1.1 Any reference to “we”, “us” or “our” is to The Football Pools Limited. Please see below for our contact details. Any reference to “you” or “your” means you as a person who participates in a Game (as defined in the Retail Terms and Conditions, Telephone Terms and Conditions, Website Terms and Conditions and Postal Terms and Conditions) (the “Terms and Conditions”) provided by us.
1.3 This Policy is incorporated in the Website Terms and Conditions, Retail Terms and Conditions, Telephone Terms and Conditions and Postal Terms and Conditions. By using or registering on the Website or participating in a Game by telephone, post or via a retailer, you accept and agree to the terms of this Policy and consent to the use of your Information as set out in this Policy.
1.4 We may modify this Policy from time to time. Any changes to this Policy shall become effective upon posting the revised Policy on our website (www.footballpools.com) (the “Website”).
2 How is personal information collected?
2.1 We collect your personal information when you:
2.1.1 register on the Website or participate in a Game by telephone, post or via a retailer;
2.1.2 update the details of your player account;
2.1.3 use the Website or the services provided by us or participate in a Game by telephone, post or via a retailer (the “Services”);
2.1.4 make a complaint or enquiry or provide feedback to us;
2.1.5 place a bet or submit an entry to a competition;
2.1.6 request to be sent communications (for example such as updates and newsletters); and
2.1.7 disclose your personal information to us through the Website or otherwise at any point, including via telephone, post or via a retailer.
2.2 All transactions via your player account or entries which are made by telephone, post or via a retailer are recorded on our computer systems. We also carry out routine monitoring of systems to assist us in improving the Services.
2.3 In addition, if you use the Website, in common with many other online services, we use “cookies” or other devices to store and sometimes track information about you (see section 8 below for more information).
3 How may your information be used?
3.1 We may collect and process your Information for the purpose of providing the Services to you and for our legitimate interests. In particular, this will include the following purposes:
3.1.1 to provide our products and services to you (including, without limitation, setting-up, operating and managing your player account) and enable you to make full use of the Website and the Services and to participate in Games;
3.1.2 to maintain our records including transaction records required for audit purposes and internal record keeping;
3.1.3 to send to you notice of important service changes, technical issue updates and substantial changes to the Terms and Conditions;
3.1.4 to customize our products and services according to your interests;
3.1.5 to send information to you about new and associated products and services and promotional offers. If you do not wish to receive promotional information from us, please make sure you click on the appropriate “opt out” box on registration, or otherwise let us know by contacting us at the details set out below in section 12;
3.1.6 to collate information and statistics for the purposes of monitoring website usage as well as to facilitate development of the Website, the Services and Games and build profiles of our customers. Such statistical information may be furnished to third parties, but will not include personally identifiable information;
3.1.7 to verify the accuracy of your Information and perform identification and verification checks;
3.1.8 to facilitate the processing of your financial transactions;
3.1.9 to investigate fraud, cheating and money laundering, to ensure compliance with, and enforce, the Terms and Conditions and to protect (or comply with processes imposed by regulators and/or sports bodies in order to protect) sports/game integrity;
3.1.10 to comply with our legal and regulatory duties, obligations and responsibilities under applicable law and otherwise to any relevant regulators and competent authorities; and
3.1.11 any other purpose as may be required to enable us to perform our contractual obligations to you.
4 Who may use your information?
4.1 In connection with the uses set out above, we may share your Information with the following third parties:
4.1.1 banks and financial institutions, credit reporting agencies, age verification agencies and such other companies that may provide such identification and verification services to us from time to time;
4.1.2 our service providers, electronic payment providers and other third party data processors, who process your Information on our behalf for the purposes identified in section 3 above;
4.1.3 relevant authorities (such as courts, police, legal advisors or any regulatory body) should the disclosure be required by law or regulation or in connection with any alleged unlawful or fraudulent activity or money laundering or any suspected breach of the Terms and Conditions by you; and
4.1.4 other online gambling operators, service providers, banks and financial institutions, credit card companies, payment systems providers and / or relevant authorities in the event of any suspected unlawful, fraudulent and / or improper activities.
4.2 Except as set out above, we will not disclose or sell your Information outside The Football Pools Limited, except: (i) in connection with any proposed or actual sale of the whole or part of our business; or (ii) to carefully selected third parties for marketing purposes subject to receiving your consent.
We shall keep records of your Information and our data collecting practices for as long as required to provide Services to you and otherwise in accordance with legal requirements and tax and accounting rules.
6 Security Measures
6.1 We are committed to ensuring that your Information is secure. In order to prevent unauthorised access or disclosure we have put in place internal control procedures to safeguard and secure the information we collect. Where your personal data is stored electronically, it is protected by firewall and encryption technology.
6.2 Unfortunately, the transmission of Information via the internet is not completely secure and, although we will do our best to protect your Information (as set out above), we cannot guarantee the security of any Information that you disclose online. You accept the security implications of providing Information via the internet and that we will not be responsible for any breach of security unless we have been negligent.
7 Controlling your Information
7.1 Subject to applicable law, you may choose to control the content or use of your Information by asking us to:
7.1.1 rectify inaccurate the use of Information held by us;
7.1.2 send to you a copy of the Information that we hold about you; and
7.1.3 erase Information which you would no longer would like us to store.
7.2 However, please note that the failure to provide Information or requiring us to stop using your Information may impact on our ability to provide the Services and your access to the Games. In particular, if you play via the Website, this may mean that your player account has to be closed.
7.3 We require you to prove your identity with two pieces of approved identification to process any requests under this section. Please address requests to email@example.com and, following receipt of your confirmed ID, we shall respond in accordance with applicable law. Where providing you with such information, where permitted by law, we reserve the right to request a reasonable fee based on our administrative costs.
8.1 This section explains what cookies are, how they are used on the Website and how to manage their use.
8.2 A cookie is a small amount of data sent from our server and stored on your computer’s hard drive. Cookies enable an improved online experience when you visit certain pages of a website, such as remembering your preferences or navigation history and to ensure that the contents and functions of a website are delivered and used more effectively.
8.3 Cookies perform various different functions. For example, some cookies are downloaded to your device temporarily for the period that you browse a particular website. These cookies might allow you to navigate between pages more efficiently or enable websites to remember the preferences you select. Other cookies can be used to help websites remember you as a returning visitor or ensure the online adverts you receive are more relevant to your specific needs and interests.
8.4.1 to store information about whether you have the flash player installed or not;
8.4.2 to store the date and time of your visit(s) to the Website;
8.4.3 to allow you to carry information across pages of the Website and other websites operated by us and avoid having to re-enter information;
8.4.4 to allow you to access stored information in your player account;
8.4.5 to allow us to tailor content to match your preferred interests or to avoid showing you the same adverts repeatedly;
8.4.6 to compile anonymous, aggregated statistics that allow us to understand how users use the Website and the Services;
8.4.7 to help us improve the structure of the Website;
8.4.9 to understand who has seen which pages on the Website;
8.4.10 to determine how frequently particular pages on the Website are visited and the most popular areas of the Website; and
8.4.11 to generally monitor usage of the Website.
8.5 The types of cookies which we use are essential for the operation of your account, such as accessing secure areas, placing bets, depositing funds and managing your account. Session cookies are used to store information about user page activities so you can easily pick up where you left off on the server’s page. Functionality cookies are also used to remember your settings and choices in order to provide enhanced and personalised features. We do not use any cookies which may be regarded as “intrusive, such as observing your activity whilst browsing the web and to present targeted and specific advertising to you as a user.
9 Other websites and third party cookies
The Website may contain links from time to time that make it easy for users to visit other websites. If you use the links to leave the Website and visit a website operated by a third party, we do not have any control over that third party website. Such third party websites generate their own cookies to track how many people have accessed their website via a link from another website and how often this is done. Accordingly, we are not responsible for the protection and privacy of any Information which you provide while visiting such websites. You should exercise caution and look at the privacy and cookies statement applicable to the website in question before submitting any Information to them.
10 Transfer of data
Owing to the global nature of our internet infrastructure and service, your Information may be transferred to countries outside the European Economic Area (“EEA”), but only in connection with the purposes set out above. Please note that some of these countries do not have protections in place regarding your Information and its use that are equivalent to the protections offered in the EEA. However, we will always take such steps as are reasonably necessary to ensure that your Information is secure and used only in accordance with this Policy.
11 Proof of Minors
11.1 The Website is not intended for or directed at persons under the age of 18 years old. By providing your Information to us via the Website 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. This may include supplying the details that you have provided to authorised credit reference agencies.
11.2 If we become aware that a minor has submitted or has attempted to submit Information via the Website or otherwise, we will not accept this information and will take steps to remove such information from our records.
13.1 The Football Pools Limited, a company registered in England and Wales (company number 10573569) with its registered office at Walton House, 55 Charnock Road, Liverpool, L67 1AA.
13.2 If you would like to complain about our practices or how your Information has been handled you can contact the Information Commissioner’s Office on their helpline: 0303 123 1113 or see their website: https://ico.org.uk/concerns/.
13.3 Our data protection registration number is ZA262123.