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This Privacy Notice is for people who don't have a Superbru account, don't fit into any of the categories above and are simply visiting our website.
Superbru is an online sports predictor and fantasy game. It is operated by SportEngage Limited, a company registered in the United Kingdom under company number 07130756. SportEngage's address is 64 Kimber Road, London SW18 4PP, United Kingdom. SportEngage acts as a data controller with respect to the personal data discussed in this policy. Being a data controller simply means we determine the purposes and means of processing your personal data.
If you sign up with Superbru or engage with us in some other way like buying merchandise, you may play our games and you might make use of other supporting features around the games such as creating your own pool inside a game, sending a direct message to another user or contacting our helpdesk. In this document, these and other similar usages of Superbru are referred to as our Services, and references to “we”, “us” and “our” refer to Superbru as operated by SportEngage Limited.
If you have any questions or concerns about your data, please contact our Data Protection Officer on email@example.com. This email inbox is proactively monitored, so you can confidently expect your query to be addressed. We aim to respond to enquiries within 30 working days but will usually be in touch much sooner.
If you are just visiting our website and don't create an account or log in, we won't collect any direct personal information (like your name or email address) from you because you won't provide it to us. However, we will collect indirect information about you as part of providing our Services to you, such as the kind of web browser you are using, as part of our legitimate interest in delivering our Services and running our business.
If you're just visiting, you'll have no need to provide any personal information directly to us.
But, we will collect other information necessary for delivering our Services to you and for maintaining the performance of our Services. This information is collected in ways that are standard industry practice but not necessarily obvious to users without technical knowledge, and which may change from time to time.
- Enable your usage of Superbru
- Record some of your preferences
- Track your browsing behaviour and device type
- Collect various data, including analytics, about how you use Superbru
- Localise content to make it relevant to where you are located
- Analyse and improve the performance of our Services
This data is automatically collected when you use and interact with our Services. It includes log files, metadata, location information and cookie/device IDs. This information includes specific data about your interactions with the features, Internet Protocol (IP) address, information about browser configuration and plugins, browser type and settings, content and links (including those of third-parties, such as social media plugins) contained within the Services, the date and time the Services were used, language preferences and cookie data, information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and error data, and some of this data collected might be capable of and be used to approximate your location.
Someone else might provide us with personal data about you. For example, if you cannot access your account, you might ask your partner or a friend to write to us to ask us to help you find the account. Typically they would provide your name and email address. In circumstances like these where others give us information about you, or you provide us with personal information about others, we will only use that information for the specific reason for which it was provided to us.
We strongly believe in both minimising the data we collect and limiting its use and purpose to only that (1) for which we have been given permission, (2) as necessary to deliver the Services you interact with, or (3) as we might be required or permitted for legal compliance or other lawful purposes. These uses include:
We collect various information relating your interactions with our Services. We utilise this information to:
- Enable you to use our Services
- Operate our website and mobile app
- Ensure the security of our Services
- Improve and optimise the operation and performance of our Services (including our websites and mobile applications)
- Diagnose problems with and identify any security risks, errors, or needed enhancements to the Services
- Detect and prevent fraud and abuse of our Services and systems
- Collecting aggregate statistics about use of the Services
- Understand and analyze how you use our Services and what products and services are most relevant to you
Often, much of the data collected is aggregated or statistical data about how individuals use our Services, and is not linked to any personal data, but to the extent it is itself personal data, or is linked or linkable to personal data, we treat it accordingly.
We may contact you directly or through a third party service provider regarding products or services you have signed up or purchased from us, or to respond to an information or service request from you, such as necessary to deliver transactional or service related communications.
We may share your personal data with third parties with which we have partnered to allow you to integrate their services into our own Services, and with trusted third party service providers as necessary for them to perform services on our behalf, such as:
- Communicating with you, such as by email or push notification
- Processing credit card payments (if you buy a Superbru Premium subscription or other paid services)
- Serving advertisements
- Conducting contests or surveys
- Performing analysis of our Services and customers' demographics
- Customer relationship management
We only share your personal data as necessary for any third party to provide the services as requested or as needed on our behalf. These third parties (and any subcontractors) are subject to strict data processing terms and conditions and are prohibited from utilising, sharing or retaining your personal data for any other purpose than as they have been specifically contracted for (or without your consent).
The hosting, analytics, email sending and other technical provisions for our website and mobile app are situated in the United States. If you utilise our Services from a country other than the United States, your communications with us may result in transferring your personal data across international borders. The European Commission has made an “adequacy decision” with respect to the data protection laws of the United States. Transfers to the United States will be protected by appropriate safeguards.
The U.S.-based Data Processors who process and store the bulk of our data participate in the E.U.-U.S. Privacy Shield Framework and we make participation in the E.U.-U.S. Privacy Shield Framework and similar programmes in other territories a top priority when selecting data processing vendors.
Your data may be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, delivering our Services to you or the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing.
We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (such as subpoena requests), to protect our property and rights or the property and rights of a third party, to protect the safety of the public or any person, or to prevent or stop activity we consider to be illegal or unethical.
To the extent we are legally permitted to do so, we will take reasonable steps to notify you in the event that we are required to provide your personal information to third parties as part of legal process.
Targeted ads or interest-based offers may be presented to you based on your activities on our webpages, and other websites. These offers will display as varying product banners presented to you while browsing. We also partner with third parties to manage our advertising on our webpages and other websites. Our third party partners may use technologies such as cookies to gather information such activities in order to provide you with advertising based upon your browsing activities and interests, and to measure advertising effectiveness.
If you do not wish to see advertising on Superbru, please consider upgrading to a Premium account at https://www.superbru.com/premium.
Alternatively you may be able to opt out of interest-based advertising by visiting http://preferences-mgr.truste.com, or if located in the European Union by visiting http://www.youronlinechoices.eu. Please note you will continue to receive generic ads.
If you are a Superbru Account Holder, you can log into Superbru and edit your account settings. If not, or if you can't log in for any reason, please contact our helpdesk at firstname.lastname@example.org and we'll help you to change or delete your data.
If you make a request to delete your personal data and that data is necessary for the products or services you have purchased, the request will be honored only to the extent it is no longer necessary for any Services purchased or required for our legitimate business purposes or legal or contractual record keeping requirements.
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
- Right of access – you have the right to request a copy of the information that we hold about you. Access to this information will be subject to an administrative fee of GBP 10 if your request is manifestly unfounded, excessive or repetitive.
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records. Erasure will be subject to an administrative fee of GBP 10 if your request is manifestly unfounded, excessive or repetitive.
- Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
- Right of portability – you have the right to have the data we hold about you transferred to another organisation.
- Right to object – you have the right to object to certain types of processing such as direct marketing.
- Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
- Right to judicial review: in the event that Superbru refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain.
All of the above requests will be forwarded on should there be a third party involved in the processing of your personal data. In order to verify your identity should you request your data or information about your data, we may ask for a copy of your passport, driving licence, national identity card or birth certificate.
All information you provide to us is stored on our secure servers or those of our trusted partner services. We implement appropriate, generally accepted technical and organisational measures to protect your personal data against unauthorised or unlawful processing, accidental loss, destruction or damage, including encryption where appropriate. Unfortunately, the transmission of information via the Internet is not completely secure. We will do our best to protect your personal information, but we cannot guarantee 100% security of your data transmitted to our servers; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security to prevent unauthorised access to our servers.
We retain personal data only for as long as necessary to provide the Services you have requested and thereafter for a variety of legitimate legal or business purposes. These might include retention periods:
- mandated by law, contract or similar obligations applicable to our business operations;
- for preserving, resolving, defending or enforcing our legal/contractual rights; or
- needed to maintain adequate and accurate business and financial records.
We may update this policy from time to time by publishing a new version on our website and in our mobile app. You should check this page occasionally to ensure you are happy with any changes to this policy. We may notify you of changes to this policy by email or public notice on our website or mobile app.
We hope this notice has helped you to understand how and why we collect and process your personal data to enable you to use Superbru.
If you have a query or wish to make a complaint about how your personal data is being processed by Superbru (or third parties as described above) please contact our Data Protection Officer at email@example.com. This email address is actively monitored and we aim to respond to all requests within 30 working days, but usually much sooner.
If you live in the European Economic Area (EEA) or otherwise believe we maintain your personal data subject to the the General Data Protection Regulation (GDPR), you may direct questions or complaints to our lead supervisory authority in the United Kingdom, the Information Commissioner's Office (ICO):
Information Commissioner's Office (ICO)
+44 303 123 1113
More information can be found at https://ico.org.uk/make-a-complaint/