Framble | Privacy Policy

This Privacy Policy explains how Flutter Media Limited ("Framble") collects, uses, stores, keeps and/or discloses your personal information when you use our mobile application or any other website or applications that we own or operate (“the Website”). It also describes your data protection rights.

The Website is not intended for children and we do not knowingly collect data relating to children.

The data controller for your personal information is: Flutter Media Limited, a company incorporated in England with company registered number 11283879 and registered address is New House Farm, Clay Lane, Hasslington, Cheshire, United Kingdom, CW1 5SQ.

Framble
Throughout this Privacy Policy, references to "Framble" include any or all direct and indirect subsidiary undertakings and related companies or agents as may exist from time to time. Framble (in this Privacy Policy, "us", "we" and "our") is the data controller and is responsible for your personal data and is subject to the EU General Data Protection Regulation 2016/679 ("the GDPR").

We have appointed a data protection and privacy officer who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the data protection and privacy officer using the details set out below.

This Privacy Policy supersedes any previous Privacy Policy or equivalent that you may have been provided with or seen prior to the Effective Date stated above, however, it is important that you read this Privacy Policy together with any other Privacy Policy or fair processing notice we may provide on specific occasions following the Effective Date when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your personal information.

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

Contact Us
Flutter Media Limited is registered with The Gambling Commission. If you have any questions about this Privacy Policy or our privacy related practices, you can contact us:

At the following address:
Data Protection & Privacy Officer Flutter Media Limited New House Farm, Clay Lane, Hasslington, Cheshire, United Kingdom, CW1 5SQ.

By email at:
[email protected]

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.

Your rights
Under the Data Protection Legislation, you have the following rights:

Right of subject access (commonly known as a "data subject access request"): the right to make a written request and obtain a copy of any information held about you by Framble.
Right to rectification: the right to have rectified any of your information which is inaccurate or incomplete, although we may need to verify the accuracy of the new information you provide to us.
Right to erasure: the right to have certain information about you erased where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove your personal information 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 information to comply with local law. Note, however, that 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.
Right to restricted processing: the right to request that we suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the information's accuracy; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information 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 information but we need to verify whether we have overriding legitimate grounds to use it.
Right to object: the right to object to the use of your information where we are relying on a legitimate interest (or those of a third party) 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 information 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.
Right to data portability: the right, in certain circumstances, to ask for information you have made available to us to be transferred to you or a third party. We will provide to you, or a third party you have chosen, your personal information 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: the right to withdraw any consent you have previously given us to handle your information. This will not affect the lawfulness of Framble's use of your information prior to the withdrawal of 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.

You will not have to pay a fee to access your personal information (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.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information 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.

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.

If you wish to exercise any of the rights set out above, please contact us.

You can find out more about your rights at https://ico.org.uk/

Third-party links
The 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 information about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave the Website, we encourage you to read the privacy notice of every website you visit.

How we collect your data
In the course of providing services to you, we collect information that personally identifies you. The information we collect about you comes from the following:

filling in forms, registering for an account with us and/or other materials you submit to us during the course of your relationship with us;
your interactions with us, transactions and use of our products and services (including the use of the Website);
your dealings with us, including via letters, telephone, email, online, messaging Apps such as Whatsapp and Skype, live chat function on the Website and/or as stated in our contracts with you;
participating in promotions, prize draws, surveys and/or in any other marketing and/or promotional event organised by us;
your public profile, including, name, photo and other information you make available to us when you like, post or otherwise interact with our social media pages;
depending on the products or services you require, third parties (including for credit and money laundering checks, among other things); and
recording and monitoring tools that we use for compliance or security purposes (e.g. recording of telephone calls, monitoring emails, etc.).

As you interact with the Website, we may automatically collect Technical Data (defined below) about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

Information we collect

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).

The personal information collected by us helps us to; identify you, manage your account with us and/or participation in our promotions. We will also collect financial information about you such as information required for us to carry our credit checks, money laundering checks, and any other checks we feel are appropriate, information about your transactions with us and any other information required in order for us to comply with our legal obligations.

The information that may be collected by us includes (but is not limited to) the following:

Identity Data including your title, name, date of birth, age, information which we need to conduct ‘know your client' checks such as details relating to your passport and credit history personal identifiers such as your social security number, national insurance number, tax file number and your professional title and occupation;
Contact Data including address and contact details;
Transaction Data including details about payments to and from you and other details of services you have purchased from us;
Profile Data including username and password, purchase of services made by you;
Financial Data including payment card details, bank account details or online e-wallet information;
Usage Data including information about how you use the Website and our services;
Marketing and Communications Data including your preferences in receiving marketing from us; and
Technical Data including 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 the Website or our internal electronic identifiers.

In certain circumstances, we may also need to collect “special categories” of information. Special categories include 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. Some checks we carry out, including money laundering, sanctions, financial crime and fraud prevention may result in us acquiring information about criminal convictions and offences (whether actual or alleged).

You do not have to provide us with your information however failure to do so may impact our ability to offer you certain services or products and could potentially result in us being unable to continue our business relation with you. If this situation arises, we will make you aware of it.

Our use of your information

We collect, use, share and store information about you in order to help us to process transactions and to enable us to improve the quality of service that we provide. We will only use your personal information when the law allows us to, most commonly 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.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product 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 information 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 personal information 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 information where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

We will only process “special categories” of information about you when we have your explicit consent to do so, we are required to do so by law or the processing of information is necessary in order for the establishment, defence or exercise of a legal claim.

Generally we do not rely on consent as a legal basis for processing your personal information other than in relation to sending direct marketing communications to you via email or text message, or as referred to above in respect of special categories. You have the right to withdraw consent at any time by contacting us. We have set out below, in a table format, a description of all the ways we plan to use your personal information, 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 information for more than one lawful ground depending on the specific purpose for which we are using your information. Please contact us if you need details about the specific legal ground we are relying on to process your personal information where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
(a) To process your registration; and/or (b) Determine your eligibility for membership; and (c) Conduct appropriate fraud checks	(a) Identity (b) Contact	Performance of a contract with you
To process and deliver the services including: (a) Administering your account (b) Manage payments, fees and charges (c) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial	(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: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey (c) To investigate and address questions and complaints and respond feedback.	(a) Identity (b) Contact (c) Financial (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 products/services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(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
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and 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 goods or services that may be of interest to you , notify you of promotional events and provide you with relevant materials	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile	Necessary for our legitimate interests (to develop our products/services and grow our business)

Telephone conversations between us and you may be recorded to enable us to improve the quality of our customer service, our products, train staff and record what is said.

Marketing

We strive to provide you with choices regarding certain personal information uses, particularly around marketing and advertising.

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 products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and, in each case, you have not opted out of receiving that marketing.

Third-party marketing: We will get your express opt-in consent before we share your personal data with any company outside of Framble for marketing purposes.
You can ask us to stop sending you marketing messages at any time by contacting us at any time or going to your profile on the app and choosing to opt out.
Where you opt out of receiving these marketing messages, this will not apply to personal information provided to us as a result of a product/service purchase.

Disclosing your personal information

Framble may pass on your personal information to trusted third parties to assist us with the activities set out in the table above. Such disclosures will enable us to provide you with the best user experience on the Website.

When we share your personal information with trusted third parties it may be transferred outside of the UK or the European Union. In these circumstances, your personal information will only be transferred on one of the following bases:-

the country is approved by the European Commission as providing an adequate level of protection for personal data;
the transfer is to a recipient in the United States of America who has registered under the EU/US Privacy Shield;
the recipient has entered into European Commission standard contractual clauses with us; or
you have explicitly consented to the same.

If you wish to find out more about us transferring your personal information outside of the European Union and the countries concerned please contact us.

We may transfer your personal information to the following external third parties:

Service providers acting as processors based in the United Kingdom who provide IT and system administration services.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
Public, regulatory or other relevant authority acting as joint controllers based in the United Kingdom who may require your personal information for any investigation and/or prosecution.
HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
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 information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

Change of purpose

We will only use your personal information 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 information 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 information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Holding information

We will only retain your personal information 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. Generally, we hold your personal information for the following periods:

a minimum of six years;
as long as is necessary for the relevant activity or as long as is set out in any relevant agreement, transaction and/or arrangement entered into;
a reasonable length of time to keep records and demonstrate compliance with professional and/or legal obligations;
any retention period required by law; and/or
the end of the period in which litigation or investigations might arise.

In some circumstances you can ask us to delete your personal information. Please see above for more information about your rights.

Security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

Your personal information will be held on secure servers and all transactions are encrypted using secure socket layer (SSL) advanced encryption technology up to 128-bit encryption. Please note that email communications with Framble are NOT encrypted or otherwise secured against outside interference; please use discretion when providing personal details via email. Once we receive your information, it will be held by us on secure servers and we will use all reasonable commercial efforts to ensure its security.

We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Changes to the privacy policy

We may update this policy from time to time. We will notify you of the changes where required by law to do so. We recommend that you review this policy regularly.

Cookies
What are cookies?

Cookies are small files of information that a website stores on a user's computer. Cookies are designed to allow the server to identify the user and understand the user's activity. Framble uses cookies on the Website in order to improve your user experience and the Website's performance.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Website may become inaccessible or not function properly.

What type of cookies does Framble use?
When you use the Framble website the following types of cookies can be set on your device:

Session Cookies: these are stored in memory of the user's device and will remain there until the user closes the browser. Once the browser is closed, stored information is then permanently removed from the user's device memory. Session Cookies does not allow Framble to access any private information or personal date from a user's device.
Persistent Cookies: these are stored on a user's device and unlike a session cookie, the closing of a browser will not permanently remove the information. The information will remain on the user's device until either the user deletes the cookie or it expires. Persistent Cookies do allow Framble to access any private information or personal date from a user's device. Please see our 'Cookies Policy' for further information.

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