EFFECTIVE FROM SEPTEMBER 2018
This policy (together with our Customer Terms https://proatar.com/tcs/ applies to your use of the Proatar application (the “Application”) and the services provided through the Application (the “Services”).
The Proatar group of companies (the “Proatar Group”) is made up of the following legal entities: PROATAR VENTURES (UK) LIMITED, PROATAR PLATFORM (UK) LIMITED, PROATAR PLATFORM (INDIA) PRIVATE LIMITED, PROATAR CRICKET (UK) LIMITED and PROATAR CRICKET PTE. (SINGAPORE) LIMITED When we refer to “Proatar” in this policy, we are referring to the relevant company in the Proatar Group responsible for processing your data.
Proatar Ventures Limited is the controller responsible for the Application. Our contact details are:
Proatar Ventures Limited (registration number 10650992)
Attention: Data Protection Team
12 Sheep Walk, Emmer Green, Reading, RG4 8NE, UK
What this policy explains
• What data we collect about you
• Why we use your data and our legal grounds for doing so
• Who we share your data with
• Whether we send your data outside of the EEA
• Marketing communications and how to opt-out
• How we keep your data secure
• Third party websites
• How long we store your data
• Your rights and how to exercise them
• Changes to this policy
• How to contact us
What data do collect we about you?
We have set out below the different types of personal data that you provide directly to us, or which we collect from you when we interact. We also wanted to let you know why we use this data and the different legal grounds which allow us to do so. You don’t have to give us any of this data but if you don’t, you may not be able to use the full functionality of the Application or receive the full benefit of the Services.
You may provide us with the following types of personal data when you directly interact with us (through the Application or otherwise):
• Contact – first name, surname, gender, DOB, account log-in information, country of residence, email address, telephone numbers, address
• Financial – billing address, purchase information, card details, transaction history
• Profile – your preferences for marketing, other preferences, your contact history Social – your social media account details
• About your game – details about your sporting background and preferences
We may also collect the following types of personal data from you when you use the Application (using Cookies or other tracking technologies):
• Technical – browser type, device information, IP address, hardware type, network and software
identifiers, operating system, system configuration
• Usage – information about how you use the Application
Why do we use your data and what are our legal grounds?
The table below sets out how we use your personal data and our lawful basis for doing so. In addition to these purposes, please note that we also anonymise and aggregate personal data (so that it does not personally identify you) and use it for testing our internal systems, carrying out research
and general customer data analysis. Because this is not personally identifiable, we can use this for any purposes.
|Reason why we use the data||What data||Legal ground for using the data|
|Register you as a Proatar user and enable you to log-in once you have registered||Contact, Profile,|
|Perform our contract with you Necessary for our legitimate interests (to make your registration/log-in experience more user friendly)|
|Process payments for Services which you make through the Application and (where applicable) to action|
|Contact, Financial||Perform our contract with you|
|Facilitate the delivery of the Services to you||Contact||Perform our contract with you|
|Send you service messages by email, SMS and/or through the Application||Contact||Perform our contract with you|
|Notify you of changes to this policy, our Customer Terms or other changes to the Application or Services||Contact||Performance of a contract with you Necessary to comply with a legal obligation|
|For internal administration and record keeping purposes||All||Perform our contract with you Comply with our legal obligations Necessary for our legitimate interests (to effectively operate our business and provide the Application)|
|Providing customer support, including answering your questions which may involve contacting you by e-mail or phone||All||Performance of a contract with you Necessary for our legitimate interests (to ensure our customers are informed and satisfied with the Application)|
|Understand who uses the Application||Contact||Necessary for our legitimate interests (to develop our business and|
understand our customer base to inform our marketing strategy)
|Get in touch with you about relevant Proatar Group products and services||Contact, Profile||We only do this if we have your consent|
|Get in touch with you about relevant products and services from our partners||Contact, Profile||We only do this if we have your consent|
|Improve and personalise your user experience by delivering more relevant content whilst you browse and to remember your preferences||Contact, Profile, Social Technical, Usage||Necessary for our legitimate interests (to develop our business, improve your user experience and inform our marketing strategy)|
|Administer the Application, including testing and analysis and to enable you to participate in interactive features of the Application||All||Performance of a contract with you|
Necessary for our legitimate interests (to ensure that the Application is fully functional and operating in the most effective way for you)
|Enable you to participate in a competition or prize draw||Contact||Perform our contract with you|
|Give you the opportunity to provide feedback to Proatarthrough reviews and surveys||Contact, Profile, Technical, Usage||Necessary for our legitimate interests (to develop our business, promote new products and services, obtain feedback from users to improve our services)|
|Verify your identity and detect fraud and security issues||All||Necessary for our legitimate interests (to prevent and detect fraud, security incidents and criminal activity)|
Sharing your data
We need to share your data with the following third parties as an essential part of being able to provide the Application and the Services to you (in accordance with the purposes set out above). In each case, we will only ever share the minimum amount of information required, and ensure that the relevant third parties are subject to suitable obligations in respect of confidentiality and security:
• Other companies in the Proatar Group
• Elite sportspeople that provide Services through the Application
• Payment service providers
• SMS and Email gateway providers
• Our professional service providers, such as marketing agencies, advertising partners and our professional advisors
• Credit reference agencies, law enforcement and fraud prevention agencies, so we can help tackle fraud
• Companies approved by you, such as social media sites (if you choose to link your accounts to us)
In addition to the above, we may also need to share your personal data with third parties if we are legally obliged to.
We do not pass your personal data to any third parties for the purpose of third party marketing unless you have consented to our doing so.
Do we send your data outside of the EEA?
The European Economic Area or “EEA” is seen as having good standards when it comes to data privacy. As such, we limit the occasions when we need to transfer or handle your data outside of the EEA. Where we do, we make sure that your data is still treated fairly and lawfully in all respects (including making sure we have a legal ground for the transfer and putting in place all necessary safeguards for such arrangement where the third party is not based in a country which is deemed to have “adequate” data protection laws).
Where applicable, you will have the right to see a copy of any safeguards we put in place for international transfers of your data. Just Contact Us if you would like to find out more.
Marketing messages and opt-ing out
You can opt-out of receiving marketing messages at any time either by Contacting Us on firstname.lastname@example.org or by using the opt-out function detailed in the relevant communication. Once you do this, we will update your profile to ensure that you don’t receive further marketing messages. Please note, it might take a few days for all our systems to be updated, so you might get messages from us while we process your request.
Even if you opt-out we may still need to send you service notifications by email, such as advising you of updates to this policy.
How we keep your data secure?
We implement industry standard security processes to ensure your data is kept safe and secure and to prevent unauthorised access or use or loss of your data. We also make sure that when we are required to share your data with third parties, they are subject to suitable confidentiality and security standards.
Despite these measures, the transmission of data via the internet is not completely secure. As such, we cannot guarantee that information transmitted to us via the internet will be completely secure and any transmission is at your own risk.
Links to third party websites
How long do we store your data?
We will store your data for as long as you have an active Proatar account*, or as long as is needed to be able to provide the Services to you and/or where you are still happy to hear from us about our latest news, products and services.
*If you’ve not used your account for more than three years, it will be flagged as inactive and we’ll contact you to ask whether you want to keep it open. Unless you reply to say ‘yes’, we’ll close the account and delete or anonymise the personal data associated with it (unless the
After this, we may still need to keep hold of your data if there is a legal reason for doing so (such as for tax or other financial reasons), where we need to resolve any disputes with you, or
where we need to enforce the Customer Terms. In such circumstances, we will only retain the amount of data strictly necessary for these reasons and otherwise, will remove your data from our systems.
You have various rights under data protection laws which entitle you, in certain situations, to:
• ask us for a copy of the personal data we hold about you;
• correct or update your personal data;
• request that we delete your personal data;
• object to the handling of your personal data where we are relying on a legitimate interest (as set out in the above table);
• restrict the processing of your personal data;
• request the transfer of your personal data (or some of it) to a third party service provider; or
• where you have provided your consent for something, in certain circumstances, you may withdraw this consent (but note that we may continue to use your personal data if we have legal grounds for doing so).
And how to exercise them….
Please Contact Us at email@example.com if you would like to exercise your rights, which you can do for free. The only time we may be allowed to charge a reasonable fee is where your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. Otherwise, we will always respond within one month (unless there is a legal reason to take longer).
We may also need to ask you to confirm your identity before we proceed with your request if it is not
clear who is making the request.
If you are concerned about the way we are handling your personal data you may also contact the ICO (Information Commissioner’s Office). However, where possible, we would really appreciate the opportunity to help with your concern in the first instance.
Changes to this policy
We may change this policy from time to time, to reflect how we are handling your data and will upload these updates onto the Application. If we make significant changes, we will make sure these are notified to you by email or other suitable method so that you are able to review the changes before you continue to use the Application.
How to contact us
If you would like to discuss anything in this policy, want to exercise your rights or have any issues with the way we are handling your data, please:
Email us: firstname.lastname@example.org or
Write to us at:
Proatar Ventures Limited (registration number 10650992)
Attention: Data Protection Team
12 Sheep Walk, Emmer Green, Reading, RG48NE, UK
LAST UPDATED: September 2018
What are cookies and tracking technologies?
These essentially enable us to store information on your browser or device to enable us or them to identify you and monitor certain activities, for the purposes set out in this policy. They may: (i) expire at the end of your browser session (allowing us to link your activities during that session – these are often called “session cookies”); or (ii) be stored on your browser/device in between sessions, enablingus to remember your preferences and actions for future visits. They need to be manually deleted or will expire after the particular period set by that cookie – these are often referred to as “persistent cookies”.
Importantly, we will not use any cookies/tracking technologies which are not strictly necessary for the operation of the Proatar Application, without first getting your consent.
What types of cookies/tracking technologies do we use?
|Strictly necessary||These are required for the operation of the Proatar Application. They include, for example, cookies that enable you to log into secure areas of the Proatar Application.|
|Analytical/performance||These allow us to see how visitors use the Proatar Application (including time spent on pages, download errors, click throughs etc). This helps us to ensure that the Proatar Application is operating effectively.|
|Functionality||These are used to recognise you when you return to the Proatar Application. This allows us to tailor your browsing experience by personalising the content you see, greet you personally without you needing to input your details each time and to remember your preferences.|
How to block these cookies/tracking technologies
You can manage your settings and block cookies/tracking technologies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including strictly necessary cookies) you may not be able to access parts of the Proatar Application.