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Last updated on June 24, 2022.

 

 

1. Introduction

 

The Fresh8 Gaming, part of the Sportradar group, respects your privacy and is committed to protecting your personal data. This privacy policy (“Privacy Policy“) governs the Fresh8 Gaming use of personal data collected by us. The definition of personal data may vary from country to country. To ensure the protection of your personal data, we define it as any information that may directly or indirectly identify you.

 

Your data protection rights, includes the ‘Right to Object’ to Fresh8 Gaming collecting and processing your personal data, so long as the right applies in the context of the purposes and legal ground for which we are collecting and processing your personal data.

 

To exercise your Right to Object, please complete this form, and we will normally revert back to you within one calendar month.

 

 

2. Who we are and what we do

 

Fresh8 Gaming PO BOX 484, Teddington, United Kingdom, TW11 1DU (“Fresh8 Gaming“, “our“, “we” or “us“) is the data controller of your personal data under this Privacy Policy with which you had, have or will have a business relationship.

 

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Fresh8 Gaming, part of Sportradar Group, is an international company that prides itself on providing the marketing automation platform for the sports betting industry to automatically connect sports fans with personalised bets. We provide solutions to create powerfully personalised advertising at scales in minutes, to automate the delivery of the real-time creative changes across multiple channels and to leverage the power of machine learning to deliver the right message, to the right person, at the right time, with the best creatives.

 

3. Personal Data That We Collect and Purposes for Processing

 

The types of personal data that we collect may vary depending on the purposes for which we collect it. For each type of situation when we collect personal data about you, we have explained below what personal data we collect and why.

 

Visitors of our Website

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When you visit and interact with our website, we collect and process personal data about you in order to:

• improve your experience when browsing our website,

• to analyse how you navigate our website,

• to keep you informed about any changes or updates to our terms and conditions, privacy and cookie notices or any other matter that may be relevant to you,

• fraud detection and prevention.

 

In order to achieve these purposes, we collect and process the following personal data about you:

• IP address,

• Cookie ID,

• Browser type,

• Operating system,

• Whether java script is supported,

• information on how you use our website (e.g. the web pages visited by you on our website),

• information on how you interact with our interactive features and respective contents.

 

 

Third Party Users

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The Internet “works” because of advertising. It is the way many websites generate the income they need to function. Our main business is to place display advertising on behalf of companies and their brands (the advertisers) on websites that sell advertising space. Our aim is to make the advertising you see relevant and useful to you. This is known as “behavioural advertising”.

 

To increase the relevance of the advertising we place, we use personal data that we have collected or have received to make informed predictions. To make the advertisement useful and or relevant to you, we process the following personal data:

• IP address,

• Cookie ID,

• Approximate (not precise) geolocation,

• Language,

• Browser type,

• Browser local,

• Operating system,

• Other usage information that may be considered as personal data.

 

If you would like to know more about the data our partners and clients collect and process, please consult the privacy notice on the website where our advertisement was displayed.

 

Business Partners

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We process certain personal data about you as a business partner for the following purposes:

• when you sign up for Fresh8 Gaming products and services on behalf of our business partners and clients.

• to respond to your questions and requests,

• to provide you with access to certain functions and features of our services and products,

• to verify your identity,

• to communicate with you about your account and our services and products.

 

For this reason we process the following personal data:

• Name and surname,

• Email address.

 

4. Sensitive Personal Data and Children’s Personal Data

 

The definition of sensitive personal data varies from country to country. Fresh8 Gaming considers sensitive personal data to be, including but not limited to, any information about you that reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs and trade union membership in addition to data concerning your health, genetic and biometric information, sex life or sexual orientation or citizenship and immigration status. Fresh8 Gaming is not knowingly or intentionally collecting any sensitive personal data.

 

Please note that the definition of “children” is subject to local and national laws and may vary accordingly. As such, based on the information available to Fresh8 Gaming, we do not knowingly or intentionally collect and process children’s data in the context of any of the products and services we offer.

 

If you believe we have inadvertently collected children’s personal data, please contact us at: privacy@sportradar.com. We will then delete the personal data as soon as possible.

 

5. Legal Bases for Processing

 

In order to achieve purposes for processing as explained in Section 3 of this Privacy Policy, we rely on multiple legal bases, depending on purposes which with the data was collected.

 

Visitors of Our Website

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Our legal bases for the for processing of personal data about visitors of our website for the purposes mentioned in the Section 3., Subsection Visitors of Our Website, we rely on the following legal bases:

 

• Consent

We process personal data based on your consent where this is explicitly stated at the moment of collection – for example, where you have provided your consent for the use of analytics cookies to show advertisements. Please note that you may withdraw your consent at any time.

 

• Contract
  Please note that the processing of your personal data is necessary for a contract we have with you and in order to perform our obligations under such contract.

 

• Compliance with legal obligations
  To comply with legal obligations as well as to establish, exercise, or defend ourselves from legal claims.

 

• Our legitimate interests

We rely on the legitimate interest ground when we process your personal data for the purposes of (i) analyzing the performance of our websites and understanding how you and our other users use them in order to improve their performance and your online experience; (ii) keeping you informed about any changes or updates to our terms and conditions, privacy and cookie notices or any other matter that may be relevant to you; and (iii) fraud detection and prevention.

 

Please note that Fresh8 Gaming only relies on the legitimate interests ground if the reason for processing your personal data is fair and lawful. Where we want to rely on legitimate interests as a legal basis for processing, we will carry out a balancing test between our legitimate interests and your privacy rights.

 

The legal grounds for processing your personal data vary according to the circumstances and context for the collection. We do not process your personal data without a legal justification.

 

 

Third Party Users

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When processing personal data for advertising purposes, legal bases are mainly determine by our clients acting as data controllers. For more information about their legal bases, please consult the privacy notice on the website where our advertisement was displayed.

 

In cases where Fresh8 Gaming is acting as data controller for advertising purposes, the personal data is always collected from our partners’ website. In any case, Fresh8 Gaming is relying either on consent or legitimate interest as legal basis:

 

• Consent

We process personal data based on your consent where this is explicitly stated at the moment of collection – for example, where you have provided your consent for the use of analytics cookies to show advertisements. Please note that you may withdraw your consent at any time.

 

• Our legitimate interests

We rely on the legitimate interest ground when we process your personal data for the purposes of (i)

 

Please note that Fresh8 Gaming only relies on the legitimate interests ground if the reason for processing your personal data is fair and lawful. Where we want to rely on legitimate interests as a legal basis for processing, we will carry out a balancing test between our legitimate interests and your privacy rights.

 

The legal grounds for processing your personal data vary according to the circumstances and context for the collection. We do not process your personal data without a legal justification.

 

 

Business Partners

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Fresh8 Gaming’s lawful basis for processing personal data of Business Partners may be:

 

• Consent

We process personal data based on your consent where this is explicitly stated at the moment of collection.

 

• Contract

Please note that the processing of your personal data is necessary for contract we have with and in order to perform our obligations under such contract.

 

• Legitimate interest

When we collect and process the personal data on the basis of “legitimate interest”, it is to provide you with information about Fresh8 Gaming’s products and services that might be of interest to you.

 

6. Cookies

 

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This policy does not expressly deal with cookies and web-beacons and how we use them. For more information about how we use cookies and the detailed list of cookies we use, please see our Cookie Policy.

 

7. How we share your personal data

 

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We share your personal only in exceptional cases and for the following purposes:

• with subcontractors and other trusted third-party providers or partners,

• withing the family of Sportradar Group companies for internal reasons, primarily for business and operational purposes, as well as to their subcontractors or other trusted third parties,

• if we go through a business transformation, such as merger, acquisition by another company, or sale of all or a portion of our assets, your personal data will likely be among the assets transferred,

• when legally required to do so (e.g. to cooperate with law enforcement investigations or other legal proceedings).

 

In case of subcontractors and other trusted third-part recipients, we share your personal data with them for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, hosting and server providers, ad networks, analytics, error loggers, debt collectors, maintenance or problem-solving providers, marketing or advertising providers, professional advisors and payment systems operators.

 

 

8. Data Transfers outside of the EU/EEA

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If your personal data is collected within the EU/EEA and transferred to countries outside the EU/EEA in which applicable laws do not offer the same level of data protection, we ensure similar protection and put in place, for example, one of these safeguards:

• we will transfer your personal data to countries that have been found to provide an adequate level of protection for personal data;

• we may also use specific approved contracts with our partners that are based in countries outside the EU/EEA. These contracts give your personal data the same protection it has in the EU/EEA;

Should you require further information regarding the relevant transborder dataflow safeguards that we have implemented, then please reach out to us at privacy@sportradar.com

 

9. How long we keep your personal data

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Fresh8 Gaming maintains robust data retention policies for the personal data we process. In instances where Fresh8 Gaming is a ‘’data controller’’, we delete all data after the purposes for which it has been collected are fulfilled (including for the purposes of satisfying any legal requirements).

 

In any event, the necessity to retain data is assessed by each business unit (in liaison with our dedicated Privacy Team) and takes into account the legal and business purposes relevant to the processing of that data and whether we can achieve those purposes through other means, the applicable legal requirements, the amount, nature and sensitivity of the personal data, and the potential risk of harm from unauthorised use or accidental disclosure of your personal data.

 

For the retention period for each of the cookies Fresh8 Gaming uses, please see our Cookie Policy.

 

10. What data protection rights you have

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You have the following data protection rights:

• Right to Access

You have the right to obtain from us a confirmation as to whether we process your personal data. Should we process your personal data, you have the right to request access to your personal data and to obtain further information regarding the processing of your personal data.

 

• Right to Rectification

You have the right to have your personal data rectified in the event that it is inaccurate. You can also rectify some of your personal data by reviewing and changing the personal data from your account settings.

 

• Right to Erasure

Under certain circumstances, you have the right to request that we delete your personal data.

 

• Right to Restriction of Processing

Under certain circumstances, you have the right to restrict the processing of your personal data.

 

• Right to Object to Processing (Right to Opt-Out)

Under certain circumstances, you have the right to object to the processing of your personal data. You can exercise your right, by completing this form.

 

• Right to Data Portability

You have the right to obtain your personal data in a structured, commonly used and machine-readable format and to have your personal data transferred to another controller, where technically feasible and insofar as the processing of your personal data is based on your consent or is necessary for the performance of a contract between us.

 

• Right not to be Subject to a Decision Based Solely on Automated Processing, Including Profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

 

• Right to Complain To a Supervisory Authority

Should you believe that we have violated any applicable data protection laws when processing your personal data, you have the right to file a complaint with the responsible Data Protection Authority.

 

• Right to Withdraw Consent

You may withdraw your consent to the processing of your personal data insofar as the processing is based on your consent. This does not apply if the processing of your personal data is required for the performance of a contract between us or if the processing is based on our legitimate interests.

 

We reserve the right to refuse to give effect to a request to exercise any of the above data protection rights if we are unable to ascertain your identity.

 

Since Fresh8 Gaming is part of the Sportradar Group, the details of the lead Data Protection Authority that Sportradar Group is registered with is as follows:

 

Austrian Data Protection Authority

 

Österreichische Datenschutzbehörde

Barichgasse 40-42,

1030 Vienna

Austria

Telephone: +43 1 52 152-0

E-Mail: dsb@dsb.gv.at

 

 

11. Security of your personal data

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Fresh8 Gaming has implemented appropriate technical and organisational measures to ensure a level of security appropriate to the risk involved in order to protect your personal data against a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, your personal data transmitted, stored or otherwise processed.

Our employees are required to keep personal data confidential. We will only transfer your personal data to third parties as described in Section 8 (Data Transfers outside the EU/EEA) of this Privacy Policy.

 

12. Do Not Sell or Share My Personal Information (APPLICABLE ONLY IF YOU ARE A RESIDENT OF THE STATE OF CALIFORNIA (CALIFORNIA CONSUMER))

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The California Consumer Privacy Act (CCPA) gives residents of the US State of California (California consumers) the right to prevent businesses from selling their personal information. If you would like to opt out of any sale of your personal information, please click on the link ‘Do Not Sell or Share Personal Information’ in the footer of our Website to record your preference or exercise your right via this form.

 

13. How this Privacy Policy May Change

 

This Privacy Policy was published on June 24, 2022.

 

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Please note that this Privacy Policy shall be updated at least once every 12 months. We will place a prominent notice that will be visible on our websites and/or Apps. You should check back here periodically to see if the Privacy Policy has been updated. We will always show the date of the latest modification of the Privacy Policy at the top of the page so you can tell when it was last revised

 

14. How to contact us

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Should you have any questions regarding the processing of your personal data or should you wish to exercise your rights under this Privacy Notice, please submit your request via this form or contact our Data Protection Officer by using the contact details provided below:

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Mr. Stefano Celardo
Sportradar GmbH
Donau-City-Strasse 1, floor 16
1220 Vienna
Austria

Email: privacy@sportradar.com

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[APPLICABLE ONLY IF YOU ARE A RESIDENT OF THE STATE OF CALIFORNIA (CALIFORNIA CONSUMER)]

In addition to the methods available above for exercising any of your rights, please note that you can submit a verifiable request also by calling us at 1 888 297 1323 (toll-free).