In general, any information and data which you provide to Footballers4Change over the Website, or which is otherwise gathered via the Website by Footballers4Change, in the context of the use of Footballers4Change’s services (“Services”) as better defined in the Section 3 below, will be processed by Footballers4Change in a lawful, fair and transparent manner. To this end, and as further described below, Footballers4Change takes into consideration internationally recognised principles governing the processing of personal data, such as purpose limitation, storage limitation, data minimisation, data quality and confidentiality.
- 1. Data controller and Data Protection Officer
To get in touch with Footballers4Change’s Data Protection Officer, please contact: info@Footballers4Change.com.
- Personal Data processed When you use the Website, Footballers4Change will collect and process information regarding you (as an individual) which allows you to be identified either by itself, or together with other information which has been collected. Footballers4Change may also be able to collect and process information regarding other persons in this same manner, if you choose to provide it to Footballers4Change.
This information may be classified as “Personal Data” and can be collected by Footballers4Change both when you choose to provide it (e.g., when you subscribe to the newsletter or request a test drive, in order to receive Footballers4Change’s Services) or simply by analysing your behaviour on the Website.
Personal Data which can be processed by Footballers4Change through the Website are as follows:a. Name, contact details and other Personal Data
In various sections of the Website – including, in particular, if you decide to create an account on the Website – you will be asked to submit information such as your name, phone / mobile numbers, e-mail address, date of birth, country of residence and address etc. When subscribing or signing up to receive Services, you might be asked to provide information as to your preferred mode of payment – PayPal, bank transfer or credit card.
In addition, whenever you participate in surveys and other promotions which may be available on the Website, as well as whenever you communicate with Footballers4Change through the contact details provided in the Website or with Customer Service, Footballers4Change may collect additional information which you choose to provide.b. Job applications
Certain areas of the Website (such as the form to request a test drive) include free text fields where you can provide Footballers4Change with some information or needs, which you may use to communicate Personal Data.
Where these fields are completely free, you may use them to disclose (inadvertently or not) more sensitive categories of Personal Data, such as data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership. The content you upload in these fields may also (inadvertently or not) include other types of sensitive information relating to you, such as your genetic data, biometric data or data concerning your health, sex life or sexual orientation.
Footballers4Change asks that you do not disclose any sensitive Personal Data on the Website, unless you consider this to be strictly necessary. As it is totally optional to provide this information, if you do, please mind that Footballers4Change needs your explicit consent to process on sort of Personal Data. Footballers4Change would stress the importance of providing your explicit consent to process this sort of Personal Data if you decide, nonetheless, to share it.d. Other persons’ Personal Data
As mentioned in the previous section, certain areas of the Website include free text fields where you can write messages to Footballers4Change. These messages may (inadvertently or not) include Personal Data related to other persons.
In any situation where you decide to share Personal Data related to other persons, you will be considered as an independent data controller regarding that Personal Data and must assume all inherent legal obligations and responsibilities. This means, among other things, that you must fully indemnify Footballers4Change against any complaints, claims or demands for compensation for damages which may arise from the processing of this Personal Data, brought by the third parties whose information you provide through the Website.
As Footballers4Change does not collect this information directly from these third parties (but rather collects them, indirectly, from you), you must make sure that you have these third parties’ consent before providing any information regarding them to Footballers4Change; if not, then you must make sure there is some other appropriate grounds on which you can rely to lawfully give Footballers4Change this information.e. Browsing data
The Website’s operation, as is standard with any websites on the Internet, involves the use of computer systems and software procedures, which collect information about the Website’s users as part of their routine operation. While Footballers4Change does not collect this information in order to link it to specific users, it is still possible to identify those users either directly via that information, or by using other information collected – as such, this information must also be considered Personal Data.
This information includes several parameters related to your operating system and IT environment, including your IP address, location (country), the domain names of your computer, the URI (Uniform Resource Identifier) addresses of resources you request on the Website, the time of requests made, the method used to submit requests to the server, the dimensions of the file obtained in response to a request, the numerical code indicating the status of the response sent by the server (successful, error, etc.), and so on.
These data are used to compile statistical information on the use of the Website, as well as to ensure its correct operation and identify any faults and/or abuse of the Website. Save from this last purpose, these data do not persist for more than 7 working days.f. Cookies
- Purposes of processing
Footballers4Change intends to use your Personal Data, collected through the Website, for the following purposes:
- To verify your identity and assist you, in case you lose or forget your login / password details for any of Footballers4Change’s registration services, to allow you to consult your purchase history, by maintaining a registered user profile, to send you Footballers4Change newsletter you subscribed for as a service and which contains only informative material, to send you any information you explicitly requested; to finalise your purchase order and deliver the products you may buy on the Website, to allow you to request a test drive, a price quote or any info you may ask for, to find the dealer next to you and to provide any other Services which you may request (“Service Provision”);
- For future marketing, promotional and publicity purposes, including to carry out direct marketing, market research and surveys, via e-mail, SMS, over the phone, banners instant messaging, through an operator, traditional mail, through Footballers4Change’s official social media pages, regarding Footballers4Change‘s products and services, as well as those of selected third parties (“Marketing”);
- For future marketing, promotional and publicity purposes, by sending you direct e-mail marketing communication regarding products and services similar to those you have purchased or requested through the use of the Website (“Soft Spam”);
- To create a profile of you as a Website user, through the use of profiling cookies and by collecting and analysing information on the preferences you select and choices you make in the Website, as well as your general activities on the Website. This profile will be used to give you information about other websites / services which Footballers4Change believes you may be interested in, and to show you information and advertisements which may be relevant to you and your interests. All algorithms involved in this processing are regularly tested, to ensure the processing’s fairness and control for bias (“Profiling”);
- For compliance with laws which impose upon Footballers4Change the collection and/or further processing of certain kinds of Personal Data (“Compliance”);
- To prevent and detect any misuse of the Website, or any fraudulent activities carried out through the Website (“Misuse/Fraud”).
- Grounds for processing and mandatory / discretionary nature of processing
Footballers4Change’s legal bases for processing your Personal Data, according to the purposes identified in Section 3, are as follows:
- Service Provision: processing for these purposes is necessary to provide the Services and, therefore, is necessary for the performance of a contract with you. It is not mandatory for you to give Footballers4Change your Personal Data for these purposes; however, if you do not, Footballers4Change will not be able to provide any Services to you
- Marketing: processing for these purposes is based on your consent. It is not mandatory for you to give consent to Footballers4Change for use of your Personal Data for these purposes, and you will suffer no consequence if you choose not to give it (aside from not being able to receive further marketing communications from Footballers4Change). Any consent given may also be withdrawn at a later stage (please see Section 8 for more information).
- Soft Spam: processing for this purpose is based on the interest of Footballers4Change of sending you direct e-mail marketing communication regarding products and services similar to those you have purchased through the use of the Website. You can block these communications, and you will suffer no consequence if you do so (aside from not being able to receive further communications from the Footballers4Change), by opposing through the link provided at the bottom of all such communications.
- Profiling: processing for this purpose is based on your consent collected by means of the banner cookie and/or with a specific tickbox. It is not mandatory for you to give consent to Footballers4Change for use of your Personal Data for this purpose, and you will suffer no consequence if you choose not to (aside from not being able to benefit from greater personalisation of your user experience regarding the Website). Any consent given may also be withdrawn at a later stage (please see Section 8 for more information).
- Compliance: processing for this purpose is necessary for Footballers4Change to comply with its legal obligations. When you provide any Personal Data to Footballers4Change, Footballers4Change must process it in accordance with the laws applicable to it, which may include retaining and reporting your Personal Data to official authorities for compliance with tax, customs or other legal obligations.
- Misuse/Fraud: Information collected for this purpose is used exclusively to prevent and detect fraudulent activities or misuse of the Website (for potentially criminal purposes).
- Recipients of Personal Data
Your Personal Data may be shared with the following list of persons / entities (“Recipients”):
- Persons, companies or professional firms providing Footballers4Change with advice and consultancy regarding accounting, administrative, legal, tax, financial and debt collection matters related to the provision of the Services and which act typically as data processors on behalf of Footballers4Change;
- Entities engaged in order to provide the Services (e.g., hosting providers or e-mail platform providers);
- Persons authorised to perform technical maintenance (including maintenance of network equipment and electronic communications networks);
- Persons authorised by Footballers4Change to process Personal Data needed to carry out activities strictly related to the provision of the Services, who have undertaken an obligation of confidentiality or are subject to an appropriate legal obligation of confidentiality (e.g., employees of Footballers4Change);
- Other companies within the Footballers4Change Group for internal administrative purposes, including the processing of clients’ or employees’ Personal Data; and
- Public entities, bodies or authorities to whom your Personal Data may be disclosed, in accordance with the applicable law or binding orders of those entities, bodies or authorities;
- Transfer of Personal Data
Considering Footballers4Change’s worldwide presence and business operations, your Personal Data may be transferred to Recipients located in several different countries. Footballers4Change implements appropriate safeguards to ensure the lawfulness and security of these Personal Data transfers, such as by relying on adequacy decisions from the European Commission, standard data protection clauses adopted by the European Commission, or other safeguards or conditions considered adequate to the transfer at hand. More information about it are available sending a written request to Footballers4Change at the following address: info@Footballers4Change.com.
- 7. Retention of Personal Data
Personal Data processed for Service Provision will be kept by Footballers4Change for the period deemed strictly necessary to fulfil such purposes – in any case, as these Personal Data are processed for the provision of the Services, Footballers4Change may continue to store this Personal Data for a longer period, as may be necessary to protect Footballers4Change’s interests related to potential liability related to the provision of the Services.
Personal Data processed for Marketing and Profiling will be kept by Footballers4Change from the moment you give consent until the moment you withdraw the consent given and renewed at fixed intervals. Once consent is withdrawn, Personal Data will no longer be used for these purposes, although it may still be kept by Footballers4Change, in particular as may be necessary to protect Footballers4Change’s interests related to potential liability related to this processing.
Personal Data processed for Soft Spam will be kept until you object to such processing by means of the link provided at the bottom of all such communications.
Personal Data processed for Compliance will be kept by Footballers4Change for the period required by the specific legal obligation or by the applicable law.
Personal Data processed for preventing Misuse/Fraud will be kept by Footballers4Change for as long as deemed strictly necessary to fulfil the purposes for which it was collected.
- Data subjects’ rights
Under the Regulation, you, as a data subject, are entitled to exercise the following rights before Footballers4Change, at any time:
- • Access your Personal Data being processed by Footballers4Change (and/or a copy of that Personal Data), as well as information on the processing of your Personal Data;
- • Correct or update your Personal Data processed by Footballers4Change, where it may be inaccurate or incomplete;
- • Request erasure of your Personal Data being processed by Footballers4Change, where you feel that the processing is unnecessary or otherwise unlawful;
- • Request the restriction of the processing of your Personal Data, where you feel that the Personal Data processed is inaccurate, unnecessary or unlawfully processed, or where you have objected to the processing;
- • Exercise your right to portability: the right to obtain a copy of your Personal Data provided to Footballers4Change, in a structured, commonly used and machine-readable format, as well as the transmission of that Personal Data to another data controller;
- • Object to the processing of your Personal Data, based on relevant grounds related to your particular situation, which you believe must prevent Footballers4Change from processing your Personal Data; or
- • Withdraw your consent to processing (for Marketing and Profiling).
Please note that most of the Personal Data you provide to Footballers4Change can be changed at any time, including your e-mail preferences, by accessing, where applicable, the user profile you can create on the Website. When requesting for the Services, you may have selected the means of communication through whom you desired the Marketing to be carried out (i.e. fax, phone, SMS, email, mail, social media). You may withdraw the consents for the Marketing through the different means of communication from the user profile, where applicable, by de-selecting the relevant options. You can also withdraw consent for Marketing via e-mail or object to Soft Spam by selecting the appropriate link included at the bottom of every e-mail message received. The same applies to the Footballers4Change newsletter you receive as a Service. Consent for Profiling via cookies may be withdrawn as described in Section 2.f or, if via tick box, by changing, at any time, the preferences of the user profile you can create on the Website. Aside from the above means, you can always exercise your rights described above by sending a written request to Footballers4Change at the following address: info@Footballers4Change.com. In any case, please note that, as a data subject, you are entitled to file a complaint with the competent supervisory authorities for the protection of Personal Data, if you believe that the processing of your Personal Data carried out through the Website is unlawful.