Summary

The Virginia Water Football Club (‘VWFC’, ‘we’, ‘us’) is committed to protecting your personal data and handling it responsibly.  

This policy covers the personal data that VWFC processes whenever you interact with us, including when you engage with us online (such as on social media or by using our website), and when you correspond with us (such as by email or over the phone).  It also covers personal data that we may receive from third parties.    

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The sections below explain in more detail:

• the types of personal data we collect from you

• the types of personal data we receive from third parties

• why we process your personal data

• who we share your personal data with

• personal data transfers outside of the UK

• how long we retain your personal data

• your rights to withdraw your consent and to object (including to direct marketing)

• your other personal data rights

 

Personal data VWFC collects from you
We collect personal data from your interactions with us, such as when you engage with us online (such as on social media or by using our website), or when you email or phone us. 

The personal data we collect from you includes: 

• the name and contact details that you provide when you contact us

• your marketing preferences, including any consents you have given us

• your browser or device information 

• information about your use of our website

• information about your engagement on social media.

• your communications with us 

• information about your attendance at VWFC events, such as matches, concerts and conferences held at VWFC.  Photos and video footage of you may be taken at these events 

• information you provide us to comply with our site entry procedures (including in respect of Covid-19) 

 

Personal data VWFC receives from third parties
Sometimes we receive personal data from third parties, in particular:  

• our commercial partners provide us with your name and contact details if you’ve asked to receive information from VWFC. 

• online personalisation providers tell us how you engage with our website  and marketing providers (Awin and Google Adsense)

• data specialists provide us with insights about our supporters, based on their own aggregated data sets 

• government and law enforcement authorities provide us with personal identification and background information when they are involved in official inquiries 

• agencies who partner with VWFC in the Community may share information with us about participants that we refer to them 

• other football clubs and football authorities may provide us with personal data to, amongst other things: (i) assist in preventing violent and antisocial behaviour at matches, (ii) enforce sanctions under the League’s Commitment Regarding Abusive and Discriminatory Conduct, (iii) combat ticket touting, and/or (iv) support with handling fan inquiries 

 

Why VWFC processes your personal data
This section explains the reasons why we process your personal data and our legal bases for doing so.

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Consent
If you’ve opted-in to receive information and offers relating to the Club and our commercial partners (for example by ticking a box on one of our websites or apps), then we’ll provide this information to you by email, text, or phone.

We also rely on your consent to process information about your use of our websites, apps and social media sites, so that we can improve your browsing experience and deliver online advertising that is relevant to you.

Wherever we rely on your consent to process personal data, you have a right to withdraw that consent.

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Legitimate interests
We process your personal data when necessary to pursue our legitimate interests in the following:   

• tailoring our websites and communications for you.  We collect information about your engagement with us online (such as pages that you have visited on our websites or apps) and combine that with aggregated insights we have about our supporter base, to build a fuller understanding of your individual preferences 

• monitoring, improving and protecting our products, content and services 

• preventing abusive, discriminatory or otherwise inappropriate or offensive behaviour, whether in person or online, that is directed towards any football club (including their players or other members of staff), match official or any other individual attending or involved in a football match 

• sending you some types of direct marketing, including by email and post (Awin and Google Adsense)

• responding to your comments or complaints 

• undertaking, or inviting you to take part in, market research 

• querying whether you have had an issue completing an online form 

• preventing, investigating and/or reporting fraud, terrorism, misrepresentation, security incidents or crime 

• to protect the health and safety and security of our spectators, staff and other visitors to our sites (including in respect of Covid-19); to enforce our terms and conditions and ground regulations; and to help detect and prevent unlawful activity using, for example, incident reports and CCTV footage 

• managing legal claims, compliance, regulatory and investigative matters 

• administering programmes run by us or our partner agencies that you have chosen to participate in 

 

Contract
We process your personal data when necessary for contractual reasons, such as to administer your account registration and competition entries and to provide products and services that you have requested.

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Legal obligation
We are legally required to process your personal data in cases where we need to: 

• obtain parental consent to provide online services directly to children 

• respond to certain requests by government or law enforcement authorities 

• comply with local Council safety requirements to collect CCTV footage of particular areas around the Stadium   

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Sensitive data 
In limited circumstances, we may need to process your sensitive personal data, such as race or ethnicity data, health data, biometric data, or data about criminal offences.  This will only ever be where we meet a lawful condition for such processing, such as where we have your consent, where the data has been made public by the data subject, or where processing is necessary for: the prevention or detection or unlawful acts, the substantial public interest, or legal claims. 

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Who VWFC shares personal data with
We will share your personal data with the following recipients: 

• commercial partners, so they can advise us how best to communicate with you on their behalf.  We do not give your data to partners for them to communicate with you directly. 

• Facebook, so that we can display relevant advertising to you on their platform (your data is converted into a unique ID before it is shared with Facebook) 

• third party suppliers involved in: data insights; website hosting; online personalisation; advertising; tracking online abuse; systems maintenance; ticketing; database management; (Awin and Google Adsense)

• organisations undertaking official data scout spotting activities within VWFC 

• public authorities or law enforcement officials, to assist with their official requests and comply with our legal obligations, including in respect of Covid-19   

• other football clubs and football authorities, where this is necessary to, amongst other things: (i) ensure the safety and security of supporters, (ii) assist in preventing violent or antisocial behaviour at matches, (iii) enforce sanctions under the League’s Commitment Regarding Abusive and Discriminatory Conduct, (iv) combat ticket touting, (v) support with handling supporter inquiries, or (vi)  if we think it’s appropriate to inform them of incidents at the ground  involving supporters 

• agencies who partner with VWFC in the Community (if you have been referred to those agencies through us)

 

Personal data transfers outside of the UK
Where your personal data is transferred to a country outside of the UK, and that country is not subject to a UK Adequacy Regulation, we will ensure your data is protected by appropriate safeguards (for example, approved standard contractual clauses or a supplier’s Binding Corporate Rules).  A copy of the relevant safeguard can be provided for your review on request

 

How long VWFC retains personal data
Where you have asked us not to send you direct marketing, we keep a record of that fact to ensure we respect your request in future.  

 

We keep a record of CCTV security footage for 30 days, unless we need to hold this data for longer to resolve an issue or to meet a legal requirement.    

We also retain information with the potential to give rise to legal disputes for 7 years. 

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Your rights to withdraw consent and to object (including to direct marketing)

Wherever we rely on your consent to process personal data, you always have a right to withdraw that consent.

You also have the right to object to any use of your personal data for direct marketing purposes, as well as to processing that we undertake based on our legitimate interests (including profiling). 

  

Your other personal data rights

In addition to your rights to withdraw your consent and to object, you have the right to ask us: 

• for access to information about your personal data or for a copy of your personal data 

• to correct or delete your personal data 

• to restrict (i.e. stop any active) processing of your personal data 

• to provide you with certain personal data in a structured, machine readable format and to transmit that data to another organisation 

These rights may not always apply, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to keep or have a compelling legitimate interest in keeping.  If this is the case then we’ll let you know when we respond to your request.