Legal
Privacy Policy
This policy is under review. It describes how the service actually works today, and we will post the reviewed version here when it is ready.
This Privacy Policy explains how Infacta handles personal data — both in Infacta Account, the central sign-in and club-management service, and in the products it signs you in to: ClubCards, FloorTime and CampGenie. Infacta is a registered business name of Groupmail Ltd. (registered in Ireland, company no. 284930, registered office Unit 15, SocoLab, Strandhill, Co. Sligo, F91 E426, Ireland) (“Infacta”, “we”, “us”). Everything here is hosted in the European Union (Frankfurt, Germany). It covers everyone who holds an Infacta account, anyone who requests an invitation for their club at id.infacta.com, and everyone whose data a club enters in a product.
Almost everything below applies to every Infacta product. Where one product differs, the difference is set out in a marked block naming that product, and for that product the marked block applies instead of the general rule. The differences are real — one product holds nothing about children, and another exists to hold their medical details — so the blocks are worth reading.
Controller and processor roles
The same pattern holds in every product. For your own Infacta account — your name, email address and sign-in credentials — and for invitation requests submitted at id.infacta.com, we are the data controller. That covers the people who run a club’s account: its owners, its admins, and the staff and volunteers they invite.
For the data a Club enters or collects about other people, the Club is the controller and we act as its processor, handling that data only to provide the service on the Club’s instructions. It is the Club that decides what it collects, who in the Club can see it, and when it goes. Who those other people are differs by product:
The Club’s members and credential holders, who may include children where the Club issues credentials to under-18s.
Venue contacts and keyholders — the people a Club deals with about hiring a space, and the caretakers or school staff who can physically open it. They are entered by the Club and are usually not club members. FloorTime holds no data about the children who attend.
The guardians who register for a camp and the children who attend it — including, for the duration of an event, the health and safety details a Club needs to run that event safely — and the people in the photos a camp’s staff take there.
Information we collect
Across the account service and every product we collect:
- Account data — your name, email address and password, and, if you choose to add them, your phone number and a profile photo. Your password is stored only as a secure hash; magic sign-in links and reset links are single-use tokens.
- Club and membership data — your club’s name, address (slug), crest and colours, and for each person: their club role, product access and the invitations sent to them.
- Invitation requests — if you ask for an invitation at id.infacta.com: your club’s name, your name, your email address and an optional message. The form is checked by Cloudflare Turnstile to keep automated sign-ups out (see Service providers). If we decline a request, we keep the reason we gave you with it.
- Membership requests — a club can ask us to add someone as a member of a product it uses: we hold that person’s name and email address, entered by the club, and any note the requester writes about the request. If you don’t already have an Infacta account, this may be a record about you that you did not create yourself.
- Access and enable requests — if a club member asks to use an app their club has already enabled, we record who asked, which app, and which club. If a club admin asks us to enable an app for the club, we record which club, which app and which admin asked. Neither kind of request has a field for writing anything else — there’s no message from the person asking.
- Audit records — administrative actions in a club’s account (for example who invited whom, or changed a role) are recorded with who did them and when.
- Usage and technical data — an essential session cookie to keep you signed in, plus log data such as IP address, browser type and timestamps.
On top of that, each product collects what it needs to do its job:
Member names, email addresses, phone numbers and photos; the credential itself — its classification, add-ons, validity and status; and verification events, which record that a credential was scanned and what status it showed.
A club’s venues and the spaces in them, its seasons, teams and closures, and the bookings its coaches make — who booked, for which team, where and when. It also holds the venue contacts and keyholders a club records: a name and mobile number, and optionally an email address and the address where a key can be collected. There are no player rosters: FloorTime books rooms, and does not track who is in a team.
From a family registering for a camp:
- Guardian contact details — name, email address and phone number, so the club can reach the adult responsible for each child.
- Each child’s name and date of birth — the date of birth because camps have age ranges and age-based groups, not because we want a birthday.
- Per-event health and safety details — medical conditions, allergies, medications, additional needs, dietary requirements, who may collect the child, and emergency contacts. These belong to one event’s registration, are asked again for the next one, and are never kept as a standing profile of a child.
- Consent records — the consent text the guardian accepted, the version of it, when they accepted, and any photo-consent choice.
- Payment status — what was ordered, what it cost, whether it is paid, refunded or cancelled, and the reference Stripe gives us. Card numbers are never sent to CampGenie and we never see or store them.
From the club: its camps and trips, and the records of who registered for them.
From a camp’s staff, if the club uses the camp album: photos taken at the camp. Before a photo is stored it is re-encoded without its hidden details, including where it was taken, and scaled down if it is large. With each photo we keep who added it, where the faces in it are and which of them an organiser has blurred, and a record of each time an organiser confirmed they had checked its faces or shared or downloaded it. Faces are found on the organiser’s own device: CampGenie works out where a face is, never whose it is, and no photo is sent to anyone else to be analysed.
How we use personal data
We use personal data to:
- create and secure accounts, and sign you in to Infacta products with one identity;
- operate club membership — invitations, roles and product access — and show clubs their own audit trail;
- provide each product a club uses, on that club’s instructions;
- send transactional email, such as invitations, magic sign-in links, password resets, email-change confirmations, credential emails and registration confirmations;
- take payment for a club where the product does that, and tell the club and the buyer what was paid;
- contact you about setting your club up, if you asked for an invitation;
- operate, maintain, secure and improve the platform; and
- prevent abuse and meet our legal obligations.
We do not sell personal data, we do not use it for advertising, and we do not profile anyone.
The health, allergy, medication, collection and emergency-contact details exist for one reason: so the club can run the camp safely and reach the right adult quickly if something happens. Names, dates of birth and consent records exist so the club knows who is attending, which group they belong in and what their guardian agreed to.
Camp photos are there so the club can share moments from the camp safely. In CampGenie they can be seen only by the club’s admins and camp organisers and by the coaches on that camp’s staff; families and the public never see the album. A photo can leave CampGenie only after an organiser confirms they have checked every face in it, and while they check, CampGenie shows them which children on the camp have no photo consent, so they can blur those children and anyone else who should not be shown. It leaves as a copy with those faces blurred, made on the organiser’s device, which the organiser shares or downloads themselves. CampGenie does not post photos anywhere; what the club does with a photo it has shared is for the club, as controller, to decide.
Sharing with Infacta products
The account service exists to be shared: when you sign in to an Infacta product, we pass it the account and membership data it needs — your name, your email address, your phone number and profile photo if you have added them, the club you are acting in, your roles there, and the club’s identity (name, crest and colours). Requests between the account service and the products are cryptographically signed.
Your profile photo is served at a web address that is hard to guess but can be viewed by anyone who has it, and replacing or removing the photo retires that address.
Within a product, a club’s data is seen by the club’s own people, as the club decides — an organiser sees the registrations for their camp, a coach sees the group they are running, a booking admin sees who booked what. Each club’s data is logically isolated, so one club can never see another’s.
Cookies
We use a single essential session cookie to keep you logged in. It is required for the service to function and is not used for advertising or cross-site tracking. Someone who is not signed in — a guardian registering a child, or a person scanning a credential — is not asked to sign in and is not tracked across sites.
The one exception is the invitation-request form at id.infacta.com, which loads Cloudflare Turnstile. Turnstile may set cookies of its own, which Cloudflare describes as strictly necessary for detecting and blocking bots. No other page loads it.
Service providers and sub-processors
We use a small number of providers to run the service — hosting and database, file storage, transactional email and, where a product takes payments, payment processing. They process data on our instructions under their own data-protection terms.
Each one is named on our Sub-processors page, with what it does, where it processes data and which products use it. We give at least 30 days’ notice before that list changes.
One of them handles only data we control, never data a club enters: Cloudflare Turnstile (Cloudflare, Inc.) checks that the invitation-request form at id.infacta.com is being filled in by a person rather than a bot. When you open that form, Cloudflare receives your IP address and technical details of your browser and connection (its user agent and TLS fingerprint), and tells us whether the check passed. We don’t send it anything you type into the form. Cloudflare also uses these signals, as a controller in its own right, to improve its bot detection; its Turnstile privacy addendum explains how.
Data retention
We keep account data for as long as your account is active. After an account is closed we delete or anonymise account data within 30 days, except for routine backups and anything we must keep to meet a legal obligation. Backups are taken daily, and operational logs are kept for a variable period — typically around 30 days.
Data a Club enters in a product is the Club’s record and is kept for as long as the Club’s account is active, then deleted or anonymised within 30 days of its closure — except where a product deletes something sooner, as CampGenie does below.
Invitation requests are kept for up to 12 months; if we haven’t been able to set your club up in that time, we delete them. Requests that are plainly spam are deleted as soon as we see them.
Membership requests are kept for 90 days after they’re decided (approved, declined or left unanswered), then deleted.
Access requests lapse if left unanswered for 14 days, and are kept for 90 days after they’re decided (approved, declined or lapsed), then deleted. Enable requests are a club record with no expiry, and are kept for as long as the club’s account is active.
If you close your account, your access requests are deleted along with the rest of your account data. An enable request you raised as a club admin is different: it’s a record of your club’s ask to us, not of you, so it survives your account closing — it just no longer links to anything that identifies you.
A club’s audit records are part of that club’s account and are kept for as long as the club’s account is active.
The medical, allergy, medication, additional-needs, collection and emergency-contact answers are deleted when the club archives the event. They are collected per event, used for that event, and purged when it is over — the registration keeps the fact that someone attended and what they paid, not their health details.
This happens when the club archives the event, not 30 days after an account closes, and it is not undone by anything in the general rules above. The rest of a registration — guardian contact details, a child’s name and date of birth, consent records and payment history — is the club’s record of who came and what was agreed, and is kept for as long as the club uses CampGenie, then deleted or anonymised within 30 days of the account closing, except for routine backups and anything we must keep to meet a legal or accounting obligation.
Camp photos, and the face boxes kept with them, are deleted at the same point: when the club archives the camp, which it can do once the camp is over. Before then an organiser can delete any photo, and a staff member can delete a photo they added. Before archiving, an organiser can download the checked photos, blurred, for the club to keep; those copies, and any photo already shared, are outside CampGenie. The record that a photo was checked, shared or downloaded stays with the club’s audit records.
Security
We take reasonable measures to protect personal data: passwords are stored only as secure hashes and are held by the account service alone, so no product stores your password; sign-in and reset links are single-use; family and credential links are single-purpose and unguessable; card details never reach our servers; data is transmitted over encrypted connections; requests between the account service and Infacta products are cryptographically signed; and each club’s data is logically isolated so one club cannot access another’s.
Personal data breaches
If a personal data breach affects data a Club has entrusted to us, we will notify the Club without undue delay and give them the information they need to meet their own obligations. For data we control, we will comply with our own notification duties under applicable law.
Where we process data and international transfers
Infacta Account and every Infacta product host their application, database and stored files in the European Union (Frankfurt, Germany), so personal data is processed in the EU by default.
Our transactional-email provider, and the payment provider used by the products that take payments, may process limited data outside the EEA/UK. So may Cloudflare, which runs a global network: the IP address and browser details it receives when you open the invitation-request form may be processed outside the EEA/UK. Where that happens, we rely on the European Commission’s 2021 Standard Contractual Clauses and, for UK data, the UK International Data Transfer Addendum. Our Sub-processors page says which provider is which.
Your rights
Depending on where you live, you may have rights to access, correct, delete, restrict or port your personal data, or to object to its processing. To exercise them, contact us below. If your data was entered by a club, the club is the controller and we may direct the request to it and support it in responding within the statutory time limit.
You also have the right to complain to your data protection authority. In Ireland that is the Data Protection Commission (dataprotection.ie).
A guardian may ask for access to the data held about them and their child, ask for it to be corrected or deleted, ask us to restrict or stop processing it, object to processing, or ask for a copy to take elsewhere. Much of it can be corrected directly through the family link on the confirmation email, which is the fastest route.
A child has these rights too; while they are young their guardian normally exercises them on their behalf, and an older child may exercise them for themselves.
Children
An Infacta account is for adults: you must be at least 18 to hold one, and the people who run and use a club’s account are adults. What a product holds about children is a different question, and the answer is not the same in each one.
FloorTime holds no data about the children who attend. It does not hold player rosters: it books rooms for teams, and a team is a name on a calendar, not a list of children.
A club may issue credentials to members who are children, and where it does, ClubCards holds that member’s details like any other — name, and whatever contact details and photo the club adds. It is the club, as controller, that must have a lawful basis and any consent it needs. In Ireland the digital age of consent is 16, so below that age a guardian’s consent is normally what a club relies on.
Children’s data is what CampGenie is for. A registration holds a child’s name and date of birth, and — for the duration of the event — the medical, allergy, medication, additional-needs, collection and emergency-contact answers their guardian gave. What is collected is set out under “Information we collect”, and when it goes under “Data retention”: the health answers are purged when the club archives the event. Registration is done by a guardian, not by the child.
If the club uses the camp album, CampGenie also holds photos of children taken at the camp. Only the club’s admins and camp organisers and that camp’s coaches can see them, they are deleted when the camp is archived, and a photo can leave CampGenie only once an organiser has checked every face in it, with any child whose guardian has not said Yes to photos blurred.
Changes to this policy
We may update this policy from time to time. We will post the new version on this page and update the “last updated” date above.
Contact
Questions or privacy requests? Email us at hello@infacta.com. Clubs acting as controllers can also read our Data Processing Agreement.