This privacy policy was last updated on June 1, 2022.

Thank you for visiting the Global DRO website and reviewing our privacy policy (“Privacy Policy”). We are committed to ensuring that your privacy is protected. This website globaldro.com and the associated Global DRO platform (both together, the “Platform”) is operated by a partnership between the Canadian Centre for Ethics in Sport, Swiss Sport Integrity, UK Anti-Doping, the United States Anti-Doping Agency, the Japan Anti-Doping Agency, Sport Integrity Australia, and Sport Integrity Commission NZ (all together, referred to as “Global DRO”).

Please read this Privacy Policy carefully. By continuing to use the Platform, you agree to have your personal information handled in the manner described in this Privacy Policy.

Our Privacy Policy includes:

• General Disclosures
• What Information We Collect And For What Purpose
• To Whom Do We Disclose Your Information And Why
• Links To Other Sites
• How Long We Retain Your Information
• Children’s Online Privacy Protection Act (COPPA)
• Your Rights With Respect To Personal Information
• Changes To This Privacy Policy
• Contact Us
• International Privacy Policy
• Collection Of Personal information
• How We Use Personal information
• The Basis On Which We Process Your Personal information
• Obtaining Consent
• Third-Parties
• Limitations
• Retention Of Personal information
• Access And Rights To Your Personal information
• Response Time
• Costs
• Identifying You In Connection With Requests
• Opt-Out And Unsubscribe
• Accuracy
• Safeguards
• Contact
• Cookies Policy
• How To Restrict Cookies
• What If I Restrict Cookies Or Do Not Consent To Cookie Collection?
• Cookie Table

General Disclosures

The Platform is hosted in the United States. If you are visiting the Platform from outside of the United States, please note that by providing us your information it is being stored or processed in the United States where our data center and servers are located and operated. This section sets forth the general Privacy Policy for the United States and other jurisdictions not otherwise specifically covered by the other jurisdiction-specific policies. 

Depending on your state or country of residence, applicable privacy laws may provide you with a right to additional disclosures as well as special consumer rights. If you are outside of the United States, please also see the provisions in our International Privacy Policy. If you are outside the United States and do not wish to allow the transfer of your personal information to the United States, you should not use this Platform and you should opt-out of the collection of cookies by following the guidelines in our section titled How To Restrict Cookies. For more information about how we utilize cookies, view our Cookie Policy.

What Information We Collect And For What Purpose

We also may collect and retain search parameter data, such as the sport nationality, role, sport, country of purchase, or other search terms. We also may collect and retain the results of the searches as well as metrics relating to these searches, such as the date and time of the search. However, this search data is not associated with your personal information. 

Within the past twelve months, we may have collected your e-mail address for the purpose of responding to your questions or concerns. However, as of the effective date of this Privacy Policy, Global DRO no longer collects e-mail address. 

To Whom Do We Disclose Your Information And Why

The personal information that we collect from you through this Platform is only used for our own internal purposes as described in this Privacy Policy and will not be publicly disclosed. We do not sell your personal information. However, we utilize a number of service providers to help maintain the Platform and provide the associated search functionality. Below is a list of those entities to whom we may disclose your personal information.

• Database Hosting Vendor.  Like many organizations, we utilize cloud databases to host our data, including your personal information, so that we can effectively and safely operate the Platform.
• Auditors.  We may be subject to audits from a number of entities, such as our regulators or service providers, as well as due to our own internal auditing policies. In order to accomplish an effective audit, we must provide information, which may include your personal information, to external auditors. We always ensure that your information is safely disclosed and stored and that auditors can only use your information for the purposes of completing an audit.
• Analytics Providers.  We may utilize analytics service providers to measure the performance of the Platform and to help us optimize the Platform’s functionality.
• Corporate Transactions.  We may share all or part of your personal information with other entities in connection with the sale, assignment, merger or other transfer of all or a portion of our organization or assets to such entities (including due to a sale in connection with a bankruptcy). We will require any such purchaser, assignee or other successor organization to honor the terms of this Privacy Policy.
• Legal Purposes.  We may disclose all or part of your personal information when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating any agreement with us, or may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other users of the Platform, or anyone else that could be harmed by such activities. We may disclose information in response to a subpoena, search warrant, in connection with judicial proceedings, or pursuant to court orders, (disciplinary) legal process or other law enforcement measures. We may disclose or access personal information when we believe in good faith that the law requires it, to establish our legal rights or to defend against legal claims, and for administrative and other purposes that we deem necessary to maintain, service and improve our Platform.
• Global DRO Member Organizations. We may disclose information that we collect through this Platform to the other Global DRO member organizations and licensees.

If you choose to provide one of the Global DRO member organizations with personal information by connecting with the organization directly via email, that personal information will be handled in accordance with each national anti-doping agency’s respective data privacy practices, not Global DRO’s data privacy practices. We encourage you to carefully review the privacy policy of each entity to which you provide information. 

Links To Other Sites

This Platform has links to other websites. Once you link to another site, you are subject to the privacy policy of the new site and its operator. We encourage you to carefully review the privacy policy of each entity to which you provide information.

How Long We Retain Your Information

We may retain your personal information for as long as is necessary to achieve the purposes as stated in the section of this Policy titled What Information We Collect And For What Purpose, but in all cases, for a period of time that is consistent with applicable law, applicable statute of limitations and our data retention practices. You can find how long cookies are retained in the cookie table at the end of this Privacy Policy. 

Children’s Online Privacy Protection Act (COPPA)

The Children’s Online Privacy and Protection Act (COPPA) regulates online collection of information from persons under the age of 13. It is our policy to refrain from knowingly collecting or maintaining personal information relating to any person under the age of 13. If you are under the age of 13, please do not supply any personal information through the Platform. If you are under the age of 13 and have already provided personal information through the Platform, please have your parent or guardian contact us immediately using the information provided under Contact Us so that we can remove such information from our files.

Your Rights With Respect To Personal Information

With regards to the personal information that is collected through the Platform, you have the right to be informed about the who, what, why and how relating to the processing of your personal information. Please refer to the table of contents at the beginning of this Privacy Policy to quickly find the specific disclosures relating to your right to be informed. Further, you may have the ability to request: (i) confirmation regarding whether or not Global DRO currently has or processes personal information about you; (ii) a copy of the personal information that Global DRO has or processes about you in a readily intelligible format; and (iii) to have your personal information rectified, amended, blocked or deleted if our processing of your personal information is inaccurate, incomplete, or excessive. You can request to exercise these rights by following the instructions provided under Contact Us. Please be as specific as possible in your request. 

However, we may not be able to comply with your request for a number of reasons:

• the information that you request is not subject to the Global DRO obligation that grants you the right to make a request in relation to your personal information;
• we are not able to comply with your request without incurring disproportionate burden or expense; or
• if complying with your request conflicts with the integrity of the anti-doping system or an Anti-Doping Organization's ability to plan or conduct No Advance Notice Testing or to investigate and establish anti-doping rule violations or other legal claims.

If any of the above reasons apply, we will let you know in our response to your request. You have the right to initiate a complaint with your country’s national anti-doping agency as stated in the section titled Contact Us. If your compliant is not resolved, you may notify the World Anti-Doping Agency of your complaint through . 

Note that we may be required to gather additional information from you in order to process your request. We will only use this information in the context of evaluating and responding to your request.

Changes To This Privacy Policy

We may amend this Privacy Policy at any time by posting revisions on our Platform. If we make any material changes in the way we process your information, we will notify you by prominently posting notice of the changes on our Platform.

Contact Us

You can contact us at privacy@globaldro.com.

If you have questions, complaints or wish to exercise your data rights as related to the Platform, please contact the privacy officer associated with your country’s national anti-doping agency:

• Canadian Centre for Ethics in Sport:
  https://cces.ca/canadian-anti-doping-program-privacy-and-personal-information-policy
• Swiss Sport Integrity:
  https://www.sportintegrity.ch/en/privacy-policy
• UK Anti-Doping:
  https://www.ukad.org.uk/privacy-notice
• United States Anti-Doping Agency:
  https://www.usada.org/privacy-statement/
• Sport Integrity Commission NZ:
  https://sportintegrity.nz/privacy-policy
• Japan Anti-Doping Agency:
  https://www.playtruejapan.org/faq/
• Sport Integrity Australia:
  https://www.sportintegrity.gov.au/privacy

This Privacy Policy only applies to how Global DRO deals with personal information. It does not apply to any other organization or to any other organization’s websites even if you access them through Global DRO. If you disclose your personal information to other organizations, your information will be dealt with according to their privacy policy.

International Privacy Policy

Both the above general Privacy Policy and this International Privacy Policy (the “International Policy”) apply to those visiting the Global DRO Platform from outside of the United States. Where the provisions of the general Privacy Policy and the International Policy cannot be construed consistently, the International Policy will govern. The Platform hosted in the United States. If you are visiting the Platform from outside of the United States, please note that by providing us your information it is being stored or processed in the United States where our data center and servers are located and operated.

Please note that, depending on your country of residence, you may have data rights as provided by the Canadian Personal Information Protection and Electronic Documents Act, the European Union General Data Protection Regulation, the UK Data Protection Act 2018, the Swiss Federal Act on Data Protection and Ordinance on the Federal Act on Data Protection, the New Zealand Privacy Act 2020, the Japanese Amended Act on Protection of Personal Information or the Australian Privacy Act 1988.THIS INTERNATIONAL POLICY APPLIES TO ALL PERSONAL INFORMATION ABOUT YOU THAT WE COLLECT, HOLD, USE AND DISCLOSE, REGARDLESS OF THE WAY IN WHICH WE COLLECT IT (I.E. WHETHER THROUGH THE PLATFORM, GLOBALDRO.COM OR OTHERWISE).

Collection Of Personal Information

Global DRO collects personal information through the provision of the Platform. You can find specific details about the personal information that Global DRO collects from you in the section titled What Information We Collect. 

Where we are the Data Controller with regard to your personal information, you may exercise your rights as data subject, including the right to object to the processing of your personal information when it is processed based on legitimate interests as described in this International Policy. Please note that your information will be transferred to and stored in the United States, whose privacy laws may not be as strong or comprehensive as the privacy laws in your own country. 

How We Use Personal Information

As a general matter, we collect your personal information primarily to administer and provision the Platform. You can find specific details about the purposes for which Global DRO collects personal information from you in the section titled What Information We Collect.

The Basis On Which We Process Your Personal information

We will only collect and process your personal information as is reasonably necessary for, or directly related to, one or more of Global DRO’s functions or activities. 

Where required by law, we rely on the following legal grounds to process your personal information, namely:

• Performance of a contract:  We may need to collect and use your personal information to enter into a contract or to perform a contract that you have with us.
• Consent:  Where required by law, we will obtain your explicit consent for collecting and processing of your personal information.
• Legitimate interests:  We may use your personal information for our legitimate interests of detecting and preventing fraud as well as maintaining the security of Global DRO’s network and information systems.

Obtaining Consent

Except when otherwise permitted by law, we obtain the requisite consent prior to collecting and, in any case, prior to using or disclosing your personal information for any purpose other than as disclosed herein. You may provide your consent to us orally, in writing, by electronic communication or any other means reasonably capable of conveying your consent. We will obtain your express consent if we collect, use or disclose sensitive personal information in our capacity as a data controller. We may also share data with third-party partners for whom you have given us consent. Your consent may also be intrinsic to the circumstances such as in the case where you have already provided personal information to us and you maintain your relationship with us or where you provide our representatives with your phone number or e-mail so that we can contact you. Except when otherwise permitted by law, we will only use the data for the purpose for which it was given.

When your consent is required, you may withdraw your consent at any time (unless withdrawing the consent would frustrate the performance of our legal obligations) upon providing to us a 30-day notice. However, the withdrawal of your consent may adversely affect our ability to provide the Platform to you and to maintain our relationship with you. Please refer to our Cookie Policy for information relating to your choice to reject or delete cookies.

Third Parties

We remain responsible for all personal information communicated to other entities for processing. As such, we ensure that other entities that are engaged to provide products or services on our behalf and are provided with personal information are required to observe the intent of this International Policy by having comparable levels of security protection or, when required, by assuring us (through a confidentiality agreement) that they will not use or disclosure the personal information for any purpose other than the purpose for which the personal information was communicated. You can find specific details about to whom Global DRO discloses your personal information in the section titled To Whom Do We Disclose Your Information And Why.

Limitations

We only collect the personal information necessary to fulfill the purposes identified to you prior to or at the time of collection, or any other reasonable and legitimate purposes or as required by law.

We do not use or disclose your personal information, except for the purposes for which it was collected, or new purposes to which you have consented, or as required or otherwise permitted by applicable law.

We do not, as a condition of providing the Platform to you or on your behalf, or as an administrative or management requirement, require consent to the collection, use or disclosure of personal information beyond what is reasonably required for such purposes, or to comply with our obligations under applicable law.

Retention Of Personal information

We may keep a record of your personal information, including correspondence or comments, in a file specific to you. We will utilize, disclose, or retain your personal information only for as long as necessary to fulfill the purposes for which it was collected and for legal or business requirements. We will establish minimum and maximum retention periods and procedures for maintaining and destroying your personal information. When personal information is retained to make a decision about you, we will retain such information for the period required in order to comply with our internal data retention policies. You can find more information about how long Global DRO stores your personal information in the section titled How Long We Retain Your Information.

Access And Rights To Your Personal information

In addition to those rights articulated in the section titled Your Rights With Respect To Personal Information, you may have additional data rights depending on your country of residence. Subject to the exceptions provided by applicable law, you may have following rights regarding your personal information: the right to access data maintained about you; the right to ensure that your data is accurate and complete; the right to correct incomplete, inaccurate or out-of-date personal information; the right to erasure, deletion or the right to be forgotten; the right to restriction or suppression of personal information; the right to data portability; the right to withdraw consent if consent was previously provided; the right to raise a complaint with Global DRO or the appropriate data protection authority; the right to opt-out of transfers of your personal information to a third party; and the right to opt-out of any direct marketing communications received from Global DRO, to the extent that you receive any.

You can request to exercise these rights by following the instructions provided under Contact Us. Please be as specific as possible in your request. 

Response Time

We will make every reasonable effort to respond to each of your written requests not later than 30 days after receipt of such requests. When applicable, we will advise you in writing if we cannot meet your requests within this time limit. When applicable, you have the right to make a complaint to the appropriate supervisory authority with respect to this time limit.

Costs

We expect to be able to respond to your request without charge as a general matter.  However, we reserve the right to collect a reasonable charge when you request the transcription, reproduction or transmission of such information. We will notify you, following your request for transcription, reproduction or transmission of the appropriate amount that will be charged. You will then have the opportunity to withdraw your request.

Identifying You In Connection With Requests

We may require that you provide to us additional information to identify yourself before we provide information about the existence, use or disclosure of your personal information in our possession. Any such information that you provide to us shall be used only for this purpose.

Opt-Out And Unsubscribe

We respect your privacy and give you an opportunity to opt-out of receiving certain information from us, to the extent that you receive any. You may opt-out of using the instructions located in e-mails sent by Global DRO or by contacting us using the information under Contact Us. 

Accuracy

We will use reasonable efforts to ensure that your personal information is kept as accurate, complete and up to date as possible. We do not routinely update your personal information in our possession, unless such a process is necessary. In order to help us maintain and ensure that your personal information is accurate and up to date, you must inform us, without delay, of any change in the data that you have provided to us.

You can at any time, challenge the accuracy or completeness of the personal information we have about you, subject to the exceptions provided by applicable law. If you demonstrate that the personal information we have on you is inaccurate or incomplete, we will amend the personal information as required. Where appropriate, we will transmit the amended data to third parties to whom we have communicated your personal information.

Safeguards

We use security safeguards appropriate to the sensitivity of personal information to protect it from loss or theft, as well as unauthorized access, disclosure, copying, use or modification. These safeguards include physical measures, such as restricted access to offices and equipment, organizational measures, such as security clearances and publishing this policy to appropriate personnel with instructions to act in accordance with its principles (for example, limiting access on a “need to know” basis), and technological measures, such as the use of passwords and/or encryption. Personal information is generally located with our database provider. 

Contact

Please direct all complaints, data requests or other inquiries regarding personal information, the Privacy Policy, the International Privacy Policy or the Cookie Policy to the appropriate contact provided in the section titled Contact Us.

Cookies Policy

Like many online platforms, Global DRO and its analytics vendors use server logs and automated data collection tools, such as browser cookies, pixel tags, scripts and web beacons. A summary of the cookies used by the Platform can be found in the cookie table at the end of this Cookie Policy. These tools are used for analytics purposes to enable us to understand how users interact with our Platform. Global DRO and our analytics vendors may tie the information gathered by these means to the identity of users.

Cookies are small text files placed on a computer or device while browsing the Internet. Cookies are used to collect, store and share bits of information about user activities. Global DRO uses both session cookies and persistent cookies.

Session cookies are used to identify a particular visit to Global DRO’s Platform. These cookies expire after a short time or when the user closes their web browser after using the Platform. Global DRO uses these cookies to allow a user who has accepted the Platform’s terms and conditions to conduct searches until the user ends the session (closes their web browser window), and to prevent cross-site request forgery attacks.

A persistent cookie will remain on a user’s device for a set period of time specified in the cookie. We use these cookies to identify and recognize a specific user over a longer period of time. They allow us to:

• register the preferred language of a user,
• generate statistics on how a user utilizes the Platform, and
• throttle a user’s request rate, if necessary.

Cookies and information captured through our Platform are stored for a certain retention period as described in the cookie table, however you can delete these cookies any time before the expiration date. 

Do Not Track (“DNT”) is an optional browser setting that allows you to express your preferences regarding tracking across websites. Most modern web browsers give you the option to send a Do Not Track signal to the websites you visit, indicating that you do not wish to be tracked. However, there is no accepted standard for how a website should respond to this signal, so we do not take any action in response to this signal. Global DRO does not have a mechanism in place to respond to DNT signals. Instead, in addition to publicly available external tools, we offer you the choices described in this Cookie Policy to manage the collection and use of information about you.

How To Restrict Cookies

You can adjust the settings in your browser in order to restrict or block cookies that are set by the Platform (or any other website on the Internet). Your browser may include information on how to adjust your settings. Alternatively, you may visit U.S. Federal Trade Commission’s website www.consumer.ftc.gov to obtain comprehensive general information about cookies and how to adjust the cookie settings on various browsers. 

You can control and delete these cookies through your browser settings through the following:

• Google Chrome
• Mozilla Firefox
• Safari
• Opera
• Microsoft Internet Explorer
• Microsoft Edge
• Safari for iOS (iPhone and iPad)
• Chrome for Android

Or you can also use the following cookie management and disposal tool from Google Analytics by downloading and installing the browser plug-in from the following link: https://tools.google.com/dlpage/gaoptout.

Most browsers allow you to refuse to accept cookies. Further, you may be presented with a banner when you first visit the Platform asking whether or not you accept cookies. If you do not consent, or if you click “reject” or “no”, then cookies will be not placed on your device or collected from you.

What if I Restrict Cookies or Do Not Consent to Cookie Collection?

Please be aware that restricting or rejecting cookies may impact the functionality of the Platform. If you reject cookies, the Platform will not remember your language preference from visit to visit

Additional general information about cookies, including how to be notified about the placement of new cookies and how to disable cookies, can be found at https://www.allaboutcookies.org.

Cookie Table