We, Sportmarket Services Limited (Sportmarket), are committed to protecting and respecting your privacy.
This policy (together with our General Terms and Acceptable Use Policy) sets out the basis on which any personal data 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 data and how we will treat it.
For the purpose of the Data Protection Act 1998 and, from 25 May 2018, GDPR (together and separately, the Act), the data controller is Sportmarket. We are a company, incorporated in Isle of Man, with registered office at Burleigh Manor, Peel Road, Douglas, Isle of Man IM1 5EP.
INFORMATION WE MAY COLLECT FROM YOU
We may collect and process the following data about you:
- Information that you submit to us, including information submitted via our website at www.sportmarket.com (Website) and/or our sport trading platform (Sportmarket Pro) available via the Website (Platform). This includes information provided at the time of registering to use our Website or our Platform. We may also ask you for information when you report a problem and we may record any telephone calls with you.
- If you contact us, we may keep a record of that contact and any related correspondence (including emails).
- Details of transactions you carry out through our Website or our Platform.
- Details of your visits to our Website or Platform (including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise) and the resources that you access.
HOW WE PROCESS PERSONAL DATA
In accordance with the Act, we will only process your personal data where we have a lawful basis for doing so. In respect of your personal data, these bases are where it is necessary to provide services to you under the performance of the contract we have with you; where we are required to do so in accordance with legal or regulatory obligations; where you have given your consent; and where it is in our legitimate interests to process your personal data provided that these do not prejudice your own rights, freedoms and interests.
We will process your personal data for the following purposes:
- To provide you with access to our Website and Platform and any services you may request. (necessary for the performance of a contract).
- To monitor and verify your use of the Website and Platform and any payments owed to us (necessary for the performance of a contract).
- To communicate with your following any queries you raise with us (consent).
- To record calls and retain communications for training purposes so that we can continue to improve our communications and customer service (legitimate interest).
- To monitor your use of our Website and Platform in order for us to improve our service and the Website and Platform (legitimate interests).
- To notify you of changes to our Website and Platform (necessary for the performance of a contract).
- To profile you for the purposes of direct marketing, both in relation to you and also in relation to customers generally, so that we can send out more appropriate marketing (legitimate interests).
- To send you direct marketing communications [where you have given your consent for us to do so / except where you have opted out of such direct marketing].
IP ADDRESSES AND COOKIES
We will collect information about your use of our Website and Platform, including where available your IP address, operating system and browser type, for system administration and reporting purposes.
We may obtain information by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer's hard drive. They help us to improve our Website and Platform and to deliver a better and more personalised service. They enable us to identify you, monitor your usage of the Website and Platform and to recognise you when you return to our Website or Platform.
If you choose to disable cookies after you have already accessed the Website or Platform we recommend that you delete any persistent cookies stored on your computer’s hard-drive. This can usually be managed via your browser settings.
WHERE WE STORE YOUR PERSONAL DATA
The data that we collect from you may, if necessary, be transferred to, and stored at, a destination outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Whenever we transfer your personal data outside of the EEA we will ensure that adequate protections are in place to keep your personal data secure
We capture your personal data over a secure link using recognized industry standard Secure Sockets Layer (SSL) technology which encrypts the data whilst passing it over the internet. This will be indicated on most browsers by a lock in the status bar at the bottom of the screen. Firewalls are also used to block unauthorized traffic to the servers.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
DISCLOSURE OF YOUR INFORMATION
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- If Sportmarket or substantially all of its assets are acquired by a third party, in which case personal data held by us will be one of the transferred assets.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, governmental or regulatory authorities or to protect the rights, property, or safety of Sportmarket, our clients, or others. This includes exchanging information with other companies and organisations for the purposes of KYC, fraud protection and credit risk reduction.
Other than the instances listed above, we will not disclose your personal information to third parties without your consent.
UPDATING YOUR INFORMATION
It is important that the information we hold about you is accurate for us to comply with our legal and regulatory obligations and to provide you with the best possible service. We therefore request that you ensure your personal data is always up to date.
The Act gives you the following rights in relation to your personal data:
- a right to access your personal data held by us;
- a right to receive certain personal data in machine-readable format;
- a right to object to processing where lawful basis is that it is in our legitimate interests, but please note that we may still process your personal data where there are other relevant lawful bases or where we have compelling grounds to continue processing your personal data in our interests which are not overridden by your rights, interests or freedoms;
- a right to have inaccurate personal data rectified;
- a right to have certain personal data erased where it is no longer necessary for us to process it, where you have withdrawn your consent, where you have objected (subject to the above), where your personal data has been unlawfully processed, or where erasing your personal data is required in accordance with a legal obligation;
- a right to request an explanation of the logic involved where we make decisions about you solely through automated means;
- a right to complain to your national data protection regulator;
- where we have specifically requested your consent to process your personal data and have no other lawful conditions to rely on you have the right to withdraw this consent; and
- a right to object to direct marketing, which can be done by opting-out of direct marketing either through your account or by opting out via the communication itself. You also have a right to object to any profiling to the extent that it relates to direct marketing only.
If you are unsure about your rights or are concerned about how your personal data may be processed, you should contact your national data protection regulator.
If you would like to exercise any of your rights, then you can do so by emailing us at email@example.com. Please be aware that whilst we will try to accommodate any request you make in respect of your rights they are not absolute rights. This means that we may have to refuse your request or may only be able to comply with it in part.
Where you make a request in respect of your rights we will require proof of identification. We may also ask that you clarify your request. If we receive repeated requests or have reason to believe requests are being made unreasonably we reserve the right not to respond.
RETAINING YOUR PERSONAL DATA
We will retain your personal data for the period necessary to provide you with services. Accordingly, once you close your account with us we will commence the process of deleting your personal data. We expect that most of your personal data will be removed within twelve months of you closing your account save for personal data that we are required to hold pursuant to statutory or regulatory obligations, to honor self-exclusion or where needed for legal claims.
We may contact you in relation to promotions, products or services that you may be interested in from time to time. You can opt-out at any time by emailing us at firstname.lastname@example.org.
We may also carry out certain profiling of you and your activity in relation to our services in order to send you more relevant marketing communications. This profiling will be undertaken based on your use of our services.