Date of last amendment: 8 June 2021, v1.1

1        Introduction

Ultimate Fan respects your privacy and is committed to protecting your personal data when you use our mobile application including any web version of the application (together the “App”).

This App is owned operated by Low 6 Limited, incorporated and registered in England and Wales under company number 10799636 with its current registered office address currently located at 1 Cranmore Drive, Shirley, Solihull, England, B90 4RZ. Low 6 Limited is part of a group of companies owned by Low 6 Limited which includes:

(together referred to as the “Low 6 Group”).

We are committed to the protection of the personal data that we process in line with the data protection principles set out in the European Union General Data Protection Regulation 2016 (“GDPR”) and the Data Protection Act (2018).

This privacy notice explains what personal data we collect from individuals who use the Low6 App. It also explains what information we collect automatically when you use our App.

Low 6 Limited is the data controller for the purposes of the GDPR in instances where you make an enquiry with us, registered as such with the Information Commissioner’s Office, registration number ZA790666.

As an information-led business, we place great importance on ensuring the quality, confidentiality, integrity, and availability of the data we hold and in meeting our data protection obligations when processing personal data. We are committed to protecting the security of your personal data. We use a variety of technical and organisational measures to help protect your personal data from unauthorised access, use or disclosure.

We update this privacy notice from time to time in response to changes in applicable laws and regulations, to our processing practices and to the products and services we offer. When changes are made, we will update the date at the top of this document. Please review this privacy notice periodically to check for updates.

2        What information do we process?

Personal data is any information relating to an identified or identifiable natural person. We process the information you give us, whether through interactions with our app, our website or by any other form of correspondence.

Information you provide to us

The categories of personal data we process include:

Any information you share through our social media channels

Information we collect from you

When you use our app, we may collect:

We may use tools to personalise the user experience of our App, which may be disabled at any time using the Privacy Settings in the App or on your device.

Information we collect from third parties:

Information we collect from publicly available resources

In order to comply with our legal and regulatory obligations (including in respect of anti-money laundering and responsible gaming) and to protect our App from abuse and fraud, we may look at other information from publicly available resources. Our searches may include collecting information about you from the following sources: social media platforms (e.g. Facebook, LinkedIn), the electoral roll, public databases (e.g. telephone directories), internet search engines (e.g. Zoopla, Google, PayScale) the insolvency registry, companies house register and the UK land registry.

These checks allow us to gather information to make informed decisions and understand if the money transacted through our App is legitimate to comply with our legal and regulatory obligations and to protect our Website from fraud and abuse.

3        Purposes and bases for processing your personal data

We may use your data for the following purposes and on the following lawful bases:

PurposeLawful Bases for Processing
Delivery and performance of our App services in accordance with our Terms and ConditionsIt is necessary to process your personal data to facilitate performance of the service contract

 

To process your financial activity on our App, including managing payment, deposits and withdrawals into your Member Account.Entering into and performing a contract with you.

To comply with our legal obligations.

Prevention and detection of crime including money laundering, fraud or other crimesWe have a legal obligation to report any such activity to the relevant authorities and regulators
Compliance with sector-specific laws, regulations, and guidelinesWe have a legal obligation to provide our services within the law and regulations set down by our Regulators
Providing you with updates about our App, additional features, and providing you with exclusive promotions and dealsIt is our legitimate interest to provide accurate and up-to-date information to App users and to increase features of the App in order to continually improve and expand the services we provide
Delivering the benefits of our App by connecting you to the services and products of our merchantsIt is our legitimate interest to promote our services and products
Improving our App and website and the overall App user and website visitor experienceIt is our legitimate interest to allow analytics and search engine providers to help improve and optimise our website and App
Ensure maintenance of a secure connection between the App and your deviceIt is our legitimate interest to ensure the integrity and security of personal data flowing through our systems
Initiate action against any user who acts outside any laws, regulations or our Terms and Conditions or Terms of Use policiesIt is our legitimate interest to ensure protection of our company products, services, and reputation
Analyse and track use of the App for reporting and analytical purposesIt is our legitimate interest to monitor App usage in order to continually improve the user experience
To enable you to participate in competitions and promotions and provide you with rewards, such as prizes, gifts and invitations to events.If you participate in a competition, this will be entering into and performing a contract with you.

 

In all other cases it will be as necessary for our legitimate interests (to provide you with a personalised experience and improve our Website) or when you give consent to us (where such consent is required).

To provide various supporting customer services to you (such as where you contact us with a question in connection with our App and/or request certain information from us)As necessary for our legitimate interests (to deal with customer service requests and respond to communications).

 

If you do not provide us with the personal data we request from you for customer services purposes, we may not be able to fully answer your queries.

To comply with our legal and regulatory obligations as a gambling operator since your log-in details can also be used to access our gambling apps (e.g. verifying our users identity and age to ensure they can use our Website, spotting bonus abuses) and to protect our users (e.g. spotting responsible gaming problems).As necessary for our legitimate interests (to run our business, to prevent fraud and illegal activities on our App).

 

As necessary to comply with our legal obligations.

 

To protect public interest

To send you marketing communications about products and services of the Low 6 Group which we think may be of interest to you.

 

Note that you are able to opt out of receiving direct marketing communications should you not wish to receive them.

As necessary for our legitimate interests (to provide you with personalised experience and improve our App.

 

When you give consent to us.

 

Where personal data is processed because it is necessary for the performance of a contract to which you are a party, we will be unable to provide our services without the required information.

4        Sharing your information

We may disclose your personal data to the Low 6 Group in accordance with the applicable data protection laws and the terms of this privacy policy, for the purposes set out in section 3 above (e.g. to set up your account, provide you with the App services, send you marketing communications etc.)

We will share your personal data outside the United Kingdom (UK) or the European Economic Area (EEA). This is necessary for the purposes of providing our services to you, but we will only share it where appropriate safeguards are in place to ensure your personal data is protected to the same standard expected within the UK and EEA.

We may share your data with service providers and suppliers to our business who process data on our behalf (including, without limitation: marketing, data analytic, hosting, IT services and security, payment, data storage, KYC, audit, legal and compliance service providers) . In such cases, our service providers and suppliers are data processors and may only use the data in line with our instructions and not for any other purpose. This and other obligations are agreed in the contract between Low6 and the service providers and suppliers in accordance with the applicable data protection laws.

Our App includes links to our social media pages which enable you to view our content through selected sites. These applications may collect your IP address or Device ID and may set a cookie on your device. When you use one of these links, you are sharing information to another website or service and this privacy policy will no longer apply. Please read the privacy notices provided by the particular social media website you are sharing through before posting any personal information using these links.

 

Please see the below non-exhaustive list of key external providers with whom we share your data, the purpose of this sharing and where possible a link to their privacy policy.

ProviderPurpose of sharingPrivacy policy
GB GroupWe share full details including name, address and date of birth. This is necessary to verify customer account details and confirm customers are over 18 years of age.www.gbgplc.com/privacy-policy
WorldpayWe share payment and personal details relating to your account and payment methods. This is necessary to process payments to and from customer accounts and in order to facilitate the product and contract.www.fisglobal.com/en-gb/privacy
FacebookWe share marketing and demographic information.

This is necessary to create exemption lists to optimise and remove certain customers from marketing campaigns.

en-gb.facebook.com/privacy/explanation
Xtreme PushTo trigger in-app messages, push notifications and text messages to usersxtremepush.com/privacy-policy
LotameLotame analyses the information it collects and receives, and organises it into user groups and audiences, based on factors such as age, gender, geography, interests and online actions. We then use the Lotame-created user groups and audiences, along with information about the possible relationships among different browsers and devices, to design and deliver customized advertising campaigns or other relevant content to users on their computers, phones, and other mobile devices.https://www.lotame.com/about-lotame/privacy/lotames-products-services-privacy-policy/
White label partnersWhere a customer has signed up via one of our white label partners, the partner may be provided with your contact details if you provide your consent.

This is necessary to facilitate the product and contract.

This privacy policy will apply.

 

5        Your rights

The GDPR provides you with certain rights in relation to the processing of your personal data, including to:

 

Some of these rights are not absolute and are subject to various conditions under applicable data protection and privacy legislation and the laws and regulations to which we are subject. If at any time you decide that you no longer wish to be contacted for marketing purposes, or if you would like to exercise any of your rights as set out above, you can contact us at privacy@low6.co.uk . You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

In addition to the above, please note that you have the right to make a complaint at any time to the Information Commissioner’s Office if you are concerned about the way in which we are handling your personal data.

6        Data retention period

We will retain your personal data for as long as is necessary to provide you with our products and ongoing services and for a reasonable period thereafter, to enable us to meet our contractual and legal obligations and to deal with complaints and claims.

In some circumstances we are legally obligated to retain information to comply with legal obligations relating to crime prevention or gambling specific regulations.

At the end of the retention period, your personal data will be securely deleted in accordance with the Low6 Personal Data Retention and Destruction Policy and Schedule.

7        Contact

You can contact Low6 in relation to data protection and this privacy notice by emailing privacy@low6.co.uk.

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