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WBA PRIVACY POLICY

INTRODUCTION

WBA respects your privacy and is committed to protecting your personal data. This privacy policy informs you on what personal data we collect and explains your privacy rights and how to contact us.

This privacy policy is applicable to any personal data which is given by you to us through the following websites: shop.wba.co.uk; wbatickets.co.uk and wbacommercial.co.uk (the “Websites”), post, email, fax, telephone, mobile messaging, face-to-face, online forms, competitions and surveys, social media (together the “Collection Methods”). However, it does not apply to personal data you provide via the official Club website (www.wba.co.uk) or via the official Club mobile application – each have a separate privacy policy governing the use and protection of any personal data you provide via those channels.

1.IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY POLICY

This privacy policy explains how WBA collects and processes your personal data when you provide it via any of the Collection Methods. It also explains the steps we take to ensure personal data is kept secure.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

WHO WE ARE

West Bromwich Albion Football Club Limited (Company Number 3295063) (the “Club”) with a registered address of The Hawthorns, Halfords Lane, West Bromwich, West Midlands B71 4LF.

The Club is part of a group of companies, specifically:

WBA Holdings Limited (Company Number 08528749)

WBA Group Limited (Company Number 07230595)

This privacy policy is issued on behalf of the Club and the group companies listed above so when we mention the Club, “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in the WBA Group responsible for processing your data.

CONTACT DETAILS

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

Full name of legal entity: West Bromwich Albion Football Club Limited

Email address: dataprotection@wbafc.co.uk

Postal address: West Bromwich Albion Football Club, The Hawthorns, Halfords Lane, West Bromwich, West Midlands B71 4LF

We would appreciate the chance to deal with your concerns; however, if you feel we have not processed your data fairly or you are not satisfied with how we have handled your personal data, you can contact the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).

THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. We have no responsibility or liability for the content or activities of these linked sites. When you leave our website, we encourage you to read the privacy policy of every website you visit.

CHILDREN’S DATA

We understand that children and young people, including those under 13 years of age (“minors”), may visit the Websites or otherwise interact with us. Minors may need their parent or guardian’s permission to use or access certain facilities or receive certain information through the Websites. 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 reasonable 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 available through our Websites or otherwise.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, maiden name, last name, username or similar identifier, title, date of birth and gender.

Contact Data includes billing address, delivery address, email address and telephone numbers.

Financial Data includes bank account and payment card details.

Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

Usage Data includes information about how you use our website, products and services.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We may record details of any disability or health needs you may have at the time of booking an event or service to help us make reasonable adjustments for you and to ensure your safety.

We may process information about criminal convictions, where this is necessary for public order and the prevention of crime, and there are adequate protections in place.

When you visit our stadium, offices or other premises we may collect CCTV images including for the purposes of public order and the prevention of crime.

We may monitor and record telephone calls for security and training purposes and to improve the quality of services provided by the Club.

IF YOU CHOOSE NOT TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you decide not to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us through the Collection Methods. This includes personal data you provide when you:

   •apply for our products or services;

   •create an account on our website;

   •subscribe to our service or publications;

   •request marketing or other information to be sent to you;

   •enter a competition, promotion or survey; or

   •give us feedback or contact us.

Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources, for example credit reference agencies, the Electoral Register, Companies House, the Government, public bodies, local authorities, the Police, data agencies. We may also use specialist data providers to assist with reviewing, segmenting and correcting the data we hold, to make sure it remains accurate and up to date and identify data that we no longer need to retain.

4.HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Where we have your consent to do so.

Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data.

We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

 

 

To register you as a new customer and to create an individual

(a) Identity

profile for you so that we understand your preferences and

 

provide you with a personalised browsing experience

(b) Contact

 

(c) Transaction

 

(d) Technical

 

(e) Usage

 

 

To process, administer and deliver your order including:

(a) Identity

(a) Manage payments, fees and charges

(b) Contact

(b) Collect and recover money owed to us

(c) Financial

(c) Communicate with you during the period of order and

(d) Transaction

delivery of the relevant product or service ordered

 

 

(e) Marketing and Communications

(d) introduce you to finance and credit product providers

 

 

 

To manage our relationship with you which will include:

(a) Identity

(a) Notifying you about changes to our terms or privacy policy

(b) Contact

(b) Asking you to leave a review or take a survey

(c) Profile

 

(d) Marketing and Communications

 

 

To enable you to partake in a prize draw, competition or

(a) Identity

complete a survey

 

 

(b) Contact

 

(c) Profile

 

(d) Usage

 

(e) Marketing and Communications

 

 

To administer and protect our business and this website

(a) Identity

(including troubleshooting, data analysis, testing, system

 

maintenance, support, reporting and hosting of data)

(b) Contact

 

(c) Technical

 

 

To deliver relevant website content and advertisements to

(a) Identity

you and measure or understand the effectiveness of the

 

advertising we serve to you

(b) Contact

 

(c) Profile

 

(d) Usage

 

(e) Marketing and Communications

 

(f) Technical

 

 

To carry out market research and or use data analytics to

(a) Technical

improve our website, products/services, marketing, customer

 

relationships and experiences

 

 

 

(b) Usage

 

 

To alert you to information about events, surveys,

(a) Identity

competitions, offers, products, services and other exciting

 

 

updates relating to us, and/or commercial partners

(b) Contact

 

(c) Technical

 

(d) Usage

 

(e) Profile

 

(f) Marketing and Communications

 

 

 

To inform you of club news, signing, ticket availability and

(a)

Identity

occasional offerings from the Club’s sponsors

 

 

 

(b)

Contact

 

(c)

Profile

 

(d)

Marketing and Communications

 

 

If you apply for a job with us, to process your job application

(a) Identity

 

(b) Contact

 

 

 

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You can update your preferences at any time via https://wba-portal-test.azurewebsites.net/login.aspx or via the option to do so as included in each marketing email sent to you by the Club.

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You may receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

OPTING OUT

You can ask us or third parties you have consented to have your personal data shared with through us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time by emailing dataprotection@wbafc.co.uk .

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

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.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. WHO DO WE PROVIDE YOUR INFORMATION TO?

We may disclose your information to third parties as follows:

to other companies within our corporate group, including WBA Holdings Limited (Company Number 08528749) and WBA Group Limited (Company Number 07230595).

in order to provide our products and services to you or to otherwise fulfil contractual obligations that we have with you, we may need to appoint other third party organisations to carry out some of the data processing activities on our behalf. These may include but without limitation, payment processing organisations, delivery organisations, fraud prevention and screening and credit risk management companies, police authorities and mailing houses.

to third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or 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 policy.

with advertising networks and/or social media platforms for the purposes of selecting and serving relevant adverts to you via those networks/platforms, and to search engine and analytics providers.

with third parties (a) if we are under a legal or regulatory duty to do so, (b) if it is necessary to do so to enforce our terms of use or other contractual rights, (c) to lawfully assist the police or security services with the prevention and detection of crime, anti-social behaviour and/or terrorist activity, (d) where such disclosure is necessary to protect the safety or security of any persons, (e) Courts or other dispute resolution forums, or other legal or regulatory authority 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 cooperating in the protection of third party rights (f) that offer finance products where you have indicated that you wish to apply for a finance product supplied by one of those third parties and/or (g) otherwise as permitted under applicable law.

with our selected partners (as may change from time to time) but we will only do this if you have consented to receive marketing relating to our sponsors and partners.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

6.TRANSFER OF DATA OUTSIDE OF THE EEA

Some organisations to which we may disclose your personal information 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, or using contractual provisions to ensure your information is properly protected.

7. DATA SECURITY

We take the security of your personal information seriously and take steps (including the implementation of appropriate technical and organisational measures) to ensure your personal information is treated securely and in accordance with this privacy policy.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

When you place orders or access your personal information through the Websites, this will be through a secure server. All sensitive/credit information you supply shall be encrypted into our databases.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Websites or apps, you are responsible for keeping this password confidential. Please do not share your password with anyone.

8. HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, and the applicable legal, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are available on your request by contacting us.

In some circumstances we will 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.

9. UPDATING YOUR INFORMATION

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

On receiving your request to update your personal information, we will use commercially reasonable efforts to update or delete your personal information as requested. However, it may not be possible to delete an entry without some delay and without retaining some residual personal information which we may need for legal, tax or audit purposes and in addition for ensuring that we suppress your information from any further communication if this is what you have requested.

10. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have a right to ask us for a copy of the information we hold about you. You can also ask us to correct or update your personal data, or to erase it or transfer it to a third party. You can object to processing of your personal information by us. Where we are using your information based on your consent you can withdraw your consent at any time.

If you wish to exercise any of the rights set out above, please email us at dataprotection@wbafc.co.uk.

FEE, INFORMATION REQUIRED AND TIME LIMITS

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

For security reasons, we may need to request specific information from you to help us to 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 try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We keep our privacy policy under regular review. This version was last updated on 20 November 2019.

Changes to how we use your information and this privacy policy will be published on this page, so you should check back regularly. If we are making a significant change to how we will be using your information we will normally contact you to let you know.