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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.

This website and the services operate under and pursuant to the Operating Agreement and are being offered by Flutter as part of the open and regulated iGaming market conducted and managed by iGaming Ontario. In the course of providing the services (i) Flutter collects, uses and discloses personal data on behalf of and as agent to iGaming Ontario; (ii) Flutter collects personal data in accordance with Freedom of Information and Protection of Privacy Act ("FIPPA") and other applicable privacy laws, and under the authority of Ontario Regulation 722/21 made under the Alcohol and Gaming Commission, and the operating agreement entered into between Flutter and iGaming Ontario.

Under this Privacy Policy, "personal data" means as information about an identifiable individual and includes any information that constitutes personal information within the meaning of the FIPPA and other applicable privacy law.

We will never intentionally collect information from individuals under the age of 19 for real money play. In the event that a parent or guardian becomes aware that his or her child under the age of 19 has provided us with personal data, the parent or guardian may contact us at the details set out below in the "Contact Us" section to have such personal data deleted.

We process your personal data for the purposes discussed in detail below, but the two main purposes are to enable us to provide you with services and to comply with our regulatory obligations, specifically:

  • On the first of these, in order for us to offer you with services we will need you to register a user account and provide bank details to deposit money.
  • On the regulatory aspect, we are required to monitor our customers and to keep records of transactions to ensure that we are offering a fair, responsible and safe service – and this includes verifying your age and monitoring our customers to ensure that they are gambling within their means.

Introduction

This Privacy Policy applies to Flutter Entertainment plc 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.

Your personal data is processed by TSG Interactive Services (Ireland) Limited, Belfield Office Park, Beech Hill Road, Clonskeagh, Dublin 4, Ireland. This is who we refer to in this Privacy Policy when saying "TSG", "we", "our" and "us" etc.

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, Junglee, Singular and FOX Bet.

While our Privacy Officer can be reached at dataprotection@flutterint.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.

How we collect your personal data

In order to provide you services, you will need to create a user account. When creating this user account, you will need to submit certain personal data such as your name, age, address and email. 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 privacy and 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 with your consent or as otherwise authorized by FIPPA or other applicable privacy law. We process your personal data when: (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) it is in our legitimate interests to process your personal data, provided that none of these interests prejudice your own rights, freedoms and interests; or, (iv) if you otherwise have given your consent or as authorized by FIPPA or applicable privacy law.

With the exception of limited circumstances, 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 it carries out such processing. In the Province of Ontario consent is the primary legal basis for processing your personal data:

Purpose

Category of Data

Lawful Basis

To set-up, administer and manage your user account 

Identity and verification data

Necessary for the performance of a contract

To provide you with our services (including to allow you to play our games)

Contacts, Web/App activity, Device and internet identifier, Financial and payments data, Location data

Necessary for the performance of a contract

To receive and respond to your communications and requests

Contacts, Messages

Necessary for the performance of a contract if the communication relates specifically to our services, otherwise legitimate interests 

To notify you with important updates to our websites, mobile applications and services 

Contacts, Messages, Devise and internet identifier

Necessary for the performance of a contract

For the purposes of your interaction with us we will retain your records for the length of your membership with us plus a retention period as specified by our retention policy.  After your membership ends, your information will still be retained as per our requirement and then destroyed in accordance with our policies.

Financial and payments data

Necessary 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)) 

Identity and verification data, Financial and payments data, Exclusion data, Location data

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 

Identity and verification data, Financial and payments data, Exclusion data

Necessary 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) 

Identity and verification data, Financial and payments data, Exclusion data, Location data

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) 

Identity and verification data, Financial and payments data, Exclusion data, Location data, Web/App activity, Device and internet identifier

Necessary to comply with a legal or regulatory obligation 

Substantial Public Interest: Preventing or detecting unlawful acts / protecting the public against dishonesty / regulatory requirements relating to unlawful acts and dishonesty / preventing fraud / suspicion of terrorist financing or money laundering  

To monitor gambling patterns and to identify possible responsible gambling concerns 

Financial and payments data, Exclusion data, Location data, Web/App activity, Device and internet identifier

Necessary to comply with a legal or regulatory obligation 

Substantial Public Interest: 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) 

Financial and payments data, Exclusion data, Location data, Web/App activity, Device and internet identifier

Necessary to comply with a legal or regulatory obligation 

Substantial Public Interest: 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 user account 

Financial and payments data, Exclusion data, Location data, Web/App activity, Device and internet identifier

Consent

To support any other purpose necessary for the performance of our contractual obligations or specifically stated at the time at which you provide your personal data 

All categories of data

Necessary for the performance of a contract

To identify any fraudulent use of our services

Financial and payments data, Exclusion data, Location data, Web/App activity, Device and internet identifier

Necessary for a legal or regulatory obligation

To identify any breach of our terms of use 

Financial and payments data, Exclusion data, Location data, Web/App activity, Device and internet identifier

Necessary for the performance of a contract

To carry out market research campaigns 

Contacts, Web/App activity, Web/App info and performance

Legitimate interests of better understanding the products and services that our customers most enjoy 

To send out surveys to better understand our products and services 

Contacts, Web/App activity, Web/App info and performance

Legitimate interests of better understanding the products and services that our customers most enjoy 

To review the results of surveys completed by you 

Contacts, Web/App activity, Web/App info and performance

Consent

To prepare statistics relating to the use of our websites, mobile applications and services by you and our other customers 

Contacts, Web/App activity, Web/App info and performance

Legitimate interests of understanding the use of, and therefore improving, our products and services

To send offers and promotions relating to our services that you may be interested in 

Location data, Web/App activity,

Consent

To record telephone calls to and from, and live chats with, our customer services representatives for training purposes  

Contacts, Audio files

Legitimate interests of improving our customer services

To record telephone calls to and from, and live chats with, our customer services for security and regulatory purposes 

Contacts, Audio files, Files and docs

Necessary for a legal or regulatory obligation

To use your name, image, username or Location data in publicity and marketing, but only when you have provided express and informed consent for us to do so 

Contacts, Audio files, Files and docs

Consent

Sharing: To share your personal information with other members of the Group who assist in providing the services to customers 

All categories of data

Legitimate interests to allow us to provide services

Sharing: To share your personal data with our professional advisors, such as lawyers and consultants 

All categories of data

Legitimate 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 

Identification and verification data, Exclusion data.

Necessary for a legal or regulatory obligation

Sharing: To share your personal data with social media services to provide you with ads on social media sites, unless you have requested not to receive such ads via your social media account 

Contacts, Web/App activity, Device and internet identifiers

Legitimate interest of better advertising our products and services

Sharing: To share your personal information with third parties for identity and Geolocation data verification 

Location data, Contacts

Necessary to comply with a legal or regulatory obligation

Substantial Public Interest: Preventing or detecting unlawful acts / protecting the public against dishonesty / regulatory requirements relating to unlawful acts and dishonesty / preventing fraud / suspicion of terrorist financing or money laundering  

Sharing: To share your personal information with third parties for fraud and anti-money laundering  detection purposes  

Identification and verification data, Exclusion data, Financial and payments data, Web/App activity,

Necessary to comply with a legal or regulatory obligation 

Substantial Public Interest: Preventing or detecting unlawful acts / protecting the public against dishonesty / regulatory requirements relating to unlawful acts and dishonesty / preventing fraud / suspicion of terrorist financing or money laundering  

Sharing: To share your personal data with law enforcement agencies for the prevention and detection of crime 

Identification and verification data, Exclusion data, Financial and payments data, Web/App activity,

Legitimate interests of helping to protect our services and our community. 

Substantial Public Interest: Preventing or detecting unlawful acts / protecting the public against dishonesty / regulatory requirements relating to unlawful acts and dishonesty / preventing fraud / suspicion of terrorist financing or money laundering  

Sharing: To share your personal data with national self-exclusion databases if you have self-excluded

Contacts, Exclusion data

Necessary to comply with a legal or regulatory obligation

 Substantial Public Interest: Safeguarding of individuals at risk / safeguarding of economic well-being of certain individuals  

Sharing: To share your personal data with gambling regulators in order to assist and comply with any investigation 

Contacts, Exclusion data

Necessary 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 

Web/App info and performance

Legitimate 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 usage 

Web/App info and performance, Web/App activity

Consent

Cookies: To track your journey to and from our website so we can understand how customers come to and from our website and give effect to any commercial arrangements 

Web/App info and performance

Consent 

Cookies: To comply with regulations, including identifying multiple user accounts, attempts to login to an unauthorized user account or potential fraud 

Web/App info and performance, Web/App activity, Device or internet identifier

Necessary to comply with a legal or regulatory obligation

Cookies: To present third party marketing 

Contacts, Web/App activity, Device or internet identifier

Consent

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.

Please note that the lawful bases set out above are those which will primarily apply although it is possible that a change in circumstance may result in a change in lawful basis – for example, if you close your user account with us we will no longer process your personal data to perform a contract with you but will continue to do so for certain purposes in order to comply with legal requirements.

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 (such as self-exclusion) to players across the Group (necessary to comply with a legal/regulatory requirement);
  • to assist with account management, identification and verification of our customers as well as other regulatory checks (necessary to comply with a legal/regulatory requirement);
  • to help ensure that customer information is up-to-date and accurate (necessary to comply with a legal/regulatory obligation);
  • to identify customers who have committed or are suspected of fraud, money-laundering or other criminal acts (necessary to comply with a legal/regulatory requirement);
  • to identify customers who have breached our Terms of Service or other terms and conditions related to our services (legitimate interests);
  • to send cross-brand marketing materials where customer has requested this (consent); and
  • to analyze and better understand our business, customers, products and services across the group (legitimate interests).

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.

Please check this Privacy Policy frequently to learn of any updates to our intra-group sharing.

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 verify your identity as required by applicable law;
  • 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

We store your personal data 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 or an Adequacy Decision is in place to protect your personal data.

Security

We consider your personal data confidential. 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. We restrict access to person data on a need-to-know basis to employees and authorized service providers who require access to fulfil their job requirements. 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.

In order to protect your account, we strongly recommend that you do not disclose your password to anyone. We will never ask you for your password in any unsolicited communication (such as letters, phone calls or email messages). If you become aware of any unauthorized access to or use of your account, you are required to notify us immediately. For general information on how to protect your information online, please refer to the resources posted by the Information and Privacy Commissioner of Ontario here.

Additionally, we maintain a Personal Data Incident Investigations and Breach Reporting Policy. We will provide you notice in the event of an incident that materially impacts your personal data (a "Data Incident"). We will notify you, iGO, and any other applicable regulatory authority about the data breach, and we will aid iGO and any applicable authorities in the management and handling of the Data Incident.

Marketing

If you have signed up to receive marketing communications, we may send you direct marketing in relation to other services offered by us or our Group provided that you have given your consent to receive such marketing.

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

Social Media Marketing

We may also use information you provide to us to show you relevant advertising and personalized content about our Group's services on certain third party social media platforms (Social Media Sites) made available to us through relevant service providers (e.g. Facebook, Twitter). If you do not wish to see these advertisements, you can change your settings on the Social Media Sites. If you do not want us to share this information with Social Media Sites you can contact us directly.

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 no longer than necessary for up to seven years. Seven years is calculated from the closure of your user account or where your user account has been dormant for this period. There are some exceptions to this retention period, namely:

  • If you self-exclude from any of our services, we will retain this information indefinitely.
  • If you are under investigation or we have identified possible fraud, money-laundering, criminal activity we may retain your personal data for longer.
  • If there is a legal dispute, we will retain your personal data for the duration of the dispute and for six years thereafter.

Personal data is removed from all physical and virtual storage devices before that equipment is decommissioned.

Updating your personal data

You can update some of your personal data at any time via your user account. We use reasonable efforts to ensure your personal data remains up to date and accurate, but we request that when your personal data changes you update your user 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. This includes receiving confirmation on whether your personal data is being processed, why it is being processed and the personal data being processed.
  • a right to rectification of inaccurate personal data or updating of incomplete personal data.
  • a right to erasure (also known as the right to be forgotten) of personal data under certain circumstances, including where you (i) object to Flutter's processing for its own legitimate interests or (ii) where Flutter's processing of the personal data is unlawful. In the case of unlawful processing, you may request that this processing is restricted rather than the personal data being erased.
  • a right to data portability i.e. to receive your personal data in a portable format or, subject to it being technically feasible, have us transfer your personal data directly to a third party. This right applies where processing is taking place based on consent or for the performance of a contract.
  • a right to object to the processing of personal data, where such processing is being conducted for the purpose of (a) direct marketing; (b) establishing, exercising or defending ourselves or others from legal claims; or (c) Flutter's legitimate interests where Flutter cannot demonstrate its interests override your interests and rights. Please note, restriction on processing may be requested while an investigation of legitimate interests takes place. You shall have the right to obtain from us restriction of processing in limited circumstances.
  • a right not to be subject to decisions taken solely on the basis of automated processing of personal data of an individual (i.e. no human involvement in the decision) which produce legal effects or have similarly significant effects unless permitted by law.

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.

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 30 days 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. However we ask that you 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, wish the register a privacy related complaint or you would like to exercise any of your rights, please contact our Support in the first instance. You can also contact our Privacy Officer at dpo@starsgroup.com.

Privacy Policy last revised: May 31, 2022