Privacy Policy

Mamelodi Sundowns FC Privacy Policy 

Introduction

SUNDOWNS FC respects your constitutional rights to privacy and data protection. Accordingly, we believe in
protecting the Personal Information you provide to us and the Service Use Data we collect from you when you use
or access our Services (such as our website and social media platforms). SUNDOWNS FC will use its best
commercial endeavours to only use or disclose your Personal Information and/or Service Use Data in the manner
stated in this policy and as authorised by you. It is our intention that through the application of this Privacy
Policy your Personal Information and the Service Use Data will be protected from being dealt with in any manner
that is inconsistent with the applicable privacy and data protection laws of South Africa.

The use of our Services (being the SUNDOWNS FC website or any third-party platforms through which our Services
are provided or are accessible) involves the processing of your Personal Information and Service Use Data, so
it’s very important that you understand how this occurs and how you can control it.

Our Privacy Policy explains inter alia:

  • What Personal Information and Service Use Data we collect from you and how we collect it;
  • How we use and disclose your Personal Information and Service Use Data; and
  • How to access and update your Personal Information. 

By registering with us and using our Services you agree to this Privacy Policy and furthermore, you consent to
the handling of your Personal Information and Service Use Data as set out in this Privacy Policy. If you do not
agree with this Privacy Policy please do not register with us nor use our Services.

In this Privacy Policy, “we”, “our” or “us” refers to SUNDOWNS FC (PTY) LTD, a company
registered in terms of the laws of the South Africa

If you have any questions regarding this Privacy Policy please email us on info@sundownsfc.com.

Purpose of this Privacy Policy

The purpose of this Privacy Policy is to explain what personal data SUNDOWNS FC, processes, stores, uses and
shares in the course and scope of its business, from its website (www.sundownsfc.co.za) Users and other persons subject to this Policy.

How SUNDOWNS FC uses your personal information depends on whether you interact with SUNDOWNS FC as a
non-registered user, supporter, a competition entrant, a purchaser of our merchandise or in some other way. This
Privacy Policy gives a general overview of how SUNDOWNS FC processes personal data but you may receive more
detailed information about data protection (including separate privacy notices) depending on the different ways
you interact with SUNDOWNS FC.

Current Legislation

The Protection of Personal Information Act 4 of 2013 (“POPI”) sets out the law on the use and processing
of personal information.

SUNDOWNS FC is committed to the protection of your personal information in accordance with POPI and any other
legislation that may be applicable.

 What is “personal information”?

“Personal information” is defined in Section 1 of POPI as follows:

““personal information” means information relating to an identifiable living person/existing juristic person and
includes all information about that person, including their characteristics and identifying information and
correspondence that are implicitly or explicitly of a private or confidential nature including, but not limited
to:

(a)     information relating to the race, gender, sex, pregnancy, marital status, national, ethnic
or social origin, colour, sexual orientation, age, physical or mental health, well-being, disability, religion,
conscience, belief, culture, language and birth of the person;

  • information relating to the education or the medical, financial, criminal or employment history of the
    person;
  • any identifying number, symbol, e-mail address, physical address, telephone number, location information,
    online identifier or other particular assignment to the person;
  • the biometric information of the person;
  • the personal opinions, views or preferences of the person;
  • correspondence sent by the person that is implicitly or explicitly of a private or confidential nature or
    further correspondence that would reveal the contents of the original correspondence;
  • the views or opinions of another individual about the person; and
  • the name of the person if it appears with other personal information relating to the person or if the
    disclosure of the name itself would reveal information about the person.”

 Why is personal information collected?

Personal information is collected essentially to enable SUNDOWNS FC to conduct and administer its business
roles and functions. This includes the provision of its regular services and the marketing and implementation
thereof.

On what basis does SUNDOWNS FC collect, process and use personal information?

 Performance of contracts:

SUNDOWNS FC will process your personal information where this is necessary for the performance of a contract
with you or to take steps at your request before entering into such a contract. For example, SUNDOWNS FC will
need to process your personal information in order to comply with the terms and conditions relating to a
competition you may have entered on the SUNDOWNS FC website or in order to process a purchase and delivery of
SUNDOWNS FC’ merchandise on our digistore.

Compliance with our legal obligations:

In some cases, SUNDOWNS FC may need to process your personal information in order to comply with its legal
obligations and legal compliance.

Legitimate interest:

In other cases, SUNDOWNS FC has a ‘legitimate interest’ in processing personal information about individuals with whom SUNDOWNS FC interacts. SUNDOWNS FC has many such interests, including commercial interests and those with a wider public benefit. In essence, SUNDOWNS FC’ principal legitimate interest is in promoting the SUNDOWNS FC’ teams and administering SUNDOWNS FC in a way that promotes and safeguards the integrity of the sport. For example, SUNDOWNS FC needs to process personal information in pursuit of SUNDOWNS FC legitimate interests in order to:

  1. market the SUNDOWNS FC’ teams and brand;
  2. ensure the security of SUNDOWNS FC events and venues;
  3. operate a customer services team, conduct surveys and seek advice from advisers with the aim of improving SUNDOWNS FC;
  4. offer its commercial and other services to you;
  5. keep appropriate records of employees, contractors, service providers, suppliers and other stakeholders;
  6. structure SUNDOWNS FC offices in Johannesburg, storing most personal information centrally and making use of certain software and/or cloud storage providers for the purposes of efficient, fast and secure access to personal information; and research and statistical analysis.

Where SUNDOWNS FC relies on legitimate interest as the legal basis for processing personal information, it has considered whether or not those interests are overridden by the interests or fundamental rights or freedoms of the individuals whose personal information is being processed and has concluded that the processing is, on balance, fair.

Consent:

SUNDOWNS FC may also process your personal information on the basis of the express consent that you give when providing your personal information.

Processing special categories of data:

Where SUNDOWNS FC processes sensitive personal information, other legal bases for processing may apply,
including where our processing is necessary for the establishment, exercise or defence of legal claims (for
example, to protect and/or defend our property or rights, or those of other stakeholders), for reasons of
substantial public interest (for example, to conduct research about fans), for provision of medical care and
treatment, for the purposes of equal opportunities monitoring or where you have otherwise given us your explicit
consent (for example, to allow the use of your personal information by a sponsor for marketing purposes).

What personal information will SUNDOWNS FC collect?

The type of personal information that SUNDOWNS FC may collect from you will depend on the primary purpose for which such information is required and collected.

What personal information is collected by SUNDOWNS FC may vary depending on your interaction with SUNDOWNS FC as a user of our website or in some other way. For example, in order to enter a competition, SUNDOWNS FC may require only basic biographical and contact details – name, identity number, date of birth and contact details. 

Generally, the following personal information may be required, depending on your interaction with SUNDOWNS FC, some of which will not be mandatory ie you may choose not to provide such information:

  1. full name;
  2. date of birth;
  3. identity number and a copy of your identity book / card;
  4. copy of your birth certificate;
  5. gender;
  6. contact details – landline and mobile number, residential address, postal address, email address, social
    media details;
  7. occupation;
  8. details of your cultural background (eg language spoken).

 Under POPI the following information is specified as “special personal information” and need only be disclosed under certain circumstances:

  1. religious or political beliefs;
  2. race or ethnic origin;
  3. trade union membership;
  4. political opinions;
  5. health, sexual life;
  6. criminal behaviour.

 How does SUNDOWNS FC collect personal information?

Personal information will in most instances be collected directly from you.

You may decide to provide your personal information to SUNDOWNS FC for a variety of reasons, including the following:

You may:

  1. want to receive our newsletter;
  2. want to become a registered supporter of SUNDOWNS FC;
  3. want to attend SUNDOWNS FC event or activity;
  4. want to purchase an item of merchandise form our digistore;
  5. purchase a match entrance ticket;
  6. attend a SUNDOWNS FC event and chose to provide your personal information at the event;
  7. apply for an employment position at SUNDOWNS FC;
  8. enter a competition or promotion conducted by SUNDOWNS FC or one of its sponsors.

 Your personal information may be collected by SUNDOWNS FC in a number of ways and through a variety of mediums:

  1. when you consent to your personal information being entered into the SUNDOWNS FC database when you register to receive a SUNDOWNS FC newsletter or other information;
  2. when you consent to your personal information being entered into the SUNDOWNS FC database when you purchase an item of merchandise form our digistore or other licensed vendor;
  3. apply to be a SUNDOWNS FC supporter;
  4. when you provide your personal information to SUNDOWNS FC in an application or consent, survey, research or feedback form (written or electronic);
  5. when you email or telephone SUNDOWNS FC;
  6. when you engage with SUNDOWNS FC on social media;
  7. when you enter a competition conducted by SUNDOWNS FC, one of its sponsors, agents or licensees;
  8. when you purchase an entrance ticket to a SUNDOWNS FC’ match.

 Collection of a Child’s personal information

The primary source of a Child’s personal information for the purposes of SUNDOWNS FC will be from a parent or guardian.  In some instances personal information may have to be obtained from a responsible person associated with the Child or from the Child directly.

 Use and disclosure of personal information

 SUNDOWNS FC will only use your personal information for the primary purpose for which you volunteered such information, for secondary purposes related to the primary purpose and as otherwise permitted by personal information protection and privacy laws.

The primary and secondary ways in which SUNDOWNS FC may use your personal information may include:

  1. to collect or verify your identity and personal information on its records;
  2. to provide you with information about SUNDOWNS FC, its activities and/or its sponsors (where you have
    provided your consent to receive such information);
  3. to assist SUNDOWNS FC in the fulfilment of its objectives and purpose;
  4. to share relevant player information with the Premier Soccer League or other relevant sporting bodies;
  5. to organize medical treatment for you;
  6. to manage your relationship with SUNDOWNS FC;
  7. to disclose to SUNDOWNS FC’s professional advisors;
  8. to assist law enforcement or regulatory bodies;
  9. to receive direct marketing communications, where you have consented to receive such communications, in relation to products, services, events, merchandise and other offers made available by SUNDOWNS FC, its agents, suppliers, sponsors, licensees, broadcasters and the like;

How we use your personal information depends on how you interact with us.

Your personal information may be disclosed to SUNDOWNS FC third party suppliers, service providers and
administrators who assist SUNDOWNS FC in the provision and administration of services to IT (such as IT
services).  These third-party suppliers, service providers and administrators will be contractually
obligated to protect your personal information, apart from legislation applicable to them.

SUNDOWNS FC will not otherwise disclose or use your personal information without your express consent unless the disclosure is in accordance with this Policy, any agreement with you or required or authorized by law.

 Security of personal information

 The security of your personal information is of paramount importance to SUNDOWNS FC.

Your personal information is secured by SUNDOWNS FC as follows:

  1. We follow industry standards on information security management to safeguard sensitive information, such as
    your personal information, and any other information entrusted to us. Our information security systems apply
    to people, processes and information technology systems on a risk management basis.
  2. We perform regular external security penetration tests throughout the year. The tests involve high-level
    server penetration tests, in-depth testing for vulnerabilities, and social engineering drills.
  3. All personal information is sent and retrieved over encrypted channels with TLS.

 How long will we store your personal information?

SUNDOWNS FC may retain your personal information for as long as is necessary to fulfil the purposes set out in this privacy notice and/or to satisfy SUNDOWNS FC’s reasonable business requirements. On expiry of the
relevant retention period, your personal information will be deleted, suppressed or anonymised, as applicable,
save that we will retain comprehensive details for archiving purposes in the public interest, or for historical
or statistical purposes.

Your rights in relation to your personal information and access to your personal information

Under Section 23 of POPI you have the right to request:

 SUNDOWNS FC to confirm whether or not SUNDOWNS FC holds personal information about you; and

  1. SUNDOWNS FC to provide a record or description of the personal information it holds about you and which third parties have had access to such information.

Under Section 24(1) of POPI you may request SUNDOWNS FC:

  1. to correct or delete your personal information in its possession or under its control that is inaccurate,
    irrelevant, excessive, out of date, incomplete, misleading or obtained unlawfully;
  2. to destroy or delete a record of personal information that SUNDOWNS FC is no longer authorised to retain in terms of section 14 of POPI.

 Should you have any enquiries or requirements regarding your personal information with SUNDOWNS FC may have please email your query or requirement to info@sundownsfc.com.