FairPlay Privacy Policy

We inform you that by accessing our Website you become a User. As a User, you declare that you are of legal age and that you have the necessary legal capacity to understand and accept in its entirety this Privacy Policy. This Privacy Policy should be read in conjunction with our Cookies Policy and the Terms and Conditions that regulate the gaming contract between FairPlay and the User.

We hope you enjoy your experience at FairPlay.

WHO ARE WE?

FairPlay club is managed by FPO Gambling Ltd, based in Malta. For any questions related to your personal data and the protection of data in general you can contact the Delegate of Data Protection of Sportium through the e-mail [email protected].

WHAT IS PERSONAL DATA AND PROCESSING?

Personal data is data that identifies or allows the identification of an individual. For example, the data that can identify a person is the first and last name, while the ID number can identify the person. Personal data includes information such as cell phone number, e-mail address, and date of birth, among others. It may also include numerical identifiers such as the IP address of your computer, as well as information obtained through cookies.

Personal data processing is any operation or set of operations that we perform on your personal data, such as, for example, the collection, recording, storage, use, and communication of your data.

WHAT KIND OF INFORMATION DO WE COLLECT?

In order to enjoy our gaming and betting services, we need information about you. The information we collect through our Website is: first and last name, gender, date of birth, nationality, ID number, city, address, zip code, state, cell phone number, email address, user name, transaction history, and game history. Also, in order to enable withdrawals, it is necessary that you provide us with a photograph of your ID card, your credit card or bank receipt if you have deposited by bank transfer, and other documentation required for the withdrawal method you use, as described in the “Payment Methods” section of the Website.

In order to verify the geographic scope of connection of the users, FairPlay also collects data related to the IP of the users. Likewise, FairPlay collects data on navigation and use of the Web Site through tools that may allow your monitoring. You can consult our Cookies Policy.

HOW DO WE PROCESS YOUR PERSONAL DATA AND WHAT RIGHTS CAN YOU EXERCISE?

We want to be transparent with you and inform you about the purposes for which we process your data. As there is a gaming agreement between us, it is necessary for you to know that your personal information is used to fulfill the following main obligations arising from that agreement:

1. To provide you with gaming and betting services.
2. To carry out appropriate investigations necessary to comply with our legal and regulatory obligations which include complying with (to the extent possible):

• The requirements and demands of any applicable gaming and wagering laws;
• The recommendations or guidance of any relevant regulatory body;
• The requirements of applicable legislation to combat money laundering, fraud, terrorist financing, bribery, corruption, and tax evasion;
• Any other laws, regulations, circulars, notices, or demands that might otherwise apply; and/or
• To carry out appropriate and necessary investigations, to ensure compliance with our regulated gambling responsibilities, in respect of self-excluded or vulnerable customers.

FairPlay not only processes your data for compliance with contractual and legal obligations but also carries out specific processing that you should be aware of. The data protection regulations require that for the processing of your data we have a basis that legitimizes such processing. Thus, in order to process your personal information we rely on different legal bases depending on the activity or processing that we carry out with your data. 

Your Consent

We may send commercial communications via SMS, email, telephone, or notifications in the case of the Fairplay App, about promotions that may be of interest to you, advantages, etc. Such sending of commercial communications will only be carried out provided that you have previously consented to the processing of your personal data for this purpose. In any case, we inform you that you can withdraw your consent and, therefore, oppose receiving commercial communications at any time in a simple way.

Our Legitimate Interest

We have a legitimate interest in collecting your personal data as it provides us with the information necessary to improve your online gaming experience more effectively. In any case, this legitimate interest is based on an analysis of the appropriate balance of our interests in processing your personal data and your rights and freedoms. The result of this analysis will determine whether or not we can use your personal information for the processing described in this Privacy Policy, except for the processing of segmentation and profiling for sending commercial communications, for which we require your express consent.

The execution of the contract

At the moment you expressly accept our Terms and Conditions you become a party to the gaming contract entered into with us. In order for us to be able to fulfill our obligations under these Terms and Conditions, we need to collect and process your personal data.

Compliance with a legal obligation

FairPlay as a gaming operator acts as a data controller and therefore we must comply with a number of obligations imposed by gaming, fraud prevention, and money laundering regulations. In particular, we need to process your personal information to verify your identity, check your age and the origin of your funds for the purpose of preventing and combating fraud and money laundering, and block gaming accounts, among others. 

Thus, in those cases in which the legal justification for any of our processing is the fulfillment of a legal obligation, your refusal to provide us with those personal data that are legally required will make it impossible for you to enjoy the service we offer since doing so would entail a breach of the regulations to which we are subject.

How long do we keep your personal data?

FairPlay is subject to compliance with legal obligations of various kinds that require the retention of information provided by users during the contractual relationship for certain periods of time (in some cases up to ten years from the end of the contractual relationship). However, and in accordance with the applicable regulations, your data will be kept for the sole purpose of complying with the aforementioned legal obligations and for the formulation, exercise, or defense of claims, during the period of limitation of the actions arising from the contractual relationships entered into.

What are your rights?

This column describes the rights that you can exercise over your data, depending on the processing that is carried out on them. Please note that depending on the legal basis on which your data is processed, your rights may be limited. 

Right of access 

You have the right to have it confirmed whether or not we are processing your personal data, and if so, the right to know what data we are processing.

Right of rectification 

You have the right to modify your data if it is inaccurate or incomplete. To do so, you must indicate which data you wish to modify and provide appropriate evidence.

Right of opposition 

You can oppose at any time to the processing of your data when the processing is based on legitimate reasons or when we are dealing with personal data whose purpose is to carry out advertising and commercial prospecting activities.

Right of erasure 

In the cases provided for by law, you can object at any time, for reasons related to your particular situation, to the processing of your data. In our case, you can oppose (i) the sending of advertising and promotional communications by electronic means by configuring it from your user account in the “My Account” section, and (ii) to have us analyze your use of the Website, by setting your preferences in the cookie management panel that we make available to you or by configuring it in the Internet browser that you use to browse the Website, as explained in our Cookies Policy.

Right to data portability 

You have the right to receive and/or transfer to a data controller other than FairPlay the personal data you have provided to us.

Right to limitation of processing 

You have the right to ask us to suspend the processing of your personal data when :

• You have contested the accuracy of your data, while FairPlay verifies the accuracy of the data; or – You have exercised your right to object to the processing of your data, while FairPlay verifies whether the legitimate reasons of FairPlay outweigh those of you as a data subject.

Likewise, this right allows you to request FairPlay to retain your personal data when:

• The data processing is unlawful and as a data subject, you object to the deletion of your data, requesting instead a restriction on its use; or.

FairPlay no longer needs your personal data for the purposes of the processing but needs them for the formulation, exercise, or defense of claims.

For what purposes do we process your data?

• Processing of user registration and account opening;
• Sending you a welcome email upon registration through our Website or App;
• Provide support in the processes of password forgetting and recovery;
• Include a history of placed and ongoing bets;
• The provision of customer service: management and processing of user incidents and/or complaints, requests for information, the exercise of rights, and/or user queries received through customer service on the Website, via telephone, or chat;
• Recording of the interaction maintained with FairPlay through the customer service channels in order to resolve incidents and improve the service;
• The management and processing of bets and other games offered on the Website and/or the App;
• The crediting of prizes to your gaming account;
• The management of deposits and withdrawals from accounts made by users;
• Management of the account in case of suspension due to inactivity and of banned and/or self-excluded users by blocking the user’s open accounts;
• The provision of gaming services: Slot, Casino, and Poker.

Additional purposes:

• Analyze and segment users’ preferences, behaviors, and gaming habits and patterns.
• Create user profiles according to their behavior, gaming patterns, and browsing habits, among others.
• To design advertising strategies and/or promotional campaigns according to such preferences and profiles.
• To monitor the use of our Website and App.
• Improve the configuration and usability or user experience of our Website and App.
• Sending commercial communications by electronic means (SMS, email etc.) about FairPlay and its products and services adapted to your tastes, preferences, interests, and gaming habits.
• Contacting Users to offer promotions and benefits tailored to their tastes, and preferences and inform them about new products and services.
• Control, detect, prevent and/or report fraudulent and/or criminal conduct.
• Investigate the origin of funds.
• To control the user’s gaming activity.
• Block those bets and/or user accounts and/or cancel bets susceptible to being fraudulent.
• Verification of the user’s identity and the means of payment used.
• To manage the participation of the users in the different promotional actions carried out by Sportium and in which the users decide to participate.
• Manage, where appropriate, the delivery of the corresponding prize to users who are winners.

What are targeting and profiling?

In order to send you marketing communications tailored to your interests, we use techniques referred to as “targeting and profiling”. Segmentation and profiling is any form of automated processing of personal data that consists of gathering all the gambling and betting data that we have stored on all player users and cross-referencing it with other user data to obtain player (model user) profiles. In this way, we can offer users promotions according to a certain type of game to which they are related.

What information do we collect to carry out the profiling?

In order to carry out the profiling, we need information about the user’s browsing behavior on our website, their location, the number of bets, their interests, etc.

How does profiling affect the sending of commercial communications and promotions by electronic means?

As a result, by means of segmentation and profiling, we can group users according to their coincidence or difference in different rules such as, for example, the products that interest them, the promotions in which they are most interested, their gambling habits or their response to the commercial communications sent by FairPlay. In other words, by applying segmentation and profiling techniques and tools on user data, FairPlay can obtain different user profiles in order to group them and offer them differentiated products and services, promotions, gaming experiences, and commercial communications much more in line with their particular characteristics.

TO WHOM DO WE COMMUNICATE YOUR DATA?

FairPlay may communicate your personal data that are strictly necessary to third parties in order to comply with the gaming contract signed with the User, such as, for example:

1. Communication with payment platforms, banks, and companies in respect to which such communication is necessary in order to process transactions. You will find more information about such platforms at the following link https://www.sportium.es/faq/deposito.
2. The personal data of the users, the prizes obtained and the means of payment will be communicated to the tax authorities in the cases provided for by law.
3. Other possible third parties to whom we may communicate your data, subject to a legal requirement or basis that legitimizes the communication:

• Legal advisors
• Courts
• Tax Administration
• Government agencies and public administration

4. Data processors who, in order to provide the necessary services, must have access to certain information and/or personal data. The data may be communicated to suppliers with access to data with whom the obligations and responsibilities that they assume in the treatment of the data are formalized, in their capacity as Data Processors. FairPlay subscribes to the corresponding data processing contracts that include the due guarantees regarding the processing of personal data, confidentiality and cancellation, destruction, or return.

Likewise, we may communicate your personal information in the following cases:

1. If we, or substantially all of our assets, are acquired by a third party in which case personal data held by us about our users will be one of the transferred assets. Any such transfer will be previously informed and communicated.
2. To enforce or apply the terms and conditions of use of our Website.
3. To protect the safety and rights of our staff and our customer users. This includes exchanging information with other companies and organizations for fraud prevention and credit risk reduction.

SPORTIUM SPORTS BETTING APP

You can continue to enjoy our betting and gaming services through the FairPlay app. Access to the App will be made by free download through Apple Store if your mobile device is Apple or Google Play if it is Android. By downloading and using the App, you become a User of the App.

Once you download our App, we ask you to be able to access your location while using it. Knowing your location allows us to detect possible fraudulent conduct. We also ask you to allow us to send you notifications of promotions, benefits, or news that may be of interest to you. Such notifications may include sounds, alerts, or balloons on the home screen. Remember that, if you activate the possibility of sending you notifications, you will have the possibility at any time to configure them from the settings on your mobile device.

As on our Website, the mobile application requires you to register in order to be able to use the betting and gaming services offered by our App. If you decide to register for the first time through our App, we inform you that your personal data will be subject to this Privacy Policy. If you have previously registered on our Website and already have an account, you will be able to access the App directly by entering your user number and password.

IS YOUR DATA SECURE?

In order to ensure fair and transparent processing of your personal information, we will adopt appropriate procedures which will include the implementation of technical and organizational measures that take into account the possible risk and correct any inaccuracies identified in the personal data processing, so that the risk of any errors is minimized, treating your data fairly and securely.

All information you provide to us is stored on secure servers. Unfortunately, the transmission or communication of information via the Internet is not completely secure. Therefore, once we have received all of your information, we will use strict security procedures to try to prevent unauthorized access.

We also ensure that our service providers also have appropriate security standards for the protection of personal data to which they have or may have access, in accordance with applicable data protection legislation.