LEGAL
A. PRIVACY POLICY
B. SAFEGUARDING PRIVACY POLICY
A. PRIVACY POLICY
In this Privacy Policy, terms such as "we", "us, "our" or similar expressions shall mean the SimPlay Ltd.
We take your privacy very seriously and are committed to protecting your personal data (meaning any information about you from which you can be identified). This Privacy Policy explains what personal data we collect when you: access the SimPlay fantasy Football App and websites at https://www.simplayfantasyfootball.com (regardless of where you visit it from), use the SimPlay fantasy Football App; play the SimPlay fantasy Football game, engage with the SimPlay Ltd (or we engage with your content) on social media platforms (including our Facebook, Twitter, YouTube and Instagram pages); and/or when you otherwise interact or communicate with us. It also explains how we may use this data, and what rights you have in relation to such data.
For information on how we collect, use and store personal data relating please refer to our Player Privacy Policy. We also have a separate Safeguarding Privacy Policy. Please read any other privacy notices which we may provide to you carefully, so that you are aware of and understand the ways in which we collect and use your personal data.
We keep our privacy practices under review and may change this Privacy Policy from time to time by posting changes on the Services or otherwise notifying them to you.
Please read this Privacy Policy carefully:
1. Background
We are a "controller" under the NDPR and other applicable data protection legislation (Data Protection Law). This means we are responsible for deciding how we use the personal data that we collect about you and, in accordance with the Data Protection Law, we will ensure that the personal data we hold about you is, at all times:
used fairly, lawfully, and transparently;
collected for limited, specific purposes only;
adequate, relevant to and limited to what is necessary for those purposes;
kept accurate and up-to-date;
not kept for longer than is necessary; and
held securely.
We shall be accountable for and able to demonstrate our compliance with our obligations under the Data Protection Law, and this Privacy Policy is one of the ways in which we do that.
In connection with some elements of the Services we also receive additional personal data about you from other organisations who have collected personal data from you. We may also receive personal data as part of the legal processes we undertake to protect our Services and our intellectual property, such as our brand or media rights, or those of our licensees/commercial partners. Each of these parties shall be a separate data controller in relation to the categories of data which it processes, and shall be accountable for its compliance with the Data Protection Law under its own privacy policy. For more information, please refer to Disclosure of your personal data below.
We have appointed a Data Protection Lead to oversee compliance with this Privacy Policy and our data protection compliance activities. The Data Protection Lead has also established a dedicated data protection team to provide the necessary support.
2. Personal Data We Collect About You
Personal data means any information about an individual from which that person can be identified. We may collect, store, transfer and use various types of your personal data:
Registration Data: To access and use some elements of the Services you must create a SimPlay Fantasy Football account by providing us with the information which is identified on the relevant registration page: name, email, gender, date of birth, and location (country/region of residence). We will also collect a username and password. Please note that some elements of the Services will not be available if you do not provide the required information. We may also ask or allow you to submit other optional information such as your mobile phone number.
Identity Data: We also ask you to provide identification information when we provide other elements of the Services: name, age, gender and social media handles/ usernames.
Contact Data: When we want to communicate with you, or you with us, we use your email address, telephone numbers, social media handles/ usernames and location (country/ place of residence).
Media Data: We use images from photographs and video footage of crowds and fans and other media content created by us (or on our behalf) matches and events or provided by you for our use. We may also use some of your user generated content in social media as further described below.
User Data: We collect your usage and preference details related to your use of the Services such as language, game-play statistics, scores, rankings, time spent playing, game profile, preferences (including favourite Clubs), survey responses, feedback and other data that you provide to us as part of your account.
Marketing and/or Communications Data: We retain your preferences in receiving marketing messages from us and our Clubs and commercial partners, and your communication preferences.
Technical Data: Certain data is automatically generated and collected by us when you use the Services such as your IP address, MAC address and other device identifiers; your clickstream to, through and from the Services (including date and time); pages you viewed or searched for; length of visits to certain pages; page interaction information (such as scrolling, clicks, and mouse-overs); methods used to browse away from the page.
Not all of the list above will necessarily apply to you - it depends on your use of the Services and your particular interaction and communications with us. Please refer to 4. HOW AND WHY WE USE YOUR PERSONAL DATA below.
Under the Data Protection Law, there are also “special categories” of more sensitive data about you such as details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientations, political opinions, trade union membership, information about your health and genetic and biometric data (“Special Category Data”) and personal data relating to criminal convictions and offences (“Criminal Offence Data”) which require a higher level of protection (collectively referred to in this Policy as “Sensitive Personal Data”). We do not regularly collect, use or store such Sensitive Personal Data but in some circumstances we may need to do so. Please refer to 4. HOW AND WHY WE USE YOUR PERSONAL DATA below and read our separate Safeguarding Privacy Policy, and any other privacy notices which we may provide to you carefully, so that you are aware of and understand the ways in which we collect and use your Sensitive Personal Data.
3. How We Collect Your Personal Data
You provide us with your personal data when you:
access, use or play the Services;
create a SimPlay Fantasy Football account for the Services;
request information, marketing and other communications to be sent to you;
enter a competition, promotion or survey;
complete surveys or provide us with your feedback; and
otherwise interact or correspond with us (including via email, social media or telephone).
In connection with some elements of the Services we also receive additional personal data about you from other organisations who have collected personal data from you and our commercial partners. We may also receive personal data as part of the legal processes we undertake to protect our Services and our intellectual property, such as our brand or media rights, or those of our licensees/commercial partners.
We collect the Technical Data automatically as you interact with our Services by using cookies and other similar web technologies.
We also use third party tools to help us manage and analyse our social media presence, and report on comments, mentions and other content that is posted about us on social media platforms and other public channels and forums. These third parties’ activities, and their information collection and sharing practices, are subject to the terms of the relevant social media platform, channel or forum. We will use this information in accordance with this Privacy Policy.
We use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to certain parts of the Services. This information is only used by us in a way which does not identify you. We do not make, and do not allow Google to make, any attempt to find out the identities of anyone visiting our website.
4. How and Why We Use Your Personal Data
We will only use your personal data where Data Protection Law allows us to. Data Protection Law says we can collect and use personal data on the following bases:
it is necessary for us to be able to perform an agreement with you.
it is necessary for our legitimate interests (and your interests and fundamental rights do not override those interests);
if we have your consent (which you can withdraw at any time); or
to comply with a legal obligation e. rules laid down by courts, statute or regulation.
Data Protection Law says we can only collect and use your Sensitive Personal Data where an additional basis applies: for reasons of substantial public interest, including when preventing or detecting unlawful acts or in connection with our regulatory and oversight functions in sport; in connection with legal claims; cases where you have made the data public yourself; or where you have given explicit consent.
Accordingly, we lawfully use your personal data in the following ways:
Delivering the Services: We use the Registration Data, User Data and Contact Data so that we can deliver the Services to you in an effective, efficient and accurate way. Without it, we would not be able to deliver a tailored service to you or respond to issues with these Services that are identified by us or you, or ensure you get the most out of your experience. Therefore, we use this data on the basis that it is necessary for us to be able to perform our agreement with you (i.e. the terms and conditions of the relevant Services) and for our legitimate interests of delivering the Services in this way.
Operating the Services: We use the Technical Data in order to operate and administer the Services including as necessary for testing, analysis, maintenance, support, reporting and hosting of data. Therefore, we use this data on the basis that it is necessary for our legitimate interests of operating the Services in this way. We also use Technical Data together with certain Identity Data and Contact Data to assist in security and fraud prevention, system integrity (such as preventing hacking, cheats and spam) and/or to facilitate our response to a legal process. Therefore, we use this data on the basis that it is necessary both for our legitimate interests in protecting the Services in this way and in order that we can comply with a legal obligation.
Competitions and promotions: We use Identity Data and Contact Data and any other personal data related to the entry (for example, a photograph) in order that we can administer and operate contests, prize draws, competitions or other promotions including selecting the winners, delivering the prizes and publishing the results (as required by Nigerian advertising regulations). Therefore, we use this data on the basis that it is necessary for us to be able to perform our agreement with you (i.e. the terms and conditions of the relevant promotion) and in order that we can comply with a legal obligation. If we want to use the personal data for any other purpose we will notify you and, if necessary, seek your consent at that time.
Marketing communications: We use the Identity Data and Contact Data to inform you of news, offers, events, competitions and promotions by specified media (including, if requested, by way of calendar notifications) which may be of interest to you and/ or our official commercial partners so that they can do this. We give you the option of providing opt-in consent to receive different kinds of direct marketing communications from us or these third parties or deciding not to do so.
OPT-ING OUT: You can withdraw your consent and opt-out of marketing communications from us at any time by updating your Email Preferences (where you have signed up to our website) or by following the instructions provided to you in the relevant communication (for example, the 'unsubscribe' link in an email). Alternatively, you may contact us at info@simplayfantasyfootball.com . We may still need to send service emails to you from time to time.
If you have chosen to receive communications directly from a commercial partner, you will be consenting to us passing the data to them to use in accordance with their privacy policy, to which we provide links on our website, so you should contact them directly if you no longer wish to receive their communications.
Other purposes: We might have to use your personal data to protect your or someone else's vital interests for example to make contact in rare emergency situations. We could also have to use your personal data in connection with legal and regulatory matters such as our maintenance of business records, compliance with external reporting requirements and internal policies and procedures and responses to requests by government, law enforcement, regulators, courts, rights holders or other third parties including in respect of the use or misuse of intellectual property, such as our brand or media rights, or those of our licensees/commercial partners or their parties. Therefore we use this data on the basis that it is necessary both for our legitimate interests in protecting, defending and enforcing rights and interests in this way and also so that we can comply with legal obligations. We may also use your personal data when we process Media Data as part of our dedicated reporting and take-down programme helping to fight serious abuse against players, coaching staff and their families in social media. We use this data for our legitimate interests in fighting abuse and, where Sensitive Personal Data is involved, in order to prevent or detect unlawful acts, in connection with legal claims and where you have made the data public yourself.
Before using your personal data for our legitimate interests, we make sure that we take into account any potential impact that such use may have on you to ensure that your interests and fundamental rights and freedoms do not override those interests. In other words, we have determined that we have a legitimate need to process your personal data and we are not aware of any reasons that, on balance, mean we should not be doing so. If you have concerns about our processing please refer to 10. YOUR RIGHTS below or contact us using the details here 12. CONTACT US.
Please also read our separate Safeguarding Privacy Policy which explain the basis of processing for the other purposes described within them.
We will only use your personal data for the purposes for which we collected it as described above, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
If you would like to find out more about the legal condition for which we process your personal information, please contact us using the details here 12. CONTACT US.
What if you do not want to share your personal data?
Unless otherwise specified above, generally we collect your personal data on a voluntary basis. However, please note that if you decline to provide certain mandatory personal data, you may not be able to access certain Services and we may be unable to fully respond to any inquiries you make.
5. Disclosure of Your Personal Data
We may disclose or share your personal data in the following circumstances:
Third Party Service Providers. We engage third party businesses to provide services to us or to you on our behalf, such as support for the internal operations of our Services (and related services), communications, data storage and delivering communications (including calendar notifications). Our service providers may access, receive, maintain or otherwise use personal data on our behalf. Our service providers only use your personal data in accordance with our strict instructions to provide the relevant services and are not permitted to use your personal data for their own purposes, unless authorised by us to do so. Where this is the case you will be notified by us and provided with their privacy policies so you can understand how they will treat your personal data.
Commercial Partners. We may also disclose your personal data to our commercial partners where you have consented or requested that we do so. For example, when you enter a competition or sweepstake which is a joint promotion, or you request to receive certain marketing communications. You will be given clear information in each case before we disclose share your personal data.
Publicity and media. We may disclose your personal data publicly via the media, social media or on the Services. For example, when sharing a comment or opinion you have provided, or if you win a competition or promotion we may disclose your name online. In such cases, we will clearly notify you of the sharing, and you will have the choice not to participate or to otherwise object to such sharing, subject to our other legal obligations.
Where you allow us to, we will share your personal data with our partners where for example it is necessary for the fulfilment of a competition. This Privacy Policy applies to our use of your personal data only.
Legally Required. We may also disclose your personal data if we believe we are required to do so by law, or that doing so is reasonably necessary to comply with legal processes or the enforcement of our rights where we receive evidence we deem sufficient to justify such disclosure or in the event of a re-organisation of the legal or ownership structure of SimPlay Fantasy Football.
Please read carefully any additional privacy notices which we may provide to you so that you are aware of and understand any other circumstances in which we may disclose or share your personal data which are specific to your use of the Services and/or your relationship with SimPlay fantasy Football.
Notwithstanding anything else in this Privacy Policy, we may share aggregate or de-identified information with third parties for research, marketing, analytics and other purposes, provided such information does not identify a particular individual and the individual cannot be re-identified.
6. Transferring Your Personal Data Outside Nigeria
Some countries outside of Nigeria do not have laws that protect privacy rights and personal data as extensively as Nigeria. We do not generally or routinely transfer personal data outside of Nigeria but some of the organisations to which we may disclose personal data may be situated outside of Nigeria. If we do transfer your personal data outside of Nigeria, we will take all necessary steps to ensure that transfers of your personal data are handled in accordance with this Policy and with the Data Protection Law. We do this by ensuring that such transfers are limited to countries which are recognised as providing an adequate level of legal protection by Nigeria or one of the specific safeguards approved by Nigeria is in place. In the event that there is any change in the law such that one or all of the safeguards are no longer valid or applicable, we will ensure that we are satisfied that alternative arrangements / safeguards are in place to protect your privacy rights as required by the Data Protection Law.
7. Security of Your Personal Data
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed (a Data Security Breach). In addition, we limit access to your personal data to those employees, contractors and other third parties who have a business need to know. They will only use your personal data on our instructions and they are subject to a duty of confidentiality. In relation to third party service providers whom we appoint to process your personal data on our behalf, we take steps to ensure that those service providers are contractually bound to protect your personal data.
We have put in place procedures to deal with any suspected Data Security Breach and will notify you and any applicable regulator where we are legally required to do so.
Where we have given you or you have chosen a password which enables you to access certain Services, you are responsible for using reasonable care in keeping this password confidential.
8. Links to Other Sites
The Services may contain links to other websites, applications and environments that are not owned or controlled by us (the Other Sites). The owners and operators of those Other Sites are responsible for their collection and/or use of your personal data and you should check their respective privacy policies. Unless specifically referred to otherwise, this Privacy Policy applies to the Services only and not the Other Sites.
9. Data Retention
We will generally only keep your personal data for as long as necessary to fulfil the purposes we collected it for (see 4. WHY WE USE YOUR PERSONAL DATA), in accordance with our internal Data Retention Policy. However, in some circumstances we may retain personal data for other periods of time, for instance where we are required to do so in accordance with legal, tax or accounting requirements, or if required to do so by a legal process, legal authority, or other governmental entity having authority to make the request.
To determine the appropriate retention period, we review - in addition to the purposes of use and how we can achieve them - other relevant factors such as the nature and scope of the personal data, the potential risks to data subjects from a Data Security Breach, and the applicable legal requirements, for example the limitation period for which legal claims can be made in court. For example, all non-activated SimPlay Fantasy Football accounts are deleted after 21 days
In accordance with our internal Data Retention Policy and the Data Protection Law, after the applicable retention period has ended, your personal data will be securely deleted or destroyed or anonymised (for example, where the data will be used in aggregated/generic form for statistical purposes).
Specific details of retention periods for different aspects of your personal data are available upon request by using the contact details provided below.
10. Your Rights
Under Data Protection Law, you have certain rights (depending on the circumstances) in connection with your personal data, which include:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are using it lawfully, provided always that this does not adversely affect the rights and freedoms of other people;
Request correction of the personal data that we hold about you. Where any of the information we hold about you is incorrect or incomplete we will act promptly to rectify this, including where you have requested us to do so. Users of the SimPlay Fantasy Football App can update their information any time via their account preferences;
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to use it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to our use (see below);
Object to use of your personal data where we are relying on our legitimate interests (see above) and there is something about your particular situation which makes you want to object to our use on this ground;
Withdraw your consent to our use of your personal data where we do so in reliance on your consent. Once we have received notification that you have withdrawn your consent, we will no longer use your personal data for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law;
Request the restriction of use of your personal data. This enables you to ask us to suspend the use of personal data about you, for example if you want us to establish its accuracy or the reason for using it; and
Request the transfer of the personal data you have provided, on the basis of consent or for a contract with us, to you or a third party where technically feasible.
We are committed to respecting your rights. You may action your rights (as may be applicable) by contacting us using the details provided below (12. CONTACT US). We will make every reasonable effort to comply with your requests within a reasonable period and in any event within the timescales provided by the Data Protection Law, unless we have a lawful reason not to do so. Requests should be made in writing and to ensure that personal data is dealt with carefully and confidentially we will require the requestor to provide verification of their identity and all applications must be accompanied by copies of at least two official documents, which show your name, date of birth and current address (for example, driving licence, birth/ adoption certificate, passport, recent utility bill).
In responding to such requests, we will explain the impact of any objections, restrictions or deletions requested.
We will not charge you a fee to exercise your rights unless your request is clearly unfounded or excessive, in which case we may charge you a reasonable fee. Alternatively, we may refuse to comply with the request in such circumstances.
Additionally, should you wish to permanently delete your SimPlay Fantasy Football account and your personal data, you may do this yourself by following the below instructions:
Log into your account on the app
Click 'Manage Profile'
Click 'Delete Account'.
You will then be prompted to enter your password. Please then click 'Confirm Password'.
On the following page, please click 'Confirm'.
Please note that if you log back in to your account during the 21 day period the account will be reactivated.
You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the Nigeria data protection authority
11. Children and Privacy
It is important to us that children can enjoy our Services in a responsible manner. We encourage parents and guardians to supervise their children's online activities by, for example, adopting control tools available from online services and software suppliers that help provide a child-friendly online environment including by preventing children from disclosing their personal data online without parental permission.
If you have parental responsibility and would like to review any personal data that we have collected online from your child, have this information deleted, and/or request that there be no further collection or use of your child’s personal data or if you have any questions about our Privacy Policy or practices, you may contact us at info@simplayfantasyfootball.com.
12. Contact Us
If you have any questions about this Privacy Policy or how we handle your personal data, please contact us using the following contact details:
SimPlay fantasy Football
info@simplayfantasyfootball.com
B. SAFEGUARDING PRIVACY POLICY
This policy explains how SimPlay Ltd uses personal data in relation to the safeguarding of children and adults at risk (together, Safeguarding Activity).
This policy applies to personal data provided by, or received in respect of persons associated with Simplay Ltd, SimPlay Fantasy Football n accordance with the Nigerian Data Protection Regulation and other applicable data protection legislation.
We keep our privacy practices and procedures under review and we may amend this policy from time to time.
PLEASE READ THIS POLICY, TOGETHER WITH ANY OTHER PRIVACY NOTICES WHICH WE MAY PROVIDE TO YOU, CAREFULLY SO THAT YOU ARE AWARE OF AND UNDERSTAND THE WAYS IN WHICH WE COLLECT AND USE YOUR PERSONAL DATA.
This policy applies to our use of your personal data.
1. Background
1.1. SimPlay ltd is a “controller” under the Data Protection Law, which means that we are responsible for deciding how we use the personal data that we collect about you.
1.2. In accordance with the Data Protection Law, we will ensure that the personal data we hold about you is, at all times:
(a) used fairly, lawfully, and transparently;
(b) collected for limited, specific purposes only;
(c) adequate, relevant to and limited to what is necessary for those purposes;
(d) kept accurate and up-to-date;
(e) not kept for longer than is necessary; and
(f) held securely.
1.3. We shall be accountable for and able to demonstrate our compliance with our obligations under the Data Protection Law, and this policy is one of the ways in which we do that.
1.4 We have appointed a Data Protection Lead to oversee compliance with this policy and our data protection compliance activities. The Data Protection Lead has also established a dedicated data protection team to provide the necessary support.
2. What Personal Data we collect and when
2.1. Personal data means any information about you from which you can be identified. It does not include data where your identity has been removed (i.e. anonymous data). There are also “special categories” of more sensitive personal data which require a higher level of protection, for example personal data revealing or concerning a person's racial or ethnic origin, health, or criminal convictions and offences. We collect and use a range of personal data, including special category personal data in some circumstances, depending on your role or relationship with the Premier League and our Safeguarding Activities. This may be in relation to your recruitment, or a report or other communication that you make or contribute to about other people, or a report or other communication that is made about you.
2.2. You provide some of your personal data to us directly.
(a) any information you may provide as part of pre-recruitment checks for roles where you would be employed or contracted by SimPlay Ltd, such as Disclosure and Barring Service (DBS) checks, which may include your identification verification, references and (where applicable) criminal record checks;
(b) reported incidents, allegations and disclosures made in accordance with the SimPlay Ltd Safeguarding Policy
(d) other information which you report, or provide in response to requests and/or in correspondence with the SimPlay Ltd in relation to our Safeguarding Activities which may include your contact details, role, statements and/or opinions; and
(e) any other personal information you share with us, including by way of email, telephone call or interview as part of our Safeguarding Activities.
2.3. Any information requested as part of a pre-recruitment and procurement check is mandatory, and failure to provide the required information may preclude you from being registered in certain roles. Other information that you provide in relation to Safeguarding Activities may be optional, although failure to provide it may have an impact on the ability to investigate and take action in relation to such matters. When you are asked to provide non-mandatory information to the Premier League this will be clearly indicated.
2.4. We will also collect other personal data about you relevant to our Safeguarding Activities from other third parties.
(a) information that is obtained from third parties through pre-recruitment and procurement checks for roles where you would be employed or contracted by the SimPlay Ltd, such as Disclosure and Barring Service (DBS) checks, which may include your identification verification, references and (where applicable) criminal record checks;
(b) reported incidents, allegations and disclosures as reported to us in our Safeguarding Referral Forms or provided in response to our requests and/or in correspondence with the SimPlay Ltd relation to our Safeguarding Activities;
(c) information that is obtained from the safeguarding activities of Clubs, Club Community Organisations, other Football Authorities and other interested parties such as the Charity Commission, charities and voluntary bodies such as the NSPCC and ChildLine, statutory bodies and agencies such as local education authorities or the police, and directly from other participants in football; and
(d) any other personal information shared with us, including by way of email, telephone call or interview as part of our Safeguarding Activities.
2.5. Information reported to us may include your personal data because your safety is of concern or because your behaviour or the behaviour of others is of concern and may include records of incidents, allegations or disclosures about abuse, exploitation, inappropriate conduct or poor practice and details of how such incidents and allegations are resolved, which may include health information and details of criminal offences and illegality (i.e. special category data).
2.6. Please note that we may collect and process your personal data (including from public sources) without your knowledge or consent where this is required and/or permitted by law.
3. How and why we use your Personal Data
3.1. We only collect and use personal data in accordance with Data Protection Law.
3.2. SimPlay Ltd may collect and use personal data because it is necessary for our "legitimate interests", that is, in order to operate, administer, regulate and govern the SimPlay Fantasy Football competitions and associated activities in an effective and lawful manner and in particular, because it is necessary:
(a) to implement and enforce our Safeguarding Policy including conducting pre-recruitment checks, receiving and reviewing reports and communications and taking necessary action to protect the welfare of individuals at risk and to prevent abuse and poor practice;
(b) to operate and administer our systems and procedures, including holding data from such checks, reports and communications, in support of our Safeguarding Policy; and
(c) in conducting our Safeguarding Policy we share such data with other parties who can help to protect the welfare of individuals at risk and to prevent abuse and poor practice.
3.3. Before using your personal data for our legitimate interests, we make sure that we take into account any potential impact that such use may have on you to ensure that your interests and fundamental rights and freedoms do not override those interests. In other words, we have determined that SimPlay Ltd has a legitimate need to process your personal data and we are not aware of any reasons that, on balance, mean we should not be doing so. If you have concerns about our processing please refer to Your Rights in Connection with Your Personal Data below.
3.4. In conducting our Safeguarding Policy, and in accordance with Data Protection Law, we may also use your personal data for purposes which are required by law, including:
(a) to comply with a legal obligation (for example, because the court has ordered us to do so);
(b) to respond to requests by the government or law enforcement authorities conducting an investigation;
(c) to implement enhanced DBS checks where individuals will interact with children or adults at risk; and
(d) to protect yours or someone else's vital interests in emergency situations.
3.5. We generally do not rely on your consent in order to process your personal data and we will inform you specifically when we seek to obtain this from you as well as your ability to withdraw that consent at any time.
Special Category Data
3.6. We also only use special category personal data in accordance with the Data Protection Law and therefore only if:
(a) It is necessary for reasons of substantial public interest. Data Protection Law provides for the use of special category personal data where it is necessary for the prevention and detection of unlawful acts, and for the purposes of safeguarding of children and individuals at risk. Data Protection Law also provides for the use of special category personal data for the purposes of measures designed to protect the integrity of a sport or a sporting event. This includes measures to prevent or protect against dishonesty, malpractice or other seriously improper conduct, or failure by a person participating in the sport or event in any capacity to comply with standards of behaviour set by a body or association with responsibility for the sport or event.
(b) We have your explicit written consent. In limited circumstances, we may approach you for your written consent to allow us to process certain sensitive data where there is no other legal basis. If we do so, we (or a third party) will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. For example, we may request consent (including parental or guardian consent) to processing a youth player’s medical and other additional needs to ensure that we comply with our obligation to safeguard children and young adults.
You have the right to withdraw your consent at any time and can do so by contacting us using the details provided below.
(c) Less commonly, we may process your personal data where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.
3.7. Unless otherwise required or permitted by law, before using your personal data for a purpose unrelated to the reason we collected it, we will notify you and explain the purpose and legal basis which allows us to do so.
3.8. If you have any questions or require any additional information about the purposes for which your personal data is required and/ or our legal justification you can contact the Simplay Fantasy Football’s dedicated Data Protection Team using the contact details set out below.
4. Who we share your Personal Data with
4.1. We may share certain elements of your personal data with other individuals and organisations as part of our Safeguarding Activities, always on a need-to-know-basis and for legitimate prescribed reasons.
4.2. We share information with sponsors, and interested parties including without limitation the Charity Commission, charities and voluntary bodies such as the NSPCC and ChildLine, statutory bodies and agencies such as local education authorities or the police, the Care Quality Commission, and other relevant third parties, including those who are the subject of Safeguarding Activities because their safety is of concern or because their behaviour or the behaviour of others is of concern and when determining the outcome of disciplinary or regulatory proceedings and appeals in respect of such proceedings.
4.3. Personal data may also be shared with third party service providers, who will process it on behalf of the controllers for the purposes identified above. Such third parties include the providers of software used by SimPlay Fantasy Football to maintain records of intelligence, case management and DBS checks.
4.4. All third-party service providers who we share your personal data with are required to take appropriate security measures to protect your personal data. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified limited purposes and in accordance with our instructions.
5. Transferring personal data outside Nigeria
5.1. Some countries outside of Nigeria do not have laws that protect privacy rights and personal data as extensively as Nigeria. Therefore, in accordance with Data Protection Law, if we do transfer your personal data outside of the Nigeria, we ensure that your personal data is afforded a similar level of protection by ensuring one of the specific safeguards approved by Niigeria.
5.2. If you would like further information on the specific mechanism used by us when transferring your personal data out of the Nigeria please contact us using the details provided below.
6. Security of your Personal Data
6.1. The Premier League is committed to protecting your privacy and has put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. Details of these measures are available upon request using the details provided below.
6.2. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
7. Data retention
7.1. In accordance with Data Protection Law, SimPlay Ltd will only keep your personal data:
(a) for as long as necessary to fulfil the specific purposes we collected it for in relation to safeguarding matters but we will review the information we hold, and the decisions and actions that we have taken, at the end of each case or investigation and thereafter every 3 years;);
(b) to the extent reasonably necessary to comply with a legal requirement or legal reasons - for example, documents containing personal data may need to be retained for an extended period of time (generally for six years) if there is a real risk that they could be the subject of a claim, or may otherwise be relevant to future litigation; or
(c) as advisable in light of certain legal issues (or potential issues) - for example, we may retain information in relation to safeguarding issues after the conclusion of an investigation so that we can address historical allegations in the future.
7.2. 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, and the applicable legal requirements.
7.3. In accordance with SimPlay Ltd’s Data Retention Policy and Data Protection Law, after the applicable retention period has ended, the personal data will be either (as applicable):
(a) securely deleted or destroyed - when the information is no longer required in any form; or
(b) anonymised (so that it can no longer be associated with you) - for example, where the data remains useful in an aggregated/ generic form for statistical purposes.
8. Your rights in connection with your Personal Data
8.1. Under Data Protection Law, you have certain rights (depending on the circumstances) in connection with your personal data, which include:
(a) Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it, provided always that this does not adversely affect the rights and freedoms of other people.
(b) Request correction of the personal data that we hold about you. Where any of the information we hold about you is incorrect or incomplete we will act promptly to rectify this, including where you have requested us to do so.
(c) Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
(d) Object to use of your personal data where we are relying on our legitimate interests (see “How and why we use your Personal Data”) and there is something about your particular situation which makes you want to object to our use on this ground.
(e) Withdraw your consent to our use of your personal data where we do so in reliance on your consent. Once we have received notification that you have withdrawn your consent, we will no longer process your personal data for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
(f) Request the restriction of use of your personal data. This enables you to ask us to suspend the use of personal data about you, for example if you want us to establish its accuracy or the reason for using it.
8.2. We are committed to respecting your rights. You may action your rights (as applicable) by contacting us using the details provided below and we will comply with your requests within a reasonable period unless we have a lawful reason not to do so. Requests should be made in writing and to ensure that personal data is dealt with carefully and confidentially SimPlay Ltd will require the requestor to provide verification of their identity and all applications must be accompanied by copies of at least two official documents, which show your name, date of birth and current address (for example, driving licence, birth/ adoption certificate, passport, recent utility bill).
8.3. Note: in responding to such requests, we will explain the impact of any objections, restrictions or deletions requested, which may be significant if our use of your personal data is necessary for you to fulfil your role or relationship with the Premier League.
8.4. We will not charge you a fee to exercise your rights unless your request for access is clearly unfounded or excessive, in which case we may charge you a reasonable fee. Alternatively, we may refuse to comply with the request in such circumstances.
9. Contact us
If you have any questions about this privacy policy or how we handle your personal data, please contact the Data Protection Lead using the following contact details:
SimPlay Fantasy Football
dataprotection@simplayfantasyfootball.com
10.Complaints
You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the Nigerian data protection authority.