1. What is this?
1.1 At The Football Pools Limited (referred to as "we", "us", "our") we take privacy seriously and we are committed to protecting it.
1.2 This policy explains when and why we collect personal information about individuals, how this information is used, the conditions under which it may be disclosed to others and how it is kept secure.
1.3 This policy may change from time to time so please check this page occasionally to ensure that you're happy with any changes.
1.4 This policy will be effective on 16 March 2020.
2. Who we are
2.1 The Football Pools Limited (company number 10573569) and its subsidiary Pools Gaming Limited (company number 11506381) are the data controllers in relation to the processing activities described below. This means that we decide why and how your personal information is processed.
3. Personal information we collect and how we collect it
3.1 The personal information we collect and the way in which we collect it is set out below:
3.2 The information you provide to us during the account registration process for any of our services by entering information via our site (www.thepools.com), our mobile application, social media platforms, or corresponding with us by phone, email, post or otherwise. This may include, but is not limited to your name, postal address, e-mail address, phone number, credit/debit card details, date of birth and any other details as might be requested from you for the purpose of registration and/or continued use of our services.
3.3 The information we may also collect if you request information or customer support. We may also ask you for information when you report a problem with our site. This is information about you that you give to us by entering information via:
our site (www.thepools.com);
our mobile applications;
social media platforms;
corresponding with us by phone, email or otherwise,
and includes name, postal address, email address, phone number, enquiry details, and may include records of any correspondence with you
3.4 The information you provide to us in order to subscribe to the services we provide through our site, mobile application or by post, posting material or requesting further services, managing your account online (including accessing documentation and engaging in correspondence with us by phone, email or otherwise). This information includes your name, postal address, e-mail address, phone number, credit/debit card details, bank account details and date of birth.
3.5 If you complete any surveys that we request you complete for research purposes, we will collect information in such circumstances as well. The information you give us includes your name, address, email address and phone number, and responses to any surveys.
3.6 Additional Personal Information we may collect about you when you use our products and services:
3.6.1 name, contact information and message if you contact us or participate in a contest or promotion;
3.6.2 technical information, including anonymous data collected by the hosting server for statistical purposes, the Internet protocol (IP) address used to connect your computer or device to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform. Details such as traffic information, location data and other communication data (including IP address and browser type) collected by your availing of the services;
3.6.3 device information including unique device identified;
3.6.5 your betting, gaming, deposits, payments, payment method and other account transactions - these are routinely analysed to assist us in improving the services we provide to you;
3.6.6 your telephone or Live Chat conversations – either to place a bet or a customer service call;
3.6.7 your response to marketing campaigns from us or through our third parties;
3.6.8 your social media profile details when you connect with or contact us through a social media account;
3.6.9 information derived based on profiling activity (see below); and
3.6.10 information from third party databases to comply with our legal and regulatory obligations.
3.7 We may also collect any personal information which you allow to be shared that is part of your public profile or third party social network, type and version, time zone setting, browser plug-in types and versions, operating system and platform.
3.8 Personal information we may receive from other sources:
3.8.1 Not all the personal information we hold about you will always come directly from you. We may also collect information from third parties such as our partners, service providers and publicly available websites (i.e. social media platforms), to comply with our legal and regulatory obligations, offer services we think may be of interest, to help us maintain data accuracy and provide and enhance the services.
4. How we use your personal information
4.1 The purposes for which we use your information and the legal basis under data protection laws on which we rely to do this are explained below.
4.1.1 Performance of the contract with you or to take steps to enter into:
We may use and process your personal information where we have supplied you (or continue to supply you) with any products or services, where we have arranged for the supply of another company's products or services to you, or where you are in discussions with us about any new service. We will use this information in connection with the contract for the supply of products or services when it is needed to carry out that contract with you or for you to enter into it. Please see clause 3 for details of the types of personal information we process for these purposes.
4.1.2 Account setup, verification and management:
We use personal information such as your name, email address, phone number, and information about your device to set up and administer your account, provide technical and customer support and training, verify your identity, process payment information and send important account and service information.
4.1.3 Where you have provided consent:
We may use and process your personal information where you have consented for us to do so. This includes:
126.96.36.199 sharing your precise geolocation with us so we can ensure that we are authorised to provide the Services to you in your location pursuant to our terms and conditions;
188.8.131.52 contacting you with marketing information about our services if you have (i) registered for an account with us online and (where we don't have another basis to contact you) indicate that you would like to receive such marketing from us; (ii) sign up to our emails or texts service via our website or other medium where available; or (iii) when you refresh your marketing preferences and provide a consent when responding to a request from us to do so;
184.108.40.206 sharing your data with our third party partners for them to contact you with marketing information about their (or their group companies, as applicable) products and services – we’ll tell you who these third party partners are at the time we ask for your consent;
220.127.116.11 you may withdraw your consent for us to use your information in any of these ways at any time – please see clause 13.1.2 for further details.
18.104.22.168 please see clause 13.1.3 for further details.
4.1.4 Where there is a legitimate interest:
We may use and process your personal information where it is necessary for us to pursue our legitimate interests as a business, or that of a third party, for the following purposes:
22.214.171.124 for marketing activities (other than where we rely on your consent to contact you by email or text with information about our products and services or share your details with third parties to do the same, as explained above in clause 4.1.3);
126.96.36.199 for analysis to inform our marketing strategy, and to enhance and personalise your customer experience (including to improve the recommendations we make to you on our website and our mobile app);
188.8.131.52 to share information (including Google Analytics data) with our third party partner, Reach Plc, in order for it to better understand our customer’s preferences and habits, and to create a profile of our customers, to inform Reach Plc’s, and its group’s, marketing personalisation strategy which is used to personalise your experience with us and Reach Plc’s brands (for further details on this sharing and Reach Plc’s brands, see clause 6.5.2 below);
184.108.40.206 to correspond or communicate with you;
220.127.116.11 to verify the accuracy of data that we hold about you and create a better understanding of you as a customer;
18.104.22.168 for network and information security in order for us to take steps to protect your information against loss or damage, theft or unauthorised access;
22.214.171.124 for prevention of fraud and other criminal activities;
126.96.36.199 to publish players' aliases / nicknames along with any winnings and prizes received on our websites;
188.8.131.52 to comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request);
184.108.40.206 to assess and improve our service to customers through recordings of any calls with our contact centres;
220.127.116.11 for the management of queries, complaints, or claims; and
18.104.22.168 for the establishment and defence of our legal rights.
4.1.5 Where there is a legal requirement:
22.214.171.124 We will use your personal information to comply with our legal obligations. We may be required to use and retain personal information:
(i) for legal and compliance reasons, such as the prevention, detection, or investigation of a crime; or fraud;
(ii) to identify you when you contact us; and
(iii) to verify the accuracy of data we hold about you.
126.96.36.199 We will verify your age and accuracy of your registration details, including disclosure of such information to third parties e.g. financial institutions and third party reference agencies. This is required for the purpose of our complying with our legal obligations.
188.8.131.52 We may also use personal information to meet our internal and external audit requirements, information security purposes, and as we otherwise believe to be necessary or appropriate under applicable law, which may include laws outside your country of residence, and also to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include such authorities outside your country of residence.
5. Data anonymisation and use of aggregated information
5.1 Your information may be converted into statistical or aggregated data in such a way as to ensure that you are not identified or identifiable from it. Aggregated data cannot be linked back to you as a natural person. We may use this data for analytical and research purposes.
6. Others who may receive or have access to your personal information
6.1 Our suppliers and service providers:
6.1.1 we may disclose your information to our third party service providers, agents, subcontractors and other organisations for the purposes of providing services to us or directly to you on our behalf. Such third parties may include cloud service providers (such as hosting and email management), marketing agencies including creative, advertising, production and customer verification and administrative services.
6.1.2 when we use third party service providers, we only disclose to them any personal information that is necessary for them to provide their service and we have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions.
6.2 Third parties who provide products and services:
6.2.1 we work closely with various third parties to bring you a range of products and services that are complementary to those that we provide.
6.2.2 when you enquire about or purchase one or more of these products or services through us, the relevant third party may use your details to provide you with information and carry out their obligations arising from any contracts you have entered into with them.
6.3 Credit/debit card payment processors:
6.3.1 when you purchase any products or services online, your credit/debit card payment is processed by a third party payment processor, who specialises in the secure online capture and processing of credit/debit card transactions. If you have any questions regarding secure transactions, please contact us using the details at the end of this policy.
6.4 Customer satisfaction surveys:
6.4.1 as customer satisfaction is important to us, we may ask a third party research company to contact you for the sole purpose of gathering general information and specific information relating to us and our products and services.
6.5 Other ways we may share your personal information:
6.5.1 we may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation. We may also transfer your personal information if we're under a duty to disclose or share it in order to comply with any legal obligation, to detect or report a crime, to enforce or apply the terms of our contracts or to protect the rights, property or safety of our visitors and customers.
6.5.2 for the purposes described in clause 184.108.40.206, we will share personal information with Reach Plc (who may share your information with companies within its group to use for the same purpose – for a list of Reach Plc’s group companies and brands, go to: https://www.reachplc.com/our-brands/)). Reach Plc will process your personal information as a separate controller and their privacy notice will apply to their use of your information, which explains more about how it uses your data, and your rights.
6.5.3 when disclosing your personal information to third parties, we will always take steps with the aim of ensuring that your privacy rights continue to be protected.
7. Where we store your personal information
7.1 All information you provide to us is stored on our secure servers which are located within the European Economic Area (EEA).
7.2 If at any time we transfer your personal information to, or store it in, countries located outside of the EEA (for example, if our hosting services provider changes) we will ensure that appropriate safeguards are in place for that transfer and storage as required by applicable law. This is because some countries outside of the EEA do not have adequate data protection laws equivalent to those in the EEA.
7.3 If you use our services whilst you are outside the EEA, your information may be transferred outside the EEA in order to provide you with those services.
8. How long we keep your information for
8.1 We will retain personal information for as long as we reasonably require it for legal or business purposes. For the unregulated jurisdictions in which we operate, and subject to us not having a legal or regulatory requirement or a risk management reason for retaining your information for a longer period, your information will not be kept for longer than 7 years post account closure. Please note that we may be required in certain circumstances to retain your information indefinitely (for example under our procedures on responsible gambling and self-exclusion). We will take all necessary steps to ensure that the privacy of information is maintained for the period of retention.
8.2 If you have signed up to receive email marketing from us we will store your personal information for as long as you are subscribed to our email list even if your account has closed. If you unsubscribe or your subscription expires because you do not interact with our marketing emails for over 7 years we will keep your email on our suppression to ensure we do not send you email.
8.3 If you have contacted us with a complaint or query we will store your personal information for as long as is reasonably required to resolve your complaint or query.
8.4 The only exceptions to the above are where:
8.4.1 we may need your personal information to establish, bring or defend legal claims or to comply with a legal or regulatory requirement;
8.4.2 the law requires us to hold your personal information for a longer period, or delete it sooner;
8.4.3 you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law (see clause 13.1.5 below); or
8.4.4 in limited cases, the law permits us to keep your personal information indefinitely provided we put certain protections in place.
8.5 When it is no longer necessary to retain your data, we will delete the personal information that we hold about you from our systems. After that time, we may aggregate the data (from which you cannot be identified) and retain it for analytical purposes.
9. Security and links to other sites
9.1 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to our website and any transmission is at your own risk. Once we have received your personal information, we put in place reasonable and appropriate controls to ensure that it remains secure against accidental or unlawful destruction, loss, alteration, or unauthorised access.
9.2 Where we have given (or where you have chosen) a password which enables you to access an account, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
9.3 Our website may contain links to other websites run by other organisations. This policy does not apply to those other websites‚ so we encourage you to read their privacy statements. We cannot be responsible for the privacy policies and practices of other websites even if you access them using links that we provide. In addition, if you linked to our website from a third party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party website and recommend that you check the policy of that third party website.
11. Our Marketing
11.1 Subject to any preferences you have expressed (where applicable), if you register an account online, via post, telephone or via the mobile app or make a sales enquiry, we use personal information to deliver marketing communications to you across various platforms. Such platforms include email, telephone, text messaging, direct mail, online, push notification or otherwise. We will do this during the period of your relationship with us and, unless specifically instructed otherwise by you, for a reasonable period of time after the relationship has ended in order to inform you about products, services, promotions and special offers which we think may be of interest to you.
11.2 From time to time, we may ask you to refresh your marketing preferences by asking you to confirm that you agree to continue receiving marketing information from us.
11.3 If you do not complete a purchase and have not indicated that you would prefer otherwise, we may send a reminder to you about your incomplete purchase.
11.4 If we send you a marketing email or SMS, it will include instructions on how to opt out of receiving these marketing communications in the future. You can also manage your information and update your marketing preferences through the "My Account" tab when you log in to thepools.com. Please allow up to 48 hours for any changes you make to your marketing preferences to be fully processed. Please remember that even if you opt out of receiving marketing emails, we may still send you important service information related to your accounts and subscriptions.
11.5 Most browsers and applications also allow you to control notifications settings. For example, when you first download our betting application on IOS, you will be asked to allow or block notifications from our application. Please refer to your browser/app settings for full details.
11.6 We may from time to time contact you with marketing information by post or by telephone or with targeted advertising delivered online through social media and platforms operated by other companies by using your personal information to tailor marketing based on your betting or gaming behaviours trends or interests to improve its relevance to you unless you object. These marketing messages will provide you with information about the products, services, active promotions or offers available to you and information about products and services provided by our selected partners and third parties.
11.7 Except where we use your personal data for marketing purposes on the basis of your prior written consent and subject to any opt out preferences you notify to us in respect of electronic direct marketing communications, we process personal data for marketing purposes as necessary for the purpose of our legitimate interests in promoting our products and services.
11.8 You have the right to withdraw your consent (opt out) at any time to our use of your personal information for marketing purposes. Please see clauses 13.1.2 and 13.1.3 below for further details on how you can do this.
12. Third party marketing and automated decisions made about you
12.2 You have the right to opt-out of our use of your personal information to provide marketing to you in any of the ways mentioned above. Please see clauses 13.1.2 and 13.1.3 for further details on how you can do this.
13. Your Rights
13.1 You have a number of rights in relation to your personal information under data protection law. In relation to certain rights, we may ask you for information to confirm your identity and, where applicable, to help us to search for your personal information. Except in rare cases, we will respond to you within one month from either (i) the date that we have confirmed your identity or (ii) where we do not need to do this because we already have this information, from the date we received your request.
13.1.1 Correcting and updating your personal information:
The accuracy of your information is important to us and we are working on ways to make it easier for you to review and correct the information that we hold about you.
In the meantime, if you change your name or address/email address, or you discover that any of the other information we hold is inaccurate or out of date, contact us using any of the details described at the end of this policy.
13.1.2 Withdrawing your consent:
Where we rely on your consent as the legal basis for processing your personal information, as set out under clause 4, you may withdraw your consent at any time by contacting us using the details at the end of this policy. If you would like to withdraw your consent to receiving any direct marketing to which you previously opted-in, you can do so using our unsubscribe tool. If you withdraw your consent, our use of your personal information before you withdraw is still lawful.
If you would like to withdraw your consent to the processing of your data for marketing purposes by any of our third party partners that you have given your consent to, you can do so at any time by contacting the relevant third party directly.
13.1.3 Objecting to our use of your personal information and automated decisions made about you:
Where we rely on your legitimate business interests as the legal basis for processing your personal information for any purpose(s), as set out under clause 4, you may object to us using your personal information for these purposes by emailing or writing to us at the address at the end of this policy. Except for the purposes for which we are sure we can continue to process your personal information, we will temporarily stop processing your personal information in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights under data protection laws, we will permanently stop using your data for those purposes. Otherwise we will provide you with our justification as to why we need to continue using your data.
You may object to us using your personal information for direct marketing purposes and we will automatically comply with your request. If you would like to do so, please use our unsubscribe tool. You may also contest a decision made about you based on automated processing by contacting our Legal Team using the contact at the end of this policy.
13.1.4 Erasing your personal information or restricting its processing:
In certain circumstances, you may ask for your personal information to be removed from our systems by emailing or writing to us at the address at the end of this policy. Unless there is a reason that the law allows us to use your personal information for longer, we will make reasonable efforts to comply with your request. You may also ask us to restrict processing your personal information where you believe it is unlawful for us to do so, you have objected to its use and our investigation is pending or you require us to keep it in connection with legal proceedings. In these situations we may only process your personal information whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company or in connection with legal proceedings.
13.1.5 Transferring your personal information in a structured data file ("data portability"):
Where we rely on your consent as the legal basis for processing your personal information or need to process it in connection with your contract, as set out under clause 4 and we process this information electronically, you may ask us to provide you with a copy of that information in a structured data file. We will provide this to you electronically in a structured, commonly used and machine readable form, such as a CSV file. You can ask us to send your personal information directly to another service provider, and we will do so if this is technically possible. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.
13.2 Complaining to the UK data protection regulator:
You have the right to complain to the Information Commissioner's Office (ICO) if you are concerned about the way we have processed your personal information. Please visit the ICO's website ICO's website for further details.
14. Changes to this policy
14.1 We may review this policy from time to time and any changes will be notified to you by posting an updated version on our website and/or by contacting you by email. Any changes will take effect 7 days after the date of our email or the date on which we post the modified terms on our website, whichever is the earlier. We recommend you regularly check for changes and review this policy whenever you visit our website. If you do not agree with any aspect of the updated policy you must immediately notify us and cease using our services.
15. Contact us
15.1 Please direct any queries about this policy or about the way we process your personal information to our Legal Team by writing to us at The Football Pools, Walton House, 55 Charnock Road, Liverpool L67 1AA, or if you would prefer to speak to us by phone, please call us on 0800 093 3013 or email us at firstname.lastname@example.org