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PRIVACY
POLICY
About us
In this Privacy Policy, we use the term “RBFC”, "Rod Beya Football Club", "RBFD", "Rod Beya Football Development" and "RB Football Development" (and “we”, “us” and “our”) to refer to Rod Beya Football Club and Rod Beya Football Development respectively. Full details about both are provided in the “Legal notice” section below.
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Introduction
Rod Beya Football Development and Football Club (hereafter referred to as “RBFD”, “we”, “us” and “our”), is the data controller for the personal information we process. We recognise that your privacy is important and consequently we are committed to protecting it. This Privacy Policy explains what personal information we process about you when you:
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purchase our products or services such as tickets, memberships and merchandise;
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attend events at our facilities;
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use our web site;
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communicate with us by email, telephone or on social media;
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subscribe to our direct marketing communications;
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interact with us as a representative of our suppliers or partners.
Other websites
Our websites and digital platforms may contain links to other websites which are outside our control and are not covered by this Privacy Policy. If you access other sites using the links provided, the operators of these sites may collect information from you which will be used by them in accordance with their privacy policy, which may differ from ours.
How to contact us about this Privacy Policy
Our RBFC and RBFD welfare officer and secretary can be contacted if you have questions about this Privacy Policy or about your personal data in general. Please write to:
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Personal information we process and what we use it for
RBFD and RBFC will only process your personal information for the purposes outlined in the following sections. If these purposes change over time or we want to use data for a new purpose which we did not originally anticipate, we will only go ahead if the new purpose is closely related to the original purpose. If the new purpose is incompatible with the original purpose, we will seek your specific consent for the new purpose; or if a clear legal provision exists requiring or allowing the new processing in the public interest, we will inform you accordingly.
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You may use the following index to navigate to different aspects of information concerning this policy:
Competitions voting and quizzes
Making an enquiry or a complaint
Interacting with us and others
Responding to requests to exercise your data subject right
More information and data complaints
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Visitors to our website
You can access and browse our websites without the need for you to actively provide us with your personal data. However, when you visit our website, we automatically collect information about your device and about your visit. This helps us to better understand how you use our digital platforms and enables us to design our site to better suit our your needs whilst also creating better, more personalised content which improves your experience for future visits. The information we collect may include:
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how you have reached our digital platform, the internet protocol (IP) address you have used, and the MAC address of your device
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your operating system, browser type, versions and plug-ins
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your journey through our digital platform, including which links you click on and any searches you made, how long you stayed on a page, and other page interaction information
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photos you share with us
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videos you have watched and the duration
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offers you have redeemed
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what content you like or share
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which adverts you saw and responded to
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which pop up or push messages you might have seen and responded to
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your current subscription status
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information collected in any forms you complete
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location based services
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ticketed access to our venues
We may also infer your country of location from the IP address you have used to access our digital platforms.
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Cookies
Some of this information is collected by cookies which are small text files that store basic information that a website can use to track on-line traffic flows, recognise repeat site visits and record information about your on-line preferences. They often include an anonymous unique identifier that is sent to your browser from our websites, which is then stored on your computer's hard drive. Cookies do not attach to your system and damage your files but observe user behaviour and compile aggregate data that we then use to improve web services. We also use cookies to measure the effectiveness of advertising.
For further, more detailed information on how we use cookies, please refer to our Cookie Policy.
The legal basis we rely on to process your personal data is article 6(1)(f) of the GDPR, which allows us to process personal data when its necessary for the purposes of our legitimate interests. The only exception to this is the placement of non-essential cookies on your devices where we rely on article 6(1)(f) of the GDPR which requires us to obtain your consent.
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Registering for a Service
To access the areas of our websites where you can register for a service, you will need to complete a form which requires you to input personal information about yourself and your child. During the registration process, you will be asked to submit personal information including:
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name,
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date of birth,
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sex,
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home address,
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email address,
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contact number
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contact and location preferences,
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your child's player history
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your child's name
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your child's age
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your child's year group
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your child's date of birth
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your child's medical history
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your child's ethnicity
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other information about you and your child that may be relevant to your registration - for example medical and learning needs, and/or allergies.
We use this information to process your registrations to your desired service, to ensure we provide you with age appropriate services to you, and to fulfil and communicate with you about your services.
Where we use this information to provide you with a service, the legal basis we rely is article 6(1)(f) of the GDPR, which allows us to process personal data for our legitimate interests.
Where we use this information to ensure we provide you with age appropriate services, the legal basis we rely is article 6(1)(c) of the GDPR, which allows us to process personal data to meet our legal obligations.
Where we use this information to fulfil or communicate with you about any services you have registered for, the legal basis we rely on to process this data is article 6(1)(b) of the GDPR, which allows us to process personal data where the processing is necessary for the performance of a contract to which the data subject is party.
We may also send you information about our latest news, competitions, events, services, service updates and offers, and those of our partners. The legal basis we rely on for this activity is article 6(1)(a) of the GDPR, which requires use to obtain your consent. this is taken on your registration form for our respective services.
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Making a purchase
We need to process your personal data in order to provide you with the products and services you purchase from us. If you have already registered an account, then we will use the information you provided during the registration process to deliver and communicate with you about your purchase. In addition to this, we will need to collect your payment card details in order to process payment
The legal basis we rely on to process this data is article 6(1)(b) of the GDPR, which allows us to process personal data where the processing is necessary for the performance of a contract to which the data subject is party.
Depending on the service or product you have purchased, we may also need to collect additional information such as:
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details of any disability or access requirement when you purchase services which will take place at our locations. This enables us to make reasonable adjustments to make your visit safe and comfortable and compliant with the Equality Act 2010. The legal bases we rely on for this are article 6(1)(c) of the GDPR which allows us to process information to meet a legal obligation and article 9(2)(b) as the processing is necessary for the purposes of carrying out our obligations in the field of social security and social protection law.
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details about any medical conditions you may have when you enrol in one of our events or programmes. We have a duty of care for all participants. Processing this information enables us to administer appropriate first aid in the event that participants are injured or taken ill whilst on our premises. The legal bases we rely on are article 6(1)(a) and 9(2)(a) which require us to obtain your explicit consent.
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details about your vehicle where the product or service you have purchased entitles you to a parking space. The legal basis we rely on to process this data is article 6(1)(b) of the GDPR, which allows us to process personal data where the processing is necessary for the performance of a contract to which the data subject is party.
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When you attend our settings, a register is taken. This is because we are legally required, for health and safety purposes, to know who is at our provisions.
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Identity screening
Sometimes where there is suspicion of illegal activity such as fraud, we will ask you to provide a copy of an identity document such as a passport. This is usually only necessary for overseas customers and some UK customers where the value of the purchase exceeds a threshold or where the delivery address is different to the card address.
In addition, we may keep the personal information of individuals suspected of suspicious purchasing activity. This information may be shared with other clubs and local law enforcement agencies as we attempt to protect the public against seriously improper conduct.
We also request copies of identity documents in accordance with FA requirements for registering players to our RBFC teams.
When we have completed the check process, we delete the copies.
The legal basis we rely on to process this data is article 6(1)(f) of the GDPR, which allows us to process personal data for our legitimate interests. In this case our legitimate interests are protecting us and our customers against fraud and adhering to FA guidelines in relation to recruitment to our football club for staff, volunteers and players.
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Location data
Our website may use your device’s location data. It may also ask you to provide your country of residence. You are under no obligation to provide this information and you can choose to provide neither. Your device settings will allow you to control this accordingly.
If you have given your permission, your location when accessing our site will be collected. We use this data to help us understand patterns in which areas are locating our website most frequently, so that we can tailor our services and advertisements locally.
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Direct marketing and market research
When you register for a service on our website or elsewhere with us, you will be asked whether you wish to be contacted to share news and updates on our services. These services will be opted out of as default and you can actively opt-in to these services by ticking the respective box/boxes.
For research purposes, when sending communications that individuals have opted in to receive, we may track the open and click through rates. This activity helps us to measure the success of campaigns for those who have provided their consent to receive marketing materials, and for specific Club updates for those individuals who have an existing relationship with the Club and are therefore receiving information as a legitimate interest. This activity can be disabled through opting out at any time, to do so, please send an email directly to hello@rbfd.co.uk.
The legal basis we rely on to process this data is article 6(1)(a) of the GDPR, which allows us to process personal data with your consent.
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Competitions, voting, and quizzes
From time to time we will run competitions, votes and quizzes. When you take part in these activities we will ask you for some basic personal information to enable us to administer the competition, vote or quiz. This will usually consist of your name/email address/phone number and/or personal preferences/answers, which we will need in order to execute the outcome.
As stated in the Direct Marketing section, we will not use this information to send you marketing communications unless you opt-in.
The legal basis we rely on to process this data is article 6(1)(f) of the GDPR, which allows us to process personal data when its necessary for the purposes of our legitimate interests.
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Making an enquiry or complaint
When you contact us to make an enquiry or complaint, we collect personal information such as your email address so that we can respond to you.
We may monitor or transcribe telephone calls for future reference in respect of a complaint or enquiry.
We record details of all enquiries or complaints on our systems and share them with the areas of the business that are best placed to address them.
The legal basis we rely on to process this data is article 6(1)(f) of the GDPR, which allows us to process personal data when its necessary for the purposes of our legitimate interests. In this case our legitimate interests are dealing with the enquiry or complaint and any subsequent issues that may arise, and to check on the level of service we provide.
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CCTV
CCTV systems may be present at the facilities that we use to provide our services, for the purposes of public and staff safety. CCTV may also be installed on the outside of some of the buildings that we use for the purposes of monitoring building security.
In all locations, signs are displayed notifying you that CCTV is in operation and providing details of who to contact for further information.
We are not responsible for the Images captured by CCTV at our respective facilities, however we may access them if required, by site permission, to identify illegal acts or acts of breech that occur at our provisions, and we may use this data to inform necessary external agencies such as the police, or to contact you directly where necessary.
If you are involved in an incident, you have the right to request images/audio recording of yourself in accordance with the General Data Protection Regulations (GDPR) and Data Protection Act 2018 and be provided with a copy of the images. You can request this by contacting the site directly. Images and audio will not be released to the media or placed on the internet for public viewing.
The legal basis we rely on to process this data is article 6(1)(f) of the GDPR, which allows us to process personal data when it is necessary for the purposes of our legitimate interests. In this case our legitimate interests are public and staff safety, crime prevention and detection.
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Interacting with us as a representative of our suppliers or partners.
RBFD and RBFC operate with a growing portfolio of suppliers. Our staff will process details of our suppliers’ or partners’ nominated business contacts in order to manage these business relationships. This includes information such as names, job titles and contact details.
We may also share information about users of our services for the purposes of allocating them the appropriate items in the sale of goods. For example, we may collect clothing sizes and allocate this to the name of a child/adult, used for the purposes of preparing orders and distributing orders correctly.
When running events and services where we invite external representatives, for example, representatives of professional football teams such as scouts, we will share your personal details with them where requested, for the purposes of their future contact with you. You will be asked to opt in to this when you register for the particular service or event.
The purpose for processing this information is for security and safety reasons. The legal basis we rely on to process your personal data is article 6(1)(f) of the GDPR, which allows us to process personal data when its necessary for the purposes of our legitimate interests.
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Applying for a job/volunteering post
When you apply for a job with us, we collect and process a range of personal data in order to assess your suitability for employment. You are under no statutory or contractual obligation to provide data to us during the recruitment process. However, if you do not provide the information, we may not be able to process your application properly or at all.
We ask for:
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personal details including name and contact details
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details of your qualifications, skills, experience and employment history;
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information about your current level of remuneration, including benefit entitlements;
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Identification documents
The legal basis we rely on for processing your personal data is article 6(1)(b) of the GDPR, which relates to processing necessary to perform a contract or to take steps at your request, before entering a contract.
We will also ask whether or not you have a disability for which the organisation needs to make reasonable adjustments during the recruitment process. The legal bases we rely on for this are article 6(1)(c) of the GDPR which allows us to process information to meet a legal obligation and article 9(2)(b) as the processing is necessary for the purposes of carrying out our obligations in the field of social security and social protection law.
You will also be asked to provide your ethnicity and medical history, for the purposes of safeguarding you during a medical emergency. The legal bases we rely on are article 6(1)(a) and 9(2)(b) which require your explicit consent.
In some cases, we need to process data to ensure that we are complying with our legal obligations. For example, it is required to check a successful applicant's eligibility to work in the UK before employment starts. It these situations the legal basis we rely on is article 6(1)(c) of the GDPR which allows us to process information to meet a legal obligation.
When we make a job offer we will also seek information from third parties, such as references supplied by former employers and information from employment background check providers. For some roles, we are legally obliged by safeguarding legislation to conduct criminal records checks. This usually applies to roles that involve working with minors. The legal basis we basis we rely on is article 6(1)(c) of the GDPR which allows us to process information to meet a legal obligation.
Sharing your information
Your information will be shared internally for the purposes of the recruitment exercise. This includes the interviewers, secretary, CEO of RBFD and board members of RBFC, who will be involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles.
We will not share your data with third parties, unless your application for employment is successful and we make you an offer of employment. The organisation will then share your data with former employers to obtain references for you, employment background check providers to obtain necessary background checks and the Disclosure and Barring Service to obtain necessary criminal records checks.
Keeping your information
If you are unsuccessful after assessment for the role, we will hold your data on file for 6 months after the end of the relevant recruitment process. At this point your data will be deleted unless you have told us that you would like your details retained in our talent pool. If this is the case, then we would proactively contact you should any further suitable vacancies arise.
If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment. This will be held for the duration of your employ with us, and thereafter if you request to be kept on file. For purposes of clarification, these measures apply to self-employed coaches, volunteers, employees and all other members who function in a role of work for RBFD and RBFC respectively, whether they are directly employed by us or freelance.
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Responding to requests to exercise your data subject rights
When you contact us to exercise your data subject rights (see “Your Rights” for more information) we will ask you for some information so that we can confirm your identity and ensure that we action your request against the right account. We do not store this information – we just use it to confirm your identity.
We maintain a record of all the data subject rights requests that we receive. If you do make a request, this record will capture your name and a differential piece of data such as your email address or CRN. We keep this record to evidence our compliance with data protection legislation and as a record of our activities in case we are challenged.
The legal basis we rely on to process this data is article 6(1)(f) of the GDPR, which allows us to process personal data when its necessary for the purposes of our legitimate interests.
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Children
If you are under 18
If you have signed up to receive a product or service, you must ensure that this is overseen and actioned by an adult. We will contact you if we suspect that you may be a legal minor and adjust contact information accordingly.
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You must get your parent or legal guardian to give us their consent to your registration, before you:
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email us or ask us to email anything to you;
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send any information to us;
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enter any competition or game that requires information about you or offers a prize;
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purchase an official membership; or
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offer or agree to buy anything online.
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Sharing your information
RBFD and RBFC share your personal data internally and with selected third-parties in the following circumstances:
Third party service providers.
In order to provide our products and services to you or to otherwise fulfil contractual arrangements that we have with you, we may need to appoint data processors to carry out some of the data processing activities on our behalf. These may include, for example, payment processing organisations, delivery organisations, fraud prevention and screening and credit risk management companies, mailing houses and IT system providers. We have contracts in place with our data processors which means that they cannot do anything with your personal information unless we have instructed them. They will not share your personal information with any other organisations and will hold it securely and retain it for the period we instruct.
Commercial Partners
We may also share personal data, such as your name and contact details, with our commercial partners but only where you have explicitly consented to this or requested that we do so. For example, when you enter a competition which is a joint promotion, or you request to receive certain marketing communications. In any case, we will provide you with clear information before we share your personal data.
Publicity and media
We may disclose your personal data publicly via the media or social media. For example, when sharing a comment or opinion you have provided or if you win a competition or promotion we may disclose your name online. You will be given the option to opt-in in to such sharing when you register for your respective service, and you can opt out at any time by notifying us in writing to hello@rbfd.co.uk
Legal and other
We may also share your data with third parties:
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if we are under a legal or regulatory duty to do so
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if it is necessary to do so to enforce our terms and conditions of sale or other contractual rights
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to lawfully assist the police or security services with the prevention and detection of crime or terrorist activity
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where such disclosure is necessary to protect the safety or security of any persons
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and/or (e) otherwise as permitted under applicable law.
Security
Protecting your personal information is very important to us and as such we have put a range of security defences in place in order to ensure it.
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Physical security measures that ensure that physical access to your data, whether it is in electronic or hard copy form, is also restricted and controlled.
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Personnel security measures such as contractual clauses in employment contracts that require our employees to protect the confidentiality of your data, and regular awareness training about data protection and information security.
Some of our IT systems are provided by third party suppliers. In these cases the security of your data is a shared responsibility and we have contracts in place which outline each party’s responsibilities for the security of data.
Keeping your information
We retain your personal information for the minimum reasonable time period to allow us to fulfil the purposes that we collected it for. We will delete or destroy your data after that time except where we need to keep any personal information to comply with our legal obligations, resolve ongoing disputes or defend ourselves against future legal claims, or enforce our agreements.
Occasionally, we may continue to use data without further notice to you. This will only be the case where any such data is anonymised and you cannot be identified as being associated with that data.
Please contact hello@rbfd.co.uk for further information about our retention periods.
Your Rights
You have certain rights in relation to your personal information. In order to exercise any of the following rights please email hello@rbfd.co.uk.
Right of access
You have the right to access the data that we hold on you. We provide you with access to your personal information upon request to hello@rbfd.co.uk.
Right to rectification
You can request that we update any of your personal information, which is out of date or incorrect. We may not always be able to change or remove that information but we’ll correct factual inaccuracies and may include your comments in the record to show that you disagree with it.
Right to erasure
In some circumstances you can ask for your personal information to be deleted. You should be aware however that this is not an absolute right and there are situations where legally, we will not be able to comply with your request. If we cannot comply with your request, we will clearly explain our reasons.
Right to object
You can object to our processing of your personal information where we do so in our legitimate interests or in the public interests. If you do object, you should provide specific reasons why you are objecting to the processing of your data. You should be aware that this is not an absolute right, and we can continue processing if we can demonstrate compelling legitimate grounds for the processing or if the processing is for the establishment, exercise or defence of legal claims. If we cannot comply with your request, we will clearly explain our reasons.
Right to restrict processing
In some circumstances, you have the right to ask us to restrict the processing of your personal data. This may be because you have issues with the content or accuracy of the information we hold and want us to restrict processing whilst these issues are addressed. Alternatively it could be because you have objected to our processing of your data for the purposes of our legitimate interests, and you want us to restrict processing whilst we considering our response. Where we comply with these requests, we will always inform you before lifting the restriction.
Consent withdrawal
Where you have given clear consent for us to process your personal data for a specific purpose, you have the right to withdraw your consent at any time. Please note that we do not rely on consent for the majority of employee personal information we process.
ID Validation
In order to understand who is at our events and ensure that they are in the correct age group. We may ask for photographic ID such as a passport, upon entry and registration.
The lawful basis that RBFD and RBFC have applied for collecting this data under data protection law is GDPR Article 6(1) - legal obligation; we have a common law duty of care to protect the welfare and wellbeing of individuals who attend matches in the Stadium.
Your personal data will be retained only for the purposes stated in this section of the privacy notice and will be held by the Club for no more than 31 days at which point it will be automatically purged.
Changes to this policy
As RBFD and RBFC changes, this Privacy Policy is expected to change as well. We reserve the right to amend this Privacy Policy at any time, for any reason, without notice to you, other than the posting of the amended Privacy Policy on our websites. We may email periodic reminders of this Privacy Policy and will email relevant data subjects to notify them of any material changes. You should check our website frequently to see the current Privacy Policy that is in effect and any changes that may have been made to it.
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More information & complaints
Should you have any questions regarding this Privacy Policy or if you wish to make a complaint about how we process your personal information, please contact hello@rbfd.co.uk.
You are also able to make a complaint to the Information Commissioner’s Office (ICO) if you think your data protection rights have been breached in any way by us. You can do this by contacting the ICO at:
Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Tel: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number.
Alternatively, visit the ICO website or email icocasework@ico.org.uk.
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