When does this policy apply?
LTFC's websites and services include:
- The Official Luton Town FC website at www.lutontown.co.uk;
- The Luton Town Football Club Official Online Store at www.hattersworld.com;
- The Luton Town Football Club Online Ticket Office at https://www.eticketing.co.uk/lutontown
- iFollow Hatters at https://www.lutontown.co.uk/ifollow/
- The official Luton Town FC social media pages on Facebook, Twitter, Instagram and YouTube;
(together the "LTFC Official Websites")
- The Luton Town Club shop at Kenilworth Road, Luton
- The Luton Town Club shop in The Mall, Luton
You can contact the data protection officer using the details set out below:
What types of personal data do we hold?
Information we hold about you may include any one or more of the following types of data.
When you register to use, purchase or engage with any of LTFC's goods and/or services, the minimum information we will usually ask you to provide is your name, email address, country of residence, telephone number, and year of birth. We may also ask you for additional information depending on the nature of our interaction with you.
When you purchase tickets (including where tickets are purchased through LTFC's official third party ticketing provider from time-to-time), merchandise and other products from LTFC Official Websites or any other official offline sales channels, we will keep a record of your transaction, including what you purchased and when, and any information you provide to us to fulfil the transaction. This may include your name, billing information, telephone number, and delivery address. We will not keep payment card information, except for the last four digits of your payment card number which we keep in case there are any payment disputes or we need to issue a refund. We will ensure that, when handling any information about you relating to a transaction, we comply with the applicable regulations of the Payment Card Industry.
Information you provide to us in response to a survey:
We may occasionally contact you to ask for your feedback on LTFC products, goods and/or services so that we can make them better and more relevant.
Information you provide to us to take part in a competition or Club engagement activation (Half-Time Hot Shots or Happy Harry's Lunch Bags for example:
We may occasionally run competitions via our website or social media channels, which require you to provide personal data, allowing us to process the competition and contact winners, runners up or other participants.
Information you provide to us in response to a job advertisement:
We regularly advertise open positions on the recruitment page of our website which you may apply for by sending your CV to the email address provided on that page.
Information you post online:
We may hold and use information and/or user generated content which you post on LTFC Official Websites or other digital services, including information about your IP address, location and click history.
Information from other companies:
We may use publicly available postal address lists and the edited electoral roll to ensure that the information we hold about you is accurate or we may use this information, together with general market research information (for example, demographic information), to add to and enhance our fan database.
Online usage information:
In most cases, you are not obliged to provide any personal data to us, but in some cases we may not be able to provide goods or services to you unless you provide certain minimum information. By way of example only, where you intend to make a purchase from LTFC, we may need to obtain and process certain information about you in order to enter into and perform the contract of sale with you.
The purposes for which we use your information
The legal basis under which LTFC will process your personal data is one or more of the following:
- To allow us to enter into and/or perform our contract with you*;
- To enable us to comply with legal obligations**;
- To pursue legitimate interests of our own or those of third parties (provided that your interests and fundamental rights do not override those interests) ***; and/or
- With your consent.****.
Further details of how we will process your personal information are listed below. We have indicated by asterisks the legal basis on which we are processing or will process your personal information.
Contract performance* / **:
LTFC may use account information and transactional information data, as necessary, to carry out or perform any contract which you may have entered into with us, including contracts for the purchase of tickets, merchandise and other products, but also our contracts with you when we operate competitions, prize draws and promotions and when we administer your online accounts and provide services to you. We also use this information to communicate with you and handle your enquiries regarding these contracts. If you order LTFC goods, products or services for another person (for example, match tickets for family or friends) we may ask you for their personal information and we will use this to provide the services you have ordered. Please ensure that you have their permission for us to process this data before providing it to LTFC.
LTFC retains records of all of its financial transactions with you in order to comply with its legal obligations to maintain adequate accounting records. LTFC may use (and disclose) the information it holds about you in order to comply with any investigative demand, court order, or a request for cooperation from a law enforcement or other government agency.
If you apply for a job with LTFC or if you volunteer with the Club or contact us in relation to potential roles which may arise in the future, we may use your information for the purposes of recruitment and selection, corresponding with you and for equal opportunities monitoring.
Marketing with your consent (where consent is necessary)****:
If you have consented to it (where consent is necessary) LTFC may contact you electronically with news and offers from LTFC, its affiliates and its official sponsors and partners (an up-to-date list of which is at https://www.lutontown.co.uk/commercial/sponsors) which we think may be of interest to you. You have the right to withdraw your consent at any time, using the link to the preference centre at the bottom of emails sent to you.
Telephone and postal marketing***
Further, we may call you (unless you have registered with the Telephone Preference Service or you have otherwise asked us not to contact you) or send you materials through the post (unless you have registered with the Mail Preference Service or you have otherwise asked us not to contact you) in relation to offers from the Club or its partners.
LTFC will analyse information it holds about you to identify trends and preferences about its customers and to get a more detailed and informed picture of how its customers are using LTFC's products and services. We do this to make better strategic decisions about LTFC and its products and services so that we can improve the way we market and provide products and services to you and LTFC supporters generally. LTFC may also use online usage information about you to administer and improve the function and content of the LTFC Official Websites, including to ensure that content is presented in the most effective manner for you and your device and browser, to allow you to participate in interactive features when you choose to do so and to keep our online services safe and secure. LTFC may also use the information it holds about you if required to protect the rights, property, or safety of LTFC, our fans, customers or others.
LTFC will not carry out any automated decision-making using information it holds about you.
Disclosure of your information
Affiliates: Information held by LTFC may be used by affiliates of LTFC for the purposes set out in this policy, where you have consented to this. Our affiliates include the Luton Town Community Trust. This may include providing them with your personal information so that they can provide you with information about their products and services that may interest you, where you have consented to this.
Sponsors and partners:
LTFC does not share your personal data with our sponsors and partners, but we may: (i) share aggregate/anonymised information which is based on this information with existing and potential sponsors and partners; and (ii) if you have consented to the same, send you information about the products and services of our partners and sponsors in our marketing communications.
LTFC suppliers and sub-contractors:
Disclosures for legal reasons:
LTFC may also disclose the information it holds about you to those persons that have a reasonable need to know such information, if it believes in good faith that this is necessary: (i) to establish, exercise or enforce its legal rights, including contractual rights; (ii) to defend itself against a legal claim; (iii) report a crime or prevent a crime (for example, ticket touting); (iv) to prevent harm to any individual or any property (including intellectual property, for example if you misuse images or videos or any other content LTFC makes available to you); (iv) to satisfy our statutory and/or regulatory obligations relating to safeguarding; or (v) to prevent fraud (for example, payment card fraud) or for credit risk reduction.
If LTFC sells or buys any business or assets, your personal data may be disclosed to the prospective seller or buyer of such business or assets so that they can carry out due diligence in respect of the sale or purchase, but only if LTFC has taken reasonable steps to ensure the security and confidentiality of that information. If LTFC (or substantially all of its assets) is acquired by a third party, personal data held about fans or users of its goods, products or services will be one of the transferred assets.
How do we keep your information secure?
LTFC is committed to ensuring that your information is secure. In order to prevent un-authorised access or disclosure of personal data, we have put in place appropriate physical, electronic and managerial procedures to safeguard and secure the information we collect. We regularly perform testing of these procedures and have an appropriate information recovery and data breach procedures in the event that we encounter any difficulties.
How long do we keep your information?
LTFC will retain your personal data for as long as necessary for the purposes it is collected as set out in this policy and for any longer period necessary for it to comply with statutory retention obligations and/or for the purposes of defending or making legal claims. Examples of some of our retention periods are set out below:
LTFC Ticket Office and Club shops:
- its financial transactions with you for six years in order to comply with its obligations to maintain adequate accounting records;
- its contracts with you for six years so that it has appropriate evidence in place if there is a claim for breach of contract made within the statutory limitation periods;
- job applications and CVs for up to six months, unless you have consented to your details being held on file in case other suitable opportunities arise;
- your account information until you close or delete your account/profile (at which point we would also delete any information from other companies or market research which we have appended to your account/profile);
- any market research we have undertaken (and which is not appended to your user account) for 3 years. Note that we will retain aggregated market research information (by which you cannot be identified) on an ongoing basis for internal purposes; and
- save as set out above, information you post online and/or online usage information for 3 years if it is on LTFC Official Websites.
If any information falls into more than one category then the longer storage period will apply.
You have several rights under applicable data protection laws (unless an exemption applies), which we have summarised below. These rights can be exercised by contacting LTFC using the details given below in this policy.
You have the right to:
- ask us not to process your personal data for direct marketing purposes;
- request access to personal information held about you and a copy of it;
- obtain, without undue delay, the rectification of inaccurate or incomplete personal data;
- obtain, without undue delay, erasure of your personal data in certain circumstances, for example if LTFC's processing of your personal data is no longer necessary for the purpose for which we collected it;
- restrict the processing of your personal data in certain circumstances rather than having it erased;
- object to the processing of, personal data in certain circumstances;
- receive personal data, which you have provided to LTFC, in a structured, commonly-used and machine-readable format and transmit that personal data to another data controller, or have LTFC do so on your behalf where technically feasible;
- be informed about any use of your personal data to make automated decisions about you, and to obtain meaningful information about the logic involved, as well as the significance and the envisaged consequences of this processing; an
- lodge a complaint about the way in which your personal data is being used to a supervisory authority.
Parental consent / supervision
Our business and the competitions, products and services we provide from time-to-time are not specifically targeted at children, but we appreciate that many children are fans of football and/or sport generally. We would therefore ask that parents and guardians supervise their children when they are online and that children under 18 do not submit personal information or content to LTFC, make purchases of LTFC goods, products or services, or take part in LTFC promotions or competitions, without the consent of their parent or guardian. LTFC reserves the right to take reasonable measures in order to verify the existence and/or validity of parental consent.
How you can contact us?
If you would like to contact LTFC about this policy or any of the legal rights outlined in it, you can contact us by email at firstname.lastname@example.org or write to LTFC at Kenilworth Stadium, 1 Maple Road East, Luton LU4 8AW. In either case, your correspondence should be marked for the attention of the Data Protection Officer.