Personal Data Protection Policy - Singapore Football Club

Who are we?

This is the Personal Data Protection Policy (the “Policy”) of Singapore Football Club Pte Ltd (201919636M), its academy, incorporated under SFC Academy Private Limited (202015695E), and its other subsidiaries (collectively, the “SFC” or “we” or “us”).

SFC recognises its responsibilities in relation to the protection of personal data collected, used, disclosed, processed, transferred and/or retained under the Personal Data Protection Act (“PDPA”).

SFC is committed to complying with the PDPA in protecting personal information and places the privacy interests of the players and parent(s)/legal guardian(s) high in its priorities. Further, SFC is committed to protecting the privacy, confidentiality, accuracy, and security of personal data provided to it.

Personal data will only be collected for lawful and relevant purposes and shall be protected from any unauthorized access, use, and/or disclosure.

This document informs you of SFC’s policy and practices on personal data matters. SFC reserves the right from time to time to update this Policy to ensure it is consistent with business requirements, industry trends and/or changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of this Policy as updated from time to time on SFC’s website.

Any updates to the Policy will be effective 30 days following the date on which this Policy is updated and posted on the website at www.singaporefootballclub.com (the “website”).

For avoidance of doubt, the word “you” or any derivation thereof (e.g. “your”), as used herein refers to owner of the personal data, including but not limited to players of the SFC and/or their parent(s)/legal guardian(s).

What Personal Data Do We Process?

Personal data is defined as information about an individual who can be identified from that data; or from that data and other information to which the organization has or is likely to have access.

Generally, the personal data SFC may collect includes (but is not restricted to):

General identification and contact information such as your name, address, email, telephone number (including emergency contact person(s)), age, date of birth, gender, marital status, employment status, nationality, residency and/or citizenship status;
Medical and health information, such as health status and medical conditions, medical examination results, injury or disability information, allergies, medical history, and dietary restrictions or habits (e.g. smoking or alcohol consumption);
Financial information and account details, only in relation to provision of payment and billing matters;
Identification numbers issued by government agencies such as NRIC, Passport, FIN, and birth certificate numbers;
Information on your interactions with us; and
Other information enabling us to provide SFC’s services, such as football related preferences (playing position, previous clubs or academies, favourite clubs), dietary restrictions or requirements, as well as photographs and images (submitted by yourself or otherwise obtained by SFC).

Do note that some of the personal data that we collect and process highlighted above may include what is defined as ‘sensitive personal data’ under the PDPA. Such information shall be treated with care and utmost confidence by SFC and shall only be used for specific purposes. For avoidance of doubt, such information will not be released to a third party without your explicit consent unless it is necessary to protect your vital interests (e.g. in event of a medical emergency) or lawfully requested by government agencies.

** If you are a child or minor below the age of 16 years, please inform and seek the consent of your parent or guardian before you provide any personal data to us. Should you have provided said data, you undertake and warrant that you have sought the said consent. If you are a parent or guardian and you have reason to believe your child or ward has provided us with personal data without your consent, express or otherwise, please contact us. **

When and how do we collect personal data?

SFC generally does not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you or by law (e.g. a parent or guardian) to disclose your personal data to us or (b) where collection and use of personal data without consent is permitted or required by the PDPA or other Singapore laws. Rest assured, we shall seek your consent before collecting any additional personal data and before using your personal data for any purpose which has not been notified to you, whether by way of this Policy or otherwise (except where permitted or authorised by law).

Most, if not all, of your personal data was obtained from you directly, either from the following sources or from any other information you provided and this may include:

Enquiry Forms, by way of our website;
Assorted Application and/or Registration Forms submitted to SFC; and
By way of support or service requests to SFC, whether in writing or otherwise.

However, in some instances, we may collect personal data directly or indirectly through various channels, including when:

From third parties such as previous educational institutions, law enforcement agencies and other government entities;
You engage SFC’s services or enter into transactions with us (or express interest in doing so);
You enter into any agreement or provide other document or information in respect of your interaction and transactions with us (e.g. email feedback, telephone calls, face-to-face meetings);
You interact with our employees, representatives, agents, and/or service providers (including administrative staff and externally hired coaches);
Your images / biometric identifiers are captured via CCTV when you are on our premises or use our services;
Your images are captured in photographs or videos taken by SFC and/or its lawful agents when you attend events or programs organised by us, including but not limited to competitions, football games, training, and/or other football related events. For avoidance of doubt, we will strive to ensure all photographs and videos taken shall comply with both civil and criminal laws of Singapore, especially those in relation to the protection of minors;
Where your personal data is publicly available where relevant and appropriate;
We receive referrals from third-parties;
We seek any personal data that is required by any legal or regulatory authorities to comply with the laws and regulations, facilitate enforcement of laws, assist in any investigation or audits etc; and
You download any cookies, location services, IP addresses when you visit our website.*

* SFC may also receive and retain certain types of information whenever you interact with SFC on its website. Through the use of “cookies”, which are small text files placed on your computer by websites, SFC is able to collect information such as your IP address, browser type, domain names, access times and referring website addresses.

SFC uses the information collected for the following purposes:

Keeping count of return visits to its website or its advertisers’ or strategic partners’ websites;
Accumulating and reporting anonymous, aggregate, statistical information on websites and advertisement usage;
Determining which features on its website that users like best;
Saving your password so you do not have to re-enter each time you visit Income website.

The cookies used on our website will not collect your personal information unless you specifically provide us with the information. You may opt to disable cookies or prevent your browser from accepting new cookies through your browser settings.

** If you choose not to allow our website to place a cookie on your computer, this may restrict your ability to perform certain transactions, use certain services or access certain content on the said website. **

How Do We Use Personal Data?

SFC may collect and use your personal data for the following non-exhaustive purposes:

To verify your identify and information;
To process applications for prospective enrolment and/or maintain existing enrolment with SFC. In determining eligibility, we will make assessments requiring your personal data. Such assessments include assessment of health and/or other risks;
To manage, respond and process enquiries, complaints, applications, requests, and feedback from you;
To maintain a confidential register of personal details, for player and team purposes;
To facilitate other football related activities as well as other events;
To administer tournaments and tour events; especially where travel is involved;
To administer the academy fees and other payments;
To communicate effectively with you and to make important announcements;
To contact your next of kin in case of emergency;
To comply with any regulatory, audit or security related requirements
To process payments to us and to you, as well as recover any debt owed to us;
To care for the medical needs of players and for disclosure to medical professionals where necessary;
To manage and prepare reports on incidents and accidents;
To monitor and coach our employees and/or external coaches;
To conduct surveys, research and/or analysis for improvement of your experience and participation with SFC, as well as the programs and events we offer;
To administer contests, lucky draws and events generally;
To send you marketing information about SFC and for marketing purposes generally;
In the case of images captured publicly at SFC events or programs, for the purposes of marketing and information, including publication on our social media platforms and/or our website;
To generally manage administrative and business operations and comply with internal policies and procedures;
To comply with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority in Singapore;
To carry out any other such purpose which may be incidental, necessary, or ancillary to SFC’s operations.

** We will only collect and use personal data in an open, fair, and lawful way that is necessary for our purposes. In some cases, we may anonymize personal data so that it no longer identifies you, in which case we are entitled to retain and use such data without restriction, including for data analytics. **

How is my consent obtained?

SFC will only collect, use, disclose, process, transfer and retain personal data for the above purposes with your consent or as allowed or required by law. We will notify you on the purposes for which we will collect, use and disclose your personal data before or at the time we collect it.

You can give your consent expressly or impliedly. Your express consent can be given to us in writing (e.g. through submission of consent forms), verbally (e.g. when speaking to our staff and/or agents, like our coaches) or electronically (e.g. through our website). Your implied consent can be given to us from your action or nature of dealings.

Any party authorized by you (including a person having a power of attorney to act on your behalf) may:

Allow us to collect, use, disclose, transfer and retain personal data for the above purposes; and
Access your personal data or information.

Can I withdraw my consent?

You may refuse or withdraw your consent for us to collect, use, or disclose your personal data by giving us reasonable notice in writing so long as there are no legal or contractual restrictions preventing you from doing so.

However, do note that if you withdraw your consent for us to use your personal data, SFC may no longer be able to provide you with the services that you have asked for or have with us.

In particular, should you not be able to provide certain mandatory personal data to us, a player’s registration with SFC may be terminated or, for a prospective player, an offer of enrolment will not be made.

Do further note that upon receipt of your written request for withdrawal of consent, we may require reasonable time for your request to be processed.

Who can we share your information with?

SFC may share your information with:

Law enforcement bodies, judicial and/or other government agencies for the purpose of meeting legal, regulatory, and/or other requirements;
Regulatory bodies, whether in Singapore or elsewhere, including football related regulatory authorities;
Foreign embassies and their appointed agencies;
Sponsors of SFC’s players, whether individually or collectively, but not inclusive of any sensitive personal data as defined under PDPA;
Professional or accreditation bodies, for the purposes of certification;
Research institutions;
Business partners and vendors we work with, including those appointed by SFC to provide services such as auditors, lawyers, contractors, printing companies, travel agencies, training organisers, and insurance companies;
Financial institutions where necessary for facilitating payments;
Other institutions or companies relating to SFC; and
In respect of images captured publicly at SFC events or programs, to our website and social media platforms.

The above list is non-exhaustive. Your information is disclosed to the above only for relevant purposes highlighted in this Policy or to protect your interests. We will also ensure that overseas organisations we work with observe strict confidentiality and data protection obligations.

In situations where a third-party under contract with us collects personal data about you (e.g. when a coach asks a player for information), we will require the third party to exercise reasonable care in handling your information.

Do I have rights to access and correct my personal data?

Under the PDPA, you have the right to request access to any personal data of yours that we have, and know generally how it is being used and disclosed over the last 12 months to the extent your right is allowed by law. However, you may be charged reasonable administrative fees for every such request.

You also have the right to request correction of your personal data.

Please forward any requests to the Data Protection Officer.

How accurate is the personal data you keep?

We generally rely on personal data provided by you (or your authorised representative). In order to ensure that personal data is current, complete, and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing.

We strive to keep your records complete, accurate, and up to date.

How long will you retain my personal data?

We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable law.

We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for business or legal purposes.

How is my personal data protected?

To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical, technical, and technological measures to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to authorised third-parties and agents on a need-to-know basis only.

Additionally, where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone and to regularly change your password.

Please be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. Rest assured, while security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures, including review of this Policy with our lawyers.

How do I contact the Data Protection Officer?

You may contact SFC’s Data Protection Officer if you have enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request (as above), in the following manner: dpo@singaporefootballclub.com

Use of Links

SFC’s website may provide links to other websites and/or servers which may contain information of interest. We take no responsibility for, and exercise no control over, the organisations, views, or accuracy of the information contained in the links provided. You should exercise caution and look at the privacy statement applicable to the website in question and we take no responsibility for any privacy issues you may encounter in accessing the links provided.

We have no control over personal data that you submit or receive from third parties. Be informed, you are the person best qualified to protect your own personal data.

If you have a link you’d like us to consider adding to our Website, please send an email to info@singaporefootballclub.com with the subject “Link Request.”

Use of Text and Images

Any content, whether in visual format or otherwise, is the property of SFC. If you would like to re-publish any information on the website, please first seek our consent by writing in to info@singaporefootballclub.com

Accessibility

SFC’s website is designed to be accessible to visitors with disabilities, and to comply with general guidelines concerning accessibility. We welcome your comments. If you have suggestions on how to make the Website more accessible, please contact us at info@singaporefootballclub.com

Opt-Out or Change Your Contact Information

SFC’s website provides users the opportunity to opt-out of receiving communications from us. You may choose to receive only specific communications or none at all. You may also update your contact information previously provided to us. You cannot remove yourself from our database, but you can prevent unwanted communication.

Kindly write to us at info@singaporefootballclub.com if you wish to opt-out or change your contact information.

Governing law

The terms and conditions of this Policy shall be governed and construed in accordance with the laws of Singapore. You agree to submit to the jurisdiction of the Courts of the Republic of Singapore, although we reserve the right to bring proceedings against you for breach of any of the conditions of this Policy in your country of residence or other relevant countries.

For avoidance of doubt, in the event that Singapore personal data protection law permits an organisation such as us to collect, use or disclose your personal data without your consent, such permission granted by the law shall continue to apply. This also applies in respect of European laws for European residents.

Singapore Football club