Privacy Notice

Overview

Below you will find our Privacy Notice 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 Notice. 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 Notice below.

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:

 

Introduction

This Privacy Notice applies to our websites, applications, goods and services that link to this policy or which do not have a separate privacy notice. The purpose of this Privacy Notice is to provide you with information about how we use your personal data. This Privacy Notice 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 NSX Betfair Brasil S.A, Av. Paulista 352 room 76, District Bela Vista Sao Paulo 01310-905 Brazil.

This is who we refer to in this Privacy Notice when saying Betfair Brasil 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 dataprotection@betfairint.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 Notice 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, Flutter Studios, Timeform, Sportsbet, BetEasy, FanDuel, TVG, Adjarabet, Sky Betting and Gaming, Maxbet, PokerStars, Junglee, Singular, Sisal, and FOX Bet.

 

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 and betting 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 Notice.

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, 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:

Purpose

Category of Data

Lawful Basis

To set-up, administer and manage your user account

Identity and verification data, Image, photo or video

Necessary to comply with a legal or regulatory obligation

 

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, Device and internet identifier

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, Messages

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, Messages, Image photo or video

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

Necessary for the performance of a contract

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 other 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, Messages

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, Location data

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

Consent

 

Legitimate interest to provide you with advertisements

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 Notice 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 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: