WEBSITE PRIVACY NOTICE
Sporting Index Ltd (“SPIN”) respects your privacy and is committed to protecting your personal data.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
(a) PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how SPIN collects and processes your personal data through your use of the website at www.sportingindex.com or any subdomains, whether accessed via a computer, telephone, mobile or any other device (the "Website") any data you may provide through the Website when you sign up to our newsletter, place bets or take part in a competition.
This website is not intended for anyone under the age of 18.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Sporting Index Ltd (a company registered in England with the registration number 02636842) is the controller and responsible for your personal data (collectively referred to as” SPIN”, “we”, “us” or “our” in this privacy notice).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your rights, please contact the data privacy manager using the details set out below.
Our full details are:
→ Full name of legal entity: Sporting Index Limited
→ Title of data privacy manager: Data Security Officer
→ Email address: email@example.com
→ Postal address: Gateway House, Milverton Street, London SE11 4AP
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority 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.
(d) CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
This version was last updated on 23 April 2018 and historic versions can be obtained by contacting us.
(e) THIRD-PARTY LINKS AND SERVICES
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 notice of every website you visit.
Sometimes we may include services on the Website that are provided by licensed third-party gambling operators. Through providing these services to you these third parties may collect your information, and for certain purposes, they will be responsible for their collection and use of your information. These third parties may need to retain and use your information for the purpose of complying with applicable gambling laws and the terms of their gambling licences. We will always inform you before you receive any service on the Website that is provided by a third-party gambling operator and we will explain how they collect and use your information.
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 follows:
• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other information about your bets placed with us.
• 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 includes your username and password, your betting history, your favourite fixtures, preferences, feedback and survey responses. See 10(b) below for further details. Please be assured that we do not use social media to profile your personal data.
• Usage Data includes information about how you use your betting account with us.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this 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).
(b) IF YOU FAIL TO PROVIDE PERSONAL DATA
(b) IF YOU FAIL TO PROVIDE PERSONAL DATA
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you (this list is not exhaustive):
• open an account with us;
• place bets;
• create an account on our Website;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
•give us some feedback.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
• Technical Data from the following parties:
→ analytics providers such as Google based outside the EU;
→ advertising networks based inside or outside the EU; and
→ search information providers based inside or outside the EU.
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside or outside the EU.
• Identity and Contact Data from data brokers or aggregators based inside or outside the EU.
• Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
• Credit Reference Agencies and Fraud Prevention Agencies (see 3(b) below).
When you apply for an account with us, we may check the following records about you (and others where applicable):
• our own records;
• those at CRAs; and
• those at FPAs.
Whether or not your application is successful, when CRAs receive a search from us they will place a search footprint on your credit file that may be seen by other businesses. Large numbers of applications within a short time period may affect your ability to obtain credit, this is applicable whether you have been accepted or declined.
We, along with CRAs and FPAs, may also link your records with those of your financial associate(s) including any previous and subsequent names. These links will remain on your and their files until you or they tell the agency you are no longer financially linked and the agency accepts this. This is called a “disassociation” and if you need to request a disassociation, please contact the CRAs directly (contact details are set out below for Call Credit).
The CRAs supply us with both public information (including the electoral register, county court judgements and bankruptcies) and shared credit and fraud prevention information including information about previous applications and the conduct of your accounts in your and your financial associate(s)’ name(s).
We may also make periodic searches at CRAs and FPAs to manage our relationship with you, and comply with our legal and regulatory obligations.
Information provided by you on our applications will be sent to CRAs and will be recorded by them. We and other organisations may access and use this information to prevent fraud and money laundering and CRAs and FPAs may use your information for statistical analysis. Information held by CRAs and FPAs will be disclosed to us and to other organisations in order to (for example):
• prevent fraud and money laundering and to check and assess applications for credit, credit related or other facilities;
• recover debts that you owe and trace your whereabouts;
• manage credit accounts and other facilities and decide appropriate credit limits;
• verify your identity;
• make decisions on credit and other facilities for you, your financial associate(s), members of your household or your business;
• check details on proposals and claims for all types of insurance; and
• check details of job applicants and employees.
When you obtain credit facilities from us, we will give details of your credit facility and how you manage it to the CRAs. If you borrow and do not repay in full and on time, the CRAs will record the outstanding debt and, in some cases, the length of time that the debt remains outstanding; other organisations may see these updates and this may affect your ability to obtain credit in the future.
If you fall behind with your payments and a full payment or satisfactory proposal is not received within 28 days of a formal demand being issued, then a default notice may be recorded with the CRAs. Any records shared with CRAs will remain on file for 6 years after your account is closed, whether any outstanding sums have been settled by you or following a default.
This information may be supplied to other organisations by CRAs and FPAs to perform similar checks and to trace your whereabouts and recover debts that you owe.
If you give us false or inaccurate information and we have reasonable grounds to suspect fraud or we identify fraud we may record this and may also pass this information to FPAs and other organisations involved in crime and fraud prevention including law enforcement agencies who may then access this information.
We and other organisations may access and use the information recorded by fraud prevention agencies from other countries.
The CRA that we use is Call Credit Limited (registration number 03961870) with registered office at One Park Lane, Leeds, West Yorkshire, LS3 1EP.
FPAs include CIFAS, with registered office at 6th Floor Lynton House, 7-12 Tavistock Square, London WC1H 9LT. You can contact CIFAS at www.cifas.org.uk/contact_us_form
4.HOW WE USE 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 the contract we are about to enter into or have entered 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 or regulatory obligation (see 4(c)below in this respect).
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you. You have the right to withdraw consent to marketing at any time by Contacting us.
b) PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Type of data
||Lawful basis for processing including basis of legitimate interest|
To register you as a new customer
Performance of a contract with you
To process and deliver our services including:
(a) Bet request and acceptance
(b) Manage payments, fees and charges
(c) Collect and recover money owed to us
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our facilities and take advantage of our opportunities)
To enable you to partake in a prize draw, competition or complete a survey
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our facilities, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation, such as those described under section 4(c)below.
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(e) Marketing and Communications
Necessary for our legitimate interests (to study how customers use our facilities, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, services, marketing, customer relationships and experiences
|Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
To make suggestions and recommendations to you about your favourite bet types and/or markets or other services that may be of interest to you
Necessary for our legitimate interests (to develop our services and grow our business)
c) LEGAL AND REGULATORY OBLIGATIONS
Regulators, government bodies, law enforcement and courts have powers to order us to provide information and, like any other organisation, we sometimes have to comply with their requests.
We may share your personal data with law enforcement, sporting bodies, regulators or any other relevant third party in order to
- aid the investigation of suspected unlawful, fraudulent or other improper activity connected with the use of the website and to report a crime or suspected crime, including money laundering or fraud; and
- to aid in the detection, prevention and prosecution of match or price fixing,
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
e) PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us, opened an account, or placed bets with us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
f) OPTING OUT
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by Contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of opening an account with us. For example, we may be required to processes personal data to meet legal or regulatory obligations.
h) 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.
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.
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
- Internal Third Parties as set out in the Glossary.
- External Third Parties as set out in the Glossary.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
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.
6. INTERNATIONAL TRANSFERS
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. 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. 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.
(b) PROTECT YOUR ONLINE ACCOUNT
We continually invest in cyber security, including devoting valuable resource to help protect your data. That said, it is vital that you keep your personal details and password confidential and secure. If you have any reason to suspect that your password has become known by someone else, you should change your password and contact us immediately.
- Email: firstname.lastname@example.org
- Telephone: From the UK: 08000 969607; or from outside the UK: +44 20 7840 4050
We are in no way responsible for any loss or damage which is due to any failure or oversight by you to protect your password and other account details, or you fail to take reasonable measures to guard against your personal data being lost or shared.
8. DATA RETENTION
(a) HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for five years after they cease being customers for tax or regulatory purposes.
In some circumstances, you can ask us to delete your data: see Request erasure below for further information.
In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see 10(b) below to find out more about these rights:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please Contact us.
(b) 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 may refuse to comply with your request in these circumstances.
(c) 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.
(d) TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may 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.
(a) LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by Contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
(b) THIRD PARTIES
INTERNAL THIRD PARTIES
Other companies in the Company’s Group and provide IT and system administration services and undertake leadership reporting.
EXTERNAL THIRD PARTIES
- Service providers acting as processors based in the United States of America who provide IT and system administration services.
- Professional advisers who provide [consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances. See 4(c)above.
- Marketing agencies who profile your transaction history to help us deliver a personalised service to you.
- Credit Reference Agencies or Fraud Prevention Agencies (see 3(b) above).
Please be assured that we do not use social media to profile your personal data.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (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 of the personal data that we hold about you. 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 of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific reasons, including lawful purposes described under 4(b)above which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party, including those mentioned in 10(b) above) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object 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 of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. 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.
Withdraw consent at any time where we are relying on consent to process your personal data. 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 services to you. We will advise you if this is the case at the time you withdraw your consent.