Our whole business revolves around fans and clubs. Data is central to this and we know first hand how important it is. We take your privacy and information seriously if you choose to share it with us.
Fanbase is: Pintxos Brothers Ltd Trading as Fanbase. We have our registered office at 44 Charlotte Square Edinburgh, EH2 4HQ United Kingdom. Our registration number is SC514573.
Welcome to Fanbase’s Privacy Notice.
Fanbase respects your privacy and is committed to protecting your personal data. This Privacy Notice will inform you as to how we look after your personal data when you use our app or visit our website (regardless of where you visit it from), and tell you about your privacy rights and how the law protects you.
Summary of how we use your data
· Fanbase uses your data to provide you with its app and website, including to connect you with our partnered sports bodies and allowing you to make purchases from these partners. Some of this data will be provided by you, and other data may be generated or provided by third parties
· Data is shared with our partnered sports bodies when you connect with their page on the app or website.
· Where we rely on your consent, such as for placing cookies or similar technologies or for contacting you for marketing purposes, you can withdraw this consent at any time.
· Our full Privacy Notice below set out the full details of this processing, including details of your data protection rights, including your right to object to certain processing.
1. Important information and who we are
Purpose of this privacy notice
This Privacy Notice sets out how Fanbase collects and processes your personal data through your use of our app and website, including any data you provide when you sign up to our app or sign up to receive special offers by email.
Our app and website is not intended for children aged under 13 and we do not knowingly collect data relating to children.
It is important that you read this Privacy Notice so that you are fully aware of how and why we are using your data and of your data protection rights. This Privacy Notice should be read together with our Website Terms & Conditions and our User Term & Conditions.
Controller and Third Party Links
Fanbase is the controller and is responsible for your personal data (collectively referred to as Fanbase, “we”, “us” or “our” in this Privacy Notice). Please note that our website and app may include links to third-party websites, plugins and applications. Clicking on those links (for example, a link to a Partner, Facebook or Instagram) may allow third parties to collect data about you. You can also choose to log into Fanbase using social media accounts, in which case we will gain access to basic information you share with those social media companies. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice on every website you visit.
Changes to the privacy notice
This version was last updated on 27 June 2019 and any historic versions are available on request. We may make changes to this Privacy Notice from time to time and, if appropriate, will notify you by email regarding changes. It is important that the personal data we hold about you is accurate and current. We would ask that you keep us informed if your personal data changes during your relationship with us.
2. The data we collect about you
We do not collect any Special Categories of Personal Data about you ( i.e details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health or genetic or uniquely identifying biometric data). Nor do we collect any information about criminal convictions and offences.
Mandatory personal data
Where we have indicated that we need to you provide certain information within our website or app, we may not be able to provide the Fanbase services if you fail to provide that data when requested. In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time. Other information is optional, such as details of your preferences, but if you do not provide this then we may not be able to provide you with certain aspects of the services.
4. How we use your personal data
We use, or process, your personal data for the following purposes:
• To fulfil a contract, or take steps linked to a contract: this is relevant where you register for the Fanbase services or enter a competition we run. This includes:
· taking payments on behalf of our Partners through our vendor, Stripe
· administering our relationship and contractual services;
· communicating with you;
· providing customer services and arranging the delivery of prizes or services;
· As required by Fanbase to conduct our business and pursue our legitimate interests, in particular:
· we will use your information to provide products and services you have requested, and respond to any comments or complaints you may send us;
· we monitor use of our websites, apps and online services, and use your information to help us monitor, improve and protect our products, content, services and websites, both online and offline and to moderate any social features of the website and app;
· we use information you provide to personalise our website, apps, products or services for you;
· we use information you provide to investigate any complaints received from you or from others, about our website, app or our products or services;
· we will use information to undertake direct marketing where consent is not required (for example, through social media or behavioural advertising)
· we will use data in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation); and
· we use data of some individuals to invite them to take part in market research;
· Where you give us consent:
· we will send you direct marketing in relation to products and services provided by us and Partners.
· we place cookies and use similar technologies in accordance with our Cookies Policy and the information provided to you when those technologies are used
· on other occasions where we ask you for consent, we will use the data for the purpose which we explain at that time.
· For purposes which are required by law, such as in response to requests by government or law enforcement authorities conducting an investigation.
Withdrawing consent or otherwise objecting to direct marketing
Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests. You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by following the instructions in the communication where this is an electronic message, or by contacting us using the details set out below.
When you visit one of our websites, we may also collect, process and use information about you and your use of the website, including any forums you visit and how you arrived at our site. Such information may be collected through "traffic data" and may entail the use of "cookies" or other tracking technologies, IP Addresses or other numeric codes used to identify your computer. When we send you emails we may include “single pixel gifs” to help us to track information like if, and when, you open an email from us.
Apple iOS, Android and other mobile or smart devices
By accessing our app from these devices you consent to cookies being stored to your device (and other tracking technologies being used to read data from your device) for the following purposes: keeping you logged in, ensuring that an appropriate version of content is presented, analytics and advertising. Many of these cookies and technologies are essential to the operation of the application. It is not currently possible to opt out or remove these cookies (or prevent use of these technologies) from the device without deleting the application.
For more information on cookies, please see our Cookies Policy.
5. Disclosures of your personal data and data transfer
Fanbase shares information with its partners, who are given access to data received in relation to Fanbase users of their [section?] through an access portal on the Fanbase solution] [add in detail on the partners' purposes of use and what will happen if a partner withdraws].
Personal data will also be shared with third party service providers, who will process it on behalf of Fanbase for the purposes identified above. In particular, we use third party providers of website design and hosting, mailing and marketing services, web chat functionality, payment processing and payment card storage. We also use third party analytical tools, which process your data to help us get better insights into our users and allow us to improve our services and promotions.
We may also share your personal data with third parties to whom we may choose to sell, transfer, or merge parts of our business or assets with. Alternatively, we may seek to acquire other businesses to merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Notice.
Personal data may be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable laws.
Some of our suppliers are located in the United States [and other countries outside the UK and EEA]. Where information is transferred outside the United Kingdom or EEA, and where this is to a stakeholder or vendor in a country that is not subject to a valid adequacy decision, data is adequately protected by approved standard contractual clauses, an appropriate Privacy Shield certification or a vendor's Processor Binding Corporate Rules. A copy of the relevant mechanism can be provided for your review on request using the contact details set out below.
8. Data Retention
We will only retain your personal data for as long as necessary 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 personal data, the potential 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, and the applicable legal requirements.
In some circumstances we may anonymise your personal data (so 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.
9. Your legal rights
You have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share (port) this data to another controller.
In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are included in both the GDPR and in local laws, such as the Data Protection Act 2018. We will inform you of relevant exemptions we rely upon when responding to any request you make.
To exercise any of these rights, or to obtain other information, such as a copy of a legitimate interests balancing test, you can get in touch with us using the details set out below. If you have unresolved concerns, you have the right to complain to an EU data protection authority where you live, work or where you believe a breach may have occurred. This is likely to be the Information Commissioner in the UK.
If you wish to exercise any of these rights, please contact our Data Protection Manager at the contact details set out below.
What we may need from you
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). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
How do I get in touch with you?
We hope that we can satisfy queries you may have about the way we process your data. If you have any questions or concerns about how we process your data, or would like to opt out of direct marketing, you can get in touch at [email] or [address]. [Any other way of expressing preferences worth mentioning, like a preference centre?]