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Privacy Policy

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The Company respects your privacy and is committed to protecting it through our compliance with this Privacy Policy

This Privacy Policy (together with our Terms & Conditions) sets out the basis on which any personal data you provide to us, will be processed.

INFORMATION WE COLLECT ABOUT YOU

Personal Data

As permitted by applicable law, we may collect, use, store and transfer different kinds of Personal Data about you when you use our services. We have grouped these into the following categories of Personal Data:

Identity Data such as first name, last name, Social Media profile, username, Contact Data such as billing addresses, email addresses and telephone numbers

Transaction Data such as details regarding offers you have signed up to or services that you have subscribed to in relation to this Website

Technical Data such as your Device IDs, your login data, access dates and times, browser type and version, device information, cookie data, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Website

Usage Data such as information about how you use our Website, products and services

Marketing and Communications

Data such as your preferences in receiving marketing from us and our third-parties

We do not require any special categories of personal data about you (e.g. religion, race, ethnic origin, politics, genetics, health, sexual orientation). Please do not provide this type of personal data to us.

Non-Personal Data

We also collect, use and share Aggregated Data such as statistical or demographic data which does not directly or indirectly reveal your identity. We use aggregate data for analysing our website usage, for example, to calculate the percentage of users accessing a specific feature on our website.

HOW YOUR DATA IS COLLECTED

Directly

You may give us your identity, contact, financial, profile data, and marketing and communications data by filling in a form or corresponding with us by post, phone, e-mail or otherwise. This includes Personal data you provide when you:

Create an account on our Website

  • Choose your marketing preferences for email, SMS, Post and Push notifications
  • Raise a ticket on the HelpDesk
  • Give us feedback
  • Speak with or email Support
  • Request information be sent to you

Indirectly

We may collect your transaction data, technical data and usage data when you interact with our Website.

We collect this Personal and Non-Personal Data by using cookies, server logs and other similar technologies.

We may receive this data from various third-parties such as analytics providers or advertising networks.

We may also receive Technical Data and Usage Data about you if you visit other websites employing our cookies or Tracking Technologies (defined below).

For more information regarding our use of Tracking Technologies, please refer to Section 10: Cookies and Similar Technologies below.    

HOW WE USE YOUR DATA

We will only use your Personal Data where permitted by law. The law on data protection sets out several different reasons for which a company may collect and process your personal data, including:

Consent: In specific situations, we collect and process your data with your consent. For example, when we rely on your consent to send you direct marketing by email or via push notifications on your device. We collect your consent when applicable laws require it (including but not limited to the Privacy and Electronic Communications (EC Directive) Regulations 2003 & The EU General Data Protection Regulation). Where we rely on your consent to use your personal data, you have the right to withdraw your consent at any time. You can do this by contacting us at dpo@fruityfreespins.com

If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Performance of a Contract: In certain circumstances, we need your personal data for the performance of a contract to which you are a party.

Legal Obligation: If the law requires us to, we may need to collect and process your data. For example, we can pass on details of people involved in fraud or other criminal activity.

Legitimate Interest: This is when we have an interest in conducting and managing our business, to enable us to give you the best experience when using the Website, products, and services. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

In the table below, we have described (i) in what context your personal data was collected, i.e., what activity you were involved in when we collected or used your personal data; (ii) the types of personal data that we hold about you; (iii) how and why we use your personal data; and (iv) what our legal basis is for using your personal data.  

SECTION 5: DISCLOSURE OF YOUR DATA

We require all parties who process your data to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purpose and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Internal Parties

Employees of The Company and The Group will process your data when you need to speak to the customer service team or our Data Protection Officer. Access to your Personal Data will be controlled and only granted where necessary to provide our services to you and/or allow us to perform any necessary or legitimate functions.

Other companies within The Group will process your data. Access to your Personal Data from companies within The Group will be controlled and only granted where necessary to provide our services to you and/or allow us to perform any necessary or legitimate functions.

External Parties

Service providers who process your Personal Data on our behalf to support our business and help provide our services to you. These include, but are not limited to, our Email Service Provider (ESP) Get Response, push notification provider One Signal, our data validation provider Kickbox, SMS supplier Text Local and our data warehouse supplier, Google’s Big Query.  

Fraud prevention and identity verification services where we believe that disclosure is necessary or appropriate to protect the rights, property, or safety of The Company, our customers or others.

Professional advisers such as lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance, financial, auditing, and accounting services to us so we can operate our business.

Third-parties where you have expressly consented to the disclosure of your Personal Data.

Law enforcement agencies, courts, supervisory authorities, regulatory bodies and related third-parties, to the extent that we are permitted or required to do so by law, or in order to comply with our legal and regulatory obligations, or in the interests of national security, or to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity.

From time-to-time, we may run contests, special offers, or other events or activities with a third-party sponsor. If you provide information to the third-party, you give them permission to use it for the purpose of that promotion. We cannot control the use of your Personal Data after you have submitted it to the third-party. If you do not want your information to be processed by the third-party, you can choose not to participate in the promotion.

Parties we do not transfer your data to

Our Website contains links to third-party websites. You will click on these to complete offers and take part in promotions. Please note, if you follow a link to any such website, we do not accept any liability or responsibility, because these websites have their own Terms & Conditions and Privacy Policies.

We do not transfer your data to these third-parties but to improve your user experience, when you click on a third-party offer and are transferred to the third-party website, we may have access to anonymised Transaction data related to your activity on the third-party website. 

Where in the world your data is transferred

The Company and The Group are headquartered in the UK. The information that you provide or that we collect as a result of your interaction with the Website and/or the user of the Services will be transferred to parties located within the EU that have been recognised by the European Commission as providing an adequate level of data protection. When transfers take place to countries outside of this consideration, we have put in place measures, including ensuring the recipient is bound by EU Standard Contractual Clauses, to protect your Personal Data.

Where any Personal Data is transferred to the USA, we also rely on the EU-US Privacy Shield Frameworks (“Privacy Shield”) to ensure recipients adhere to the Privacy Shield Principles.

HOW LONG YOUR DATA IS KEPT

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means. 

In some circumstances, we may anonymise your Personal Data so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you no longer have a relationship with us, we will retain and securely destroy your Personal Data subject to the foregoing and in accordance with applicable laws and regulations. If you request to receive no further contact from us, we will keep some basic information about you on our suppression list in order to avoid sending you unwanted materials in the future.

YOUR DATA SUBJECT RIGHTS

How to make a request

If you would like to exercise any of the data subject access rights in the table above (each, an “Access Request”) please send an email to offers@fruityfreespins.com. We will respond to your request without undue delay and no later than one month.

You will be required to pay an administrative fee of £10 but you will not usually be required to pay more than that to exercise your rights unless your request is manifestly unfounded or excessive.

We may need to confirm your identity before fulfilling your request and ensure your right to access your Personal Data (or exercise other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it.

If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can make a complaint to the relevant Supervisory Authority. In the UK this is the Information Commissioner’s Office (ICO). You can contact the ICO through their website: https://ico.org.uk/concerns/ or by telephone: 0303 123 1113.

UNSUBSCRIBE OR DELETE YOUR ACCOUNT

If you have registered on out website, you can unsubscribe from marketing emails by clicking the ‘unsubscribe’ link at the bottom of our emails. Please allow up to 48 hours for changes to take effect. When you unsubscribe we will store your name and email address on a separate database to ensure we do not contact you again. Unsubscribing will not delete your personal data. If you wish to exercise your right to erasure (“be forgotten”), please contact our Data Protection Officer at offers@fruityfreespins.com  To unsubscribe from the Company’s push notifications, please follow the advice given by One Signal, our push notification provider, here: https://documentation.onesignal.com/docs/unsubscribe-from-notifications. Push notifications will only ever come from The Company and not third parties. You are free to opt-out of push notifications at any time.

SECTION 9: SECURITY AND STORAGE OF YOUR PERSONAL DATA

We use appropriate technical and organizational measures to protect Personal Data we process about you. However, no transmission of information via the Internet or wireless network can be guaranteed to be 100% secure.  As a result, while we strive to protect your Personal Data, you acknowledge that there are security and privacy limitations of the Internet which are beyond our control and accordingly, the security, integrity and privacy of data exchanged between you and us through the Website cannot be guaranteed.

We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. If you believe that your access credentials or Personal Data have been compromised, please contact us immediately.  

SECTION 10: COOKIES AND SIMILAR TECHNOLOGIES

The Company uses cookies on our Websites to provide you with the best experience when you browse our website and to improve our site and its contents. By continuing to browse the site, you are agreeing to our use of cookies.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Other storage technologies you may come across include web beacons and pixels. A web beacon is an often-transparent graphic image that is placed on our website or in an email that is used to monitor the behaviour of users visiting our sites or receiving our emails. Web beacons are usually used in conjunction with cookies to check that you can see our content. A pixel refers to the code that is placed on our website that triggers a cookie. A pixel is essentially an image but instead of calling an image to be displayed, it calls an application on a media buying platform that will cause a cookie to be downloaded to your browser if your browser settings allow.

To find out how to opt-out of the collection and use of your information via storage technologies, see our section below on Blocking or Declining Cookies.

For further information about behavioural advertising, cookies and other storage technologies, and the steps you can take to protect your privacy online visit http://optout.aboutads.info/?c=2#!/ or http://www.youronlinechoices.eu/

We use the following cookies:

Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to register your contact details on a Website.

Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users find what they are looking for easily.

Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Strictly Necessary Cookies

These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.

Cookies used:

Performance Cookies

These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site.

All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.

Cookies used:

Targeting Cookies

These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites.

They do not store directly personal information but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising but equally, you will not be able to experience the site fully.

Cookies used:

BLOCKING OR DECLINING COOKIES

Depending on your browser, you can configure your web browser to delete and/or block the use of cookies. We have provided some links to the more commonly-used browsers below. Please click on the appropriate browser link for instructions on how to manage cookies:

For further information about behavioural advertising, cookies and other storage technologies, and the steps you can take to protect your privacy online visit http://www.youronlinechoices.eu/. If you wish to opt-out of any interest-based advertising visit https://preferences-mgr.truste.com/. Please note, you will continue to receive generic ads.  

UPDATES TO THIS POLICY

In the event of updates to our service that materially expand the sharing or use of your personal information in ways not already disclosed to you, we will notify you by email and update this privacy policy accordingly. We will gain your consent for processing activities where necessary.  

CONTACT INFORMATION

  Last updated 18.11.20

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