Privacy Policy (Website)

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Iconic Football Academy Privacy Policy (Website) 20230524

This Privacy Policy (Website), 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 is 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.

This privacy policy (“Policy”) describes the types of personal data collected by Iconic Football Academy, your use of this Iconic Football Academy website (“Site”), what happens to that personal data and your rights. ‘Personal data’ is essentially information from which an individual person can be identified. You should read this Policy together with any other privacy  information which may be provided on specific occasions when personal  data about you is collected on the Site. That will ensure you are fully aware of how and why we are using your data. This Policy supplements any other notices and is not intended to override them.

What Does This Policy Cover?

This Policy applies to personal data collected by Iconic Football Academy through your use of the Online Facilities.  Where personal data is collected and used for the purposes set out in this Policy, Iconic Football Academy are ‘data controllers’ under data protection law applicable in the EU (“Data Protection Law”).  You should read this Policy together with any other privacy information which may be provided on specific occasions when personal  data about you is collected on the Online Facilities. That will ensure you are fully aware of how and why we are using your data. This Privacy Policy supplements any other notices and is not intended to override them.

What Does This Policy NOT Cover?

Personal data you provide to third parties, other than through this Site.  This Policy applies to personal data collected by Iconic Football Academy through your use of the Site.

Offline

This Policy does NOT apply in relation to any data you provide to Iconic Football Academy through offline scenarios separate from the Site, such as unrelated telephone inquiries or in person. For your  offline interactions with Iconic Football Academy, please see the Iconic Football Academy Privacy Notice.

Links to Third Party Websites and Services

We are not responsible or liable for the content, privacy notices or services offered by websites or apps other than the Iconic Football Academy Site. We encourage you to read those notices.This includes websites and apps which link from any of the Site.

What Information Do We Collect?

Information which identifies you, contact information, financial or transactional information, technical and profile data, information about how you use the Online Facilities, and/or preferences you have notified to us. We may collect, use, store and transfer different kinds of personal data about you. For the purpose of this Policy we have grouped these together as follows:

• Identity Data such as your name(s),  username or similar identifier, marital status, title, date of birth, gender and job title (if  relevant).
• Contact Data such as your address, billing address (where different), email address, preferred language and telephone numbers.
• Financial Data such as your bank account, PayPal account and/or payment card details.
• Transaction Data such as details about payments to and from you and other details of products or services you  have purchased from us or accessed on the Online Facilities.
• Technical Data such as your internet  protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types versions and statuses,  operating system and platform and other technology on the devices you  use to access the Online Facilities. The Online Facilities use cookies,  which are small files with a code that is stored on your device, with  your consent, and is retrieved when you next visit the Online Facilities. This allows information about your use and browsing  to be recognized.   
• Profile Data such as your username and password, associated social media accounts, supported team or Club, your interests, preferences, posts or comments on interactive  features (if any), feedback and/or survey responses.
• Usage Data such as information about how you use the Online Facilities and services provided through them  (including newsletters and marketing emails, and advertisements). This may include information about page views, length  of visit or use and exit route, timing, frequency and patterns of your use, along with navigation paths when using the Online Facilities – this  information does not directly identify you. We use various tools to help us with this, including Google Analytics. Where you have subscribed to receive the newsletter or marketing emails we will also receive information about whether you open, delete, or access links contained in the newsletter,  the browser or app type used and whether opened via mobile or desktop.
• Communications Data includes information you provide when communicating with us, your preferences in receiving  marketing from us and our third parties (where relevant), and any other communication preferences.
• 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 Policy.
• 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 do not collect this information, and where we do it is held in an anonymized form detached from your other data so it does not reveal your identity. We do  not collect any information about criminal convictions and offences.

Use Of Images, Videos, And Media Content

1. This Privacy Policy explains how Iconic Football Academy uses images and media content in compliance with the General Data Protection Regulation (GDPR) and the Data Protection Act 2018.
 

2. Types of Images Used:
 

• Photographs and Videos: 
  • We capture photographs and videos of players during training, matches, and events for promotional and educational purposes.
  • Consent for using such media is obtained during the registration process.
• AI-Generated Images: 
  • We sometimes use AI-generated images for promotional purposes. These images  are created using platforms that comply with commercial licensing terms.
• Licensed Images: 
  • We use royalty-free images from authorised platforms such as GoDaddy, ensuring compliance with their licensing agreements.

3. Consent for Media Usage:
 

• By participating in our programmes, 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.
• Participants have the right to withdraw their consent for the use of their photographs or videos at any time by contacting us at privacy@iconicfootballacademy.com

4. Legal Basis for Processing Images:
 

• Consent: 
  • For photographs and videos of identifiable individuals, we rely on explicit consent obtained during registration.
• Legitimate Interest: 
  • For AI-generated or licensed images, we ensure they are used in line with our legitimate interest to promote our academy while complying with licensing terms.

5. Transparency and Attribution:
 

• All images used on our website, social media, and marketing materials are either: 
  • Owned by Iconic Football Academy.
  • AI-generated under appropriate licensing.
  • Licensed from royalty-free platforms like GoDaddy.

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

If You Fail To Provide Personal Data?

Use of services accessed through the Online Facilities may require you to provide specific types of information. Where you fail to provide that information, we may not be able to perform the contract we have or are trying to enter into with you. For example, we may not be able to provide you with access to the football programme due to not giving us any medical information (any unknown medical history could potentially put you at risk if you have an underlying condition or previous injury that could do you harm).

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. 

How Do We Collect Your Personal Data?

Through direct interactions with you or your use of the Online Facilities, automated technologies, relevant third parties and publicly available sources such as social media platforms.

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

• Direct interactions. You  may give us your Identity, Contact, Financial, Communication and certain Profile Data by filling in forms or by corresponding with us using contact details we provide on the Online Facilities. This includes, amongst other things, personal data you provide when you, for example, request a newsletter subscription, participate in interactive features including any competition, promotion, survey, or give us feedback. 
• Automated technologies or interactions. As  you interact with the Online Facilities, Technical & Usage Data about your equipment, browsing actions and patterns may also be  collected or generated, along with Profile and Communications Data. We  collect this personal data by using cookies, server logs and other  similar technologies. We do not receive data from other websites you visit. Please see our cookie policy for further details. Other websites may use cookies which activate beyond  their websites, including when you use the Online Facilities (you should  check the cookies policy of those websites in those instances).
• Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below: 
  • Technical & Usage Data from parties such as our analytics  providers (including Google), and advertising networks (see below); 
  • Identity, Contact, Profile, Financial, Transaction, Usage and  Technical Data from providers of technical, payment and delivery  services;
  • Identity, Contact, Profile, Usage and/or Technical Data from social media platforms which are publicly available or through which you may log in or interact with the Online Facilities; 
  • Identity, Financial and/or Contact Data from data brokers or aggregators, such as those used for any credit reference or similar pre-service vetting facility (if any); and
  • Information from lawfully available sources where relevant to our bringing, defending or assisting in legal action (such as the police, regulators, investigators or publicly available sources). 

We may also supplement the information collected with other  information that we obtain from our dealings with you or which we receive from other organisations.

What Do We Use Your Personal Information For?

We use information about you for the following purposes:

• Services, Products & Opportunities-  To allow you to register an account or otherwise receive products, services and other opportunities (such as subscribe to a newsletter), and fulfil any of our obligations for delivery of those.  Automated processes may assess your eligibility to receive services based on the information you provide - if you think that process has incorrectly refused you a subscription, let us know why and we will review it.  Processing your data for this purpose will usually be necessary (i) to perform any contract with you for the relevant service where applicable (ii) to comply with legal obligations where applicable or (iii) otherwise, for our legitimate interests in complying with third party requirements which enable us to provide the service(s).
• Payments and Finance- to collect payments from you for any paid for products or services, and/or administer any payments which may become due to you.  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.
• Participation and Interactive Features (if any)-  to enable you to participate in chat rooms, forums, message boards, and/or news groups on or associated with the Online Facilities on which you may have the possibility to post information (if any) and, where we deem necessary, to  respond to any such posts you make. Information you post in these areas may become public information and must always comply with our Terms Of Use (in relation to the official website www.iconicfootballacademy.com and a copy can be found on that website). The processing of your personal data here will usually be necessary (i) to perform any contract with you for the relevant service or (ii) for our legitimate interests in  running and improving our services and managing our relationship with you as a customer.
• Publications– to include you in relevant publications, such as where you win a promotion we or one of our commercial partners carry out. We will usually ask you for permission in  these circumstances.  
• Manage and Improve- to manage and improve the Online Facilities, notify you of applicable changes where required and allow you to use the features offered by the Online Facilities. This  will usually be necessary (i) to perform any contract with you where  relevant for applicable services (ii) to comply with legal obligations  where applicable or (iii) otherwise, for our legitimate interests in managing our relationship with you as a customer, improving our service, and/or record keeping. 
• Communications- to communicate with you where necessary for purposes other than marketing. This will usually be  necessary (i) to perform any contract with you for applicable services where relevant (ii) to comply with legal obligations where applicable or  (iii) otherwise, for our legitimate interests in managing our relationship with you as a customer, improving our service, and/or record keeping.
• Administer and Protect- to administer and protect our business, the Online Facilities, and rights of ourselves or other associated third parties (including those of other users and  partners). This may include routine tasks such as troubleshooting, data  analysis, testing, system maintenance and support as well as more formal  matters such as bringing, defending or assisting in legal action where necessary.  This will usually be necessary (i) for our legitimate interests in running our business and systems in a secure manner,  business restructuring, protecting our rights and property (including  intellectual property) and preventing or tackling illegal activity or  (b) to comply with a legal obligation where applicable.
• Marketing & Associated Profiling- to alert you to information about events, surveys, competitions, offers,  products, services and other updates relating to us, and/or commercial partners. We only do this through email, SMS, or online direct messaging (such as using any private message facility on website or as may be permitted on associated social media platforms) where you have agreed, so this is on the basis of your consent. However, if you are an existing customer we may contact you about our products or services similar to those you have  previously received or inquired about (unless you have chosen not to  receive such communications). You can change your mind or adjust your preferences any time afterwards by emailing us at privacy@iconicfootballacademy.com We may measure the effectiveness of our communications, including Usage Data relating to  newsletters and other marketing emails as set out in the 'What Information Do We Collect' section above. We also use tools to help us and our advertising network make  relevant advertising available to you when you use the Online Facilities and our associate social media platforms (including facilities made available for this purpose by Facebook), and  measure how effective that advertising is. To do this we rely on cookies, which may include codes associated with your device but do not themselves identify you by name. Information which cookies we use is available in our Cookies policy, with guidance about how you can set your browser to refuse all or some cookies. This type of bespoke advertising (and any postal marketing) is carried out  on the basis it is necessary for the legitimate interests of us or applicable commercial partners in marketing relevant products, services or offers. 
• Email Marketing Consent- By signing up via our forms or providing your email address, you consent to receive marketing emails from Iconic Football Academy. These emails may include updates about our programmes, offers, and academy news. You can withdraw your consent at any time by clicking the "unsubscribe" link  in our emails or contacting us at privacy@iconicfootballacademy.com.
• Research, Analysis & Personalisation-  To carry out market research so that we can improve the products and services we offer, and in some circumstances personalise content (including advertising as mentioned earlier), delivered to you. Your feedback is valued and helps to inform the commercial strategy, marketing activity and initiatives within Iconic Football Academy. This will usually be necessary for our legitimate interests to study how customers use our products/services, to develop them, to grow our business and to inform our commercial and marketing strategy. 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 Policy 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 we will explain the legal basis which allows us to  do so. In some circumstances, this may require your consent.

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 fulfil 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. 

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 Policy;
• 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 Policy, 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 Policy. 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.

What Are Your Rights?

Under the Data Protection Laws you may have the following rights in relation to your personal data in certain circumstances: 

• Request Access: (also known as a "data subject access request"). You can receive a copy of the personal data we hold about you.
• Request Correction: You can have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of new data you provide.
• Request Deletion: You can ask us to delete  or remove personal data in certain circumstances, for example where:  there is no good reason for us continuing to process it; you have  successfully exercised your right to object to processing (below); or  where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
• Object to Processing of your personal data: this applies where: we are relying on a legitimate interest or those of a third party (see the 'What Do We Use Your Personal Data For?' section above),  and you feel our processing on this ground impacts your fundamental rights; or where we are processing your personal data for direct marketing purposes.
• Request Restriction of Processing: you can  ask us to suspend processing of your personal data where: you want us to establish the data accuracy; our use of the data is unlawful but you do not want us to erase it; where you need us to hold the data even  if we no longer require it as you need it to establish, exercise or  defend legal claims; or you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request Transfer: you can ask us to  provide to you, or a third party of your choice, your personal data. This right only applies to information which: you initially provided consent for us to use your data, or you provided and we used the information to perform a contract with you (see 'What Do We Use Your Personal Data For' section above).
• Right to withdraw consent;. This only applies where we are relying on consent to process your personal data (see 'What Do We Use Your Personal Data For' section above). If you withdraw your consent, we may not be able to  provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. All requests set out in this section or other queries relating to this Policy should be addressed to privacy@iconicfootballacademy.com  See 'Who Can You Contact For Further Details?' section below. Please note we may not always be able to comply with your request due to our legitimate interests or other legal reasons. If applicable, these will be notified to you in response to a relevant request.

You will not usually have to pay a fee to exercise any of the above rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive (or we may refuse to comply with your request in these circumstances). For security reasons, we may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). We may also ask you for further information in relation to your request. We will always try to help with any concerns so ask that you contact us in the first instance.

Who Can You Contact For Further Details?

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

How to Exercise Your Rights:
To exercise any of the rights listed above or for queries related to this policy, please contact us at privacy@iconicfootballacademy.com.

• We aim to respond to all valid requests within 30 days of receipt.
• In some cases, it may take longer if your request is particularly  complex or if you have made multiple requests. If this happens, we will  notify you and keep you updated on the progress.

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 policy it will be posted on this page so you should check back from time to time.  This Policy was last updated on 01st January, 2025.