Privacy Policy - Cambodian Premier League

1. Purpose

This Privacy Policy explains how Cambodian Premier League Co., Ltd. (“CPL”, “we”, “us” or “our”) collects, uses, discloses, stores and protects personal information through https://cpl-cambodia.com and related digital interactions under CPL's control, subject to any separate privacy notice that applies to a particular service.

2. Data Controller

Cambodian Premier League Co., Ltd.
No. 113C, Mao Tse Tung Blvd, Phum 7, Sangkat Toul Svay Prey Ti Mouy, Khan Boeung Keng Kong, Phnom Penh 120106, Kingdom of Cambodia
Telephone: +855 97 79 78 222
Email: [email protected]

3. What Personal Information May Be Collected

Only depending on the interaction, CPL may collect name; contact details; age or date of birth where necessary; nationality where relevant; photographs and video images; communications and enquiries; ticket or event information where CPL receives it; participation information; IP address; browser, operating-system and device information; Website usage and security information; and other information reasonably necessary for competition administration, safeguarding, integrity, legal compliance or a specific CPL activity.

4. Sources of Information

Information may be only collected directly from you; through Website forms and subscriptions; through participation in CPL competitions, program, surveys or campaigns; from authorized clubs, partners and service providers; through publicly available sources where lawful; through cookies and similar technologies; or through third-party platforms when you choose to interact with CPL there.

5. Purposes of Processing

CPL may process personal information to: (a) operate and secure the Website; (b) respond to enquiries and complaints; (c) administer competitions, fixtures, events and program; (d) manage fan engagement, surveys, competitions and newsletters; (e) administer CPL Cares and community initiatives; (f) support safeguarding and protection of children and vulnerable persons; (g) support competition integrity, disciplinary or misconduct processes; (h) prevent fraud and abuse; (i) comply with law and applicable sporting regulations; (j) establish, exercise or defend legal rights; and (k) carry out other purposes disclosed at the time information is collected.

6. Basis and Lawfulness of Processing

CPL will process personal information only where there is a lawful basis under applicable law. Depending on the circumstances, this may include your consent; performance or administration of a requested service or activity; compliance with a legal or regulatory obligation; protection of a person's vital or legitimate interests where applicable; legitimate operational, security, sporting or administrative interests where permitted by law; or another lawful basis.

7. Consent

Where CPL relies on consent, consent will be requested in a manner appropriate to the relevant activity. Subject to applicable law, consent may be withdrawn by contacting CPL or using the relevant unsubscribe or preference mechanism. Withdrawal does not affect processing lawfully carried out before withdrawal and does not prevent continued processing where CPL has another lawful basis.

8. Cookies and Tracking

CPL may use necessary cookies and, where applicable, preference, analytics, performance or marketing technologies. Where a consent mechanism is legally required for a category of technology, CPL will implement an appropriate mechanism before or at the time of deployment, same shall be notified in advance.

9. Photographs, Video and Sports Content

CPL is a professional football competition operator and may create and publish photographs, videos, interviews, match footage, highlights and other audiovisual material. Such material may contain identifiable players, coaches, referees, officials, spectators, guests, partners, media personnel and members of the public. CPL may use such material for legitimate sporting, editorial, archival, broadcasting, promotional, sponsorship, community and operational purposes, subject to applicable law, contractual rights, venue terms and any consent required for the particular use.

10. Players, Clubs, Officials and Sporting Records

CPL may process and publish legitimate professional sporting information such as player names, club affiliation, appearances, goals, assists, match statistics, competition records and disciplinary information where necessary for competition administration, sporting integrity, editorial reporting, historical records or legitimate promotion. CPL will avoid publishing unnecessary personal information merely because it is available internally.

11. Children and Young Persons

CPL recognizes the heightened importance of protecting children and young persons. Where an activity involves children, CPL will apply age-appropriate safeguards and seek parental or legal-guardian involvement where required by law or the activity. Personal information concerning youth participants will be limited to what is reasonably necessary for football, safeguarding, welfare, education, competition and community purposes.

12. Sensitive or High-Risk Information

Information concerning health, welfare, safeguarding, disciplinary matters, allegations of misconduct, biometric information, identity documents and information concerning children may require enhanced safeguards. CPL will limit collection and access to what is reasonably necessary and will use such information only for a lawful and legitimate purpose.

13. Disclosure to Third Parties

CPL may disclose personal information, where lawful and reasonably necessary, to authorized CPL personnel; clubs and competition stakeholders; FFC, AFC, FIFA and relevant sporting bodies; event and ticketing operators; hosting, technology and security providers; communications and analytics providers; payment providers; professional advisers; insurers; competent authorities; and other service providers acting on CPL's instructions. CPL will seek appropriate contractual confidentiality and security protections from relevant service providers.

14. International Processing

Some technology, hosting, analytics, communications or other service providers may process information outside Cambodia. Where information is transferred internationally, CPL will take reasonable steps to ensure the transfer is lawful and subject to appropriate safeguards under applicable law.

15. Security

CPL will maintain reasonable administrative, technical and organizational measures designed to protect personal information against unauthorized access, accidental loss, unlawful disclosure, alteration, destruction and misuse. No electronic system is completely secure. Where CPL becomes aware of a material personal-information incident, it will investigate, contain and remediate the incident and make notifications required by applicable law.

16. Retention

CPL will retain personal information only for as long as reasonably necessary for the purpose for which it was collected, unless a longer period is required or permitted by law. Retention may depend on legal, regulatory, sporting, contractual, safeguarding, dispute-resolution and archival requirements. When information is no longer required, CPL may securely delete, anonymize or otherwise dispose of it.

17. Individual Rights

Subject to applicable Cambodian law and any lawful limitations, an individual may have rights concerning personal information held by CPL, including rights to request access or correction, object to or restrict certain processing, request deletion where available, withdraw consent where consent is the basis, and opt out of direct marketing. The scope, procedure and timing of such rights will depend on the law applicable at the time of the request.

18. How to Make a Privacy Request

Requests should be sent to [email protected] with a subject line “Privacy request”. CPL may request reasonable information to verify identity and protect against unauthorized disclosure. CPL will respond within a reasonable period and in accordance with applicable law. If a request cannot be fulfilled, CPL will explain the applicable legal or operational reason where appropriate.

19. Direct Marketing

Where permitted by applicable law, CPL may send newsletters, news, fixtures, match updates, event information and promotional communications. Recipients may unsubscribe through the relevant mechanism or by contacting CPL. Opting out of marketing does not prevent essential communications concerning an event, competition, transaction, service, legal matter or other non-marketing purpose.

20. Social Media and Third-Party Websites

CPL may operate social-media pages and link to third-party websites. Those platforms may independently collect and process information under their own policies and social media guidelines as amended from time to time. CPL does not control third-party privacy practices and users should review the relevant third-party terms before submitting information.

21. Safeguarding, Integrity and Reporting

Where a person submits a safeguarding, integrity, whistleblowing or misconduct report, CPL may process information concerning the reporter, subject, witnesses and other relevant persons for investigation, protection, disciplinary action, legal compliance or cooperation with competent authorities. CPL will seek to limit access and disclosure to persons with a legitimate need to know, while recognizing that confidentiality cannot be guaranteed where disclosure is required by law or necessary for a fair investigation.

22. Public Information and Sporting Legitimate Interests

Certain professional sporting information may appropriately be made public as part of the normal operation of a professional football competition. CPL will seek to distinguish legitimate public sporting information from unnecessary disclosure of private information.

23. Incident Response

CPL will maintain an internal process for identifying, assessing, containing and responding to suspected personal-information incidents. Where applicable law requires notification to an authority or affected individual, CPL will make the required notification within the applicable timeframe and with the information required by law.

24. Changes to This Policy

CPL may update this Privacy Policy to reflect changes in law, regulation, Website functionality, technology or processing practices. The updated version will be published with a revised Last Updated date. Where applicable law requires additional notice or consent, CPL will provide it.

25. Complaints

If you believe CPL has mishandled personal information, please contact CPL first at [email protected]. CPL will investigate and seek to resolve legitimate concerns. This does not prevent a person from exercising any statutory complaint or enforcement right available under Cambodian law.

26. Governing Law

This Privacy Policy is governed by the laws of the Kingdom of Cambodia and any other mandatory legal requirements applicable to the relevant processing activity.