What does this notice cover?
The Wager application (the "App") is the official app of the peer-to-peer sports betting exchange operated by Cato Partners Limited (“Operator”, “we” or “us”). This notice describes how we will make use of your data when you’re enjoying our App or our website (“platform”). It gives you more information on:
● Data we collect
● Data we receive from third parties
● How we use such data
● How we share such data
● How we store such data
● Your rights
● Who you can contact
● How long we retain your data
● How we manage cookie
What information do we collect?
We collect and process your personal data when you enjoy our platform. This includes:
● Sign-up information. Location*, title*, first name*, surname*, date of birth*, email address*, phone number*, username*, password* and / or numerical PIN*, security question, security answer, country of residence*, address*
● Betting preferences. Deposit limits, Time outs, Self exclusion
● Statistics. Average odds, win percentage, betting form
● Payment information. Amounts*, payment method, and credit card details
● Marketing information. Marketing preferences*, including any consents you have given us
● Technical information. Information related to the device or the browser you use to access our platform*
● Mobile Identifiers. When you are using our mobile application, we may also automatically record your Google Advertising ID (if you are using an Android device) or your Advertising Identifier (IDFA – if you are using an iOS device; together with the Google Advertising ID – "Mobile Advertising IDs"), for advertising or analytics purposes. The Google Advertising ID is an anonymous identifier, provided by Google Play services. If your device has an Advertising ID, we may collect and use it for advertising and user analytics purposes. If your device does not have Advertising ID, we may use other persistent identifiers. The information collected may be also stored on your device. Please see below how you can reset you mobile Advertising ID or opt-out of receiving targeted ads through your mobile Advertising IDs.
Some of the above data are mandatory for legal reasons or to satisfy our Terms and Conditions, without them it will not be possible to access our services. Mandatory data are marked with an asterisk. All other data are optional.
How we collect the information
Mobile Device Opt-Out - you may opt out of receiving targeted ads on mobile devices using the Android operating system, by using platform level controls enabled through your device settings. You should consult your device settings and instructions provided by your device manufacturer. However, we provide the following information solely for informational purposes.
If you have an Apple device, you can opt out of targeted advertising by updating to iOS 6.0 or higher, and setting "Limit Ad Tracking" to "ON". You can do this by clicking on Settings -> Privacy -> Advertising, and toggling "Limit Ad Tracking" to "ON". This prevents apps that you use from using your Apple device’s Advertising Identifier to serve you targeted ads. In addition, or as an alternative, you may reset your device’s Advertising Identifier, which will result in your device being disassociated from ad targeting profiles based on the Advertising Identifier in effect prior to reset. You can do this by clicking on Settings -> Privacy -> Advertising -> Reset Advertising Identifier. Again, you should consult Apple’s support web pages and instructions for the most current applicable settings.
If you have an Android device, you can opt out of targeted advertising on your device. You can do this by clicking the menu icon to display the apps list, then find and select the Google Settings icon, then find and select "Ads" and check the box "Opt out of interest-based ads". In addition, or as an alternative, you may reset your device’s Android advertising ID, which will result in your device being disassociated from ad targeting profiles based on the Android advertising ID in effect prior to reset. You can do this by clicking the menu icon to display the apps list, then find and select the Google Settings icon, then find and select "Ads" and selecting "Reset advertising ID". Note that Android settings menus may vary among device manufacturers and these instructions may not be accurate for your device. You should consult Google’s settings and instructions for the most current settings information.
What information do we receive from third parties?
Sometimes, we receive information about you from third parties:
Information from other sources: We may also collect and combine information we receive online with other information, including usage information from online advertising. We also supplement or combine data with information from a variety of other sources or outside records, including third-party data providers that provide us with personal data to comply with our legal and regulatory obligations including KYC requirements. We use that combined information in accordance with this privacy notice.
Social media: When you interact with us or content through social media, we receive information from your interaction with our content (e.g., content viewed, and information about advertisements you have been shown or have clicked on). By interacting with our sites through social media, you consent to our use of data from the social media in accordance with this privacy notice.
How do we use this information?
We process your personal data for the following purposes and related reasons:
1. Registration setting and service enjoyment
Registration setting and service enjoyment. We use your personal data to enable you to create and administer your user account and to enjoy our platform. When you provide a credit or debit card as payment, we use third parties to check the validity of the sort code, account number and card number you submit in order to prevent fraud
Fulfilling contractual obligations
Our legitimate interests:
- Improving and developing new products and services
- Being more efficient
- Fighting fraud
- Retaining your betting preferences and statistics to make suggestions to you for other services which we believe you will also be interested in
2. Communicating with you and others
We use personal data to communicate with you, e.g. to notify you when you win a bet, to respond to your inquiries, to contact you about your account, or to send you information about promotions, offerings, and our features by email, SMS, online ads, push notification.
Please see our instructions to opt out receiving marketing communication below.
We use your data when you interact with social media features to serve you with advertisements and engage with you on social media. You can learn more about how these features work, what kind of data we obtain about you, and find out how to opt out by reviewing the privacy notices of the relevant social media.
With your prior consent (where required)
Our legitimate interest:
o Communicating important information
o Improving and developing new products and services
o Being more efficient
3. Improving your journey
We monitor our platform, and use your information to help us monitor, improve and protect our content, services and platform.
We also use information you provide to personalise our platform and services for you.
We use data of some individuals to invite them to take part in market research or surveys.
- Retaining and evaluating information on your recent visits to our platform, your betting activity and how you move around for analytics purposes in order to understand how you use our platform so that we can make it more intuitive
- Defining types of customers for new products or services
- Developing a profile of you and your interactions with us so that we can provide tailored offers, opportunities and services that may be of interest to you
We could use personal data we collect to detect, investigate, and prevent activities that may violate our Terms and Conditions or that could be fraudulent, violate gambling legislation or that may be otherwise illegal.
We also use personal data to comply with legal requirements. For instance, we collect and analyse your age, your location and you betting activity to ensure that we can provide you with our services and we use third parties to check the accuracy of your account details.
Following the above, we will use data in connection with legal claims, compliance, regulatory and investigative purposes as necessary including disclosure of such information in connection with legal process or litigation.
- Protecting our business interests and rights, privacy, safety and property, or that of the public
- Sharing your information with third parties in order to allow us to pursue available remedies or limit damage that we may sustain
Who will we share this data with, where and when?
With your consent. We may share your personal data when you provide us with your consent to do so.
Service providers. Personal data will also be shared with third party service providers, who will process it on behalf of us for the purposes identified above. In particular, we use third party providers of hosting, product development and maintenance, payment, match and odds data, user analysis, marketing and identity checking.
Other users. The following data are shared on your user page with all other users: picture, name, username, win %, average odds, and recent betting activity e.g. their last 5 bets. Please note that financial information relating to bet will never be made public or shared with other users.
Law enforcement officials. Personal data may be shared with government authorities, regulators and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable laws.
Change of control. In the event that the business is sold or integrated with another business, your details will be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new owners of the business.
Affiliates and other third parties. We share personal data we collect with our affiliates and related companies to provide, offer, market, and otherwise communicate with you about their own products and services but also for compliance, registration and management purposes.
Where is your Personal data stored?
Some of our service providers process your data for us outside the EEA. where data protection and privacy regulations will not offer the same level of protection as in other parts of the world, such as the European Union. Where information is transferred outside the EEA, and where this is to a service provider in a country that is not subject to an adequacy decision by the EU Commission, data is adequately protected by EU Commission approved standard contractual clauses, an appropriate Privacy Shield certification or a Processor Binding Corporate Rules. A copy of the relevant mechanism can be provided for your review on request to us.
What rights do I have?
You have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share (port) this data to another controller.
In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).
You have the right to appeal the result of our KYC checks if you were not successful. This should be done by emailing us within [3 working days] from the date of the refusal. We or our KYC partner will manually review your details and confirm whether the original automated assessment should be upheld.
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law or regulation to keep or have compelling legitimate interests in keeping (for example, self-exclusion data). Relevant exemptions are included in both the GDPR and in the Data Protection Act 2018. We will inform you of relevant exemptions we rely upon when responding to any request you make.
To exercise any of these rights, you can get in touch with us – or our data protection officer – using the details set out below. If you have unresolved concerns, you have the right to complain to your local protection authority. This is likely to be the Information Commissioner’s Office in the UK.
Withdrawing consent and opt-out of receiving marketing communications.
Where we have asked for your consent to process your personal data, you have the right to withdraw this consent at any time.
You can opt-out of direct marketing or profiling we carry out for direct marketing, at any time. You can do this by following instructions included in our marketing communications, by managing your preference here or by contacting us using the details set out below.
By opening an account, you agree to be contacted about regulatory, compliance and legal issues
How do I get in touch with you or your data protection officer?
We hope that we can satisfy queries you may have about the way we process your data. If you have any concerns about how we process your data, or would like to opt out of direct marketing, you can get in touch at firstname.lastname@example.org or by writing to Unit 2, 124 East Road, London, N1 6FD. You can also get in touch with Wager’s data protection officer at email@example.com or by writing to Unit 2, 124 East Road, London, N1 6FD.
Who is the data controller?
The Wager data controller is Cato Partners Limited registered in England and Wales under company number 11583047 and having its registered office at Unit 2, 124 East Road, London, England, N1 6FD.
How long will you retain my data?
Where we process registration data, we do this for as long as you are an active user of our platform and for 6 years after this.
Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data so that we can respect your request in future.
Where we process personal data in connection with performing a contract, we keep the data for 6 years from your last interaction with us.
We retain information needed to respect requirements around self-exclusion for the duration of the self-exclusion period you will instruct us to apply. We will apply an additional seven years period at the end of the defined exclusion period unless you tell us otherwise.
What does it mean?
During your use of our platform, Cookies may be installed on your device, in particular on your computer, tablet or smartphone.
Which Cookies are used?
We use different types of Cookies on our platform (App and website):
They are essential in order to enable you to move around our platform and use its features, such as accessing secure areas. Without them, services like enabling appropriate content based on your type of device cannot be provided.
Functionality Cookies: They allow our platform to remember choices you make (such as your user name, or the region you are in) and provide enhanced, more personal features.
Performance Cookies: We use user behavioural tracking to create user journey and funnels. Technically we’re tracking every screen interaction you make so we can create user journeys and funnels. They allow us to analyse traffic, trends, use and identify any bug. They help us to improve your experience as well as the design and content of our platform.
Advertising Cookies: Our platform may use a third-party advertising network, to deliver targeted advertising. They may also have the capability to track your browsing across sites, apps and social media.
Social Media Cookies: They are used when you share information using a social media sharing button or “like” button on our platform, or when you engage with our content on or through a social media site such as Facebook. The social network will record that you have done this. This information may be linked to targeting/advertising activities.
Cookies consent management solution
The first time you visit our platform, a notice informs you of the presence of these Cookies and you are invited to state your preferences. You can also manage Cookies at any time.
Notification regarding updates
We may revise this Privacy Notice at any time by posting an amended version on our platform. If we update the terms of this Privacy Notice, the updated terms will apply to each of your uses of the platform from that point on. Some of the provisions contained in this Privacy Notice may also be superseded by provisions or notices published elsewhere on the platform. We will use reasonable efforts to ensure that any important changes will be notified to you by an appropriate method, such as a notice on the App. However, it is your responsibility to check the Privacy Notice regularly to take notice of any changes we make, and you agree to do so.
Please contact firstname.lastname@example.org for any further information
Wager is the trading name of Cato Partners Limited of 124 East Road, London N1 6FD