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.
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