‘Personal data’ is essentially information from which an individual person can be identified.
The Policy is set out in sections so you can click through to the specific areas you want to know. The detail is in each section, along with a quick read summary where relevant.
EFL Digital operates the Online Facilities on behalf of the Club. EFL Digital is part of the EFL group of companies, so when this policy refers to the “EFL Digital Group” that’s what we mean. The EFL Digital Group may use your data on the basis set out in this Policy, as may the Club.
References to “we”, “us” and “our” in this Policy are all references to EFL Digital Limited and the Club.
In brief… Personal data collected by the EFL Digital Group when you use the Online Facilities. This personal data may also be used by the Club.
This Policy applies to personal data collected by the EFL Digital Group through your use of the Online Facilities.
Where personal data is collected and used for the purposes set out in this Policy, EFL Digital and the Club are both ‘data controllers’ under data protection law applicable in the EU (“Data Protection Law”).
You should read this Policy together with any other privacy information which may be provided on specific occasions when personal data about you is collected on the Online Facilities. That will ensure you are fully aware of how and why we are using your data. This Policy supplements any other notices and is not intended to override them.
This Policy does NOT apply in relation to any data you provide to the Club or EFL Digital Group through offline scenarios separate from the Online Facilities, such as unrelated telephone enquiries or in person.
This Policy does NOT apply where the Club collects your personal data for its own use without any involvement of the EFL Digital Group. This may be (i) on the Online Facilities, or (ii) on other web-based facilities of the Club such as its own official mobile application, or its own separate website for merchandise or ticket sales etc.
Where this is the case on the Online Facilities, that will be clearly noted on the relevant page used by the Club to collect your information.
In these circumstances only the Club will be the ‘data controller’ for the purpose of Data Protection Law. The EFL Digital Group will not be controlling your data for these purposes.
Links to Third Party Websites and Services
We are not responsible or liable for the content, privacy notices or services offered by websites or apps other than the Online Facilities. We encourage you to read those notices.
This includes websites and apps which link from any of the Online Facilities, with the exception of: (i) the Club’s official ticketing and merchandise service and/or official Club mobile app, which only the Club controls, and (ii) the official EFL website or other sections of the iFollow app (excluding those for the Club), which EFL Digital controls.
In brief…Information which identifies you, contact information, financial or transactional information, technical and profile data, information about how you use the Online Facilities, and/or preferences you have notified to us. We use safeguards for any collection of children’s data.
We may collect, use, store and transfer different kinds of personal data about you. For the purpose of this Policy we have grouped these together as follows:
- Identity Data such as your name(s), username or similar identifier, marital status, Club supporter or similar number, title, date of birth, gender and job title (where relevant).
- Contact Data such as your address, billing address (where different), email address, preferred language and telephone numbers.
- Financial Data such as your bank account, PayPal account and/or payment card details.
- Transaction Data such as details about payments to and from you and other details of products or services you have purchased from us or accessed on the Online Facilities (including as part of any iFollow subscription you have).
- Technical Data such as your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types versions and statuses, operating system and platform and other technology on the devices you use to access the Online Facilities.
the Online Facilities. This allows information about your use and browsing to be recognised. Full information on which cookies we use is available in
our Cookies Policy, along with guidance about how you can set your browser to refuse all or some cookies (but that may affect some use of the Online
- Profile Data such as your username and password, associated social media accounts, supported team or Club, your interests, preferences, posts or comments on interactive features (if any), feedback and/or survey responses.
- Usage Data such as information about how you use the Online Facilities and services provided through them (including iFollow, newsletters and marketing emails, and advertisements). This may include information about page views, length of visit or use and exit route, timing, frequency and patterns of your use, along with navigation paths when using the Online Facilities – this information does not directly identify you. We use various tools to help us with this, including Google Analytics (see our Cookies Policy for further information). Where you have subscribed to receive the Club newsletter or marketing emails we will also receive information about whether you open, delete, or access links contained in the newsletter, the browser or app type used and whether opened via mobile or desktop.
- Communications Data includes information you provide when communicating with us, your preferences in receiving marketing from us and our third parties and (where relevant) any other communication preferences.
- Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be generated from your personal data but does not directly reveal your identity. However, if we combine or connect Aggregated Data with your personal data so that it can directly identify you, we treat the combined data as personal data which will be used in accordance with this Policy.
Special Categories of Personal Data includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political
opinions, trade union membership, information about your health and genetic and biometric data). We generally do not collect this information, and where
we do it is held in an anonymised form detached from your other data so does not reveal your identity. We do not collect any information about criminal
convictions and offences.
If you fail to provide personal data
Use of services accessed through the Online Facilities may require you to provide specific types of information. Where you fail to provide that information,
we may not be able to perform the contract we have or are trying to enter into with you. For example, we may not be able to provide you with access to an
We understand that children and young people, including those under 13 years of age (“minors”), may visit the Online Facilities 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 Online Facilities.
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 reasonably
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 Online Facilities.
In brief… Through direct interactions with you or your use of the Online Facilities, automated technologies, relevant third parties and publicly available sources such as social media platforms. Some data passes through our contractor's systems before coming to us.
We use different methods to collect data about you, including through:
- Direct interactions. You may give us your Identity, Contact, Financial, Communication and certain Profile Data by filling in forms or by corresponding with us using contact details we provide on the Online Facilities. This includes, amongst other things, personal data you provide when you: request an iFollow or newsletter subscription); participate in interactive features, including any competition, promotion or survey; or give us feedback.
- Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
- Technical & Usage Data from parties such as our analytics providers (including Google), and advertising networks (see below);
- Identity, Contact, Profile, Financial, Transaction, Usage and Technical Data from providers of technical, payment and delivery services;
- Identity, Contact, Profile, Usage and/or Technical Data from social media platforms which are publicly available or through which you may log in or interact with the Online Facilities;
- Identity, Financial and/or Contact Data from data brokers or aggregators, such as those used for any credit reference or similar pre-service vetting facility (if any); and
- Information from lawfully available sources where relevant to our bringing, defending or assisting in legal action (such as the police, regulators, investigators or publicly available sources).
We may also supplement the information collected with other information that we obtain from our dealings with you or which we receive from other organisations, such as our commercial partners, and group companies.
In brief… To deliver services you request; take payments; allow you to make use of interactive features (if any); manage and improve our services; communicate with you; marketing and associated profiling (only where you have agreed for email, sms, phone or social media direct messaging); administer, analyse use of and improve the Online Facilities; protect and enforce our legal rights or those of others.
We may profile your use of the Online Facilities and communications you agree to receive, and automated processes also assess your eligibility when you request a subscription to iFollow.
Several legal grounds apply to our use of your data, depending on which of the above purposes we use it for. These may include where: you consent; we need to perform any contract with you; we need to comply with legal requirements; or as necessary for our legitimate interests, but balanced against your rights.
We use information about you for the following purposes:
- Services, Products & Opportunities- to allow you to register an account or otherwise receive products, services and other opportunities (such as an iFollow subscription or newsletter) and fulfil any of our obligations for delivery of those. Automated processes may assess your eligibility to receive services such as iFollow subscriptions, based on the information you provide - if you think that process has incorrectly refused you a subscription, let us know why and we will have a human review it.
Processing your data for this purpose will usually be necessary (i) to perform any contract with you for the relevant service where applicable (ii) to comply
with legal obligations where applicable or (iii) otherwise for our legitimate interests in complying with third party requirements which enable us to provide
- Payments and Finance- to collect payments from you for any paid for products or services, and/or administer any payments which may become due to you. This will usually be necessary (i) to perform any contract with you for the paid for service or (ii) to comply with legal obligations where applicable or (iii) for our legitimate interests in recovering debts due to us.
- Publications– to include you in relevant publications, such as where you win a promotion we or one of our commercial partners carry out. We will usually ask you for permission in these circumstances.
- Manage and Improve- to manage and improve the Online Facilities, notify you of applicable changes where required and allow you to use the features offered by the Online Facilities. This will usually be necessary (i) to perform any contract with you where relevant for applicable services (ii) to comply with legal obligations where applicable or (iii) otherwise for our legitimate interests in managing our relationship with you as a customer, improving our service, and/or record keeping.
- Communications- to communicate with you where necessary for purposes other than marketing. This will usually be necessary (i) to perform any contract with you for applicable services where relevant (ii) to comply with legal obligations where applicable or (iii) otherwise for our legitimate interests in managing our relationship with you as a customer, improving our service, and/or record keeping.
- Administer and Protect- to administer and protect our businesses, the Online Facilities, and rights of ourselves or other associated third parties (including those of other users and partners). This may include routine tasks such as troubleshooting, data analysis, testing, system maintenance and support as well as more formal matters such as bringing, defending or assisting in legal action where necessary. This will usually be necessary (i) for our legitimate interests in running our business and systems in a secure manner, business restructuring, protecting our rights and property (including intellectual property) and preventing or tackling illegal activity or (b) to comply with a legal obligation where applicable.
- Marketing & Associated Profiling- to alert you to information about events, surveys, competitions, offers, products, services and other exciting updates relating to us, and/or commercial partners.
We only do this through email, sms, automated phone calls or online direct messaging (such as using any private message facility on the Club website or as may be permitted on associated social media platforms) where you have agreed, so this is on the basis of your consent. However, if you are an existing customer we may contact you about our products or services similar to those you have previously received or enquired about (unless you have chosen not to receive such communications).
You can change your mind or adjust your preferences any time afterwards either in your personal profile page (also known as a ‘preference centre’)
which is accessible from all of our emails, or emailing us at email@example.com.We will also stop sending these in direct response to any other express
communication from you asking to do so. We may measure the effectiveness of our communications, including Usage Data relating to newsletters and
other marketing emails as set out in the “What information do we collect?” section above.
We also use tools to help us and our advertising network make relevant advertising available to you when you use the Online Facilities and our associated
social media platforms (including facilities made available for this purpose by Facebook), and measure how effective that advertising is. To do this we rely
on cookies, which may include codes associated with your device but do not themselves identify you by name. As mentioned earlier, full information on
which cookies we use is available in our Cookies Policy, along with guidance about how you can set your browser to refuse all or some cookies. This type
of bespoke advertising (and any postal marketing) is carried out on the basis it is necessary for the legitimate interests of us or applicable commercial
partners in marketing relevant products, services and exciting offers.
- Research, Analysis & Personalisation- to carry out market research so that we can improve the products and services we offer, and in some circumstances personalise content (including advertising as mentioned earlier) delivered to you. Your feedback is valued and helps to inform the commercial strategy, marketing activity and initiatives across the EFL Digital Group and Club. This will usually be necessary for our legitimate interests to study how customers use our products/services, to develop them, to grow our business and to inform our commercial and marketing strategy.
We may also process your personal data for other reasons, in compliance with the above rules, where this is required or permitted by law. Where we reasonably consider that we need to process your personal data for another reason that is compatible with the original purpose set out in this Policy we will do so. If that is ever the case and you wish to get an explanation as to how processing for any 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.In some circumstances, this may require your consent.
In brief…usually in the European Economic Area (EEA) but always in a manner that ensures proper security. We will only keep the minimum amount of information for as long as we need it for the purpose(s) set out in this Policy.
We are committed to protecting the security of your personal data, which we generally hold in secure data centres in the European Economic Area (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 (certain contracts are approved by the European Commission).
In relation to personal data sent to the US, we usually check whether the ‘Privacy Shield’ applies – that ensures a similar level of protection to personal data shared within the EEA. See https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/eu-us-privacy-shield_en, for further details.
We will keep the personal data you have provided only for as long as we reasonably require to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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. This is in addition to any applicable legal requirements.Details of any specific retention periods for different aspects of your personal data are available on request by contacting us at firstname.lastname@example.org.
For legal reasons we may have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for up to seven years after they cease being customers– this is particularly for any paid for products or services.
In some circumstances you can ask us to delete your data: see the “What are your rights?” section below for further information.
We may 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.
We have put in place appropriate operational, technical and security measures to reduce the risk of your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. This includes use of encryption where relevant, for example in relation to financial information you provide through the Club iFollow service which is encrypted for additional security. 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.
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.
If we have given you a password to access certain parts of the Online Facilities, you must keep the password safe and make sure you use a secure browser.
In brief… other companies in the EFL Digital Group or Club group; new owners of those businesses; legal bodies; selected contractors who help us provide the Online Facilities (including payment service, hosting and other technical providers); affiliates in the football industry; and commercial partners and sponsors of the Club and/or EFL Digital Group, including where you have agreed to receive marketing information from them.
We may disclose your information to third parties as follows:
- to other companies within our corporate group, including any of our affiliated community trusts and charitable schemes. Click for details about the EFL Digital Group and Club group;
- to third parties to whom we may choose to merge with, sell or transfer all or parts of our business or our assets (or businesses we may acquire). New owners of our business may use your personal data in the same way as set out in this Policy;
- to service providers who carry out some data processing activities on our behalf. For example, mailing services, payment processing, IT infrastructure, software and hosting, analytics, and advertising delivery service providers, along with other relevant partners used to help us deliver the Online Facilities to you.
We do not allow our third-party service providers to use your personal data for their own purposes unless they can otherwise lawfully do so;
- to our commercial partners or sponsors. For example, if required for prize or opportunity fulfilment in relation to promotions you engage with (but only for direct electronic marketing purposes where you have agreed to this). Click for details about the current EFL Digital Group and Club commercial partners;
- other organisations in the football industry where required for completion of the purposes set out in this Policy, such as other football leagues, clubs, governing bodies, and match venues. For example, if you enter a competition and win tickets to a match we may need to share details with the stadium or participating clubs, for ticket delivery and/or health and safety or other legal reasons;
- to professional advisers including lawyers, bankers, auditors and insurers where required for those parties to provide services to us;
- to law enforcement agencies, Courts or other dispute resolution forums, or other legal or regulatory authorities 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 co-operating in the protection of third party rights; and/or
- to any credit reference or similar pre-service or communication vetting agency (if any) for the purposes of fraud protection and credit risk reduction in relation to paid for services you request from us or assisting our compliance with lawful requirements.
We may have to share your personal data with the parties above for the purposes set out in the “What do we use your information for?” section of this Policy. In some circumstances, there may be other lawful reasons for the third party to use your data in accordance with any privacy notice they make available to you.
We may also provide anonymised Aggregated Data to third parties. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.
In brief… Access or object to use of your data; have your data corrected, erased, transferred or used only in a restricted way; complain to us or the Information Commissioner; withdraw consent to use your data. Some rights are only available in limited circumstances.
Under the Data Protection Laws you may have the following rights in relation to your personal data in certain circumstances:
- Request Access: (also known as a "data subject access request"). You can receive a copy of the personal data we hold about you.
- Request Correction: You can have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of new data you provide.
- Request Deletion: You can ask us to delete or remove personal data in certain circumstances, for example where: there is no good reason for us continuing to process it; you have successfully exercised your right to object to processing (below); or where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
- Object to Processing of your personal data: this applies where: we are relying on a legitimate interest or those of a third party (see the “What do we use your personal data for?” section above) and you feel our processing on this ground impacts your fundamental rights; or where we are processing your personal data for direct marketing purposes.
- Request Restriction of Processing: you can ask us to suspend processing of your personal data where: you want us to establish the data's accuracy; our use of the data is unlawful but you do not want us to erase it; where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request Transfer: you can ask us to provide to you, or a third party of your choice, your personal data in a machine-readable format. This right only applies to automated information which: you initially provided consent for us to use your data (see the “What do we use your personal data for?” section above); or your provided and we used the information to perform a contract with you (see the “What do we use your personal data for?” section above).
- Right to withdraw consent;. This only applies where we are relying on consent to process your personal data (see the “What do we use your personal data for?” section above). If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
All requests set out in this section or other queries relating to this Policy should be addressed to EFL Digital. See the “Who can you contact for further details?” section below. Please note we may not always be able to comply with your request due to our legitimate interests or other legal reasons. If applicable, these will be notified to you in response to a relevant request.
You will not usually have to pay a fee to exercise any of the above rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive (or we may refuse to comply with your request in these circumstances).
For security reasons, we may need to request specific information from you to help us 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.
If you have any concerns about how we use your data you also have the right to raise this with the Information Commissioner’s Office at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF (https://ico.org.uk). However we will always try to help with any concerns so ask that you contact us in the first instance.
In brief…Yes we like to ensure you are up to date about our use of your personal data. If we update this policy we will notify you, unless the changes are minor.
We may need to update this Policy, and minor changes will be posted on this page so you should check back from time to time. Significant changes will be notified to you.
This Policy was last updated on 25th August 2020.
Data Protection Officer, EFL Digital Limited, EFL House, 10-12 West Cliff, Preston, Lancashire, England PR1 8HU or email@example.com. Please include your name, address, and/or email address when you contact us.
Details of the Club’s Data Protection Officer can be found in the Club Privacy Notice (if any) on the Club’s website.
This policy is to comply with the new “General Data Protection Regulation” (“GDPR”) which came into effect on the 25th May 2018.
As part of that undertaking, we are committed to safeguarding the privacy of the personal information that we gather.
Bolton Wanderers Football & Athletic Company, is registered at the University of Bolton Stadium, Burnden Way, Lostock, Bolton, BL6 6JW registered in England and Wales – 12090433. VAT Number: 328 9255 76
Please read this Policy in conjunction with our Terms and Uses as detailed in Section 6.1
This policy applies to personal information regarding fans and other individuals with whom we do business or who buy tickets, products, or services from us and to the use of that personal information in any form.
When you use the BWFC website, or contact us by post, telephone, fax, email, mobile messaging or verbal communication we may collect, store and use certain personal information that you disclose to us. The personal information in this policy refers to information that does or is capable of identifying you as an individual. The type of personal information that we may collect from you includes, but is not limited to the following:
• your name, gender, personal and work contact details, date and place of birth, image/photos, nationality,
• your credit card details, and your account details such as customer reference number or customer ID and credentials,
• information, feedback or content you provide regarding your marketing preferences;
• information collected whilst you access an app or the BWFC website
Sensitive Personal Information
There may be instances in which the personal information that you provide to us or that we collect is considered “Sensitive Personal Information” (SPI) under the privacy laws of some countries. These laws define the following “SPI” to mean personal information from which we can determine or infer an individual’s; racial or ethnic origin, political opinions, religious beliefs or other beliefs of a similar nature, membership in a trade union or professional association, physical or mental health or condition, medical treatment, genetic data, sexual life.
Judicial data (including information concerning the commission or alleged commission of a criminal offence).
Financial records may form part of SPI. We will only process SPI to the extent permitted or required by applicable law.
Subject to applicable laws, we may collect, use and disclose relevant portions of your personal information in order to:
• provide and charge for products and related services;
• provide you with a better or more personalized level of product, service, and/or experience including information and services from a third party (such as other products, or offers related to your preference for a given product);
• respond to requests for information and services, including services from a third party (such as a companies who make and transport products, provide services, and research product buyers);
• fulfil contractual obligations to you;
• conduct market research, customer satisfaction and direct marketing and sales promotions;
• administer general record keeping;
• meet legal and regulatory requirements;
Bolton Wanderers Football & Athletic Company., uses and retains your personal information for as long as is necessary to fulfil the purpose.
On occasion, we may disclose your personal information. We would always ensure that disclosure was made in line with the relevant law.
Where necessary we may make disclosure (in addition to those described above) these include:
6.1 Service providers and suppliers Due to the needs of the business we may call on the services of market research companies to assist us. When this occurs we oblige those third parties to protect your personal information in accordance with the terms and uses https://www.bwfc.co.uk/terms-of-use/ of this policy.
6.2 Business transfers Any personal information collected about you is regarded as a business asset. As such if the business transferred its assets then your data could be regarded as one of those assets.
6.3 Legal requirements We reserve the right to disclose any personal information if any of the following apply:
- we are compelled to do so by law
- lawfully requested to do so by a government entity
- to protect or defend our rights or property in accordance with applicable laws
- compliance with accounting/tax rules and regulations
- any specific record retention laws.
If you access the Bolton Wanderers Football & Athletic Company. website, you may wish to know the following:
7.1 Our Website You can browse our website and log on without revealing your identity.
7.2 Usage information We collect information about how you use our website. Examples of such information include the Internet Protocol address automatically assigned to your computer each time you browse the Internet;
the time of your visit;
the pages you access;
the amount of time you spend on each page;
the type of Internet browser you use;
your device’s operating system;
the URL of any websites that you visited before and after visiting our website. This information is not linked to you as an individual unless you create a user profile, but we may keep records of the device being used.
7.3 Cookies and other similar technology
We use cookie technology on our website to allow us to evaluate and improve the functionality. Cookies by themselves cannot be used to reveal your identity.
However, if you block them, you will not be able to use all of the features of our website, including the customization features associated with creating a user profile. Further information about cookies and other similar technology and how they work is available at allaboutcookies.org.
7.4 Social media
Our website may also contain plug-ins and other features that integrate third party social media platforms into our website. You will be able to activate them manually. If you do so, the third parties who operate these platforms may be able to identify you, they may be able to determine how you use this website and they may link and store this information with your social media profile. Please consult the data protection policies of these social media platforms to understand what they will be doing with your personal data. If you activate these plug-ins and other features, you will be doing so at your own risk.
7.5 Creating a user profile
You can create a user profile on Bolton Wanderers Football & Athletic Company. website to, among other things, facilitate your online transactions, and to tailor your experience on our websites to your interests. This allows us to make more appropriate recommendations to you. We may use the information you provide in your user profile to populate other databases maintained by us and our service providers, as applicable.
By creating a user profile, you are agreeing that we may use the personal information you provide for these purposes. You can view, update or remove any personal information that you have provided to us for inclusion in your user profile by amending your user profile online or emailing firstname.lastname@example.org.
If you subsequently elect to remove your user profile, we reserve the right to use any personal information previously provided by you for inclusion in your user profile for record keeping and quality assurance purposes (unless we are required by law to delete or cease to process or use your personal information). Even if you choose not to create a user profile, you can still use our websites to search for and purchase services.
Because the security of your personal information is important to us, we use Secured Socket Layer (“SSL”) software in order to encrypt the personal information that you provide to us. If your browser is SSL enabled (which most are), your transmission of personal data to us online will be encrypted. You can verify whether this information is transmitted using SSL encryption by confirming the symbol of a closed lock or solid key on the bottom bar of your browser window. You can also verify that your personal information will be encrypted using SSL encryption by making sure that the prefix for the web address listed for that page has changed from “http” to “https”. If you do not see the appropriate symbol and the “https” prefix, you should not assume that the personal data that you are being asked to provide will be encrypted prior to transmission. The information we collect from you online is stored by us and/or our service providers on databases protected through a combination of physical and electronic access controls, firewall technology and other reasonable security measures. Nevertheless, such security measures cannot prevent all loss, misuse or alteration of personal information and we are not responsible for any damages or liabilities relating to any such incidents to the fullest extent permitted by law. Where required under law, we will notify you of any such loss, misuse or alteration of personal information that may affect you so that you can take the appropriate actions.
7.7 Minor children
Our website does not sell products or services to children under the age of 18. If you are under the age of 18 (or a minor in the jurisdiction in which you are accessing our website), you must involve a parent or guardian.
You may always choose what personal information (if any) you wish to provide to us. However, if you choose not to provide certain details, some of your experiences with us may be affected (for example, we cannot deliver a product without an address).
If you provide us with your contact details (e.g. postal address, email address, telephone number or fax number), we may contact you to let you know about the products, services, promotions and events offered that we think you may be interested in.
You can always choose whether or not to receive any or all of these communications by contacting us as described in Section 11 below or following the “unsubscribe” instructions contained in the communications. In some jurisdictions, in addition to you agreeing to this Policy, data privacy laws may require us to obtain a separate consent before we send you information that you have not specifically requested. In certain circumstances, your consent may be implied (e.g. where communications are required in order to fulfil your requests and/or where you have volunteered information for use by us).
In other cases, we may seek your consent expressly in accordance with applicable laws (e.g. where the information collected is regarded to be SPI under local regulations). We will abide by any request from you not to send you direct marketing materials.
When such a request is received, your contact details will be “suppressed” rather than deleted.
This will ensure that your request is recorded and retained unless you provide a later consent that overrides it.
According to current law:
you have a right of access to a copy of the information comprised in your personal data;
a right to object to processing that is likely to cause or is causing damage or distress;
a right to prevent processing for direct marketing;
a right to object to decisions being taken by automated means;
a right in certain circumstances to have inaccurate personal data rectified, blocked, erased or destroyed;
a right to claim compensation for damages caused by a breach of the Data Protection Act.
If you want to inquire about any personal information we may have about you, you can do so by sending us a written request by letter or email to the addresses set out in Section 11 below.
Please be sure to include your full name, address, and/or email address and phone number so we can ascertain your identity and whether we have any personal information regarding you, or in case we need to contact you to obtain any additional information we may require to make that determination.
You may request that we correct, cancel, and/or stop processing or using personal information that we hold about you. If we agree that the personal information is incorrect, or that the processing should be stopped, we will delete or correct the personal information.
If we do not agree that the personal information is incorrect we will tell you that we do not agree, explain our refusal to you and record the fact that you consider that personal information to be incorrect in the relevant file(s).
If you have any questions about this Policy, or any concerns or complaints with regard to it, or if you would like to submit a request (in the manner described in Section 10 above), please contact us by any of the following means:
• by calling 0844 871 2932 (Option 1) Home football Ticketing, (Option 2) Bolton Central, (Option 3) for Match day Hospitality, Advertising and our Sponsorship Team, (Option 4) for Bolton Whites Hotel or (Option 5) to speak to a member of staff
• by calling our reception at Bolton Wanderers Football & Athletic Company. on 01204 673673
• by post at Bolton Wanderers Football & Athletic Company., University of Bolton Stadium, Burnden Way, Lostock, Bolton, BL6 6JW
by email: email@example.com
If you are not satisfied with the response that you receive, you can escalate your concern to the Data Protection Office by sending an email to firstname.lastname@example.org.
You may request that we correct, cancel, and/or stop processing or using personal information that we hold about you.
If we agree that the personal information is incorrect, or that the processing should be stopped, we will delete or correct the personal information.
If we do not agree that the personal information is incorrect we will tell you that we do not agree, explain our refusal to you and record the fact that you consider that personal information to be incorrect in the relevant file(s).
All requests for access to your personal information must be submitted in writing by letter to the Data Protection Office, Bolton Wanderers Football & Athletic Company., University of Bolton Stadium, Burnden Way, Lostock, Bolton, BL6 6JW or email to email@example.com.
We may respond to your request by letter, email, telephone or any other suitable method. What forms of ID will I need to provide in order to access this? BWFC accepts the following forms of ID when information on your personal data is requested:
Utility bill (dated within the last 3 months)
Upon seeing any form of ID, a representative from the Club will sign to say they have seen it, on what date and that any photo ID is a true likeness of the person requesting their data. Where you make more than one request in quick succession, we may respond to your subsequent request by referring to our earlier response and only identifying any items that have changed materially.
Please note that if requests are found to be manifestly unfounded or excessive, we reserve the right to charge a fee of £20.00, as permitted or refuse to respond. The purpose of the fee is to cover administrative costs.
Where we refuse to respond to a request, we will explain why to you, informing you of your right to complain to the supervisory authority.
This policy may change due to business needs or changes in legislation. To assist you, this Policy has an effective date set out below.
Effective date: 23rd May 2018 – Updated: September 2019
In the event of any inconsistencies between the English version of this policy and any version of this policy in any other language, the English version shall prevail (to the fullest extent permitted under applicable law).
Privacy Notice: for Bolton Wanderers’ FanLogic processing
FVWL FOOTBALL LIMITED t/a Bolton Wanderers Football and Athletic Company (BWFC) is the data controller and is a UK company with a registered address of University of Bolton Stadium, Burnden Way, Bolton, BL6 6JW, and registration number: 12090433
The GDPR defines personal data as “any information relating to an identified or identifiable natural person (’data subject’)” (Article 4(1)). It does not include data where the identity has been removed (anonymous data).
This notice covers only the processing by our commercial partner FanLogic (the registered trade name for Fan Data Pools Limited), of the personal data that we collect from fans who opt-in to our third party / commercial partners mailing list. The processing is permissible under the consent these fans have given relating to the purpose of our third party / commercial partners mailing list, which is ‘to alert you to information about events, surveys, competitions, offers, products, services and other exciting updates relating to us, and/or commercial partners’.
FanLogic will combine the personal data you have provided us (i.e. your name, email address, telephone number/s, address and date of birth) with other personal data (such as your lifestyle data) that you have already provided to public sources and is publicly available (such as research surveys, open data, government data), to provide you with rewards, special offers and promotions. Your personal data will be used only for these purposes and it will not be shared or disclosed to any anyone other than FanLogic’s appointed sub-processors (click here for the most up to date list).
FanLogic stores your personal data securely using suitable physical, electronic and managerial procedures, security measures and appropriate safeguards to prevent its unauthorised access, use or disclosure. It is stored in the UK and is not transferred to any countries outside the EU. It is kept and used only for as long as is necessary for the stated purposes and it is deleted when those purposes no longer apply and / or you withdraw your consent, which you may do at any time.
You have the right to request access to and rectification or erasure of your personal data; or restriction of the processing concerning it; and, you may object to its processing. You may ask for your data in a portable format, or for it to be transmitted to another company on your behalf. You also have the right, with certain exceptions, to be not subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. You may contact us to withdraw your consent to processing by FanLogic at any time and you also have the right to lodge a complaint with the supervisory authority (the UK’s Information Commissioner's Office (ICO), www.ico.org.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.
If you would like to know what personal data FanLogic holds about you or would like a copy of the data or to exercise any of your rights, please contact our Data Protection Officer as shown below. Please mark as ‘Subject Access Request’. We will respond to your request without delay and within one month.
You will not have to pay a fee to access your personal data (or to exercise any of your 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.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Address: Bolton Wanderers Football Club, University of Bolton Stadium, Burnden Way, Bolton BL6 6JW
We keep our privacy notice under regular review to ensure that it meets legal requirements, relevant guidance published by the ICO and industry standards. If we have to make any material changes to any of the above, we will inform you in advance of the proposed changes and seek your consent to the changes. Otherwise we reserve the right to make non-material changes to this notice at any time so it is strongly recommended that you check this notice often, referring to the date of the last update.