PRIVACY NOTICE

This privacy notice sets out how Hibernian Supporters Limited (“we”, “our”) collect, store and use information about you when you use or interact with our website, hiberniansupporters.co.uk (our “website”) or that you provide to us and how the law protects you. Please read this privacy policy so that you are aware of how and why we are using your personal data.

For the purpose of the General Data Protection Regulation (“GDPR”), we are the Data Controller of any personal data we hold regarding you. We respect your privacy and are committed to protecting this data. We adhere to the principles of the GDPR when processing your personal data.

If you have: (i) any concerns about our processing of your personal data; or (ii), you have a general enquiry in relation to data protection, please contact [email protected].

You have the right to make a compliant at any time to the Information Commissioner’s Office (“ICO”), the UK’s supervisory authority for data protection issues (www.ico.gov.uk). 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. What is personal data?

Personal Data: means any information relating to an identified or identifiable natural person (“Data Subject”) from which that Data Subject can be identified directly or indirectly (in particular, by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person).

Special Category of Data: means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

When we refer to “personal data”, we mean both personal and special category of data, although we do not envisage that we will collect any special category data from you.

1. The data we collect about you

We primarily collect personal data from you through direct interactions with us by our website, email, telephone or face to face.  We may also have personal data returned to us from third parties which you engage with in relation to our services to you (such as data on amounts paid by you to us which is returned to us from our payment providers Go Cardless and Stripe)

We may collect the following data to undertake one of the services that you have requested:

• Name;
• Contact information including address, postcode, email address and telephone number;
• Any data regarding how you use our website though cookies that we use on our website;
• Payment details for membership contributions;
• IP addresses – we may collect information (where available) about your IP (internet protocol) address, operating system and browser type. This data provides us with information about your browsing actions and patterns.  It is used to inform improvements to our website and for internal system administration; and
• Any other information you post, email or otherwise send to us.

As you interact with our website, we will automatically collect technical data regarding your equipment, browsing actions and patterns. We collect this personal data by using cookies and similar technologies.

1. Where will we store your data?

Your personal data will be stored in the UK.

1. If you fail 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 fail to provide that data when requested, we may not be able to perform the contract we have entered into with you or accept you as a member. In this case, we may have to cancel a product, service or membership you have with us but we will notify you if this is the case at the time.

1. How we use your personal data

To provide you with our services, and to be a member of Hibernian Supporters Limited, we need to know your name and contact details.

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 are fundamental rights do not overrise those interests;
• Where we need to comply with a legal obligation; and
• For office administration and internal record keeping purposes.

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. 

1. Purposes for which we will use your personal data

We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so.

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

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.

1. Disclosures of your personal data

We may disclose your personal data to third parties:

• when engaging with Hibernian Football Club in relation to our legitimate interests as the supporters group (for example organising match day mascots and producing a Hibernian Supporters football);
  
• when engaging with third party partners to provide services to Hibernian Supporters Limited members (for example using a tour provider to arrange travel to away matches);
• to process membership contributions via our payment providers (currently GoCardless Limited);
• in the event that we sell or buy any business or assets, in which case, we may disclose your personal data to the prospective seller or buyer of such business or assets;
• if we or substantially all of our assets are acquired by a third party, in which case, personal data held by us about you will be one of the transferred assets;
• if we are under a duty to disclose or share you personal data in order to comply with any legal obligation or in order to enforce or apply our terms of use and other contracts (for example recording membership with Companies House);  and
• to protect the rights, property, or safety of us or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

In all instances where we disclose your personal data to third parties, we will ensure that your data is appropriately protected.

Where our suppliers process our personal data on our behalf, we require them to put in place appropriate security measures to protect your personal data in line with out policies. We do not allow our suppliers to use your personal data for their own purposes that only permit them to process your personal data for specified purposes, in accordance with out instructions and data protection law.

1. International transfers

We do not transfer your personal data outside the European Economic Area (the “EEA”).

1. Is your personal data safe?

We work hard to protect your personal data and have adopted appropriate technical and organisational measures to prevent it from being accidentally lost, used or accessed in an unauthorised way, altered or destroyed.

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.

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.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to us via the internet. Any transmission is at your own risk.

1. Data retention

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 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 period for difference aspects of your personal data are available in our retention policy which you can request by contacting us.

1. How we use cookies

We use traffic log cookies to identify which pages are being used. This helps us analyse data about webpage traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system. Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. The following are the cookies currently running on our website:

• _ga – Google Analytics – website statistics
• _gid – Google Analytics – website statistics
• _gat – Google Analytics – website statistics
• 1P_JAR – Targeting/Advertising
• CONSENT – Performance
• PHPSESSID – Session Identifier
• WFVT_ – Wordfence – security
• wordfence_verifiedHuman – Wordfence – security
• wfwaf-authcookie-cc0695a02d6014f8a282c81063db17bc – Cookie notice

1. Your legal rights

Under certain circumstances, you have rights under data protection law in relation to your personal data. We have summarised your rights below:

• You can request access to your personal data.
• You can seek to restrict our processing of your personal data or ask us to rectify any personal data we hold about you.

• • You can object to us processing your personal data where we are relying on legitimate interest and we will cease processing for the purpose you object to.  An exception to this would be where we have compelling legitimate grounds for processing which override your interests, rights and freedoms or where it is necessary for the establishment, exercise or defence of legal claims.

• • You have the right to ask us to provide you with your personal data in a structured, commonly used and machine-readable format to allow you (or us on your behalf) to transmit this information to another party.  More information can be found at www.ico.org.uk.

• • You have the right to ask for the data held about you to be corrected. Please help us keep our records updated by informing us of any changes to your personal data.

• • You have the right to ask us to erase the personal data we hold about you. Such circumstances include: (a) where we no longer need your personal data for the purposes set out above; (b) if you withdraw your consent to our processing; (c) if you object to our processing based on our legitimate interest and we have no overriding legitimate grounds to continue processing your personal data; (d) if we process the data unlawfully; or (e) where the personal data has to be erased to comply with legal obligation to which we are subject.  We will consider any such request in line with data protection law.  Please note this is not an absolute right and there may be circumstances where we choose not to delete all of the personal data we hold about you.  More information about your right of erasure can be found at www.ico.org.uk. 

If you would like to exercise any of the rights set out above, please contact [email protected].   

1. Third party links

Our website may, from time to time, contain links to and from third party websites, plug-ins and applications. If you follow a link to any of these websites or services, you may allow third parties to collect or share data about you. We do not control these third party websites and we do not accept any responsibility or liability for any personal data that may be collected through these websites or services (such as, contact and location data). We encourage you to read the privacy policy of each website you visit.

1. Changes to our privacy notice

We keep this privacy notice under regular review. Any changes we may make to our privacy notice in the future will be posted on our website and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our privacy policy.

1. Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to [email protected].