Dabblebet Privacy Notice

This Privacy Notice explains how FSB Technology (UK) Ltd (“FSB”) and Perform Media Services Ltd (“Perform”) together with other companies within the Perform Group (which means our subsidiaries, our ultimate holding company and its subsidiaries) use information we collect about you and the choices you can make about the way your information is collected and used. We are committed to protecting and respecting your privacy.

This Privacy Notice applies to and is incorporated in the dabblebet Terms of Use and applies to dabblebet.com and our free to play games known as dabble 4Cast and dabble 5-a-side live(“Services”). FSB and Perform are both data controllers of information collected through the Services, and may be referred to as “we”, “us” and “our” throughout this Privacy Notice.

This Privacy Notice sets out the basis on which any personal information we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal information and how we will treat it. By accessing and using the Services which is made available via our website or through our apps, or any mobile versions thereto or by continuing to use the Services you are accepting and consenting to the practices described in this Privacy Notice.

This Privacy Notice has been last updated on 25 May 2018.

INFORMATION WE MAY COLLECT FROM YOU

We may collect and process the following data about you:

Information you give us

You may give us information about you:

- When you enter such information while using the Services, such as when you place funds in your player account, place a bet or make a selection in our free to play games;
- When you interact with our customer service team;
- When you participate in our surveys or marketing promotions;
- If you choose to provide information relating to reviews or ratings, favourite sports, tournaments, teams, events or personalities, and/or other subjects of interest to sports fans;
- In relation to your account settings;
- When you set preferences in the 'My Account' section of our website and/or app;
- When you otherwise provide information to us through the Service or elsewhere.

Collection of Information

We, whether directly or through third party suppliers, will collect information regarding your use of our Service, including but not limited to:

- Your name, username and password;
- Your personalized account details (see below);
- Your contact address, including your email address, phone numbers and/or billing address;
- Your interactions with our site, applications and emails;
- Your payment method, including details of your payment country; payment type and the history of any failed/successful payments (other than when you solely play our free to play games);
- Information regarding use of the Services. This information includes your activity on the Service, such as your bet selections, amount staked, transactions carried out, watching history and promotional engagement.
- Your entry details for a competition or promotion;
- Device IDs or unique identifiers, location data, device and software characteristics (such as type and configuration), connection information, statistics on page views, referral URLs, ad data, website and app navigation, IP address and standard web log information;
- With your consent, the location of your device;
- Information collected via the use of Cookies, web beacons and other technologies. See our Cookies policy for more details;
- Your betting, gaming and payment history on the Service and other account transactions or selections if you solely play our free to play games;
- Any website that referred you to the Service, together with any online and email marketing campaigns related to the Service;
- information we collect using cookies stored on your device about how you use our Service and/or selected third party websites. For more information please see the Cookies section below;
- information that you provide as part of Know Your Customer and anti-money laundering checks, including copies of identification documentation and bank account information (other than when you solely play our free to play games);
- The types of devices you use to view the Service(s);
- Behaviour on our Service as you click around our website or application; and
- Online and email marketing campaigns related to the Service(s) that you receive or subscribe to in relation to the Service(s).

Account There are certain Services you will only be able to access by registering with us. To register with us, you must provide us with at least your first name, surname, email address, date of birth, username and password.

Failure to provide information

Where you are signing up to a betting or gaming Service, FSB may be required to collect and process certain data about you (including your home address) in order to meet its legal obligations in providing the Service. If you fail to provide that information – such as copies of documents to confirm your identity – we may be unable to provide you with the Service.

Uses made of the information

We may use the personal information you provide to us to do some or all of the following, in each case to the extent permitted by applicable data protection laws:

- administer our website and apps;
- provide the Service(s) you have requested;
- improving your browsing experience by personalising the Services for you (subject to your settings in the cookies section). For example, we will present you with features we know you have used or think you are likely to use or show you the bet slip that best suits your preferred style of betting;
- recommend goods, services or promotions which may be of interest to you or contact you in order to conduct market research (but only where you have requested us to do so). For these purposes, we will create a profile about your interests and preferences which will enable us to increase our advertising and communication relevance;
- prevent, detect and investigate potentially prohibited or illegal activities, including fraud, cheating, and money laundering and enforce our terms;
- to notify you about changes to our Services;
- contact you in order to conduct market research (but only where you have requested us to do so);
- send out email alerts, text messages or device notifications in relation to our Service;
- send you prizes won via our website or apps;
- provide third parties with statistical information about our users – but this information will not be used to identify any individual user;
- deal with enquiries and complaints;
- provide our commercial partners with information about users’ use of co-branded services, including historical use data;
- to comply with any legal, regulatory and compliance requirements:

i. We need to comply with a range of legal and regulatory requirements, some of which involve the use of personal information and/or set out timescales for which we need to keep that information. As a provider of betting and gaming services, we are regulated by the Gambling Commission of Great Britain. To comply with our regulatory requirements, we carry out checks during account opening and throughout the life of account to ensure our you bet and play responsibly and legally. Please note that our free to play games are not regulated in the same manner.

ii. We take our social responsibility and our commitment to responsible gambling very seriously and we actively look for behaviour that may indicate someone is at risk of problem gambling so that we can intervene at an early stage to provide them with support and direct them to sources of help.

iii. Where a customer based in Great Britain self-excludes through the “GAMSTOP” national self-exclusion scheme, we will receive a notification of this, which we will use to apply the chosen restriction across our site and apps.

iv. To help us understand the factors that can indicate the early stages of problem gambling, we look at information about customers who have self-excluded (either directly or through “GAMSTOP”), such as age, location and past betting behaviour, to identify common factors. This helps us intervene earlier in cases where customers may be at risk of problem gambling, and provide them with better support.

v. We are also subject to laws and regulations relating to other aspects of our business, such as payment processing or complaint handling and some of these too involve the use of, or set timescales for holding, your personal information.

- to understand customer trends and patterns; and
- develop aggregate analysis in respect of our users and business intelligence that enables us to operate, protect, make informed decisions and report on the performance of our business and understand how, where and why you use our Services.

Disclosure of your information

We may share your information with selected third parties including:

- Business partners, suppliers and sub-contractors in connection with providing Services to you.
- Advertisers and advertising networks that require the data to select and serve relevant adverts to you.
- Analytics and search engine providers that assist us in the improvement and optimisation of our site.
- In the event that Perform sells the business operating and/or making available the Service or it is integrated with another business, in which case Perform may disclose your personal information to our advisers and any prospective buyer’s advisers as well as to the new owners of the business.
- If we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our terms of use; and
- In order to prevent fraud, cheating and money laundering we may disclose your information and for betting and gaming history to third parties including, but not limited to, any relevant regulator, gaming and sporting bodies, financial institutions and law enforcement agencies or any other body that deals with the investigation of alleged offences.
- Fraud, Money Laundering and Other Illegal Activity – When you set up an account with us, place bets or play our games (other than our free to play games), we carry out identity verification, fraud prevention and anti-money laundering checks, validating the information you give against third-party crime prevention databases and, where necessary, information from publicly-available sources. We may ask you to provide physical forms of identification and/or we may telephone to confirm your identity We share your personal data with organisations that verify details and transactions and identify potential indicators of illegal activity, which they make available to other organisations using their services. Where necessary, we share your data with Credit Reference Agencies (such as GB Group Ltd) or fraud prevention agencies, which keep a record of that information and make it available to other organisations for use in credit decisions, identification checks and fraud detection and prevention. These agencies keep a record of the information we and other companies provide and make it available for use by other organisations carrying out identification checks and fraud prevention. In order to provide this essential service, these agencies/services are ‘data controllers’ for the purposes of data protection law, which means they own and control the information we and their other subscribers provide to them. As ‘data controllers’, they are obliged to comply with data protection law and can use the information shared with them only to provide these checks. We cannot provide our products and services without carrying out these essential checks by sharing your data in this way, so it is important that we make you aware of it from the outset. If you are not happy for us to pass your information to credit and fraud prevention agencies, you will not be able to open an account and use our pay-to-play products and services.
Where required by law, or in circumstances where FSB deem it appropriate, it may disclose your information, including your betting and gaming history, to any relevant regulator, police, gaming and sporting body, or law enforcement agencies or any other body that deals with the investigation of alleged offences.

Security

We understand that the security of your personal information is important to you. When handling personal information, security is paramount and we seek to ensure that personal information is protected through appropriate technical and organisational measures. We use reasonable administrative, logical and physical controls, including password protection, to safeguard your personal information against loss, theft and unauthorised 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 personal information in accordance with applicable law, we cannot guarantee the security of your personal information.

INTERNATIONAL DATA TRANSFERS

Information that Perform collects may be stored and processed in and transferred between any of the countries in which Perform operates in order to enable Perform to use the information in accordance with this Privacy Notice.

Information which you provide may be transferred by Perform to our group companies, commercial partners, suppliers or agents located outside your country. We will ensure adequate protection of personal data transferred outside of your country as required under applicable law.

PARENTS AND GUARDIANS

The Services are not intended for or directed at persons under 18 years of age. By providing your information to us via the website, app or otherwise you represent to us that you are at least 18 years old and acknowledge that your information can be used to verify that this is the case.

If we become aware that a minor has submitted or has attempted to submit information via the app or otherwise, we will not accept this information and will take steps to remove such information from our records.

Marketing

As mentioned above, we may contact you with information about offers, products and services that might be of interest to you (but only if you have consented to receive such marketing). If you have consented to receiving marketing communication by either (i) ticking the marketing box when you signed up or (ii) ticking the marketing tick-box within the My Account section of our website, and then confirming this via email, but you no longer wish to receive these notifications, please send us an email at support@dabblebet.com. You can also click on the ‘Unsubscribe’ link at the bottom of any of our marketing emails.

Contact

Questions, comments and requests regarding this Privacy Notice are welcomed and should be addressed to support@dabblebet.com.

For our clients located in the EEA, we provide further information in our Privacy Notice Annex (see below).

Changes

We reserve the right to change the practices described in this Privacy Notice at any time by posting an updated Privacy Notice. Please check here periodically. If we amend this notice, your continued use of the Services will amount to your acknowledgment of the amended notice.









ANNEX TO PRIVACY NOTICE

ADDITIONAL INFORMATION FOR EEA AND SWISS INDIVIDUALS

In order to comply with data privacy regulations in the EEA, Switzerland and UK, Perform and FSB provides additional information to its EEA based individuals.

What is personal data?

“Personal data” is information about you (a “data subject”) the use of which is governed by applicable data protection laws. It will include any information from which you can be identified, directly or indirectly, in particular by reference to an identifier such as your name, an identification number, location data, an online identifier or other information about your identity. Most of the personal information provided by you will constitute personal data.

Who is responsible for your data?

The data controllers for your information are:

Perform Media Services Ltd
Sussex House
Plane Tree Crescent
Feltham
TW13 7HE
United Kingdom

and

FSB Technology (UK) Ltd
2nd Floor
167-169 Great Portland Street
London
W1W 5PF

Perform Media Services Ltd is registered as a data controller with the Information Commissioner’s Office (registration number ZA188575).

FSB Technology (UK) Ltd is registered as a data controller with the Information Commissioner’s Office (registration number ZA011811).

What is the legal basis on which we rely to process your data?

On some occasions, we process your data with your consent (for example, when you agree to participate in our surveys and other activities or when you give us consent to send you marketing communication or to deal with your enquiries).

On other occasions, we process your data when we need to do this in order to fulfil a contract with you (for example, settling a bet) or where we are required to do this by law (for example, where we have to fulfil anti-money laundering requirements).

We also process your data when it is in our legitimate interests to do this and when these interests are not overridden by your data protection rights. For example, we may process your personal data in our legitimate interests to ensure that our platforms and Services are provided efficiently and in a user-friendly and personalised manner taking into account user feedback, data and profiles, unless consent is required for any such processing under applicable law. We will process personal data to ensure the security of our business and the information of our users, and to ensure the proper and efficient administration of our business.

How long do we keep data?

We keep your data for only as long as required to provide you with the necessary Services and to carry out the processing set out in this Privacy Notice, and in line with our obligations under applicable law. This means that we will generally not keep your personal information for longer than six years following your last interaction with us.

Your rights

You may ask us for a copy of your information, to correct it, erase it or to transfer it to other organisations at your request. You also have rights to object to some processing and, where we have asked for your consent to process your data, to withdraw this consent. In particular, you have rights to object to direct marketing at any time. Where you withdraw your consent, this will not affect the legitimacy of the processing conducted prior to your request.

Where we process your data because we have a legitimate interest in doing so (as explained above), you also have a right to object to this. Where we make a decision based solely on automated processing which significantly affects the data subject, he or she may have the right to contest the decision, express his or her point of view and obtain human intervention.

These rights may be limited in some situations – for example, where we can demonstrate that we have a legal requirement to process your data.

Please use the contact information set out in our Contact section above. We will aim to acknowledge your enquiries within 72 hours and respond within one month, unless otherwise required by law.

We hope that we can satisfy queries you may have about the way we process your data. If you have any questions or concerns, or wish to exercise any of your rights, you can get in touch at support@dabblebet.com or use one of the “contact us” forms on the Service. However, if you have unresolved concerns you also have the right to complain to the relevant data protection authority (in the case of the UK, the Information Commissioner).