Privacy Policy
In this Privacy Policy, terms such as "we", "us, "our" or similar expressions shall mean the Premier League Charitable Fund (PLCF).
We take your privacy very seriously and are committed to protecting your personal data (meaning any information about you from which you can be identified). This Privacy policy explains what personal data we collect when you: access https://plprimarystars.com or contact or engage with the Premier League Primary Stars on social media platforms (including our Facebook, Twitter and Instagram pages) (the Services); and/or when you otherwise interact or communicate with us. It also explains how we may use this data, and what rights you have in relation to such data.
Premier League Primary Stars (PLPS) is funded and delivered by The Football Association Premier League Limited (PL) and the PLCF. The PL and PLCF aim to be transparent about the way we collect and process personal data. This website is managed by the PLCF.
If you have any questions about this Privacy Notice and our cookies policy, please contact our Data Protection Lead at the PLCF by emailing dataprotection@plcf.co.uk
1. WHO WE ARE
The PLCF is a charity that is committed to providing the best opportunities for people from all walks of life to develop their full potential, particularly through sport. It does this through a number of programmes that embrace one or more of the following themes: community cohesion, education, health and sports participation. It receives most of its funding from the PL. The information we collect may be used by either organisation in accordance with arrangements in our Data Sharing Agreement.
We are a "controller" under the General Data Protection Regulation (the GDPR) and other applicable data protection legislation (Data Protection Law). This means we are responsible for deciding how we use the personal data that we collect about you and, in accordance with the Data Protection Law, we will ensure that the personal data we hold about you is, at all times:
1. used fairly, lawfully, and transparently;
2. collected for limited, specific purposes only;
3. adequate, relevant to and limited to what is necessary for those purposes;
4. kept accurate and up-to-date;
5. not kept for longer than is necessary; and
6. held securely.
We shall be accountable for and able to demonstrate our compliance with our obligations under the Data Protection Law, and this Privacy policy is one of the ways in which we do that.
We have appointed a Data Protection Lead to oversee compliance with this Privacy policy and our data protection compliance activities.
2. WHAT PERSONAL INFORMATION DO WE COLLECT?
Personal data means any information about an individual from which that person can be identified. The types of personal data that the PLCF collects include:
For the purposes of the Services, we will never ask you for any special category data (race, ethnic origin, politics, religion, trade union membership, health, sex life or sexual orientation).
3. WHERE DO WE COLLECT INFORMATION FROM?
We collect information in the following ways:
Information you give us
Information from Third Parties
Information we get from your use of our website
Information in the public domain
4. WHAT MIGHT WE DO WITH YOUR INFORMATION?
We will only use your personal data where Data Protection Law allows us to. Data Protection Law says we can collect and use personal data on the following bases:
1. it is necessary for us to be able to perform an agreement with you.
2. it is necessary for our legitimate interests (and your interests and fundamental rights do not override those interests);
3. if we have your consent (which you can withdraw at any time); or
4. to comply with a legal obligation i.e. rules laid down by courts, statute or regulation.
Accordingly, we lawfully use your personal data in the following ways:
Delivering the Services: We use the Registration Data so that we can deliver the Services to you in an effective, efficient and accurate way. Without it we would not be able to deliver a tailored service to you or respond to issues with these Services that are identified by us or you, or ensure you get the most out of your experience. Therefore, we use this data on the basis that it is necessary for us to be able to perform our agreement with you (i.e. the terms and conditions of the relevant Services) and for our legitimate interests of delivering the Services in this way.
Operating the Services: We use the Technical Data to operate and administer the Services including as necessary for testing, analysis, maintenance, support, reporting and hosting of data. Therefore, we use this data on the basis that it is necessary for our legitimate interests of operating the Services in this way. We also use Technical Data together with certain Identity Data and Contact Data to assist in security and fraud prevention, system integrity (such as preventing hacking, cheats and spam) and/ or to facilitate our response to a legal process. Therefore, we use this data on the basis that it is necessary both for our legitimate interests in protecting the Services in this way and in order that we can comply with a legal obligation.
Communication: We use the Contact Data to inform you of:
1. New PLPS resources, announcements and exciting opportunities. This is provided to you in a monthly newsletter sent directly to your email address.
2. Research opportunities. When the PLCF engage with researchers to test the impact of PLPS, researchers and organisations may email you directly for input into research design, methodology and evaluation.
3. Local football club community organisations. The PLCF may provide local football club community organisations with your details so they can contact you about their programmes and activities.
We give you the option of providing opt-in consent to receive the above communications from us or deciding not to do so.
The PLCF will never provide external organisations with these details without your consent. If you opt in to any of these, you can ask to be removed at any time by emailing plprimarystars@premierleague.com.
What if you do not want to share your personal data?
Unless otherwise specified above, generally we collect your personal data on a voluntary basis. However, please note that if you decline to provide certain mandatory personal data, you may not be able to access certain Services and we may be unable to fully respond to any inquiries you make.
5. HOW WE UPDATE YOUR INFORMATION
We continuously review our PLPS register to ensure your data is as accurate as possible and always appreciate it if you let us know if your details change.
6. WHO MIGHT WE SHARE YOUR INFORMATION WITH?
We are committed to protecting your data and therefore it will never be disclosed or sold to external organisations other than those acting as agents and data processors carrying out work on our behalf. Where we enter into a relationship with an external party, any such arrangements will be subject to a formal agreement between the PLCF and that organisation to protect the security of your data. They only act under our instructions and we maintain full responsibility for your data. The third-party suppliers which the PLCF engage for this PLPS are:
EdComs
EdComs administer this website on behalf of the PLCF and are the data processor.
The Education Company Limited
The Education Company Limited administer the Spirit database and information from registration contact details are shared with this database. The Education Company Limited are also the data processor.
Where a third-party supplier engages with an external organisation, we will ensure the third-party supplier is compliant with data protection laws. EdComs use the following organisations to provide marketing and mailing software:
Dotmailer – are used to provide email mailouts to registered users and recruitment emails to potential new users
Mandrill – are a transactional email platform from MailChimp and send automated emails to registered users.
7. HOW TO ACCESS, CORRECT OR DELETE YOUR INFORMATION
You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please email the Data Protection Lead at dataprotection@plcf.co.uk or write to us at Premier League Charitable Fund, 30 Gloucester Place, London W1U 8PL.
We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information that you think is inaccurate.
If you do not want to receive any further information about Premier League Primary Stars and would like us to remove your name from our mailing list, please contact us to let us know. Please address all your requests, by email or mail, to our Data Protection Lead. To help us locate any personal information about you (or in case we need to get in touch with you to obtain further information to help us locate your records) please include your full name, address and telephone number with your request.
8. HOW WE KEEP YOUR DATA SAFE
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 (a Data Security Breach). In addition, we limit access to your personal data to those employees, contractors and other third parties who have a business need to know. They will only use your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected Data Security Breach and will notify you and any applicable regulator where we are legally required to do so.
Where we have given you or you have chosen a password which enables you to access certain Services, you are responsible for using reasonable care in keeping this password confidential.
9. HOW LONG WE STORE YOUR DATA FOR
We will hold your personal information on our systems for as long as is necessary for the relevant activity. If you request that we stop sending you marketing materials we will keep a record of your contact details and appropriate information to enable us to comply with your request not to be contacted by us, we won’t keep any information that we don’t need.
10. CHANGES TO THIS NOTICE
We keep our privacy practices under review and may change this privacy policy from time to time by posting changes on the PLPS website or otherwise notifying them to you.
This Privacy Notice was last updated on 24 May 2018.
11. YOUR RIGHTS
Under Data Protection Law, you have certain rights (depending on the circumstances) in connection with your personal data, which include:
We are committed to respecting your rights. You may action your rights (as may be applicable) by contacting us using the details provided below and we will comply with your requests within a reasonable period unless we have a lawful reason not to do so.
Requests should be made in writing and to ensure that personal data is dealt with carefully and confidentially we will require the requestor to provide verification of their identity and all applications must be accompanied by copies of at least two official documents, which show your name, date of birth and current address (for example, driving licence, birth/ adoption certificate, passport, recent utility bill).
In responding to such requests, we will explain the impact of any objections, restrictions or deletions requested.
We will not charge you a fee to exercise your rights unless your request is clearly unfounded or excessive, in which case we may charge you a reasonable fee. Alternatively, we may refuse to comply with the request in such circumstances.
You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK data protection authority. The ICO's contact details as are follows: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF; Tel: 0303 123 1113 (local rate) or 01625 545 745; https://ico.org.uk/global/contact-us/
CONTACT US
If you have any questions about this Privacy Policy or how we handle your personal data, please contact us using the following contact details:
PLCF Data Protection Lead
The Football Association Premier League Limited
30 Gloucester Place,
London, W1U 8PL
dataprotection@plcf.co.uk
(0)207 864 9000
In this Cookies Policy, any use of the words "you", "yours" or similar expressions shall mean any user of this website whatsoever. Terms such as "we", "us, "our" or similar expressions shall mean the Premier League Charitable Fund.
Cookies are small pieces of information that are stored by your browser on your computer’s hard drive and they are used to record how you navigate this website on each visit. Cookies identify your browser, and basic information that you have shared with Google to our servers when you visit our website. They do not identify you as an individual. If you do not want to accept cookies you can easily disable this function by changing the settings on your Internet browser.
HOW WE USE COOKIES
We use a type of cookie called Analytical/Performance Cookies. These allow us to recognise and count the number of users of our website and see how such users navigate through our website. This helps to improve how our website works, for example, by ensuring that users can find what they are looking for easily. The following table sets out a more detailed description of the cookies we use and their purpose:
Cookie Name: _ga, _gat
Description: These are third party cookies placed by Google that allow us to use the Google Analytics service.
Purpose: These cookies enable us to anonymously track how visitors access and browse our website, thereby enabling us to optimise and improve our service. Further information is available at:
www.google.co.uk/intl/en/analytics/privacyoverview.html
Cookie Name: PHPSESSID
Description: These manage your visit to our website.
Purpose: These cookies keep you logged in when using the site.
Cookie Name: New Relic
Purpose: This provides monitoring of server status for web and app use in real-time.
Cookie Name: JSESSIONID
Purpose: This is used to store a session identifier so that session counts can be monitored.
Cookies do not cause harm to your computer but if you do wish to stop your computer accepting cookies, navigate to the settings of your Internet browser.
Cookie Name: Facebook Pixel
Description: This cookie tracks whether you have visited Premier League Primary Stars in the past. Further information is available at:
https://www.facebook.com/business/learn/facebook-ads-pixel
Purpose: These cookies are used to optimise Facebook Ads.
CHANGES TO THIS COOKIES POLICY
Our policies and procedures are under continual review. We may, from time to time, update our cookies policy. Any such changes will be posted on this page.
CONTACT
Questions, comments and requests regarding this Cookie Policy should be addressed to dataprotection@plcf.co.uk or to the PLCF, 30 Gloucester Place, London, W1U 8PL.