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Effective: May 25, 2018

Introduction

The website hosted at www.bdstadia.co.uk is operated by BD Stadia Ltd, a company registered in England and Wales with company registration no. 06751259, and having its registered office at Morningside, Linden Close, Thornton Cleveleys, Lancashire, United Kingdom, FY5 2RA.

BD Stadia Ltd is a licensed operator of in-stadium betting services. When it provides those services, BD Stadia Ltd collects Personal Information about its customers.

The in-stadium betting services provided by BD Stadia Ltd appear under the brands of various third party sports betting companies. BD Sport Limited (a company in the same group as BD Stadia Ltd) makes arrangements with those third party sports betting companies for the branding of BD Stadia Ltd’s services. BD Stadia Ltd may share Personal information about its customers with BD Sport Ltd. BD Stadia Ltd may also refer its customers to a third party sports betting company.

BD Sport Ltd is a company registered in England and Wales with company number: 6421307 whose registered office is at 17 St. Peter’s Place, Fleetwood, Lancashire FY7 6EB.  BD Stadia Ltd and BD Sport Ltd are part of a group of companies headed by Gaming Nation, Inc., which we will refer to as the “BD Sport Group”.

For the purposes of this Privacy Notice, references to “BD Stadia”, “we”, “us”, or “our” refer to both BD Stadia Ltd and BD Sport Ltd, which are independent data controllers in respect of your Personal Information. References to “the Website” refer to www.bdstadia.co.uk, www.bdsportgroup.com, and related websites and applications.

BD Stadia is committed to respecting and protecting the accuracy, confidentiality and security of your Personal Information. We want you to feel secure when visiting the Website and using the services we offer via the Website (the “Services”).

This Privacy Notice sets out our policies concerning the collection, use, disclosure and protection of Personal Information we receive from individuals using the Website, or from customers using the Services, as well as the types of cookies that BD Stadia uses on our Website.

“Personal Information” means all information relating to an identifiable person who can be directly or indirectly identified by reference to the information.

BD Stadia may update this Privacy Notice from time to time. We will take appropriate measures to notify you about material changes in a manner that is consistent with the significance of the changes we make.

 

Accountability

BD Stadia is responsible for Personal Information under its control, and will take all reasonable steps to handle such Personal Information fairly and to ensure compliance with applicable laws in relation to the processing of Personal Information.

In order to oversee overall compliance with this Privacy Notice and with applicable data protection laws, BD Stadia has designated a Data Protection Officer. Contact information for BD Stadia’s Data Protection Officer can be found at the end of this Privacy Notice.

 

The Personal Information We Collect

  • Voluntary information: If you visit our Website, request or subscribe to marketing materials, download content, contact us, place a winning ticket reimbursement, betting order or register to use the Services, we will collect Personal Information that you voluntarily provide to us (that may include your IP address, name, title, address, email address and telephone number, and contact preferences) in order to respond to your request or enquiry.
  • Governmentissued ID: In certain instances, you will be required to provide a copy of a government-issued ID, in order for us to verify your identity. Please note that this information may be required in order for you to use or continue using our Services.
  • Information we collect from third parties: We may collect data about you from third party service providers, such as information about your credit history from credit agencies and other financial information which is relevant to the provision of our Services, as well as information which is gathered in order to verify your identity and prevent fraudulent or illegal activity.
  • Device information: We may collect specific types of connection details and information with regard to your device, software or hardware that may identify you, such as: your device’s unique identifiers (e.g. UDID, IMEI, MAC address), IP address and geo-location data.
  • Technical information: In order to enhance the functionality of our Website and to provide you with a better user experience, we may collect technical information transmitted by your device, including certain software and hardware information (e.g. your language preference, the type of browser and operating system your device uses, access time, the domain name of the website from which you linked to our Services; etc.).
  • Analytics information: We collect information about your use of our Services, such as log files, user activity (e.g. pages viewed, the amount of time spent on particular pages, online browsing, clicks, actions, etc.), time stamps, alerts, etc. This information is collected for amongst other things troubleshooting errors and bugs as well as for research, profiling and analytics purposes about your use of our Website and Services, and providing you with tailored marketing and personalized products and Services.

You are under no obligation to provide Personal Information to us. However, certain Personal Information is essential for the provision and quality of the Services that we offer (for example, enabling you to collect winnings relating to bets you have placed at our stadiums).

 

Purposes and Legal Bases for Collecting Personal Information

BD Stadia collects, uses and discloses Personal Information for the following purposes:

  • to develop, manage, deliver and support our products and Services;
  • to ensure high standards of service to customers;
  • to contact our customers with regard to the Services as well as administrative or account-related information;
  • to respond to enquiries and fulfil requests, such as sending requested materials or documents regarding our Services;
  • to provide marketing and promotional communications (where this is in accordance with applicable law), and to determine the effectiveness of marketing and promotional campaigns;
  • to prevent you from using our Website and Services if you have requested that we do so (i.e. where you self-exclude);
  • to verify a customer’s identity;
  • to process transactions;
  • to perform data analysis, audits, fraud monitoring and prevention, develop new products, improve or modify our Services, and identifying usage trends;
  • to comply with regulatory and licensing requirements related to our gambling licence;
  • to identify and disclose any suspected unlawful, fraudulent, or other improper activity connected with our Website and Services (including money laundering)
  • to comply with applicable laws, comply with legal and regulatory processes, enforce our terms and conditions, and protect our operations, rights, safety or property.

BD Stadia’s legal basis for collecting, using and disclosing Personal Information will depend on the Personal Information concerned and the specific context in which we collect it, including:

  • Where you have given us consent. We collect, use and share your Personal Information for the purpose of marketing to you, where you have given us consent to do so. At any time you can easily withdraw your consent to us marketing to you by emailing us at marketing@bdsport.co.uk, or by following the unsubscribe instructions provided in the email or other communication that you receive from us.
  • Where the processing is necessary for the performance of your contract with us. We collect, use and share your Personal Information where such information is essential to provide the Services to you. You are under no obligation to provide such Personal Information to us. However, you might not be able to use access and/or use some or part of the Services if you choose to withhold Personal Information that is required for those services.
  • Where the processing is necessary for us to comply with our legal obligations. In some circumstances, we are legally required to collect, use and share your Personal Information. For example, in connection with the prevention, detection or investigation of a crime or fraud, or where we are obliged to do so by the terms of the licence issued to us by the UK Gambling Commission. Where we process your Personal Information in order to comply with our legal obligations, we may need to retain such information in order to demonstrate that we have complied with our legal obligations.
  • Where the processing is necessary for a task carried out in the public interest. We collect, use and share your Personal Information where such processing is necessary for the purposes of the prevention or detection of an unlawful act, or is necessary for the exercise of a protective function (such as protecting members of the public against dishonesty or other improper conduct). We may rely on this as a legal basis for processing and/or sharing ‘special categories’ of data, or data relating to criminal convictions or offences.
  • Where we have legitimate interests in the processing. We collect, use and share your Personal Information where such processing is necessary for our legitimate business interests, unless we determine that those interests are overridden by your interests or your fundamental rights and freedoms. By way of example, we have determined that we have legitimate interests in developing new products, improving or modifying our Services, and identifying usage trends.

 

Sharing Personal Information

BD Stadia may share Personal Information with our employees, contractors, consultants, affiliates, service providers, business partners and other parties who require such information to assist us with providing you with the Services.

  • We share your Personal Information with our holding company, Gaming Nation, Inc. We may also share your Personal Information with other companies in the BD Sport Group.
  • We share your personal data with the UK Gambling Commission and other gaming regulators with whom we are licensed.
  • We may use third party providers in order to manage aspects of your account; including anti-fraud and anti-money laundering checks, credit risk checks. These third party providers may have access to or process your Personal Information for the purpose of providing these services to us.
  • We may use third party service providers in order to advertise and market to you and manage our advertising activities. Your Personal Information may be shared with these third parties in order for them to provide such services to us.
  • We may share some or all of your Personal Information in connection with or during negotiation of any potential sale or investment in any of the companies in the BD Sport Group or in the event of a corporate transaction (e.g. a sale of a substantial part of our respective businesses, a merger, financing, restructuring, consolidation, acquisition, corporate divestiture, dissolution transaction, or other proceeding involving the sale, transfer, divestiture or disclosure of all or a portion of our business or assets). In the event of an insolvency, bankruptcy, or receivership, your Personal Information may also be transferred as a business asset.
  • In some cases we may disclose your Personal Information and any other information and/or records relating to you, if we are under a duty to disclose or share these details in order to comply with any legal obligation, or when ordered to do so by any governmental or administrative authority. We may also share such information if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our terms of use, or as otherwise required by law.

As a gambling operator, we are subject to strict legal and regulatory obligations to ensure you can use our Services. Because of this, we may share your Personal Information with certain third party service providers (such as credit reference agencies, fraud prevention agencies, payment service providers and similar third parties) that are also “data controllers” in respect of the Personal Information about you that is held by them.

The use, collection and disclosure of Personal Information may involve BD Stadia transferring Personal Information across borders. Where we transfer Personal Information from the EEA to other countries in which applicable laws do not offer the same level of data privacy protection as in your home country, we take steps to ensure that your data is treated securely and in accordance with this privacy notice. For example, we use approved contractual clauses, intragroup agreements and other measures designed to ensure that the recipients of your Personal Information protect it.

Please contact us if you have any questions regarding the security measures that we have in place with regard to Personal Information.

 

Cookies

We use certain types of Cookies on the Website. “Cookies” are small text files containing small amounts of information which are downloaded to your device when you visit a website, so that the website can remember some information about your browsing activity on the website, either for the duration of your visit or for repeat visits. The cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie. Cookies are useful because they allow a website to recognise a user’s device. They do many different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improving your user experience. In general, cookies make the interaction between you and websites faster and easier.

The following describes the types of cookies that BD Stadia currently uses or may in the future use on our Website:

  • Session Cookies: These are temporary cookies that expire when you close your browser. A session cookie assigns a randomly-generated, unique identification number to your device when you access the Website. Assigning your device a number facilitates the proper functioning of the features of our Website by permitting us to maintain a persistent “state” for your session, including information relating to transactions you might make. We also use session cookies to collect anonymous information (i.e., information that does not identify you personally) about the ways users use the Website, such as which pages they visit, which links they use, and how long they stay on each page. We analyse this information (known as “click-stream information”) to better understand our users’ interests and needs and to improve the content and functionality of the Website.
  • Persistent Cookies: Unlike a session cookie, a “persistent cookie” does not expire when you close your browser. It stays on your device until the expiration date set in the cookie (for example, at the end of a calendar month) or until you delete it. Persistent cookies can be used to “tag” your device so that the next time you visit (or someone using your device visits), our server will recognise you, not by name, but by the “tag” on your device. This will enable us to provide you with a personalised experience even if we do not know who you are. It will also allow us to collect more accurate information about the ways people use the Website, for example, how people use the Website on their first visit and how often they return. Using persistent cookies permits us to provide you with a more personalised experience and, in some cases, may save you the trouble of re-entering information already in our database.
  • Strictly necessary cookies: These cookies are essential for the running of our Website. Without these cookies, parts of our Website would not function. They enable you to move around the Website and use its features, such as accessing secure areas. These cookies do not track where you have been on the Internet and do not gather information about you that could be used for marketing purposes.
  • Performance cookies: These cookies are used to monitor the performance of our Website, for example, to determine the number of page views and the number of unique users the Website has. Web analytics services may be designed and operated by third parties on BD Stadia’s behalf. The information provided by these cookies allows us to analyse patterns of user behaviour, and we use that information to enhance user experience or identify areas of the Website which may require maintenance. These cookies do not collect information that identifies a visitor. All information collected through these cookies is aggregated and therefore anonymous.
  • Functional cookies: These cookies allow the Website to remember choices you make (such as your preferences, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. The information these cookies collect may be anonymised, and they cannot track your browsing activity on other websites.
  • Targeting or advertising cookies: These cookies, which may be placed on your device by us or our trusted third party service providers, remember that you have visited a website and use that information to provide you with advertising which is tailored to your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Without these cookies, online advertising you encounter will be less relevant to you and your interests.
  • Web Beacons: When you visit our Website, your device may receive one or more “web beacons” in order to assist us with delivering cookies, to collect anonymous information about the use of the Website by our users, and to deliver customised or targeted content to you on the Website and through our partners. Web beacons (also referred to as “tracking pixels,” “1×1 gifs,” “single-pixel gifs,” “pixel tags,” or “action tags”) are graphic images, usually no larger than a 1×1 pixel, placed at various locations on the Website. They also help us identify browser types, search terms that bring users to our Website, and the domain names of websites that refer traffic to us. We also utilise web beacons to provide us with more information on any emails we send out. In particular, a web beacon in an email communication will send us information to let us know that you have received, opened, or acted upon an e-mail you have chosen to receive from us.
  • JavaScript Tags/Pixels: These are used by us to collect anonymous information about the use of the Website by our users, and to deliver customised or targeted content to you on the Website and through our partners. We may use JavaScript tags to anonymously track how visitors interact with our Website, including where they came from and the manner in which they use our Website.

Some people find the idea of a website storing information on their device intrusive. If you would prefer to opt out of cookies, it is possible to manage them by changing the cookie settings on your device, in your browser settings. Existing cookies that have already been set can be deleted from your hard drive. You can also block some or all cookies. However, you should be aware that you might lose some features and functionality of our Website if you do so. For more detailed information about cookies and how to manage and delete them, visit http://www.aboutcookies.org or http://www.allaboutcookies.org.

 

Third Party Links

BD Stadia’s Website contains links to third party sites including the websites of our partners, and we recommend and encourage you to read the privacy policies posted on those third party sites. BD Stadia is not responsible for and has no control over information that is submitted to, or collected by, these sites.

 

Retention

BD Stadia will retain your Personal Information for as long as necessary to fulfil the purposes for which it was collected, or to comply with applicable legal, tax or regulatory requirements. After this time, any Personal Information you have provided to us will be deleted or made anonymous.

Please note that we may be required in certain circumstances to retain your Personal Information indefinitely (for example, in order to comply with our policies and procedures in connection with responsible gambling and self-exclusion). We will take all necessary steps to ensure that the privacy of your Personal Information is maintained for the period of retention.

BD Stadia may use and disclose aggregated and anonymous or de-identified information to third parties, including the general public. For example, we may analyse and publish reports on usage trends or statistics from across our global customer base for information or marketing purposes, but only after we have removed any Personal Information. This type of aggregated and anonymous or de-identified data can help BD Stadia to improve our products, services and advertising, and it can be used by customers and the public to better understand trends in the industry.

 

Your Rights

You have a number of rights in respect of your Personal Information, which are detailed below. Some of these only apply in specific circumstances and are qualified in several respects by exemptions in data protection legislation. We will advise you in our response to your request if we are relying on any such exemptions.

  • Accuracy: BD Stadia will make reasonable efforts to ensure that the Personal Information collected and used by us is accurate, complete and up-to-date to meet the purposes for which it is collected and used. However, you have the right to request correction to your Personal Information in the event it is inaccurate, incomplete or out of date.
  • Access: You have the right to access your Personal Information. This includes (a) identification of and access to any or all of your Personal Information under BD Stadia’s custody or control; (b) an explanation of how that Personal Information is or has been collected, used or disclosed by BD Stadia; and (c) the names of any individuals and organisations to which your Personal Information has been disclosed by BD Stadia.
  • Erasure: You can request that BD Stadia erases your Personal Information where there is no compelling reason for us to continue processing it.
  • Data portability: This right allows you to obtain the Personal Information that you have provided to us with your consent or which was necessary for us to provide you with our Services in a format which enables you to transfer that Personal Information to another organisation. You may have the right to have your Personal Information transferred by us directly to the other organisation, if it is technically feasible.
  • Restriction of processing: You have the right in certain circumstances to request that BD Stadia suspends processing of your Personal Information. Where we agree to suspend our processing of your Personal Information we will still be permitted to store your Personal Information, but any other processing of this information will require your consent, subject to certain exemptions.
  • Objection to processing: You have the right to object to BD Stadia’s use of your Personal Information, where it is processed on the basis of our legitimate interests. However, BD Stadia may continue to process your Personal Information, despite your objection, where there are compelling legitimate grounds to do so or we need to process your Personal Information in connection with any legal claims.
  • Withdrawal of consent: Where BD Stadia has relied upon your consent to process your Personal Information, you have the right to withdraw that consent.   .

Any request to exercise your rights in respect of your Personal Information must be made in writing to BD Stadia’s Data Protection Officer and provide sufficient detail to identify the Personal Information and the action being sought.

We will respond to written requests within thirty (30) days of receiving such request. We will either make the requested information available within that time period, or provide written notice of an extension where additional time is required to fulfil the request. If BD Stadia cannot fulfil your request in full or in part, you will be provided with a response in writing that explains the reason for refusal and the further options available to you.

 

Safeguarding Personal Information

BD Stadia will make reasonable security arrangements and use appropriate technical and organisational measures to protect all Personal Information under our control (regardless of the format in which it is held) against unauthorised access, loss, theft, collection, use, disclosure, duplication, modification, disposal or similar risks, by both individuals outside of BD Stadia as well as within. The types of security safeguards that we use vary, depending on the nature and sensitivity of the Personal Information, the harm that might result from its improper use or loss, and how it is stored (e.g. in paper or electronically).  BD Stadia’s security safeguards include locked filing cabinets, physically secured offices where Personal Information is held, limited employee access, the use of IDs, passwords, restricted servers, firewalls and encryption for electronic files, as well as contractual requirements for service providers to provide comparable security measures.

BD Stadia will use appropriate security measures when disposing of and destroying Personal Information, such as shredding documents and deleting electronically stored information, in order to prevent unauthorised access.

BD Stadia will continually review and update our security policies and controls as technology changes to ensure ongoing Personal Information security.

 

Use by Children

The Website and the Services are not intended for use by minors. BD Stadia does not knowingly collect Personal Information about minors. If you believe that we have mistakenly or unintentionally collected a minor’s Personal Information, please contact BD Stadia’s Data Protection Officer.

 

Complaints Procedure

Complaints, concerns or inquiries about BD Stadia’s data protection practices, including compliance with this Privacy Notice, should be made in writing or e-mail to:

Data Protection Officer:             John Lee

BD Sport Group Ltd
17 St Peter’s Place
Fleetwood, UK
FY7 6EB
privacy@bdsportgroup.com
+44 (0) 1772 804 850

You also have the right to make a complaint to the ICO (www.ico.org.uk/concerns/) or (if not the ICO) your local national data supervisory authority.