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Privacy Policy

Overview

Below you will find our Privacy Policy which tells you about how we will process your personal data and about rights that you have under data protection. We strongly recommend that you familiarize yourself with this Privacy Policy. However, we understand that people have busy lives and so want to provide you with a quick overview of how we will use your personal data – please remember though that this first section is an overview only and should not be read instead of reading the full Privacy Policy below.

Introduction

This Privacy Policy applies to our websites, applications, goods and services that link to this policy or which do not have a separate privacy policy. The purpose of this Privacy Policy is to provide you with information about how we use your personal data. This Privacy Policy may be updated from time-to-time so we recommend that you review it regularly, however where we make material changes, we will make sure to alert you to this.

Who is the Controller?

The controller (formerly known as data controller) of your personal data is REEL Italy Ltd, Villa Seminia, 8, Sir Temi Zammit Avenue, Ta' Xbiex, XBX 1011, Malta. This is who we refer to when saying "REEL", "we", "our" and "us" etc.

And, what about the Data Protection Officer, or is it DPO?

Yes, we have appointed a Data Protection Officer (DPO). While our DPO can be reached at dpo@starsgroup.com, our Customer Service team will be your initial point of contact if you wish to exercise your rights. Please see the 'Your Rights' section below.

What is meant by the "Group"?

Reference to the Group within this Privacy Policy means Flutter Entertainment plc and all or any of its direct or indirect subsidiary undertakings, joint venture partners, and their related companies wherever located in the world as may exist from time to time including, but not limited to, Paddy Power, Betfair, Timeform, Sportsbet, BetEasy, FanDuel, TVG, Adjarabet, Sky Betting and Gaming, Full Tilt, PokerStars and FOX Bet.

How we collect your personal data

In order to provide you services, you will need to create a gaming account. When creating this gaming account, you will need to submit certain personal data such as your name, age, address and email, telephone number, Italian fiscal code, ID details, place of residence. Additional information will also be required for you to utilize some of our services, such as your bank card details.

We also collect information about the transactions you make, including your gambling activity. We may collect personal data through surveys which we, or companies engaged by us for such purpose, undertake. In addition, we collect information about your use of our websites, mobile applications and services. We will also collect other information necessary for us to process your personal data for the purposes set out in this Privacy Policy.

Where you contact us, we will process any personal data you provide in these communications.

We may also collect personal data from third party service providers, such as credit reference agencies and fraud prevention companies.

Finally, we also use "cookies" and similar technologies which may collect certain information about you, such as your devices' IP addresses and online activity, some of which will constitute your personal data. You can learn more about the cookies we use in the 'Cookies' section below.

How will we use your personal data

In accordance with data protection laws, we will only process your personal data when we have a lawful basis for doing so in respect of your personal data. We process your personal data if: (i) it is necessary to provide services to you under the performance of the contract we have with you; (ii) we are required to do so in accordance with legal or regulatory obligations; (iii) you have given your consent; or, (iv) it is in our legitimate interests to process your personal data, provided that none of these interests prejudice your own rights, freedoms and interests.

With the exception of limited circumstances indicated below, we do not process special categories of personal data about you (such as personal data relating to your health, ethnicity, religion, political persuasion, trade union membership or sexuality) or personal data relating to criminal offences or convictions. For the limited circumstances in which we process special categories of personal data, we have set out the additional lawful basis required in italics below.

The following is a list of the purposes for which we process your personal data, and the lawful basis on which we carry out such processing:

PurposeLawful Basis
To set-up, administer and manage your gaming accountNecessary for the performance of a contract
To provide you with our services (including to allow you to play our games)Necessary for the performance of a contract
To receive and respond to your communications and requestsNecessary for the performance of a contract
To notify you with important updates to our websites, mobile applications and servicesNecessary for the performance of a contract
To ensure that we are able to fulfil our regulatory obligations regarding your use of our services, including by verifying the accuracy of any information you provide us, verifying your identity and verifying your age (which may involve us disclosing your personal data to third parties or supplementing your personal data with information received from third parties (such as credit reference agencies))Necessary to comply with a legal or regulatory obligation
To ascertain sources of funds and wealth, and to determine your ability to afford the amount you spend, when required under applicable lawsNecessary to comply with a legal or regulatory obligation
To comply with our obligations under applicable laws (including gambling legislation, and regulatory and licensing requirements related to our gambling licenses)Necessary to comply with a legal or regulatory obligation
To identify and disclose any suspected unlawful, fraudulent, or other improper activity connected with our websites, mobile applications and services (including money laundering)Necessary to comply with a legal or regulatory obligation
To monitor gambling patterns and to identify possible responsible gambling concernsNecessary to comply with a legal or regulatory obligation

Substantial Public Interest, including safeguarding of individuals at risk / safeguarding of economic well-being of certain individuals
To prevent you from using our websites, mobile applications and services if you have requested that we do so (such as self-exclusion)Necessary to comply with a legal or regulatory obligation

Substantial Public Interest, including safeguarding of individuals at risk / safeguarding of economic well-being of certain individuals
To comply with any deposit, spend or loss limits that you have set or which have been applied to your gaming accountNecessary to comply with a legal or regulatory obligation
To identify any breach of our terms of useNecessary for the performance of a contract
To prepare statistics relating to the use of our websites, mobile applications and services by you and our other customersLegitimate interests of understanding the use of, and therefore improving, our products and services
To send informative communications relating to our products and services that you may be interested inNecessary for the performance of a contract
To record telephone calls to and from, and live chats with, our customer services representatives for training purposesLegitimate interests of improving our customer services
Sharing: To share your personal information with other members of the Group who assist in providing the services to customersLegitimate interests to allow us to provide services
Sharing: To share your personal data with our professional advisors, such as lawyers and consultantsLegitimate interests to allow us to seek advice
Sharing: To share personal data with other members of the Group to ensure that responsible gambling measures can be applied across the group where required by applicable lawsNecessary for a legal or regulatory obligation
Sharing: To share your personal information with third parties for identity and geolocation verificationNecessary to comply with a legal or regulatory obligation
Sharing: To share your personal information with third parties for fraud and anti-money laundering detection purposesNecessary to comply with a legal or regulatory obligation
Sharing: To share your personal data with law enforcement agencies for the prevention and detection of crimeNecessary to comply with a legal or regulatory obligation
Sharing: To share your personal data with national self-exclusion databases provided by applicable laws or regulations if you have self-excludedNecessary to comply with a legal or regulatory obligation
Sharing: To share your personal data with gambling regulators in order to assist and comply with any investigationNecessary for a legal or regulatory obligation
Cookies: To operate our websites and mobile applications, including allowing you to interact with our websites and mobile applications and to recall selections as you move between pages within the limits strictly necessary for their operationLegitimate interest of using a website with at least standard functionality to provide our services
Cookies: To analyze your use of our website, monitor our web audience and populate certain content on our website in line with your usageConsent
Cookies: To track your journey to and from our website so we can understand how customers come to and from our websiteConsent
Cookies: To comply with regulations, including identifying multiple gaming accounts, attempts to login to an unauthorized gaming account or potential fraudNecessary to comply with a legal or regulatory obligation

In addition to the purposes set out above, we may also process your personal data for other purposes that we deem compatible with those listed above. We will update this Privacy Policy accordingly, when we do this.

Intra-Group Sharing

We are part of the Group and there will be instances where your personal data is shared with other members of the Group. This will occur in the following circumstances:

  • to enable us to identify and replicate responsible gambling measures;
  • to players across the Group;
  • to assist with account management, identification and verification of our customers as well as other regulatory checks;
  • to help ensure that customer information is up-to-date and accurate;
  • to identify customers who have committed or are suspected of fraud, money-laundering or other criminal acts;
  • to identify customers who have breached our terms of service or other terms and conditions related to our services; and
  • to analyze and better understand our business, customers, products and services across the Group.

We may also in the future share personal data with other members of our Group for purposes that are related to and compatible with those set out above. Finally, where we are required by law or regulation to share personal data throughout our Group for reasons beyond those set out above we will be required to do this.

Disclosing your personal data

In addition to the purposes involving the sharing of your personal data listed above, we will also disclose your personal data to processors we engage. We will have a contract in place with each such processor to ensure your personal data is kept secure.

We may also disclose your personal data in the following circumstances:

  • when required by applicable law or regulation (disclosure to a governmental, regulatory or enforcement authority) to comply with a legal/regulatory requirement; and
  • on the basis of legitimate interest
    • in order to defend ourselves legally and/or in relation to legal proceedings; and
    • whilst negotiating a takeover, purchase or merger, and pursuant to the same.

Transferring your personal data outside of the EEA

Your personal data may be accessed in the Isle of Man, a territory that has received an Adequacy Decision from the European Commission regarding its suitable data protection laws. Your personal data may also be accessed by members of the Group who are located outside of the European Union and in such cases we have implemented standard contractual clauses to ensure adequate protection of your personal data.

We may also share your personal data with third parties outside of the European Union and in all such cases we will ensure that standard contractual clauses and other measures required under applicable laws and regulations or an Adequacy Decision are in place to protect your personal data.

Security

We will take appropriate security, technical and organizational measures to ensure that your personal data is kept secure and to prevent the theft, loss or unauthorized access to your personal data. It is important to understand however that security can never be guaranteed and you will not hold us liable save where the security of your personal data is compromised due to our negligence.

Informative communications

If you have signed up to services offered by us we may send you informative communications in relation to other services and products offered by us or our Group provided that you have expressly requested to receive such communications.

At any time you can manage your choices via your gaming account. You can also unsubscribe by using the tools in any informative communication you receive. Please note that if you unsubscribe from informative services it may take up to five working days for this to take effect.

Cookies

In this Privacy Policy, we use the expression 'cookie' to refer to cookies and similar technologies we use to store information (such as web beacons). A cookie is a simple text file that is stored on your computer or mobile (or other) device by a website's server, and only that server will be able to retrieve or read the contents of that cookie. Each cookie is unique to your web browser. It will contain some anonymous information, such as a unique identifier and the website name and some digits and characters.

Almost all websites and applications you visit, including our websites, will use cookies in order to improve your user experience by enabling that website and/or application to 'remember' you, either for the duration of your visit (using a 'session cookie') or for repeat visits (using a 'persistent cookie').

Cookies are used to improve your use of a website or application, for example through letting you navigate between pages efficiently and storing your preferences. Cookies make the interaction between you and the website faster and easier. If a website or application doesn't use cookies, it will think you are a new visitor every time you move to a new page on the website. Cookies can also be used to enable targeted advertising and analyzing your browsing of a website.

You can learn more about cookies generally and how to disable them on your browser here.

You can learn more about what advertising cookies exist on your device and you can disable them directly by clicking here.

Retention of your personal data

We retain your personal data for ten years. Ten years is calculated from the closure of your gaming account. There are some exceptions to this retention period, namely:

  • If you are under investigation or we have identified possible fraud, money-laundering, criminal activity we may retain your personal data for the longer period required by such investigations.
  • If there is a legal dispute, we will retain your personal data for the longer period required by the duration of the dispute.
  • If personal data are processed to comply with a regulatory or legal obligations (including self-exclusion), they will be retained for the period required under applicable regulatory or legal obligations.

Updating your personal data

You can update some of your personal data at any time via your gaming account. We request that when your personal data changes you update your gaming account as soon as possible. If you are unable to change your information via your user account, please contact Support.

Your rights

You have the following rights in relation to your personal data:

  • a right to access your personal data held by us (also known as a subject access request);
  • a right to receive certain personal data in machine-readable format;
  • a right to have inaccurate or out-of-date personal data rectified;
  • where we have specifically requested your consent to process your personal data and have no other lawful conditions to rely on, you have the right to withdraw this consent;
  • a right to have certain personal data erased where it is no longer necessary for us to process it, if you have withdrawn your consent pursuant to the paragraph above, where you have objected pursuant to the paragraph below, where your personal data has been unlawfully processed, or where erasing your personal data is required in accordance with a legal obligation;
  • a right to object to the processing if the lawful basis is that it is in our legitimate interests to process your personal data, but please note that we may still process your personal data if there are other relevant lawful bases or if we have compelling grounds to continue processing your personal data in our interests which are not overridden by your rights, interests or freedoms;
  • a right to request an explanation of the logic involved if we make decisions about you solely through automated means; and

If you are unsure about your rights or are concerned about how your personal data may be processed, you should contact our Support or your national data protection supervisory authority, the Garante per la protezione dei dati personali.

If you would like to exercise any of your rights then you can do so by contacting Support. Please be aware that while we will try to accommodate any request you make in respect of your rights, they are not absolute rights. This means that we may have to refuse your request or may only be able to comply with it in part.

When you make a request in respect of your rights, we will require proof of identification. We may also ask that you clarify your request. We will aim to respond to any request within one month of verifying your identity, but it may take longer (we will notify you if this is the case). If we receive repeated requests, or have reason to believe requests are being made unreasonably, we reserve the right not to respond.

Supervisory authorities

If you have any complaints you have the right to contact your own national data protection supervisory authority, the Garante per la protezione dei dati personali, however you may consider to contact us in the first instance to allow us the opportunity to address your concerns.

Contact us

If you have any questions regarding our use of your personal data, or you would like to exercise any of your rights, please contact our Support in the first instance. You can also contact our Data Protection Officer at dpo@starsgroup.com.

Privacy Policy last revised: April 8, 2021