This Data Protection Statement (“this Statement”) explains what information we collect from and about membership applicants and members, how their information will be used, how long we keep it for and what their related rights are.
1. Who are we?
1.1 We are Hull City Tigers Limited (UK registered company number 04032392). Our registered office and address for correspondence is the KCOM Stadium, Hull, HU3 6HU.
1.2 We are committed to ensuring that all personal information we hold is treated properly and in accordance with applicable data protection legislation. We are registered as a data controller with the Information Commissioner’s Office (“ICO”) and our registration number is ZA274325. In accordance with applicable data protection legislation, we are required to explain to you how we will treat any personal data which we collect about you.
1.3 This Statement applies to anybody who applies to us for a membership or subsequently becomes a member (including any member who is named in a membership agreement entered into with us by another member). This Statement covers the personal information we collect in connection with each application for a membership and each membership provided by us. This Statement does not apply to corporate memberships (e.g. Premier Tiger).
1.4 You promise that any information you supply to us is accurate and up-to-date, that you will inform us if any such information requires updating and that where you submit any other person’s details to us you have that other person’s permission or are otherwise legally permitted to do so on their behalf.
1.5 You have the right to lodge a complaint with the ICO if you have any concerns with regard to the way in which we process your personal information. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
1.6 Please note that any information that you submit to us via our website will also be processed in accordance with our website privacy and cookies policy, a copy of which can be accessed via the following URL: www.hullcitytigers.com/privacy-policy.
2. What information do we collect and how do we use it?
2.1 Where you apply for a membership agreement with us or are the lead member in a membership agreement, you may give us information about you by completing one of our information capture forms, or by corresponding with us by telephone, e-mail or otherwise. This information may include your name, postal address, telephone number, email address, date of birth, payment and bank account details.
2.2 If you are named in a membership application or membership agreement made by or with another person, we will collect your name, address and date of birth as part of the application process and any related correspondence with the lead applicant/member.
2.3 Regardless of the success of the application, any information submitted to us in connection with an application for a membership will be used as necessary for our legitimate interest in processing the relevant application.
Where you are a member, we will also use your information (including information collected by us during the application process and in connection with your subsequent membership) as follows:
2.4 Where you are the lead member named in the membership agreement, we will use your information where necessary for the performance of your membership agreement. For example, your payment/bank account details will be used by us for collecting your monthly membership fee and any applicable joining fee, and your postal address will be used for the purposes of sending you your membership card(s);
2.5 For all members, we will use your personal information as necessary for our legitimate interests in administering the relevant membership agreement and providing our related services and membership benefits to you. For example:
(a) your contact details will be used where we need to contact you in relation to your membership;
(b) we will use your personal information to enable you to receive your membership benefits and to compile a record of your membership activity (for example, a record of your membership card usage will be maintained which includes details of matches attended, purchases made and any Tigers Rewards points accrued by you as part of your membership);
(c) we will use your date of birth and postcode for account verification and security purposes; and
(d) if you correspond with us (e.g. using email), we may retain the content of your correspondence together with your contact details and our responses where necessary for our and your legitimate interests in order that we can appropriately manage your membership, to reply to your correspondence and for training and quality purposes. This may include us recording and monitoring our telephone calls with you for such purposes.
2.6 Where we need to collect personal data in connection with your membership and you fail to provide that data when requested, we may not be able to provide you with all membership benefits or otherwise perform any related membership agreement that we have or are trying to enter into with you.
2.7 In limited circumstances, we may approach you for your consent to allow us to process certain information for purposes not referred to in this Statement. If we do so, we will provide you with details of the information we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of any contract with us that you agree to any request for consent from us. If you do provide us with consent, you will be able to withdraw it at any time via the method that we notify you of when obtaining your consent. Any such withdrawal will not affect the lawfulness of our processing of your personal information based on your consent before you withdrew it.
2.8 Please note that we may also record footage of individuals attending Club home or away matches as part of any image and/or audio-visual recording created by the Club of spectators attending any such match. We may use any such images and recordings for our commercial activities where such use is in our legitimate interests (so long as our interests are not overridden by the impact on you). Such activities may include Club promotional activities and displaying such images on the Official Hull City Tigers Ltd website in relation to any competition or promotion operated by the Club.
3. News Updates and Marketing Information
3.1 Where you have given us your consent, we may use your relevant personal information to provide you with Club news updates and to inform you of special offers, promotions, new products and new services via post, telephone, SMS or email. We may also use your information to send you news and other updates by such means in relation to our official sponsors and partners if you give us your consent.
3.2 You may withdraw your consent to us using your information for the purposes mentioned in section 3.1 above at any time. This can be done by e-mailing us at [email protected], writing to us at Hull City Tigers Limited, KCOM Stadium, Hull, HU3 6HU, clicking on the appropriate link of any of our marketing e-mails or (if you are a registered user of our official website) amending your preferences on your personal profile page on our official website. Any such withdrawal will not affect the lawfulness of us sending such communications to you before you withdrew your consent.
3.3 Please note that if you withdraw (or do not provide) your consent to us sending you such information, this will mean that you will not be notified by us of any such news or marketing information (such as product discounts and ticket bundles), including any discounts and offers only made available to members.
4. To whom will we disclose your personal information?
4.1 We may share your personal information with third parties where necessary for our legitimate interests as listed below:
(a) with third parties who are processing your information on our behalf in accordance with our instructions. This includes TeamCard (our third party turnstile entry software provider);
(b) with third parties who are directly involved in dealing with any request, enquiry, complaint or other correspondence submitted by you;
(b) with third parties who are providing us with professional advice where permitted by law;
(c) in connection with criminal investigations, legal proceedings or prospective legal proceedings where permitted by law; and
(d) in order to establish, exercise or defend our legal rights, such as under any membership agreement (including providing information to others for the purposes of fraud prevention and enforcing our ground regulations).
4.2 If you receive services from us which involve the services of a third party, we will pass information about you to that third party so they can provide you with those services on our behalf.
4.3 In the event that you provide us with feedback regarding our activities, we may disclose that feedback to those of our suppliers who are involved in those activities where it is in our legitimate interests to do so in order to improve our services.
4.4 We may also disclose your personal information to a third party in the event that we:
(a) sell or buy any business or assets (in which case we may disclose your personal information to the prospective seller or buyer of such business or assets or their professional advisors) or if we or substantially all of our assets are acquired by a third party. Any such disclosure will be made where necessary for the legitimate interests of us and/or the third party in respect of the proposed transaction; or
(b) assign, transfer or license our rights in the membership scheme to a third party, in which case any such disclosure will be where necessary for the legitimate interests of the third party to administer the scheme and continue to honour any active membership agreements,
however in each case we will not transfer your personal information to any such third party unless we are satisfied that they are able to provide an adequate level of protection in respect of your personal information.
4.5 We may also share your personal information with third parties where we are legally required to do so, or where we have stated or informed you otherwise (e.g. in this Statement).
4.6 Please note that we may use the services of a supplier outside the European Economic Area (EEA) for sending marketing and other email communications (for example SurveyMonkey and MailChimp). This may involve your email address being processed by the relevant supplier on our behalf outside of the EEA. If we do this, we will require the relevant supplier to put in place appropriate technical and organisational data protection security measures (for example, as part of our contract with the relevant supplier or by verifying that they operate under the EU-U.S. Privacy Shield framework (please see www.privacyshield.gov for further details)).
4.7 Except as provided in this Statement, we will not provide or disclose your information to third parties without your express consent for any purpose (including but not limited to direct marketing). We do not sell personal information under any circumstances.
4.8 Where we share your personal information with third parties we will take reasonable steps to ensure that it is properly protected and processed in accordance with this Statement.
5. Away Tickets
5.1 Please note that if you purchase or obtain any away match tickets in connection with your membership (for any competition, including at any neutral venue such as Wembley Stadium), we may disclose your name, postal address and away match seat number (if applicable) to the relevant away team or away venue. This is because we will be acting on behalf of the relevant away team or away venue in supplying the relevant away tickets.
6. Your rights
6.1 You have a legal right to see a copy of the personal information that we keep about you and to require us to correct any inaccuracies, subject to certain exemptions. In some circumstances you may also have the right to:
(a) request that we erase any personal information held about you;
(b) restrict our processing of your personal information (for example, to ask to suspend the processing of personal information to establish its accuracy or the reasons for processing it);
(c) data portability (i.e. to request the transfer of personal information to a third party); and
(d) object to our processing of your personal information where we are relying on a legitimate interest (or those of a third party).
6.2 Requests in respect of the above should be made in writing to the Data Compliance Officer, Hull City Tigers Limited, KCOM Stadium, West Park, Hull, HU3 6HU or via email at [email protected] Please contact the same address if you have any reason to believe that information we hold about you is inaccurate. We will respond to your request as soon as possible and, in any event, within one month from the date of receiving the request. Please note that we may, where legally permitted, reject any such request or limit the scope of our response (e.g. if, in the circumstances, the right does not apply to you).
6.3 In accordance with applicable data protection legislation, we follow security procedures in the storage and disclosure of your information. We may therefore request proof of your identity and rights before complying with any request of a nature described in section 6.1 above.
6.4 You will not generally have to pay a fee to exercise any of your rights described in section 6.1 above. However, we may charge a reasonable fee if you make a related request which is clearly unfounded or excessive. Alternatively we may refuse to comply with your request in such circumstances.
7. Retention and destruction of your personal information
7.1 Any personal data held by us in relation to any of the purposes described in this Statement will be retained by us in accordance with our information retention policy (a copy of which is available upon request) for a reasonable period having regard to the relevant purpose, following which it will be destroyed. For example:
(a) Information relating to members will ordinarily be retained for the duration of the relevant membership agreement and for a further year after the termination of their membership (so that we are able to identify whether a joining fee is payable should a former member reapply for a membership); and
(b) If you have consented to receiving news updates and marketing information from us, your preferences in that regard and related contact details will be retained by us unless and until (a) we cease sending such information, or (b) you withdraw your consent – following which we will suppress such personal information without delay so that you no longer receive such information.
7.2 Save for any news update and marketing preference information suppressed under section 7.1(b) above, your information will be securely destroyed at the end of the relevant retention period described or otherwise referred to in this section 7.
7.3 Whilst taking into consideration our legal obligations, we will on an ongoing basis: review the length of time that we retain personal data for; consider the purpose or purposes for which we hold the personal data in deciding whether (and for how long) to retain it for; securely delete personal data that is no longer needed for such purpose or purposes; and update, archive or securely delete information if it goes out of date.
7.4 We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know that information.
7.5 We have put in place procedures to deal with any suspected data security breach and will notify you and/or any applicable regulator of a suspected breach where we are legally required to do so.
8. How will you know if we make any changes to this Statement?
We may amend this Statement from time to time. If we make any changes to the way in which we use your personal information we will notify you by writing to you or by sending you an e-mail. We will also post a notice on our website’s homepage. You can view the current version of our Membership Data Protection Statement at any time by accessing the following URL: www.hullcitytigers.com/privacy-policy/membership-data-protection-statement/
If you have any questions about this Statement or our treatment of your personal data, please write to us at The Data Compliance Officer, Hull City Tigers Limited, KCOM Stadium, Hull, HU3 6HU or email us at [email protected]