GILLINGHAM FOOTBALL CLUB LIMITED PRIVACY POLICY

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (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, marital status, title, date of birth, gender media handles and your image.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Medical includes details of medication and/or health issues and/or disability regarding mascot experience or any concession claimed and/or where appropriate health related information / temperature readings required in response to an epidemic / pandemic / health emergency.
• Safety/Security/Conviction includes details of any actual or suspected convictions, orders, arrests, breach of the law, breach of football authority rules and regulations, breach of any terms and conditions of entry to a match and/or any suspected involvement in incidents which may impact on the and/or safety and/or security on match days or other events the Club takes part in.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We may process information about criminal convictions, where this is necessary for public order and the prevention of crime, and there are adequate protections in place.

When you visit our stadium, offices or other premises we may use surveillance systems to capture CCTV images and sound including for the purposes of public order and the prevention of crime (see Section 5 (Use of Surveillance Systems).

We may monitor and record telephone calls for security and training purposes and to improve the quality of services provided by the Club.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Personal Data by filling in forms or by corresponding with us through the Collection Methods which include by post, phone, email or otherwise. This includes personal data you provide when you:
  • apply for our products or services;
  • create an account on our website;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey;
  • attend an event;
  • attend one of our properties and are recorded via one of our surveillance systems; or
  • give us feedback or contact us.

• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources including for example credit reference agencies, the Electoral Register, Companies House, the Government, public bodies, local authorities, the Police, data agencies. We may also use third parties to provide technical, payment and delivery services (e.g. our ticketing partner) as well as specialist data providers to assist with reviewing, segmenting and correcting the data we hold, to make sure it remains accurate and up to date and identify data that we no longer need to retain.

How we use your personal data

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 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 – we may send you marketing material for example.
• Where we need to comply with a legal obligation.
• Where we have your consent to do so.

You have the right to withdraw consent to marketing at any time by contacting us. If you unsubscribe – we will keep a record of that.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that 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 where more than one ground has been set out in the table below.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

From time to time we may contact you to tell you more about offers, services, products and other initiatives available to you through us.  We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

Opting out

You can ask us or third parties you have consented to have your personal data shared with through us to stop sending you marketing messages at any time by contacting us at any time.

On receiving your request to update your personal information, we will use commercially reasonable efforts to update or delete your personal information as requested. However, it may not be possible to delete an entry without some delay and without retaining some residual personal information which we may need for legal, tax or audit purposes and in addition for ensuring that we suppress your information from any further communication if this is what you have requested.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Change of purpose

We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Use of surveillance systems

We may monitor and/or record telephone calls for security and training purposes.

Please note that for your safety and security, and for the reasons set out in the section titled “Purposes for which we will use your personal data”, we operate surveillance systems (which includes CCTV) 24 hours a day. Images are monitored by authorised personnel up to 24 hours a day, every day of the year.

We will never engage in covert monitoring or surveillance (that is, where individuals are unaware that the monitoring or surveillance is taking place) unless, in highly exceptional circumstances, there are reasonable grounds to suspect that criminal activity or extremely serious malpractice is taking place and, after suitable consideration, we reasonably believe there is no less intrusive way to tackle the issue. Covert monitoring will only be carried out for a limited and reasonable period of time consistent with the objectives of making the recording and will only relate to the specific suspected illegal or unauthorised activity.

Disclosures of your personal data

We may disclose your information to third parties as follows:

• in order to provide our products and services to you or to otherwise fulfil contractual obligations that we have with you, we may need to appoint other third party organisations to carry out some of the data processing activities on our behalf. These may include but without limitation, payment processing organisations, customer relationship management, delivery organisations, organisations that provide streaming services in respect of Club content/matches, fraud prevention and screening and credit risk management companies, police authorities, providers that can check details against the Telephone Preference Service and mailing houses. 
• to third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
• with advertising networks and/or social media platforms for the purposes of selecting and serving relevant adverts to you via those networks/platforms, and to search engine and analytics providers.
• with third parties (a) if we are under a legal or regulatory duty to do so, (b) if it is necessary to do so to enforce our terms of use or other contractual rights, (c) to lawfully assist the police, security services, football authorities and other football clubs with (1) the prevention and detection of crime, anti-social behaviour and/or terrorist activity and (2) maintaining safety and security at the Club’s premises or such other premises where the Club is partaking in an event, (d) where such disclosure is necessary to protect the health, safety or security of any persons, (e) Courts or other dispute resolution forums, or other legal or regulatory authority if we are under a duty to disclose or share your personal data to comply with any legal obligation, or are enforcing or protecting our rights, or lawfully cooperating in the protection of third party rights (f) if required to do so to deal with or in connection with any complaint or claim received, (g) to ensure that any issues with or had by the Club travelling fans can be efficiently resolved (h) that the Club uses to provide products and services to you, (i) that offer finance products where you have indicated that you wish to apply for a finance product supplied by one of those third parties and/or (j) otherwise as permitted under applicable law.
• With, where permitted, our selected partners (as may change from time to time) and other carefully selected businesses that, in our opinion, might be of interest to you.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

International transfers

Some organisations to which we may disclose your personal information may be situated outside of the EEA. Whenever we transfer your personal data out of the EEA, we take reasonable steps to ensure that your information is still properly protected. This may include safeguards such as checking the relevant countries have been deemed to provide an adequate level of protection for personal data by the European Commission, or using contractual provisions to ensure your information is properly protected.

Data Security

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.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data Retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are available on request.

Updating your information

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.

On receiving your request to update your personal information, we will use commercially reasonable efforts to update or delete your personal information as requested. However, it may not be possible to delete an entry without some delay and without retaining some residual personal information which we may need for legal, tax or audit purposes and in addition for ensuring that we suppress your information from any further communication if this is what you have requested.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have a right to ask us for a copy of the information we hold about you. You can also ask us to correct or update your personal data, or to erase it or transfer it to a third party. You can object to processing of your personal information by us. Where we are using your information based on your consent you can withdraw your consent at any time.

In order for us to locate relevant footage from a surveillance system, any requests for copies of recorded surveillance system images must include the date and time of the recording, the location where the footage was captured and, if necessary, information identifying the individual. We reserve the right to obscure images of third parties when disclosing surveillance system data as part of a subject access request, where we consider it necessary to do so. Where this is not possible we may refuse to provide you with CCTV footage whilst acting in accordance with data protection legislation.

If you wish to exercise any of the rights set out above, please email us at dataprotection@priestfileld.com.

Whilst we hope you would contact the Club first, you have the right to contact the Information Commissioners Office at any time. Please see www.ico.org.uk for contact details.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could 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.

Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

External Third Parties

• Service providers acting as processors based in the United Kingdom who provide IT and system administration services.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the data's accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.