This privacy policy explains how we collect, use, share, transfer, and sell (for California residents) your personal data when you use the services provided on our sites and our apps or interact with us; and your data privacy rights.
Personal data is any information about you by which you can be identified or be identifiable.
This can include information such as your name, date of birth, email address, postal address, phone number, mobile number, information about your device (such as the IP address, which is a numerical code to identify your device that can provide information about the country, region or city where you are based) and information relating to how you use and interact with our sites, apps and services.
When we refer to “personal data” in this policy, we are also referencing “personal information,” as it is defined under California law, and as it is defined under Australian law.
Sometimes our sites and apps may contain links to sites and services that are not part of the NineThreeSeven network. These sites and services have their own privacy policies. If you follow a link to these sites and apps, you should read the privacy policy shown on their site.
NineThreeSeven is trading name of Frontcourt Studio Limited of Gascoyne House, Moseleys Farm Business Centre, Fornham All Saints, Bury St Edmunds, Suffolk, United Kingdom, IP28 6JY. Frontcourt Studio Limited is the data controller in respect of your personal data. This means that we are responsible for deciding how and why we hold and use your personal data. If you want to contact us directly, you can email us at privacy@ninethreeseven.com.
We collect your personal data when you visit our websites and apps, subscribe for products or services or when you interact with us. We will only collect your personal data in line with applicable laws.
We collect your personal data in various ways:
When you use our sites or apps we may also use cookies or similar technology to collect extra data, including:
We will not collect special categories of data from you - such as personal data concerning your race, political opinions, religion, health or sexual orientation - unless you have chosen to provide that type of personal data to us.
Our apps may use personal data based on the content you have viewed. Information on bugs and crashes is also sent to us when you use our apps. We also collect “event data” when you perform specific actions within our apps.
We collect personal data when you:
We use personal data collected through our sites and apps only when we have a valid reason and the legal grounds to do so. We determine the legal grounds based on the purposes for which we have collected your personal data.
The legal ground may be one of the following:
For example, where you have provided your consent to receive marketing emails from us. You can withdraw your consent at any time. In the case of marketing emails you can withdraw your consent by clicking on the “unsubscribe” link at the bottom of the email.
In some cases, we may have a legal obligation to use or keep your personal data.
Where it is necessary for us to understand our users, promote our services and operate our sites and apps efficiently. Examples of when we rely on our legitimate interests to use your personal data include:
When you sign up to our services we may add to the personal data you give us by combining it with other personal data shared with us by other trusted organisations. This includes, for example, the region that you are located in, so that we can personalise our websites and apps by using your local currency or language.
We may also obtain your personal data from partners whose offers we include in some of our marketing communications and we use this personal data to ensure that we do not send you irrelevant marketing.
We also use personal data based on the content you have viewed on our sites and apps and your interaction with the content to add you to groups with similar interests and preferences, so that we can make our online advertising more relevant. Sometimes we use data about your interests or demographics that some of our global third parties have collected from you online to add you to these groups.
We do not aim any of our products or services directly at persons under the age of 18 and we do not knowingly collect personal data about children under 18. We also note that California law prohibits sale of personal data of consumers between 13-16 years of age unless the guardian has authorized the sale. We comply with this requirement.
We have implemented appropriate technical and organisational controls to protect your personal data against unauthorised processing and against accidental loss, damage or destruction. Unfortunately, sending any information, including personal data, via the internet is not completely secure. Although we will do our best to protect your personal data once with us, we cannot guarantee the security of any personal data sent to our site while still in transit and so you provide it at your own risk.
We share your personal data with other organisations that are not directly linked to us under the following circumstances:
We may share your data with other organisations that provide services on our behalf. We may do this to perform a contract we have entered into with you, where it is in our legitimate interests or with your consent. Examples of when we may share your data with service providers include sharing with:
We may also share your data collected through our websites and apps with our advertising partners, as set out in our cookie policy. These partners help us deliver relevant advertising across our websites and apps.
We may reveal your personal data to any law enforcement agency, court, regulator, government authority, or in connection with any legal action if we are required to do so to meet a legal or regulatory obligation, where the request is proportionate, or otherwise to protect our rights or the rights of anyone else (for example, in response to valid and properly served legal process such as subpoena or warrant).
We will attempt to notify you prior to disclosing your data unless (i) prohibited by applicable law from doing so, or (ii) there are clear indications of unlawful conduct in connection with your use of our services.
We may share your personal data with other organisations when our web pages use social plug-ins from these organisations. These other organisations may receive and use personal data about your visit to our sites or apps. If you browse our site or view content on our apps, personal data they collect may be connected to your account on their site. For more information on how these organisations use personal data, please read their privacy policies.
We may share your personal data to any other organisation that buys, or to which we transfer all, or substantially all, of our assets and business. If this sale or transfer takes place, we will use reasonable efforts to try to make sure that the organisation we transfer your personal data to uses it in line with our privacy policy.
Any organisations which access your data in the course of providing services on our behalf will be governed by strict contractual restrictions to make sure that they protect your data and keep to all data privacy laws that apply. We may also independently audit these service providers to make sure that they meet our standards. These transfers to third parties may constitute “sale” of your personal information under California law.
Data we collect may be transferred to, stored and processed in any country or territory where we or one of our service providers are based or have facilities. While other countries or territories may not have the same standards of data protection as those in your home country, we will continue to protect personal data that we transfer in line with this privacy policy.
Whenever we transfer your personal data out of the European Economic Area (EEA), we ensure appropriate safeguards.
We keep your personal data for only as long as we need to. How long we need your personal data depends on what we are using it for, as set out in this privacy policy. If we no longer need your data, we will delete it or make it anonymous by removing all details that identify you. If we have asked for your permission to process your personal data and we have no other lawful grounds to continue with that processing, and you withdraw your permission, we will delete your personal data. However, when you unsubscribe from marketing communications, we will keep your email address to ensure that we do not send you any marketing in future.How we may contact youMarketing communications and email newslettersIf we have your permission, we may send you materials we think may interest you. We also offer a range of email subscription products and newsletters. You can decide not to receive these emails at any time and will be able to “unsubscribe” directly by clicking a link in the email.
Sometimes we may contact you for market research purposes, for example about a survey.
If you have raised a query or a complaint with us, we may contact you to answer your query or to resolve your complaint.
If you elect to use the “do not sell” button, we will not recontact you about that choice for at least 12 months.
When you visit our sites or when you use our apps, we may collect personal data from you automatically using cookies or similar technologies. A cookie is a small file that can be placed on your device that allows us to recognise and remember you.
A cookie is a small file that can be placed on your device that allows us to recognise and remember you. It is sent to your browser and stored on your computer’s hard drive or tablet or mobile device. When you visit our sites, we may collect information from you automatically through cookies or similar technology, such as a tag, pixel, or other web beacon.
We use cookies in a range of ways to improve your experience on our site, including:
Ultimately, this allows us to provide our services free of charge.
In the next section, we explain in more detail how we use cookies and similar technology on our sites and apps for a number of purposes.
Other organisations may also collect user information on our sites through cookies, tags and pixels. Tags and pixels, also known as web beacons, are similar to cookies but are collected through embedded images.
Using cookies and other technology allows other organisations to help us to analyse how our site is being used, measure the number of visitors to the site, and display advertising. To accomplish these goals, NineThreeSeven utilises cookies, tags, pixels, and other web beacons to communicate information about you to others.
If you are a California or US resident, you may elect to opt out of all sales of personal information through these cookies, tags, pixels, and web beacons by clicking the “Do not sell” link located in the footer of our products.
Cookies that are used by NineThreeSeven are referred to as “first-party cookies” and those that are used by our partners are “third-party cookies”. Because of how cookies work, our website cannot access third-party cookies; nor can other organisations access the data in the cookies we use on our website. There are more details about both types of cookies in the following sections.
We use four types of cookies:
Cookies are a key part of how we deliver advertising on our sites. Among other uses, they allow us to show more relevant advertising to people who visit our products by showing you adverts that are based on your browsing patterns and the way you have interacted with our sites and apps. We can then show you adverts which we believe may interest you.
As you browse our site, some of the cookies and similar technology we place on your device are for advertising, so we can understand what sorts of pages you read and are interested in. We can then display advertising on your browser based on these interests. For instance, if you have been browsing a lot of Premier League fixtures, you may be shown more adverts about betting on the Premier League.
There are times when we want to reach our users who use social media to market our own products and services. We use cookies to help with this. For example, we place a pixel on our web pages that allows Facebook to place cookies on your web browser. When a user who uses Facebook returns to Facebook from our sites, Facebook can identify them as part of a group of our users and, on behalf of NineThreeSeven, deliver them marketing messages from us. Based upon our agreements with these other companies, the data that can be obtained from a visit to one of our websites is limited to the URL of the pages that have been visited and, in some cases, the status of any unfinished or completed commercial transactions undertaken with us, together with the limited information a browser might pass on, such as its IP address. In addition to the cookie controls that we mentioned above, if you are a Facebook user you can opt out by following this link.
We may also share and receive online data collected through cookies and similar technology with our advertising partners. This means that when you are on another website, you may be shown advertising based on your browsing patterns on our sites. We may also show you advertising on our sites based on your browsing patterns on other sites that we have obtained from our advertising partners.
Online retargeting is another form of online advertising that allows us and some of our advertising partners to show you advertising based on your browsing patterns and interactions with other sites. The use of cookies may mean that when you are on another site, you may be shown advertising based on what you have looked at on our sites. This allows companies to advertise to you if you leave their website without making a purchase.
Our apps integrate third-party software that provides us with information about how the app is used and what content you have viewed for the purposes of online advertising and analytics, in a similar way to our sites. It uses cookies from some of the providers listed here, among others.
You can manage the use of cookies on our sites, including advertising cookies, and disable the sharing of data with partners for advertising purposes by using the steps set out here.
Under California law, this collected data can be considered “personal information.” In some cases you can turn off advertising cookies on a cookie-by-cookie basis, and we give the most common examples below.
You can further manage the use of advertising cookies and disable the sharing of data with partners for advertising purposes by clicking the privacy settings link in the footer of this page. However, if you are located in the US, please use the “Do Not Sell button” instead, you can find it in the footer of every page.
This option will reduce the number of advertising partners with whom we share your data, although you will still see some advertising that has been tailored to you.
You can switch some cookies off through the Your Online Choices site. You may need to do this again each time you use a different IP address, device, or virtual private network. You can also adjust the global privacy setting or plug-in which should be communicated to use via your browser.
It is also possible to stop your browser from accepting cookies altogether by changing your browser’s cookie settings. You can usually find these settings in the “options” or “preferences” menu of your browser. The following links may be helpful, or you can use the “Help” option in your browser.
You have a number of rights with regard to the personal data that we hold about you and you can contact us with regard to the following rights in relation to your personal data:
If you would like to exercise any of your rights specified above, please email privacy@ninethreeseven.com. We will deal with requests within one month.
We may need to request specific information from you to help us confirm your identity. If your request is complicated or if you have made a large number of requests, it may take us longer. We will let you know if we need longer than one month to respond. You will not have to pay a fee to obtain a copy of your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.
Under the California Consumer Privacy Act, California Civil Code Section 1798.100, if you are a resident of California you may contact us with regard to the following rights in relation to your personal data:
If you want to make any of these requests, please contact privacy@ninethreeseven.com.
We will deal with requests for access to your personal data within forty-five (45) days for California-specific requests.
To help us respond as you expect, please specify that you are making a request under the California Consumer Privacy Act. We may need to request specific information from you to help us confirm your identity.
Your rights to privacy are also protected by the Australian Privacy Principles in force under the Privacy Act 1988 (Cth). These privacy laws place requirements on us to treat your personal information collected in line with those principles, including to disclose to you what personal information we collect about you and how we use it, to store your information securely and to allow you to exercise the following rights:
-Right of access to the personal information held about you; and -Right of correction to correct your information when it is incorrect.
These principles and rights are reflected throughout this privacy policy.
If you have contacted us at privacy@ninethreeseven.com with a privacy related complaint and you are not satisfied with our handling of that complaint, you may refer that complaint to the Office of the Australian Information Commissioner:
GPO BOX 5218, Sydney NSW 2001
If you have any questions about how we use your personal data or if you have a concern about how your personal data is used, please email us at privacy@ninethreeseven.com. Complaints will be responded to within 30 days.
If you are not satisfied with the way your concern has been handled, you can refer your complaint to the Information Commissioner’s Office.
If we decide to change our privacy policy we will post the changes here. If the changes are significant, we may also choose to email all our registered users with the new details. If required by law, we will get your permission or give you the opportunity to opt out of any new uses of your data.
