‘Personal data’ is essentially information from which an individual person can be identified.
The Policy is set out in sections so you can click through to the specific areas you want to know. The detail is in each section, along with a quick read summary where relevant.
In brief… The EFL Digital Group and the Club for which this website is branded. Details of our Data Protection Officer(s) can be found here.
EFL Digital operates the Online Facilities on behalf of the Club. EFL Digital is part of the EFL group of companies, so when this policy refers to the “EFL Digital Group” that’s what we mean. The EFL Digital Group may use your data on the basis set out in this Policy, as may the Club.
References to “we”, “us” and “our” in this Policy are all references to EFL Digital Limited and the Club.
Click for company information about the Club, EFL Digital Group and our Data Protection Officer(s).
In brief… Personal data collected by the EFL Digital Group when you use the Online Facilities. This personal data may also be used by the Club.
This Policy applies to personal data collected by the EFL Digital Group through your use of the Online Facilities.
Where personal data is collected and used for the purposes set out in this Policy, EFL Digital and the Club are both ‘data controllers’ under data protection law applicable in the EU (“Data Protection Law”).
You should read this Policy together with any other privacy information which may be provided on specific occasions when personal data about you is collected on the Online Facilities. That will ensure you are fully aware of how and why we are using your data. This Policy supplements any other notices and is not intended to override them.
This Policy does NOT apply in relation to any data you provide to the Club or EFL Digital Group through offline scenarios separate from the Online Facilities, such as unrelated telephone enquiries or in person.
This Policy does NOT apply where the Club collects your personal data for its own use without any involvement of the EFL Digital Group. This may be (i) on the Online Facilities, or (ii) on other web- based facilities of the Club such as its own separate website for merchandise or ticket sales etc.
Where this is the case on the Online Facilities, that will be clearly noted on the relevant page used by the Club to collect your information.
In these circumstances only the Club will be the ‘data controller’ for the purpose of Data Protection
Law. The EFL Digital Group will not be controlling your data for these purposes.
For further information about how the Club uses your data in these circumstances, [check out the Club Privacy Notice OR please contact your Club].
Links to Third Party Websites and Services
We are not responsible or liable for the content, privacy notices or services offered by websites or apps other than the Online Facilities. We encourage you to read those notices.
This includes websites and apps which link from any of the Online Facilities, with the exception of: (i) the Club’s official ticketing and merchandise service, which only the Club controls, and (ii) the official EFL website, which EFL Digital controls.
In brief… Information which identifies you, contact information, financial or transactional information, technical and profile data, information about how you use the Online Facilities, and/or preferences you have notified to us. We use safeguards for any collection of children’s data.
We may collect, use, store and transfer different kinds of personal data about you. For the purpose of
this Policy we have grouped these together as follows:
Identity Data such as your name(s), username or similar identifier, marital status, Club supporter or similar number, title, date of birth, gender and job title (where relevant).
Contact Data such as your address, billing address (where different), email address, preferred language and telephone numbers.
Financial Data such as your bank account, PayPal account and/or payment card details.
Transaction Data such as details about payments to and from you and other details of products or services you have purchased from us or accessed on the Online Facilities (including as part of any iFollow subscription you have).
Profile Data such as your username and password, associated social media accounts, supported team or Club, your interests, preferences, posts or comments on interactive features (if any), feedback and/or survey responses.
Usage Data such as information about how you use the Online Facilities and services provided through them (including iFollow, newsletters and marketing emails, and advertisements). This may include information about page views, length of visit or use and exit route, timing, frequency and patterns of your use, along with navigation paths when using the Online Facilities – this information does not directly identify you. We use various tools to help us with this, including Google Analytics (see our Cookies Policyfor further information). Where you have subscribed to receive the Club newsletter or marketing emails we will also receive information about whether you open, delete, or access links contained in the newsletter, the browser or app type used and whether opened via mobile or desktop.
Communications Data includes information you provide when communicating with us, your preferences in receiving marketing from us and our third parties and (where relevant) any other communication preferences.
Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be generated from your personal data but does not directly reveal your identity. However, if we combine or connect Aggregated Data with your personal data so that it can directly identify you, we treat the combined data as personal data which will be used in accordance with this Policy.
Special Categories of Personal Data includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). We generally do not collect this information, and where we do it is held in an anonymised form detached from your other data so does not reveal your identity. We do not collect any information about criminal convictions and offences.
If you fail to provide personal data
Use of services accessed through the Online Facilities may require you to provide specific types of information. Where you fail to provide that information, we may not be able to perform the contract we have or are trying to enter into with you. For example, we may not be able to provide you with access to an iFollow subscription.
We understand that children and young people, including those under 13 years of age (“minors”), may visit the Online Facilities or otherwise interact with us. Minors may need their parent or guardian’s permission to use or access certain facilities or receive certain information through the Online Facilities. Minors may also be asked to confirm they have that permission, and we reserve the right to verify parental or guardian consent, where required.
We try not to make a minor’s participation in activities with us contingent on the minor disclosing any more personal information than is reasonably necessary in order to do so. We do not actively market to minors or use (or pass to any third party) personal information on persons known to be minors for any commercial purposes, without proper consent.
Other age restrictions may apply to certain products, services or opportunites available through our Online Facilities.
In brief… Through direct interactions with you or your use of the Online Facilities, automated technologies, relevant third parties and publicly available sources such as social media platforms. Some data passes through our contractors systems before coming to us.
We use different methods to collect data about you, including through:
Direct interactions. You may give us your Identity, Contact, Financial, Communication and certain Profile Data by filling in forms or by corresponding with us using contact details we provide on the Online Facilities. This includes, amongst other things, personal data you provide when you: request an iFollow or newsletter subscription); participate in interactive features, including any competition, promotion or survey; or give us feedback.
Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
We may also supplement the information collected with other information that we obtain from our dealings with you or which we receive from other organisations, such as our commercial partners, and group companies.
In brief… To deliver services you request; take payments; allow you to make use of interactive features (if any); manage and improve our services; communicate with you; marketing and associated profiling (only where you have agreed for email, sms, phone or social media direct messaging); administer, analyse use of and improve the Online Facilities; protect and enforce our legal rights or those of others.
We may profile your use of the Online Facilities and communications you agree to receive, and automated processes also assess your eligibility when you request a subscription to iFollow.
Several legal grounds apply to our use of your data, depending on which of the above purposes we use it for. These may include where: you consent; we need to perform any contract with you; we need to comply with legal requirements; or as necessary for our legitimate interests, but balanced against your rights.
We use information about you for the following purposes:
We may also process your personal data for other reasons, in compliance with the above rules, where this is required or permitted by law. Where we reasonably consider that we need to process your personal data for another reason that is compatible with the original purpose set out in this Policy we will do so. If that is ever the case and you wish to get an explanation as to how processing for any 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. In some circumstances, this may require your consent.
In brief… usually in the European Economic Area (EEA) but always in a manner that ensures proper security. We will only keep the minimum amount of information for as long as we need it for the purpose(s) set out in this Policy.
We are committed to protecting the security of your personal data, which we generally hold in secure data centres in the European Economic Area (EEA).
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 (certain contracts are approved by the European Commission).
In relation to personal data sent to the US, we usually check whether the ‘Privacy Shield’ applies – that ensures a similar level of protection to personal data shared within the EEA. See https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/eu-us-privacy- shield_en, for further details.
We will keep the personal data you have provided only for as long as we reasonably require 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. This is in addition to any applicable legal requirements. Details of any specific retention periods for different aspects of your personal data are available on request by contacting us at firstname.lastname@example.org.
For legal reasons we may have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for up to seven years after they cease being customers – this is particularly for any paid for products or services.
In some circumstances you can ask us to delete your data: see the “What are your rights?” sectionbelow for further information.
We may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
We have put in place appropriate operational, technical and security measures to reduce the risk of your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. This includes use of encryption where relevant, for example in relation to financial information you provide through the Club iFollow service which is encrypted for additional security. 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.
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.
If we have given you a password to access certain parts of the Online Facilities, you must keep the password safe and make sure you use a secure browser.
In brief… other companies in the EFL Digital Group or Club group; new owners of those businesses; legal bodies; selected contractors who help us provide the Online Facilities (including payment service, hosting and other technical providers); affiliates in the football industry; and commercial partners and sponsors of the Club and/or EFL Digital Group, including where you have agreed to receive marketing information from them.
We may disclose your information to third parties as follows:
We may have to share your personal data with the parties above for the purposes set out in the “What do we use your information for?” section of this Policy. In some circumstances, there may be other lawful reasons for the third party to use your data in accordance with any privacy notice they make available to you.
We may also provide anonymised Aggregated Data to third parties. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.
In brief… Access or object to use of your data; have your data corrected, erased, transferred or used only in a restricted way; complain to us or the Information Commissioner; withdraw consent to use your data. Some rights are only available in limited circumstances.
Under the Data Protection Laws you may have the following rights in relation to your personal data in certain circumstances:
All requests set out in this section or other queries relating to this Policy should be addressed to EFL Digital. See the “Who can you contact for further details?” section below. Please note we may not
always be able to comply with your request due to our legitimate interests or other legal reasons. If applicable, these will be notified to you in response to a relevant request.
You will not usually have to pay a fee to exercise any of the above rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive (or we may refuse to comply with your request in these circumstances).
For security reasons, 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). We may also ask you for further information in relation to your request.
If you have any concerns about how we use your data you also have the right to raise this with the Information Commissioner’s Office at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF (https://ico.org.uk). However we will always try to help with any concerns so ask that you contact us in the first instance.
In brief… Yes we like to ensure you are up to date about our use of your personal data. If we update this policy we will notify you, unless the changes are minor.
We may need to update this Policy, and minor changes will be posted on this page so you should check back from time to time. Significant changes will be notified to you.
This Policy was last updated on 2 May 2018.
Data Protection Officer, EFL Digital Limited, EFL House, 10-12 West Cliff, Preston, Lancashire, England PR1 8HU or email@example.com. Please include your name, address, and/or email address when you contact us.