1. INTRODUCTION
We at Social Match Play Ltd take privacy and the security of your personal information extremely seriously. This policy sets out how we handle our information and the steps we have taken to keep it secure. This Policy also sets out where, how, and why we collect your personal information and your rights over any personal information we hold about you.
2. US TERMS
Any reference to ‘we’, ‘us’, or ‘our’ relate to Social Match Play Ltd, a private limited company registered in the United Kingdom, Company number 13214287. The term “Website” refers to www.jostl.app or any other website owned and managed by Social Match Play Ltd. The term App refers to JOSTL.
3. YOU TERMS
Any reference to “you”, “your” or the “customer” is reference to our registered customers or any person using our Website or App
4. APPLICATION
This Policy applies to all users of our services on our Website or our App or through interaction with us on social media pages run by us. This policy applies to customer’s, third-party providers, and employees. This privacy policy should be read in conjunction with our Terms and Conditions.
5. CHANGES
This Policy is updated from time to time. Any significant changes which affect users will be included in an updated Terms and Conditions. When we do update the Policy we will publish the updated date and version of the policy. Previous versions of the policy are available on request.
6. INFORMATION WE COLLECT
We collect personal information about you when you interact with us and use our services on both our App and website. We will only process your personal information where we have a lawful, legal, and legitimate basis to do so.
This may include ‘Special Category Data’ as defined in the General Data Protection Regulations (GDPR). Special Category Data may include –
personal data revealing racial or ethnic origin;
personal data revealing political opinions;
personal data revealing religious or philosophical beliefs;
personal data revealing trade union membership; genetic data;
biometric data (where used for identification purposes);
data concerning health;
data concerning a person’s sex life;
Page 2 of 4 and data concerning a person’s sexual orientation. The GDPR places tighter controls on the processing of ’special category data and we would only process information categorized as such where we have a lawful, legal and legitimate basis to do so and assess the processing against the rights and freedoms of the data subject.
7. WHO WE SHARE WITH
We may need to share personal information with other organisations to ensure that we meet our legal or regulatory obligations, or where we need support in delivering our services to you. All information is shared only where we have a lawful, legal and legitimate basis to do so. We may share your information in the following circumstances:
Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you for the delivery of our services, this includes but is not limited to; Where you have opted-out of receiving marketing from us, have been barred, or self-excluded, we may share suppression lists with our affiliates and selected third parties, to ensure you do not receive unsolicited marketing; Analytics and search engine providers or third-party providers that assist us in the improvement and optimization of our site and other selected third parties; In the event of our insolvency we may share your information with insolvency firms or data controllers. If we, or substantially all of our assets, are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;
8. OUR LEGAL REQUIREMENTS
We have legal and regulatory obligations to implement measures to identify and investigate any suspected unlawful, fraudulent, or improper activity connected with our services, including, but not limited to, possible money laundering, or the use of proceeds of crime and fraud. We have implemented manual and automated checks when processing your personal data to highlight any suspicious activity which requires the sharing of your personal information with various third-party providers. In addition, automated identification, verification, and credit checks are carried out on our behalf by third-party organisations. These decisions are necessary for us to comply with our contractual and legal obligations.
9. MARKETING
We will ask for your consent and preferences to marketing by SMS or Email. If you consent your information will be shared with our Third Party marketing organization with whom we contract to deliver marketing services. We conduct due diligence with all our third-party providers to ensure their privacy policy meets all legal requirements. You may withdraw your consent to marketing at any time within the ‘My Account’ section of our App or Website, or by following the ‘Opt Out’ instructions on any marketing communication you may receive.
10. RESPONSIBLE GAMBLING
For the purposes of prevention or detection of crime as well as responsible gambling, we may also supplement the information about you with information that we receive from third parties or collate by accessing third-party sources, including information published on the internet about or by you, for example on social media and social networking sites.
11. RETENTION
We will only retain your personal data as long as is necessary. In certain circumstances we will be required to retain personal data for specified periods of time to comply with regulatory or legal obligations.
12. COOKIES
A ‘cookie’ is a small text file that is downloaded onto your device when you visit a website and that enables the website to obtain certain information from your browser, such as your preferences. We use cookies that in particular obtain information about your device (such as IP address, device type, geo-location data and browser information).Cookies allow us to maximise your experience using the Website by increasing its functionality depending on the type of device you are using, and by changing the language the Website is presented in. A cookie does not harm your device nor does it contain any viruses or other malware. Disabling these cookies would mean you might not be able to access certain features. You can disable the cookies by selecting the appropriate settings in your browser. However, if you do this you may lose some useful functionality such as personalisation and ‘keep me signed in’ and ‘remember me’ features.
13. YOUR RIGHTS
You have a range of rights in respect to the manner in which we process your personal data. These rights are set out in detail below. You can contact us using the “contact us” section on our website to exercise one of these rights. We will reply to any request received from you within one month as of the date of the request.
1. Right to Access – You may request access to personal data that we hold concerning you.
2. Right to Rectify – You may ask us to rectify inaccurate personal data that we hold concerning you.
3. Right to be Forgotten – You may ask us to delete personal data that we hold concerning you. This right only applies:
a. Where we no longer require your personal data to achieve the objective for which it was collected, or,
b. Where you have withdrawn your consent for us to use your personal data on the basis of your consent, or,
c. When you oppose the manner in which we process your data.
d. Where we are not required to hold your personal data to meet our requirements set forth by local laws or regulators.
4. Right to Limit - You may request us to limit our processing of the personal data that we hold concerning you in certain circumstances. This right applies when:
a. You dispute the accuracy of the personal data that we hold, or,
b. You have the right to request us to delete the personal data, but prefer that our processing be limited, or,
c. We no longer need to use the personal data to achieve the objective for which we collected it, but you/we need this data to deal with legal proceedings.
5. Right to Receive - In certain circumstances, you have the right to receive personal data with which you have provided us. This shall be delivered in a widely used, machine-readable structured format. You also have the right to request us to transfer this personal data to another organisation, at your request.
6. Right to Oppose – You may oppose the processing of your personal data that we hold when the processing of this data is necessary for the purposes of our legitimate interests, unless we are able to prove that there exist legitimate and compelling reasons for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defense of legal claims.
7. Right of Automation – You may request to not be subject to a decision based solely on automated processing, including profiling, producing legal effects on you or significantly affecting you in a similar way.
8. Right to Withdraw – Where we rely on your consent for using your personal data, you may withdraw this consent at any time.
14. CONTACTING US
If you have any questions surrounding this policy, or if you wish to exercise one of your rights, you can contact us through our website using our Contact us section. Alternately you may send a request to our registered offices addressed to: Data Protection Officer, Social Match Play Ltd.
