Last updated: 14th December 2021
Interpretation and Definitions
The words of which the initial letter is capitalised have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
- Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Sport Brokers (UK) Limited, Eldon House, Penistone Road, Kirkburton, Huddersfield, West Yorkshire, England. For the purpose of the GDPR, the Company is the Data Controller.
- You or Your means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable. Under GDPR (General Data Protection Regulation), You or Your can be referred to as the Data Subject or as the User as you are the individual using the Service.
- Application means the software program provided by the Company downloaded by You on any electronic device, named SportsBroker.
- Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
- Account means a unique account created for You to access Our Service or parts of Our Service.
- Website refers to SportsBroker, accessible from sportsbroker.com
- Service refers to the Application or the Website or both.
- Country refers to: United Kingdom.
- Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analysing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors.
- Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.
- Facebook Fan Page is a public profile named 'SportsBroker' specifically created by the Company on the Facebook social network, accessible from https://www.facebook.com/SportsBrokerHQ/
- Personal Data is any information that relates to an identified or identifiable individual. For the purposes of GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.
- Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
- Device means any device that can access the Service such as a computer, a cell phone or a digital tablet.
- Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
- Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
Below You will find answers to the following frequently asked questions about how We collect, use and share Your personal information:
- What is the personal information that We collect?
- Why do We collect personal information?
- How do We collect Your personal information?
- How do We use personal information?
- With whom do We share personal information?
- How do We secure personal information?
- How do We respect Your choices about Your personal information?
- SportsBroker does not sell Your personal information under the customary definition of sale
- Whom do I contact if I have questions or concerns?
1. What is the personal information that We collect?
Depending on how You choose to interact with SportsBroker, We may collect personal information from You, for example Your name, e-mail address, billing address, phone number, debit card or bank account information, date of birth and other persistent identifiers that can be used to personally identify You. We may also collect other personal information regarding Your interaction with SportsBroker Websites and Apps, including usage information, team, competition and other sports related preferences, trading behaviour, the items that You browse, read, view and otherwise access, and Your geographic location. We do not store Your debit card or bank account information.
2. Why do We collect personal information?
We collect Your personal information in an effort to provide You with a superior customer experience, product and, as necessary, to administer Our business. It allows Us to provide You with easy access to Our products and services, with a particular focus on game related information that may be of most interest to You. For more information as to why We collect personal information, please see the section below entitled: "How do We use Your personal information?"
Your personal information also allows us to communicate with You about special offers, promotions, and other marketing programs and news that may be of interest to You, in a way that is intended to be interesting to You on a personal basis. It may also enable us to provide information that broadens Your knowledge of the SportsBroker Service and educates in a way that is intended to increase the enjoyment gained from usage of the SportsBroker Service. You always have the opportunity to unsubscribe from promotional emails by following the instructions included in each marketing email or by changing Your preferences in Your account.
3. How do We collect Your personal information?
(a) Information that You provide to us
However, there are a number of circumstances in which You may need to provide us with Your personal information.
The most common of these circumstances include:
- Creating an account in order to partake in the SportsBroker service
- Using SportsBroker Apps and Websites
- Contacting customer service
- Verifying Your account
- Entering contests
- Signing up for promotional communications
- Signing up for educational communications
For Your convenience, We have provided a summary description of each of these circumstances below:
Creating an account in order to partake in the SportsBroker service
Using SportsBroker Websites and Apps
SportsBroker Websites and Apps may provide You with the ability to enter (either directly, or by authorising SportsBroker to access the information from a third party such as a social networking site or application) certain information such as Your personal preferences around sports including types of sports, sports competitions, teams, players and team staff in order for Us to tailor the SportsBroker experience to Your personal tastes.
Contacting Customer Service
When You contact customer service, We may ask You to provide, or confirm, personal information so that We can ensure Your account security, Our legal obligations and also to better serve You.
If You enter a contest We offer, We may ask You to provide personal information so that We can consider Your entry and, if You win, so that You may redeem Your prize.
Signing up for promotional communications
If You sign up to receive promotional communications or notifications from Us, We may ask You to provide personal information so that We can provide these to You.
(b) Information automatically collected
There are circumstances in which We automatically receive and collect information from You. The most common sources of this information include:
- Web server logs
- Pixel tags or clear GIFs
- Third party web analytics services
- Targeted advertising
- Email Marketing
- Customer Relationship Management
- Facebook Fan Page
- Facebook Insights
- Your Device or Apps You use
- Geolocation, including general and precise location information
- Social media sites
- Business partners, contractors, and other third parties
For Your convenience, We have provided a summary description of each of these circumstances below:
Web server logs
When You visit a SportsBroker App or Website, Our web servers may automatically log information that Your browser sends us. For example, We may receive and collect: the name of the domain and host from which You access the Internet; the Internet Protocol (IP) address of the computer You are Using; the date and time You access the SportsBroker App or Website; and the Internet address of the website from which You linked directly to the SportsBroker Website. We may also collect information regarding search queries run on the SportsBroker Website. We use this information to monitor the usage of the SportsBroker Apps and Websites and as necessary for Our business.
Browsers are typically set to create cookies automatically though under data protection regulations upon first use of a site You must decide how Your browser handles cookies for that particular site. You can also choose to have Your browser notify You when cookies are being written to Your computer or accessed, or You can disable cookies entirely.
Pixel tags or clear GIFs
We may use sensing technologies that Use pixel tags or clear GIFs (which are also called web beacons). These technologies allow Us to determine the effectiveness of Our e-mail and advertising and marketing efforts. For this purpose, We tie the pixel tags and clear GIFs to personally identifiable information. We may also collect information regarding the links within such marketing materials that You click on to enable Us to understand the effectiveness of Our marketing efforts.
Third party web analytics services
We work with third party service providers, including but not limited to Google Analytics, Google Tag Manager, MixPanel and AppsFlyer to help us better understand how You use the SportsBroker App and Websites.
These third party service providers will place cookies in Your browser to collect information such as how You were referred to the SportsBroker App or Website, how You navigate around the SportsBroker App or Website, what You purchase and what traffic is driven by various marketing methods. This information will help Us to better serve You and provide You with more personalised information and product offerings.
We do not allow third party service providers to collect Your debit card information, e-mail address, or password information. These third party service providers may only use Your personal information to perform services for Us and may not share Your personal information with anyone else, or use it for any other purpose, except on an aggregated, non-personally identifiable basis.
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of Our Service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network.
Google Tag Manager is an enterprise-grade tag management solution for efficient analytics. It supports third party analytics and offers advanced tag management technologies that enables us to better understand the usage of Our product and website.
MixPanel is provided by MixPanel Inc.
You can prevent MixPanel from using Your information for analytics purposes by opting-out. To exercise Your choice with respect to their collection of information on SportsBroker please visit this page: https://mixpanel.com/optout/
AppsFlyer is provided by AppsFlyer Ltd.
You can prevent AppsFlyer from using Your information collected from Your specific device for analytics purposes by opting-out. To exercise Your choice with respect to their collection of information on SportsBroker from Your device please visit this page: https://www.appsflyer.com/legal/opt-out/
We use Facebook Custom Audiences to deliver targeted advertisements to individuals who visit or use Our Apps and Websites.
We use Google Ads to deliver targeted advertisements to individuals who visit or use Our Apps and Websites.
You may see these advertisements on SportsBroker Websites and third party apps and websites, and across different devices You use. We may use this process to help Us manage and improve the effectiveness of Our marketing efforts. If you would like to learn more about the third party advertisers that may be aware of the fact that you visit SportsBroker Websites or use Our Apps, and to understand Your opt-out choices, please visit the website of The European Advertising Industry here. Please note this does not opt You out of being served all advertising. You will continue to receive generic ads.
We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. If You receive marketing communications via email it is because You have opted-in to do so. SportsBroker operates a strict double opt-in policy. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us via Our customer service chat in-app.
We may use Email Marketing Service Providers to manage and send emails to You.
dotdigital is an email marketing sending service provided by dotdigital EMEA Limited (company number: 03762341) whose registered office is at No. 1 London Bridge, London, SE1 9BG.
Customer Relationship Management
We use MixPanel and Zendesk to manage Our relationships with Our customers.
Facebook Fan Page
The Company has entered into agreements with Facebook that define the terms for use of the Facebook Fan Page, among other things. These terms are mostly based on the Facebook Terms of Service: https://www.facebook.com/terms.php
Data Controller for the Facebook Fan Page
The Company is the Data Controller of Your Personal Data collected while using the Service. As operator of the Facebook Fan Page https://www.facebook.com/SportsBrokerHQ/, the Company and the operator of the social network Facebook are Joint Controllers.
We use the Facebook Insights function in connection with the operation of the Facebook Fan Page and on the basis of the GDPR, in order to obtain anonymized statistical data about Our users.
For this purpose, Facebook places a Cookie on the device of the user visiting Our Facebook Fan Page. Each Cookie contains a unique identifier code and remains active for a period of two years, except when it is deleted before the end of this period.
Facebook receives, records and processes the information stored in the Cookie, especially when the user visits the Facebook services, services that are provided by other members of the Facebook Fan Page and services by other companies that use Facebook services.
Your Apps or Devices you use
When You use Our Apps with a device, We automatically collect information through the App or Device when it is connected to the Internet. For example, We may receive and collect information concerning device registration, operating system, settings, usage, firmware version, signal strength, search queries, network interaction, the name of the network from which You access the Internet, the Internet Protocol (IP) address of the device you are using, unique device identifiers (UDIDs), downloads, sideloaded content, configuration, or service information relating to any malfunction of the App or Device. This may include information regarding Your activity on such Apps or Devices, such as virtual shares traded, pages opened, date and time of use, time elapsed, matches monitored, completed transactions, incomplete transactions, actions taken etc.
In addition, to provide location-based services on Devices or through Apps, SportsBroker and third party application providers may automatically collect real-time geographic location information or other location-based information about You and Your Device or other mobile device on which the App is installed. This information may be used to ensure We operate within the law according to Your location, provide certain device or application functionality or to offer, provide and improve products and services.
Business partners, contractors, and other third parties
We may collect personal information and other information about You from business partners, contractors and other third parties. This includes, but is not limited to, instances in which You affirmatively authorise third parties to provide Us with information. Such information may be collected via, but not limited to, software applications that you download or Use on Your Device or that otherwise allow You to interact with the SportsBroker enterprise.
4. How do We use Your personal information?
SportsBroker uses Your personal information across Our enterprise to provide You with a superior customer experience and, as necessary, to administer Our businesses. For example, We use Your personal information to:
- Provide you with products, services and information across the SportsBroker enterprise, through emails from our businesses, and on the SportsBroker Websites and online interactive communities, Your Devices, Digital Content, Apps and software;
- Administer Our programs;
- To protect against deceptive and fraudulent activity;
- Provide customer service online;
- Conduct research and perform analysis in order to measure, maintain, protect, develop and improve Our products and services;
- Administer contests, promotions or surveys and provide appropriate notifications;
- Communicate with you about special offers, events, or new products or services that may be of interest to you;
- Customise and enhance the SportsBroker Websites and advertising;
- Make communications necessary to notify you regarding security, privacy, and administrative issues; and
- Manage Our business.
5. With whom do We share personal information?
Protecting the privacy and security of Your personal information is a priority at SportsBroker. SportsBroker shares your personal information with:
- Other entities within the SportsBroker enterprise. SportsBroker owns and operates other operations and businesses and We may share Your personal information with Our other business units and operations, even if such business units or operations are sold.
- Service providers, subcontractors and agents who perform services on Our behalf. We provide personal information to third party service providers, subcontractors, and agents that work under contract on Our behalf to provide certain services. These third parties do not have the right to use personal information We provide to them in any way that is not authorised by SportsBroker. They are contractually obligated to use such information only as necessary to assist Us and to maintain the confidentiality and security of such information.
- Third party affiliate programs. We work with certain third party entities to help them administer their own affiliate programs by providing them with purchasing information about their customers who make purchases from SportsBroker. We disclose only the information that is necessary to make these third party programs work. This information is in the form of an anonymised key and includes the sum total of the purchases made at SportsBroker. We require such entities to obtain Your consent before We provide them with this information, which they usually do as part of their own process.
- Payment processing companies. Debit card transactions are handled by third party financial institutions and their vendors and contractors who receive debit card numbers and other personal information from Us to verify the debit card numbers and process transactions. Although SportsBroker's treatment of this information is governed by this policy, the use of Your information by the third party financial institutions and their vendors and contractors will be subject to their own privacy policies.
- Law enforcement officials and as required by law. SportsBroker may release personal information to third parties when We determine, in Our judgment, and without Your consent, that it is necessary to (a) comply with the law, regulation, legal process, or enforceable governmental request; (b) enforce or apply the terms of any of Our policies or user agreements; (c) establish or exercise Our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of Our policies, (d) protect the rights, property or safety of SportsBroker, Our employees, Our customers, users, or others; or (e) to comply with Your request for the provision of services by a third party intermediary.
- Your Consent. We may ask if You would like us to share your information with other unaffiliated third parties who are not described elsewhere in this policy.
6. How do We protect personal information?
No method of transmission over the Internet, or method of electronic storage, is fully secure. While We use reasonable efforts to protect Your personal information from unauthorised access, use, or disclosure, We cannot guarantee the security of Your personal information. In the event that We are required by law to inform You of a breach to Your personal information We may notify you electronically, in writing, or by telephone, if permitted to do so by law.
Some of Our websites permit you to create a SportsBroker account. When You do You will be prompted to create a password. You are responsible for maintaining the confidentiality of Your password, and You are responsible for any access to or use of Your account by someone else that has obtained Your password, whether or not such access or use has been authorised by You. You should notify us immediately of any unauthorised use of Your password or account.
7. How do We respect Your choices about Your personal information?
You may choose to opt out from receiving marketing and promotional communications from SportsBroker at any time by following the instructions below.
- For SportsBroker Customers: At any time, You may choose to opt-out of the receipt of any promotional communications by clicking on the opt-out link provided at the bottom of each email and following the instructions.
Even if You opt-out of receiving promotional communications, you may continue to receive emails and notifications relating to order confirmations, back order notifications, membership information, and/or other business-related communications; these are classed as transactional communications and will not contain promotional or marketing materials.
8. SportsBroker does not sell Your personal information under the customary definition of sale.
We do not provide Your name, phone number, address, email address or other personally identifiable information to third parties in exchange for money.
Analytics & Targeted Advertising
You may choose to opt out of the collection of automatically collected information, including cookies, Google Analytics, MixPanel, ApssFlyer and targeted advertising, by following the instructions given in Section 3(b) above, or by using the functionality in Your browser to reject cookies.
Accessing, correcting and deleting Your information
You may have the right under Your jurisdiction's data protection law to the following with respect to some or all of Your personal information:
To request access to Your personal information (including under Article 15 of the General Data Protection Regulation ("GDPR"));
To request that We rectify or erase Your personal information (including under GDPR Articles 16 and 17);
To request that We restrict or block the processing of Your personal information (including under GDPR Articles 21 and 22);
To provide Your personal information directly to another, i.e., a right to data portability (including under GDPR Article 20); and
When We previously obtained Your consent, to withdraw consent to processing (including under GDPR Article 21).
If required by law We will grant a request to delete information, but You should note that in many situations We must keep some of Your personal information to comply with Our legal obligations, resolve disputes, or for another one of Our non-commercial business purposes.
Please address written requests for any of the above and questions about Your rights to email@example.com.
Note that, as required by law, We will require You to prove Your identity. We may conduct an identity verification by email. Depending on Your request, We will ask for information such as Your name, date of birth and for a copy of photo identification in the form of a driver's license or passport. Following a request, We will use reasonable efforts to supply, correct or delete personal information about You in Our files.
9. Whom do I contact if I have questions or concerns?
Policies for Minors, those aged under 18
SportsBroker operates a strict 18 or over policy to sign-up and create a SportsBroker account.
If You are a parent or guardian who believes that Your Minor under the age of 18 has submitted personal information or other information to Us without Your consent, please contact firstname.lastname@example.org. Once We verify that You are the parent or legal guardian, at Your request, We will promptly provide to You information regarding what, if any, personal information We have collected about Your child and how it has been used or shared. We will, at Your request, remove personal information about Your child from Our database and instruct any affiliates and third party partners to do the same.
Data retention policy
We will retain Your information for as long as Your account is active or as needed to provide You with services. We will retain and use Your information as necessary to comply with Our legal obligations, resolve disputes, and enforce Our agreements.
You may use an authorised agent to submit a request to access Your information, delete Your information, or opt out of the sale of Your information. To designate an agent for these purposes:
- You must provide us with a copy of a written and signed permission given to Your authorised agent; and
- You must verify Your own identity directly with Us.
Do Not Track Disclosure
Important information about third party devices, ISPs, websites and applications
If you are concerned about how Your personal information is used, please email us at email@example.com or contact us via Our customer support in-app. You may also have the right to lodge a complaint against us. To do so, contact Your local data protection authority.
By doing business or interacting with SportsBroker, you are consenting to the transfer, storage, and processing of Your personal information to and within facilities located in the United Kingdom, the European Union and other facility locations selected by SportsBroker.