Data Protection

When you interact with us through our website (or otherwise) you may provide, or we may collect, certain information from which you are personally identifiable (which may be referred to as personal data). For the purposes of the General Data Protection Regulation or “GDPR” (and all other laws relating to the use your personal data), we are the “data controller”, meaning that we are responsible for deciding how your personal data is used and more importantly, for keeping your data safe and only using it for legitimate reasons.

We are committed to protecting your privacy and will take all steps necessary to comply with our legal obligations when using your personal data. This Data Protection explains how we fulfill this commitment, so please read this carefully.

WHAT THIS POLICY TELLS YOU

1. What types of personal data you provide to us (or which we collect from you) when using our website or when you directly interact with us on other occasions;
2. How and why we use this data and the reasons we are legally allowed to do so;
3. Who we share your data with;
4. Your rights over your data and how you can exercise those rights; and
5. How to contact us if you have any issues or want to find out more.

WHAT INFORMATION DO WE COLLECT AND WHAT DO WE USE IT FOR?

You may provide us with the following types of personal information when you register with Bespoken DMCC or otherwise when you directly interact with us (when using our website or otherwise):

• Identity – first name, surname, Bespoken log-in information (password), country of residence.
• Contact – email address, telephone numbers and address.
• Financial – payment card details, billing address, purchase information, payment history.
• Social -if you choose to open a Bespoken account using your Facebook, Twitter or Google account, we will use your contact information used for the relevant account to help populate your Bespoken registration page.We may collect the following types of information from you when you use our website (using Cookies or other tracking technologies):
• Usage – information about how you use our website, including time spent on page, click-through, download errors

Technical– IP address, browser type, hardware type, network and software identifiers, device information, operating system and system configuration

The table below sets out how we use your personal data and our lawful basis for doing so. We may process your personal data for more than one lawful basis depending on the specific purpose for which we are using it. Importantly, we will only use your personal data when the law allows us to.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

In addition to the above, we may also anonymous and aggregate your personal data in a way which means you cannot be identified. This may be helpful to us for testing our internal systems, carrying out research and general customer data analysis. Because this is not personally identifiable, we can use this for any purposes.

WHO DO WE SHARE YOUR DATA WITH?

Importantly, we do not pass your personal data onto any third parties for them to market their products/services to you. If in the future we decide that we want to, we will only do so if we have your consent. We do however share your personal data with third parties to help us deliver our products and services to you in the most effective way possible. These include third parties who assist us with:

• Delivering relevant Bespoken email and text marketing (to the extent you have not unsubscribed)
• Our customer reviews and surveys
• Personalizing the content on our website to ensure a tailored user experience
• Delivering relevant targeted and re-targeted advertising to keep you up to date with our services
• Detecting fraud or criminal activity
• Creating your Bespoken account (being your social media companies who you have used to provide log-in information as part of the sign-up process)
• Running our competitions, such as our auditors, judges, professional advisors
• Other aspects of our service delivery, such as hosting our website and processing customer payments.

In addition to the above, we may also be required to share your personal data with third parties if required by law or regulation. In such circumstances, we will make sure that the disclosure is only to the extent required by law or regulation.

HOW WE KEEP YOUR DATA SECURE?

We adopt industry standard security processes to ensure your data is kept safe and secure and to prevent unauthorized access or use or loss of your data. By way of example, we use secure server software (EV SSL), which encrypts all information you input before it is sent to us. We also make sure that third parties who need to handle your data when helping us to deliver our services are subject to suitable confidentiality and security standards. Despite the security measures we implement, please be aware that the transmission of data via the Internet is not completely secure. As such, we cannot guarantee that information transmitted to us via the Internet will be completely secure and any transmission is at your own risk.

HOW LONG DO WE KEEP YOUR DATA FOR?

We will keep your data for as long as you hold a Bespoken account and/or where you are still happy to hear from us about our latest news, products and services. Once you no longer wish to be engaged with Bespoken we may still need to keep hold of your data if there is a legal reason for doing so (such as for tax purposes where you have made purchases to play in our competitions or where we need to resolve any disputes with you).

CHANGES TO OUR DATA PROTECTION.

If we amend our Data Protection, or we make any substantial changes, we will email you if it’s appropriate.

YOUR RIGHTS.

In certain situations, you are entitled to:

• access a copy of your personal data;
• correct or update your personal data, which you can do yourself by logging into your account or if you would prefer, please contact us and we can help you out;
• erase your personal data;
• Object to the processing of your personal data where we are relying on a legitimate interest (as set out in the above table);
• Restrict the processing of your personal data;
• Request the transfer of your personal data to a third party; or

If you want to exercise any of these rights, please contact us. You don’t have to pay a fee to exercise your rights, unless your request is clearly unfounded, repetitive or excessive (in which case we can charge a reasonable fee). Alternatively, we may refuse to comply with your request in these circumstances. Where your request is legitimate, we will always respond within one month (unless there is a legal reason to take longer, such as where your request is particularly complex). We may also need you to confirm your identity before we proceed with your request if it is not clear to us who is making the request. In addition to the above, you may get in touch with the ICO (Information Commissioner’s Office) if you are concerned about the way in which we are handling your personal data. However, where possible, we would really appreciate you speaking with us first if you have any concerns.

HOW TO OPT-OUT OF BESPOKEN MARKETING

You can opt-out of any Bespoken marketing at any time either by contacting us or by using the opt-out function detailed in the relevant marketing email. Please note that we may still need to send you service notifications by email, such as advising you of updated privacy terms or terms of play.

We do not pass your data onto any third parties for their marketing purposes. However, should there be any need in the future we will always get your consent. You can then opt-out from any third party marketing at anytime following the same process as above.

CONTACT US

If you would like to discuss anything in this policy or if you want to exercise your rights, please get in touch:

Email: contact@justbespoken.com

Telephone: +971 4 2438778