Introduction
Flutter Entertainment ("Flutter") respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from). This policy will tell you about your privacy rights and how the law protects you.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below.
Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
1. Important information and who we are
2. The data we collect about you
3. How is your personal data collected
4. How we use your personal data
5. Disclosures of your personal data
6. International transfers
7. Data security
8. Data retention
9. Your legal rights
10. Glossary
1. Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how Flutter collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our news announcements and/or fill out a contact form.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Controller
Flutter is the controller and responsible for your personal data (collectively referred to as Flutter, the “Company”, "we", "us" or "our" in this privacy notice). The pages on the website (‘the website’) are published by Design Portfolio on behalf of Flutter Entertainment (“Flutter Entertainment”, “us” or “we”). Design Portfolio will not collect any information about individuals, except where it is specifically and knowingly provided by them.
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.
Contact details
Our full details are:
FLUTTER ENTERTAINMENT,
Belfield Office Park,
Beech Hill Road,
Clonskeagh,
Dublin 4
or you can contact our Data Protection Officer on DP@Flutter.com
Filing a complaint
If you are not satisfied with how we manage your personal data, you have a right to make a complaint to your local Data Protection Authority.
Changes to the privacy notice and your duty to inform us of changes
We may change this policy by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective as of 25 February 2022.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. To amend your personal data, please contact communications@flutter.com
Third-party links
This website may include links to third-party websites, plug-ins and applications or store cookie files on your computer in order to deliver its service(s). Clicking on those links or enabling those connections may allow third parties to collect, store or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:
- Identity Data includes first name and last name.
- Contact Data includes company name, if applicable, and email address.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Profile Data includes your username or similar identifier and password, preferences.
- Usage Data includes information about how you use our website, products and services.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you;
- subscribe to our service or publications;
- enquire about our products or services
- Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie declaration for further details.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below.
- Technical Data from the following parties:
- Analytics, storage, tools and media providers;
- IP tracking service providers;
- automated quality control tools;
- automated security and compliance tools;
- social media and media networks such as Twitter, LinkedIn, YouTube and Vimeo; and
- email distribution and survey providers;
- Technical Data from the following parties:
- Identity, Contact and Usage data from providers of data feeds and hosting services provided in the UK.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
- Where you have provided your consent to process your data.
Click here to find out more about the types of lawful basis that we will rely on to process your personal data.
Where we rely on consent as a legal basis for processing your personal data you have the right to withdraw consent to marketing at any time by contacting us, or unsubscribing using the link in the communication you have received.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.
1. To register you as a new user
Type of data
(a) Identity
(b) Contact
Lawful basis for processing
Provision of consent
2. To manage our relationship with you
This includes answering any queries you may have
Type of data
(a) Identity
(b) Contact
(c) Marketing and Communications
Lawful basis for processing
(a) Necessary to comply with a legal obligation
(b) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
3. To administer and protect our business and this website
This includes troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data.
Type of data
(a) Identity
(b) Contact
(c) Technical
Lawful basis for processing
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)
(b) Necessary to comply with a legal obligation
4. To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Type of data
(a) Technical
(b) Usage
Lawful basis for processing
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
5. To make suggestions and recommendations to you about goods or services that may be of interest to you
Type of data
(a) Identity
(b) Contact
Lawful basis for processing
Necessary for our legitimate interests
6. To provide regulatory news via an automated email alert service
Type of data
(a) Identity
(b) Contact
Lawful basis for processing
Necessary for our legitimate interests and as you have requested to receive RNS announcements
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and communications. We have established the following personal data control mechanisms:
Third-party marketing
We will get your express opt-in consent before we share your personal data with any company outside the Flutter group of companies for marketing purposes.
Opting out
You can ask us or third parties to stop contacting you at any time by contacting us or clicking ‘unsubscribe’ on your email alerts.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase or experience or other transactions.
Cookies
Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site about aspects of your visit. For more information about the cookies we use and how you can control them, please see our cookie declaration.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in section 4 above.
- Internal Third Parties as set out in the Glossary.
- External Third Parties as set out in the Glossary.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
Flutter Entertainment operates businesses in multiple jurisdictions some of which are not located in the European Economic Area (“EEA”). Countries outside the EEA do not always have strong data protection laws. Where we transfer personal information from the EEA to other countries in which applicable laws do not offer the same level of data privacy protection as in your home country, we take measures to provide an appropriate level of data privacy protection. For example, we use approved contractual clauses, intragroup agreements and other measures designed to ensure that the recipients of your personal information protect it. We take steps to ensure that the information we collect is processed according to this privacy policy and the requirements of the applicable law wherever the data is located. Please contact us below if you require further information.
Please contact us if you would like further information on the specific mechanism used by us when transferring your personal data out of the UK.
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.
8. Data retention
How long will you use my personal data for?
We retain personal information for as long as we reasonably require it for legal or business purposes. We will take all necessary steps to ensure that the privacy of information is maintained for the period of retention.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
- Access to personal data
- Correction of personal data
- Right to withdraw consent
- Right of erasure
- Right to data portability
- Right to restrict processing of personal data
- Right to object to processing of personal data
- Rights relating to automated decision making and profiling
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access 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. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
THIRD PARTIES
Internal Third Parties
Other companies in the Flutter Group including all or any of its direct or indirect subsidiary undertakings, joint venture partners, and their related companies wherever located in the world as may exist from time to time acting as independent controllers AND/OR processors.
External Third Parties
- Digital service providers acting as processors, who provide a number of services, including but restricted to data feeds, hosting, SSL, data analysis, CRM, video streaming, social media and sharing services.
- Marketing services providers acting as processors including mailing and survey companies who provide distribution, reporting and analysis of emails and surveys.
- Regulators, law enforcement
YOUR LEGAL RIGHTS
Under the General Data Protection Regulation, and any other laws in your country of residence, you, as a data subject have a number of rights which are detailed below. Some of these only apply in specific circumstances and are qualified in several respects by exemptions in data protection legislation. We will advise you in our response to your request if we are relying on any such exemptions.
- Access to personal data: You have a right to request a copy of the personal information that we hold about you. Should you wish to make such a request, please see the Contact Us section for information on how to contact us.
You should include adequate information to identify yourself and such other relevant information that will reasonably assist us in fulfilling your request. Your request will be dealt with as soon as possible. - Correction of personal data: You can request us to rectify and correct any personal data that we are processing about you which is incorrect. We provide you with account settings and tools to access the information associated with your account.
- Right to withdraw consent: Where we have relied upon your consent to process your personal data, you have the right to withdraw that consent.
To opt out of marketing, you can use the unsubscribe link found in the marketing communication you receive from us. For other marketing preferences, you can visit the My Account tab when you log into your account or the "Contact Us" option within the relevant Service. - Right of erasure: You can request us to erase your personal data where there is no compelling reason to continue processing. This right only applies in certain circumstances, it is not a guaranteed or absolute right.
- Right to data portability: This right allows you to obtain your personal data that you have provided to us with your consent or which was necessary for us to provide you with our products and services in a format which enables you to transfer that personal data to another organization. You may have the right to have your personal data transferred by us directly to the other organization, if this is technically feasible.
- Right to restrict processing of personal data: You have the right in certain circumstances to request that we suspend our processing of your personal data. Where we suspend our processing of your personal data we will still be permitted to store your personal data, but any other processing of this information will require your consent, subject to certain exemptions.
- Right to object to processing of personal data: You have the right to object to our use of your personal data which is processed on the basis of our legitimate interests. However, we may continue to process your personal data, despite your objection, where there are compelling legitimate grounds to do so or we need to process your personal data in connection with any legal claims. You can exercise your right to object to any profiling that takes place in the course of our use of cookies by managing your settings preferences, as outlined in our Cookie Policy. You also have the right to object to any profiling that is carried out for the purpose of direct marketing. You can exercise this right by using the unsubscribe link found in the marketing communication that you receive from us.
- Rights relating to automated decision making and profiling: You have the right not to be subject to a decision which is based solely on automated processing (without human involvement) where that decision produces a legal effect or otherwise significantly affects you. This right means you can request that we involve one of our employees or representatives in the decision-making process. We are satisfied that we do not make automated decisions of this nature.