PROPSHOP- PRIVACY POLICY

INTRODUCTION

Last Updated: July 2024

Fantasy Advance Ltd. (“Company”, “we”, “our” or “us”) develops and operates a mobile application, “Propshop – Sports Betting” (“Propshop” or “Service(s)”). This Policy is integrated into and forms part of the Company’s Terms of Use, which we may update from time to time, and a current version of which is available by accessing the “My Zone” section in Propshop and thereafter clicking on personal settings icon

We are dedicated to protecting your privacy rights and making our practices regarding your personal data more transparent and fairer. This Privacy Policy (“Policy”) was designed to help you understand the information we collect, store, use and share, and it applies whenever you visit, install, interact or otherwise access or use any of our Services.

We strongly urge you to read this Policy and make sure that you fully understand and agree to it. If you do not agree to this Policy, please discontinue, and avoid using our Services. You are not legally required to provide us with any Personal Data (as defined below), but without it, we will not be able to provide you with the full range or with the best experience of using our Services.

Specifically, this Policy describes–

  1. What types of data we collect?
  2. Tracking technologies
  3. Why we process your Personal Data?
  4. With whom we share your Personal Data?
  5. Marketing and advertising
  6. Your rights
  7. Transfer of Personal Data
  8. How we protect your Personal Data?
  9. Minors
  10. Retention
  11. Updates to this Policy
  12. Controlling version
  13. Contact us

WHAT TYPES OF DATA WE COLLECT?

We collect personal data from you, meaning any information which potentially allows your identification with reasonable means (for example, email address or name, collectively “Personal Data”). This section sets out how and when we collect and process Personal Data about you. 

  1. Account information: If you choose to register an account with our Services, we collect your email address, birthdate, and username;
  2. Betting information: If you choose to synchronize our Services with a third-party sportsbook account through Sharp Sports Inc. (“Sharp Sports“), we will be able to obtain data from your third-party sportsbook, includingcash/bonus balance, net profits, winning percentages, and information about your betting activities. This may include bet type, name, odds, winning amounts, status and timestamps. Please note that the Company will never have access to your login credentials from Sharp Sports – these credentials are exclusively processed on Sharp Sport’s servers.Please note that by using the synchronization feature, you authorize Sharp Sports to access and share your Personal Data from your third-party sportsbook account with the Company. Sharp Sports’ service is governed by its own privacy policy and terms and conditions, and the Company is not responsible for the privacy practices of Sharp Sports or any third-party linked to the Services;
  3. Contact information: If you voluntarily contact us, participate in surveys or other promotional activities, or subscribe to newsletters, through any means of communications we make available for inquiries, you may be required to provide us with certain information such as your name, your organization name (i.e., on behalf of which you contact us), email address, and any additional information you decide to share with us; and
  4. Usage information: When you interact with our Services, we collect certain information, including but not limited to your online identifiers, Internet Protocol (IP) address, Google Advertising ID on Android devices, Apple Advertising ID for iOS devices (IDFA), precise geolocation, time zone, browser type, language preference, referring pages,domain names, log files, Cookie ID, unique identifiers (e.g., MAC address and UUID), session and screen recordings, number of clicks, as well as data concerning your device, operating system, etc.

2.    TRACKING TECHNOLOGIES:

When you visit or access our Services, we use cookies, pixels, beacons, local storage and similar technologies (“Tracking Technologies“). These Tracking Technologies allow us to automatically collect information about you, your device, and your online behaviour, in order to enhance your navigation in our Services, improve our Services’ performance, perform analytics, customize your experience and offer you, for example, tailored content and advertisements that better corresponds with your interests.

2.1  What types of Tracking Technologies do we use?

When you use or access our Services, we use the following categories of Tracking Technologies:

  1. Strictly necessary Tracking Technologies: these Tracking Technologies are automatically placed on your computer or device when you access or take certain actions to our Services. These Tracking Technologies are essential to enable you to navigate around and use the features of our Services. We do not need to obtain your consent in order to use these Tracking Technologies;
  2. Advertising Tracking Technologies: these Tracking Technologies collect information about your browsing habits in order to make advertising more relevant to you and to your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of an advertising campaign. The Tracking Technologies remember the websites you visit and that information is shared with other parties such as advertisers and publishers;
  3. Functionality Tracking Technologies: these Tracking Technologies allow our Services to remember choices you make (such as your language) and provide enhanced and personalized features. For example, these Tracking Technologies are used for authentication (to remember when you are logged-in) and support other features of our Services; and
  4. Performance Tracking Technologies: these Tracking Technologies collect information about your online activity (for example the duration of your visit on our Services), including behavioural data and content engagement metrics. These Tracking Technologies are used for analytics, research and to perform statistics (based on aggregated information).

2.2   How and by whom Tracking Technologies are stored on your device?

If you are accessing our services through a mobile device app, you can withdraw your consent to personalized advertising experience on your device at any time by using your device settings as follows:

  1. On iOS, depending on the applicable iOS version, you may withdraw consent across all apps by either enabling the “Limit Ad Tracking” setting or disabling the “Allow Apps to Request to Track” permission in your iOS device settings. Depending on the applicable iOS version, instead of withdrawing consent on a device-wide basis, you may also have the option of withdrawing consent on a per-app basis by disabling tracking permissions for specific apps that appear under the “Allow Apps to Request to Track” setting in your iOS device settings (precise directions may differ depending on the applicable iOS version).

3.    WHY WE PROCESS YOUR PERSONAL DATA?

This section explains for what purposes we use your Personal Data and outlines the legal bases that underlie our usage.

  1. Provision of our Services; support: We use your Personal Data, such as your email address, to provide you with our Services and provide customer support. This includes, for example, allowing you to log-in or respond to your inquiries. Our provision of services can include Personal Data such as your betting information, if you choose to sync your Personal Data from third-party sportsbooks like Sharp Sports into our Services;
  2. Improve our Services: We collect and analyze information about you and your usage of our Services for the purposes of usability, quality, functionality and effectiveness of our Services, including debugging to identify and repair errors and undertaking internal research for technological development and demonstration;
  3. Auditing: Related to counting ad impressions of unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with relevant specifications and standards;
  4. Marketing and advertising: We use Tracking Technologies in order to provide you with advertisements when you visit our Services, including personalized and non-personalized advertising;
  5. Integrity: We process certain information about you and your usage of our Services in order to keep the integrity and security of our Services, prevent fraud and enforce our policies;
  6. Compliance with applicable laws; assistance to law enforcement agencies: We process your Personal Data in order to comply with our legal obligations under applicable laws.

4.    WITH WHOM WE SHARE YOUR PERSONAL DATA?

4.1  We share, sell and disclose your Personal Data as described below:

a)     Service providers: our service providers work on our behalf, and need access to certain Personal Data in order to provide their services to us. These companies include, but are not limited to, cloud storage providers, analytics services, fraud prevention, etc.;

b)    Third party advertisers: we partner with third parties to either display advertising on our Services or to manage our advertising on other websites or apps. Our third party advertisers use Tracking Technologies to gather information about your activities on our Services and other websites and apps in order to provide you advertising based upon your browsing activities and interests;

c)     Third Party Integrations: our Services allow you to integrate with certain third party services, in order to connect your account to our Services or to place purchases (e.g., Apple, Google or Facebook accounts);

d)    Compliance with laws and assistance to law enforcement agencies: we disclose some data about you to government or law enforcement officials or private parties. The disclosure will be made in our sole discretion, as we believe it necessary or appropriate to respond to claims and legal procedures (including but not limited to subpoenas), to protect our or a third party’s property and rights, to protect the safety of the public or any person, or to prevent or stop any activity we consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable. We also may be required to disclose an individual’s Personal Data in response to a lawful request by public authorities, including meeting national security or law enforcement requirements;

e)    Auditors and advisers: we share your data with our external auditors, advisors and professional service providers (e.g. lawyers, accountants, insurers etc.) for ensuring our compliance with regulatory requirements and industry standards, auditing, managing disputed etc.; and

f)      Mergers and acquisitions: we will transfer, sell or otherwise share your data in case of entering into a business transaction such as a merger, acquisition, reorganization, bankruptcy, or sale of some or all of our assets.

4.2  In the 12 preceding months, we have disclosed, shared or sold the following categories of your Personal Data:

Category of Personal Data  Personal Data Categories of third partiesPersonal Data was disclosed, shared, or sold
IdentifiersA real name, internet protocol address, email address, account name, technical device data and any other unique personal identifier including online identifier.Service providersPersonal Data was Disclosedand Shared.  
Internet protocol address, email, technical device data and any other mobile identifier, including Google Advertising ID and IDFA.Third party advertisers.
Commercial data  Products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.Service providers, third party advertisers.Personal Data was Disclosed and Shared.
Internet or other electronic network activity data  Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.Service providers, third party advertisers.Personal Data was Disclosed and Shared.
Inferences drawn from other Personal Data  Profile reflecting a person’s preferences and/or characteristics.Service providers.Personal Data was Disclosed and Shared.
Profile reflecting a person’s preferences and/or  characteristics.Third party advertisers.
Sensitive Personal Data (under the relevant applicable laws)Precise geolocationNonePersonal Data was not Disclosed, Share or Sold.

4.3  In the 12 preceding months, we have collected Personal Data from the following categories of sources:

  1. Consumer directly;
  2. Marketing Affiliates;
  3. Advertising networks;
  4. Data analytics providers; and
  5. Operating Systems.

5.    MARKETING AND ADVERTISING:

We use your Personal Data ourselves or by using our third party subcontractors for the purpose of providing you with promotional materials, ads, products, services, websites and applications which relate to our affiliated companies or our business partners (collectively: “Marketing Affiliates”), which we believe may interest you.

You can decline receiving further marketing offers from us at any time, by clicking the ‘unsubscribe’ or ‘opt-out’ link located at the bottom of each marketing email sent by us.

Please note that even if you unsubscribe from our marketing-mailing list, we can continue to send you service-related updates and notifications.

6.    YOUR RIGHTS:

Depending on the jurisdiction in which you reside, you may have certain rights under relevant applicable laws regarding the collection and processing of your Personal Data. To the extent these rights apply and concern you, you can contact us via the contact details available below and ask to exercise the following rights:

  1. Rights of access to your Personal Data: yyou have the right to receive confirmation as to whether or not Personal Data concerning you is being processed, and access your stored Personal Data, together with supplementary information;
  2. Right of data portability: you have the right to request us to move, copy and transfer your Personal Data easily from one IT environment to another, in a safe and secure way, without affecting its usability;
  3. Right of rectification: you have the right to request rectification of your Personal Data in our control in the event that your believe the Personal Data held by the Company is inaccurate, incomplete or outdated;
  4. Right of deletion/erasure: you have the right to request that the Company erase or delete Personal Data held about you at any time. You may also exercise your right of deletion independently by navigating to ‘My Zone’ tab, clicking on your profile icon and then clicking ‘Delete Account’;
  5. Right to restriction or objection to processing: you have the right to request that the Company restrict or cease to conduct certain processing of your Personal Data at any time;
  6. Right to withdraw your consent: to the extent we process Personal Data on the basis of your consent, you have the right to withdraw your given consent at any time;
  7. Right to limit use and disclosure of your sensitive Personal Data: you have the right to request to limit the collection of your sensitive Personal Data, to that use which is necessary to perform our Services;
  8. Right not to be subject to automated decision making: you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or similarly significantly effects to you.
  9. Right to Opt-Out of the Sale or share of Personal Data: in the event that we sell or share your Personal Data for behavioral advertising purposes, you have the right to submit a request to opt-out of the sale or share of your Personal Data;
  10. Right to non-discrimination: you have the right to be free from any discrimination for exercising your rights, such as offering you different pricing or products, or by providing you with a different level or quality of services, based solely upon your request;
  11. Right to lodge a complaint and appeal our decisions: all requests, complaints or queries may be addressed to the Company via the contact details available below . We will consider any requests, complaints or queries and provide you with a reply in a timely manner. We take our obligations seriously and we ask that any concerns are first brought to our attention, so that we can try to resolve them. To the extent you feel unsatisfied with our response to your request to exercise your rights, you may choose to send us a request to appeal our decision. If you are unsatisfied with our response, you can lodge a complaint with the applicable data protection supervisory authority.

Please note that these rights are not absolute, and may be subject to the relevant applicable laws, our own legitimate interests and regulatory requirements.

Use of an Authorized Agent

  1. You can use an authorized agent to make a request to exercise your right under applicable laws on your behalf if:
    The authorized agent is a natural person or a business entity; and
    2. You sign a written declaration that you authorize the authorized agent to act on your behalf. If you use an authorized agent to submit a request to exercise your right, please provide us with a certified copy of your written declaration authorizing the authorized agent to act on your behalf using the contact information below.

b. The request must:

  1. Provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Data or an authorized agent. We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request and confirm the Personal Data relates to you; and
  2. Describe your request with sufficient details to allow us to properly understand, evaluate, and respond to it.

c. We will only use Personal Data provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

7.    TRANSFER OF PERSONAL DATA

We operate globally, thus any information that we collect, disclose or share, including your Personal Data, can be stored and processed in various jurisdictions around the world, including (but not limited to) the European Economic Area, United Kingdom, Israel and United States, for the purposes detailed in this Policy.

8.    HOW WE PROTECT YOUR PERSONAL DATA?

We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your Personal Data. While we seek to protect your information to ensure that it is kept confidential, we cannot guarantee the security of any information. You should be aware that there is always some risk involved in transmitting information over the internet and that there is also some risk that others could find a way to thwart our security systems. Such breaches can lead to things such as reputational harm, fraud or identity theft.

Therefore, we encourage you to exercise discretion regarding the Personal Data you choose to disclose. If you feel that your privacy was treated not in accordance with our Policy, or if any person attempted to abuse the Services or acted in an inappropriate manner, please contact us directly via our contact details available below.

9.    MINORS

We do not knowingly process, sell or share the Personal Data of users under the age of 18 (as determined under the applicable laws where the individual resides; “Minors”). By accessing, using or interacting with our Services, you certify to us that you are not a Minor. In the event that we have collected Personal Data from a Minor without parental consent (as required), we will delete that information upon discovery. If you believe that we might have any Personal Data from or about a Minor, then please contact us through the contact details available below.

10. RETENTION

We will retain your Personal Data for as long as necessary to provide our Services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined to take into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time.

11. UPDATES TO THIS POLICY

We reserve the right to change this Policy at any time. The most current version will always be posted through our Services (as reflected in the “Last Updated” heading). You are advised to check for updates regularly. By continuing to access or use our Services after any revisions become effective, you agree to be bound by the updated Policy.

12. CONTROLLING VERSION

This Policy has been drafted in the English language, which is the original and controlling version of this Policy. All translations of this Policy into other languages shall be solely for convenience and shall not control the meaning or application of this Policy. In the event of any discrepancy between the meanings of any translated versions of the Policy and the English language version, the meaning of the English language version shall prevail.

13. CONTACT US:

If you have any question, inquiry or concern related to this Policy or the processing of your Personal Data, you may contact our privacy team as follows:

Fantasy Advance Ltd.
info@fantasyadvantage.com