PRIVACY POLICY - APP
The mobile application is a service provided through Futbol Club Andorra SAOE (hereinafter, the "Club"). Therefore, the personal data you provide to access and, where appropriate, register on the mobile application (hereinafter, "APP") will be processed by the Club as data controllers.
Who is responsible for the processing of your personal data?
Your personal data will be processed by FC Andorra, with NIF: A-713653-Z and address at C/Pau Casals 6, 2n 2ª, AD500 Andorra la Vella, which is a Sports Limited Company.
Contact the Club's Data Protection Officer: Albert Pedret Llucià
Where do we get your personal data?
The Club will process the data you provide through the registration form (email as mandatory) and other data inferred as a result of the use and activity you carry out on the APP, identifiers to be able to provide the services offered through it, such as the registered user ID, Device ID and Advertising ID (Mobile Advertising ID (MAID- on Android and IDFA or IDFV on iOS), operating system, device model and telemetry, for example, will also be recorded when you click on a certain content or the time you stay on the asset) or your interactions with the communications we send you via push notification, In-App or Mail, if applicable (e.g., clicking on the content of a communication).
Finally, we inform you that, in the iOS version of the APP, Apple will ask for your permission to use your device's advertising identifier ("IDFA") for any of the purposes that require it, in accordance with the section For what purpose do we process your personal data? of this Privacy Policy.
Data shared through LALIGA:
We inform you that, if you are a LALIGA user, you can use your account to register:
- Email address (Required for registration)
- First name (Optional)
- Last name (Optional)
- Phone number (Optional)
- Birthday (Optional)
- Gender (Optional)
- City (Optional)
- State (Optional)
- Country (Optional
For what purpose do we process your personal data?
Main purposes:
The Club undertakes to process your personal data in accordance with the provisions of the applicable regulations and, in particular, for the following purposes:
- Registration and access to the APP: We inform you that the personal data you provide when registering will be processed by the Club for the purposes of facilitating your registration and access to the APP. In particular, the Club will use your email address and user ID to fulfil this purpose.
In this regard, we inform you that the Club, in order to verify the validity of the email provided to register you in the APP, uses the services of a third-party provider (RP Solutions, Inc.) that involves an international transfer of personal data to the United States, country that guarantees an equivalent level of protection to that provided within the European Union for personal data transferred from Europe to third-party providers ubicated in the United States and are adhered to the Data Privacy Framework. LALIGA’s third party provider is among these providers.
- Push notifications about the APP services: You can receive push notifications regarding the APP services through the usual notification system of your Smartphone or Tablet (for example, about the start of matches, results, goals, cards or any other event that occurred in the match, etc.). You may object to the sending of such communications, at any time, through the "notification center" of the APP or through the settings of your own Smartphone or Tablet. These notifications may be displayed on your device when you are outside or inside the mobile app, and we will use your user ID to send you the notification.
The legal basis for the purposes mentioned above is that the processing is necessary for the performance of a contract to which the data subject is a party pursuant to the provisions of Article 6.1 b) of the General Data Protection Regulation.
- Internal reports: Likewise, the Club will process in aggregate form the personal data that you have provided through registration (in this case, country or favorite players) or social login (in your case, birthday, gender, page likes and current city), the data of use of the APP, device model, operating system and telemetry, for example, clicking on a certain content or the time you remain on the asset) and finally, the interactions with communications of any kind that you receive (for example, clicking on the content of a communication) or in the communication with the APP's support, for the elaboration of relevant metrics and statistics that allow analyzing the use made of the APP by the different segments of users that are generated and the impact of their campaigns, evaluating the interest they have aroused among the aforementioned segments based on the data analyzed.
- Use of the identifier for advertisers ("IDFA") on iOS (Apple) devices
The use of the IDFA for the purpose of "Internal Reporting" requires the user's tracking permission within Apple's iOS operating system. In the event that the user has not given permission for the use of the IDFA, the Club may carry out this purpose using the IDFV of the device.
At any time, the user can accept or decline the tracking permission in the iOS settings of the user's Apple device.
The legal basis for the aforementioned purpose is that the processing is necessary for the satisfaction of the Club's legitimate interest by virtue of the provisions of art. 6.1 f) of the General Data Protection Regulation, consisting of extracting lessons from the information provided and obtained from users that allows it to improve the APP and optimize the communication campaigns it carries out based on the interest that they generate among the different user groupings.
You have the right to object to the aforementioned purpose at any time in accordance with the procedure described in the section "What are your rights when you provide us with your personal data?".
- Security and quality control of assets: the Club will process the data of use of the APP (user ID, device ID, device model, operating system and telemetry, for example, user actions carried out within the APP), for the detection of errors and problems of the APP, as well as the optimization of the services provided through it.
The legal basis for the aforementioned purpose is that the processing is necessary for the satisfaction of the Club's legitimate interest by virtue of the provisions of art. 6.1 f) of the General Data Protection Regulation, consisting of offering an APP with the highest possible quality and the best experience for its users. Before doing so, we inform you that the Club has carried out an analysis of proportionality between its legitimate interest and the rights and freedoms of its users. You can request the conclusions of this analysis through dpo@fcandorra.com
You have the right to object to the aforementioned purpose at any time in accordance with the procedure described in the section "What are your rights when you provide us with your personal data?".
Additional purposes:
The following are the additional purposes for which the Club may process your personal data:
- Club commercial communications: So that the Club can send you commercial communications via email, push notifications, in-app or SMS or other instant message channels about its activities (the competitions it organises, campaigns, public viewings, shows or live events), products, services, competitions, offers, sweepstakes and/or promotions of the Club, (hereinafter, "Club products and services").
For this purpose, the Club will only process your email address and your user ID.
We also inform you that, in order to send you commercial communications via email or SMS and commercial push notifications, the Club uses a service from a third-party provider (salesforce.com EMEA Limited) that involves an international transfer of personal data to the United States, country that guarantees an equivalent level of protection to that provided within the European Union for personal data transferred from Europe to third-party providers ubicated in the United States and are adhered to the Data Privacy Framework. LALIGA’s third party provider is among these providers.
The legal basis for the processing of your data for the aforementioned purpose is the consent you have given us for the processing of your data for the specific purposes selected pursuant to the provisions of Article 6.1 a) of the General Data Protection Regulation. Your personal data will be kept for this purpose until you revoke the consent granted.
You have the right to withdraw your consent at any time in accordance with the procedure described in the section "What are your rights when you provide us with your personal data?", without affecting the lawfulness of the processing based on consent prior to its withdrawal.
- Simple segment creation: This allows the Club to send you segmented commercial communications via email, SMS, or other instant messaging channels about the Club's products and services. These communications will be based on the information you have provided (e.g., we will send you communications about products that may interest you based on your age or your province of residence).
The information used to create segments will only include that declared by the user during registration (in this case, gender, country, city, age, and favorite team or sport), with a low level of detail about the user's profile and without using inferred information or data from third-party sources. These segments are not exhaustive. This way, the commercial communications will be sent according to the simple segments created with the aforementioned information, avoiding sending content unrelated to you.
The legal basis for the aforementioned purpose is that the processing is necessary for the satisfaction of the Club's legitimate interest by virtue of the provisions of art. 6.1 f) of the General Data Protection Regulation, consisting of effectively taking advantage of the personal data provided by the user to achieve greater interest and return of the communications sent. Before doing so, we inform you that the Club has carried out an analysis of proportionality between its legitimate interest and the rights and freedoms of its users, the conclusions of which you can request through dpo@fcandorra.com
You have the right to object to the aforementioned purpose at any time in accordance with the procedure described in the section "What are your rights when you provide us with your personal data?".
- Comprehensive Club Profiling: If you give us your permission, the Club will create a comprehensive profile of you to offer personalized experiences, information, and products through personalized commercial communications via email, SMS, or other instant messaging channels (as long as you have given your consent for the "Club Commercial Communications" purpose) or by displaying personalized banners on websites, apps, or social media with advertisements about the Club's products and services.
In this way, the aforementioned information will be directed at segments (groups of users created based on the information obtained from them or from your use of the Platform or other Club assets) that we may create based on the following data sources:
- Social login (in this case, first and last name, birthday, gender, city, and province of residence);
- Interactions with the communications or notifications you receive (e.g., clicking on communication content);
- Inferred data based on your use and activity on the Platform (device ID, registered user ID, device model, operating system, and telemetry, such as clicking on certain content or the amount of time you spend on an asset).
Additionally, the Club will generate these segments considering the following profiling techniques:
- Individual campaign performance measurement: The Club will use information on open rates, average click rates, email bounces, or subscription cancellation rates to measure the performance of campaigns at an individual level. Based on this, segmentations will be created using the inferred information about you and the other declared information, to target you again with more relevant campaigns or include you only in those where you've shown greater interest (e.g., if you're highly active in certain communications, we may send you similar ones more frequently).
- Campaign optimization: You will be excluded from advertising campaigns about giveaways you've already participated in, apps you've registered for or downloaded, products you've purchased, or services you've previously acquired (e.g., we’ll avoid offering you a Club app if we know you've already downloaded it). To do this, we'll cross-reference your information with that obtained from other Club assets you use.
- Users with similar tastes and preferences: Based on the Club's profile of you, we can send you personalized content by considering other users with similar profiles (e.g., if we identify that other users similar to you like eSports, we will show you ads related to eSports).
- User scoring: The Club will derive an unknown variable from known variables provided by or inferred about you in order to carry out an analysis of its users, with the aim of identifying those more likely to use or purchase Club products, and if applicable, offer you the Club’s products and services.
- Retargeting: If you have interacted with the Club without registering or without using or downloading the relevant Club asset, the Club may use the identifying data from your device and/or email address to target you with ads in non-Club environments in order to achieve the desired interaction.
The legal basis for the processing of your data for the aforementioned purposes is the consent you have given us for the processing of your data for the specific purposes selected pursuant to the provisions of Article 6.1 a) of the General Data Protection Regulation. Your personal data will be kept for these purposes until you revoke the consent granted.
You have the right to withdraw your consent at any time in accordance with the procedure described in the section "What are your rights when you provide us with your personal data?", without affecting the lawfulness of the processing based on consent prior to its withdrawal.
How long will we keep your personal data?
The personal data we process will be kept as long as the purposes for which they were collected persist and/or you do not revoke the consents you have granted, or you do not exercise your rights of deletion, opposition or limitation of processing.
In this sense, the Club will keep your personal data duly blocked for the following retention periods for the sole purpose of dealing with responsibilities of any kind that may arise:
- Registration and access to the APP: the data provided for registration and access to the APP will be kept as long as you do not request the deletion of your data, this purpose persists and, once it has ended, during the limitation period of the legal actions that may arise from it.
- Push notifications on the APP services: the data provided for push notifications on the APP services will be kept as long as you do not request the deletion of your data, this purpose persists, you do not oppose the sending of the same and, once this purpose has been fulfilled, during the limitation period of the legal actions that may arise from it.
- Commercial communications from the Club: the data provided for commercial communications made by the Club will be kept as long as you do not request the deletion of your data, this purpose persists, you do not revoke the consent granted or limit the processing and, once this purpose has been fulfilled, during the limitation period of the legal actions that may arise from it.
- Creation of simple profiles of the Club: the data provided for the preparation of simple profiles will be kept as long as you do not request the deletion of your data, this purpose persists, you do not oppose the processing and, once this purpose has been fulfilled, during the limitation period of the legal actions that may arise from it.
- Exhaustive profiling of the Club: the data provided for the preparation of exhaustive profiles will be kept as long as you do not request the deletion of your data, this purpose persists, you do not revoke the consent granted or limit the processing and, once this purpose has been fulfilled, during the limitation period of the legal actions that may arise from it.
To whom will your personal data be disclosed?
Your Personal Data will not be communicated to other third parties, unless legally obliged.
What are your rights when you provide us with your personal data?
We inform you that, at any time, you can exercise your rights of access, rectification, opposition, deletion, portability and limitation of processing before the Club.
What do your rights as a user consist of?
- Right of access: you have the right to obtain confirmation as to whether the Club processes your personal data, as well as to access it.
- Right to rectification: you may request either of the two entities to modify or rectify personal data that are inaccurate.
- Right to erasure: you can request both entities to delete your personal data.
- Right to restriction of processing: In certain circumstances, you may request the limitation of the processing of your data, in which case they will only be kept for the exercise or defence of claims.
- Right to object: you may object to the processing of your data for the purpose you specify. The Club will cease to process the data, except for compelling legitimate reasons, or the exercise or defence of possible claims.
- Right to portability: if the APP allows it, you may exercise the right to portability of your data, in a structured, commonly used and machine-readable format, and to transmit them to another data controller.
How do I exercise my rights?
By sending an email to dop@fcandorra.com.
If you have given your consent for the purposes for which it has been requested, you may revoke it, at any time, by following the procedure established in each of the commercial communications you receive, or through the Subscription Center found in your profile within the APP and sending an email to the address: dpo@fcandorra.com.
The revocation of the consent given will not affect the use you may make of the website or the lawfulness of the processing based on said consent prior to its withdrawal.
Likewise, if you consider that you have not obtained satisfaction in the exercise of your rights, you can contact the Club's data protection officer at the email address dop@fcandorra.com or file a complaint with the Spanish Data Protection Agency through its website www.aepd.es.
Are there any limitations?
The Club informs you that in order to use and, where appropriate, register in the APP you must be at least 14 years old.