Information

Privacy Policy

INTRODUCTION

The Portsmouth Community Football Club Ltd (‘Pompey’) is committed to protecting the privacy and security of the personal information we collect from you and handling it responsibly.

This privacy notice describes how we collect, use and store personal information about you during and after any interaction with us. It also covers and protects all personal data that we receive from third parties with your consent.

Pompey is a data controller. This means that we are responsible for deciding how we hold, use and store personal information about you. We are required under the data protection laws to notify you of the information contained in this privacy notice.

We may update this at any time so please check back at any time to view any changes.

It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using your personal information.

DATA PROTECTION PRINCIPLES

We will comply with all relevant data protection law (including the GDPR). This requires that the personal information we hold about you must be:

  1. Used lawfully, fairly and in a transparent way.
  2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
  3. Relevant to the purposes we have told you about and limited only to those purposes.
  4. Accurate and kept up to date.
  5. Kept only if necessary for the purposes we have told you about.
  6. Kept securely.

THE KIND OF INFORMATION WE HOLD ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified, whether directly or indirectly. It does not include data where the identity has been removed (anonymous data).

There are also "special categories" of sensitive personal data which require a higher level of protection.

We collect personal data from your interactions with us, for example when you purchase tickets, attend an event at Fratton Park, or when you email or phone us.

The personal data we collect from you includes:

  • The name and contact details when you purchase tickets, enter competitions or send any enquiry to Pompey.
  • Your payment card and address details.
  • Your marketing preferences, including any consents you have given us or third parties.
  • Information about your use of our websites and apps.
  • Your communications with us. (For example, by email, social media, events or enquiries).
  • Information about your attendance at Fratton Park, such as matches, events and tours.
  • Images and Videos may be taken as these events and all parts of the stadium are covered by CCTV.

HOW YOUR PERSONAL INFORMATION IS COLLECTED

We typically collect personal information from you through TicketMaster (www.eticketing.co.uk/pompeyfc) when purchasing tickets, tours or events online, via the web browser and cookies, through our enquiry tab (https://www.portsmouthfc.co.uk/contact-us/ or  http://commercial.portsmouthfc.co.uk/contact), when you email through to us, at any point on the Pompey (www.portsmouthfc.co.uk)  EFL Digital website where you login, through any register your interest and any competitions you enter via our social media/google forms.

HOW WE WILL USE INFORMATION ABOUT YOU

We will only use your personal information when the law allows us to. If you opted-in to receive information and offers from us and our partners (for example by giving consent on one of our competition or registration forms) then we will provide any offers or information to you by email, phone/SMS or post.

Click here to see a list of our current partners.

Most commonly, we will use your personal information in the following circumstances:

  • Where we need to perform the contract, we have entered with you.
  • Where we need to process the orders that you have placed with us.
  • Where we need to administer your account with us.
  • Where we seek feedback on the products and services that we provide.
  • Where we need to notify you of changes to our products and services.
  • Where we send you information about other products or services that you have specifically requested from us.
  • Where we need to comply with a legal or regulatory obligation.
  • Using incident reports cards and CCTV to investigate any issues arisen on a matchday/event and ensure the security and safety of our fans and staff.
  • We may need to process a job application or respond to an enquiry about a possible job with us.
  • 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 also use your personal information in the following situations, which are likely to be rare:
  • Where we need to protect your interests (or someone else's interests).
  • Where it is needed in the public interest or for official purposes.
  • Where we may detect crime within the stadium.

COOKIES

Like many other websites, the Pompey websites uses cookies. 'Cookies' are small pieces of information sent by an organisation to your computer and stored on your hard drive to allow that website to recognise you when you visit. They collect statistical data about your browsing actions and patterns and do not identify you as an individual. For example, we use cookies to [store your country preference]. This helps us to improve our website and deliver a better more personalised service.

It is possible to switch off cookies by setting your browser preferences. Turning cookies of may result in a loss of functionality when using our website.

To view more information about the cookies used on our sites please visit;

Cookie Consent tab on https://www.eticketing.co.uk/pompeyfc

EFL Digital Privacy Policy on https://www.portsmouthfc.co.uk/website-privacy-policy/

Our Commercial Site on http://commercial.portsmouthfc.co.uk/information/cookies

DATA SHARING

We may have to share your data with third parties (listed here), including third-party service. We require third parties to respect the security of your data and to treat it in accordance with the law and we will have a contract in place with each of these third parties to ensure the protection of your personal information.

Why might you share my personal information with third parties?

We may share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.

How secure is my information with third-party service providers and other entities in our group?

All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies and this is supported by a contractual agreement with clear obligations on the third parties. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our written instructions.

What about other third parties?

We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.

DATA SECURITY

We have put in place appropriate technical and security measures to protect the security of your personal information. Details of these measures are available upon request.  Third parties will only process your personal information on our written instructions and where they have agreed to treat the information confidentially and to keep it secure as part of their contractual arrangement with us.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, workers, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures are available upon request.

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

HOW LONG YOUR PERSONAL INFORMATION IS STORED FOR

We keep personal data about your purchases, bookings and interaction for as long as your ticketing account remains active, and for a limited time afterwards (for in the event you reinstate your account or have any questions about it). This is also the case for any event bookings through C & B/Hospitality. We retain personal data about your purchases for 6 years from the initial transaction so that we can meet our legal and contractual obligations and understand how you purchase.

CCTV footage is kept for up to 42 days and held if we need to resolve an issue or meet a legal requirement. Body cam footage is also kept for the same length of time.

IF YOU ARE UNDER 16

Aged 13-15

If you are aged 13-15, you must first tell your parent or legal guardian that you wish to register on our digital platforms and get their consent. You must make sure that your parent or legal guardian knows and agrees each time before you:

   • email us or ask us to email anything to you;

   • send any information to us;

   • enter any competition or game that requires information about you or offers a prize;

   • purchase an official membership; or

   • offer or agree to buy anything online.

If you are the parent or legal guardian of a user of our digital platforms who is aged 13 to 15 we do not seek your direct consent to their registration, but we expect them to inform you and get your agreement in advance before they register and before each time they do any of the activities listed above.

Aged under 13

If you are under 13 and wish to register, you must truthfully tell us your name, email address, country and date of birth. We will then ask you for the name and email address of your parent or legal guardian. We will send them an email, so they are aware of your request and will ask them for their consent and to confirm they have authority to give that consent. We need their consent or refusal within 7 days, or else we will assume consent is not granted. Their consent can be withdrawn at any stage.

Even if your parent or legal guardian gives their consent to your registration, if you are under 13 we still expect you to tell them and get their agreement in advance each time before you:

  • email us or ask us to email anything to you;
  • send any information to us;
  • enter any competition or game that requires information about you or offers a prize; or
  • offer or agree to buy anything online.

If you are the parent or legal guardian of a user of our digital platforms who is under 13, they can access and use unrestricted areas, but we will need your direct consent if they wish to gain access to restricted areas.

RIGHTS OF ACCESS, CORRECTION, ERASURE AND RESTRICTION

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes at any point by emailing info@pompeyfc.co.uk

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

  • Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
  • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground.
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request for transfer of your personal information to another party

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact our DPO.

No fee usually required

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

What we may need from you

We may need to request specific information. To ensure we are speaking to the correct person we will to of (certified copy of your passport, valid driving License or utility bill) from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact our Data Protection Officer in writing or email optout@pompeyfc.co.uk . Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Data Subject Access Request

If you wish to submit a data subject access request, please email privacy@pompeyfc.co.uk with proof of identification (Passport/Driving license).

CHANGE OF PURPOSE

We will only use your personal information 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 we need to use your personal information for an unrelated purpose, we will notify you in writing and we will explain the legal basis which allows us to do so.

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

CHOICES YOU HAVE WITH YOUR PERSONAL INFORMATION

You have a choice about whether you wish to receive information from us. If you do not want to receive direct marketing communications from us about the work we do and our exciting products and services, then you can select your choices by ticking the relevant boxes situated on our registration, competition and register your interest forms. The opt out can be found at the bottom of each of these forms and you can opt out from one method of delivery, from third party or from all.

We will not contact you for marketing purposes by email, phone/SMS or post unless you have given your prior consent. You can change your marketing preferences at any time by contacting us by email:

optout@pompeyfc.co.uk

or write to us at:

Portsmouth Community Football Club Ltd
Fratton Park
Portsmouth
Hampshire
PO4 8RA

DATA PROTECTION OFFICER(DPO)

We have appointed a data protection officer to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your information, please contact our

DPO by email on privacy@pompeyfc.co.uk.

CHANGES TO THIS PRIVACY NOTICE

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

If you have any questions about this privacy notice, please contact the DPO on privacy@pompeyfc.co.uk

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