This policy was last updated on 7 March 2023.

Introduction
Welcome to the Iron Maiden Fan Club privacy policy. This policy relates specifically to the fanclub-only website fanclub.ironmaiden.com
We respects your privacy and is committed to protecting your personal data and we do not sell your data in any form. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

1. IMPORTANT INFORMATION AND WHO WE ARE

1.1 Purpose of this privacy policy
This privacy policy aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you sign up to our Fan Club.

1.2 Controller
This policy applies when IronMaiden.com Ltd is the controller of, and responsible for, your personal data (referred to as “IronMaiden.com” “we”, “us” or “our”). If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us: [email protected]

Please note, some aspects of our services, such as our online store and purchase of Fan Club membership, are managed by a third party, MusicGlue, via the site merch.ironmaiden.com. In these instances, MusicGlue will be the controller of your personal data. For more information, see “How your personal data is collected and our partners” below and MusicGlue’s privacy policy and terms and conditions:

MusicGlue’s privacy policy: https://www.musicglue.com/policies
MusicGlue’s terms and conditions: https://www.musicglue.com/terms-and-conditions

1.3 Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

1.4 Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. THE TYPES OF DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• Identity Data includes first name, last name, username or similar identifier.
• Contact Data email address.
• 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 technology on the devices you use to access this website.
• Profile Data country and optional date of birth.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Whilst this may be derived from your personal data, it is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.

2.1 Special Categories of Personal Data
In very limited circumstances, we may collect Special Categories of Personal Data about you. This will only be in situations where you have intentionally sent in this information to us, for example by sharing with us personal photographs as part of our Fan Club which may reveal Special Category Personal Data, such as ethnicity. We will only process this information on the basis that:
• you have provided explicit consent; and/or
• you have explicitly made this information public by sharing it with our Fan Club.
We do not intentionally collect any other Special Categories of Personal Data about you. Nor do we collect any information about criminal convictions and offences.
Please note. We do not target our website at children (i.e. individuals aged under 18). Any photographs that are sent in by fans that we (in absolute our discretion) believe include children, will be permanently deleted and will not be shared as part of our fan engagement initiatives. This is to protect the rights of freedoms of those children.
Special Categories of Personal Data includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data.

2.2 If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3 HOW YOUR PERSONAL DATA IS COLLECTED AND OUR PARTNERS

We use different methods to collect data from and about you, depending on how you interact with us and our website.

3.1 Using our website
As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and similar technologies. Please see our Cookie Policy https://fanclub.ironmaiden.com/cookies/ for further details.

3.2 Contacting us and/or registering for our marketing communications
You may give us your Identity and Contact information by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you sign up to our mailing lists and when you share your letters or photographs with us. For more information on the personal data contained in photographs you send in to us, see “special categories of personal data” above.

Our mailing list is hosted by MailChimp. We will only send you marketing communications with your consent. You have the right to withdraw consent to marketing communications at any time. If you would like to update your mailing options or unsubscribe from our list, you will find a link to do so at the bottom of every mailer we send.

We do not sell, share or transfer any of your data without your express consent. Emails you receive from us will always be relevant and we do not allow external companies to promote products to our mailing list.
If we have shared a piece of content you provided to us, and you later wish to remove that photo or piece of content, please contact us. If someone has posted a photo which belongs to you or depicts you, and you want it removed, please contact us.

3.3 Signing up to our Fan Club and making purchases on our website
All of the purchases you make on our website, including signing up for our Fan Club, will be managed by our third-party partner, MusicGlue, via the online shop (merch.ironmaiden.com). For this purpose, MusicGlue is the controller of your personal data.
IronMaiden.com and MusicGlue may share your personal data with one-another or carefully selected third parties to enable us to effectively administer aspects of your purchase(s) or membership to our Fan Club, pursuant to MusicGlue’s privacy policy and terms and conditions. This includes sharing Identity, Profile, Usage and Contact Information so that we can:
• administer our competitions, prize draws, or surveys, including sending out prizes;
• administer delivery of any goods you have ordered;
• get in touch with you where, for example, you have sent in your letters or pictures, or sent us a query or complaint; or
• administer our Fan Club Forum.
In relation to competitions or prize draws, we may appoint a third party to administer and supply prizes and may share your personal data with that third party (where necessary) for this purpose. We may also be legally obligated to share limited personal data of competition winners as proof that a winner has been selected. More information will be available in the applicable competition or prize draws’ terms and conditions.

In relation to the Fan Club Forum, we can see your posting history and any content you have uploaded to our forum. If you have an issue and want to delete your posting history, please contact us. We may purge old posts and uploaded files approximately once every 36 months.

3.4 Other third parties or publicly available sources.

We may also receive personal data about you from various third parties and public sources. We do this to enable us to engage with our fans where they have made this information public. For example:
• We may embed YouTube videos on our website form time-to-time. You should check the settings of your Google account to see what data is being tracked or shared about the videos you upload or watch.
• We may also embed user-generated content from Instagram and/or Twitter (or other social media content) on our website. We curate and highlight this content, which has already been made publicly available and we take no responsibility for miss-attribution of content, or if the personal information shared is not accurate. If we embed a post which you would like removed, please contact us.

4 DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties set out above.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

5 INTERNATIONAL TRANSFERS
Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it, by ensuring that:
• We only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data, or
• We use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

6 DATA SECURITY
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. When processing personal data on our behalf, they will only process your personal data on our instructions and will be 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.

7 HOW LONG WE WILL USE YOUR PERSONAL DATA FOR
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

8 YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are summarised below.
You have the right to:
• Request access. Commonly known as a “data subject access request”. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. We may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing. You may object to our processing where we are relying on a legitimate interest and you feel the processing impacts on your fundamental rights and freedoms or where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information, which override your rights and freedoms.
• Request restriction. This enables you to ask us to suspend the processing of your personal data in the certain scenarios, such as if you want us to establish the data’s accuracy or where you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request transfer. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. 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.
• Right to withdraw consent. Where we are relying on consent to process your personal data, you can withdraw this consent. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

8.1 No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

8.2 What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

8.3 Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

9 OUR LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform a contract we have (or are about to) enter into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal obligation.

9.1 Purposes for which we will use your personal data

9.2 Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.