Privacy & cookie policy

Policy version: 11th April 2023

Privacy Policy

1 INTRODUCTION
This Privacy Policy is provided by Invest In Play Ltd (trading as Invest In Play), a private company limited by guarantee without share capital registered in England and Wales under company number: 14231131 with registered office 2nd Floor Grove House, 774-780 Wilmslow Road, Didsbury, Greater Manchester, England, M20 2DR (‘we’, ‘our’ or ‘us’) when you visit our website, make an enquiry with us, or register with our Platform (Services).
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on how and why we collect, store, use and share any information relating to you (your personal data).
It also explains your rights in relation to your personal data and how to contact us or the relevant regulator in the event you have a complaint. Our collection, storage, use and sharing of your personal data is regulated by law, including under the UK General Data Protection Regulation (UK GDPR).
We are the controller of personal data obtained via the Services, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.

WHAT THIS POLICY APPLIES TO
This privacy policy relates to your use of the Services only.
The Services may link to or rely on other apps, websites, APIs or services owned and operated by us or by certain trusted third parties to enable us to provide you with Services. These other apps, websites, APIs or services may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other apps, websites or services, please consult their privacy policies as appropriate. For more information see the section ‘Who we share your personal data with’ below.

PERSONAL DATA WE COLLECT ABOUT YOU
The personal data we collect about you depends on the particular activities carried out through the Services. We will collect and use the following personal data about you:

Category of data	In more detail
Identify and account data you input into the Services Registration is mandatory in order to use the Services	· Your name · Your email address · Your telephone number · Your account details, such as username and password · Your employer and job title
Data collected when you use specific functions in the Services	Data you store online with us using the Services including your usage history or preferences (while such data may not always be personal data as defined at law in all cases we will assume it is and treat it in accordance with this policy as if it were)
Data collected when you make an enquiry with us	· Your name · Your email address · Details of correspondence via phone, email or post

If you do not provide personal data we ask for where it is required, including the geo-localisation services, it may prevent us from providing services and/or the Services to you.

We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.

SENSITIVE DATA
Sensitive personal data (also known as special category data) means information related to personal data revealing racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic data; biometric data (where used for identification purposes); data concerning health; data concerning a person’s sex life; and data concerning a person’s sexual orientation.
Please note that we do not knowingly or intentionally collect sensitive personal data or information about criminal convictions from individuals and that you should not submit sensitive data to us.
If, however you do submit sensitive data to us, such as if you make this sensitive data available to other users of the Services (such as by publishing it through any forum feature we may make available from time to time) we will assume that you have purposefully made any such sensitive data manifestly public.

HOW YOUR PERSONAL DATA IS COLLECTED
We collect personal data from you directly when you sign up to the Services, contact us directly or reach out to us via social media, make submissions via the Services when a forum element is available, or indirectly, such as your activity while using the Services.
At this point in time, we do not collect any personal information about you using cookies or similar technologies. In the event that this were to change and if we were to decide to collect personal data about you using cookies, you would be notified of this change by means of in-app notification, with detailed information regarding our use of cookies and similar technologies to be made available in the relevant cookies policy.

HOW AND WHY WE USE YOUR PERSONAL DATA
Under data protection law, we can only use your personal data if we have a proper reason, e.g.:
(i) where you have given consent
(ii) to comply with our legal and regulatory obligations
(iii) for the performance of a contract with you or to take steps at your request before entering into a contract, or
(iv) for our legitimate interests or those of a third party
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).
The table below explains what we use your personal data for and why.

What we use your personal data for	Our reasons
Create and manage your account with us	To perform our contract with you or to take steps at your request before entering into a contract
Providing services and/or the functionalities of the Services to you	Depending on the circumstances to perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions of Use which apply to the Services)
To enforce legal rights or defend or undertake legal proceedings	Depending on the circumstances: · to comply with our legal and regulatory obligations · in other cases, for our legitimate interests or those of a third party, i.e. to protect our business, interests and rights or those of others
Communications with you not related to marketing, including about changes to our terms or policies or changes to the Services or service or other important notices	Depending on the circumstances: · to comply with our legal and regulatory obligations · in other cases, for our legitimate interests or those of a third party, i.e., to provide the best service to you
Protect the security of systems and data	To comply with our legal and regulatory obligations we may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests or those of a third party, i.e., to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us
Operational reasons, such as improving efficiency, training, and quality control or to provide support to you	For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service to you
Statistical analysis to help us manage our business, e.g., in relation to our performance, customer base, app and functionalities and offerings or other efficiency measures	For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you and improve and develop our app
Updating and enhancing user records	Depending on the circumstances: · to perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions of Use which apply to the Services) · to comply with our legal and regulatory obligations · where neither of the above apply, for our legitimate interests or those of a third party, eg making sure that we can keep in touch with our customers about their accounts and new products or functionalities related to the Services and our services
To comply with our legal and regulatory obligations	Depending on the circumstances: · to perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions of Use which apply to the Services) · to comply with our legal and regulatory obligations where neither of the above apply, for our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about their accounts and new products or functionalities related to the Services and our services
To share your personal data with members of our group and third parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency. In such cases information will be anonymised where possible and only shared where necessary	Depending on the circumstances: · to comply with our legal and regulatory obligations · in other cases, for our legitimate interests or those of a third party, i.e., to protect, realise or grow the value in our business and assets

See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.

MARKETING
We intend to send you email marketing to inform you of our services such as promotions.
We will always ask you for your consent before doing sending you marketing communications, except where you have explicitly opted-in to receiving email marketing from us in the past or except where you were given the option to opt-out of email marketing when you initially signed up for your account with us and you did not do so.
You will have the right to opt out of receiving marketing communications at any time by:
• contacting us at info@investinplay.com
• using the ‘unsubscribe’ link included in all marketing emails you may received from us
We will always treat your personal data with the utmost respect and never sell or share it with other organisations for marketing purposes.
For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.

WHO WE SHARE YOUR PERSONAL DATA WITH
We routinely share personal data with service providers we use to help us run our business or provide the services or functionalities in the Services, including developers and cloud storage providers.
We only allow service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.
We or the third parties mentioned above may occasionally also need to share your personal data with:
 external auditors, e.g. in relation to the audit of our accounts and our company —the recipient of the information will be bound by confidentiality obligations
 professional advisors (such as lawyers and other advisors)—the recipient of the information will be bound by confidentiality obligations
 law enforcement agencies, courts or tribunals and regulatory bodies to comply with legal and regulatory obligations
 other parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
We will not share your personal data with any other third party.

HOW LONG YOUR PERSONAL DATA WILL BE KEPT
We will keep your personal data for as long as you have an active account with us and for a period of up to 6 years thereafter to comply with any accounting or legal obligations including in the event of the pursuit or defence of legal claims. Once you have closed your account with us, we will move your personal data to a separate database so that only key stakeholders in our business on a ‘need to know basis’ have access to such data.
Following the end of the of the aforementioned retention period, we will delete or anonymise your personal data.

TRANSFERRING YOUR PERSONAL DATA OUT OF THE UK
We may transfer your personal data outside the United Kingdom (UK) and European Economic Area (EEA). Where we transfer your personal data outside of the UK and the EEA, we will only do so for the purposes mentioned in this Policy and any contract that we have entered into with you or the entity that you are representing.
Countries outside of the UK and the EEA do not have the same data protection laws as the UK and EEA. Therefore, when making such a transfer of data, we will always rely on a safeguard mechanism under the UK GDPR and/or the EU GDPR. We will only transfer your personal data to a country which the European Commission or the UK authorities have given a formal adequacy decision/regulation that confirms this third-country provides an adequate level of data protection similar to those which apply in the UK and EEA. If the third-country does not have an adequacy decision awarded to it, any transfer of your personal information will be subject to entering into the European Commission’s Standard Contractual Clauses (the SCCs) which are designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal data.
Transfers of personal data from the UK to the EEA shall be done on the basis of the adequacy regulation awarded to the European Union by the UK pursuant to the withdrawal of the UK from the European Union which was granted in June 2021.
If you would like further information please contact us using the details provided at the end of this Policy. We will not otherwise transfer your personal data outside of the UK and the EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.

YOUR RIGHTS
You generally have the following rights, which you can usually exercise free of charge. For more information regarding these rights, please visit the ICO website here.

Access to a copy of your personal data	The right to be provided with a copy of your personal data.
Correction (also known as rectification)	The right to require us to correct any mistakes in your personal data.
Erasure (also known as the right to be forgotten)	The right to require us to delete your personal data—in certain situations.
Restriction of use	The right to require us to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data.
Data portability	The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations.
To object to use	The right to object: · at any time to your personal data being used for direct marketing (including profiling) · in certain other situations to our continued use of your personal data, e.g. where we use you personal data for our legitimate interests.
Not to be subject to decisions without human involvement	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you We do not make any such decisions based on data collected by the Services.

For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.
If you would like to exercise any of those rights, please complete a request form—available on our website at [insert link] or email , call or write to us—see below: ‘How to contact us’. When contacting us please:
o provide enough information to identify yourself (e.g., your full name and username) and any additional identity information we may reasonably request from you, and
o let us know which right(s) you want to exercise and the information to which your request relates

KEEPING YOUR PERSONAL DATA SECURE
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

HOW TO COMPLAIN
Please contact us if you have any queries or concerns about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with the Information Commissioner.
The Information Commissioner can be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113.

CHANGES TO THIS PRIVACY POLICY
We may change this privacy policy from time to time. When we make significant changes we will take steps to inform you, for example via the Services or by other means, such as email.

HOW TO CONTACT US
You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details are shown below:

Invest In Play, Adamson House, Towers Business Park, Wilmslow Road, Didsbury, Manchester, M20 2UL, UK
info@investinplay.com
+44 7737 058965

COOKIES POLICY

Please read this cookie policy carefully as it contains important information on who we are and how we use cookies on our Services. This policy should be read together with our Privacy Policy which set out who we are, how to contact us, what data is collected, how and why we collect, store, use and share personal information generally, as well as your rights in relation to your personal information and details of how to contact us and supervisory authorities if you have a complaint.

COOKIES
A cookie is a small text file which is placed onto your device (e.g. your smartphone or other electronic device) when you use our Services. When we use cookies on our Services, you will always be informed by a pop-up within the Services.
Cookies help us to recognise you and your device and allow us to store some information about your preferences or past actions, including your location data (for more information, please see our Privacy Policy).
For example, we may monitor how many times you use our Services, which parts of the Services you go to, location data. This information helps us to understand use of the Services by our users. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually.
For further information on our use of cookies, including a detailed list of your information which we and others may collect through cookies, please see below.
For further information on cookies generally, including how to control and manage them, visit the guidance on cookies published by the UK Information Commissioner’s Office, www.aboutcookies.org or www.allaboutcookies.org.

CONSENT TO USE COOKIES AND CHANGING SETTINGS
We will ask for your consent to place cookies or other similar technologies on your device, except where they are essential for us to provide you with a service that you have requested (e.g. to allow you to remain logged-in to the Services as you navigate within the Services and use the Services functionalities).
You can withdraw any consent to the use of cookies or manage any other cookie preferences by using the tool made available to you within the Services itself. You can then adjust sliders or untick boxes as appropriate to reflect your choice. It may be necessary to refresh or restart the Services for the updated settings to take effect.

OUR USE OF COOKIES
The table below provides more information about the cookies we use and why:

The cookies we use	Name	Purpose	Whether cookie is essential for us to provide you with a service that you have requested and whether we will seek your consent before we place the cookie
Session Cookie	Persistent Cookie	Session cookies are used to store authentication credentials during a browsing session. This allows the user to navigate the website without having to log in again for each page they visit. This also allows the user to return to the website after a session without having to re-authenticate.	This cookie is essential to provide the service. We will always seek consent before placing the cookie.

The cookies we use

Name

Purpose

Whether cookie is essential for us to provide you with a service that you have requested and whether we will seek your consent before we place the cookie

Session Cookie

Persistent Cookie

Session cookies are used to store authentication credentials during a browsing session. This allows the user to navigate the website without having to log in again for each page they visit. This also allows the user to return to the website after a session without having to re-authenticate.

This cookie is essential to provide the service. We will always seek consent before placing the cookie.

HOW TO TURN OFF ALL COOKIES AND CONSEQUENCES OF DOING SO
If you do not want to accept any cookies, you may be able to change your device settings so that cookies (including those which are essential to the services requested) are not accepted. If you do this, please be aware that you may lose some of the functionality of our Services and of other Services you use on your device. For further information about cookies and how to disable them please go to the guidance on cookies published by the UK Information Commissioner’s Office, www.aboutcookies.org or www.allaboutcookies.org.

CHANGES TO THIS POLICY
This policy was published on 1st April 2023 and last updated on 1st April 2023. We may change this cookies policy from time to time, when we do we will inform you via the Services or by sending an email to the email address you provided when you signed up to the Services.