Privacy Notice

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Iconic Football Academy Privacy Notice 20230524

This Privacy Notice is issued by ICONIC  GLOBAL SPORTS S.L. a company duly registered under the laws of Spain  with Company Registration Number B-13988977. The company operates under  the trade name "Iconic Football Academy" with the principal place of  business located at Avenida De Andalucía, 9, Benahavís 29679, Málaga,  Spain.  Iconic Football Academy is committed to  protecting your personal data and privacy. This document outlines how we  collect, use, and safeguard your information in accordance with  applicable laws and regulations.

Iconic Football Academy is committed to protecting the privacy and security of your personal data. ‘Personal data’ is essentially information from which an individual person can be identified. This privacy notice (“Notice”) describes how we collect and use personal information about you in a range of circumstances. You should read this Notice, together with any other privacy information which may be provided on the specific occasions when personal data about you is collected by Iconic Football Academy. This Notice supplements any other notices, and is not intended to override them. 

Iconic Football Academy organizes and administers certain competitions and events from time to time. References to “we”, “us” and “our” in this Notice are all references to Iconic Football Academy. Where personal data is collected for the purposes set out in this Notice, Iconic Football Academy will usually be a ‘data controller’ under data protection law applicable in the EU (“Data Protection Law”). That  means we decide the purposes and manner in which your data is used – as  set out in this Notice. Sometimes however, we may only be using your personal information as directed by other organizations in which case that organization will tell you why and how your data is used. Contact details for Iconic Football Academy Officer can be found in the “Who can you contact for further details?” section below.

This Notice does not apply where another privacy notice or policy of ours applies to your specific circumstances. This may include, for  example, in the circumstances set out in this section:-

Online

This Notice does NOT apply in relation to any data collected through  the Iconic Football Academy official website or associated Iconic Football Academy platforms, in which case the Iconic Football Privacy Policy (Website) will apply.

Job Applicants & Staff 

This Notice does NOT apply where you are applying for work with us, in which case the Candidate Privacy Policy will apply. A separate Staff Privacy Notice will apply.

We may collect, use, store and transfer different kinds of personal data about you. For the purpose of this Notice we have grouped these together as follows:

• Identity Data such as your name(s), title, date of  birth, gender, username, ID number or other similar identifier, your employer or education provider, job or role title, photographs and imagery (including CCTV if you visit our  premises) and marital status (where relevant).
• Contact Data such as your personal and/or work address(es), billing address (where different), email address(es),  preferred language, telephone numbers and any of the above for any parent, guardian, helper or other persons connected to you where applicable.
• Financial Data such as your bank account, PayPal account and/or card and other payment details.
• Transaction Data such as details about payments to and from you and other details of products, services, competitions, event  attendance and other opportunities you have purchased from or accessed or acquired through us (if any).
• Profile Data such as (where relevant) your personal  and/or corporate interests, qualifications, training or occupational experience, associated social media accounts, supported team and/or Club, any username and password we may allocate you for use of our  facilities, preferences, feedback and/or survey responses you provide. 
• Communications Data includes information you provide when communicating or meeting with us, history of your attendance and/or communication with us, and your preferences in receiving marketing or other communications from us and our affiliated third parties.
• Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be generated from your personal data but does not directly reveal your identity. However, if we combine or connect  Aggregated Data with your personal data so that it can directly identify you, we treat the combined data as personal data which will be used in  accordance with this Notice.

Special Categories of Personal Data  includes details about your race or ethnicity, religious or  philosophical beliefs, sex life, sexual orientation, political opinions,  trade union membership, information about your health and genetic and  bio-metric data. We generally limit our collection of this information –  see below for further information.

If you fail to provide personal data

Receipt of services, products, opportunities or fulfilment of other obligations we may owe to you might require you to provide specific types of information. Where you fail to provide that information, we may  not be able to enter or perform the relevant contract or specific obligation we have, or allow you to engage in the opportunity.

Children’s Data

We understand that children and young people, including those under 18 years of age (“minors”),  may interact with us. Minors may need their parent or guardian’s  permission to use or access certain facilities, opportunities or receive certain information from us. Minors may also be asked to confirm they have that permission, and we reserve the right to verify parental or  guardian consent, where required. We try not to make a minor's participation in activities with us contingent on the minor disclosing any more personal information than is reasonably necessary in order to do so. We do not actively market to  minors or use (or pass to any third party) personal information on  persons known to be minors for any commercial purposes, without proper consent. Other age restrictions may apply to certain products, services or opportunities we make available from time to time. 

We use different methods to collect data about you, including:

• Direct interactions. We may collect data when interacting with you or your organisation directly. For example, when you or your organization corresponds with us or fill in forms for  sending to us.
• Shared technologies or platforms. Sometimes your data may be contained in public shared platforms we are entitled to access. For example, those associated with football clubs may have their details uploaded, and members of the press or photographer details may be contained in shared industry databases for accreditation purposes.
• Football Clubs, Authorities & Organisations.  Other organisations in the football industry (including clubs, leagues, governing bodies, membership and collective interest bodies, equality, inclusion and not-for profit sporting organisations), may provide us with your details as part of ensuring proper governance and administration of the game. For example, personnel in the football industry may find their details are shared with us due to the nature of their role.
• Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below: 
  • Our sponsors and other commercial partners, including where required to administer prizes through promotions they run in the course of their partnership with us;
  • Our suppliers and service providers, including providers of technical, payment, delivery and fulfilment services;
  • Social media platforms and websites which are publicly available or through which you may interact with us;
  • Data brokers or aggregators such as those used for any credit reference or similar pre-service vetting facility (if any);
  • Corporate and other official databases, company registries;
  • Other information from lawfully available sources where relevant to our bringing, defending or assisting in legal action (such as the  police, regulators, investigators or other public interest organisations).  

We use information about you for the following purposes:

• Services, Products & Opportunities - to allow you to apply for and receive products, services, other opportunities, and fulfil any of our obligations for delivery of those. Likewise for receipt by us of any products, services or opportunities from you or your organisation.  Processing your data for this purpose will usually be necessary (i) to  perform any contract with you for the relevant service (ii) to comply  with legal obligations where applicable or (ii) for our and/or Iconic Football Academy legitimate interests in receiving deliverables pursuant to any commercial relationship with you or your organisation.
• Events & Competitions – in connection with your  accreditation or attendance at and/or fulfilment of obligations relating to relevant events we organise and other competitions we may administer from time to time. This may include fans, corporate attendees and/or  those requiring accreditation such as members of the press and/or photographers. This will usually be necessary (i) to perform any contract with you for your attendance or participation (ii) to comply  with legal obligations where applicable or (ii) for our and/or our  legitimate interests in ensuring proper and effective governance, regulation and administration of our events and competitions.
• Payments and Finance- to collect payments from you for any paid for products or services, opportunities and attendance at events, and/or administer any payments which may become due to you or  your organisation.  This will usually be necessary (i) to perform any  contract with you for the paid for service or (ii) to comply with legal  obligations where applicable or (iii) for our legitimate interests in recovering debts due to us.
• Publications and Announcements– to include you in relevant publications or announcements. For example, relevant staff of Iconic Football Academy will have their work contact details included in announcements and/or announcements. Academy players or member of their family may also be included in publications such as to promote you as a winner of promotions or surveys we or our commercial  partners run, or in relation to crowd photographs from our events. The  processing of your personal data here will usually be on the basis you have given permission or where necessary for our legitimate interests in  properly administering, developing and raising awareness of our services, events, competitions and operations, managing the relationship  between you or your organisation and us or our affiliates, and making any lawful press releases or announcements.
• Manage and Improve- to manage and improve our operations, including notifying you of applicable changes where required. This will usually be necessary (i) to perform any contract  with you (ii) to comply with legal obligations where applicable or (iii)  for our legitimate interests in managing our relationship with you or your organisation, improving our operations, and/or record keeping.
• Communications & Engagement- to communicate with  you where necessary, including dealing with queries, complaints,  meetings and other correspondence other than for marketing purposes (for  which, see below). This will usually be necessary (i) to perform any contract with you for applicable products or services (ii) to comply  with legal obligations where applicable or (iii) for our legitimate  interests in managing our relationship with you or your organisation,  improving our operations, and/or record keeping.
• Administration, Protection & Security- to  administer and protect our business and rights, and those of other associated third parties (whether organisations or individuals). This may include routine tasks such as data analysis (for example, checking event attendees against any banning list or order databases), system maintenance and support as well as more formal matters such as bringing, defending or assisting in legal action where necessary.  
• We take our obligations to safeguard vulnerable people seriously. We do this by collecting/accessing and analysing records of incidents and allegations of abuse, exploitation or inappropriate conduct, and preventative measures by reference to the law and our rules and regulations. We may collect and process personal data (including from public sources) without your knowledge where this is required and/ or permitted by law.
• We also operate CCTV at our office premises for security purposes (see below). Processing for these purposes will usually be necessary (i) for our legitimate interests in running our business and systems in a secure  manner, protecting rights and property (including intellectual  property), and preventing or tackling illegal activity or (ii) to comply  with a legal obligation.
• Marketing & Associated Profiling- to alert you to information about events, opportunities, surveys, competitions, offers, products, services and other updates relating to us, our and/or commercial partners. We only do this through email, SMS, or online direct messaging (such as using any direct private message facility i.e. social media messaging) where you have agreed, so this is on the basis of your consent. You can change your mind or adjust your preferences any time afterwards by emailing us at privacy@iconicfootballacademy.com We will also stop sending these in direct response to any other express communication from you asking to do so.We may use tools to measure the effectiveness of our communications, including whether you open, delete, or access links contained in the communications, and the browser, app or general device type used.
• Research, Analysis & Personalisation- to carry out  market research so that we can improve our operations, events and products, services and opportunities we offer, and in some circumstances personalise communications or facilities made available. Your feedback is valued and helps the regulatory and commercial strategy, marketing activity and initiatives across Iconic Football Academy. This will  usually be necessary for our legitimate interests to study how you engage with us, to develop our operations, grow our  business and to inform our strategies.

We may also process your personal data for other reasons, in compliance with the above rules, where this is required or permitted by law. Where we reasonably consider that we need to process your personal data for another reason that is compatible with the original  purpose set out in this Notice we will do so. If that is ever the case and you wish to get an explanation as to how processing for any new purpose is compatible with the original purpose, please contact us at privacy@iconicfootballacademy.com

If we need to use your personal data for an unrelated purpose, we  will notify you and explain the legal basis which allows us to do so. In  some circumstances, this may require your consent. In the occasional circumstances where we require special categories of personal data or that relating to criminal convictions, this will only be in accordance with Data Protection Law and therefore usually if:

• It is necessary for us to carry out our legal obligations.
• It is needed in the public interest.  For example, where it is necessary for the purposes of measures designed to protect the integrity of a sport or a sporting event, and/or prevention of unlawful acts.
• We have your explicit written consent.
• You have already made the information public.
• It is needed for administration of justice or in relation to legal claims.
• It is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent.

We may also collect special categories of personal data to be held in  an anonymised form detached from your other data so does not reveal  your identity. For example, if we carry our equal opportunities or  similar inclusion based surveys from time to time.

Regulated Persons Privacy Policy

This section applies to individuals whose personal data is processed as part of Iconic Football Academy’s regulatory functions. This includes football players, trialists, player family members, agents, managers, coaches, scouts, and staff members.

1. What Data We Collect:

As part of our regulatory functions, we may collect the following personal data:

• Identity Information: Full name, date of birth, nationality, and identification documents (e.g., passport, ID).
• Contact Information: Email address, phone number, and postal address.
• Performance Data: Training performance, match statistics, and video footage.
• Health Data: Medical assessments, injury records, and physiotherapy reports (processed with explicit consent or as required by law).
• Employment Data (Staff): Employment history, qualifications, and certifications.
• Agent and Manager Data: Licensing information and contact details.

2. Purpose of Data Processing:

We collect and process personal data for the following purposes:

• To comply with legal and regulatory obligations under football governing bodies.
• To evaluate and monitor player performance and eligibility.
• To provide medical support and ensure player health and safety.
• To manage contractual agreements (e.g., with players, agents, and staff).
• To support player development and career progression.

3. Legal Basis for Processing:

We process personal data under the following legal bases:

• Legal Obligation: To comply with regulations set by football governing bodies or employment laws.
• Contractual Necessity: To fulfill obligations under contracts with players, staff, or agents.
• Consent: For processing sensitive data like medical assessments or performance videos.

4. Data Sharing:

We may share regulated persons’ data with:

• Football governing bodies (e.g., federations, leagues) to comply with regulations.
• Medical professionals for health assessments and treatment.
• Scouts, clubs, or agents (with prior consent) to support career progression.
• Legal or regulatory authorities as required by law.

5. Data Retention:

We retain personal data for as long as necessary to fulfil regulatory requirements or as required by law.

6. Your Rights:

As a regulated person, you have the following rights under GDPR:

• Access: Request access to the personal data we hold about you.
• Correction: Request corrections to inaccurate or incomplete data.
• Objection: Object to data processing where applicable.
• Erasure: Request deletion of your data where it is no longer required.
• Data Portability: Request transfer of your data to another organisation.

To exercise your rights, please contact us at privacy@iconicfootballacademy.com 

In relation to any CCTV at our premises, visitors are  made aware of this by appropriate signage. Cameras are located in communal areas only where necessary for the above security purposes and  not in any area which would have a disproportionate intrusion on your privacy. Footage is subject to restricted access and personnel controls, stored on our secure systems.

How Do We Store Your Information And For How Long?

Location

We are committed to protecting the security of your personal data, which we hold in a secure centre in the European Economic Area (EEA). Some organisations to which we may disclose your personal information (only if authorised by yourself), may be situated outside of the EEA. Whenever we transfer your personal data out of the EEA, we take reasonable steps to ensure that your information is still properly protected. This may include safeguards such as checking the relevant countries have been deemed to provide an adequate level of protection for personal data by the European Commission. In relation to personal data sent to the US, we usually check whether the ‘Privacy Shield’ applies – that ensures a similar level of  protection to personal data shared within the EEA. 

Duration

We will keep the personal data you have provided only for as long as we reasonably require to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means. This is in addition to any applicable  legal requirements.Details of any specific retention periods for different aspects of your personal data are available on request by contacting us at privacy@iconicfootballacademy.com For legal reasons we may have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for up to seven years after they cease being customers – this is particularly for any paid for products or services.  In some circumstances you can ask us to delete your data: see the 'What Are Your Rights' section below for further information. We may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. 

Security

We have put in place appropriate operational, technical and security measures to reduce the risk of your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or  disclosed. There is a wide range of personal data that includes email addresses, location, mobile  numbers, identification numbers, etc. On our web forms, we mark fields as personal as this applies a higher degree of sensitivity to the data collected using the field and it exercises more control over how this data is processed. For instance, when one tries to export the data from the respective field or insert the data into an email, a warning will appear. Only after providing additional confirmation can the action be carried out. We also add an extra layer of security to the form respondents' data while it is stored, by enabling field-level encryption. Encrypting data protects your data from any possible data leak or unauthorised access. It is the process of encoding information to make it accessible only to the authorised parties. In addition, we limit access to your personal data to those employees, agents,  contractors and other third parties who have a business need to know. If we have cause to believe there are any suspected personal data breach, we will notify you and any applicable regulator of a breach where we are legally required to do so. If we have given you a password to access certain parts of the Online Facilities, you must keep the password safe and make sure you use a  secure browser. 

Use of CAPTCHA on Our Forms

We are committed  to protecting your personal information and ensuring your privacy. As  part of this commitment, we have implemented CAPTCHA technology on our  online forms to enhance security and prevent spam or automated submissions.

What is CAPTCHA?

CAPTCHA (Completely Automated Public Turing test to tell Computers and Humans Apart) is a security measure used to  verify that form submissions are made by a human and not by automated  bots. This helps us maintain the integrity and security of the  information submitted through our forms.

Data Collection and Usage

When you interact with our forms that use CAPTCHA, certain data may be collected to assess whether the user is human. This data can include, but is not limited to, IP addresses,  browser information, and user interactions with the CAPTCHA widget.

Your Privacy

We use this data solely for the purpose of securing our forms and preventing unauthorised access or spam. We do not  use this information for marketing purposes or share it with third  parties, except as required by law.

Your Consent

By using our forms, you consent to the collection and processing of data as outlined in this privacy notice. If  you have any questions or concerns about our use of CAPTCHA or your  privacy, please contact us at privacy@iconicfootballacademy.com  or to the Data Protection Officer, Iconic Football Academy, Avenida De Andalucía 9, BENAHAVÍS, 29679, Málaga, Spain

Who Do We Provide Your Information To?

We may disclose your information to third parties as follows:

• to third parties to whom we may choose to merge with, sell or transfer all or parts of our business or our assets (or businesses we may acquire). New owners of our business may use your personal data in the same way as set out in this Notice;
• to service providers who carry out some data processing activities on our behalf. For example, mailing services, payment processing, IT infrastructure, software and hosting, analytics, advertising delivery service providers, along with other relevant partners used to  help us deliver the Site to you. We do not allow our third-party service providers to use your  personal data for their own purposes unless they can otherwise lawfully do so;
• to our commercial partners or sponsors. For example, if required for prize or opportunity fulfilment in relation to promotions you engage with (but only for direct electronic marketing purposes where you have agreed to this);
• other organisations in the football industry where required for completion of the purposes set out in this Notice, such as other football leagues, clubs, governing bodies, and match venues. For example, if you enter a competition and win tickets to a match we may need to share details with the stadium or participating clubs, for ticket delivery and/or health and safety or other legal reasons;
• to professional advisers including lawyers, bankers, auditors and insurers where required for those parties to provide services to us;
• to law enforcement agencies, Courts or other dispute resolution  forums, or other legal or regulatory authorities if we are under a duty  to disclose or share your personal data to comply with any legal  obligation, or are enforcing or protecting our rights, or lawfully  co-operating in the protection of third party rights; and/or
• to any credit reference or similar pre-service or communication vetting agency (if any) for the purposes of fraud protection and credit risk reduction in relation to paid for services you request from us or assisting our compliance with lawful requirements.

We may have to share your personal data with the parties above for the purposes set out in the “What do we use your information for?” section of this Notice. In some circumstances, there may be other lawful  reasons for the third party to use your data in accordance with any privacy notice they make available to you. We may also provide anonymised Aggregated Data to third parties. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.

Use Of Images, Videos, And Media Content

At Iconic Football Academy, we are committed to respecting your privacy and protecting your personal data. This Privacy Notice outlines how we collect, use, and protect your information in compliance with the General Data Protection Regulation (GDPR) and the Data Protection Act 2018.

1. Use of Images and Media Content:

• We use a mix of images on our website and marketing materials, including: 
  • Photographs and videos taken during training sessions, matches, and events.
  • AI-generated images created specifically for promotional purposes.
  • Licensed, royalty-free images from authorised platforms like GoDaddy.

2. Consent for Media Usage:

• By participating in our programs, players and participants grant  permission for their photographs and videos to be used for marketing,  promotional, and educational purposes.
• Participants also agree to represent the academy as ambassadors, without any expectation of compensation.
• Consent is obtained during the registration process, and participants have the right to withdraw their consent at any time by  contacting us at privacy@iconicfootballacademy.com

3. Transparency and Attribution:

• All AI-generated and licensed images used on our platforms comply with the licensing terms of their respective sources.

4. Your Rights:

• You have the right to: 
  • Withdraw consent for the use of your images at any time.
  • Request access to your personal data, including images.
  • Request the removal of images from our marketing materials where applicable.

Who Can You Contact For Further Details?

Please include your name, address, and/or email address when you contact us. privacy@iconicfootballacademy.com  or to the Data Protection Officer, Iconic Football Academy, Avenida De Andalucía 9, BENAHAVÍS, 29679, Málaga, Spain

Will This Policy Change?

We like to ensure you we are up to date about our use of your personal data. If we update this Notice the changes will be posted on this page so you should check back from time to time.  This Notice was last updated on 24th May, 2023.