Privacy Policy
Data protection compliance statement – First Kick Football
This document demonstrates our commitment to protect the privacy and security of your personal information. It contains information regarding how we collect and use personal data or personal information about you in advance of any employment relationship in accordance with the General Data Protection Regulation (GDPR) and all other data protection legislation currently in force.
Pursuant to that legislation, when processing data we will:
· process it fairly, lawfully and in a clear, transparent way
· collect your data only for reasons that we find proper for your account, services we provide or marketing purposes.
· only use it in the way that we have told you about
· ensure it is correct and up to date
· keep your data for only as long as we need it
· process it in a way that ensures it will not be lost or destroyed or used for anything that you are not aware of or have consented to (as appropriate).
First Kick CIC is a “data controller”. This means that we are responsible for determining the purpose and means of processing personal data relating to you.
“Personal data”, or “personal information”, means any information relating to an identified, or identifiable individual in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
There are “special categories” of sensitive personal data, meaning data relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health conditions, sex life or sexual orientation, genetic data, and biometric data which require a higher level of protection.
This statement is applicable to job applicants. It is not intended to, neither will it, form part of any contract of employment or contract of services. We reserve the right to make changes to this statement at any time, if you are affected by substantial changes we will make an alternative statement available to you.
Where you are successful in your application and are appointed to a position you will receive details of our data protection compliance statement (privacy notice).
DETAILS OF INFORMATION WE WILL HOLD ABOUT YOU
The list below identifies the kind of data that we will process about you:
· personal contact details such as name, telephone numbers, and personal email addresses
· date of birth
HOW WE COLLECT YOUR PERSONAL INFORMATION
Your personal information is obtained through the signing up process when booking on to one of our services (online, over the phone or by filling out our data forms).
PROCESSING INFORMATION ABOUT YOU
We will only administer personal information in accordance with the lawful bases for processing. At least one of the following will apply when we process personal data:
· consent: You have given clear consent for us to process your personal data for a specific purpose.
· contract: The processing is necessary for a contract we have with you, or because we have asked you to take specific steps before entering into a contract.
· legal obligation: The processing is necessary for us to comply with the law (not including contractual obligations).
· vital interests: the processing is necessary to protect someone’s life.
· public task: the processing is necessary for us to perform a task in the public interest or for our official functions, and the task or function has a clear basis in law.
· legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party unless there is a good reason to protect your personal data which overrides those legitimate interests.
LAWFUL BASIS FOR PROCESSING YOUR PERSONAL INFORMATION
We consider that the basis for which we will process the data contained in the list above (see section above - details of information we will hold about you) for a range of different business purposes and to enable us to comply with our legal obligations. Occasionally, we may process personal information about you to pursue legitimate interests of our own or those of third parties, provided there is no good reason to protect your interests and your fundamental rights do not override those interests.
We use your personal information to fulfill a contract with you and to provide you with our services, to comply with our legal obligation, protect your vital interest, or as may be required for the public good.
The circumstances in which we will process your personal information are listed below:
· To provide payment processing and account management, operate, measure and improve our Services, keep our Services safe, secure and operational, and customise site content that includes items and services that you may like in response to actions that you take.
· To contact you regarding your account, to troubleshoot problems with your account, to resolve a dispute, to collect fees or monies owed or as otherwise necessary to provide you customer service.
· When contacting you for such purposes as outlined above, we may contact you via email, telephone, SMS/text messages, postal mail and via mobile push notifications.
· When contacting you via telephone, to ensure efficiency, we may use autodialed or pre-recorded calls and text messages as described in our User Agreement and as authorised by applicable law. Message and data rates may apply.
· To provide other services requested by you as described when we collect the information.
· We use general location information to provide you with location based services (such as advertising, search results and other personalised content).
· To prevent, detect, mitigate, and investigate fraud, security breaches or other potentially prohibited or illegal activities.
· To enforce our User Agreement, this privacy notice, or other policies, and to monitor restrictions on offers to buy or sell outside of eBay and member-to-member communications for violations of our policies or applicable laws.
We use your personal information to pursue our legitimate interests where your rights and freedoms do not outweigh these interests. We have implemented controls to balance our interests with your rights. This includes to:
· Improve our Services, for example by reviewing information associated with stalled or crashed pages experienced by users allowing us to identify and fix problems and give you a better experience.
· Personalise, measure and improve our advertising based on your advertising customisation preferences.
· Contact you via email or postal mail in order to offer you coupons, discounts and special promotions, poll your opinions through surveys or questionnaires and inform you about our Services, as authorised by applicable law.
· Contact you about public policy matters, or other current events, related to your ability to use our Services. This could include an invitation to join a petition, letter writing, call or other sort of public policy related campaigns.
· Deliver targeted marketing, service updates and promotional offers based on your communication preferences.
· Measure the performance of our email marketing campaigns (e.g. by analysing open and click rates).
· Monitor and improve the information security of our site and mobile applications.
With your consent, we may use your personal information to:
· Provide you with marketing via telephone calls, email, SMS/text.
· Provide you with marketing from third parties.
· Use your precise geo-location to provide location based services.
· Use your sensitive personal information to facilitate transactions in certain categories.
You have the right to withdraw your consent at any time.
We may use technologies considered automated decision making or profiling. We will not make automated-decisions about you that would significantly affect you, unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are required by law to use such technology.
There may be more than one reason to validate the reason for processing your personal information.
SHARING DATA
We may disclose your personal information to the following parties for the following purposes:
First CIC employees who may use it to:
· Provide joint content and services (like registration, transactions and customer support)
· Help detect, investigate, mitigate and prevent potentially fraudulent and illegal acts, violations of our User Agreement and data security breaches
· Provide you personalised advertising
· Improve their products, sites, applications, services, tools and marketing communications.
· Members of our First Kick LTD family will use your personal information to send you marketing communications only if you have consented to receive such communications from them or if otherwise permitted by the law.
Service Providers and financial institutions partners as follows:
· Third party service providers who help us to provide our Services, payment processing services, assist us in providing customised advertising, to assist us with the prevention, detection, mitigation, and investigation of potentially illegal acts, violations of our User Agreement, fraud and/or security breaches, bill collection, affiliate and rewards programs, co-branded credit cards and other business operations.
· Third party financial institutions with whom we partner to offer financial products to you, for them to provide joint content and services (such as, registration, transactions and customer support). These third party financial institution partners will use your personal information to send you marketing communications only if you have requested their services.
Law enforcement, legal proceedings and as authorised by law
· To comply with our legal requirements, enforce our User Agreement, respond to claims that a listing or other content violates the rights of others, or protect anyone's rights, property or safety.
· To law enforcement or governmental agencies, or authorised third-parties, in response to a verified request or legal process relating to a criminal investigation or alleged or suspected illegal activity or any other activity that exposes us, you, or any other of our users to legal liability. We will only disclose information we deem relevant to the investigation or inquiry.
· To credit agencies or bureaus as authorised by applicable national laws (e.g. information on late or missed payments or other defaults on your account that may be reflected in your credit report or file).
· To third parties involved in a legal proceeding, if they provide us with a subpoena, court order or substantially similar legal basis, or we otherwise believe in good faith that the disclosure of information is necessary to prevent imminent physical harm or financial loss or to report suspected illegal activity.
Change of Ownership
If we are subject to a merger or acquisition with/by another company, we may share information with them in accordance with our global privacy standards. Should such an event occur, we will require that the new combined entity follow this privacy notice with respect to your personal information. If we intend to handle your personal information for any purposes not covered in this privacy notice, you will receive prior notification of the processing of your personal information for the new purposes.
DATA SECURITY
As part of our commitment to protecting the security of any data we process, we have put the following measures in place:
- A Security Policy in place that is followed by all staff.
If you would like further details please contact Claire Ashton by emailing c.ashton@firstkickfootball.co.uk by calling the head office on 01772 428 086.
In addition, we have put further security measures in place to avoid data from being accessed, damaged, interfered with, lost, damaged, stolen or compromised. In cases of a breach, or suspected breach, of data security you will be informed, as will any appropriate regulator, in accordance with our legal obligations.
Any data that is shared with third parties is restricted to those who have a business need, in accordance with our guidance and in accordance with the duty of confidentiality.
DATA RETENTION
Our specific retention times for personal information are documented in our regional records retention schedules. How long we retain personal information can vary significantly based on context of the Services we provide and on our legal obligations. The following factors typically influence retention periods:
How long is the personal information needed to provide our Services?
This includes such things as maintaining and improving the performance of our products, keeping our systems secure, and maintaining appropriate business and financial records. This is the general rule that establishes the baseline for most of our data retention periods.
Is the personal information sensitive?
If so, a shortened retention time is generally appropriate.
Have you provided consent for a longer retention period?
If so, we will retain data in accordance with your consent.
Are we subject to a legal, contractual, or similar obligation to retain your personal information?
Examples can include mandatory data retention laws in the applicable jurisdiction, government orders to preserve data relevant to an investigation, or personal information retained for the purposes of litigation.
After it is no longer necessary for us to retain your personal information, we will dispose of it in a secure manner according to our data retention and deletion policies.
YOUR RIGHTS IN RELATION TO YOUR DATA
We commit to ensure that any data we process is correct and up to date. It is your obligation to make us aware of any changes to your personal information.
In some situations, you may have the:
- Right to be informed. This means that we must tell you how we use your data, and this is the purpose of this privacy notice.
- Right to request access. You have the right to access the data that we hold on you. To do so, you should make a subject access request.
- Right to request correction. If any data that we hold about you is incomplete or inaccurate, you are able to require us to correct it.
- Right to request erasure. If you would like us to stop processing your data, you have the right to ask us to delete it from our systems where you believe there is no reason for us to continue processing it.
- Right to object to the inclusion of any information. In situations where we are relying on a legitimate interest (or those of a third party) you have the right to object to the way we use your data where we are using it.
- Right to request the restriction of processing. You have the right to ask us to stop the processing of data of your personal information. We will stop processing the data (whilst still holding it) until we have ensured that the data is correct.
- Right to portability. You may transfer the data that we hold on you for your own purposes.
- Right to request the transfer. You have the right to request the transfer of your personal information to another party.
Where you have provided consent to our use of your data, you also have the unrestricted right to withdraw that consent at any time. Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use. There will be no consequences for withdrawing your consent. However, in some cases, we may continue to use the data where so permitted by having a legitimate reason for doing so.
If you wish to exercise any of the rights explained above, please contact Claire Ashton by emailing c.ashton@firstkickfootball.co.uk or by calling the head office on 01772 428 086
Consequences of your failure to provide personal information
If you neglect to provide certain information when requested, it may affect our ability to enter into a contract with you, and it may prevent us from complying with our legal obligations.
Change of purpose for processing data
We commit to only process your personal information for the purposes for which it was collected, except where we reasonably consider that the reason for processing changes to another reason and that reason is consistent with the original basis for processing. Should we need to process personal information for another reason, we will inform you of this and advise you of the lawful basis upon which we will process.
Important note: We may process your personal information without your knowledge or consent, in compliance with the above rules (see above section - lawful basis for processing your personal information).
In the event that you enter into an employment contract with us, any information already collected may be processed further in accordance with our data protection policy, a copy of which will be provided to you.
QUESTIONS OR COMPLAINTS
Should you have any questions regarding this statement, please contact Claire Ashton on c.ashton@firstkickfootball.co.uk or by calling 01772 428 086.
The supervisory authority in the UK for data protection matters is the Information Commissioner (ICO). If you think your data protection rights have been breached in any way by us, you are able to make a complaint to the ICO.