Summary 
Dair Ltd (‘Dair’) is committed to protecting your personal data and handling it responsibly. 

This policy covers the personal data that Dair collects whenever you interact with us, including when you use our websites and apps, when you attend our events and when you correspond with us (such as by email or over the phone).  It also covers personal data that we may receive from third parties.  

The sections below explain in more detail:

• the types of personal data we collect from you
• the types of personal data we receive from third parties
• why we process your personal data
• who we share your personal data with
• personal data transfers outside of the EEA
• how long we retain your personal data
• your rights to withdraw your consent and to object (including to direct marketing)
• your other personal data rights
• how to contact us and exercise your rights
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If you would like to know how we collect information about your use of our websites, apps and social media sites, you can read our Cookies Policy here

Personal data Dair collects from you

We collect personal data from your interactions with us, such as when you engage with our websites and apps, attend an event, or when you email or phone us. 

The personal data we collect from you includes:

• the name and contact details that you provide when you register as a member with us
• your payment and address details
• your marketing preferences, including any consents you have given us
• your browser or device information
• information about your use of our websites and apps
• your communications with us
• information about your attendance at Dair events.  Photos and video footage of you may be taken at these events

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Personal data Dair receives from third parties
Sometimes we receive personal data from third parties, in particular:  

• online personalisation providers tell us how you engage with our websites and apps  
• data specialists provide us with insights about our supporters, based on their own aggregated data sets
• if you register as a supporter using your social media account, the social media platform provides us with information that you have consented to share with us
• government and law enforcement authorities provide us with personal identification and background information when they are involved in official inquiries
• agencies who partner with Dair may share information with us about supporters that we refer to them

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Why Dair processes your personal data
This section explains the reasons why we process your personal data and our legal bases for doing so.

Consent
If you’ve opted-in to receive information and offers relating to Dair and our commercial partners (for example by ticking a box on one of our websites or apps), then we’ll provide this information to you by email, text, or phone. 

We also rely on your consent to process information about your use of our websites, apps and social media sites, so that we can improve your browsing experience and deliver online advertising that is relevant to you (for more information, click here to see our Cookies Policy).

And occasionally we may rely on your consent to process health or other sensitive information.

Wherever we rely on your consent to process personal data, you have a right to withdraw that consent

Legitimate interests
We process your personal data when necessary to pursue our legitimate interests in the following:  

• tailoring our websites and communications for you.  We collect information about your engagement with us online (such as pages that you have visited on our websites or apps) and combine that with aggregated insights we have about our supporter base, to build a fuller understanding of your individual preferences
• monitoring, improving and protecting our products, content and services
• checking the credit or debit card details you provide (to process your payments and prevent fraudulent transactions)
• sending you some types of direct marketing, including by email and post
• responding to your comments or complaints
• undertaking, or inviting you to take part in, market research
• querying whether you have had an issue completing an online form
• preventing, investigating and/or reporting fraud, terrorism, misrepresentation, security incidents or crimes
• managing legal claims, compliance, regulatory and investigative matters
• processing job applications
• administering programmes run by us or our partners that you have chosen to participate in

You have a right to object to any processing that we undertake for our legitimate interests. 

Contract
We process your personal data when necessary for contractual reasons, such as to administer your account registration and competition entries and to provide products and services that you have requested.

Legal obligation
We are legally required to process your personal data in cases where we need to:

• obtain parental consent to provide online services directly to children
• respond to certain requests by government or law enforcement authorities 

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Who Dair shares personal data with
We will share your personal data with the following recipients:

• commercial partners, so they can advise us how best to communicate with you on their behalf.  We do not give your data to partners for them to communicate with you directly
• third party suppliers involved in: data insights; website hosting; online personalisation; advertising; systems maintenance; ticketing; database management; identity checking; payment processing; delivery logistics; and credit and debt management   
• government authorities or law enforcement officials, to assist with their official requests and comply with our legal obligations  
• agencies who partner with Dair (if you have been referred to those agencies through us)

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Personal data transfers outside of the EEA

The EEA includes all EU countries, as well as the UK, Iceland, Liechtenstein and Norway.  Some of the third parties that we share personal data with may need to transfer personal data outside of the EEA, for example to the United States of America

Where your personal data is transferred to a country outside of the EEA and that country is not subject to an UK adequacy decision, we will ensure your data is protected by appropriate safeguards (for example, UK approved standard contractual clauses, a Privacy Shield certification, or a supplier’s Binding Corporate Rules). 

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How long Dair retains personal data
We retain personal data about your Supporter membership for as long as your account remains active, and for a limited period of time afterwards (in case you decide to reactivate your membership or have queries about it).

We retain personal data relating to your purchases for several years from the date of the relevant transaction.  This is to understand your purchasing preferences and to meet our legal and contractual obligations.  If your purchase has enduring relevance then we’ll keep relevant information for as long as we remain responsible to you for that purchase. 

Where you have asked us not to send you direct marketing, we keep a record of that fact to ensure we respect your request in future. 

We also retain information with the potential to give rise to legal disputes for 7 years. 

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Your rights to withdraw consent and to object (including to direct marketing)

Wherever we rely on your consent to process personal data, you always have a right to withdraw that consent

You also have the right to object to any use of your personal data for direct marketing purposes, as well as to processing that we undertake based on our legitimate interests (including profiling

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Your other personal data rights
In addition to your rights to withdraw your consent and to object, you have the right to ask us:

• for access to information about your personal data or for a copy of your personal data
• to correct or delete your personal data
• to restrict(i.e. stop any active) processing of your personal data
• to provide you with certain personal data in a structured, machine readable format and to transmit that data to another organisation

These rights may not always apply, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to keep or have a compelling legitimate interest in keeping.  If this is the case then we’ll let you know when we respond to your request.

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How to contact us and exercise your rights
The easiest way to stop receiving information from us is by opting out of communications through your online preference centre (this is linked to in our communications with you and is accessible at times via your account settings).  You can also correct your registration details through your online account.

We will do our best to assist with any queries you have about your personal data.  You can contact our Data Protection Officer at any time using the contact details below.  When you do so, please provide your full name, your preferred contact information, and a summary of your query.

If you have unresolved concerns, you also have the right to complain to an UK data protection authority where you live, work or where you believe a breach may have occurred. This is likely to be the Information Commissioner’s Office in the UK.

Last updated 28 March 2021

We suggest that you check back here for updates, as we will update this policy from time to time.

With thanks to Arsenal Football Club who provided the source for this policy.