The Association of Football Agents

1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how the Association of Football Agents UK Limited (the “AFA”) collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up as a member of the AFA, register for our newsletters or register for our events.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

The AFA is the controller and responsible for your personal data (collectively referred to as "we", "us" or "our" in this privacy policy).

The AFA is a limited company registered in the UK with company number 12282978. While it is a legal entity in its own right, the AFA does not currently have a centralised administrative function and it is managed on a day to day basis by its directors, who are also directors of UK based football agencies. The impact of this on the use of personal data is explained below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact us via email at: [email protected]

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.

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

We keep our privacy policy under regular review.

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.

Third-party links

The AFA 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.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

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, maiden name, last name, username or similar identifier, title, date of birth and gender.
  • Contact Data includes delivery address, email address and telephone numbers.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the AFA website.
  • Profile Dataincludes your feedback and survey responses.
  • Usage Data includes information about how you use our website and services.
  • Marketing and Communications Dataincludes your preferences in receiving marketing from us and your communication preferences.

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. 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 website 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.

If you fail to provide personal data

Where we need to collect personal data by law, or in order to allow us to provide you with information or invite you to our events, and you fail to provide that data when requested, we may not be able to provide you with the information or extend the relevant invitation. We will notify you if this is the case at the time.

3. How is your personal data collected?

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

  • Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you register as a member of the AFA, subscribe to our publications, register for our events and contact us.
  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
4. How we use your personal data

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

  • To carry out any obligations we may have to you as an AFA member, as well as to send you material and communications which you have requested.
  • To promote our events
  • To provide you with access to our website
  • To send you information relevant to direct marketing, surveys, events and feedback.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

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 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.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a member
  1. Identity
  2. Contact
 Performance of our obligations to you
To manage our relationship with you which will include:
  1. Notifying you about changes to our terms or privacy policy
  2. Asking you for feedback or to take a survey
  1. Identity
  2. Contact
  3. Profile
  4. Marketing and Communications
  1. Performance of our obligations to you
  2. Necessary to comply with a legal obligation
  3. Necessary for our legitimate interests (to keep our records updated and to study how members use our services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
  1. Identity
  2. Contact
  3. Technical
  1. 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)
  2. Necessary to comply with a legal obligation
To deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
  1. Identity
  2. Contact
  3. Profile
  4. Usage
  5. Marketing and Communications
  6. Technical
 Necessary for our legitimate interests (to study how members interact with the AFA, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, marketing, member relationships and experiences
  1. Technical
  2. Usage
 Necessary for our legitimate interests (to define types of members for our provision of information and events, to keep our website updated and relevant, to develop our services and to inform our marketing strategy)
To make suggestions and recommendations to you about information, services and events that may be of interest to you
  1. Identity
  2. Contact
  3. Technical
  4. Usage
  5. Profile
  6. Marketing and Communications
 Necessary for our legitimate interests (to develop our services and further the interests of the AFA and its members)

Marketing

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide what information to send to you and what events may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or have signed up as a member of the AFA and you have not opted out of receiving that marketing.

Third-party marketing

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

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of your membership of the AFA.

Cookies

Cookies are small text files that can be used by web sites to make a user's experience more efficient. The law states that we can store cookies on your machine if they are essential to the operation of this site but that for all others we need your permission to do so. The AFA website may use some non-essential cookies.

We do not use cookies to track individual users or to identify them, but to gain useful knowledge about how the site is used so that we can keep improving it for our users. Without the knowledge we gain from the systems that use these cookies we would not be able to provide the service we do. This site uses different types of cookies.

If you want to delete any cookies that are already on your computer, please refer to the instructions for your file management software to locate the file or directory that stores cookies. You can access them through some types of browser. Search in your cookie folders for ‘theafa.uk' to find our cookies if you wish to delete them. More information about cookies, including how to block them or delete them, can be found at AboutCookies.org.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above.

  • The AFA is administered by its directors and staff within the football agencies to whom they belong. This currently includes Creative Artists Agency and the football agencies it operates (CAA Base and CAA Stellar) and Wasserman. Data may be shared with staff within these agencies in order to facilitate the administration of the AFA.
  • The AFA uses a third party organisation, Rocket Media, to help maintain its website and to store personal data relating to its members. For further information please see https://rocket-media.net/gdpr/

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 do not transfer your personal data outside the UK.

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.

9. Your legal rights

You have certain rights in respect of your personal data, including the right to access, correct, restrict, and request the erasure of your personal data, and obtain a copy of it in a machine-readable format.

You also have the right to object to your Personal Information being used for certain purposes, including to send you marketing.

We will comply with any requests to exercise your rights in accordance with applicable law. Please be aware, however, that there are a number of limitations to these rights, and there may be circumstances where we are not able to comply with your request. To make any requests regarding your personal data, or if you have any questions or concerns regarding your personal data, you should contact us using the details below. You are also entitled to contact the UK Information Commissioner’s Office if you have any concerns No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.