JACKSONVILLE JAGUARS UK PRIVACY NOTICE
APPLICABLE TO ITS UK OPERATIONS
Last revised June 2022
When does this Privacy Notice apply?
When we talk about “personal data”, we mean any information which relates to an identified or identifiable living individual. Individuals might be identified by reference to a name, an identification number, location data, an online identifier (such as an IP address) or to other factors that are specific to them, such as their physical appearance. Jaguars’ websites and services include-
– The official Jaguars UK Website at www.jaguars.co.uk;
– The official Jaguars UK social media pages on Facebook, Twitter, Instagram, Snapchat and YouTube (“Social Media Platforms”); and
– Any future official Jaguars UK mobile application(s) and/or websites developed and launched by Jaguars;
(together the “Jaguars UK Official Websites“)
What types of personal data do we hold and how do we collect and receive personal data?
Information we hold about you may include any one or more of the following types of data-
- Personal data you provide to us-
Account information- When you register to use, purchase or engage with any of Jaguars’ goods and/or services, the minimum information we will usually ask you to provide is your name, email address, post code and country of residence. We may also ask you for additional information depending on the nature of our interaction with you.
Transactional information- When you purchase tickets (including where tickets are purchased through the NFL and/or through Jaguars’ or the NFL’s official third party ticketing provider from time-to-time), merchandise and other products from Jaguars UK 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 Jaguars or NFL products, goods and/or services so that we can make them better and more relevant. We will process feedback and survey responses and the content of any communication from you to us.
Marketing preferences and communications data- We may collect information about your marketing preferences, including where you opt in on the Jaguars UK Official Websites and your service communication preferences.
Information you provide to us in response to a job advertisement- We may advertise open positions on the Recruitment page of our website which you may apply for by sending your CV to the email address provided. We use your name, email address and telephone number and we will process any personal data about you that you volunteer, including during any interview, when you apply for a position with us. We may also process your personal data obtained from any third parties we work with in relation to our recruitment activities, including without limitation, recruitment agencies, background check providers, credit reference agencies and your referees. The personal data we process may include your contact details, details of your education, qualifications and employment history, any other personal data which appears in your CV or application, any personal data that you volunteer during an interview or your interactions with us, or any personal data which is contained in any reference about you that we receive. Such information may also include special categories of personal data (such as information about your health, any medical conditions and your health and sickness records) and information relating to criminal convictions and offences if that information is relevant to the role you are applying for.
Information you provide to us in order to take part in an activity or an event- In order to take part in an activity operated by Jaguars you may need to provide data such as your name, date of birth, address, ethnicity, sex and relevant medical information. We will also collect data on attendance and performance.
In addition, we may collect your data if you attend an event organised by Jaguars, including matches, training sessions or events held at the Wembley Stadium, or matches training sessions or events held at other locations in the United Kingdom. This will include name, email address, post code and contact number.
Information you provide when you are providing us with products or services- When you provide us with goods or services we may collect your name, email address and contact number and any other personal data you volunteer which is relevant to our relationship with you or the organisation you represent.
- Personal data we collected using cookies and other similar technologies
Information you post online- We may hold and use information and/or user generated content which you post on Jaguars UK Official Websites, including information about your IP address, location and click history.
To ensure that our App can operate properly and provide you with the features you want, the provider of your mobile device may collect certain Technical Data. The data is automatically collected and transmitted to us from your device during your use of the App, (“Usage Data”) and includes- (i) device name (e.g. “Apple iPhone” or “Samsung Galaxy” or any other name that you have given your device); (ii) operating system and version; (iii) system language; (iv) general device data, such as voice and regional settings; (v) IP address of the device; (vi) date and time of use; and (vii) application ID to identify your installation of the App.
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.
If you fail to provide your personal data
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 Jaguars, 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 Jaguars 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.
|Description (as further described in the What types of personal data do we hold and how do we collect and receive personal data section above)
|Jaguars 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 Jaguars 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 Jaguars.
|To allow us to enter into and/or perform our contract with you;
To enable us to comply with legal obligations
Our legitimate interest to ensure that we are able to help you with your enquiry, provide a good standard of service and improve our customer services
|Where we have a legal obligation to process your personal data
|Jaguars retains records of all of its financial transactions with you in order to comply with its legal obligations to maintain adequate accounting records.
Jaguars may use (and disclose if required) 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.
|To enable us to comply with legal obligations
|For recruitment purposes
|If you apply for a job with Jaguars or if you volunteer with the Jaguars or contact us in relation to potential roles which may arise in the future, we may use your personal data to communicate with you about the recruitment process and to comply with our legal and regulatory obligations in relation to recruitment.
We also use your personal data for the purposes of reviewing our equal opportunity profile in accordance with applicable legislation. We do not discriminate on the grounds of gender information for the purposes of recruitment and selection, corresponding with you and for equal opportunities monitoring.
|In connection with us taking steps at your request to enter into a contract we may have with you; or
Our legitimate interest to use personal data in such a way to ensure that we can make the best recruitment decisions.
We will not process any special (or sensitive) categories of personal data or personal data relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent.
|Sending marketing communications
|Jaguars may process your personal data in order to contact you electronically with news and offers from Jaguars, its affiliates and its official sponsors, media partners, and partners (an up-to-date list of which is at www.jaguars.co.uk) which we think may be of interest to you.
Our marketing communications will include non-personalised marketing. Non-personalised marketing, while addressed to you, is marketing that is not tailored to you.
If we have collected your consent to send you marketing communications (where consent is necessary) you have the right to withdraw your consent at any time, by writing us at Union Jax, LLC, 8th Floor, 30 Panton Street, London SW1Y 4AJ, Attention- Marketing.
Our legitimate interest to use your personal data for marketing purposes
|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 Jaguars or its sponsors, media partners or partners, or to notify you of a prize you may have won.
|Our legitimate interest to send you marketing communications;
Our legitimate interest to use your personal data to enable us to administer our promotion fairly and effectively and to ensure that we comply with self-regulatory codes governing the operation of promotions;
To perform our obligations in accordance with any contract that we may have with you (e.g. the promotion terms and conditions)
|Jaguars 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 Jaguars’ products and services. We do this to make better strategic decisions about Jaguars and its products and services so that we can improve the way we market and provide products and services to you and Jaguars supporters generally.
|Our legitimate interests to carry out analysis to understand the effectiveness of our business and in order to make strategic decisions
|Ensuring the proper functioning of the Jaguars UK Official Websites
|Jaguars may also use online usage information about you to administer and improve the function and content of the Jaguars UK 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.
|If you use our App and associated features and functionality
|Our App may send us (or our IT suppliers) an error message in the event of a crash or other error (e.g. after the App has unexpectedly quit because of a program error or has stopped responding to your input). The error message contains IP address; browser type and operating system; geolocation, to ensure we’re showing you the correct notices and information; any other unique numbers assigned to a device and information about which part of the App’s software code has caused the error. This information helps us understand the cause of the error so that we can develop a fix to prevent that error from reoccurring and therefore improve the App for all users.
When you open the App for the first time, you may be asked for permission to send you push notifications. If you allow this feature, our App will send you push notifications, for example, reminders, alerts, updates and other information. You can configure and turn off push notifications via your device settings at any time. You can also select the exact notifications you would like to receive using the in-app settings.
If you permit location settings, you will be asked if the App is allowed to access your location. If you allow this feature, we will determine your location to provide you with site-specific functions, like showing you which of our locations are close to you. You can configure and turn location settings off via your device settings at any time.
If certain features require access to your camera or microphone, or photo and videos, or your phone contacts, you will be asked if you want to use this function and provide such access before using it for the first time. You can enable or disable access to these functions at any time via your device settings.
|Our legitimate interest to use your data and send error messages (if applicable) in such a way in order to secure our App and to detect and resolve errors and cyberattacks;
Consent, where you have enabled features such as push notifications, location, camera, microphone, or photo and video upload functions, as it will be your choice to receive such notification or allow us access to this information.
|If you link to the Social Media Platforms and interact with our social media pages
|We will process your personal data if you interact with our social media pages on the Social Media Platforms.
|Our legitimate interest to use personal data to ensure that we provide the Jaguars UK Official Websites in an effective way and to promote the Jaguars UK Official Websites via social media
|Business administration and legal compliance
|Jaguars may also use the information it holds about you if required to protect the rights, property, or safety of Jaguars, our fans, customers or others.
We may use your personal data- (i) to comply with our legal obligations; (ii) to enforce our legal rights; (iii) to protect the rights of third parties; and (iv) in connection with a business transition such as a merger, reorganisation, acquisition by another company, or sale of any of our assets.
|Our legitimate interest to use your personal data in connection with a business transition, to enforce our legal rights or to protect the rights of third parties;
|Receipt of products and services from our suppliers
|If we have engaged you or the organisation you represent to provide us with products or services (for example, if you or the organisation you represent provide us with services such as IT support or financial advice), we will collect and process your personal data in order to manage our relationship with you or the organisation you represent, to receive products and services from you or the organisation you represent and, where relevant, to provide our products and services to others.
|Performance of a contract that we may have with you or the organisation you represent;
Our legitimate interest to use personal data in such a way to ensure that we have an effective working relationship with you or the organisation you represent and are able to receive the products and services that you or your organisation provides, and provide our products and services to others, in an effective way.
Jaguars will not carry out any automated decision-making using information it holds about you.
When you open emails from us, we may receive a confirmation notifying us that you opened the email, if your computer supports such capabilities. We also may keep track of what emails we send you and what emails you may be receiving from our affiliates. Additionally, we keep a record of what communications you have selected to receive or not to receive. If you would like to opt-out of receiving such emails, please click on the “unsubscribe” link in the email and follow the instructions.
Disclosure of your information
Affiliates- Information held by Jaguars may be used by affiliates of Jaguars for the purposes set out in this policy, where you have consented to this. Our affiliates include Fulham Football Club, Fulham Football Club Foundation, and those businesses which share common ownership with Jaguars. 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.
Third party event organisers- Where you attend an event hosted at Jaguars but organised by a third party (for example leagues or regulatory bodies such as the NFL, Jaguars’ affiliate, Fulham Football Club, or third party vendors generally), Jaguars may share your data with the relevant parties for use in relation to the event.
Sponsors and partners- Jaguars 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.
Third-party suppliers who assist us in administering our promotions- We share personal data with specialist suppliers who assist us in administering our prize draws, prize competitions and other promotions.
Auditors, lawyers, accountants and other professional advisers- We share personal data with professional services firms who advise and assist us in relation to the lawful and effective management of our organisation and in relation to any disputes we may become involved in.
Disclosures for legal reasons- Jaguars 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 Jaguars 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.
Business transfer- If Jaguars 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 Jaguars has taken reasonable steps to ensure the security and confidentiality of that information. If Jaguars (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.
Regulatory compliance- As above, Jaguars will be a member of the NFL. As such, Jaguars is subject to the rules and regulations of the NFL. Jaguars may disclose personal information about you to the NFL where this is required for the purposes of complying with those rules and regulations. The NFL will respect the security of your personal data and treat it accordance with the applicable law. Further information about the NFL’s use of personal data can be found in the NFL International privacy notice at- http- //www.nfluk.com/privacy.html.
How we obtain your consent
Where our use of your personal data requires consent, you can provide such consent at the time we collect your personal data following the instructions provided, or by informing us using the contact details set out in the “How can you contact us” section below.
Transfers outside the UK and European Economic Area (EEA)- Where necessary to provide our services your information may be transferred to or accessed outside of the UK and or EEA, including to our Jaguars’ affiliate, Jacksonville Jaguars LLC, who is based in the USA.
Non-EEA countries do not have the same data protection laws as the UK and the EEA. In particular, non-EEA countries may not provide the same degree of protection for your personal data, may not give you the same rights in relation to your personal data and may not have a data protection supervisory authority to help you if you have any concerns about the processing of your personal data. However, when transferring your personal data outside the UK or the EEA, we will comply with our legal and regulatory obligations in relation to your personal data, including having a lawful basis for transferring personal data and putting appropriate safeguards in place to ensure an adequate level of protection for the personal data. We will take reasonable steps to ensure the security of your personal data in accordance with applicable data protection laws.
Where data is transferred to Jacksonville Jaguars, LLC, your information will only be transferred for the internal purposes of Jaguars and will not be used for marketing unless you have consented to this. Where we use certain service providers and where data is transferred to Jacksonville Jaguars, LLC we may use specific contracts approved by the European Commission and the UK government which give personal data the same protection it has in Europe. For further details, see https- //ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en
How do we keep your information secure?
Jaguars 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?
Jaguars 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-
– its financial transactions with you for seven years in order to comply with its obligations to maintain adequate accounting records;
– its contracts with you for seven 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 Jaguars UK Official Websites, subject to internet system caches in the ordinary course.
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 Jaguars 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 Jaguars’ 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 Jaguars, in a structured, commonly-used and machine-readable format and transmit that personal data to another data controller, or have Jaguars 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; and
- lodge a complaint about the way in which your personal data is being used to a supervisory authority. If you have a concern about any aspect of our privacy practices, including the way we have handled your personal data, please contact us using the contact details provided in the “How can you contact us” section below. You can also report any issues or concerns to a national supervisory authority in the Member State of your residence or the place of the alleged infringement. You can find a list of contact details for all EU supervisory authorities at http- //ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
As we are incorporated in the United Kingdom, our regulatory authority is the Information Commissioner’s Office (“ICO”). Contact details for the ICO can be found on its website at https- //ico.org.uk.
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 Jaguars, make purchases of Jaguars goods, products or services, or take part in Jaguars promotions or competitions, in each case, without the consent of their parent or guardian. Jaguars reserves the right to take reasonable measures in order to verify the existence and/or validity of parental consent. If we discover that we are holding the personal data of a minor, we will delete that information as soon as possible. Please contact us if you have reason to believe that a minor may have submitted personal data to us (see the “How can you contact us?” section below).
Links to other websites
Third party app stores
If you wish to download and install our App from an app store (such as Google Play or the Apple AppStore), you must first register with the provider of the respective app store), for a user account and agree to that app store’s user agreement. We have no influence on the terms of such user agreement and are not a party to such user agreement. When downloading and installing one of our Apps, certain information is transmitted to the respective provider of the app store (e.g. Google or Apple) including your username, your email address and the customer number of your account, the time of download and the individual device code and, in the case of in-app purchases, your payment information. We have no influence on this process and are not responsible for you downloading and installing our App on your mobile device.
In the event that all or substantially all of our assets are sold or transferred to another party, or another transaction occurs in which your personally identifiable information is one of the business assets transferred, all personally identifiable information that has been collected and saved may be one of the business assets we transfer. You will be notified of such a transfer in accordance with the “Changes to the Policy” section below.
How you can contact us?
If you would like to contact Jaguars 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 Jaguars at Union Jax, LLC, 8th Floor, 30 Panton Street, London SW1Y 4AJ. In either case, your correspondence should be marked for the attention of the Senior Information Officer.