor and doesn't ever go through our servers nor get provided to the event organiser. We store a record of the payment transaction, including the last 4 digits of the credit card number and as-of billing address, for account history, invoicing, and billing support. We store your billing address to calculate any sales tax due in Australia, to detect fraudulent credit card transactions, and to print on your invoices.

Event Organisers - access to Entrant Information #

Event Organisers are in a privileged position as they handle the personal information - including age, medical history, and sports performance - of other parties. As such, event organisers are also bound to protect the privacy of their entrants.

Event Organisers must not share any personal information provided to them by an Event Entrant using Outer Circle without prior written permission from that Entrant. This means that you cannot publish a list of event registrants, nor can you share somebody's medical history or other details.

Event Organisers - Emergency contact details #

During the course of running a footrace, Event Organisers may use emergency contact details provided to them by an Entrant in a circumstance that one would reasonably expect such details to be used. For example if an athlete has a major injury it is expected that the event organisers, or their delegate, would contact the emergency contact person(s) provided to them by the athlete.

Geolocation data #

We may log all access to all accounts by full IP address so that we can verify no unauthorized access has happened. We may keep this login data for as long as your product account is active.

We also log full IP addresses used to sign up an account. We may keep this record forever because they are used to mitigate spammy signups.

Web analytics data — described further in the Website Interactions section — are also tied temporarily to IP addresses to assist with troubleshooting cases.

Website interactions #

When you browse our marketing pages or applications, your browser automatically shares certain information such as which operating system and browser version you are using. We track that information, along with the pages you are visiting, page load timing, and which website referred you for statistical purposes like conversion rates and to test new designs. We sometimes track specific link clicks to help inform some design decisions. These web analytics data are tied to your IP address and user account if applicable and you are signed into our Services.

We may use 3rd party tools to assist with this data tracking and management.

Cookies and Do Not Track #

We do use persistent first-party cookies to store certain preferences, make it easier for you to use our applications, and support some in-house analytics. A cookie is a piece of text stored by your browser to help it remember your login information, site preferences, and more. You can adjust cookie retention settings in your own browser. To learn more about cookies, including how to view which cookies have been set and how to manage and delete them, please visit: www.allaboutcookies.org.

At this time, our sites and applications do not respond to Do Not Track beacons sent by browser plugins.

Voluntary correspondence #

When you write to us with a question or to ask for help, we keep that correspondence, including the email address, so that we have a history of past correspondences to reference if you reach out in the future.

We also store any information you volunteer like surveys. Sometimes when we do customer interviews, we may ask for your permission to record the conversation for future reference or use. We only do so if you give your express consent.

Information we do not collect #

We don’t collect any characteristics of protected classifications including race, religion, sexual orientation, or physical and mental abilities or disabilities. You may provide these data voluntarily, such as if you include a pronoun preference in your email signature when writing into our Support team.

We also do not collect any biometric data.

Our default practice is to not access your information. The only times we’ll ever access or share your info are:

To event organisers, for events that you have registered for. This is so those event organisers can safely and fairly run their event and collect payment from you. This is the driving purpose of our service!
To provide products or services you've requested. We do use some third-party services to run our applications and only to the extent necessary process some or all of your personal information via these third parties. You can view the list of third-party services we use in our Subprocessors list. Having subprocessors means we are using technology to access your data. No Outer Circle human looks at your data for these purposes. We also use some other processors for other business functions, which you can view in the above list.
To help you troubleshoot or squash a software bug, with your permission. If at any point we need to access your account to help you with a Support case, we will ask for your consent before proceeding.
To investigate, prevent, or take action regarding restricted uses. Accessing a customer’s account when investigating potential abuse is a measure of last resort. We have an obligation to protect the privacy and safety of both our customers and the people reporting issues to us. We do our best to balance those responsibilities throughout the process. If we do discover you are using our products for a restricted purpose, we will report the incident to the appropriate authorities.
When required under applicable law. If the appropriate law enforcement authorities have the necessary warrant, criminal subpoena, or court order requiring we share data, we have to comply. Otherwise, we flat-out reject requests from local and federal law enforcement when they seek data. And unless we’re legally prevented from it, we’ll always inform you when such requests are made.

If Outer Circle is acquired by or merged with another company — we don’t plan on that, but if it happens — we’ll notify you well before any info about you is transferred and becomes subject to a different privacy policy.

Location of Site and Data #

Our products and other web properties are operated in the United States. If you are located in Australia, the European Union or elsewhere outside of the United States, please be aware that any information you provide to us will be transferred to the United States. By using our Site, participating in any of our services and/or providing us with your information, you consent to this transfer.

Your Rights With Respect to Your Information #

At Outer Circle, we apply the same data rights to all customers, regardless of their location. Currently some of the most privacy-forward regulations in place are the European Union’s General Data Protection Regulation (“GDPR”) and California Consumer Privacy Act (“CCPA”) in the US. Outer Circle recognizes all of the rights granted in these regulations, except as limited by applicable law. These rights include:

Right to Know. You have the right to know what personal information is collected, used, shared or sold. We outline both the categories and specific bits of data we collect, as well as how they are used, in this privacy policy.
Right of Access. This includes your right to access the personal information we gather about you, and your right to obtain information about the sharing, storage, security and processing of that information.
Right to Correction. You have the right to request correction of your personal information.
Right to Erasure / “To be Forgotten”. This is your right to request, subject to certain limitations under applicable law, that your personal information be erased from our possession and, by extension, all of our service providers. Fulfillment of some data deletion requests may prevent you from using Outer Circle services because our applications may then no longer work. In such cases, a data deletion request may result in closing your account.
Right to Complain. You have the right to make a complaint regarding our handling of your personal information with the appropriate supervisory authority.
Right to Restrict Processing. This is your right to request restriction of how and why your personal information is used or processed, including opting out of sale of personal information. (Again: we never have and never will sell your personal data).
Right to Object. You have the right, in certain situations, to object to how or why your personal information is processed.
Right to Portability. You have the right to receive the personal information we have about you and the right to transmit it to another party.
Right to not be subject to Automated Decision-Making. You have the right to object and prevent any decision that could have a legal, or similarly significant, effect on you from being made solely based on automated processes. This right is limited, however, if the decision is necessary for performance of any contract between you and us, is allowed by applicable law, or is based on your explicit consent.
Right to Non-Discrimination. This right stems from the CCPA. We do not and will not charge you a different amount to use our products, offer you different discounts, or give you a lower level of customer service because you have exercised your data privacy rights. However, the exercise of certain rights (such as the right “to be forgotten”) may, by virtue of your exercising those rights, prevent you from using our Services.

Many of these rights can be exercised by signing in and directly updating your account information.

If you have questions about exercising these rights or need assistance, please contact us at [email protected]. For requests to delete personal information or know what personal information has been collected, we will first verify your identity using a combination of at least two pieces of information already collected including your user email address. If an authorized agent is corresponding on your behalf, we will first need written consent with a signature from the account holder before proceeding.

How we secure your data #

All data is encrypted via SSL/TLS when transmitted from our servers to your browser. The database backups are also encrypted in transit. Most data are not encrypted while they live in our database (since it needs to be ready to send to you when you need it), but we go to great lengths to secure your data at rest.

For more information about how we keep your information secure, please review our security overview.

When you delete data in your accounts #

For event entrants, we give you the option to delete data. Data you delete is removed from our servers immediately. Some data is not deleted, in particular a reord of events you have entered previously. This is because the event organiser requires this information for their financial and taxation purposes. We do remove your contact details (phone number, email address) and medical history from those entries.

We also have some backups of our application databases, which are kept for up to another 30 days. This means that when you trash things in our applications, they are purged within 30 days from all of our systems and logs. Retrieving data for a single account from a backup is cost-prohibitive and unduly burdensome so if you change your mind you’ll need to do so before your data are deleted from our active servers.

We also delete your data after an account is cancelled. This applies both for cases when an account owner directly cancels and for auto-cancelled accounts. Please refer to our Cancellation policy for more details.

Changes & questions #

We may update this policy as needed to comply with relevant regulations and reflect any new practices. Whenever we make a significant change to our policies, we will notify account holders via email.

Have any questions, comments, or concerns about this privacy policy, your data, or your rights with respect to your information? Please get in touch by emailing us at [email protected] and we’ll be happy to answer them!