Last Updated September 2022
Our registered office is at 1 Charterhouse Mews, London, England, EC1M 6BB. We are a company registered in England and Wales, with company number 11507205.
- What information we may collect about you;
- How we will use information we collect about you;
- Whether we will disclose your details to anyone else; and
- Your choices and rights regarding the personal data we hold about you.
Please note that our Platform may enable you to interact with, and share personal data with, third parties. Please see the ‘Interacting with third parties’ section below for more information.
2. PERSONAL DATA WE MAY COLLECT ABOUT YOU
We may collect and process the personal data set out below when you use our Platform or otherwise deal with us. When we talk about “personal data”, we mean any information which relates to an identified or identifiable living individual. Individuals might be identified by reference to a name, an identification number, location data, an online identifier (such as an IP address) or to other factors that are specific to them, such as their physical appearance.
Information that you need to provide or that is created when creating a Fan Account or a Publisher Accont (together “Account”) on the Platform and/or information that you supply as part of your profile (“Profile Information”)
- Your account name;
- Your username (your handle) – please note that this will be assigned to you automatically although you can request that we change this to a username of your choosing, subject to availability and it complying with our username requirements, by contacting us at email@example.com;
- Your password for the Platform;
- Your profile image;
- You phone number;
- Your email address;
- Your preferences/interests (e.g. what sports you like to watch); and
- Any other information that you supply as part of your Account profile, such as your date of birth, gender and your address.
Information that may be provided by you when you contact us or when we otherwise deal with you (“Contact Information”)
- Your full name;
- Your username;
- Your email address;
- Your telephone number (if you choose to provide this); and
- Details of your enquiry or our relationship with you or the organisation you represent.
When you purchase Cast Credits, when we send you a refund or we otherwise make payments to you, we and/or our third party payment service providers will process your card payment and/or bank account information in order to facilitate these transactions.
When Users upload Content to the Platform we will process any personal data that is contained in the Content.
Information that is automatically generated by us and/or is collected by cookies and similar technologies (“Insights Information”)
We and/or our third party service providers may collect the following data (some of which will be data relating to your interests) using Cookies:
- a count of the number of visitors to our Platform or users that have opened one of our emails;
- device and browser operating system, type, version, make and model;
- IP address and device identifiers communicated by your device;
- pages visited and Content viewed on the Platform, including time spent;
- page interaction information, such as scrolling, clicks and browsing methods;
- websites where visitors have come from and where they go afterwards;
- page response times and any download errors; and
- other technical information relating to end user device, such as IP address or browser plugin.
Information collected via our Social Media channels (“Social Media Information”)
The Platform contains links to our channels on Facebook, Instagram, Twitter, LinkedIn, TikTok and Snapchat. These third party platforms have their own respective privacy policies (which we would advise you to read) for which those sites are solely responsible. Should you visit our social media pages and choose to follow or connect with us on social media (including interacting with any ‘like’ or similar embedded features on our Platform or social media channels), we may receive personal data from the social media providers (depending on your social media privacy settings), including:
- your name (and/or your social media unique username);
- your email;
- your gender and/or age; and
- your general interests and preferences (e.g. Likes, Shares, Posts).
Job Application Information
As part of any recruitment process, we collect and process personal data relating to job applicants. Such data may include:
- your name, address and contact details, including email address and telephone number;
- details of your qualifications, skills, experience, and employment history;
- information about your current level of remuneration, including benefit entitlements; and
- any other information that you voluntarily submit as a part of the recruitment process.
We may collect this information in a variety of ways. For example, personal data might be contained in application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment, including online tests.
3. HOW WE USE YOUR PERSONAL DATA?
To provide the Platform to you and other Users
We will process your personal data (in particular the Profile Information and Content Information) to process and validate your account registrations and to deliver our Platform to you under the T&Cs.
The Platform also enables Users to purchase and/or earn Cast Credits (and Publishers to earn money) as set out in our T&Cs. We and/or our third party payment partners process your personal data (in particular Insights Information relating to Content that you view on the Platform and your Payment Information) to calculate how many Cast Credits and/or how much money you and other Users have earned and/or spent as a result of your use of the Platform and to process your transactions (in particular purchases, refunds and other payments that we make to you).
Where indicated on the Platform, some of your Profile Information (in particular your handle) may be visible to other Users.
The processing of information in this way is necessary for us to ensure the Platform delivers the features promised and functions properly. For these purposes, we rely upon the legal basis of performance of the contract that we have with you (being the T&Cs) or it is otherwise in our and/or our other Users’ legitimate interests (being our commercial interests in providing enhanced services and functionality to you and our oth
To respond to your enquiries and requests for support
We will process personal data about you (in particular your Contact Information) so that we are able to properly respond to your enquiries and support requests, in accordance with the T&Cs.
For the above purposes, we rely upon the legal basis of performance of a contract (being our T&Cs) and our legitimate interests, being our commercial interests to respond to your queries and requests for support.
To undertake surveys and obtain feedback
From time to time we may invite you to provide feedback about us, our Platform and/or Content in the form of online surveys. We will collect and process your personal data (in particular your Contact Information and, if applicable, certain Profile Information and Insights Information, as well as any other personal data you choose to volunteer in your response) so that we can effectively obtain and analyse this feedback.
We use this information to help us to monitor and improve our Platform.
It is in our legitimate interest to use the personal data provided by you so that we can improve our Platform and provide it in an effective way.
To directly market Content and the Platform to you
We may use your personal data (including your Contact Information) to send you push notifications and/or emails in order to keep you informed with news and updates about the Platform and Content that we think you may be interested in.
Our marketing may be non-personalised (i.e. aimed at our Users in general) or personalised to you based on your personal data (please see the ‘To help us personalise your Recast experience’ section below for further information about how we personalise our marketing and the lawful basis that we rely on to do so).
It is in our legitimate interest to use your personal data for marketing purposes, however we will only send marketing communications to you by email where you have consented to receive such content by email, or where we have another lawful right to send marketing to you using email. For example, in certain circumstances we may rely on our legitimate interest to send marketing by email to Users that have made purchases on the Platform. We may also rely on our legitimate interest to send marketing by email to certain business Users of our Platform.
Note, we may run partnerships with other companies and brands in the sports and ticketing space, including Publishers, with whom we may share your personal data for their own marketing purposes. Where we share your personal data in this way, we will obtain your consent.
We hope that you would like to receive our updates, but we do not want to send you marketing that is not of interest for you. You can unsubscribe from any marketing emails that we send by clicking unsubscribe at the bottom of any marketing email that you receive from us. You can also turn off push notifications by using the settings made available to you on the Platform.
To personalise your Recast experience
We and our third party partners may process your personal data to personalise your Recast experience. By ‘personalising your Recast experience’, we mean using your personal data to:
- determine the type of Content that we think you may be most interested in, and showing you that Content;
- tailor our own marketing materials that we send to you (see the ‘To directly market the Platform and Content to you’ section above).
We and our third party partners use your Profile Information (typically the preferences/interests, such as what sports you like to watch, that you have told us about) together with any of your personal data that our third party partners may independently hold to do this. We do this so that the Content and marketing you receive is likely to be more relevant to your interests. For example, if you’ve told us that you like to watch football, you may see more Content on the Platform relating to football, or we might send you an email about a football club’s Channel on our Platform.
It is in our legitimate interests to engage with our Users and ensure that they receive the best possible experience on the Platform.
To personalise advertising that you see on our Platform
We and our advertising partners may process your personal data (such as Insights Information and certain Profile Information, together with any of your personal data that our advertising partners may independently hold) to place you in ‘audiences’ (based on, for example, your interests, demographic information and/or location).
We and our advertising partners use these audiences to personalise the advertisements that you see on our Platform. This may also include showing you advertisements for third party services when you use our Platform. Please note that the contents of third party advertisements that you see on the Platform are provided by these third parties and not us.
We rely on your consent to personalise your experience in the manner described above. We collect this in various ways. For example:
- where your personal data is collected through the use of non-essential Cookies, we and our third party partners generally rely on your consent to collect your personal data and for the subsequent processing of it, as indicated through your Cookie preferences. You can change your Cookie preferences at any time by visiting your Cookie Settings
- where your personal data is supplied by you, we will obtain your consent at the point at which we collect that personal data. You can withdraw that consent at any time either by contacting us as indicated below or by using any feature that we may provide through the Platform, such as unticking the relevant box in your profile.
To deliver advertising relating to our Platform to you on other websites and services
We and our third party partners may show advertisements relating to our Platform to you when you use third party websites and services (including social media and other platforms). In particular we and our third party partners may advertise you in the following ways:
- Online personalised advertising
We and our third party partners may use your Insights Information and other data that is collected through your interactions with third party websites and services (including social media and other platforms) to provide you with, and analyse the effectiveness of, personalised ads when you visit other websites and/or use other services.
By “personalised ads”, we mean advertisements for Content or services that you may have shown an interest in when you have used our Platform or which we or our partners otherwise think you might be interested in based on your browsing habits. Note, our third party partners may also use the data that is collected to show personalised ads for products and services offered by third parties.
- Advertising to you on social media and other platforms
We may share your email address and other identifiers such as your phone number or device ID (usually in an encrypted or ‘hashed’ form) with third party providers of social media platforms and other services, such as Facebook, and other similar platforms (“Social Platforms”), so that the third party providers can try to “match” your data with the data of their registered users.
Where there is a successful match, our advertising will be displayed to you when you use the relevant Social Platform (e.g. on your Facebook newsfeed) or we may decide to exclude you from the audience that sees the advertising (e.g. where we want to show our advertisements to people that do not use our Platform). This is known as “custom audience” advertising, because we “customise” the audience that we want to reach on the relevant Social Platform.
Some of the advertising that you see may be personalised to you (please see the ‘Personalising your experience on the Platform and the marketing advertising that we deliver to you’ section below).
This activity is also subject to the privacy choices you have elected to make on such Social Platforms.
- Advertising to other people who share similar interests and characteristics to you (or if you are someone that has seen this advertising)
We will provide your personal data to third party providers of Social Platforms (as described above and in the ‘Personalising your experience on the Platform and the marketing/advertising that we deliver to you’ section). We may ask the third party providers of those Social Platforms to find other registered users of their services who share similar interests and characteristics to you, which will be based on information that the third party holds about you and its other registered users.
This is known as “lookalike” audience advertising because we are trying to show our advertising to people who “look like” you.
If you are someone who has seen this advertising on a Social Platform, please note that this activity is based on data that you have provided to the Social Platform (which we do not receive) and is also subject to the privacy choices you have elected to make on such third party services.
Where we use your personal data in respect of the above activities, we rely on the consent that you have provided in respect of the collection of such data, or it is otherwise in our legitimate interests to promote our Platform to you in this way.
Note, it is in our legitimate interests to further use your personal data to advertise our Platform to those who share similar interests and characteristics with you. If you are someone who has seen this advertising (because we think you ‘look like’ our Users) , it is in our legitimate interests that the Social Platform uses the data that you have provided to it to advertise our Platform, although please note that we do not receive this data and you should exercise your rights in respect of such data in accordance with the privacy notice of the relevant Social Platform.
Operating our Social Media channels
We may process personal data (including the Social Media Information), to engage with Users on our social media channels and to find out how Users interact with our social media channels.
We process this personal data on the basis of our legitimate interests, being our interests in engaging with our Users and promoting the commercial success of our Platform (including by improving our advertising and marketing).
To run prize draws, prize competitions and other promotions
From time to time we may run prize draws, prize competitions and other promotions on our Platform and/or on our social media accounts. For the purposes of administering such promotions, we may process your personal data (including Contact Information and any other personal data volunteered by you in relation to your entry to the promotion, including your physical address).
Our promotions are subject to separate terms and conditions, which you may be required to accept as a condition of entry.
It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you (e.g. the promotion terms and conditions) or it is in our legitimate interest to use your personal data to enable us to administer our promotion fairly and effectively and to ensure that we comply with self-regulatory codes governing the operation of promotions.
To maintain and keep secure our Platform and to prevent fraudulent, illegal or unacceptable activity
We will process your personal data to ensure that our Platform and our Users are kept secure and free of harm, to ensure that your use of our Platform is lawful and in compliance with our T&Cs, to maintain and prevent disruption to our Platform (including to fix any problems that arise).
It is in our and our User’s legitimate interests to use your personal data in this way, to ensure that our Platform operates in a secure and effective way.
For insights and analytics purposes
We may process your personal data (including your Profile Information, Insights Information, and Content Information) so that we can better understand our Users and their use of our Platform (for example, which parts of our Platform are most popular with our Users).
We will analyse this data to improve and measure the effectiveness of our Platform (including any Content or services that we provide through the Platform) and our marketing activities, to develop new services, and to remember your preferences.
We may aggregate and/or de-identify this information so that it cannot be linked to you. We may then use that aggregated and/or de-identified information for any purpose, including marketing, and share that information with any third parties, including our advertising partners and Publishers.
We and our third party partners may also use Insights Information to measure the effectiveness of advertisements that you see on the Platform and our marketing communications, and this information may be shared with advertisers on an anonymous and/or aggregate basis. We may also publicise anonymous, aggregate statistics through our website or other channels although this will not include your personal data.
If you apply for a job with us, we will use your Job Applicant Information to conduct our recruitment process, including assessing your skills, qualifications and suitability for the role and/or communicating with you about the recruitment process.
We need to process this information to take steps at your request prior to entering into a contract with you.
In some cases, we need to process personal data to ensure that we are complying with our legal obligations. For example, we are required to check a successful applicant’s eligibility to work in the location of our offices before employment starts.
We also have a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows us to manage the recruitment process, assess and confirm an applicant’s suitability for employment and decide to whom to offer a job.
Receipt of products and services from our suppliers
If we have engaged you or the organisation you represent to provide us with products or services (for example, if you or the organisation you represent provide us with services such as IT support or financial advice), we will collect and process your personal data (in particular your Contact Information) in order to manage our relationship with you or the organisation you represent, to receive products and services from you or the organisation you represent and, where relevant, to provide our Platform.
It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you or the organisation you represent, or it is in our legitimate interest to use personal data in such a way to ensure that we have an effective working relationship with you or the organisation you represent and are able to receive the products and services that you or your organisation provides, and provide our Platform to others, in an effective way.
Business administration and legal compliance
We may use your personal data: (i) to comply with our legal obligations; (ii) to enforce our legal rights or defend potential legal claims; (iii) to protect the rights of third parties; and (iv) in connection with a business transition such as a merger, reorganisation, acquisition by another company, or sale of any of our assets.
Where we use your personal data in connection with a business transition, to enforce our legal rights or to protect the rights of third parties, it is in our legitimate interest to do so. For all other purposes described in this section, we have a legal obligation to use your personal data to comply with any legal obligations imposed upon us, such as a court order.
We will not process any special (or sensitive) categories of personal data or personal data relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent
4. DATA SHARING
Third party suppliers who provide applications/ functionality, data processing or IT services
Payment providers and banks
Advertising, marketing and data management partners
Third party marketing and CRM specialists
We share personal data with specialist suppliers who assist us in managing our marketing database and sending out our marketing communications and account-related communications.
Recruitment agencies and related organisations
We share personal data with external recruiters, third party providers that undertake background checks on our behalf and other entities within our group of companies.
Auditors, lawyers, accountants and other professional advisers
We share personal data with professional services firms who advise and assist us in relation to the lawful and effective management of our organisation and in relation to any disputes we may become involved in.
Law enforcement or other government and regulatory agencies and bodies
We share personal data with law enforcement or other government and regulatory agencies or other third parties as required by, and in accordance with, applicable law or regulation.
Other third parties
Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, or to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.
5. YOUR RIGHTS IN RELATION TO PERSONAL DATA WHICH WE PROCESS RELATING TO YOU
You have the following rights over the way we process personal data relating to you, as set out in the table below.
If you would like to exercise any of these rights please send your requests to firstname.lastname@example.org
Right of access
You have the right to ask us to confirm whether we are processing your personal data and, if so, request a copy of the personal data we hold about you. If we provide you with such information, we will not charge you for this unless your request is manifestly unfounded or excessive. Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
Right of rectification
If the personal data we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have shared your personal data with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you who we’ve shared your personal data with so that you can contact them.
Right of erasure
You can ask us to delete or remove your personal data in some circumstances, such as where we no longer need it or where you withdraw your consent (where applicable). If we have shared your personal data with others, we will let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal data with so that you can contact them directly.
Right to restrict processing
You can ask us to “block” or suppress the processing of your personal data in certain circumstances such as where you contest the accuracy of that personal data or you object to us processing it for a particular purpose. This may not mean that we will stop storing your personal data but, where we do keep it, we will tell you if we remove any restriction that we have placed on your personal data to stop us processing it further. If we’ve shared your personal data with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal data with so that you can contact them directly.
Right to object to us processing your personal data
You can ask us to stop processing your personal data, and we will do so, if we are: (i) relying on our own or someone else’s legitimate interest to process your personal data, except if we can demonstrate compelling legal grounds for the processing; or (ii) processing your personal data for direct marketing purposes.
Right to obtain a machine readable copy of your personal data, which you can use with another service provider
If we are processing data in order to perform our obligations to you, or because you consented, or if that processing is carried out by automated means, we will help you to move, copy or transfer personal data that you have provided to us to other IT systems.
If you request, we will supply you with the relevant personal data in CSV format. Where it is technically feasible, you can ask us to send this information directly to another IT system provider if you prefer.
Right to withdraw consent
If we rely on your consent as our legal basis for processing your personal data, you have the right to withdraw that consent at any time. You can exercise your right of withdrawal by contacting us at email@example.com or by using any other opt-out mechanism we may provide, such as an unsubscribe link in an email.
Right to make a complaint to a Supervisory Authority
If you are unhappy with the way we are processing your personal data we encourage you to first let us know by contacting firstname.lastname@example.org.
However, you can also submit a complaint to a Supervisory Authority. As we are incorporated in the United Kingdom, our regulatory authority is the Information Commissioner’s Office (“ICO”). Contact details for the ICO can be found on its website at ico.org.uk.
6. DATA RETENTION
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
You can ask us to delete your Account at any time by selecting “Delete My Account” in the Settings area. We may also delete accounts in the circumstances set out in our T&Cs. Once Accounts have been deleted, we will generally delete all personal data associated with the Account within 30 days of Account deletion. However, we will retain your credit ledger history for accounting and audit reasons for up to six years from the date of deletion and your telephone number to fraud prevention reasons for up to one year from the date of deletion.
If you delete any Content, it will no longer be available to you or any other Users via the Platform. However, the deleted Content will remain in the ‘back-end’ of our systems and retained for accounting and audit reasons, and for legal compliance reasons, for up to six years from the date of deletion.
If any personal data is only useful for a short period (e.g. for a specific activity, promotion or event), we will not retain it for longer than the period for which it is used by us.
If you have opted out of receiving marketing communications from us, we will need to retain certain personal data on a suppression list indefinitely so that we know not to send you further marketing communications in the future. However, we will not use this personal data to send you further marketing unless you subsequently opt back in to receive such marketing.
7. INTERACTING WITH THIRD PARTIES
The Platform may contain hyperlinks to services owned and operated by third parties. In addition, the Platform may enable you to interact and/or share data with other Users (including providing Publishers with your personal data so that they can contact you directly).
These third party services and Publishers may have their own privacy policies and we recommend that you review them. We do not accept any responsibility or liability for the privacy practices of such third party services or other Users and your use of these, and your decision to interact and/or share data with other Users, is at your own risk.
We do not use our Platform to knowingly solicit information from, or market to, children under the age sixteen (16).
As further set out in our T&Cs, you’re only allowed to use the Platform and send personal data to us if you are either sixteen (16) years or older. If you are between sixteen (16) and eighteen (18) years old you must review our T&Cs with your parent or guardian, have them accept it on your behalf, as well as approve your use of the Platform.
In the event that we learn that we have collected personal data from children under the age sixteen (16), we will delete that information as quickly as possible. If you believe that we might have any information from or about children under the age sixteen (16), please contact us at email@example.com
We will take reasonable and appropriate technical and organisational measures to ensure a level of security appropriate to the risk that could be encountered via the use of our Platform, taking into account the likelihood and severity those risks might pose to your rights and freedoms.
In particular, we will take precautions to protect against the accidental or unlawful destruction, loss or alteration, and unauthorised disclosure of or access to the personal data transmitted, stored or otherwise processed by us.
Please be aware that, while we make the security of our Platform and your personal data a high priority, no security system can prevent all security breaches.
Unfortunately, the transmission of information via the internet is not completely secure. We do our best to protect your personal data, but we cannot always guarantee the complete security of your data transmitted through our Platform. Subject to applicable law, the sharing of your personal data with us and any transmission of the data is at your own risk.
10. INTERNATIONAL DATA TRANSFERS
The data we collect from you may be transferred to, and stored at, a destination outside the United Kingdom and European Economic Area (“EEA”). It may also be processed by staff that operate outside the UK/EEA and work for us or our suppliers. These staff may be engaged in the maintenance of the Platform, and the provision of support services.
These countries do not have the same data protection laws as the UK and the EEA and may not provide the same degree of protection for your personal data or give you the same rights in relation to your personal data. However, where transferring your personal data to such countries, we will comply with our legal and regulatory obligations in relation to your personal data, including having a lawful basis for transferring personal data and putting appropriate safeguards in place to ensure an adequate level of protection for the personal data. We will take all reasonable steps to ensure that your data is treated securely and in accordance with applicable data protection laws.
In particular, where your personal data is transferred outside of the EEA to a territory not subject to an adequacy decision by the European Commission (meaning that the relevant country has been deemed by the UK and the European Commission to offer an adequate level of protection), we have agreements in place with the relevant parties which include standard data protection clauses adopted by the relevant data protection regulator and approved by the relevant UK and/or EEA authorities that give personal data the same protection it has in the UK and the EEA. Alternatively, we may put in place other appropriate safeguards. If you require more information about these safeguards, you can contact us at firstname.lastname@example.org
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