THE MARKET PRIVACY POLICY
This privacy policy explains how The Market and Boyce Group Ltd [MBG] uses personal data that you provide or which MBG collects and holds about you when you use its official websites and/or other services.
MBG is the data controller of this information for the purposes of this policy.
MBG’s Information Officer is contactable using the details set out below.
MBG’s websites and services include:
The Market, Kingsway Centre;
Kingsway Centre;
The official MBG social media pages on Facebook, Instagram, TikTok and LinkedIn; (together the “MBG Official Websites”)
WHAT TYPES OF PERSONAL DATA DO WE HOLD?
Information we hold about you may include any one or more of the following types of data:
Account information: When you register to use, purchase or engage with any of MBG’s goods and/or services, the minimum information we will usually ask you to provide is your name, email address, date of birth, gender, home address, telephone number and mobile number. We may also ask you for additional information depending on the nature of our interaction with you.
Transactional information: When you purchase items owned by MBG official third party ticketing provider from time-to-time), including merchandise and other products from MBG 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 MBG products, goods and/or services so that we can make them better and more relevant.
. Information you provide to us in response to a job advertisement: We regularly advertise open positions on the Join the Team page of our website, which you may apply for by sending your CV to the email address provided
. Information you post online: We may hold and use information and/or user-generated content which you post on MBG websites, including information about your IP address, location and click history.
. Information from other companies: We may use publicly available postal address lists and the edited electoral roll to ensure that the information we hold about you is accurate, or we may use this information, together with general market research information (for example, demographic information), to add to and enhance our fan database.
. Online usage information: If you use MBG websites we may collect your browser type, the full Uniform Resource Locators (URL), through and from our site (including date and time), products you viewed or searched for, page response times, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs) and methods used to browse away from the page.
Online usage information may be linked to a unique identifier, but we do not link online usage information to named individuals. In order to collect online usage information, we use cookies and other similar technologies.
Information you provide to us in order to take part in an activity or an event at The Market: In order to take part in an activity operated by MBG, you may need to provide data such as your name, date of birth, address, ethnicity, gender and relevant medical information, as required in the circumstances. We will also collect data on attendance and performance.
In addition, we may collect your data if you attend an event organised by MBG, including matches or events held at Kingsway Centre or other venues.
. 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 MBG, we may need to obtain and process certain information about you in order to enter into and perform the contract of sale with you.
. Information you provide us when you report an incident at MBG, MBG will collect the telephone number used to report the incident and any other personal information you provide, this may include (by way of a non-limiting example) your name and address.
. Your data will never be used for marketing purposes, but MBG may contact you to discuss the details of your report.
. Special Categories of Personal Data: MBG may, from time to time, collect special categories of personal data on you. This includes personal data revealing racial or ethnic origin, religious or philosophical beliefs, data concerning your health and/or states of physical or mental health or personal data concerning your sexual orientation.
MBG may collect these special categories of personal data for the purposes of better understanding our fan base, identifying ways to improve communication to all areas of our fan base and to maintain MBG’s commitment to equality and diversity as it relates to all those who engage with MBG.
The table below sets out examples of the categories of personal data:
. Personal data revealing racial or ethnic origin
. Personal data revealing religious or philosophical beliefs
Data concerning health
. Personal data concerning an individual’s
You can opt out of MBG processing your special categories of personal data at any time by either opting out of any communication sent to you or notifying the Information Officer (details below).
THE PURPOSES FOR WHICH WE USE YOUR INFORMATION
The legal basis under which MBG 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.
Legal obligations: MBG retains records of all of its financial transactions with you in order to comply with its legal obligations to maintain adequate accounting records. MBG may use (and disclose) the information it holds about you in order to comply with any investigative demand, court order, or a request for cooperation from a law enforcement or other government agency.
Contract performance: MBG 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 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 MBG goods, products or services for another person (for example, event tickets or prizes and offers 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 MBG.
Recruitment: If you apply for a job with MBG or if you volunteer with MBG or contact us in relation to potential roles which may arise in the future, we may use your information for the purposes of recruitment and selection, corresponding with you and for equal opportunities monitoring.
Its financial transactions with you for six years in order to comply with its obligations to maintain adequate accounting records;
Its contracts with you for six years so that it has appropriate evidence in place if there is a claim for breach of contract made within the statutory limitation periods;
Job applications and CVs for up to six months, unless you have consented to your details being held on file in case other suitable opportunities arise;
Your account information until you close or delete your account/profile (at which point we would also delete any information from other companies or market research which we have appended to your account/profile)
Any market research we have undertaken (and which is not appended to your user account) for 3 years. Note that we will retain aggregated market research information (by which you cannot be identified) on an ongoing basis for internal purposes; and save as set out above, information you post online and/or online usage information for 3 years if it is on MBG websites.
If any information falls into more than one category, then the longer storage period will apply.
Marketing where it is in our legitimate interest: We may also market to you with news and offers from MBG, affiliates and official sponsors and partners which we think may be of interest to you, and conduct related surveys, or analytics, where it is in our legitimate interest, and where your consent is not necessary.
This can apply to individuals (e.g. analytics) but also to contacting data subjects who work for businesses that take corporate memberships or sponsorships with us.
Telephone and postal marketing: Further, we may call you (unless you have registered with the Telephone Preference Service or you have otherwise asked us not to contact you) or send you materials through the post (unless you have registered with the Mail Preference Service or you have otherwise asked us not to contact you) in relation to offers from the venue or its partners.
Marketing with your consent (where consent is necessary): If you have consented to it (where consent is necessary) MBG may contact you electronically with news and offers from MBG, affiliates and official sponsors and partners from time to time, which we think may be of interest to you. You have the right to withdraw your consent at any time.
Other purposes: MBG 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 MBG’s products and services.
We do this to make better strategic decisions about MBG and its products and services so that we can improve the way we market and provide products and services to you and MBG visitors generally.
MBG may also use online usage information about you to administer and improve the function and content of the MBG 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.
MBG may also use the information it holds about you if required to protect the rights, property, or safety of MBG, our partners, vendors, entertainers, customers or others.
In addition, where you attend an event hosted at MBG but organised by a third party, MBG may share data with them.
YOUR RIGHTS
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 MBG 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 MBG’s processing of your personal data is no longer necessary for the purpose for which we collected it;
Restrict the processing of your personal data in certain circumstances rather than having it erased;
Object to the processing of, personal data in certain circumstances;
Receive personal data, which you have provided to MBG, in a structured, commonly used and machine-readable format and transmit that personal data to another data controller, or have MBG 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.
DISCLOSURE OF YOUR INFORMATION
Sponsors, vendors and partners: MBG does not share your personal data with our sponsors and partners, but we may share aggregate/anonymised information which is based on this information with existing and potential sponsors and partners;
MBG suppliers and sub-contractors: MBG may share your information with suppliers and sub-contractors from time-to-time in order that they can process it on MBG’s behalf for the purposes set out in this privacy policy.
However, where we do so we will put in place suitable measures in order to protect your information. These third parties may include (but may not be limited to): (i) call centre providers; (ii) IT service providers (such as hosting providers); (iii) mailing houses or document storage companies; (iv) delivery services; (v) analytics, marketing services (including surveys) and search engine providers; (vi) credit reference agencies; and/or (vii) payment processing companies.
Disclosures for legal reasons: MBG 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; (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 MBG 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 MBG 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 MBG has taken reasonable steps to ensure the security and confidentiality of that information. If MBG (or substantially all of its assets) is acquired by a third party, personal data held about patrons or users of its goods, products or services will be one of the transferred assets.
Affiliates: Information held by MBG may be used by affiliates of MBG for the purposes set out in this policy, where you have consented to this. 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.
HOW DO WE KEEP YOUR INFORMATION SECURE?
MBG is committed to ensuring that your information is secure. In order to prevent unauthorised 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?
MBG 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.
PARENTAL CONSENT / SUPERVISION
Our business, products and services we provide from time-to-time are not specifically targeted at children, but we appreciate that children may be interested in MBG products and services.
We would therefore ask that parents and guardians supervise their children when they are online and that children under 13 do not submit personal information or content to MBG, make purchases of MBG goods, products or services, or take part in MBG promotions or competitions, without the consent of their parent or guardian.
MBG reserves the right to take reasonable measures in order to verify the existence and/or validity of parental consent.
HOW YOU CAN CONTACT US?
If you would like to contact MBG about this policy or any of the legal rights outlined in it, you can contact us by email or write to MBG at Kingsway Centre, Newport, NP20 1LR. In either case, your correspondence should be marked for the attention of the Information Officer via media@boycegroup.co.uk
COMPLAINTS
If you believe we have not complied with your rights, we ask you to contact us to give us the opportunity to address any concerns. You may contact the Information Commissioner’s Office (www.ico.gov.uk) which is the UK’s data protection regulator.
