Privacy Policy

Effective Date: 1 October, 2019

Who are we?

We are Stakester Ltd (“Stakester”) registered in the UK at Companies House under number 11876982 (incorporating Stakester Inc in the USA, which is a wholly owned subsidiary of Stakester Ltd).

We are based at Kemp House, 160 City Road, London, United Kingdom, EC1V 2NX

Our Data Protection Officer can be reached by emailing privacy@stakester.com. Stakester plays a dual role when it comes to processing. In some situations, we act as a Controller, in others we are the Processor. 

Stakester as a Processor

When we are a Processor of personal data, we are doing so purely on the instruction of another company (the Controller). If you are a customer, then that company is likely to be the card or merchant provider or Google as a search engine provider. To find out more about how your data is protected by them, you should contact them directly. A non-exhaustive list is:

Apple Store / In-App Payments
Their Privacy Policy can be viewed at: https://www.apple.com/legal/privacy/en-ww/

Google Analytics 
This is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

Google Play / In-App Payments
Their Privacy Policy can be viewed at: https://www.google.com/policies/privacy/

Mastercard
Their Privacy Policy can be viewed at: https://www.mastercard.co.uk/en-gb/about-mastercard/what-we-do/privacy.html

Safecharge
Their Privacy Policy can be viewed at:https://www.safecharge.com/privacy-cookies-policy/

Visa
Their Privacy Policy can be viewed at:https://www.visa.co.uk/legal/privacy-policy.html

We have chosen to appoint a Data Protection Officer because we process a lot of sensitive data on behalf of other companies and we want to ensure that we are protecting your rights and freedoms at all times, in the course of our day to day activities.

Stakester as a Controller

Tell me more…
Stakester also act as a Controller. This is only for the data that we process for our day to day internal business operations, as well any technical data that is collected by our app.We only collect the data that we need to carry out a task and do not keep data longer than is necessary. We delete data when it is no longer required for the purpose that we collected it.This privacy notice refers to the data we process as a Controller only.We are happy to talk to you about how we process and protect data, just email us privacy@stakester.com

Customer Privacy Notice

Data that we hold and how we use it
As a Customer, we hold the gaming, location, contact and payment details required to carry out our contract with you, manage our relationship and keep you up to date with changes and improvements to our services. This data would have been sourced from you directly.

Lawful basis for processing
Our lawful basis for processing your data is a combination of Contract and Legitimate Interest. We use legitimate interest when we use your data to keep you up to date with changes and improvements to our goods and services. Results of a legitimate interest balancing test indicate that this use is pursuing a legitimate interest, is necessary for the purpose of keeping you updated and growing our business, and unlikely to cause you risk or harm. 

Data Sharing and Transfers
Like most companies, we use a number of third parties as part of our data processing, for example cloud services and technology services. We have Data Processing Agreements in place with these providers. Where data is transferred outside of the EEA, we ensure that appropriate protection and mechanisms are in place.We do not sell your data to anybody and we do not share it with anyone other than our contracted processors.

Retention Periods
We hold data on Customers for the length of time that you are a customer of ours, then another 7 years in case of any dispute.

Technical and Operational Security
All data is password protected, access controlled, backed up securely and encrypted when appropriate.All employees are trained in data protection and are aware of their obligations to ensure the privacy of all data subjects.Data Privacy by Design and Default is an integral part of our development processes.

Your Rights
You have rights in respect of our processing of your personal data. The relevant rights are:Request a copy of your personal data and information about our processing of itRequest that we delete information on you, if we do not need to hold itRequest that we correct any personal data that we hold on youRequest that we stop processing your data, although we can still hold itRequest that we move your data to another organisation’s IT system electronically, in some circumstancesRequest that we suppress your data for marketing purposesIf we have used consent as our lawful basis for processing your data then you have the right to withdraw consent at any time.If you want to exercise any of these rights, just contact us on privacy@stakester.com

You also have the right to lodge a complaint about our processing with a supervisory authority — in the UK that is the ICO whose details are here: https://ico.org.uk/global/contact-us/postal-addresses/

Employee Privacy Notice
If you are an Employee of Stakester, please refer to the Data Protection notice that is stored in the Employee Handbook.

Potential Customer Privacy Notice

Data that we hold and how we use it
As a Potential Customer, we hold your name, location, gaming and contact details so we can build a relationship with you. This data will have been sourced directly from you at an event, or from your company website or a similar publicly available source. We only hold your data if we legitimately think you will have an interest in using our product.

Lawful basis for processing
Our lawful basis for processing your data is a Legitimate Interest for marketing purposes. We give you the chance to opt out of all marketing on anything that we send you. We only share details of our own goods and services in our marketing. If your data was not sourced directly from you, then we will contact you once we have the data to let you know that we have your data and give you the chance to opt out. Our legitimate interest balancing test indicates that this is a legitimate purpose: you would not be surprised to hear from us based on the nature of your job role, and our processing does not cause any harm or risk to you as a data subject.

Data Sharing and Transfers
Like most companies, we use a number of third parties as part of our data processing, for example cloud services and technology services. We have Data Processing Agreements in place with these providers. Where data is transferred outside of the EEA, we ensure that appropriate protection and mechanisms are in place.We do not sell your data to anybody and we do not share it with anyone other than our contracted processors.

Retention Periods
We hold data on potential customers for as long as we think you are likely to be interested in our goods and services, or until the point at which you opt out of communications. At this point you are added to a suppression list so we do not contact you again. When you become a Customer, then the privacy Notice for Customers will apply.

Technical and Operational Security
All data is password protected, access controlled, backed up securely and encrypted when appropriate.All employees are trained in data protection and are aware of their obligations to ensure the privacy of all data subjects.Data Privacy by Design and Default is an integral part of our development processes.All devices are protected by a leading enterprise mobility management technology

Your Rights
You have rights in respect of our processing of your personal data. The relevant rights are:Request a copy of your personal data and information about our processing of itRequest that we delete information on you, if we do not need to hold itRequest that we correct any personal data that we hold on youRequest that we stop processing your data, although we can still hold itRequest that we move your data to another organisation’s IT system electronically, in some circumstancesRequest that we suppress your data for marketing purposesIf we have used consent as our lawful basis for processing your data then you have the right to withdraw consent at any time.If you want to exercise any of these rights, just contact us on privacy@stakester.com

You also have the right to lodge a complaint about our processing with a supervisory authority — in the UK that is the ICO whose details are here:https://ico.org.uk/global/contact-us/postal-addresses/

Investor/Shareholder Privacy Notice

Data that we hold and how we use it
As an Investor or private Shareholder in Stakester, we hold your contact details. This data would have been sourced from you directly.

Lawful basis for processing
Our lawful basis for processing your data is a legal obligation; we are legally obliged to document who the owners of our business are. 

Data Sharing and Transfers
Like most companies, we use a number of third parties as part of our data processing, for example cloud services and technology services. We have Data Processing Agreements in place with these providers. Where data is transferred outside of the EEA, we ensure that appropriate protection and mechanisms are in place.We share your contact details in line with our regulatory requirements, so will be listed in official documents such as company filings and would be used in any potential data room.

Retention Periods
We hold your contact data for the length of time that you are an investor or shareholder of ours, then until the expiration of the legal obligations.

Technical and Operational Security
All data is password protected, access controlled, backed up securely and encrypted when appropriate.All employees are trained in data protection and are aware of their obligations to ensure the privacy of all data subjects.Data Privacy by Design and Default is an integral part of our development processes.

Your Rights
You have rights in respect of our processing of your personal data. The relevant rights are:Request a copy of your personal data and information about our processing of itRequest that we delete information on you, if we do not need to hold itRequest that we correct any personal data that we hold on youRequest that we stop processing your data, although we can still hold itRequest that we move your data to another organisation’s IT system electronically, in some circumstancesIf you want to exercise any of these rights, just contact us on privacy@stakester.com

You also have the right to lodge a complaint about our processing with a supervisory authority — in the UK that is the ICO whose details are here: https://ico.org.uk/global/contact-us/postal-addresses/

App User Privacy Notice

Data that we hold and how we use it
As an App User, you provide some data to enter into a contract with us. This will be your name and contact details as well as gaming and location data. We also process data about the way you use our app, including your IP address and browsing time. This helps us to optimise the performance of our app, monitor it for security purposes and drive improvements for our users.

Lawful basis for processing
Our lawful basis for processing your data is a combination of Contract, Legitimate Interest and Consent. We use your contact details to provide you with the app and the appropriate technical support as needed; this is our contract with you. We use legitimate interest when we use your data to improve the performance of the app, process your data for marketing purposes, and protect it from illegal use. Results of a legitimate interest balancing test indicate that this use is pursuing a legitimate interest,  and unlikely to cause you risk or harm. When we send marketing messages to you, we rely on consent under the Privacy and Electronic Communications Regulations (PECR). This consent is collected via the app. You can withdraw this consent at any time.

Data Sharing and Transfers
Like most companies, we use a number of third parties as part of our data processing, for example cloud services and technology services. We have Data Processing Agreements in place with these providers. Where data is transferred outside of the EEA, we ensure that appropriate protection and mechanisms are in place.We do not sell your data to anybody and we do not share it with anyone other than our contracted processors.

Retention Periods
We hold data used to fulfil the contract for 36 months after the termination of the contract.We delete log data 36 months after you cease using the app.We remove you from our marketing database, onto a suppression list, when you opt out of receiving communications from us.

Technical and Operational Security
All data is password protected, access controlled, backed up securely and encrypted when appropriate.All employees are trained in data protection and are aware of their obligations to ensure the privacy of all data subjects.Data Privacy by Design and Default is an integral part of our development processes.

Your Rights
You have rights in respect of our processing of your personal data. The relevant rights are:Request a copy of your personal data and information about our processing of itRequest that we delete information on you, if we do not need to hold itRequest that we correct any personal data that we hold on youRequest that we stop processing your data, although we can still hold itRequest that we move your data to another organisation’s IT system electronically, in some circumstancesRequest that we suppress your data for marketing purposesWhere we have used consent as our lawful basis for processing your data then you have the right to withdraw consent at any time.If you want to exercise any of these rights, just contact us on privacy@stakester.com

You also have the right to lodge a complaint about our processing with a supervisory authority — in the UK that is the ICO whose details are here: https://ico.org.uk/global/contact-us/postal-addresses/

Website Browsing Privacy Notice

Data we process
When you browse our website we drop only essential cookies or web beacons that make our site work or which can be used to improve our service to you. These may include tracking cookies, session cookies, preference cookies and security cookies. If you submit data into the forms on our website to request a demo or further information then we process your name, address, gaming data and any other contact information you provide, including your phone number, only for the purposes that you have provided it for. The lawful basis for processing this data is contract, you have supplied information with a view to us offering you a service.

Data Sharing and Transfers
Like most companies, we use a number of third parties as part of our data processing, for example cloud services and technology services. We have Data Processing Agreements in place with these providers. Where data is transferred outside of the EEA, we ensure that appropriate protection and mechanisms are in place.We do not sell your data to anybody and we do not share it with anyone other than our contracted processors.

Technical and Operational Security
All data is password protected, access controlled, backed up securely and encrypted when appropriate.All employees are trained in data protection and are aware of their obligations to ensure the privacy of all data subjects.Data Privacy by Design and Default is an integral part of our development processes.

Your Rights
You have rights in respect of our processing of your personal data. The relevant rights are:Request a copy of your personal data and information about our processing of itRequest that we delete information on you, if we do not need to hold itRequest that we correct any personal data that we hold on youRequest that we stop processing your data, although we can still hold itRequest that we move your data to another organisation’s IT system electronically, in some circumstancesRequest that we suppress your data for marketing purposesIf we have used consent as our lawful basis for processing your data then you have the right to withdraw consent at any time.If you want to exercise any of these rights, just contact us on privacy@stakester.com

You also have the right to lodge a complaint about our processing with a supervisory authority — in the UK that is the ICO whose details are here: https://ico.org.uk/global/contact-us/postal-addresses/

Children’s Privacy
Our Service does not  address anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us on privacy@stakester.com. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

Privacy Policy Variation
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We will let you know via email or  a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page

Contact and complaints
As stated throughout you can contact our DPO on privacy@stakester.com You also have the right to lodge a complaint about our processing with a supervisory authority — in the UK that is the ICO whose details are here: https://ico.org.uk/global/contact-us/postal-addresses/