STIRLING
ALBION FC PRIVACY NOTICE
1
INTRODUCTION
Stirling Albion FC respects your
privacy and is committed to protecting your personal data. This privacy notice
will inform you about how Stirling Albion uses and protects your personal data.
In this Notice, “Data Protection Legislation” means all
applicable legislation which relates to the protection of individuals with
regards processing personal data, including the General Data Protection
Regulation (EU) 2016/679.
It is important that you read this privacy notice
together with any other privacy notice or fair processing notice we may provide
on specific occasions when we are collecting or processing personal data about
you so that you are fully aware of how and why we are using your data.
We are
what is known as a "data controller" of your personal data. When we say "we" or "us", we mean STIRLING ALBION FOOTBALL AND ATHLETIC CLUB LTD which has its
registered office at Forthbank Stadium, Stirling, FK7 7UJ with Company Number
SCO24021 and is the controller responsible for your personal data.
3.1
What is personal
data?
Personal data, or personal
information, means any information about an individual from which that person
can be identified. It does not include data from which an individual can no
longer be identified (anonymous data).
We may collect, use, store and
transfer different kinds of personal data about you which we have grouped
together as follows:
•
Identity Data: includes first
name, maiden name, last name, username or similar
identifier, title, date of birth and
gender;
•
Contact Data: includes billing
address, delivery address, email address and telephone numbers;
•
Financial
Data: includes bank account and payment card details;
•
Transaction Data: includes
details about payments to and from you and other details of products, tickets
and services you have purchased from us;
•
Profile Data: purchases or orders
made by you, your interests, preferences, feedback and survey responses;
•
Competition Entry Data: includes
your name, address and email address and any other information you provide when
entering a competition;
•
Equal Opportunity Data: includes
information on your gender, sexual orientation, ethnicity, age, religion and
details of any disability that you may have;
•
Marketing and Communications Data: includes
your preferences in receiving marketing from us and our third parties and your
communication preference;
Live: 40925410 v 4
We will collect your personal data in a number of ways,
including when you provide your details directly to us in connection with one
of the purposes set out in this Notice;
·
purchase of Shares
·
purchase of a season ticket
·
enrolment in one of our community classes or holiday camps;
·
register to receive or download information,
newsletters or other documentation;
·
book or enquire regarding hospitality packages;
·
sign up to attend any of our events;
·
enter a competition, promotion or survey; or
·
provide us with feedback
·
purchase an item in the online club shop
5.1
What processing
grounds do we rely on?
We will only use your personal
data when the law allows us to. Most commonly, we will use your personal data
in the following circumstances:
·
Where you have provided us with your consent to send
you marketing communications;
·
Where we need to perform the contract we are about to enter into or have entered into with you;
·
Where it is necessary for our
legitimate interests (or those of a third party) and your interests and
fundamental rights do not override those interests; and
·
Where we need to comply with a legal or regulatory obligation.
Please note that we may process your personal
information without your knowledge or consent, where this is required or
permitted by law. Generally we do not rely on consent as a legal basis for
processing your personal data other than in relation to sending direct
marketing communications to you via email. You have the right to withdraw
consent to marketing at any time by contacting us.
We may process your personal data for more than one
lawful ground depending on the specific purpose for which we are using your
data. Please contact us if you need details about the specific legal ground we
are relying on to process your personal data.
We will primarily use your information for the following purposes:
·
Season
Tickets: where you have purchased a season ticket, we may send you information about specific
matches, hospitality days/other offers or reminders for renewal of your season
ticket.
·
Community
Classes/Holiday Camps: where you have booked a
place/places at any of our community classes or on our holiday camps, we may send you information relevant to the sessions that you have booked. We may also
send information about future classes or camps.
·
Hospitality:
where you are or have been booked in for a hospitality event, we may send you information relevant to the
day you have booked or about future events/days.
·
Marketing
Communications: Where we have
your consent to do so, we may send
you marketing emails and promotions which we think you will be interested in.
·
Shareholders
: Where we are
required to provide you with information regarding the Company.
·
Club
Online Shop: where you have purchased an item in the shop, you
may receive communications regarding new shop items that become available,
sales, items on your wish list etc.
Where
necessary, we may also use your information for the following additional
purposes:
·
as is required to ensure the safety
of all those attending football matches and for the purposes of preventing crime;
·
to monitor operational and safety related incidents;
·
to apprehend and prosecute
offenders, and provide evidence to take civil action in the courts; and
·
to prevent fraud.
We will only use your personal
information for the purposes for which we collected it, unless we reasonably
consider that we need to use it for another reason and that reason is
compatible with the original purpose. If we need to use your personal information
for an unrelated purpose, we will explain the legal basis which allows us to do
so.
6.1
Marketing by us
We may use your personal
data to send you marketing communications, providing you with details of upcoming matches, community
classes/holiday camps, hospitality days, events, competitions, sponsorship
opportunities and informing you of opportunities to purchase match tickets and
merchandise.
You will receive marketing communications from us if you
have given us your express consent to receive marketing communications, or if
you has previously expressed an interest in the product/service/event about
which we are messaging you.
We use the Mailchimp service to send you periodic newsletters and
this means that some of your personal data is transferred to servers in the
USA.
The Mailchimp service is covered by both the EU-US and Swiss-US
Privacy Shield regimes and is used by many EU and worldwide businesses. As
such, in our opinion, it poses a minimal threat to your privacy rights and
freedoms.
We have also completed a Data Processor Agreement addendum with
Mailchimp that specifically covers customers located in the EU.
You can read more about Mailchimp’s privacy measures at: https://blog.mailchimp.com/gdpr-tools-from-mailchimp/
You can ask us to stop sending you marketing messages at
any time by contacting us at any time. Where you opt out of receiving these
marketing messages, you may still receive messages from us for non-marketing
purpose, for example, service messages providing important announcements
regarding an event which you have purchased tickets for.
All of our mailchimp emails have an unsubscribe link at
the bottom which will automatically delete you from our database.
7.1
Disclosure to
selected third parties
The information you provide to us
will be treated as confidential. However, we may disclose your information to
other third parties who act for us for the purposes set out in this Notice or
for purposes approved by you, including to suppliers who provide marketing,
financial, and ticketing services. We require all third
parties to respect the security of your personal data and to treat it in
accordance with the law. We do not allow our third-party service providers to
use your personal data for their own purposes and only permit them to process
your personal data for specified purposes and in accordance with our
instructions.
7.2
Transferring
data outside of the EEA
We may need to transfer your
information outside of the European Economic Area (EEA) to service providers, agents, subcontractors and regulatory
authorities in countries where data protection laws may not provide the same
level of protection as those in the EEA, such as the USA. Whenever we transfer
your personal data out of the EEA, we shall ensure a similar degree of
protection is afforded to it by taking steps to ensure that appropriate
safeguards is implemented in accordance with the Data Protection Legislation.
We will only retain your personal
information for as long as necessary to fulfil the purposes we collected it
for, including for the purposes of satisfying any legal, accounting, or
reporting requirements.
To determine the appropriate
retention period for personal data, we consider
the amount, nature, and sensitivity of the personal data, the potential risk of
harm from unauthorised use or disclosure of your personal data, the purposes
for which we process your personal
data and whether we can achieve those
purposes through other means, and the applicable legal requirements.
In some circumstances we may
anonymise your personal information so that it can no longer be associated with
you, in which case we may use such information without further notice to you.
We may hold your personal information for longer
where it is necessary to do so for the management of any active or potential
legal proceedings, to resolve or defend claims, and for the purpose of making
any necessary remediation payments.
We have put in place appropriate
security measures to prevent your personal data from being accidentally lost,
used or accessed in an unauthorised way, altered or disclosed. In addition, we
limit access to your personal data to those employees, agents, contractors and
other third parties who have a business need to know. They will only process
your personal data on our instructions and they are subject to a duty of
confidentiality.
Under Data Protection Legislation, you have
the right at any time to:
·
Request access to
your personal information (commonly known as a “data subject access request”). This enables you to receive a copy
of the personal information we hold
about you and to check we are lawfully processing it;
·
Request correction of
the personal information that we hold
about you. This enables you to have any incomplete or inaccurate information we
hold about you corrected;
·
Request erasure of
your personal information. This enables you to ask us to delete or remove
personal information where there is no good reason for us continuing to process
it. You also have the right to ask us to delete or remove your personal
information where you have exercised your right to object to processing (see below);
·
Object to processing
of your personal information where we are
relying on a legitimate interest (or those of a third party). You also have the
right to object where we are
processing your personal information for direct marketing purposes;
·
Request the
restriction of processing of your personal information. This enables you to ask
us to suspend the processing of personal information about you, for example if
you want us to establish its accuracy or the reason for processing it;
·
Request the transfer of your personal
information to another party; and
·
Withdraw your consent to the
processing of your personal information at any
time.
You will not have to pay a fee to exercise any
of your rights.
If you would like to exercise any
of your rights above, please contact us by email to office@stirlingalbionfc.co.uk.
We try to respond to all legitimate requests
within one month. Occasionally it may take
us longer than a month if your request is particularly complex or you have made
a number of requests. In this case, we will
notify you and keep you updated.
We may amend this Notice from time
to time. If we make any substantial changes we will notify you by posting a
prominent notice on our website or by email. Historic versions can be obtained
by contacting us.
It is important that the personal
data we hold about you is accurate and current. Please keep us informed if your
personal data changes during your relationship with us.
13.1
Contact Details
If you have any questions about this privacy notice, including any
requests to exercise your legal rights, please contact us by emailing office@stirlingalbionfc.co.uk.
You can make a complaint to us by emailing office@stirlingalbionfc.co.uk, or to the data protection
supervisory authority, the Information Commissioner's Office, at https://ico.org.uk/.
Reviewed
February 2020