This notice is provided to explain the basis on which any personal information we collect from you, or which you provide to us, is processed. TLSA is committed to protecting and respecting your privacy in accordance with its privacy policy and cookies policy which has recently been updated. The basis on which we process your personal information is set out within these policies.
 

PRIVACY POLICY

While collecting and processing your personal data, Tiercé Ladbroke S.A. (« TLSA »), a company established under the laws of Belgium registered in the Banque Carrefour des Entreprises under number 0422.876.943 and whose registered address is at the following address : Chaussée de Wavre n° 1100, 1060 Brussels (Ouderghem), Belgium (Phone . : +32 800 380 692 ; E-mail : help@footfoot.be; web site : www.footfoot.be, www.tatatam.be) is acting as the data controller.

TLSA is committed to protecting and respecting your privacy.

This privacy policy provides information to you about the basis on which any personal data we collect from you, or that you provide to us, will be processed by us, when you are a visitor to our website ("site").  This privacy policy shall be read in conjunction with our cookie policy[MP1] , and our site terms of use / terms and conditions.[MP2] 

This privacy policy applies to websites operated by TLSA ("we", "our", and "us"): www.footfoot.be, www.tatatam.be

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

Information we may collect from you

We will collect and process the following data about you either from your use of our site:

• Information you give us.  This is information about you that you give us by filling in forms on our site / in person or by corresponding with us by phone, face-to-face, e-mail or otherwise and includes information you provide when you register to use our site, subscribe to any of our services, use the services provided by our site or certain third party services, when you provide us with information requested by us for the verification of your identity, information submitted as part of any promotions, competitions, betting opportunities, games or contests in which you participate, or when you report a problem with our site.   The information you give us may include your name, address, date of birth, gender, e-mail address, user name and password, phone number, details of any comments you provide to us and financial and credit card information. Other information you give us may include feedback regarding our services, our stores or our sites and responses to surveys and/or market research (although you do not have to respond to such surveys or requests).   We may also collect and process records of any correspondence and communications with us and telephone calls may also be recorded.
  
  
  
• Information we collect about you. With regard to each of your visits to our site we may automatically collect the following information:
  
  
  • technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, MAC addresses, traffic data, location data, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform and cookies, which will be collected in accordance with our cookies policy;
    
    
  • details of your visits to our sites, details of your personal attributes, preferences and habits when using our services; we will use this information to (a) create a profile of you in order to fulfil our regulatory and legal duties; (b) create a profile for you for the purpose of enhancing your customer experience with us. If you do not wish to be profiled in this way (under (b)), please contact us at DPO.belgium@footfoot.be.
    
    
  • information about your visit on our site, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time), services you viewed or searched for, your conduct via the site and (where relevant) details of the fulfilment of any of your orders, and any other site activity, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call us;
    
    
  • transaction history and details of bets, gaming payments and other transactions you conduct on our site and (where relevant) details of the fulfilment of any of your orders, and any other on-site activity.
    
    
    
• Information we receive from other sources. To comply with our regulatory obligations we will complete our own due diligence or use third party providers to assist us with background / identity or financial verification checks and may also receive information from our regulators (or third parties operating in our sector) in respect of barred / self-excluded customer lists. Personal information may also be provided to us from online vendors, service providers who refer you to our sites or services, from customer lists lawfully acquired from third party vendors and from other third parties who work with us in connection with our sites or services.   Third-party service providers may, without limitation, be appointed to provide technical support, process your transactions and maintain your accounts or to run promotions or marketing campaigns. We may have access to any personal information provided to such vendors, service providers and third party e-commerce services.
  
  

               HOW WE USE YOUR INFORMATION

We use information held about you in the following ways:

• Information you give to us. We will use this information:
  • to carry out our obligations arising from any agreements entered into between you and us and to provide you with the information, products and services that you request from us;
  • to carry out appropriate and necessary investigations and discharge our legal and regulatory obligations and duties, including to comply with (to the extent applicable):
    • the requirements of any applicable gambling, betting or gaming law;
    • the guidance of any relevant regulatory body;
    • the requirements of applicable legislation for the combatting of money laundering, fraud, terrorist financing, bribery, corruption, tax evasion, the provision of financial or other services to persons who may be subject to economic or trade sanctions, and including (where applicable) in respect of barred customers; and
    • any other local laws, regulations, directions, codes of practice, circulars, orders notices or demands which may otherwise apply;
  • to carry out appropriate and necessary investigations and discharge our regulated social gaming responsibilities, in respect of self-excluded or vulnerable customers;
  • to send you a welcome email, to verify your account when you register with the site and to send you other emails for the purposes of providing any services, products, competitions or promotions to you, including in relation to account management or system maintenance;
  • to provide you with marketing information about other services or products we offer that are the same or similar to those that you have already purchased, or services or products you have consented to receiving on the site;
  • to notify you about changes to our services and/or products;
  • build a profile of you, your preferences and your habits. If you do not want us to use your information in this way, please let us know by contacting DPO.Belgium@footfoot.be;
  • to provide customer support; and/or
  • to ensure that content from the site is presented in the most effective manner for you and for your computer.
    
    Please note we will not use any financial or credit card information for any purpose other than to discharge our legal / regulatory duties and to process payments by you for our products and services or due to you by agreement.
    
     
• Information we collect about you. We will use this information:
   
  • to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • to carry out appropriate and necessary investigations and discharge our legal and regulatory obligations and duties, including to comply with (to the extent applicable):
    • the requirements of any applicable gambling, betting or gaming law;
    • the guidance of any relevant regulatory body;
    • the requirements of applicable legislation for the combatting of money laundering, fraud, terrorist financing, bribery, corruption, tax evasion, the provision of financial, other services to persons who may be subject to economic or trade sanctions, including (where applicable) in respect of barred customers; and
    • any other local laws, regulations, directions, codes of practice, circulars, orders notices or demands which may otherwise apply;
  • to carry out appropriate and necessary investigations and discharge our regulated social gaming responsibilities, in respect of self-excluded or vulnerable customers;
  • to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
  • to enhance our site experience to ensure you receive a personalised and continuously improving customer service;
  • to allow you to participate in interactive features of our site, when you choose to do so;
  • as part of our efforts to keep our site safe and secure;
  • for data-matching purposes in respect of your use of our site / services and your use of certain third party services;
  • to deliver (whether directly or indirectly via third parties) effective and personalised marketing material and content of the data controller  and to assist us in the improvement and optimisation of advertising, marketing material and content, our services and the sites;
  • to measure, understand or monitor the effectiveness of advertising, promotions, marketing material and content and any joint initiatives with our affiliates, suppliers, partners, subcontractors and other selected third parties;
  • build a profile of you, your preferences and your habits. If you do not want us to use your information in this way, please let us know by contacting DPO.Belgium@footfoot.be;
  • to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you where permitted; and/or
  • to make suggestions and recommendations to you and other users of our site or services about goods or services that may interest you or them.
    
    
    
• Information we receive from other sources. We will combine this information with information you give to us and information we collect about you.  We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
   
• For the avoidance of doubt, to the extent that promotions or competitions are offered to individuals who do not hold an account with us, and where personal information is provided, such personal information will be held in accordance with this privacy policy.
  
  

               HOW TO AVOID TARGETED ADVERTISING ON SOCIAL MEDIA?

If you have a player account with TLSA, if you have expressed an interest in our activities or simply if you have expressed an interest on the Internet for certain themes (e.g. sporting events), it is possible that targeted advertising appears on your social networks.

If you do not want to see this kind of advertising, it is very simple to adjust your account settings on these social media.
Below you will find links explaining how to proceed for the major social media.
 

• Facebook: https://www.facebook.com/help/164968693837950?helpref=related&ref=related
• Youtube: https://myaccount.google.com/privacy?utm_source=OGB&utm_medium=app&pli=1#ads
• Twitter: https://help.twitter.com/en/safety-and-security/privacy-controls-for-tailored-ads
• Instagram: https://help.instagram.com/519522125107875?helpref=page_content
   

USING YOUR INFORMATION IN ACCORDANCE WITH DATA PROTECTION LAWS

Data protection laws require that we meet certain conditions before we are allowed to use your data in the manner described in this privacy policy.  We take our responsibilities under data protection laws extremely seriously, including meeting these conditions.  To use your personal data, we will rely on four conditions, depending on the activities we are carrying out:

• Compliance with legal obligations: As a regulated entity, we are obliged to comply with applicable guidance provided by any relevant regulatory body and has obligations under applicable legislation, including gambling, betting and gaming law and anti-money laundering/ fraud legislation. In particular, we will need to process your personal information to verify your identity, establish your age and your source of funds for the purposes of combatting money laundering, fraud, terrorist financing, bribery, corruption, tax evasion, the provision of financial or other services to persons who may be subject to economic or trade sanctions and to establish whether you have self-excluded or have been barred from any of our shops or from using our services (or those of other gambling operators). Failure to provide the requisite personal information on sign-up / as you use our site or services, will unfortunately mean we cannot provide our services to you, as to allow you to use our service would mean we would be in breach of our legal obligations. You will not be able to object to processing or ask for the deletion of your personal information insofar as it falls under this category.
• Necessary for the entry into / performance of a contract: When you enter into a transaction with us, a contract between you and us will have been entered into. In order for us to fulfil our obligations under such contract (e.g. to allow you to place a bet and pay out winnings), we will need to collect and process your personal information. Failure to provide the requisite personal information on sign-up and financial information on entering into the transaction or objecting to this type of processing / exercising your deletion rights will unfortunately mean we cannot provide our services to you.  
• Consent:  We may send you marketing messages across our platforms such as email, text messages, telephone, direct mail, inbox messaging, push notifications  about us and our site, stores, services and offers where you have not unsubscribed or managed through the preference centre, and where you have placed a bet or purchased other services from us. We provide easy ways to stop our marketing, and you can opt out at any time.  

If you are not a customer of ours but have provided us with consent to use your details for marketing purposes, then we may also contact you about our site, stores, services and offers.

If you have confirmed that you would like to hear from us about other party's goods and services then we will use your details to contact you with marketing information about such party's goods and services.  

If you have confirmed that you would like to hear directly from a third party (including other members of our Group) about such party's goods and services then we will share your details with such third party so they can contact you about their goods and services. 

In each of the situations above, you have the right to withdraw your consent at any time and can object to processing of this nature. Where you consent to us sending you marketing information, we will treat this as lasting for 24 months unless we tell you otherwise at the time.

• Legitimate interests:  To use your personal data for any other purpose described in this privacy policy, we will rely on a condition known as "legitimate interests".  It is in our legitimate interests to collect your personal data as it provides us with the information that we need to provide our services to you more effectively. Effectively, this requires us to carry out a balancing test of our interests in using your personal data (for example, in order to provide you with the information, products and services that you request from us), against the interests you have as a citizen and the rights you have under data protection laws (for example, to not have your data sold to third party marketing companies without your knowledge, or not store your personal data in insecure or unstable countries or regions).  The outcome of this balancing test will determine whether we can use your personal data in the ways described in this privacy policy (except in relation to marketing, where we will always rely on your explicit consent).  We will always act reasonably and give full and proper consideration to your interests in carrying out this balancing test.

HOW LONG WE KEEP YOUR INFORMATION FOR
 

When your data is no longer required for the purposes listed above, we will delete it within the periods set out below:

• Marketing consents will be refreshed/deleted after 24 months;
• Call recordings will typically be deleted after 19 months;

Any other information will typically be deleted within 10 years from the date of our last positive interaction with you. We may keep your personal information for up to 10 years, to enable us to retain the information we may require for legal and regulatory purposes.

If you are not a customer and we have collected information about you, this will be deleted within 3 months (provided we do not need to keep it for regulatory purposes e.g. barred / fraudulent customers).
 

Disclosure of your information

We may disclose your personal information to any member of the Entain Group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in article 11 of the Belgian Companies Code ("Entain Group").  

We will only disclose your information to:
 

• business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
• our affiliates and selected third parties, where you have expressly opted-out of receiving marketing from us / third parties, have been barred or self-excluded, in which case we may share suppression lists with our affiliates and selected third parties, to ensure you do not receive unsolicited marketing;
• members of the Entain Group and third party suppliers and service providers for the purposes listed under HOW WE USE YOUR INFORMATION above;
• third party suppliers and service providers to the extent they assist the Entain Group with its legal / regulatory obligations e.g. providers of services in respect of anti-money laundering, fraud, verification etc.;
• selected third parties so that they can contact you with details of the services that they provide, where you have expressly opted-in/consented to the disclosure of your personal data for these purposes;
• analytics and search engine providers that assist us in the improvement and optimisation of our site and other selected third parties;
• other gambling operators, banks, credit card companies, ESP's (defined below) and appropriate agencies for the purpose of investigating and safeguarding against underage, fraudulent, criminal or suspicious activity (or other activities we are bound by law, regulation or guidance to investigate and safeguard against) or if we have reason to believe that you have undertaken such activity; and
• our regulators, law enforcement or fraud prevention agencies, as well as our legal advisers, courts, applicable independent adjudication services, sports' governing bodies and betting integrity organisations and any other authorised bodies, for the purposes of investigating any actual or suspected criminal activity or other regulatory or legal matters etc.

In order to bet or play real money games you will need a facility to send and receive money. Third party electronic payment processors and/or financial institutions may be used to process such financial transactions ("ESP's"). By accepting this privacy policy you agree to the sharing of necessary personal information, with the ESP's, to enable the processing of transactions. Where necessary this may include the transfer of information outside of the EEA.

We will disclose your personal information to third parties:
 

• in the event that we consider selling or buying any business or assets, in which case we will disclose your personal data to any prospective sellers or buyers of such business or assets;
• in the event of any insolvency situation (e.g. the administration or liquidation) of Entain Group plc, or a data controller or any of its group entities;
• if we, or substantially all of our assets, are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;
• in order to enforce or apply our website terms of use;
• to protect the rights, property, or safety of us, our staff, our customers, or others.  This includes exchanging information with other companies and organisations (including without limitation, other gambling operators and the local police or other local law enforcement agencies) for the purposes of staff and customer safety, crime prevention, fraud protection and credit risk reduction; and
• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or regulatory requirements, or otherwise for the prevention or detection of fraud or crime.

Where we store your personal data

In order to ensure fair and transparent processing, we will, taking into account our processing activities, adopt appropriate procedures for the processing of personal data, which shall include implementing technical and organisational measures which take into account the harm that may be suffered, and correct inaccuracies identified in personal data processed, so that risk of errors are minimised and your personal data is processed in a fair and secure manner.
All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
From time to time, service providers, members of the Entain Group and organisations with whom we work, may be located outside the European Economic Area in countries that do not have the same standards of protection for personal data as the UK. We will, however, always use every reasonable effort to ensure sufficient protections are in place to safeguard your personal data. We will also ensure that our service providers enter into compliant processing agreements with us to ensure that your personal data is processed in accordance with applicable data protection legislation.
 

Your rights

You have a number of rights under data protection law in relation to the way we process your personal data.  These are set out below.  You may contact us using the details on our site (or by contacting our DPO directly – details below) to exercise any of these rights, and we will respond to any request received from you within one month from the date of the request.
 

Right 1

A right to access personal data held by us about you.

Right 2

A right to require us to rectify any inaccurate personal data held by us about you.

Right 3

A right to require us to erase personal data held by us about you.  This right will only apply where (for example): we no longer need to use the personal data to achieve the purpose we collected it for; or where you withdraw your consent if we are using your personal data based on your consent; or where you object to the way we process your data (in line with Right 6 below). 

Right 4

In certain circumstances, a right to restrict our processing of personal data held by us about you.  This right will only apply where (for example): you dispute the accuracy of the personal data held by us; or where you would have the right to require us to erase the personal data but would prefer that our processing is restricted instead; or where we no longer need to use the personal data to achieve the purpose we collected it for, but you require the data for the purposes of dealing with legal claims.  

Right 5

In certain circumstances, a right to receive personal data, which you have provided to us, in a structured, commonly used and machine readable format.  You also have the right to require us to transfer this personal data to another organisation, at your request.

Right 6

A right to object to our processing of personal data held by us about you where the processing of such data is necessary for the purposes of our legitimate interests, unless we are able to demonstrate, on balance, legitimate grounds for continuing to process personal data which override your rights or which are for the establishment, exercise or defence of legal claims.

Right 7

A right for you not to be subject to a decision based solely on an automated process, including profiling, which produces legal effects concerning you or similarly significantly affect you.

Right 8

A right to withdraw your consent, where we are relying on it to use your personal data (for example, to provide you with marketing information about our services or products). 

To exercise any of your rights above, please contact DPO.Belgium@footfoot.be.  Questions, comments and requests regarding this privacy policy are welcomed.

If you have any concerns regarding our processing of your personal data, or are not satisfied with our handling of any request by you in relation to your rights, you also have the right to make a complaint to our lead supervisory authority, which is the Belgian Data Protection Authority.  Their address is:

Drukpersstraat 35 Rue de la Presse,
1000 Brussels,
Belgium

Changes to THIS privacy policy

Any changes to this privacy policy in the future will be posted on this page, and where appropriate, notified to you by email. Please check back frequently to see any updates or changes to this privacy policy.
 
This policy was last reviewed and updated: 20 July 2020