WHAT INFORMATION DO WE COLLECT?
We collect two types of information from our Users:
• Personal Information
The first type of information is information that identifies or may reasonably identify an individual reasonable effort (“Personal Information”). Personal Information which is being gathered may consist of the following:
• Contact details: you may voluntarily provide us with certain contact details, such as your full name and email address.
• Voluntary information: We also collect information which you provide us voluntarily. For example, when you respond to communications from us, communicate with us via email or share additional information about yourself through your use of the Services, such as on the chat feature and in games.
• Device information: we collect specific types of connection details and information with regard to your device, software or hardware that may identify you, such as device’s unique identifiers (e.g. UDID, IMEI, MAC address), browser fingerprinting, IP address and geo-location data.
• Social networks: when you voluntarily decide to register through your social network account (such as your Facebook account), we will have access to basic information from your social network account, such as your name, birthdate, profile picture and friends’ list, as well as information you made publicly available on such account.
• Information we collect from third parties: We collect Personal Information from third party service providers, such as information about your credit history from credit agencies and other financial information which is relevant to the provision of the Services, as well as information which is gathered in order to verify your identity and prevent fraudulent or illegal activity.
• Non-Personal Information
The second type of information is un-identified and non-identifiable information pertaining to a User(s), which may be made available or gathered via the User’s use of the Services (“Non-Personal Information”).
Non-Personal Information which is being collected consists of technical information and aggregated usage information, and may contain, among other things, the User’s operating system, type of browser, screen resolution, browser and keyboard language, the User’s ‘click-stream’ and activities on the Services, the period of time the User visited the Services and related timestamps, etc.
For the avoidance of doubt, any Non-Personal Information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection or linkage exists.
Types of Non-Personal Information we collect from or about you:
• Technical information: In order to enhance the functionality of the Services and to provide you with a better user experience, we collect technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time and the domain name of the website from which you linked to the Services; etc.). This information also includes anonymous online identifiers, such as the Google Advertising ID and the IDFA.
• Device and app information– this category includes your device’s type and model, system language, the device’s operating system (such as Android or iOS), SDK version, mobile carrier name, mobile browsers installed on the device (such as Chrome or Safari), app history and usage information (such as information about running and installed apps on the device), information regarding downloads and installations of mobile applications and any information regarding in-app events (such as in-app purchases), and anonymous identifiers assigned to your device, such as its iOS Identifier for Advertising (IDFA), Google Advertising ID, or other types of device identifiers.
• Location information– we collect information about your general location (such as city and country). For example, we may use the IP address to identify your general location. This information does not tell us where your device is precisely located. This information is sent as a normal part of internet traffic. In addition, we also collect implicit location information, which allows us to infer that you are either interested in a place or that you might be at the place – this information does not actually tell us where your device is precisely located.
• Ad information– this category includes information about the online ads and personalized content we have served (or attempted to serve) to you. It includes things like how many times an ad has been served to you, what page the ad appeared on, whether you viewed, clicked on or otherwise interacted with the ad, ad engagement history and whether you visited the advertiser’s website, downloaded an app or purchased the product or service advertised.
• Log and analytics information: we collect information about your use of the Services, such as applications’ usage, log files, user activity (e.g. referral URL, pages viewed, the amount of time spent on particular pages, online browsing, clicks, actions, etc.), time stamps, alerts, etc. This information is collected for amongst other things troubleshooting errors and bugs as well as for research and analytics purposes about your use of the Services.
How & why we use the data we collect
We use the User Information for three main purposes: to operate and improve the platforms and to ensure that we can provide the Services; to optimize the content on the platforms, and send marketing and show advertising to our users.
More specifically, we will use the User Information to do one or more of the following things:
(a) administer our platforms;
(b) provide the Service requested by the user;
(c) improving the browsing experience by personalizing the Service to the user;
(d) recommend goods, services or promotions which may be of interest to the user or contact users in order to conduct market research (with the consent of the user, where necessary). For these purposes, we will create a profile about your interests and preferences which will enable us to increase our advertising and communication relevance;
(e) prevent, detect and investigate potentially prohibited or illegal activities, including fraud, cheating, and money laundering and enforce our terms;
(f) to notify users about changes to our Service;
(g) send out email alerts, text messages notifications or device notifications in relation to our Service;
(h) send users prizes won via the platforms, and supply services purchased via our platforms;
(i) send notices and invoices to users, and collect payments from them;
(j) provide third parties such as our third-party digital publishers who deploy ePlayer with statistical and other information about our users as required to operate the platforms or Services;
(k) deal with enquiries and complaints;
(l) provide our commercial partners with information about users’ use of co-branded services, including historical use data;
(m) comply with any legal or regulatory requirements and otherwise to any respond to any relevant regulator or competent authority as required by law;
(n) understand user trends and patterns; and
(o) develop aggregate analysis in respect of our users and business intelligence that enable us to operate, protect, make informed decisions and report on the performance of our business.
The digital sports media platforms we operate are designed to attract as many users as possible. In our case, our users are typically sports fans or interested in sports news and other sports-related content. The creation of this content and the work that goes into ensuring that the platforms continue to be class-leading digital sports destinations are funded by advertising revenues which we receive as a result of showing users advertising or other sponsored or branded content on the platforms. We have a legitimate interest in ensuring that we deliver this advertising in a responsible way, and in allowing us to deliver it to the users most likely to be interested in it, and in doing so we employ User Information, such as the user’s location, how the user engages with the platforms and the content that the user views.
The Services are not designed or directed to persons under the age of 18 or persons under the age of legal consent with respect to the use of the Services of any jurisdiction, whichever is higher (“Legally of Age”). If you are not Legally of Age, you should not download or use the Services nor provide any Personal Information to us.
We reserve the right to access and verify any Personal Information collected from you. In the event that we become aware that a user who is not Legally of Age has shared any information, we may discard such information
WITH WHOM WE SHARE INFORMATION?
We share Personal Information with any of the following recipients:
• Our clients that deploy our Services on their online properties (such as websites and mobile apps); this includes our clients whose websites or apps you have visited, as well as an advertiser whose site or app you have visited – we share information about how you have interacted with such websites or apps.
• Companies within the Company and other affiliated companies;
• Subcontractors and third party service providers, as well as their subcontractors, which by way of example include (but is not limited to) cloud computing companies, marketing affiliates, identity verification and fraud prevention services, and other data verifiers;
• Auditors, contractors or advisers of any of the Company’s business processes;
• To any third parties who investigate, detect or prevent fraudulent or illegal activity (e.g. governmental authorities, police, banks and other investigatory organizations);
• Licensing authorities, governmental and regulatory bodies, in accordance with applicable laws and regulations; and
• TRANSFER OF INFORMATION
• Since we operate globally, it may be necessary to transfer your Personal Information to countries outside the European Union. The data protection and other laws of these countries may not be as comprehensive as those in the European Union.
On this platform, we use the following types of cookies:
• Strictly necessary cookies – These cookies are essential to enable the user to navigate around the platform securely and to provide the user with Services they have specifically requested.
• Functionality cookies – These cookies enhance the functionality of the platforms by storing user preferences. For instance, they can remember your name and location, if you provide this information and the types of content you are interested in.
• Performance cookies – These cookies improve the performance of the platforms. For instance, they help pages load quicker.
• Analytics cookies – We may use third party analytics services such as Google Analytics and others. Your IP address and other information will be collected by automated means to evaluate your use of the website, compile reports on website activity, identify user patterns and provide related services. For more information about how Google Analytics uses your information please click here. In addition, authentication and tracking logs will be used to compile usage statistics.
• Targeting/advertising – These cookies help us serving of relevant advertisements and implement frequency capping procedures.
These types of cookies may also be placed on the platform by our business partners or service providers.
Most web browsers automatically accept cookies, but if you prefer, you can change your browser to prevent that, or opt-out as explained below. You may not be able to take full advantage of our platforms or use certain functions if you disable cookies.
THIRD PARTY SERVICES
You should always review their privacy practices carefully before providing Personal Information to such third parties.
You are knowingly and voluntarily assuming all risks of using any third-party websites, services or applications. You agree that we shall have no liability whatsoever with respect to such third party sites and your usage of them.
We understand that the security of your User Information is important to you. When handling User Information, security is paramount and we seek to ensure that User Information is protected through appropriate technical and organizational measures.
We use reasonable administrative, logical and physical controls, including password protection, to safeguard your User Information against loss, theft and unauthorized access, use or modification. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your User Information in accordance with applicable law, we cannot guarantee the security of your User Information.
If you reside in the EU or in other jurisdictions that afford you with the below rights, you may contact us at any time by email (at email@example.com ), and request:
1. To access or delete any Personal Information relating to you
2. To change or update any Personal Information relating to you (for example, if you believe that your Personal Information is incorrect, you may ask to have it corrected or deleted). Note that you may also request that we will correct errors with regard to your Personal Information (except in cases where the information is required to be kept in its original format under any applicable laws and regulations);
3. That we will restrict or cease any further use of your Personal Information;
4. That we will provide the Personal Information you volunteered to us in a machine-readable format.
Please note that these rights are not absolute and requests are subject to any applicable legal requirements, including gambling regulations and other legal and ethical reporting or document retention obligations. We may also rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion, in accordance with our internal policies.
Questions, comments, and requests regarding this Privacy Notice are welcomed and should be addressed to firstname.lastname@example.org