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This policy explains what personal information we collect, why we collect it, who else sees it, where it is held and how long we keep it. We have written it for the people who use our software, and for the parents and guardians of the children who compete on it.
We are Inchol Solutions Inc., and we build and operate software for dance and cheer competitions.
Our Privacy Officer answers questions about this policy and about the personal information we hold.
The address dpo@inchol.com reaches our Privacy Officer.
The telephone number is toll free within Canada and the United States. It may not be reachable from outside North America. If you are in the United Kingdom, the European Economic Area or anywhere else outside North America, please use email or post.
If your complaint is about the Privacy Officer, write to our postal address marked for the attention of the Chief Executive Officer, who then takes the decisions the Privacy Officer would normally take.
Our postal address is on Your Privacy Rights.
This policy covers these websites and the software we provide through them.
It is written for three groups of people.
This policy is about information we handle through our products and services: information about customers, the people who use our software, visitors to our websites, and others whose information reaches us that way. Information about our own employees, contractors and job applicants is not covered here. It is handled under our employment privacy terms, and anyone who works for us can ask our Privacy Officer for them.
The other pages in this set are listed at Privacy and Security Policies.
Which role we play decides who is responsible for your information and who answers your questions.
Where you hold an account with us, or buy photographs and video, an event pass or extended hosting, we are responsible. We decide what is collected and why, this policy governs it, and you exercise your rights with us.
Where a competition organizer runs a competition on our software and you enter or compete, the organizer is responsible. We hold that information on the organizer's documented instructions and act on those instructions, and on the permission described under How we use competition information and media to improve our software. The organizer's own privacy policy governs it, and the organizer decides the outcome of a request about it.
Procurement and security reviewers use other words for this. The General Data Protection Regulation, where it applies to something we do, calls the first role a controller and the second a processor.
Sometimes our own staff photograph or film at an event, under a contract with the competition organizer. Ask us about those photographs and video in the same way as any other question about a competition. We answer where the answer is ours to give, and otherwise we send your question to the organizer on the day we receive it and tell you who they are.
Many families deal only with their dance or cheer studio. If the studio entered your child, the information reached the competition organizer through the studio. Once it is in our software the organizer is responsible for it, in the way described above. Anything the studio keeps for itself is the studio's, and the studio is the one to ask about it.
We are a British Columbia company, and British Columbia's Personal Information Protection Act is the law we work under. Canada's federal privacy law, PIPEDA, applies as well where personal information crosses a provincial or national border in the course of business. Where the privacy law of the United Kingdom or the European Union reaches a particular thing we do, we follow it for that activity. We look at that activity by activity rather than assuming an answer.
Each table says who collects the information. That matters, because it decides which of the two roles above applies to it.
| What we collect | Who collects it | Where it comes from |
|---|---|---|
| Name, email address, telephone number, and postal or billing address | We do | From you, when you open the account or buy something |
| Account login details | We do | From you |
| Purchase and order history | We do | From what you buy from us |
| Payment details | Our payment providers take card payments for us. Each of them is named at Service Providers and Subprocessors | From you, through the payment provider |
| Correspondence with our support team | We do | From you, when you write to us |
| What we collect | Who collects it | Where it comes from |
|---|---|---|
| Name, date of birth or age division, gender where the competition uses gendered divisions, and studio or team affiliation | The competition organizer, through our software | From the organizer, or from a studio entering on a family's behalf |
| Entry and routine details, scores, placements and judges' critiques | The competition organizer, through our software | Created during the competition |
| Photographs and video of performances | The competition organizer, through our software. Where our own staff take them under a contract with the organizer, see the note under Two different roles | From the organizer, from a studio, or from our own staff at an event |
If you buy photographs and video, an event pass or extended hosting, that purchase is ours and it belongs in the account table above. It stays on our side of the split.
When you visit one of our websites, the software that serves the page makes a record automatically, whether or not you have an account. The record holds your IP address, which is the number that identifies the internet connection your device is using, together with your browser and operating system and an approximate location worked out from the IP address. It also holds the pages you visited, the links you followed and the time of your visit. We make that record ourselves, so it is ours and we are responsible for it.
You can read our websites without telling us who you are. That is not the same as being anonymous. What our websites load from other companies is set out at Cookies and Analytics.
Our rule is to collect no more than the purpose needs.
We do not ask for sensitive information such as health details, racial or ethnic origin or religious belief. It is best kept out of a support message or a competition form.
We decide what we need personal information for before we collect it, or at the time, and we use it for that and nothing else. The table says what we use it for and what allows us to.
| What we use it for | What allows us to |
|---|---|
| Opening and running your account, and fulfilling your orders | You ask us to, when you open the account or buy from us |
| Taking payment and issuing receipts | You ask us to, when you buy from us |
| Answering you when you write to our support team | You ask us to, when you write |
| Keeping the software secure and preventing fraud and abuse | Keeping the software safe is part of providing it |
| Sending you our newsletter | Your consent. You ask for it, and you can withdraw at any time |
| Keeping financial and tax records | Canadian tax and business law requires it |
| Running a competition for an organizer | The organizer's documented instructions, and the purpose is the organizer's, not ours |
| Improving our software, including its automated tools | The organizer's agreement in its contract with us, and this notice. You may ask us to exclude your information. |
Where we rely on your consent, which is the case for the newsletter, you can withdraw it at any time. Withdrawing does not affect your account.
We may use the information and media handled through our software to improve the software itself, where the competition organizer has agreed to it, and only on the written authority of our Chief Executive Officer and our Privacy Officer together. This section says what that covers, what we use it for, and what we will not do. This section says what that covers, what we use it for, and what we will not do.
What it covers. Competitor records and entry details. Scores, placements and judges' critiques, including recorded audio and video of a critique. Photographs and video of performances. Information about how the software is used, such as which features are used and where faults occur. Support correspondence about the software.
What we use it for. Three purposes, and no others. Developing and testing our software. Training, testing and checking the automated tools inside it, such as the tools that select photographs from a performance, prepare judges' critiques and improve image and video quality. Finding and fixing faults.
Permission first. No use of this kind starts until our Chief Executive Officer and our Privacy Officer have given written permission for it. We keep a record of what was permitted, for what purpose, and when.
What we will not do. We do not sell this material, use it for advertising, or give it to any company other than those listed on our Service Providers and Subprocessors page. We do not use photographs or video to identify who a person is by their face or body. Access is limited to the people doing the work. Where the work can be done without knowing who a person is, we remove names and other identifying details first.
If you would rather we did not. Tell us at dpo@inchol.com, naming the competition and the competitor, and we will exclude that information and media from all future use of this kind, including any further training. You can also ask the competition organizer to instruct us.
Our software is used for competitions whose competitors include children. This section is for their parents and guardians.
What is collected about a competitor is the list under What we collect, who collects it and where it comes from. It includes scores, placements and judges' critiques as well as a name and an age division. There is no separate list for children.
The competition organizer collects that information through our software, and we hold it on the organizer's documented instructions. It decides what it asks for, and it is responsible for any permission the law requires before a child's information is collected.
An account with us must be held by an adult. A child does not need an account to compete.
Who can see the photographs and video of a performance is the organizer's decision. A question about that, or a request to take them down, goes to the organizer. Send it to us if you prefer, and we send it to the organizer on the day we receive it.
Your child's competition records and photographs and video are within what we may use to improve our software, and you can ask us not to. What that covers and what we will not do is under How we use competition information and media to improve our software.
What a parent or guardian can ask us, and what we will do.
Ask us anything about your child's record. Email dpo@inchol.com.
If we are responsible for the information, which is the first of the two roles above, we answer you.
When the competition organizer is responsible, we cannot answer a request about that information, or change or delete it, without the organizer's instruction. We send your request to the organizer on the day we receive it, we tell you who they are, and we act on their instruction. The organizer decides the outcome.
How to make a request, how we confirm who you are, and what happens next are on Your Privacy Rights.
We do not sell personal information. What our websites load from other companies, and what that sends to them, is on Cookies and Analytics.
Outside companies handle personal information for us so that we can run the software, deliver photographs and video, take payments and support you. Service Providers and Subprocessors lists each one, what it does, what information is involved and where it is held. Before we disclose personal information to a service provider we require a written agreement to be in place, and we remain accountable for the information while it is with the provider.
Information moves in two directions here, and it helps to keep them apart.
The organizer's own privacy policy governs the information it is responsible for, and it is worth reading. If you do not know who the organizer is or how to reach them, ask us and we will tell you.
Photographs and video reach the people the organizer allows to see them. That is a different thing from giving information to a company that works for us, and the Children section says whom to ask.
Where the law requires us to disclose personal information, or where it is necessary to protect someone's safety, we may do so.
If our business or its assets are sold or merged, personal information may transfer with it. This policy continues to apply to it until you are told of a change.
The personal information we hold is kept on systems run for us by outside companies, in more than one country. The servers that host our competition platform are in the United States. Service Providers and Subprocessors names each company, what it handles and where it is.
Information held in another country may be reachable by that country's authorities under that country's laws. We remain accountable for it wherever it is held.
We keep personal information for as long as the purpose it was collected for needs it, and for any further period a law, a contract or a dispute requires. Then we delete it. Photographs and video of a performance are generally hosted for three months from the day they are uploaded. A competition organizer may set a different period. Before that period ends a parent or guardian holding an account may buy extended hosting, and otherwise the media is deleted. Competition information is kept for as long as the organizer’s purpose reasonably requires.
If you want to know the period for your competition, ask the organizer, or ask us and we will tell you who they are.
Where we use personal information to make a decision about you, we keep it for at least one year afterwards, so that you have time to ask us for it.
Information a competition organizer is responsible for is not ours to delete. That request goes to the organizer in the way described under Two different roles, and the organizer decides. Where we are responsible, this is what happens.
When we act on a request to delete, we remove the details that identify you from our live systems: your name, contact details and anything else that points to you. Competition results and counts stay, without anything that identifies you in them, because organizers rely on them. A copy of your information may remain in a backup until that backup expires, and we do not use it for anything while it is there. If we ever restore from a backup we apply your deletion again.
We send a newsletter about new features and promotions. You receive it only if you have asked for it.
Every newsletter carries an unsubscribe link, and you can also ask us to stop by emailing dpo@inchol.com. How long each route takes is on Your Privacy Rights. Stopping the newsletter does not affect your account.
A service message is not marketing. Service messages are order confirmations, receipts, security notices and information about a competition you have entered or bought from. You receive them while you hold an account. Anything that promotes a competition you have not entered is marketing, and you can stop it in the same way as the newsletter.
Cookies, analytics tags and advertising pixels have their own page, Cookies and Analytics. It records what each of our websites loaded when we checked, what each thing does, and what you can do about it.
The safeguards we commit to, what we do when something goes wrong, and how to tell us about a problem you have found are all on How We Protect Your Information. We require access to personal information to be limited to the people whose work requires it.
After a breach. If we are responsible for the information, we report it and tell the people affected where the law requires that. If it does not, we still decide whether to, and we record the reason either way. That page sets out those duties. Where the information is held on a competition organizer's documented instructions, we tell the organizer. The decision whether to contact the people affected is then the organizer's and not ours, unless the organizer instructs us in writing to contact you or the law places that duty on us directly.
Telling us about a problem. If you think personal information has been exposed, or you have found a security flaw in our software, please tell us. How to do that, and what to include, is on How We Protect Your Information.
You have rights over your personal information. They include asking us what we hold about you, asking us to correct it, and in some cases asking us to delete it.
How to make a request, how long we take, what happens if we refuse, how to complain and whom to complain to are on Your Privacy Rights. Send your request to us whichever of the two roles applies, and that page explains what we do with it in each case.
We update this policy when our services or our obligations change. The version and the date it was prepared are at the top of this page.
Where a change materially affects how we use your personal information, we tell you before it takes effect. We do that by email where we hold your address, and by a note at the top of this page for everyone else.
Product Guarantee
We stand proudly behind our products and commitment to our clients. If you have any suggestions or concerns and wish to speak with us please let us know right away. We are always happy to assist.
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CheerComp Genie
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