Privacy Policy
Introduction
Fanblock is a fan-engagement platform that enables fans to buy a square yard block of their club's home ground in the Metaverse and provides an entry point to a fully integrated fan engagement ecosystem.
Fanblock is a data controller respecting your privacy and understanding the importance of maintaining the confidentiality of your personal data and any other information stored about you.
Fanblock is committed, in the course of its activities and in compliance with applicable data protection laws, to ensure the confidentiality, integrity and availability of your personal data, as well as to respect your privacy.
The commitments described in this privacy policy (the "Privacy Policy") fulfil the values, the principles of action and behaviour of Fanblock and are established in compliance with applicable Swiss and European laws.
Date of issue of the latest version of this Privacy Policy: 09/2023
1. Coverage of the Privacy Policy
This Privacy Policy applies to Fanblock's processing of your personal data when you visit and use any Fanblock website, app or service which links to this Privacy Policy. This means information that identifies you personally such as your name, location, photo and contact details or data that can be linked with such information in order to identify you directly or indirectly. We refer to these websites, apps, social media profiles and pages and services in this Privacy Policy, collectively the "Fanblock Platforms".
This Privacy Policy also covers Fanblock's collecting and processing of any personal data that Fanblock's business partners share with Fanblock.
2. Personal Data collected
Fanblock collects and processes personal data in respect of your use of and interactions with the Fanblock Platforms in order to provide you with services, improving your experience, preventing fraud and to communicate with or share information with users of the Platforms. "Personal Data" means any information that may be linked directly or indirectly to you as an individual.
This section provides more detailed information regarding the type of Personal Data we may collect and process depending on the Fanblock Platform that you are engaging with, including but not limited to:
(a) Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender and ID number.
(b) Contact Data includes billing address, delivery address, email address and telephone numbers.
(c) 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 analytic tools on the devices you use to access Fanblock Platforms.
(d) Cookie and Device Data. Details can be found in Section 10.
(e) Financial Data includes some payment debit/credit card details.
(f) Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us such as pack of Fanblocks or selling your NFTs.
(g) Usage Data includes information about how you use Fanblock Platforms.
(h) Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
(i) Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
(j) Other. Other information you may provide to us, for example photographs, competition entries, gaming.
3. Personal Data collection process
We collect your Personal Data in a number of ways as described below.
3.1 Information provided to Fanblock directly:
We collect Personal Data from you where you:
(i) register an account with us (including via social media profiles such as Facebook and Google+) or log in and make changes to your online account;
(ii) register to receive marketing communications from us;
(iii) access and purchase products/services from us;
(iv) enter into a competition or play games on Fanblock Platforms;
(v) interact with our social media profiles; and
(vi) contact us (including over the phone, or via email, post, live chat or social media messaging).
3.2 Personal Data we collect from third parties:
We collect information on you from third parties, such as clubs, Clubs' commercial partners, and Fanblock suppliers, where you:
(i) have a contract in place with such third parties which requires the transfer of your Personal Data to us; and/or
(ii) register through such third parties to receive marketing communications from us.
3.3 Personal Data collected automatically:
Fanblock also automatically receives and records non-sensitive information on its technical infrastructure logs about your computer when you visit Fanblock Platforms, regardless of whether you have registered for an account or not by just browsing our servers.
Fanblock may collect, including but not limited to, your Web browser software, your internet protocol (IP) address which identifies your computer, Fanblock's cookies, the referring website and the page you requested.
Fanblock may also collect information about your location, and your online activity on the Fanblock Platforms. Please refer to Cookie and Device Data section for more details in relation to our use of cookies.
4 Use of Personal Data
The Personal Data of yours which we collect or hold will be used in a number of ways depending on the Fanblock Platform as explained below. Under data protection laws we have to have a lawful basis for processing your Personal Data. We have indicated the lawful basis upon which we rely in the headings below.
Where we rely on "legitimate interest" as a lawful basis for processing your Personal Data, same is based upon our need to know and/or use your Personal Data to , improve the services and products we offer to you; your experience when you interact with us; to ensure effective operational management and internal administration of our business; and the exercise of our rights.
4.1 Contracts
If you enter into a contract with Fanblock (for example to purchase a pack of Fanblocks, open an account, create a custodial crypto wallet, receive, trade or sell NFTs, play games and win prizes) we need to process your Personal Data in order to fulfil the contract by providing the services, processing payments and entering into correspondence in relation to the same. If you do not provide the information to us, we may not be able fulfil the contract and provide the products or services to you.
4.2 Consent
Fanblock asks for your consent to send you direct marketing communications relating to a pack of Fanblocks or selling your NFTs and other Fanblock activities we administer. You can choose to unsubscribe at any time as explained in the section headed “your rights” below. In some limited circumstances, Fanblock does not need to obtain your consent for marketing as explained in the legitimate interest section below.
4.3 Legal obligation
Fanblock is under legal obligation to protect, investigate, deter and report fraudulent, unauthorised or illegal activity. Certain of your Personal Data may be retained or used in the combat and prevention of fraud (including credit card fraud), to enable refunds; and for financial record keeping requirements.
4.4 Legitimate interest
Fanblock may process your Personal Data where it is necessary for our legitimate interests as a business in the following situations:
- Account management and record keeping and correspondence in relation to products and services you receive from us;
- Fraud detection and checks;
- To respond to any enquiries, information requests or complaints you make to us or that are made about you;
- To inform you of upcoming competitions, games, promotions and community initiatives and communicate with you about these, where you have shown an interest;
- To send you marketing communications where we have a commercial relationship (for example where you purchase packs from our platform) with you and you have not objected to receiving such communications from us;
- To contact you for your views and feedback on our products and services;
- To assist with internal record keeping;
- To provide you with, and maintain the quality of, our platforms and to analyse the use of our platforms in order to help guide improvements.
- To enable better service and personalisation as explained in more detail below.
- To assist in the prevention of or detection of a crime or equivalent malpractice.
- To assist in the identification and prosecution of offenders.
Where we rely on legitimate interest as a ground for processing your personal data, we carry out a "balancing test" to ensure that our processing is necessary and that your fundamental rights of privacy are not outweighed by our legitimate interests, before we proceed with such processing.
We keep a record of these balancing tests. You have a right to the Personal Data contained in these balancing tests on request, and can find out more by contacting us using the details below.
We may also use aggregate, anonymised information in order to help us develop our services and may provide such information to third parties. This information cannot identify you.
5 Personal Data sharing and disclosure
We may share your Personal Data with the parties set out below for the purposes set out above.
- With external third parties who perform functions on our behalf and who also provide services to us, such as research companies, professional advisors, technology providers and hosting companies; advertising companies and exchanges; analytics companies; payment providers; fraud and credit checking companies, provided in each case, that these third parties comply with similar and equally stringent undertakings of privacy and confidentiality in relation to your Personal Data.
- With external third-party data services; who help up to segment and understand our audience by providing additional information.
- With external third-party platforms and advertisers (such as Facebook or Google) to help us identify customers similar to our audience or to serve relevant adverts and content to you on third party websites. The information shared with these advertisers is pseudonymised to protect your personal data.
- With external third parties, where Fanblock finds that it is necessary, as determined in Fanblock's sole discretion, to investigate, prevent or take action regarding illegal activities, suspected fraud, emergency situations involving potential threats to the physical safety of any persons, violations of contractual obligations or as otherwise required by law.
- Certain third parties pursuant to court orders or warrants.
- To third parties where you give us express permission to share your personal data in the course of your relationship with us from time to time.
Save for the circumstances set out above, Fanblock will not sell, rent or transfer your personal data to third parties: (i) without your consent; (ii) for reasons which are not consistent with the purpose for which the data were originally collected; or (iii) for other purposes authorised by law.
6 Transfer of Personal Data
Your personal data is generally stored within the EEA but in limited circumstances may be transferred to suppliers that are not within the EEA. Where Fanblock transfers your personal data from within the EEA to a country outside the EEA, we ensure adequate security measures are in place to offer equivalent protection as your Personal Data would receive within the EEA and in compliance with applicable data protection law. We have in place EU Model Contractual Clauses as an adequate safeguard for transfers outside the EEA.
7 Data retention and archiving
Personal Data processed by Fanblock will be retained only for as long as is necessary to fulfil the purposes outlined above in this Privacy Policy. This will generally (but not in all cases) be for the duration of time where you utilise our services, to comply with our legal obligations or to protect Fanblock's rights. When determining the relevant retention periods for your Personal Data, we will take into account factors including:
- our contractual obligations and rights in relation to the Personal Data involved;
- egal obligation(s) under applicable law to retain data for a certain period of time;
- statute of limitations under applicable law(s) which is the period during which contractual claims could be brought, being 10 years in Switzerland;
- our legitimate interests where we have carried out balancing tests (see section on "Use of Personal Data" above);
- (potential) disputes; and
- guidelines issued by relevant data protection authorities.
8 Your rights
By law, you have a number of rights (subject to certain conditions) when it comes to your Personal Data. Further information and advice about your rights can be obtained from the data protection regulator in your country.
Rights
What does this mean?
Your right to object to processing
You have the right to object to certain types of processing, including processing for direct marketing (i.e. if you no longer want to be contacted with potential offers or opportunities). Unsubscribing from newsletters and e-mail marketing communications can most easily be done by clicking on the unsubscribe link at the bottom of any email newsletter we have sent to you or, alternatively, by modifying your account settings and preferences.
Your right to be informed
You have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and your rights. This is why we are providing you with the information in this Privacy Policy.
Your right to Access your personal data
You have the right to obtain access to your personal data (if Fanblock is processing it), and certain other information (similar to that provided in this Privacy Policy).This is so you are aware and can check that we are using your personal data in accordance with data protection law.
Your right to Update and Rectification
You are entitled to have your personal data corrected if it is inaccurate or incomplete.You are generally able to review, correct or update your personal data at any time by accessing your account on the Fanblock Platforms where it has been created. However, you may choose to send us a written request to do so on your behalf at any time.
The right to erasure
This is also known as "the right to be forgotten" and, in simple terms, enables you to request the deletion or removal of your Personal Data where there is no compelling reason for Fanblock to keep using it. This is not a general right to erasure, there are exceptions.You are generally able to delete your Personal Data at any time by accessing your account on the Fanblock Platforms where it was created. However, you may choose to send us a written request to do so on your behalf at any time.
Your right to restrict processing
You have rights to "block" or suppress further use of your Personal Data. When processing is restricted, Fanblock can still store your Personal Data, but will not use it further. We keep lists of people who have asked for further use of their Personal Data to be "blocked" to make sure the restriction is respected in future.
Your right to data portability
You have rights to obtain and reuse your Personal Data for your own purposes across different services.
Your right to lodge a complaint
You have the right to lodge a complaint about the way Fanblock handles or processes your Personal Data with your national data protection regulator by contacting the applicable data protection regulator directly.
Your right to withdraw consent
If you have given Fanblock your consent to anything we do with your Personal Data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your Personal Data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your Personal Data for marketing purposes.
You can exercise your right to erasure (e.g. delete your account) by sending an email with the subject "Account deletion" to the following address: privacy@fanblock.com
To exercise any other of these rights, you can contact us in writing (including via email or regular mail) on the details below. Please note that we may require receiving a proof of your identity before we can respond to your request.
Email: privacy@fanblock.com
Mail: Fanblock AG
Baarerstrasse 12
CH-6300 Zug
Switzerland
We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:
- baseless or excessive/repeated requests, or
- further copies of the same information.
Fanblock may refuse, restrict or defer the provision of information where Fanblock has the right to do so under current data protection legislation.
Please consider your request responsibly before submitting it. We will respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we will come back to you and let you know.
9 Data Security
We want you to feel confident about using the Fanblock Platforms. Therefore, Fanblock defines and implements the reasonable technical and organisational measures necessary to maintain the security of Personal Data, according to the nature of the Personal Data processed and the circumstances of the processing, with the objective of avoiding (in the realm of the possible and having regard to the state of the art) non-authorised processing or access, alteration or loss (to ensure confidentiality, integrity and availability respectively).
Fanblock uses industry standard SSL encryption to protect data transmissions. If you communicate with Fanblock other than via Fanblock Platforms (e.g. by email), you should however note that the secrecy of the Internet is uncertain. By sending sensitive or confidential e-mail messages or information which are not encrypted, you accept the risk of such uncertainty and possible lack of confidentiality over the Internet.
Identity theft and the practice currently known as "phishing" are of great concern to Fanblock. Safeguarding information to help protect you from identity theft is a great concern. Fanblock does not and will not, at any time, request your credit card information, your account ID, login password or national identification numbers in a non-secure or unsolicited e-mail or telephone communication.
10 Cookies
Cookies are text files that are placed on your computer and may be used to store your information. Fanblock uses cookies to provide you with content specific to your interests and track your use of Fanblock Platforms. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Fanblock Platforms may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.
11 Profiling
We may use the personal data you provide to us via Fanblock Platforms, alone or in combination with personal data you have provided to our advertising partners to better understand your interests so we can try to predict what other products, services and information you might be most interested in. We call this profiling. Profiling enables us to tailor our communications (both directly from us and via our advertisers) and those of our third parties to make them more relevant and interesting for you.
If you don't want us to do this you may opt-out here http://www.networkadvertising.org/choices/, or http://www.aboutads.info/ or, for EU users only here: http://youronlinechoices.eu/.
Additionally, you may also opt-out of interest-based advertising by accessing the settings pages of our external advertisers:
We do not use your Personal Data to make automated decisions about you that may have legal or similarly significant effects on you. Further information about your rights is set out at Section 8.
12 Children's privacy
The protection of Personal Data of children and adolescents is of particular concern to Fanblock. The Fanblock Platforms and their content are not directed at children under the age of eighteen (18).
Fanblock will not knowingly collect Personal Data from or about children under eighteen (18). If a parent or legal guardian becomes aware that his or her child under eighteen (18) has registered as a user without their consent, he or she should delete the relevant account or if this is not possible, inform Fanblock immediately.
13 Links to other sites
If any part of the Fanblock Platforms link to other websites, those websites do not operate under this Privacy Policy. If you choose to visit an advertiser or click on another third-party link, you will be directed to that third party's website. We do not exercise control over third party websites and therefore recommend you examine the privacy statements posted on these other websites to understand their procedures for collecting, using and disclosing Personal Data.
14 Changes to this Privacy Policy
The Privacy Policy is available at any time through the Fanblock Platforms and may be amended from time to time. We shall place an updated version on the applicable page of the Fanblock Platforms. The applicable Fanblock Platform may also provide notices of changes to this Privacy Policy or other matters by displaying notices or links to notices to you generally on or within the Fanblock Platforms.
You are responsible for regularly reviewing this Privacy Policy. Fanblock reserves the right to change this Privacy Policy at any time without prior notice to you. We will however notify you where we have made significant changes and where we have a relationship with you.
15 Contact Fanblock
If you have any questions about this Privacy Policy, please contact us on the details below. If you are not satisfied with our response to a complaint you have made, or think we are not complying with data protection law, you can make a complaint to the data protection regulator in your country.
Email: privacy@fanblock.com
Mail: Fanblock AG
Baarerstrasse 12
CH-6300 Zug
Switzerland