Real Madrid Foundation Technical Academy Singapore
In furtherance of the obligations imposed by the Personal Data Protection Act 2010 (“PDPA”), Real Madrid Foundation Clinic in Malaysia (“RMFCM”) operated by Spanish Sports Ventures Sdn. Bhd. (formerly Britannia Gateway Sdn. Bhd.) with company registration number 1215326-T (the “Company”) is dedicated to implementing the appropriate safeguards and data protection policies to ensure that your personal data is handled lawfully.
- the use of their image and/or voice either through recordings or through photographs, whose purpose will be to promote the various events of the Group or any one of them;
- the collection of his/her image and/or voice, reproduction and subsequent publication in different media, television, radio, Internet, promotional videos of the Group or any one of them as well as other promotional channels such as magazines, brochures, ads and billboards;
- the processing of personal data relating to their health by the Group or any one of them, and its transmission to Tune Protect and to other insurance companies that will support the provision of medical coverage for these activities;
- the transmission of their personal data where necessary, for everything related to the internal programme organization, to facilitate access to sports facilities, residence, bus transfers and other related companies providing services to the Company for the operation of the business and participation of your child in the programme;
- the transfer of personal data to companies directly or indirectly related to Group or any one of them for the purpose of commercial communications, newsletters, magazines, even electronically, of the different events organized by any member of the Group and own products linked to the company and others sold by companies directly or indirectly related to the Group or any one of them;
- the transfer of your personal data or your representation to Real Madrid CF and Real Madrid Foundation, to receive communications, news on events, promotions or the club, to participate in draws, promotions and offers linked to the activities of Real Madrid CF and Real Madrid Foundation that best suit their characteristics including the use of email and mobile phone;
RMFCM needs to process personal data about you for the purposes of providing the service. Under the PDPA the term ‘process’ covers activities related to collecting, recording, holding or storing the personal data and the carrying out of any operations for such data and or such other matters permitted under the PDPA.
The practices described in this policy applies from the time you first provide personal data to RMFCM and shall continue during the course of your receipt of our service and where applicable, pursuant to the completion of the service.
Information collected from you by others outside the ownership or control of RMFCM, such as third party web sites that you access through links on our website or in any of our email communications, are governed by those entities’ privacy policies, and not RMFCM.
2. The information we collect
Personal Data: ‘Personal Data’ is defined by the PDPA as data, whether true or not, about an individual who can be identified from that data and/or other information to which an organisation has or is likely to have access by reason of providing the service.
When enquiring about or signing up for our service, you may provide us information that can be used to identify you on an individual basis and allow us to contact you as part of the service; it is this information that is deemed ‘personal data’ for the purposes of this policy.
3. The ways we use information
Purpose: RMFCM process the Personal Data for the purposes of operating maintaining and enhancing our service for you and other customers. You may be contacted through your email address for administrative purposes; for customer relationship management purposes; internal record keeping and managing employment relationships; to share with you updates and more information (including promotional/marketing material) related to the service; to understand and analyse the usage trends, interests, and preferences of our customers; to improve the way our service works; to introduce new features and services; and all other purposes necessary and/or incidental to our business and all purposes necessary for or related to any of the above purposes.
New Purpose: Should Personal Data be required to be used for a new purpose, the data subject’s approval will be obtained prior to using his/her Personal Data for such new purpose or the data subject will be notified, in the case where an exemption to the consent or notification obligation is not provided by the PDPA. In the case where customers provide us with Personal Data of third parties, our customers need to obtain all consents, if necessary, from such third parties to collect, use and disclose Personal Data for the purposes as set out above.
4. Sharing of information
Right to Disclose: Personal Data may be disclosed within RMFCM to any of its existing or future related or associated companies or to any other third party(ies) such as auditors, professional consultants or advisors (including law firms), accountants, agents, insurers, governmental bodies and authorities or any other third party in order to satisfy the purposes for which the Personal Data was collected. Personal Data may also be transferred outside Malaysia to be processed subject to the requirements of the PDPA.
Minors: The parents of minors are deemed to have provided consent to the use of the Personal Data for the said minor by making enquiries for the minor and/or by applying for service by registering the minor’s participation in the service. Please note that we do not sell, or share your (or your child’s) personal information to any third party for any marketing or advertising purpose to external parties save as disclosed in this policy.
Third Party Disclosure: We do not share personal information except as expressly provided in this policy, and in particular as follows:
- RMFCM work with third party service providers to provide various services for us in order for us to deliver our service to you in the best way possible, such as airlines, IT and insurance services. To the extent, it is necessary for these service providers to complete their contractual obligations to us, these third parties may have access to or process your personal identifiable information. Generally, our policy is to make these disclosures under limitations comparable to those in this policy, although certain large service providers, such as large hosting providers, do not expressly agree to such limitations in their contracts with us or their other customers. Nevertheless, we will always strive to limit the information shared with such third parties to the minimum necessary and such sharing is guided by a “need-to-know” basis.
- Many third parties who we provide your personal information to may provide certain government and law enforcement agencies access to information stored by such third parties without providing notice to us, in some cases as required by law and in other cases voluntarily, and we have no control over such activities.
- RMFCM may make certain automatically collected and other aggregate non-personally identifiable information to assist such third parties in understanding its users’ interests, habits, and usage patterns for certain programs, content, services, promotions, related to the service.
- RMFCM may also disclose Personal Data if required to do so by law, such as in response to a subpoena, or in the good-faith belief that such action is necessary to comply with the law, or in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with investigative or law enforcement activity. Such disclosure may also be made to government or regulatory agencies having jurisdiction over our business and service.
- RMFCM reserves the right to disclose your information that it believes, in good faith, is appropriate or necessary to take precautions against liability; to protect us and others from fraudulent, abusive, or unlawful uses or activity; to investigate and defend ourselves against any third party claims or allegations; to assist government enforcement agencies; to protect the security or integrity of the service; or to protect our, our users’, and others’ rights, property, and security.
Cookies: When using the Website, you may be sent one or more cookies – small text files containing a string of alphanumeric characters to your computer. Please note that not all cookies will remain on your computer and all cookies can be removed. If in doubt, please refer to your web browser’s “Help” section to learn the proper way to modify your cookie settings. Cookies will be used to: (a) personalise our services, such as remembering your information so that you will not have to re-enter it during your next visit to our website; (b) provide customised third-party advertisements and information; (c) monitor and analyse the effectiveness of our website content and (d) monitor aggregate usage metrics such as number of visitors and pages viewed etc.
Visitor information: When you visit the Website or open one of our emails (HTML communications such as newsletters), RMFCM may be provided by our IT service providers with certain information from your web browser which may include Internet Protocol address (“IP Address”) or other device address or ID, web browser and/or device type, the web pages or sites that you visit just before or just after visiting the Website, the pages you view on the Website, and the dates and times that you visit, access, or use the Website.
5. Third party services
Our website or other communications related to the service that is sent to you may contain references and links to websites and services provided by third parties. Any personal information you provide on third party sites or services is provided directly to that third party and is subject to that third party’s policies governing privacy and security. Please note that this policy does not apply to the practices of third parties that may process the Personal Data for and on behalf of RMFCM that it does not own or control. RMFCM is not responsible for the content or privacy and security practices and policies of third party sites or services to which links are displayed on our website or other communications related to our service that we may send to you. Each person is encouraged to learn about third parties’ privacy and security policies before providing them with personally identifiable information.
6. Our commitment to data security
Storage measures: Reasonable security measures are in place to protect Personal Data against unauthorised access, collection, use, disclosure, copying, alteration, accidental loss or theft, destruction, damage or similar risks. All employees of RMFCM are made aware of the importance of maintaining confidentiality of the Personal Data collected from our clients or staff. The access to Personal Data of employees is on a need-to-know basis only.
No assurance is given that information you transmit to us will not be lost or compromised, either during or after transmission. Further RMFCM is not liable or responsible for the wrongful extraction and/or use and disclosure of Personal Data obtained from RMFCM through no fault of its own. RMFCM will employ certain safeguards designed to help improve the integrity and security of your personal information and continue to work on how to enhance such safeguards, no physical or technical system, process, transmission, or storage mechanism is completely secure or immune from outages, losses, attacks, circumvention, design or implementation flaws, and human error. If we learn of a security breach, then we may attempt to notify you electronically so that you can take appropriate protective steps or take necessary action with the authorities.
Accuracy: RMFCM is not responsible for the accuracy or completeness of any Personal Data provided to it. If there is a complaint about the inaccuracy of the Personal Data kept by RMFCM, that complaint can be referred to the Data Protection Officer.
Retention: RMFCM will keep Personal Data no longer than is necessary for the purpose it was collected for or any business or legal purposes. We will take all reasonable steps to ensure that all Personal Data is destroyed, permanently deleted or anonymised if it is no longer required for such purposes.
7. Rights of Data Subject
You have the right under the PDPA to access your Personal Data. You may, of course, decline to share your Personal Data, in which case we may not be able to provide you the service or certain aspects of the service . Any access request may be subject to a fee to meet the cost in providing you with details of the Personal Data. Such request shall be made in writing to the Data Protection Officer at the address below.
You may update, correct, or delete your Personal Data with us by making such a request to us at firstname.lastname@example.org. In order to protect your privacy and security, RMFCM may take steps to verify your identity before making corrections to your personal data.
8. Contact for inquiries regarding Personal Data
You may contact the relevant department as follows:
606 2404 188
Spanish Sports Ventures Sdn. Bhd., Persiaran Kolej, 71760 Bandar Enstek, Negeri Sembilan, Malaysia
9. Amendment of Policy