Walsh Enterprises LTD, is a company registered in England and Wales with the registration number 08935516 and registered address Market House, 10 Market Walk, Saffron Walden, Essex, England, CB10 1JZ (below referred to as “WEL”) processes personal data in accordance with law, including the General Data Protection Regulation. When we below refer to “we, our and us”, we refer to WEL.
1 - The type of data that WEL processes
WEL will process both non-personal data, i.e. information that cannot be attributed to a person, and personal data, i.e. information regarding an identifiable person.
1.1 Non-personal data
Non-personal data that WEL will collect from you.
When you use our services, i.e. download and use our apps, such as “Fluentfootball” or "Sweetspot", we use tools or third party analytical software to automatically collect non-personal data about you and your use of our Services. Such non-personal data is information that is aggregated and de‑personalised and which cannot be used to identify you. We collect this information by using an advertiser ID, which is a technology that differentiates smartphones and other devices from each other through a unique number. By tracking the number, an advertiser ID makes it possible for us to collect information about your use of our Services. The types of non-personal data that WEL collects can, for example, consist of an advertiser ID, information about your use of the Services, such as what teams and players you are interested in and your prediction in a specific game, your hardware, device software platform and firmware, software installation properties, including, but not limited to unique installation identifier and software version, your country specific settings and other non-personal data as reasonably required by WEL to enhance the Services.
1.2 Personal data
WEL will process both personal data submitted by you to WEL as well as personal data that WEL will collect from you.
Personal data submitted by you to WEL.
When you contact WEL by requesting technical support, by requesting WEL to save your app settings (if you use an Android device) or by signing up for any of the services that we or our partners provide in the apps, such as competitions displayed in the apps, you will provide your personal data, such as name, e-mail address, phone number, address, personal identification number, birth date and/or sex. Apart from these situations, WEL will not require you to provide any personal data in order for you to use the Services and therefore not process any other personal data.
Personal data that WEL will collect from you.
As described above, see section 1.1, WEL will collect and process data about you when you use our Services. When you request technical support, request us to save your app settings or sign up for any of the services provided by us or any of our partners in the apps, and provide us with your personal data mentioned above, we will be able to link your personal data to your advertiser ID. This means that all data (described above as non-personal data) that we have collected about you before this time through your advertiser ID, becomes identifiable information about you. Therefore, all data mentioned in section 1.1 will also be regarded by WEL as personal data after this point. For this reason, the information below also addresses such information. When referring to “personal data” below, non-personal data that has become personal data is included.
Personal data about third parties included in communication.
WEL may receive e-mails or other information containing personal data about third parties and therefore process such personal data. If required, WEL will inform you as a third party of the processing separately.
2 - What's the purpose of processing personal data and what is the legal basis for processing it?
It is important that you understand the purpose of WEL’s processing of your personal data and the legal basis for processing your data.
Provision of Services.
In order to make it possible for you to use our Services properly and for us to provide you with technical support and an opportunity for you to sign up for our services in the apps or to save your app settings (if you use an Android device and request that your app settings are being saved), WEL will process your personal data. The legal basis for WEL's processing of your personal data is that the processing is necessary for the performance of our contract with you or to take steps to enter that contract.
In order to make it possible for you to sign up for any of the services provided by our partners in the apps, such as competitions displayed in the apps, WEL will process your personal data. The services are organised by our partners and WEL only displays and provides the possibility for you to sign up for it. It is the partner company that is responsible for the processing of your personal data and that is the controller of the personal data provided by you, and WEL processes your personal data as a processor. The legal basis for WEL’s processing of your personal data is that the processing is necessary for the performance of your contract with the partner company or to take steps to enter such a contract.
Marketing.
As a user of WEL’s Services, we will provide you with information about our Services and our partners’ services that we believe you will find interesting and relevant due to your user behaviour, for example by displaying ads and other marketing from us and our partners in the Services and in social media. WEL will process your relevant personal data for such marketing purposes. The advertisement serving technologies that are used in order to enable us to provide you with customised marketing information are integrated into the Services. If you do not wish to be subject to this technology you can turn off the advertisement serving technologies in the settings of the device that you are using. If you turn the advertisement technologies off it will not limit the function of the Services and affect your user experience. The legal basis for WEL’s processing of your personal data for marketing purposes is that the processing is necessary for the purpose of a legitimate interest which is not overridden by your interests, rights or freedoms. Such a legitimate interest, e.g. to market WEL’s and WEL's partners’ products and services, exists based on our interest to develop our business and to offer you services that match your interests and needs. WEL’s interest in processing your personal data for marketing purposes overrides your potential interest in protecting your personal privacy.
3 - How long might WEL process your personal data?
WEL will store your personal data for as long as is needed for the processing related to the purposes and legal grounds described above. Your personal data may be stored in different locations in our systems and for different purposes. In light of this, personal data which has been deleted from one system because it is no longer needed there, may still exist in another system for a different purpose.
Personal data that WEL processes in order to provide the other Services, including technical support, will be stored for up to five years after your request for support. The reason for this is to make it easier for you to get assistance from WEL. It is often the same technical problem that users experience. Therefore WEL needs to see the history of technical problems that have arisen when you have used the apps. Personal data that WEL processes in order to provide you with the opportunity to save your app settings (when using an Android device), will be stored for as long as you request the app settings to be saved. Personal data that WEL processes in order to make it possible for you to sign up for any of the services provided by us or our partners in the apps, will be stored by WEL for no longer than one year after the service has been provided or for as long as is requested by the partner company.
Personal data that WEL processes for marketing purposes will be stored no longer than three years after either your last contact with WEL or your last active use of the Services. It is not possible for WEL to see if you remove the apps from your device or if you stop using the apps. This is since some users use the Services only to receive the apps’ push notifications (a use of the apps which we are not able to track), while some users browse and use the apps very actively (which enables for us to track the use). Therefore, WEL will regard you as a customer and user of the Services for three years from your last contact with WEL or your last active use of the Services, and may use your personal data for marketing purposes during this time.
Your personal data may be processed for a longer period than stated above if necessary to comply with legal requirements or authority decisions.
To whom does WEL transfer your personal data and where is your personal data processed geographically?
In addition to the processing performed by WEL, your personal data may also be processed by others. Your personal data will be disclosed to and processed by WEL, and WEL’s partners, such as gambling companies that you have signed up for in the app.
Your personal data will also be disclosed to companies who process personal data on WEL’s behalf, so-called processors. WEL has contracts in place that ensure that the processors process your personal data in accordance with this integrity policy and WEL’s instructions.
WEL may also disclose your personal data in order to permit a merger, an acquisition or a sale of all or parts of WEL’s assets. WEL may also disclose your personal data to authorities that require that WEL disclose such personal data. Your personal data will be disclosed to entities both within and outside of the UK, EU and EEA. Your personal data might also be disclosed to and processed by some companies yet to be confirmed.
5 - Your legal rights
You have the right to, free of charge, upon written request to the e-mail address listed below, receive information about what personal data WEL stores about you and how that personal data is used and processed. In the event that your personal data is inaccurate or wrong, you have the right to request that WEL corrects or removes the personal data.
If your request is unfounded or your request is excessive, e.g. should you frequently and within short intervals ask to receive information about what personal data WEL stores about you or that WEL shall provide a copy of or remove the personal data in question, WEL have the right to refuse to act on your request, or to charge a reasonable fee which covers the administrative costs of the action requested by you.
Your right to object.
You may object to your personal data being processed for direct marketing purposes at any time. If you do not want your data to be used for direct marketing, you can notify WEL by sending an e-mail to WEL at charles@walshenterprises.co.uk. We will then, as far as possible, stop processing and delete the personal data. However, we cannot delete the personal data if we need to continue processing it for any of the other purposes mentioned above.
You may also contact WEL if you are unhappy with the way WEL is processing your personal data. You have the right to file a complaint with the supervisory authority regarding WEL’s processing of your personal data or handling of any inquires related to it.
WEL may change this privacy policy. Such changes will enter into force no earlier than 30 days after WEL has informed you of the revised privacy policy in the app(s) or by other notification.
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Walsh Enterprises Ltd is a company registered in England and Wales: No.089355161
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