REAL MADRID CLUB DE FÚTBOL General Policy for the Protection of Personal Data
Who is responsible for the processing of your data?
Identity: Real Madrid Club de Futbol
Postal address: Av. Concha Espina, número 1, 28036, Madrid
Contact Data Protection Office: email@example.com
How will we process your data?
In compliance with the provisions of current legislation on data protection, and in the context of the new regulatory framework established by virtue of the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council, of 27 April 2016, relating to the protection of natural persons with regard to the processing of personal data and the free circulation of said data (hereinafter, the "General Regulations"), and the national regulations on the protection of personal data, we inform you that the personal data that you provide us (hereinafter, the "Data"), will be subject to processing by Real Madrid Club de Futbol (hereinafter, "Real Madrid", or the " CLUB ", indistinctly), with registered office in Madrid, Avenida Concha Espina, 1, 28036, Madrid (Spain).
You declare that the information and data you have given us is accurate and true, reserving the CLUB the right to exclude from the services those interested parties who have provided false information, without prejudice to legal action. You will be solely responsible for any false or inaccurate statements that you make and for the damages caused to the CLUB or to third parties.
All the fields that appear on the Real Madrid forms will be required to be completed, so the omission of any of them may lead to it being impossible for us to meet your request, unless the form itself has fields of voluntary completion.
Personal data will be treated with the degree of protection legally required to avoid any loss, alteration, treatment or unauthorised access.
If you have any questions regarding data protection you can contact the Real Madrid Data Protection Office through the email firstname.lastname@example.org.
With what purpose and legitimacy do we process your personal data?
In general, your data will be processed by the CLUB for the fulfilment of the following purposes:
- Management of your relationship with the CLUB: Real Madrid will be able to process your data for the management of your relationship with the CLUB, including in this process, the development of any operation necessary for its maintenance.
- Organisation of services and events: The CLUB organises draws, competitions and promotional events. In these cases, the interested party who wants to participate, will sign up voluntarily by completing the forms that the CLUB provides for this purpose. The CLUB will process the data obtained through the participation forms in these services and events in order to be able to manage the interested party's participation, as well as the publication of the prizes, or any additional information that may be necessary, in the event that it occurs. This process will only be carried out if Real Madrid has the consent of the interested party.
- Management of requests and applications: In order for Real Madrid to manage those requests and applications that you send us, the CLUB will process the information you provide. This information will allow the CLUB to give you an answer to them, and to put at your disposal solutions that adapt to your needs. The CLUB undertakes to process the data obtained and provided by you as long as they are necessary for the purpose described.
- Sending newsletters and magazines: Real Madrid will carry out, both by ordinary and electronic means, the sending of newsletters and magazines, as well as information on the activities and services of the CLUB, as long as you have consented to this service.
Whenever this service is carried out by electronic means, it will be legitimised in satisfying the legitimate interests of the CLUB, by virtue of the provisions of article 21 of Law 34/2002, from July 11, on services of the company of information and electronic commerce, as well as the European Regulation of Commercial Electronic Communications. At any time you can object to this service through contact with the Real Madrid Data Protection Office in the email mentioned above.
- Conducting surveys on customers or potential customers: In order to verify the quality of communications, the procedures of Real Madrid, the service we provide, as well as the products and services that we provide, the CLUB may conduct satisfaction surveys.
This process is based on the legitimate interest of the CLUB. In order to improve our procedures, we can contact you to find out your level of satisfaction with them, and thus be able to improve those issues that require your greatest satisfaction. You can always object to receiving any communication of this nature through contact with the Real Madrid Data Protection Office in the email address mentioned above.
- Communication of your personal data to third parties collaborators and sponsors: Real Madrid may, on certain occasions, communicate your personal data to collaborators and sponsors for the development of commercial actions by them (through post, mailing, fax, SMS, electronic mail and any telematic means) by means of a general nature or adapted to your personal characteristics, as long as you have given your consent through the form established for that purpose. Also, we inform you that you can oppose and/or withdraw your consent for this service at any time.
- Distribution of correspondence and commercial offers
7.a) Distribution of correspondence and commercial offers regarding the Club's products and services that are the same or similar to those that you have previously engaged or purchased, on the basis of the legitimate interest that Real Madrid holds in this regard and, in relation to correspondence sent electronically, as stipulated in Article 21 of the Law 34/2000, 11 July, relating to services in the information society and digital business. We will handle your personal data for these purposes as long as you don't oppose such handling.
7.b) Distribution of correspondence and customised commercial offers of the Club's products and services, as well as, products and services offered by our sponsors and partners, where relevant, as long as you have given us your sent to do so and have not withdrawn your consent or opposed such handling of your personal data. You can withdraw your consent at any time, as is indicated below.
Customisation of commercial and promotional offers: During the maintenance of your relationship with the CLUB, the personal data that you make available to us through any website, web form or application made available to you, or the contracting of products and services, may be subject to automated decisions that have legal implications on your person, as well as the creation of profiles, including automatic techniques that use the current data, navigation data from cookies, historical and statistical, data that can be obtained through other sources of information (third-party sources and social networks), for the optimisation of the product offers that we make available, prices and new proposals, through segmentation in different groups in relation to common patterns. This process will only be carried out if the CLUB has the consent of the interested party.
Additionally, in the event that you are a member of the Club Membership group, you can contact the Online Partner Service Office (https://socios.realmadrid.com), registering and identifying yourself beforehand with your Membership number. In order to oppose and/or withdraw your consent for this at any time.
- In the case that you are a member of Real Madrid Club de Fútbol, the CLUB could process your data for the following purposes with additional character:
- Management of the relationship with the members, basketball season ticket holders and holders of the electronic ticket, including economic, accounting, fiscal and administrative management, among others: The CLUB will be able to process your data for the management of your membership status, including this service, the modification and/or updating of your data, changing of personal data, modification of bank account details, updating the members of the family unit, updating of photos, requesting of duplicates, monitoring of payments and status of social quotas, management of the financing of social quotas, management of the request for the reduction of quotas.
In the same way, your data will be processed for the application of football or basketball subscription management, request for visits to the Sports City, management of the purchase of tickets at the Santiago Bernabéu Stadium and on trips outside the stadium such as basketball and Real Madrid Castilla, in case it is necessary due to its physical condition, the management of the ticket and circulation of the sports grounds, request for tickets for the concerts held at the Santiago Bernabéu Stadium, and the management of complaints, claims and/or suggestions.
- Management of membership registration and cancellation, registration and cancellation of football and basketball subscribers, whether temporary or permanent, registration and cancellation of electronic tickets: In order for the CLUB to manage all registrations and cancellations of member registrations and subscribers, temporary or definite, football or basketball, the CLUB will treat the information you provide, including that which could be obtained from the navigation through the website. This information will allow the CLUB to know your profile, and thus be able to make better offers, and put at your disposal information that may be of interest to you about events and activities organized by the CLUB. The CLUB undertakes to process the data obtained and facilitated by you for the maintenance of its membership status, and the relationship it maintains with the CLUB, provided that this data is necessary for the purpose described.
- Management of incidents in the stadium and infractions according to the Disciplinary Rules of the Club: Likewise, you are informed that the CLUB will process your personal data, as long as this relates to altercations, fights, brawls or public disorder in which you may be involved, as well as to deal with infractions stipulated in the Regulations of the Club's Disciplinary Committee. This data may be communicated to the authorities and security forces and bodies for judicial purposes and citizen security. On the other hand, you also know and consent that personal data related to such situations may be notified by these authorities to the CLUB for the purposes indicated above.
- Additionally, in the event that you are part of the Madridista Loyalty Program, holding the status of Madridista, we will treat your information with the following purposes:
- Management of the relationship with the Madridista and access to the advantages of the Loyalty Program: The CLUB will be able to process your data for the management of your Madridista status, included in this service is the development of any operation and, by way of example and not limiting, the provision of the Madridista Card, the modification and/or update of your data, change of personal information, modification of bank account details or means of payment, request for duplicates, and the monitoring of your payments.
Real Madrid will process your data for the exploitation of the Madridista program, as well as any other complementary means put at your disposal in the terms set out in the General Conditions of the Madridista Loyalty Program, such as the "Promotional Media", making available the "Advantages offered by the Madridista Program", and the access and enjoyment of the promotions, advantages and additional draws that, if applicable, are developed and that will be considered "Special Advantages".
The Advantages and/or Special Advantages may be offered by Real Madrid or by, entities collaborating or sponsoring the Club, successively related to or incorporated into the Madridista Loyalty Program.
- Sending newsletters, magazines, and communications to the Madridista Loyalty Program: We also inform you that your information may be processed to keep you informed of the activities and procedures related to your Madridista status, news and organisation of organised events by the CLUB and, occasionally, the CLUB will carry out, both by ordinary and electronic means, the sending of newsletters and magazines, as well as information about the activities and services of the CLUB, in the terms included in the General Program Conditions of the Madridista Loyalty, as long as the Madridista has not opposed this service. This service is based on a legitimate interests of the CLUB, in relation to the need to keep the Madridista informed about the exclusive advantages derived from their participation in the Madridista Loyalty Program.
In accordance with the previous, whenever this service is carried out by electronic means, and refers to products and services related to the CLUB, it will be legitimised in satisfying the legitimate interests of the CLUB, pursuant to the provisions of article 21 of Law 34/2002, from July 11, on services of the information society and electronic commerce, as well as the European Regulation of Electronic Commercial Communications. The Madridista may oppose this service at any time.
- Failure to comply with the General Conditions of the Madridista Loyalty Program: In addition, the CLUB may proceed to process your personal data, in relation to improper use of the Madridista Loyalty Program, in order to process your cancellation and cancellation thereof, and/or the Promotional Media, and to terminate the enjoyment of the Advantages and/or Special Advantages, in the terms set out in the General Conditions of the Madridista Loyalty Program. The CLUB will carry out this service in order to guarantee the correct development of its relationship with the Madridista, not exceeding in any case the scope of this purpose, and acting in strict compliance with the current legislation.
- If you were a member of one of the official supporters’ clubs associated with the CLUB (hereinafter, "Peñista"), Real Madrid will be able to process your data for the following purposes with additional character:
- Management of the relationship with the Peñista: The CLUB will be able to process its data for the management of its Peñista status, including this service the development of any operation and, by way of example and not limitation, the modification and/or updating of its data.
- In the event that you are a Legal Representative or Contact Person of any of the entities with which Real Madrid Club de Fútbol has a relationship, we will process your personal data as informed below:
Purpose: Real Madrid Club de Fútbol process your personal data in order to control the development and fulfilment of the contracts subscribed by the Club and other entities or persons, as well as to maintain contact with them. The processing of your data is necessary for the fulfilment of the contractual relation, as well as to satisfy the legitimate interest of the Club in the indicated pursued purpose. Your data will not be used by Real Madrid for any ulterior purpose nor will they be the object of automated individual decisions.
Category and origin of the data: The data of yours that we process are identifying and of a labour or professional nature and of another type (powers of attorney) and may have been provided to us by you or your legal representative, by the entity or person for whom you work or whom you represent and with whom the Club relates and who has been able to provide them to us directly or through another entity by virtue of a contract or commitment signed with the former.
Storage period: We will store your data for these purposes for as long as the contractual relationship remains in force and subsequently, for an additional and foreseeable period of 5 years (or period that in the future is legally established for the prescription of personal claims) for the purposes of possible exercise or defense of claims.
Recipients of your data: Your data may be communicated to the sponsoring and collaborating companies of the Club (which you can consult here), as well as to the Fundación Real Madrid provided that you have given us your consent to this effect or that it is necessary for the execution and fulfilment of the contracts subscribed by the Club. Additionally, if necessary, we may share your personal data with Administrations or Public Bodies (in order to obtain licences or project accreditation), Registrators and Notaries, legal service professionals and Courts or other dispute resolution bodies. In the event that any of these recipients is located outside the European Economic Area (EEA), such transfer is justified insofar as it is necessary for the conclusion or execution of a contract that is of interest to you, or because it is necessary for the formulation, exercise or defence of claims.
- In the case that you are attending events and games:
- Recording of your image for video-surveillance purposes: based on the legal obligation established by Law 19/2007 against violence, racism, xenophobia and intolerance in sport and the regulations that develops it, as well as in accordance with the legitimate interest that the CLUB holds in conducting identification, control and security activities within its facilities, which is coincident with the public interest.
Your data will be stored for these purposes for a maximum period of one month from the time of collection, except in those cases where they must be kept to evidence the perpetration of actions that undermine the integrity of persons, property or facilities.
- Recording and diffusion of your image as an attendant to the event and/or specific game: on the basis of the legitimate interest that assists the CLUB in this regard, your image may be recorded and diffused, in an incidental manner, during the recording and broadcasting of the event and/or game for informative purposes. Your data will be processed as long as this legitimate interest is maintained.
- In case that you have acquired a ticket for a match/event
- Manage the relationship with the Club and associated obligations, including the provision of post-sale service and management, invoicing and collection and the fulfilment of accounting and tax obligations. The Club is entitled to carry out these tasks as they are necessary for the development of the contractual relationship that binds the Club to you, as well as for compliance with the regulations to which the Club is subject.
- Compliance and security control, which includes advice and legal defence of the Club, control of compliance with regulations, security in our facilities, including by means of video surveillance, as well as the security of games outside our facilities (including the making of a local supporters list), for which the Club is legitimised by the legitimate interest that the Club has in ensuring the correct development and safety in its activities, as well as being necessary to ensure the public interest and compliance with the regulations to which the Club is subject.
- Diffusion of the event with informative purposes, based on the legitimate interest that assists the CLUB in this matter, your image may be captured and diffused, in an accessory manner, during the recording and broadcasting of the event and/or match with informative purposes.
Your data has been provided to us directly by you or your legal representative or, exceptionally, by third parties: External portals authorized by the Club for the purchase of tickets, external Agencies and the Media which provide us with images of matches and events, as well as, only if applicable, people related to a claim or incident in which you may be involved or interested.
We will store your data on an ordinary basis until the contracted services are provided and, thereafter, duly blocked, for a period of 5 years or the legal period foreseen for the eventual defense or filing of claims. However, the data related to the invoicing and accounting will be kept for a period of up to 10 years from the accrual date derived from the purchase of the ticket, and any data obtained from the recording as an attendee to the event and/or specific match will be stored for as long as the journalistic interest remains and, in any case, for the Club's own newspaper library.
c) Categories of personal data to be processed: For the aforementioned purposes, we process identifying data of personal, economic and/or financial characteristics relating to the transaction, the sales channel, date of the operation, amount of the operation, sector, row, seat, match ID, locator, time of the match, working day, type of entry (VIP or Regular), identification number in case you were a member of Real Madrid Club de Fútbol and/or part of the Madridista Loyalty Program, in the case of out-of-home matches the means of transport to the destination and, only if necessary, data relating to claims or incidents in which you may be involved or interested in.
d) Recipients of your data:
We may share your data with the following entities and/or individuals:
- Financial entities for the management of collections and payments.
- Sports Organizations, rival Clubs, National Police (in the case of out-of-home matches).
- Tax Agency, Institute of Accounting and Account Auditing and other bodies, competent administrations and entities or that are legally qualified or authorized.
- In the event of eventual claims and/or infringements: Courts and Tribunals and other dispute resolution bodies, such as Arbitration Courts and mediators, State Security Forces and Corps, Notaries, Insurance Companies, Federations and Sports Clubs.
- In the unlikely event of a data protection incident: Spanish Data Protection Agency or other competent Control Authority, as well as other entities involved in a data protection incident to whom said incident has to be reported.
- Diffusion of match images to external media, as well as to the general public through the Club's diffusion channels.
- Prodware Spain, S.A.
- Onebox Ibérica, S.L.
- Ilunion Outsourcing, S.A.
- Correos and other companies of messaging and management of postal shipments.
- Providers of collection and accounting services.
- Computer and storage services (Microsoft).
- Professionals and companies of legal advice, consultancy and/or audit.
- Other suppliers that can complement or replace the previous ones.
As a result of data disclosures and/or the above referred processing agreements, your personal data may be transferred to:
- Sports Organizations, Federations and other Clubs outside the European Economic Area (EEA), being this transfer covered due to being necessary for the proper provision of the product/service purchased by you.
- Microsoft, in the United States, ensuring an adequate level of protection due to the adhesion of this company to the system of the Agreement EU - USA "Privacy Shield", from which you can obtain more information here.
- In the event of eventual claims and/or infringements involving interested parties outside the EEA: Courts, Tribunals, Arbitration Courts and Mediators, Insurance Entities and Federations and Sports Clubs outside the EEA, the transfer being covered as necessary for the formulation, exercise or defence of claims.
If you are the legal Representative or Contact for one of the entities Real Madrid Club de Fútbol works with, we will treat your personal data in line with the following:
Aim: Real Madrid Club de Fútbol will treat your personal data in order to control the development and fulfilment of the contracts that involve the Club and other entities or persons, as well as to communicate with them. Data processing is necessary to fulfil the contractual relationship, and to satisfy the Club’s legitimate interest in the aforementioned purpose. Your data will not be used by Real Madrid for ulterior means, nor will it be object of automated individual decisions.
Category and origin of the data: Any data of yours that we handle is for identification, for work related and professional purposes amongst others (powers of representation) and may have been provided by you or your legal representative, by the entity or person for you work for or are represented by, and with whom the Club deals with. The data may have been provided to us directly or from another entity under a contract or agreement detailed within.
Data retention period: We will keep your data for the aforementioned purposes for the duration of the contractual relationship and subsequently, for an additional, forecast term of five years (or a term that is legally established in the future for such actions) in order to take action or deal with any complaints.
Recipients of your data: Your data may be passed on to companies that sponsor or collaborate with the Club (these can be seen here), as well as the Real Madrid Foundation, provided that the necessary consent has been given for the implementation and fulfilment of the contracts signed by the Club. In addition, and if necessary, the club could pass on your personal data to Public Administrations or Bodies (in order to obtain licences or accreditation for projects), Registrars and Notaries, legal professionals and Courts, as well as other conflict resolution bodies. If any of these recipients are outside of the European Economic Area, said transfer would be justified where necessary to carry out or execute a contract in its interest, or if it is necessary for developing, acting on or dealing with complaints.
- Finally, in the event that you register for any of the official CLUB websites, or the forms that the CLUB makes available to you, Real Madrid may process your data for the following purposes with additional character:
- Management of registration and cancelations of users: In order for Real Madrid to manage all registrations and cancellations of user registrations made through any website, form or application made available to them, and whenever applicable, the CLUB will treat the information you provide, including that which may be obtained through any website, web form or application that is made available to you. This information will allow the CLUB to know your profile, and thus be able to make better offers, and put at your disposal information that may be of interest to you about events and activities organised by the CLUB. The CLUB undertakes to process the data obtained and provided by you for the maintenance of your registration as a user and for the management of your relationship with the CLUB, provided that this data is necessary for the purpose described, as well as for the management of the rest of purposes that we inform you.
- The personalisation of our commercial and promotional offers: During the maintenance of your relationship with the CLUB, the personal data that you make available to us through any website, web form or application made available to you, or the contracting of products and services, may be subject to automated decisions that have legal effects on their person, as well as the creation of profiles, including automatic techniques that use the current data, navigation data from cookies, historical and statistical, data that can be obtained through other sources of information (third-party sources and social networks), for the optimization of the product offers that we offer, prices and new proposals, through segmentation in different groups in relation to common patterns. This process will only be carried out if the CLUB has the consent of the interested party.
- Processing of data relating to own and third party cookies in order to analyse your browsing habits and improve services: You can consult the detail of the information on the cookies policy of Real Madrid in the use of the aforementioned data in the following link https://www.realmadrid.com/en/legal/cookies-policy.
How do we guarantee the security of your data?
Real Madrid maintains security measures to protect personal data in accordance with the content of the provisions of the GDPR, and has established all the technical means at its disposal to prevent loss, misuse, alteration, unauthorised access and theft of data that you provide us with.
How will minors' data be processed?
Real Madrid will not collect or process personal data for children under fourteen (14) years of age, without fully complying with the requirements established in the applicable data protection regulations, regarding compliance with the duty to inform and obtain those consents that they are necessary.
How long will we keep your data?
The personal data that is accessed by virtue of your relationship with the CLUB will be processed as long as they are accurate for the management of the purposes reported. In this sense, the CLUB will keep the personal data once its relationship with you is duly blocked, during the limitation period of the actions that may arise from the relationship maintained with the interested party.
Once blocked, your data will be inaccessible to the CLUB, and will not be processed by it, except for making it available to Public Administrations, Judges and Courts, for the attention of possible responsibilities arising from the process, as well as for the exercise and defence of claims before the Spanish Agency for Data Protection.
Finally, the CLUB will retain your data with a view to keeping you updated about the Real Madrid products, events and services that may be of interest to you up until such point as you withdraw your consent or request to be unregistered.
Who will receive your data?
Real Madrid will communicate your personal data:
2. Public Organisations, Judges and Courts and, in general, competent Authorities, when the CLUB has the legal obligation to provide them.
3. The CLUB has the collaboration of some third-party service providers that have access to your personal data and that the referred data in the name and on behalf of Real Madrid as a consequence of the provision of services.
Additionally, the CLUB has contracted the provision of services by the Microsoft Corporation, in charge of data processing located in the United States, a country that does not belong to the European Economic Area. Real Madrid has signed with this company Type Contract Clauses (TCC) that legitimize the international transfer of data.
4. In the event that you are an attendee at events and games: your data may be disclosed to diverse media and specialized websites, which may be based outside the European Economic Area (EEA), in which case the CLUB has adopted the relevant warranties by signing standard contractual clauses, of which, if required, we would provide you with a copy upon request.
What are your rights when you provide us with your data?
You may, in relation to the processes that are based on obtaining your consent, withdraw your consent through the procedure detailed in the following paragraph.
You may exercise, if you wish, the rights of access, rectification and deletion of data, as well as request that you limit the processing of your personal data, oppose it, request the portability of your data, as well as not be subject to automated individual decisions, sending a written communication or contacting the CLUB through the following email address: email@example.com.
You can also contact the CLUB by postal mail at the address: Av. Concha Espina, number 1, Madrid.
Against which authority can you exercise your claims?
You can file a complaint with the CLUB's Data Protection Office, through the address firstname.lastname@example.org, or in the post to Avenida de las Fuerzas Armadas, number 402, Madrid, in order for us to satisfy your rights in this matter. In any case, you can always go to the Spanish Agency for Data Protection in C/ Jorge Juan number 6, Madrid as the control authority in matters of data protection.
How can I contact the Real Madrid Data Protection Delegate?
For any questions relating to the processing of your data, or if you have any issue or comment that you wish to make that are linked to data processing that Real Madrid carries out, you can contact our Data Protection Delegate using the following means: Postal address: Avenida de las Fuerzas Armadas, number 402, 28055, Madrid E-mail: email@example.com.