What does this policy cover?
It also describes your data protection rights, including a right to object to some of the processing which we carry out. More information about your rights, and how to exercise them, is set out in the “What rights do I have?” section.
Dugout may collect various types of information about you through your use of our Platforms to process your requests, to provide a more personalized user experience and to help us improve the services we offer (see below for more information).
Dugout will be the Data Controller of any personal data we collect about you.
What information do we collect?
- your name;
- your gender;
- your age/date of birth;
- your home address, email address and phone number;
- your marketing preferences, including any consents you have given us and how you engage with our email marketing communications;
- information related to your IP address and web browsing activity conducted on your device including activity related to online advertising displayed on your device;
- your favourite Publishers and sports teams.
When viewing content through our Embed Player we collect and process personal data about you which includes;
- information related to the device you use to access our Platforms; and
- your geo-location.
In the event that we require you to provide additional personal information, including any sensitive personal information, we will provide you with further information about why we are collecting such information and how we will use it.
What information do we receive from third parties?
Sometimes, we receive information about you from third parties. For example we may process data about your browsing history collected through cookies and similar technologies from our publisher partners (see Marketing below for more information).
How do we use this information, and what is the legal basis for this use?
We process this personal data for the following purposes:
- To fulfil a contract, or take steps linked to a contract: this is relevant where you use our services. This includes, for example:
- administering your entries into any competitions that we run;
- As required by Dugout to conduct our business and pursue our legitimate interests, in particular:
- we will use your information to provide the Platforms and other services you have requested, and respond to any comments or complaints you may send us;
- we monitor use of our Platforms, and use your information to help us monitor, improve and protect our products, content, services and the Platforms, both online and offline;
- we use information you provide to personalise our Platforms, in order that we can offer you a more relevant, tailored experience on the Platforms;
- we monitor customer accounts to prevent, investigate and/or report fraud, misrepresentation, security incidents or crime, in accordance with applicable law;
- we use information you provide to investigate any complaints received from you or from others, about the Platforms or our products or services;
- we will use data in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation); and
- we use data of some individuals to invite them to take part in market research;
- Where you give us consent:
- where required by law to send you direct marketing in relation to our relevant products and services, or other products and services provided by us, our affiliates and carefully selected partners;
- we place cookies and use similar technologies (see Cookie Section below) and the information provided to you when those technologies are used. Similarly, when you download or use Dugout apps on your mobile devices or TV, information may be accessed from, or stored on your device which may require your consent under applicable laws;
- on other occasions where we ask you for consent, we will use the data for the purpose which we explain at that time.
- For purposes which are required by law:
- In response to requests by government or law enforcement authorities conducting an investigation.
We embed videos with Dugout content in our publisher's partners' websites. These videos may set cookies and similar technologies on your device which may be shared with Dugout and our partners for analytics and advertising purposes. You have the right to opt-out of this processing at any time (see Your Rights section below).
From time to time we will ask you whether you wish to receive marketing material from Dugout containing information about our services and partners.
You can always tell us that you do not wish to receive direct marketing communications from Dugout. But remember, if you do not want us to get in touch, you may miss out on valuable and exciting offers. If you would prefer not to receive direct marketing communications from us, simply let us know at any time by contacting us using the details below or by following the opt out instructions in the relevant communication. Please note that this will not stop you from receiving service messages from us.
We may use information which we hold about you to show you relevant advertising on third party sites (e.g. Facebook, Google, Instagram, Snapchat and Twitter among other third party publisher sites). This could involve showing you an advertising message where we know you have used Dugout products and services. If you do not want to be shown targeted advertising messages from Dugout, some third party sites allow you to request not to see messages from specific advertisers on that site in future. If you want to stop all personalised services from Dugout, including targeted advertising messages on third party sites you can block Cookies through your browser or device settings or contact us for further advice. For further information see www.youronlinechoices.com
Withdrawing consent or otherwise objecting to direct marketing
Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests. You have an absolute right to opt-out of any direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by following the instructions provided in the communication where this is an electronic message, or by contacting us using the details set out below.
Who will we share this data with, where and when?
We may share your Personal Information with the Publisher(s) with whom we work when we are running a competition. In these cases, Dugout and the relevant publisher must both comply fully with data protection legislation.
We share your data with football clubs, other affiliates and carefully selected partners who we work with to pursue our legitimate interest.
Where you enter competitions, we share your data with the third parties (such as sports teams) who provide competition prizes and assist us in administering competitions.
We may provide information to advertisers and to third parties, including information relating to, but not limited to, sales and web-usage, to enable us to sell advertising and monitor the efficacy of our relationships with third parties.
Personal data may be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable laws.
Personal data will also be shared with third party service providers, who will process it on behalf of Dugout for the purposes identified above. In particular, we use third party providers of [website hosting, , marketing services] and administering competitions.]In the event that the business is sold or integrated with another business, your details will be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new owners of the business.
We may transfer some of your information outside of the European Economic Area ("EEA"). Where information is transferred outside the EEA or the United Kingdom, and where this is to a stakeholder or vendor in a country that is not subject to an adequacy decision by the EU Commission, data is adequately protected by EU Commission approved standard contractual clauses, an appropriate Privacy Shield certification or a vendor's Processor Binding Corporate Rules. A copy of the relevant mechanism can be provided for your review on request to [firstname.lastname@example.org].
What rights do I have?
The rights in this section apply to individuals based in the EEA and the UK.
You have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share (port) this data to another controller.
In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are included in both the GDPR and in relevant local implementing legislation. We will inform you of relevant exemptions we rely upon when responding to any request you make.
To exercise any of these rights, or to obtain other information, such as a copy of a legitimate interests balancing test, you can get in touch with us using the details set out below. If you have unresolved concerns, you have the right to complain to an EU data protection authority where you live, work or where you believe a breach may have occurred.
How do I get in touch with you?
We hope that we can satisfy queries you may have about the way we process your data. If you have any concerns about how we process your data, or would like to opt out of direct marketing, you can get in touch at [email@example.com] or by writing to Dugout, Dugout Limited, 8th Floor, 2 Minster Court, London, EC3R 7PP.
How long will you retain my data?
Where we process personal information for marketing purposes or with your consent, we process the information until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your information indefinitely so that we can respect your request in future.
Where we process personal information in connection with performing a contract, we keep the personal information in line with the contractual limitation period.
WHAT IS A COOKIE?
A cookie is a small text file that in certain circumstances third parties, place on your device when you visit our Platform, interact with the Platforms and/or open some of our emails. Cookies, amongst other things, allow Us to recognise you each time you interact with our Platforms and provide you with a more personalised user experience. There are in existence a variety of different cookies which are designed for use in specific sets of circumstances.
When you interact with the Platforms , we may place a cookie on your browser to enable Us to recognise you the next time you use the Platforms. . We may also place a further cookie on your browser when you register for dugout.com, this will enable us to remember you next time you come to sign in, eliminating the need for you to re-enter your login details and customising your future uses of the Platforms..
Cookies may also be used to track your use of the Platforms to better develop them, for example, determining which parts of the Platform are more popular and determining content accordingly.
We may also place cookies on your user device to provide you with behavioural advertising and monitor the advertising on the Platform.
Small pieces of code called pixel tags, web beacons or GIF files, are used in conjunction with cookies to help us manage and monitor our online advertising and wider business arrangements with third parties. These files will allow us to aggregate information relating to advertising and your usage of the Platforms. The type of information collected includes, but is not limited to, information relating to advertising responses, page views, promotion views and purchases made. Such pixel tags may be used to recognise third party cookies (cookies generated by third parties) and inform us and/or third parties of which advertisement or link brought you into the Platforms, allowing us to monitor the efficacy of our business relationships with third parties. Please see the section below entitled 'Use of different cookies' for more detail on the various cookies in use by Us and how they work.
USE OF DIFFERENT COOKIES
We will use different cookies at various stages of your use of the Platforms. :
Strictly Necessary Cookies: These cookies are essential in order to enable you to move around the Platform and use its features, such as accessing secure areas. Without these cookies, services like enabling appropriate content based your type of device cannot be provided.
Performance Cookies: These cookies collect information about how visitors use our Platforms, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how the Platforms work.
Functionality Cookies: These cookies allow us to remember choices you make (such as your language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
Targeting/Advertising Cookies: These cookies are used to deliver advertising more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaigns. They are usually placed by advertising networks with our permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers.
LIST OF COOKIES BEING USED
For a list of the cookies we use, please see here.
Cookies are also placed on our embed player which appears on our publisher partners’ websites. In these circumstance we rely our publisher partner to obtain consent on Dugout’s behalf.
You can change your cookie preferences and withdraw your consent at any time using our Cookie Consent Tool. For further information we recommend you visit the following websites for further information on altering your cookie settings:
For more detailed information on how to clear or disable all of your browser cookies, please go to http://www.google.com/support/accounts/bin/answer.py?answer=32050&hl=en
©Dugout Limited (October, 2019)