Privacy Policy

Latest update: 02/04/2025 – New Policy

This Privacy Policy describes our policies and procedures on the collection, use, and disclosure of your information when You become a member of Football Supporters Europe (FSE) or use the services provided by the Organisation. It also outlines Your privacy rights and how the law protects You. 

FSE uses your Personal Data to maintain and improve services provided by the Organisation. By using such services, you agree to the collection and use of information in accordance with this Privacy Policy. 

If you have any questions about this Privacy Policy, You can contact us by email: info@fanseurope.org with ‘Privacy Policy’ in the Subject Line. 

INTERPRETATION AND DEFINITIONS 

Interpretation 

In this Privacy Policy, each capitalised term will have the meaning set out below. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural. 

Definitions 

For the purposes of this Privacy Policy: 

• Account means a unique account created for You to access our Service or parts of our Service. 

• Organisation (referred to as either “the Organisation”, “We”, “Us” or “Our” in this Privacy Policy) refers to Football Supporters Europe e.V., c/o Jugend und Sport e.V., Bernstorffstraße 172, 22767 Hamburg, Germany. The FSE Office can also be contacted by emailing: info@fanseurope.org. For the purpose of the GDPR, the Organisation is the Data Controller. 

• Cookies are small data files that a website will place on Your computer, mobile device, or any other device, containing the details of Your browsing history on that website. 

• Country refers to: Germany 

• Data Controller, for the purposes of the EU and UK General Data Protection Regulation (“GDPR”)), refers to the Organisation as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data. 

• Device means any device that can access the Service such as a computer, a mobile device or a digital tablet. 

• FSE Facebook Page is a public profile named ‘Football Supporters Europe’ specifically created by the Organisation on the Facebook social network, accessible from  https://www.facebook.com/FansEurope 

• Personal Data is any information that relates to an identified or identifiable individual. For the purposes for GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity. 

• Service(s) refers to the services the Organisation provides by representing the interests of supporters in European football, for example through the website and any other forms of digital communication including our Fans Digest newsletter, network mailing lists, social media activity and interactions, and email responses related to individual requests for support or information, as well as all communication activities related to our membership activities. 

• Service Provider means any natural or legal person who processes the data on behalf of the Organisation. It refers to third-party companies (email marketing service providers, web analytics providers, or member management providers) or individuals employed by the Organisation to facilitate the Service, to provide the Service on behalf of the Organisation, to perform services related to the Service or to assist the Organisation in analysing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors. 

• Website refers to Football Supporters Europe (FSE), accessible at https://www.fanseurope.org/ 

• You means the individual accessing or using the Service, or the Organisation, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable. Under the EU and UK GDPR, You can be referred to as the Data Subject or as the User as you are the individual using the Service. 

COLLECTING YOUR PERSONAL DATA 

Types of Data Collected 

Personal Data 

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You.  

Identity Data 

Identity Data is collected when You contact the Organisation, sign up for our Fan Digest newsletter, register for an Account with Our membership system, submit a membership application on behalf of Yourself or Your fan organisation, request a reimbursement related to membership activities, or voluntarily respond to a survey, registration, or request for certain information. The data includes Your name, surname and Date of Birth. Date of Birth is collected related to membership applications only and is to ensure delegates are at least 18 years of age and eligible to vote. 

Contact Data 

Contact Data is collected when You contact the Organisation, sign up for our Fan Digest newsletter, register for an Account with Our membership system, or submit a membership application on behalf of Yourself or Your fan organisation, or voluntarily respond to a survey or request for information. This data may include email addresses, phone numbers, and in the case of membership applications, a postal address (membership applications), or age range (FSE Away Fan survey). Your postal address is collected as a means to verify membership identity and produce anonymised data such as the number of members in each country. 

Financial & Transaction Data 

The Organisation may request or store some financial data from You in relation to reimbursement of costs incurred during membership-related activities. Donations to the Organisation’s activities may be made through PayPal (https://www.paypal.com/donate/?cmd=_s-xclick&hosted_button_id=TS6BE6RX8Z7WQ&ssrt=1704797236910), after which the Organisation receives a notification of such a donation which includes Your name, email, transaction ID number, and the amount donated.  

• Technical & Usage Data 

Usage Data 

Usage Data is collected automatically when using the Service(s) provided. 

Usage Data collected when You interact with Our Website may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers, and other diagnostic data. 

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data. 

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device. 

The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies. 

USING YOUR PERSONAL DATA 

The Organisation may use Personal Data for the following purposes: 

• To provide and maintain our Service: using your Identity, Financial and Contact Data to send you our Fan Digest newsletter once a month and membership updates as needed. Where You have requested Our Services, these activities are necessary to provide You with those Services under the contract between You and Us. It is also in our legitimate interests to provide and maintain our services by sharing relevant information to You and inviting You or your fan organisation to share relevant information when appropriate 

• To manage Your Account: using your Personal and Contact Data to create Your user profile and to keep a record of You as a member. Where You have requested Our Services, these activities are necessary to manage Your Account and fulfil the contract between You and Us. It is also in Our legitimate interests to keep accurate and up to date business records of all account users to allow Us to meet all legal obligations for compliance or tax purposes 

• To manage Your Membership: using Identity, Financial and Contact Data to create and maintain a membership profile for You, as well as your fan organisation(s) if relevant. It is in Our legitimate interests to communicate information including updates about Our Biannual General Meetings, constitutional changes, annual reports, and membership activities to You to keep you updated and to promote transparency. In some instances, We are required to collect and retain information for compliance with Our legal obligations 

• To contact You: using your Identity and Contact data to contact You by email or other equivalent forms of electronic communication, such as messenger applications and social media platforms regarding relevant updates or informative communications related to the Organisation’s main activities. It is in Our legitimate interests to respond to queries made to us and reach out when appropriate to provide new and/or additional service updates as needed.  

• For business transfers: We may use Your Personal Data to evaluate or conduct a merger, divestiture, restructuring, reorganisation, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred. It is in our legitimate interests to act in the best interests of the Organisation at all time. We may also process your Personal Data in these situations, in order to comply with Our legal obligations.  

• To analyse the way You use our Services: using your Usage Data to improve Our Website, Services and relationships to measure how You use Our Website.  

• Aggregated/Anonymised Data: We may collect, use and share Your aggregated or anonymised data such as statistical or demographic data for reporting purposes, including membership analysis, identifying trends and to improve our Service and Your experience with Us. Aggregated Data could be derived from your Personal Data, but it is not considered Personal Data in law as this data will not directly or indirectly reveal Your identity.  

We may share Your Personal Data in the following situations: 

• With Service Providers: We may share Your Personal Data with Service Providers to monitor and analyse the use of our Service 

• For business transfers: We may share or transfer Your Personal Data in connection with, or during negotiations of, any merger, sale of Organisation assets, financing, or acquisition of all or a portion of Our business to another Organisation. 

• With other users: when You share Personal Data or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. 

• With Your consent: We may disclose Your Personal Data for any other purpose with Your consent. 

Third party Service Providers 

The Organisation uses the following third-party Service providers to monitor, analyse, and improve the Services provided. 

• Google Analytics: Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track, monitor, and create aggregated reports about the use of our Service. This data is shared with other Google services; however, the monitoring and reporting is for internally use only and not shared with any other third party. Google may use the collected data to contextualise and personalise the ads of its own advertising network. You can opt-out of having your activity on the Service being made available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity, or by using your browse in ‘Private’ or ‘InCognito’. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page:  https://policies.google.com/privacy 

• Mailchimp: Mailchimp is an email marketing service provided by The Rocket Science Group LLC, which is part of the Intuit group. The Organisation uses its services to send its monthly Fan Digest newsletter and membership-related communications. Members and members of the general public receive Our Fans Digest newsletter by signing up to membership (in the case of members) or by using the sign up form on our website, popup form on our website, or via a hosted form shared via FSE’s communications channels. FSE members also receive updates about their membership and practicalities of that, including notices of meetings and BGMs. You may opt-out of receiving any, or all, of these communications from Us by using the unsubscribe link or instructions provided in any email We send. 

FSE uses MailChimp’s default privacy setting which track Open Rates, Clicks, Unsubscribes, Your Device Type, Predicted Demographics (including age and gender), and Your location by country. Anonymised data is reporting within the FSE’s team only, and never shared with any external third party. For more information on the privacy practices of Mailchimp please visit their Privacy policy:  https://www.intuit.com/privacy/statement/  

• SheepCRM: SheepCRM is a cloud-based Customer Relation Management system provided by Authentic Digital Limited in the United Kingdom. The Organisation uses its services to maintain its membership database including the creation of accounts (users), member profiles (for individual members and fan organisations), record changes to membership records, and communication with members on specific topics within the platform itself. For more information about SheepCRM’s privacy policy, visit: https://sheepcrm.co.uk/privacy-policy. Full details of SheepCRM’s Data Processing Agreement can be found here: https://sheepcrm.co.uk/data-processing-agreement.  

• Invisible reCAPTCHA: We use an invisible captcha service named reCAPTCHA to add a layer of security to our Fan Digest sign up form. reCAPTCHA is operated by Google. The reCAPTCHA service may collect information from You and from Your Device for security purposes to ensure You are a human being. The information gathered by reCAPTCHA is held in accordance with the Privacy Policy of Google:  https://policies.google.com/privacy 

Tracking Technologies and Cookies 

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyse Our Service. For more information about the cookies We use and Your choices regarding cookies, please visit our Cookies Policy: https://www.fanseurope.org/cookies-policy/

Retention of Your Personal Data 

The Organisation will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with Our legal obligations (for example, if We are required to retain Your data to comply with applicable laws), resolve disputes, and enforce Our legal agreements and policies. 

The Organisation will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods. 

Transfer of Your Personal Data 

We will share Your Personal Data within our Organisation. This may involve transferring Your Personal Data to the UK or the EEA, depending on where You are based. If we transfer Your Personal Data outside of the UK or EEA to countries which have laws that do not provide the same level of data protection as UK or EEA laws, We ensure that a similar degree of protection is afforded to it by ensuring that appropriate safeguards are implemented.  

Service provider operations outside of the EEA & UK 

As Mailchimp has servers in the US, Your Identity and Contact Data may be transferred to the US when the Organisation uses Mailchimp to send Our Fan Digest newsletter and membership updates. Mailchimp uses specific standard contractual terms approved for use in the UK and EEA which give the transferred Personal Data the same protection as it has in the UK and EEA, namely The International Data Transfer Addendum to the European Commission’s standard contractual clauses for international data transfers to ensure Personal Data from the UK and EEA receives the same level of protection when it is transferred to the US. 

The Organisation does not currently use the services of any other Service provider based outside of the EU and UK. 

Disclosure of Your Personal Data 

Business Transactions 

If the Organisation is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy. 

Other legal requirements 

The Organisation may disclose Your Personal Data in the good faith belief that such action is necessary to: 

• Comply with a legal obligation 

• Protect and defend the rights or property of the Organisation 

• Prevent or investigate possible wrongdoing in connection with the Service 

• Protect the personal safety of Users of the Service or the public 

• Protect against legal liability 

Security of Your Personal Data 

The security of Your Personal Data is very important to Us and a key and ongoing priority for the Organisation; however, remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.  

To mitigate this risk, we have put in place appropriate security measures to prevent Your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to Your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions, and they are subject to a duty of confidentiality. 

We have put in place procedures to deal with any suspected Personal Data breach and will notify You and any applicable regulator of a breach where We are legally required to do so. 

DETAILED INFORMATION ON THE PROCESSING OF YOUR PERSONAL DATA 

GDPR PRIVACY 

Legal Basis for Processing Personal Data under GDPR 

We may process Personal Data under the following conditions, which we have identified above under “Using Your Personal Data”: 

• Consent: You have given Your consent for processing Personal Data for one or more specific purposes. 

• Performance of a contract:  Where processing is necessary for Us to provide the Services under Our contract with You. 

• Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Organisation is subject. 

• Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person. 

• Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Organisation. 

• Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Organisation. 

In any case, the Organisation can help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract at any time by emailing: info@fanseurope.org. 

Your Rights under the GDPR 

The Organisation undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights. 

You have the right under this Privacy Policy, and by law if You are within the EU, to: 

• Request access to Your Personal Data. The right to access, update, or delete the information We have on You. In relation to sheepCRM, You can access, update or request deletion of Your Personal Data directly within Your account. If You wish to do this with the Personal Data We hold about you and You are unable to perform these actions Yourself, please contact Us by emailing: info@fanseurope.org. This also enables You to receive a copy of the Personal Data We hold about You. 

• Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected. 

• Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes. 

• Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it. 

• Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You. 

• Withdraw Your consent. You have the right to withdraw Your consent for Us to use your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service. 

Exercising of Your GDPR Data Protection Rights 

You may exercise Your rights of access, rectification, cancellation, and opposition by contacting Us at: info@fanseurope.org. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible. 

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA. A list of Data Protection Authorities with their contact details is available here: https://digital-strategy.ec.europa.eu/en/library/list-personal-data-protection-competent-authorities 

FSE’s FACEBOOK PAGE 

Facebook Insights 

We use the Facebook Insights function in connection with the operation of the FSE Facebook Page and on the basis of the GDPR, in order to obtain anonymised statistical data about Our users. 

For this purpose, Facebook places a Cookie on the device of the user visiting Our Facebook Fan Page. Each Cookie contains a unique identifier code and remains active for a period of two years, except when it is deleted before the end of this period. 

Facebook receives, records, and processes the information stored in the Cookie, especially when the user visits the Facebook services, services that are provided by other members of the Facebook Page and services by other companies that use Facebook services. 

 Visit the Facebook Privacy Policy (https://www.facebook.com/privacy/policy/) for more information about how Facebook manages Personal data or contact Facebook online, or by mail: Facebook, Inc. ATTN, Privacy Operations, 1601 Willow Road, Menlo Park, CA 94025, United States. 

CHILDREN’S PRIVACY 

Our Service is not intended for anyone under the age of 13. We do not knowingly collect Personal Data from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us by emailing: info@fanseurope.org. If We become aware that We have collected Personal Data from anyone under the age of 13, without verification of parental consent, We will take steps to remove that information from Our servers. 

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent’s consent before We collect and use that information. 

LINKS TO OTHER WEBSITES 

Our Service (website and newsletters) may contain links to other websites that are not operated by Us. If You click on a third-party link, You will be directed to that third party’s site and We may be aware of this action (Click on Link) because of the analytics tools currently in place. We strongly advise You to review the Privacy Policy of every site You visit. 

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services. 

CHANGES TO THIS PRIVACY POLICY 

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page. 

We will outline key changes and update the “Last updated” date at the top of this Privacy Policy every time a change is made, and include a notification in our subsequent Fans Digest newsletter and Membership mailing. 

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page. 

CONTACT US 

If you have any questions about this Privacy Policy, You can contact us by email: info@fanseurope.org with ‘Privacy Policy’ in the Subject Line.