Under data protection laws, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes, and your rights in relation to your personal data. This information is provided at www.fairplayexchange.co.uk and it is important that you read that information.
Before installation of this App, please indicate your consent to our processing of your personal data (including your name, contact details, financial and device information) as described in the policy www.fairplayexchange.co.uk
YES I consent to the installation of the App for the purposes of peer to peer gambling.
NO I do not consent to the installation of the App.
Once you provide consent by selecting "YES", you may change your mind and withdraw consent at any time by contacting us info@fairplayexchange.co.uk but that will not affect the lawfulness of any processing carried out before you withdraw your consent.
YES I consent to processing of my Location Data (including details of my current location disclosed by GPS technology so that location-enabled Services are activated to ensure we comply with our gambling licence issued by the UK Gambling Commission licence.
NO I do not consent to processing of my Location Data and location-enabled Services are disabled in my settings.
Fairplay Exchange Limited, a company registered in England & Wales with company registration number 13229819 (we) are committed to protecting your personal data and respecting your privacy.
This policy (together with our end-user licence agreement as set out at www.fairplayexchange.co.uk (EULA) and any additional terms of use incorporated by reference into the EULA, together our Terms of Use) applies to your use of:
This policy is provided in a layered format so you can click through to the specific areas set out below.
Important Information And Who We Are
The Data We Collect About You
How Is Your Personal Data Collected?
How We Use Your Personal Data
Disclosures Of Your Personal Data
International Transfers
Data Security
Data Retention
Information we collect from other sources
Who we share your information with
Your Legal Rights
Glossary
Description Of Categories Of Personal Data
Fairplay Exchange Limited, a company registered in England & Wales with company registration number 13229819 is the controller and is responsible for your personal data (collectively referred to as "Company", "we", "us" or "our" in this policy).
We have appointed a data protection officer (DPO). If you have any questions about this privacy policy, please contact them using the details set out below.
Our full details are:
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues.
We keep our privacy policy under regular review.
This version was last updated on 28 February 2022. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you by email. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.
Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.
We may collect, use, store and transfer different kinds of personal data about you as follows:
We explain these categories of data here Description Of Categories Of Personal Data Below.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
We will collect and process the following data about you:
We use cookies and/or other tracking technologies to distinguish you from other users of the App, App Site, the distribution platform (Appstore) or Services Sites and to remember your preferences. This helps us to provide you with a good experience when you use the App or browse any of Our Sites and also allows us to improve the App and Our Sites. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy.
We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:
Click here Glossary: Lawful Basis to find out more about the types of lawful basis that we will rely on to process your personal data.
We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
| Purpose/Activity | Type of data | Lawful basis for processing |
|---|---|---|
| To install the App and register you as a new App user |
Identity Contact Financial Device |
- Your consent |
| To process in-App purchases and deliver Services including managing payments and collecting money owed to us |
Identity Contact Financial Transaction Device Marketing and Communications Location |
- Your consent
- Performance of a contract with you - Necessary for our legitimate interests (to recover debts due to us) |
| To manage our relationship with you including notifying you of changes to the App or any Services |
Identity Contact Financial Profile Marketing and Communications |
- Your consent - Performance of a contract with you - Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services) - Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions) |
| To enable you to participate in a prize draw, competition or complete a survey |
Identity Contact Device Profile Marketing and Communications |
- Your consent - Performance of a contract with you - Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business) |
| To administer and protect our business and this App including troubleshooting, data analysis and system testing |
Identity Contact Device |
- Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security) |
| To deliver content and advertisements to you To make recommendations to you about goods or services which may interest you To measure and analyse the effectiveness of the advertising we serve you To monitor trends so we can improve the App |
Identity Contact Device Content Profile Usage Marketing and Communications Location |
- Consent - Necessary for our legitimate interests (to develop our products/Services and grow our business) |
When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table Purposes for which we will use your personal data:
Many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
Where we use certain service providers, we may use specific contracts approved by the UK which give personal data the same protection it has in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.
We will collect and store personal data on your Device using application data caches and browser web storage (including HTML5) and other technology.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see Your legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
In the event that you do not use the App for a period of 365 days then we will treat the account as expired and your personal data may be deleted.
Where you have asked us to provide a restricted product or service, we may collect information from One Account Mobile Limited (1account) and third-party providers of identity data to 1account. This is necessary for 1account to verify that you meet the minimum age and identity verification requirements as determined by relevant UK age restriction and other legislation. We will record that you have been successfully verified so that you don’t need to go through the process again. You can find information about how 1account manage your personal data and view their privacy policy by visiting their website: 1account.net.
Where you have asked us to provide an restricted product or service, we may share your information with One Account Mobile Limited (1account), and third-party providers of identity data to 1account. This is necessary for 1account to verify that you meet the minimum age and identity verification requirements as determined by relevant UK age restriction and other legislation. 1account may retain relevant data for the purpose of future verifications. All data processed by 1account is subject to appropriate security measures. Data retained by 1account is subject to periodic review to ensure it is not held for longer than necessary. You can find information about 1account how manage your personal data and view their privacy policy by visiting their website: 1account.net.
Under certain circumstances you have the following rights under data protection laws in relation to your personal data.
You have the right to:
You also have the right to ask us not to continue to process your personal data for marketing purposes.
You can exercise any of these rights at any time by contacting our DPO.
Consent - means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.
Legitimate Interest - means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract - means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation - means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Marketing partners which have agreements in place to share data for the purpose of promotion.
Service providers acting as processors who provide IT and system administration services.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue and Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.
