Brighton & Hove Albion

This privacy policy sets out how (The) Brighton and Hove Albion Football Club Limited (“we” or the “Club”) uses and protects your personal data.

The Club uses your personal data to allow you to use the features on this website, to administer your online and offline relationships with the Club, to manage the safety and security of our venues and events, to comply with the Club's legal obligations and to provide you with Club products, services and other offerings. Some of this information will be provided by you, and others will be generated by the Club or provided by third parties.

This privacy policy is provided in a layered format. More information on each section can be found below.

1. Important information and who we are – here you can find details of our full company name, address and how to contact our DPO.

2. The types of data we process about you – here you can find information on the categories of data we may process about you if you use this site and any of the services available on it.

3. How is your personal data collected? – here you can find information on how we collect data about you on this website. For example, this may be through interactions with you via this site, through automated means (e.g. website cookies) and/or via third parties collecting data on our behalf e.g. Seatgeek, our ticketing provider.

4. How we use your personal data and retention – here we set out the legal bases we are relying on when processing your personal data. This is a requirement of UK data protection legislation and our DPO can explain further if you have any questions.

5. Disclosures of personal data – here we set out the third parties that we may share your personal data with and the reasons for doing so.

6. International Transfers – not all countries have the same data protection requirements. Therefore before we share your personal data we are required to ensure that either that country’s requirements have been approved by the UK Government (called an ‘adequacy decision’) or that the necessary contractual protections are in place. Please see this section for more information or contact our DPO for more information.

7. Data Security – please see here for information on how we protect your personal data.

8. Data Retention – please see here for information on how long we will hold your personal data.

9. Your legal rights and complaints – we are required to inform you of your legal rights under UK law which are set out here. Additionally, if you wish to make a complaint about our processing of your personal data, you can find the details for the Information Commissioners Office.

10. Changes to the privacy policy and your duty to inform us of changes – please see here to understand our process for updating and reviewing this policy.

11. Third Party Links – this website contains third party links. Please see here for information on these.

1. Important information and who we are

This privacy policy gives you information about how (The) Brighton and Hove Albion Football Club Limited collects and uses your personal data through your use of this website, including any data you may provide when you register with us as a MyAlbion+ member, sign up to our newsletter, purchase a product via our retail site, tickets via our ticketing site and/or take part in a competition.

Controller

(The) Brighton and Hove Albion Football Club Limited (company no. 00081077) is the controller and responsible for your personal data (collectively referred to as "we", "us" or "our" in this privacy policy). Our address is: The American Express Stadium, Village Way, Falmer BN7 5SH.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights (paragraph 9), please contact the DPO at dataprotection@brightonandhovealbion.com or via the address above.

2. The types of personal data we collect about you

Personal data means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, last name, any previous names, username or similar identifier, marital status, title, date of birth and gender. If you attend any event at the American Express Stadium and/or at any other Club owned property, we may capture photos and video footage which features you.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data includes internet protocol (IP) address, your Single Sign On (SSO) login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you interact with and use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

purchase our products, tickets or services via our website;
create a MyAlbion+ account on our website;
subscribe to our newsletters or to receive other marketing material;
enter a competition, promotion or survey; or
give us feedback or contact us.

Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

Third parties or publicly available sources. We will receive personal data about you from various third parties

Technical Data is collected from the following parties:
analytics providers such as Google Analytics and HotJar which are based outside of the UK; and
UserWay regarding your accessibility settings that you have activated on the site.

Contact, Financial and Transaction Data is collected from providers of technical, payment and delivery services that you use when purchasing products from our online retail or ticketing sites.

4. How we use your personal data

Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose/Use	Type of data	Legal basis and retention period
To register you as a new customer for either ticket or retail purchases through the website	(a) Identity (b) Contact	Performance of a contract with you We will retain this data for the period that your actively use your account. If your account remains inactive for a period of three years then your account will be closed and the personal data will be deleted.
To process and deliver your order for our products or tickets purchased through this website including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) (c) Consent (in respect of marketing communications) We will retain transaction data for seven years from the date of your last transaction.
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Dealing with your requests, complaints and queries	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and manage our relationship with you We will retain this data for the period that your actively use your account. If your account remains inactive for a period of three years then your account will be closed and the personal data will be deleted.
To enable you to partake in a prize draw, competition or complete a survey	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) We will retain this data for a period two years.
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation We will retain this data for a period of two years.
To deliver relevant website content and online advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) We will retain this data for the period that your actively use your account. If your account remains inactive for a period of three years then your account will be closed and the personal data will be deleted.
To use data analytics to improve our website, products/services, customer relationships and experiences and to measure the effectiveness of our communications and marketing	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) We will retain this data for a period of three years from the date it is collected.
To send you relevant marketing communications and make personalised suggestions and recommendations to you about goods or services that may be of interest to you based on your Profile Data	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	Consent, having obtained your prior consent to receiving direct marketing communications We will retain this data for the period that your actively use your account. If your account remains inactive for a period of three years then your account will be closed and the personal data will be deleted.
To carry out market research through your voluntary participation in surveys	Identity Contact (e) Profile	Necessary for our legitimate interests (to study how customers use our products/services and to help us improve and develop our products and services). We will retain this data for a period of three years from the date it is collected.

Direct marketing

During the MyAlbion+ process on our website when your personal data is collected, you will be asked to indicate your preferences for receiving direct marketing communications from (The) Brighton and Hove Albion Football Club Limited via email.

We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

Third-party marketing

We will get your express consent before we share your personal data with any third party (e.g. one of our sponsors or partners) for their own direct marketing purposes.

Opting out of marketing

You can ask to stop sending you marketing communications at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to order confirmations regarding your ticket or a product that you have purchased via our retail site, updates to our Terms and Conditions, checking that your contact details are correct or that you would like your account to remain active after a period of inactivity.

For more information about the cookies we use and how to change your cookie preferences, please see https://shop.brightonandhovealbion.com/page/cookiepolicy

5. Disclosures of your personal data

We may share your personal data where necessary with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.

KORE – for management of your MyAlbion+ account.
Gemba – for creating statistics and anonymised information regarding the use of our website and services.
YinzCam – operate our website and mobile application. They therefore process your Identity, Contact, Profile, Usage and Technical information on our behalf.
SeatGeek – for ticketing purchases, managing your season ticket and hospitality tickets.
The FA, Premier League, UEFA and/or opposition clubs – we may be required to send Identity information pursuant to football regulations the Club is subject to and/or to facilitate you receiving away tickets to football matches.
Google Analytics and HotJar – your Usage data and your IP address is shared so we can better understand individuals use of our website.
Google Ads – your Usage data and IP address is shared with Google Ads if you agree to advertising cookies on our website.
Meta (Facebook and Instagram) and X – our websites may provide interactive features that engage with social media sites, such as Facebook, Instagram and X. If you agree to advertising cookies on our website, your Usage data and IP address may be shared with Meta and X to tailor advertising to you.
StreamAMG – Technical data will be collected when you interact with a video player on our site.
UserWay.org – accessibility function on the website.
Police – your Identity information may be shared with the police in the event that we are requested information about an incident and/or we need to report an incident involving you to the police.
Payment providers - We will share your personal data with our payment providers, merchants and 3D-Secure Services for fraud prevention purposes when you make purchases through this website.
Our commercial partners – subject to your prior consent, we may share your Identity and Contact information with our commercial partners for marketing purposes.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law.

Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place:

We will only transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data as specified by the UK Government.
We may use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely The International Data Transfer Addendum to the European Commission’s standard contractual clauses for international data transfers. To obtain a copy of these contractual safeguards, please contact us at dataprotection@brightonandhovealbion.com.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see paragraph 9 below for further information.

In some circumstances we will 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.

9. Your legal rights

You have a number of rights under data protection laws in relation to your personal data.

You have the right to:

Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see ‘Opting out of marketing’ in paragraph 4 for details of how to object to receiving direct marketing communications).
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data (see the table in section 4 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. 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.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
If you want us to establish the data's accuracy;
Where 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.

If you wish to exercise any of the rights set out above, please contact us at dataprotection@brightonandhovealbion.com

What we may need from you

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.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (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.

10. Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 17 July 2024.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

11. Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

App Privacy Policy

(The) Brighton and Hove Albion Football Club Limited (we) are committed to protecting your personal data and respecting your privacy.

Introduction

This policy applies to our collection of your personal data through your use of Brighton and Hove Albion Football Club App (which was last updated on 17 July 2024) mobile application software (App), once you have downloaded onto your mobile telephone or handheld device (Device).

Any of the services accessible through the App (Services) that are available on the App. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. This App is not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

Important information and who we are

(The) Brighton and Hove Albion Football Club Limited is the controller and is responsible for your personal data (collectively referred to as "we", "us" or "our" in this policy).

We have appointed a data protection officer (DPO). If you have any questions about this privacy policy, please contact them using the details set out below.

Contact details

Our full details are:

Full name of legal entity: (The) Brighton and Hove Albion Football Club Limited
Address: American Express Stadium, Village Way, Brighton, East Sussex, BN1 9BL
Email address: dataprotection@brightonandhovealbion.com

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

This version was last updated on 18 July 2024. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you by email and/or when you next start the App. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

Third party links

Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.

The data we collect about you

We may collect, use, store and transfer different kinds of personal data about you as follows:

Identity Data.
Contact Data.
Financial Data.
Transaction Data.
Device Data.
Content Data.
Profile Data.
Usage Data.
Marketing and Communications Data.
Location Data

We also collect, use and share Aggregated Data such as statistical or demographic data to personalise marketing and the appearance of the App.

Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this 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). Nor do we collect any information about criminal convictions and offences.

How is your personal data collected?

We will collect and process the following data about you:

Information you give us. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us about you by filling in forms on the App Site and the Services Sites (together Our Sites), or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the App Site, download or register an App, subscribe to any of our Services, search for an App or Service, share data via an App's social media functions, and when you report a problem with an App, our Services, or any of Our Sites. If you contact us, we will keep a record of that correspondence.
Information we collect about you and your device. Each time you visit one of our Website (www.brightonandhovealbion.com) or use one of our Apps we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies. Please see our cookie policy here for further details.
Location Data. We also use GPS technology to determine your current location when using the App, including (but not limited to determine your location within the American Express Stadium). Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings.
Information we receive from other sources including third parties and publicly available sources. We will receive Device Data from analytics providers from our App provider, YinzCam and Google, both of which are based outside the UK.

We use cookies and/or other tracking technologies to distinguish you from other users of the App, Website, the distribution platform (Appstore) and to remember your preferences. This helps us to provide you with a good experience when you use the App or browse any of Our Sites and also allows us to improve the App and Our Sites.

For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy.

How we use your personal data

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

Where you have consented before the processing.
Where we need to perform a contract we are about to enter or have entered with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Where we need to comply with a legal or regulatory obligation.

We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Purposes for which we will use your personal data

Purpose/activity	Type of data	Lawful basis for processing
To install the App and register you as a new App user	Identity Contact Financial Device	Your consent
To process in-App purchases and deliver Services including managing payments and collecting money owed to us	Identity Contact Financial Transaction Device Marketing and Communications Location	Your consent Performance of a contract with you Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you including notifying you of changes to the App or any Services	Identity Contact Financial Profile Marketing and Communications	Your consent Performance of a contract with you Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services) Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)
To administer and protect our business and this App including troubleshooting, data analysis and system testing	Identity Contact Device	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)
To deliver content and advertisements to you To make recommendations to you about goods or services which may interest you To measure and analyse the effectiveness of the advertising we serve you To monitor trends so we can improve the App	Identity Contact Device Content Profile Usage Marketing and Communications Location	Consent Necessary for our legitimate interests (to develop our products/Services and grow our business)

Disclosures of your personal data

When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out:

KORE – for management of your MyAlbion+ account.
Gemba – for creating statistics and anonymised information regarding the use of our website and services.
Google Ads – your Usage data and IP address is shared with Google Ads if you agree to advertising cookies on our website.
Google Analytics and HotJar – your Usage data and your IP address is shared so we can better understand individuals use of our website.
Meta (Facebook and Instagram) and X – our App may provide interactive features that engage with social media sites, such as Facebook, Instagram and X. If you agree to advertising cookies on our App, your Usage data and IP address may be shared with Meta and X to tailor advertising to you.
YinzCam – operate our website and mobile application. They therefore process your Identity, Contact, Profile, Usage and Technical information on our behalf.

International transfers

Many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
Where we use certain service providers, we may use specific contracts approved by the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

Data security

All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our App (e.g. MyAlbion+ membership), you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

We will collect and store personal data on your Device using application data caches and browser web storage (including HTML5) and other technology.

When using certain services include social networking, chat room or forum features please ensure that you do not submit any personal data that you do not want to be seen, collected or used by other users.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

Data retention

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

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see ‘Your legal rights’ below for further information.

Your legal rights

Under certain circumstances you have the following rights under data protection laws in relation to your personal data.

Please see below to find out more about your rights in respect of:

Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer or your personal data.
Right to withdraw consent.

You also have the right to ask us not to continue to process your personal data for marketing purposes.

You can exercise any of these rights at any time by contacting us at dataprotection@brightonandhovealbion.com

Glossary

Lawful basis

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Third Parties

KORE – for management of your MyAlbion+ account.
Gemba – for creating statistics and anonymised information regarding the use of our website and services.
YinzCam – operate our website and mobile application. They therefore process your Identity, Contact, Profile, Usage and Technical information on our behalf.
Google Analytics and HotJar – your Usage data and your IP address is shared so we can better understand individuals use of our website.
Google Ads – your Usage data and IP address is shared with Google Ads if you agree to advertising cookies on our website.
Meta (Facebook and Instagram) and X – our App may provide interactive features that engage with social media sites, such as Facebook, Instagram and X. If you agree to advertising cookies on our App, your Usage data and IP address may be shared with Meta and X to tailor advertising to you.

Your legal rights

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
if you want us to establish the data's accuracy;
where 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 the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. 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.

Description of categories of personal data

Identity Data: first name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender.
Contact Data: billing address, delivery address, email address and telephone numbers.
Financial Data: bank account and payment card details if you make a purchase via this App.
Transaction Data: includes details about payments to and from you and details of in-App purchases.
Device Data: includes the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting.
Content Data: includes information stored on your Device, including login information, photos, videos or other digital content, check-ins, other information you input via the App.
Profile Data: includes your username and password, in-App purchase history, your interests, preferences, feedback and survey responses.
Usage Data: includes details of your use of any of our Apps or your visits to any of Our Sites including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Location Data: includes your current location disclosed by GPS technology.