SPREADEX PRIVACY POLICY
Version: 2.1
Effective Date: 10th September 2018
Date of Last Revision: 7th September 2018
The data controller
Spreadex Limited (a company registered in England and Wales with company number 03720378 and whose registered office is Churchill House, Upper Marlborough Road, St Albans, AL1 3UU). Contact Details dpo@spreadex.com. 01727 895 000.
We are a financial spread betting, sports spread betting, sports fixed odds betting and online casino firm.
We are committed to protecting the privacy of our clients and we do not sell your data to third parties. We want to provide a safe and secure service where we deal with your personal information. This means information that identifies you personally such as your name, photo or contact details or data that can be linked with such information in order to identify you.
Quick Guide to Contents
- What personal information do we collect about you?
- How do we use your personal information?
- How long do we keep your personal information for?
- Who do we share your personal information with?
- What happens if you do not provide us with the information we request?
- Do we make automated decisions concerning you?
- Do we transfer your personal information outside the EEA?
- Setting your marketing Preferences
- What are your rights?
- How do we contact you?
- How do you contact us?
- How to make a complaint
What personal information do we collect about you?
We collect and process your information in the following ways:
Information you give us
- Your name, address and contact details
- Your date of birth and gender
- Information about your income, wealth and tax status
- Your employment
- Your national insurance number
- Location data
- Any other similar information or information provided by you
We may ask you for further information occasionally, for example in a customer survey. These requests are voluntary but if you request a product or service that requires further information, you will be required to provide this information before we can provide access to it
Information we collect automatically
- Your IP
- Products you trade and performance
- Historical data about your bets including the amounts you withdraw and deposit
- Your device ID, hardware model, operating system and version, language, serial number, location data and mobile network
- Your preferences for different types of products and services
- All communications made electronically or by telephone
Information we receive from third parties
- Either through paid for third-party marketing lists, public sources or through our refer-a-friend scheme
- Data from Experian on your credit history and score
- Publically available information such as social media, property ownership, electoral roll, annual returns for companies, industry bodies and insolvency registers and others
- Gamstop National Self Exclusion Scheme
How do we use your personal information?
To provide a requested service or carry out a contract with you.
- To verify your identity
- To establish and manage your account
- To provide you with products and services
- To provide you with information about our products and services
- To assess your needs
- For internal business purposes and record keeping
Where we have your consent
- If you have provided answers to a customer survey or live chat
- For marketing by us (to prospective clients)
Where we have a legitimate interest
- To verify your identity
- To establish and manage your account
- To assess your needs
- To enable us to improve our products and services
- To develop and market new products and services
- To protect our commercial interests
- To form a profile
- To investigate inquiries or disputes
- To provide references about you
- To send you surveys
- For data analysis such as counting web page visits and cookie tracking to make sure our product and services we provide are relevant
- For marketing by us (based on a soft opt-in) including after a short period after your account has closed
- For internal business purposes and record keeping
- To disclose your data for due diligence in the event of a restructure or acquisition
Where we have a legal obligation
- To verify your identity
- To form a profile
- To comply with applicable law, court order, other judicial process, or the requirements of any applicable regulatory authorities
- To provide references about you
- For internal business purposes and record keeping
How long do we keep your personal information for?
We keep your information for the following periods as long as reasonably needed for legal or business purposes.
Clients: 6 years after closure of your account
Prospective clients: 1 year after submitting details
In certain circumstances, we may need to hold on to your data indefinitely. For example, if a regulator has requested that we retain your data for the purpose of an investigation or to meet our obligations under responsible gambling and self-exclusion.
We will take care to ensure the privacy of your data during the retention period.
WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?
We share your personal information with trusted third parties where we have retained them to provide services that you or our clients have requested, such as Mastercard to provide payments. These third parties comply with similar and equally stringent undertakings of privacy and confidentiality.
We share your personal information with third parties who perform functions on our behalf and who also provide services to us, such as professional advisors, IT consultants carrying out testing and development work on our business technology systems, research and mailing houses and function co-ordinators. These third parties comply with similar and equally stringent undertakings of privacy and confidentiality.
Where required we share your personal information with third parties to comply with a legal obligation; when we believe in good faith that an applicable law requires it; at the request of governmental authorities conducting an investigation; to verify or enforce our Customer Agreement or other applicable policies; to detect and protect against fraud, or any technical or security vulnerabilities; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of third parties, visitors to the our website, our business or the public.
CREDIT REFERENCE AGENCY NOTICE:
In order to process your application, we will supply your personal information to credit reference agencies (CRAs) and they will give us information about you, such as about your financial history. We do this to assess creditworthiness and product suitability, check your identity, manage your account, trace and recover debts and prevent criminal activity.
We will also continue to exchange information about you with CRAs on an ongoing basis, including about your settled accounts and any debts not fully repaid on time. CRAs will share your information with other organisations. Your data will also be linked to the data of your spouse, any joint applicants or other financial associates.
The identities of the CRAs, and the ways in which they use and share personal information are explained in more detail here.
WHAT HAPPENS IF YOU DO NOT PROVIDE US WITH THE INFORMATION WE REQUEST OR ASK THAT WE STOP PROCESSING YOUR INFORMATION?
If you do not provide the personal information necessary, or withdraw your consent for the processing of your personal information, where this information is necessary for us to provide services to you, we will not be able to provide these services to you.
DO WE MAKE AUTOMATED DECISIONS CONCERNING YOU?
No, we do not carry out automated decision making.
DO WE USE COOKIES TO COLLECT PERSONAL DATA ON YOU?
To provide better service to you on our websites, we use cookies to collect your personal data when you browse. See our cookie policy here for more details.
DO WE TRANSFER YOUR PERSONAL INFORMATION OUTSIDE THE EEA?
We may transfer your personal information to processors engaged on our behalf outside the European Economic Area. We ensure that there are appropriate safeguards in place and the transfer is lawful.
TAWK.TO LIVE CHAT
Tawk.to, our live chat provider, complies with the data protection requirements of the EU-US Privacy Shield and is registered with the Information Commissioner’s Office (ICO) in the UK.
Marketing Preferences
We want you to be in control of the ways we contact you.
As we set our campaigns in advance, once you have unsubscribed it may take 7 days for it to be actioned.
Emails: To unsubscribe from marketing emails you can click the unsubscribe link in each marketing email we send.
Texts: To unsubscribe from marketing text messages you are able to reply to a free number with a shortcode.
Phone: To prevent further marketing phone calls, please let our operator know and we will stop any further marketing phone calls.
Push Notifications: You are able to disable push notifications from Spreadex on your device or in the settings section of our app.
Mail: To prevent further marketing mailings please get in touch with our customer service team.
What are your rights?
By law, you have a number of rights when it comes to your personal information. Further information and advice about your rights can be obtained from the data protection regulator in your country.
The right to object to Processing
You have the right to object to certain types of processing, including processing for direct marketing (i.e. if you no longer want to be contacted with potential opportunities).
The right to be informed
You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Policy.
The right of access
You have the right to obtain access to your information (if we’re processing it), and certain other information (similar to that provided in this Privacy Policy).
This is so you’re aware and can check that we’re using your information in accordance with data protection law.
The right to rectification
You are entitled to have your information corrected if it’s inaccurate or incomplete.
The right to erasure
This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.
The right to restrict processing
You have rights to ‘block’ or suppress the further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.
The right to data portability
You have rights to obtain and reuse your personal information for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability.
The right to lodge a complaint
You have the right to lodge a complaint about the way we handle or process your personal information with your national data protection regulator.
The right to withdraw consent
If you have given your consent to anything we do with your personal information, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal information with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal information for marketing purposes.
We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for baseless or excessive/repeated requests and/or further copies of the same information.
Alternatively, we may be entitled to refuse to act on the request.
Please consider your request responsibly before submitting it. We’ll respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we’ll come back to you and let you know.
How will we contact you?
We may contact you by phone or email. If you prefer a particular contact means over another please just let us know.
How can you contact us?
If you have any enquiries you can contact us at dpo@spreadex.com.
Alternatively, you can contact us by post:
Data Protection
Spreadex
Churchill House
Upper Marlborough Road
St Albans, Hertfordshire
AL1 3UU
Make a complaint
Please contact our data protection team using the contact details below.
If you are not satisfied with our response, you have the right to raise a complaint with the Information Commissioner’s Office (ICO).
Please visit https://www.ico.org.uk/concerns to find out more.
Changes to our privacy policy
We keep our privacy policy under regular review and we will place any updates on this page. This privacy policy was last updated on 25th April 2018.
