1.2 Star Spreads Ltd is both licensed and operates in the Republic of Ireland. Our address is: Star Spreads Limited, The Connolly Building, 42/43 Amiens Street, Dublin 1, Ireland. Our Company Number is 475533. We operate and control the website www.starspreads.com (hereinafter referred to as ‘the Website), our mobile telephone Betting Apps (hereinafter referred to as the ‘Betting Apps’) and our telephone betting service, which collectively are referred to hereinafter as the ‘Services’.
1.4 We may process and hold information relating to you, including but not limited to personal data as defined in the Data Protection Act 1988 and the Data Protection (Amendment) Act 2003, in an electronic database or manual format for account administration and marketing purposes and also in order to satisfy legal, regulatory and statutory requirements.
2.2 Please read this policy carefully so as to ensure that you understand our values, views and practices regarding the capture, retention, processing, use and transfer where applicable of your information.
4 What Information We May Collect About You
4.1 We may automatically collect, record, store and process information that is not personally identifiable about you when you access the website including but not limited to the type of internet browser and computer operating system you are using, the domain name of the website from which you came, the number of visits, the average time spent and the pages viewed on our website. We may use this information within our Company to measure the use of our website and improve its contents.
4.2 In addition to the information set out above, in the event that you apply to open an account with us we may collect, record, store and process additional information about you including but not limited to the following:
a) Your contact information, which includes but is not limited to your name (first and last name), your date of birth, your gender, your physical address, your email address, your IP address and your telephone numbers.
b) Your financial information, which includes but is not limited to your billing information, payment card details and details of transactions you carry out through our website.
c) Other information about you that is available from publicly available sources (for example, the Electoral Register and the appropriate register of court judgements) which may be relevant to your use of the services. We may combine it with the information you have provided to us to assist us in assessing your application for credit with us and verifying your identity to detect and prevent crime and money laundering. For more information please refer to our Account Operating Rules.
d) Other mandatory details that may be requested from you for the purpose of applying to open an account with us.
4.3 We may also collect, record, store and process data about you including but not limited to:
a) Details of your visits to our services together with the resources and webpages that you access, including but not limited to traffic data, location data, IP address(es) and other communications data.
b) Technical information about the device(s) that you use to access our services.
c) All communications correspondence you have with us whether in writing, by telephone, email or in any other form.
d) Your betting, payments and other account transactions which will be routinely analysed so as to assist us in improving the service that we provide to you.
e) Information about how you use our services and/or selected third party websites from cookies stored on your device. (For further information on cookies, see clause 10 below.)
4.4 All telephone conversations including calls in relation to betting with us and client service calls may be recorded both to assist us in training and quality management and to facilitate the speedy resolution of any disputes.
5 How We Use Your Information
5.1 We will only use the information that we collect to process your transactions and requests or for any other purpose detailed in this policy. This processing may include sharing your information with our third party data handlers and with the professional advisers who assist us with the performance of the services we offer. Your information may be processed for one or more of the following reasons:
a) To set up, operate and manage your account.
b) To verify your age, identity and the accuracy of your application details, including obtaining information from third parties such as financial institutions and credit reference agencies.
c) To provide you with betting services.
d) To process your transactions via your banking service provider.
e) To respond to any enquiry from you regarding a transaction you have made with us.
f) To enforce or apply our Client Agreement and other agreements with you (including our Terms and Conditions of Use for the Star Spreads Website).
g) To comply with our legal and regulatory duties, obligations and responsibilities.
h) To investigate suspected unlawful, fraudulent or other improper activity connected with use of the website and to report a crime or suspected crime, including money laundering or fraud.
i) To enhance our client services and provide a more personalised service.
j) To keep you informed of future events, offers and promotions from us via SMS, email, telephone and/or post.
k) To carry out customer research, analysis and testing.
l) To carry out risk management.
m) To assist in diagnosing system problems and administering the website.
n) Any other purpose which is necessary for the performance of our contractual obligations to you.
6 Sharing Your Information With third Parties
6.1 We may share your information with third parties to verify the accuracy of the information you provide to us and to comply with our legal and regulatory duties, obligations and responsibilities. This may include sharing your information with third party companies and organisations for the purposes of fraud protection, credit risk reduction and verifying the information you provide to us (including your age). Examples of this include but are not limited to:
a) Sharing your information when making enquiries with a credit reference agency.
b) Sharing the information you have given us with a third party organisation to verify the accuracy of it.
c) Passing your information to a debt collection agency if we need to collect outstanding debts from you because you do not make payments due to us in good time.
d) Passing your information to legal advisers should we need assistance in enforcing our legal rights against you.
e) Disclosing any of your information that we are legally required or permitted to do, without prior notice to you, in relation to suspected unlawful, fraudulent or other improper activity connected with use of the website and/or to report a crime or suspected crime, including money laundering or fraud.
6.2 If Star Spreads Limited or substantially all of its assets should be acquired by a third party, all personal data held by us may be one of the assets transferred.
7 Making Enquiries With Credit Reference Agencies
7.1 The information held by credit reference agencies and fraud prevention agencies may be searched by us and other organisations on our behalf and used to make assessments and decisions regarding credit and credit-related services, verify your identity, manage your accounts including updating and maintain the accuracy of your records, trace your whereabouts, recover debts that you owe us and prevent crime, fraud and money laundering. Your credit rating may be affected by these searches and any records shared with credit reference agencies will remain on their files for 6 years after they are closed.
8.1 We may use your information to send you targeted marketing material from time to time relating to our services such as future events, other promotional activities and information about special offers that we feel may be of interest to you. Your information will not be disclosed to any external third parties for marketing purposes.
8.2 We may communicate with you by the following methods – email, SMS (commonly known as text), post and telephone. You have the right to stop receiving our marketing communications at any time. If you no longer want to receive these communications or would like to change your marketing preferences you can inform us by clicking on the relevant link in our marketing emails to you, and these communications will be stopped or modified as soon as reasonably practicable. You may stop SMS communications at any time by replying ‘stop texts’ or contacting us in any other way and letting us know that you want us to stop sending these marketing communications to you.
9 International Transfer of Your information
10 Device Monitoring and Cookies
10.1 We may collect information about the device(s) you use to access our services for anti-fraud monitoring purposes. This information includes but is not limited to the Internet Protocol (IP) address, memory and operating system of the device is not personally identifiable information.
10.4 The following are examples of some of the types of cookies we use:
a) Visitor identification cookies. These are anonymous identifiers used to recognise a visitor across visits which may be used to identify repeat visits and analyse cross-visit behaviour.
b) Tracking cookies. These are account-related identification cookies used to recognise you as a client and maintain your session on the website. They may be used to link site usage information with transactional information when analysing and optimising your user experience.
c) Customisation cookies. These uniquely identify you, recognise you as a returning visitor and are used to customise your experiences on the website.
d) Testing cookies. These are anonymous cookies used to randomly generate variants of content and maintain the visitor’s view of that content. They may be used to record a variant’s performance in achieving goals such as helping visitors to register.
e) Analytical cookies. These are used to collect information about how visitors use our website. This information is then used to compile reports and to assist us in improving the website.
11 Security and Protecting Your Information
11.1 We recognize the importance of online security for all our clients and we take precautions to ensure the security of your personal information and strive to keep it accurate. To ensure the security of personal data we maintain appropriate administrative, technical and physical safeguards to protect against accidental or unlawful destruction, loss, corruption, unauthorised disclosure, access and all other unlawful forms of processing of the personal data in our possession. Any payment transactions will be encrypted using SSL technology.
11.2 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 any data you transmit to our site and you do so at your own risk. Once we have received your information we will use strict procedures and security features to try to prevent unauthorised access.
12 Links to Third Party Websites
13.0 Accessing Your Personal Information
13.1 Under the Data Protection Acts 1988 & 2003 you may at any time request a copy of any personal information that we hold about you. If you would like a copy of some or all of that information you can request it by writing to us at Star Spreads Limited, The Connolly Building, 42/43 Amiens Street, Dublin 1, Ireland or emailing enquiries@StarSpreads.com. We may charge an administration fee to cover the cost of supplying this information.
14.0 Retention and Disposal
14.1 We will only keep your information for as long as is necessary to supply you with products and services or as required by law. We may be required in certain circumstances to retain your information indefinitely, for example under our procedures to maintain responsible gambling and self-exclusion.
14.2 When personal information is no longer required it will be destroyed either by shredding it or by another approved destruction method to prevent unauthorised parties from gaining access to the information.