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Privacy Policy

Privacy Policy

1. PRIVACY POLICY

    Downton Football Club (collectively referred to as “the Club”, "we", "our", "us") take your privacy very seriously and wants to make sure all the personal information we have collected about you, is safe and secure whether we collect it through our service provider website at https://theclubhousedownton.co...  (“Site”) or from other sources.

    This Policy set outs our commitments to you, in compliance with the General Data Protection Regulation (GDPR) and the Data Protection Act 2018 (“DPA 2018”) (together “Data Protection Laws”) and explains how we collect, store and use the personal information we collect from you. We are the data controller, responsible for the processing of any personal data you give us. We take reasonable care to keep your information secure and to prevent any unauthorised access to or use of it.

    We have not appointed a Data Protection Officer to oversee our compliance with data protection laws as we are not required to do so. In case of any questions please refer to the contact section at the end of this Policy.

    2. PRIVACY NOTICE

      Collecting specific, relevant personal information is a necessary part of us being able to provide you with any services you may request from us or in providing services to our members or just managing our relationship with you.

      When we hold or use your personal information as a data controller (see below for a description of what this is) we will provide you with a privacy notice which sets out in detail what information we hold about you (see below what information we hold), how your personal information may be used and the reasons for these uses, together with details of your rights.

      Where we collect personal information from you directly, we will provide this privacy notice at the time we collect the personal information from you. Where we receive your personal information indirectly, we will provide this privacy notice when we first contact you, first pass the data to someone else or within a month, whichever is the earlier.

      We will only provide this privacy notice to you once, generally at the start of our relationship with you.

      3. THE DIFFERENCE BETWEEN DATA CONTROLLERS/PROCESSORS

        A data controller is a person who controls how personal information is processed and used.

        A data processor is a person who processes and uses personal information in accordance with the instructions of a third party, i.e. the data controller.

        Section 9 covers your rights regarding your personal data. These rights can generally only be exercised against a data controller of your information.

        4. WHAT PERSONAL DATA WE HOLD ON YOU

          Personal data means any information about an individual from which that individual can be identified.

          We collect, store, use and transfer personal data of our junior player members and their parents and/or their guardians and other Club members.

          You provide information about yourself when you register with the Club, and by filling in forms at an event or online, or by corresponding with us by phone, e-mail or otherwise.

          The information you give us may include your name, date of birth, address, email address, phone number, gender, and the contact details of a third party in the case of emergency. We may also ask for relevant health information and criminal records history, which is classed as special category personal data, for the purposes of your health, wellbeing, welfare and safeguarding. Where we hold this data it will be with the explicit consent of the member or, if applicable, the member’s parent or guardian.

          Where we need to collect personal data to fulfil Club responsibilities and you do not provide that data, we may not be able to honour or administer your membership.

          We only collect data that are relevant, adequate and limited to delivering our services. It is your responsibility to provide accurate and up-to-date information, so please ensure any changes are notified to us. Please refer to section 14 on how to get in contact with us.

          5. WHY WE NEED YOUR PERSONAL DATA

            We will only use personal data for any purpose for which it has been specifically provided.

            We have set out below, in a table format, a description of 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.

            Purpose/ Processing ActivityLawful Basis for processing under Article 6 of the GDPR
            Processing membership forms and payments / subscriptionsPerformance of a contract
            Organising matchesPerformance of a contract
            Sending out match or Club information and updatesPerformance of a contract
            Sharing data with coaches, managers or officials to run training sessions or enter eventsPerformance of a contract
            Sharing data with leagues we are in membership of, county associations and other competition providers for entry in eventsPerformance of a contract
            Sharing data with committee members to provide information about club activities, membership renewals or invitation to social eventsThe Club has a legitimate interest to maintain member correspondence for club community purposes.
            Sharing data with third party service or facility providersThe Club has a legitimate interest to run the organisation efficiently and as it sees fit. Provision of some third party services is for the benefit of the Club and its members.
            Sharing anonymised data with a funding partner as condition of grant funding e.g. Local AuthorityThe Club has a legitimate interest to run the organisation efficiently and as it sees fit. Application for funding is a purpose that benefits the Club and its members.
            Publishing match and league resultsConsent. We will only publish your personal data in a public domain, including images and names, if you have given your consent for us to do so. In the case of children under the age of 13 then only with written consent of parent/guardian
            Sending out marketing information such as newsletters and information about promotions and offers from sponsorsConsent. We will only send you direct marketing if you are an existing member or other associated individual and you have not previously objected to this marketing, or, you have actively provided your consent.
            To ensure we understand possible health risks. This is special category data.Consent. We will only process details on your medical history with your consent.

            6. WHO WE SHARE YOUR PERSONAL DATA WITH

              When you become a football playing member of the Club, your information, may be shared with one or more of the following third parties:

              • The Football Association
              • Testway Football League
              • Wessex Football League

              We may disclose your personal information to third parties to comply with a legal obligation; or to protect the rights, property, or safety of our members or affiliates, or others

              We do not sell, trade or rent your personal information to others.

              7. PROTECTION OF YOUR PERSONAL DATA

                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.

                8. HOW LONG WE HOLD YOUR PERSONAL DATA

                  We keep personal data on our members while they continue to be a member or are otherwise actively involved with the Club. We will only hold your information for as long as is necessary.

                  The duration for which we retain your personal information will differ depending on the type of information and the reason why it was collected. Personal information that we need to retain for legal or regulatory purposes will be retained for at least six years from the last season you are registered with the Club, in accordance with usual commercial practice and regulatory requirements.

                  The personal data that is stored on Whole Game System administered by the FA is subject to the FA privacy policy so we advise you to review that policy (http://www.thefa.com/public/privacy/wgs-portal) in conjunction with this notice. If you would like your personal data to be deleted from Whole Game System then please contact the FA.

                  9. YOUR RIGHTS REGARDING YOUR PERSONAL DATA

                    Under Data Protection Laws individuals have certain rights (Rights) in relation to their own personal data.

                    In summary these are:

                    • The rights to access their personal data, usually referred to as a subject access request
                    • The right to have their personal data rectified
                    • The right to have their personal data erased, usually referred to as the right to be forgotten
                    • The right to restrict processing of their personal data
                    • The right to object to receiving direct marketing materials
                    • The right to portability of their personal data
                    • The right to object to processing of their personal data
                    • The right to not be subject to a decision made solely by automated data processing.

                    You should note that some of your rights may not apply as they have specific requirements and exemptions which apply to them and they may not also apply to personal information recorded and stored by us.

                    As a data subject you are not obliged to share your personal data with the Club. If you choose not to share your personal data with us we may not be able to register or administer your membership.

                    If you are unhappy with the way we are using your personal information you can complain to the UK Information Commissioner’s Office or your local data protection regulator. More information about your legal rights can be found on the Information Commissioner’s website at https://ico.org.uk/for-the-public/.

                    However, we are here to help and would encourage you to contact us to resolve your complaint first. To exercise any of your rights, or if you have any questions relating to your rights, please see contact section at the end of this Policy.

                    10. LINKING WITH THIRD PARTY SITES

                      The Site may, from time to time, contain links to and from the websites of our associates, partners, other regional bodies, the FA and clubs, etc. If you follow a link to any of these websites, please note that these websites have their own privacy policies and they will be a data controller of your personal information. We do not accept any responsibility or liability for these policies and you should check these policies before you submit any personal information to these websites.

                      In addition, if you linked to this Site from a third-party site, we cannot be responsible for the privacy policies and practices of the owners or operators of that third-party site and recommend that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions.

                      11. COOKIES

                        Certain parts of the Site uses "cookies" to track of your visit and to help you navigate between sections. More information about cookies can be found on the Site website at http://www.myclubhouse.co.uk/Home/CookiePolicy.

                        12. SECURITY

                          We have taken measures to keep your personal information safe and to prevent unauthorised access to, or use, or disclosure of it. Unfortunately, no information transmission over the Internet is guaranteed 100% secure nor is any storage of information always 100% secure, but we do take all appropriate steps to protect the security of your personal information.

                          13. CHANGES TO THIS POLICY

                            Any changes we may make to this Policy in the future will be posted on our Site and, where appropriate, notified to you by e-mail. When we change this Policy in a material way, we will update the version date at the bottom of this page. Please check back frequently to see any updates or changes to this Policy and should you object to any alteration, please contact us as set out below.

                            14. CONTACT

                              In the event of any query or complaint in connection with the information we hold about you, please contact us by post or email.

                              Post should be addressed to:

                              GDPR Enquiries, The Clubhouse, Downton FC, Wick Lane, Downton, Salisbury SP5 3NF

                              Emails should be sent to secretary@downtonfc.com. Please put GDPR on the subject line.

                              Whilst this privacy policy sets out a general summary of your legal rights in respect of personal information, this is a very complex area of law. More information about your legal rights can be found on the Information Commissioner’s website at https://ico.org.uk/for-the-public/.

                              Version dated 21 July 2019

                              Privacy Policy for Junior Members

                              We at the Downton Football Club want to make sure all the personal details we hold about you are safe and secure, so we have put together this note to tell all of our junior members, whether you are a player or simply a fan of the sport, how we make sure we just do that and what to do in case you have any questions for us or want to see what information we have.

                              We are, what is known as, a data controller. This means we have control over how your details are used and who we pass them to.

                              Sometime Clubs like ours need to appoint an individual called a “Data Protection Office” to make sure that we are being very careful with your information.

                              We don’t need to have Data Protection Officer, but we have a person who can be contacted instead to make sure your details are safe. Please refer to section 10 on how to get in contact with us.

                              1. WHAT TYPE OF DETAILS DO WE COLLECT FROM YOU?

                                We might collect the following personal details about you before, during or after your time as a member, such as:

                                • details of how we can contact you, such as your name, email address, where you live and phone number;
                                • your birthday;
                                • your gender;
                                • membership details including when you signed up to be a member and any date you decide
                                • any bank details belonging to your parent or guardian so that we can receive payments from you and details of any payments you make;
                                • videos and photos of you;
                                • your passport or other ID cards;
                                • details of family members, coaches and other people we might need to contact in case of an emergency;
                                • any disciplinary information or details of any issues you have with us or we have with you; and
                                • any other information to allow us to run the football club and administer your memberships.

                                2. SPECIAL CATEGORIES OF PERSONAL INFORMATION

                                We may also hold and use what is called “special information” such as any information about your health such as any injuries you have/have had or times you may not have been very well.

                                We will only use it if we have a really good reason to do so such as:

                                • if it is in the interests of the public and we have a lawful reason to use it;
                                • we need it to help us with a legal case we are involved in;
                                • certain laws allow us to use it; or
                                • you have told us you are happy for us to use it.

                                In the table below we refer to these as the “special reasons”.

                                3. WHERE DO WE GET THIS INFORMATION FROM?

                                  We will normally collect personal information about you when you create an account through our service provider website at https://www.theclubhousedownton.com (“Site”) to become a member of The Clubhouse (Downton Football Club), or when you want to talk to us on the phone, by e-mail or in some other way.

                                  4. HOW DO WE USE YOUR INFORMATION?

                                    What do we use your information for?What type of information do we use?What reason do we have to use it (this is the boring legal bit…)

                                    To make sure your membership with us runs smoothly and we can provide the very best service for you.

                                    All contact and membership details, any chats we have had and your likes and dislikes.

                                    We need all this information to make sure we do a good job in managing your membership with us.

                                    To send you information which we think you might like such as opening hours, upcoming events and any updates.

                                    All contact and membership details.

                                    We need all this information to make sure we do a good job in managing your membership with us.

                                    To send you other information we think you might like or which you have asked us to send to you.

                                    All contact and membership details.

                                    Only where you have told us you want to receive this type of information.

                                    If you are under the age of 13 your parent or guardian must have given their consent to allow us to send you marketing messages.

                                    To help you if you have a question or you are not happy with something we have done.

                                    Contact details and any chats we have had.

                                    It is in our interests to make sure we deal with any issues you have quickly.

                                    We will keep all of your details on our files.

                                    All of your personal details.

                                    It is in our interests to hold your details on file so we can deal with any issues with your membership and to make sure we do a good job in managing your membership. Sometimes we may have to keep your details because the law tells us we have to.

                                    If we use any ‘special information’, we will only do so on the basis of one of the ‘special reasons' we talked about above and after we obtained your consent.

                                    To promote the sport, our events and membership packages.

                                    Any photos or videos of you.

                                    Only where you have told us you are happy to use our photos.

                                    To make sure we are keeping up with health and safety.

                                    Details of the events and competitions you have attended.

                                    It is in our interests to make sure we provide you and others like you with a safe place to play your sport.

                                    Sometimes we may have to keep your details because the law tells us we have to.

                                    We might use details about your health (including any injuries or disability) to make sure you are playing in a safe environment by making changes to the design of our sports facilities and to ensure you are well enough to participate.

                                    Details about your health.

                                    We will only use this ‘special information’, on the basis of one of the ‘special reasons' we talked about above and after we obtained your consent.

                                    To put together all the information we need in case there are any disciplinary or other issues with your membership.

                                    All of your personal details.

                                    It is in our interests to make sure we provide you and others like you with a safe and fair place to play your sport.

                                    If we use any ‘special information’, we will only do so on the basis of one of the ‘special reasons' we talked about above and after we obtained your consent.

                                    To make sure we are fairly offering opportunities to everyone.

                                    Name, your birthday, gender, information which part of the world you or your family are from, details about your health and performance.

                                    It is in our interests to make sure we provide you and others like you with the same opportunity to get into sport no matter who you are and where you come from.

                                    If we use any ‘special information’, we will only do so on the basis of one of the ‘special reasons' we talked about above and after we obtained your consent.

                                    In some cases we might need the information you have given us to make sure we can do what we say we are going to do with your details. Other times, we may not need it, but if we don’t have it, we may not be able to provide you with the best possible service.

                                    If you have told us we can use your information in a certain way, you can tell us to stop using it at any time. Please refer to section 10 on how to get in contact with us.

                                    5. HOW CAN YOU STOP US FROM MARKETING TO YOU?

                                      Sometimes we may wish to contact you by email, post or text message to tell you about things we think you might like. We will only do this if you have told us you are happy to receive these messages and you can tell us to stop at any time. Please refer to section 10 on how to get in contact with us.

                                      6. WHO ELSE MAY USE YOUR DETAILS?

                                        We may send your details to others to help us run our organisation. These are:

                                        • The Football Association
                                        • Testway Football League
                                        • Wessex League

                                        7. ARE YOUR DETAILS SAFE?

                                        We have put in place security measures to make sure your details don’t go missing or get used in a way they shouldn’t be.

                                        Did you know that all ‘data controllers’ based in the UK like us are subject to laws that make sure that your personal details are safe?

                                        That is why we don’t share your personal details to anyone outside of the UK.

                                        8. HOW LONG DO WE KEEP PERSONAL INFORMATION FOR?

                                          We collect personal details from you for different reasons and so we might keep it for different lengths of time. For example, we might have to keep it for a long time for legal reasons, but most of the time, we will keep your details for six years after you last get in touch with us.

                                          It is important to make sure that the details we hold about you is accurate and up-to-date, so make sure you let us know if anything like your email address or phone number changes. You can normally do this by contacting us. Please refer to section 10 on how to get in contact with us.

                                          9. WHAT ARE YOUR RIGHTS?

                                            Did you know you can ask us to do lots of things with your details?

                                            You can ask us:

                                            • to tell you how your details are being used;
                                            • to provide you with a copy of all details we hold on you;
                                            • to correct some of the details we hold if they are not correct or out of date like your contact details for example;
                                            • to delete all of the details we hold on you (unless we have a good reason not to!);
                                            • to stop using your details in a certain way;
                                            • to send your details to you or another organisation like any club you play at for example; and

                                            Some of the rights may not always apply to the personal details we hold for you as there are sometimes requirements and exemptions attached which means we need to hold on to certain information and other times the rights may not apply at all.

                                            DON’T FORGET though, if you have told us we can use your information in a certain way and you would like us to stop, you can tell us to stop at any time and you can always tell us to stop sending you marketing messages.

                                            More information about these rights can be found online here https://ico.org.uk/for-the-public/. If you have any questions or are unhappy about something, please refer to section 10 on how to get in contact with us.

                                            10. WHAT HAPPENS IF WE NEED TO CHANGE THIS NOTICE?

                                              Keep an eye out for changes to this notice on the Site. If we make big changes the version date at the bottom of the notice will be updated. Of course where we are required to do so by law, we will ask for your permission before we change the reason for using your details.

                                              11. HOW CAN YOU GET IN TOUCH?

                                                If you have a question or a complaint, you can always get in touch with us by post or email.

                                                Post should be addressed to:

                                                GDPR Enquiries, The Clubhouse, Wick Lane, Downton SP5 3NF

                                                Emails should be sent to secretary@downtonfc.com.

                                                Version dated 07 July 2021



                                                Use of Email Tracking Pixels

                                                All emails sent by the system contain a tracking pixel. This is used to track whether each email has been opened by the recipient, and when. This information can be viewed by those users of the system with permission to view email delivery reports. We do not display any information regarding the location of the recipient. Note that the tracking pixel is only activated if the recipient chooses to download images into their email client.

                                                Data Processor

                                                We, Downton Football Club, make use of the myClubhouse software supplied by Simmetrics Ltd to process personal data we include on our myClubhouse website in accordance with our privacy policy set out above. Simmetrics Ltd processes your personal data on our behalf and they can only do so in accordance with our written instructions. You can find the details of our data processor’s privacy policy here: http://www.myclubhouse.co.uk/Home/PrivacyPolicy.

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