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Privacy notice

Iconic Football Academy Privacy Notice

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, if you are successful.

Players & Regulated Persons

This Notice does NOT apply where we process your personal data as part of our regulatory function if you are a football player, player family member, agent, manager, trialist, coach, scout, or member of staff for Iconic Football Academy. Where we are processing your personal data as part of our regulatory function, the Iconic Football Academy 'Regulated Persons Privacy Policy' 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 fulfillment 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 organization 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 & Organizations. Other organizations in the football industry (including clubs, leagues, governing bodies, membership and collective interest bodies, equality, inclusion and not-for profit sporting organizations), 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 fulfillment 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 organizations).

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 fulfill any of our obligations for delivery of those. Likewise for receipt by us of any products, services or opportunities from you or your organization. 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 organization.
Events & Competitions – in connection with your accreditation or attendance at and/or fulfillment of obligations relating to relevant events we organize 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 organization. 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 organization 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 organization, 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 organization, 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 organizations 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 analyzing 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 & Personalization- to carry out market research so that we can improve our operations, events and products, services and opportunities we offer, and in some circumstances personalize 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 anonymized 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.

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 organizations to which we may disclose your personal information (only if authorized 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 unauthorized 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 anonymize 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 unauthorized 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 unauthorized access. It is the process of encoding information to make it accessible only to the authorized 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.

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 fulfillment in relation to promotions you engage with (but only for direct electronic marketing purposes where you have agreed to this);
other organizations 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 anonymized Aggregated Data to third parties. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.

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, 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 we will notify you, unless the changes are minor. Minor changes will be posted on this page so you should check back from time to time. Significant changes will be notified to you. This Notice was last updated on 24th May, 2023.

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