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.
Who we are and how to contact us
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 firstname.lastname@example.org.
The types of personal data we collect about you
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:
directly from you, when you sign up for our services and when you browse our sites or use our apps
personal data we generate about you, e.g. personal data we use to authenticate you, or personal data in the form of your IP address or your preferences
personal data we collect from third parties, e.g. personal data that helps us to combat fraud or which we collect, with your permission, when you interact with your social media accounts
Personal data we generate about you
your IP address - a numerical code to identify your device, together with the country, region or city where you are based
your geolocation data - your IP address can be used to find information about the latitude, longitude, altitude of your device, its direction of travel, your GPS data and data about connection with local Wi-Fi equipment
information on how you interact with our services
your browsing history of the content you have visited on our sites, including how you were referred to our sites via other websites
details of your computer, mobile, TV, tablet or other devices, for example, the unique device ID, unique vendor or advertising ID and browsers used to access our content
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.
When you use our apps
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.
How we collect personal data
We collect personal data when you:
subscribe to our newsletter(s) or alerts
enter our competitions and surveys
sign up for marketing communications
use mobile devices to access our content
access and interact with any of our sites and app
through cookies and other similar technology
when you contact us via email, social media, our apps or similar technologies or when you mention us on social media
How we use your personal data
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.
Legal grounds for using 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.
Compliance with law
In some cases, we may have a legal obligation to use or keep your personal data.
Our legitimate interests
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 we analyse what content has been viewed on our sites and apps, so that we can understand how they are used and improve our content
to carry out marketing analysis to better understand your interests and preferences so that we can make our marketing more relevant to your interests and preferences
to show you personalised advertising by creating “segments” of particular types of audiences so that we may show you advertisements that may be more relevant to your interests and the ‘’segments’’ you may be in. These ‘’segments’’ are also used to inform the building of custom audiences so that we can identify our audience across third party websites, such as social media platforms like Facebook.
for internal administrative purposes related to when you use our services - such as our accounting and records - and to make you aware of any changes to our services
to collect and log IP addresses to improve the website and monitor website usage
to personalise our services (for example, so you can sign in) by remembering your settings, and recognising you when you sign in on different devices
enabling you to share our content with others using social media or email
when responding to your queries and to resolve complaints
Personal data that we receive about you from other organisations
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.
Using children’s personal data
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.
Security of your personal data
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.
When we share or sell your personal data
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:
error tracking software providers, such as Google Firebase, to help us diagnose and fix errors and optimise the performance of our website and apps
service providers that help us carry out analytics, facilitate audience creation and segmentation and to measure our audience engagement
service providers that help provide us with insights and analytics that help us to improve our products and services. For example, we use Google Analytics to understand how visitors engage with our sites or apps . If you don’t want Google Analytics to be used in your browser, you can install the ‘Google Analytics Opt-Out Browser Add-On’, provided by Google
data management companies that help us collect data via online forms and surveys
Agencies and authorities if required by law
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.
Social media organisations
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.
Organisations that acquire NineThreeSeven
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.
International data transfers
Whenever we transfer your personal data out of the European Economic Area (EEA), we ensure appropriate safeguards.
How long we keep your personal data
Sometimes we may contact you for market research purposes, for example about a survey.
Responding to your queries or complaints
If you have raised a query or a complaint with us, we may contact you to answer your query or to resolve your complaint.
Special Note to California Users
If you elect to use the “do not sell” button, we will not recontact you about that choice for at least 12 months.
Cookies and similar technologies
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.
What is a cookie?
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.
Understanding how you use our site
Showing you content that is relevant to you
Showing you products and services that are relevant to you
Working with partners to deliver to you relevant advertising
Ultimately, this allows us to provide our services free of charge.
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.
What types of cookies do we use?
We use four types of cookies:
Essential – cookies that are essential to provide you with services you have requested.
Performance – cookies which measure how often you visit our sites and how you use them. We use this information to get a better sense of how our users engage with our journalism and to improve our sites and apps, so that users have a better experience.
Functionality – cookies that are used to recognise you and remember your preferences or settings when you return to our site, so that we can provide you with a more personalised experience.
Advertising – cookies that are used to collect information about your visit to our site, including the content you have viewed, the links you have followed and information about your browser, device and your IP address. We have set out more details on this below.
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.
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.
How to manage advertising cookies on our websites and apps
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.
Your privacy and data protection rights with regard to the personal data that we hold about you
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:
You have the right to receive a copy of the personal data we hold about you
You have the right to correct the personal data we hold about you
Where applicable, you may also have a right to receive a machine-readable copy of your personal data
You also have the right to ask us to delete your personal data or restrict how it is used, consistent with the GDPR. There may be exceptions to the right to erasure for specific legal reasons which, if applicable, we will set out for you in response to your request
Where applicable, you have the right to object to processing of your personal data for certain purposes
Where you have provided us with consent to use your personal data, you can withdraw this at any time
If you would like to exercise any of your rights specified above, please email email@example.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.
Your California privacy rights
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:
Right of Access: You have a right to request access to the personal data we may hold on you for the past twelve (12) months. You may submit up to two (2) requests per year of access to your personal data.
Right to Opt-In/Opt-Out of Sale of Personal Data: For individuals sixteen (16) years or older, you have the right to opt-out of sale of personal data we may hold on you. You can exercise this right at any time by pressing the “Do not sell” link in the footer of every page. For individuals between thirteen (13) to sixteen (16) years old, you have the right to opt-in to the sale of personal data we may hold on you.
Right to Deletion: You also have the right to ask us to delete personal data we may hold on you or restrict how it is used. There may be exceptions to the right to deletion for specific legal reasons which, if applicable, we will set out for you in response to your request.
Right to Non-Discrimination: We will not discriminate against you for exercising any of your California Consumer Privacy Act rights.
If you want to make any of these requests, please contact firstname.lastname@example.org.
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 under the Australian Privacy Act
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.
If you have contacted us at email@example.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
Contact us for information about how we use your personal data
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 firstname.lastname@example.org. 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.
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