Protecting your privacy is important to Settleit App Limited (“We”, “Us” or “Our”). This policy outlines how personal data we collect from you, or that you provide to us, will be processed through the use of our website. Please read the following policy to understand the information we collect, how we will use that information and the circumstances where we will share it with third parties. The policy also describes your data protection rights, including a right to object to some of the processing which the company carries out. More information about your rights, and how to exercise them, is set out in the “Your Rights” section.
This website is not intended for children and we do not knowingly collect data related to children.
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.
When you use our services, we collect the following types of information:
Information you provide us:
Personal data means any information about an individual from which that person can be identified. It does not include any data where the identity has been anonymised. We may collect, use, store and transfer different kinds of personal data about you which we have grouped as follows:
• “Identity Data” includes first name, last name, title, date of birth and gender.
• “Contact Data” includes billing address, correspondence address, email address and telephone numbers.
• “Financial Data” includes bank account and payment card details.
• “Technical Data” includes IP address, login data, browser type and version, time zone settings and location, browser plug-in types and versions, and operating system and platforms.
• “Transaction Data” includes details about payments to and from you.
• “Profile Data” includes your username and password, deposits made, your bets placed, your gaming habits, preferences, social media information, feedback and survey responses.
• “Usage Data” includes information about how you use our website and services.
• “Marketing and Communications Data” includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Additional Information collected:
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). Nor do we collect any information about criminal convictions and offences.
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 use various methods to collect data from and about you including through:
• Direct interactions you may give us your Identity, Contact and Financial Data when registering to use our services, setting up an account, placing any SETTLE-ITs/bets or engaging in any gaming. You may also provide this data when giving any feedback, contact us, requesting marketing data or entering any promotion/competition.
• Third parties or publicly available sources. We may from time to time receive information about you from third parties and publicly available websites (i.e. advertising networks, analytics providers, social media platforms and search information providers).
We will only use your personal data when the law allows us to. Most commonly we will process your personal data for the following service and business related purposes:
To fulfil a contract with you, or take steps linked to a contract with you.
• Delivering our services to you
• Verifying your identity and undertaking necessary security checks (including checks undertaken by trusted third parties and making use of registers held by authorised credit reference agencies)
• Taking payments from you
• Communicating with you in relation to your account and our services
• Providing customer services to you
As required by the company to conduct our business and pursue our legitimate interests, in particular:
• in order to provide a better betting service, we may use your usage data in order to provide trading information to our liquidity partners. Data made available to our liquidity partners includes an anonymous unique identifier that represents counterparty information and markets accessed;
• we monitor use of our websites and online services, and use your information to help us monitor, improve and protect our content, services and websites, both online and offline;
• we use information you provide to personalise our website, products or services for you;
• we monitor customer accounts to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law;
• we use information you provide to investigate any complaints received from you or from others, about our website or our products or services; and
• we will use data in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation).
Where you give us consent:
• we will send you direct marketing in relation to products and services provided by us, our affiliates and carefully selected partners;
• we place cookies and use similar technologies in accordance with our Cookies Policy and the information provided to you when those technologies are used; and
• on other occasions where we ask you for consent, we will use the data for the purpose which we explain at that time.
• NOTE: you have the right to withdraw any consent given at any time by contacting us at firstname.lastname@example.org.
As a policy we do not disclose any personal information to anyone other than those employees or third parties that need access to your data.
Personal data may be shared with some trusted third party service providers, who will process it on behalf of the company, such as:
• Payment providers
· Identity verification agencies
· Credit rating agencies
· Fraud protection agencies
· Digital marketing and content delivery agencies
· Gambling Commission
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.
Personal data may also be shared with government authorities, law enforcement officials or relevant regulators if required, if mandated by law or if required for the legal protection of our legitimate interests in compliance with the applicable laws.
Personal data may be shared with sporting bodies the Group has agreements with for the purpose of policing the integrity and enforcing the rules of a sport or detection and prevention of a crime.
We may be required to transfer your personal data outside of the European Economic Area (“EEA”). Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring:
• 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;
• 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; and
• 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 Europe and the US.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
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.
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.
In some circumstances you can ask us to delete your data (see your rights below) and in certain circumstances we will anonymise your personal data for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Under the General Data protection regulation, you, as a data subject have a number of rights which are detailed below. Some of these only apply in specific circumstances and are qualified in several respects by exemptions in data protection legislation. We will advise you in our response to your request if we are relying on any such exemptions.
Should you wish to exercise any of the below please contact us. You will not have to pay a fee to access your personal data or to exercise any other right. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply in these circumstances.
• Access to personal data: You have a right to request a copy of the personal information that we hold about you. Should you wish to make such a request, please email email@example.com
You should include adequate information to identify yourself and such other relevant information that will reasonably assist us in fulfilling your request. Your request will be dealt with as soon as possible.
• Correction of personal data: You can request us to rectify and correct any personal data that we are processing about you which is incorrect. We provide you with account settings and tools to access the information associated with your account.
• Right to withdraw consent: Where we have relied upon your consent to process your personal data, you have the right to withdraw that consent.
• To opt out of marketing, you can use the unsubscribe link found in the marketing communication you receive from us.
• Right of erasure: You can request us to erase your personal data where there is no compelling reason to continue processing. This right only applies in certain circumstances, it is not a guaranteed or absolute right.
• Right to restrict processing of personal data: You have the right in certain circumstances to request that we suspend our processing of your personal data. Where we suspend our processing of your personal data we will still be permitted to store your personal data, but any other processing of this information will require your consent, subject to certain exemptions.
• Right to object to processing of personal data: You have the right to object to our use of your personal data which is processed on the basis of our legitimate interests. However, we may continue to process your personal data, despite your objection, where there are compelling legitimate grounds to do so or we need to process your personal data in connection with any legal claims.
In accordance with the General Data Protection Regulation (EU 2016/679), the data controller is Settleit App Limited of Unit A, Ensign House, Juniper Drive, London SW18 1TA.