Privacy Policy

Welcome to our Privacy policy relating to the use of the Website FPLWolpack.com (the “Website”) and participation in our tournaments from time to time (the “Tournament”)

We respect your privacy and are committed to protect your personal data and processing in compliance with applicable laws including but not limited to Regulation (EU) 2016/679) of the European Parliament and the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (the “GDPR”).

This Privacy Policy will inform you as to how we look after your personal data through your use of this Website, including any data you may provide through this website when you sign up to our blog or take part in a Tournament.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and policies and is not intended to override them.

  1. Who We Are

The Data Controller of your Personal Data is FPLWolfpack (“We,” “Us,” “Our”). The purpose of this Privacy Policy is to inform you of how the Company collects, processes, uses, stores and protects your Personal Data as well as your rights with respect to the processing of your Personal Data.

  • By visiting Our Website and participating in a Tournament, you hereby acknowledge reading and fully accepting the terms set out in this Privacy Policy.
  • you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. Should you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us at FPLWolfpack.
  • Changes to privacy policy, your duty to inform us of changes and third-party links
  • We keep our privacy policy under regular review. This version was last updated on the 13th of August 2020. We reserve the right to amend and update this Privacy Policy, as may be appropriate, and any changes thereof shall come in force and effect from the instance they appear online on the Website. Any substantial modifications to this Privacy Policy will communicated to you.
  • It is of utmost importance that the personal data we hold about you is accurate sand current. Please keep us informed if your personal data changes during your relationship with us.
  • The Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
  • Principles of Data Processing
  • We fully respect your fundamental rights and consider protection of your Personal Data to be a priority. Accordingly, when processing, We follow the following basic principles:
    • We submit your Personal Data only for lawful and fair processing, and We maintain full transparency vis-à-vis the way We handle your Personal Data;
    • We collect and process your Personal Data only for specified, explicit, and legitimate purposes as outlined in this Privacy Policy, and We do not process it further in any manner incompatible with these purposes;
    • We process your Personal Data only to the extent that it is necessary and appropriate to purposes for which it is collected;
    • We make reasonable efforts to ensure that your Personal Data is accurate and, where necessary, updated with regard to the purposes of the processing, taking all reasonable steps to immediately delete or correct it in case of inaccuracy; and
    • We process your Personal Data in a manner that guarantees its security by using appropriate technical and organizational measures.
  • In general, we comply with all applicable laws statutory obligations, as Data Controller of your Personal Data.
  • The Data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, title, date of birth and gender.
  • Contact Data includes [delivery address, email address and telephone numbers].
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Website
  • Profile Data includes your username and password, your interests, preferences, feedback and survey responses. 
  • Usage Data includes information about how you use our Website.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Where we need to collect personal data by law, or under the terms of any Tournament, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

  • How your personal data is collected

We use different methods to collect data from and about you including through:

  • Direct interactions. you may give us your [Identity, Contact and Financial Data] by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • create an account on our website;
    • subscribe to our service or publications;
    • request marketing to be sent to you;
    • enter a Tournament; or
    • give us feedback or contact us.
  • Third parties or publicly available sources. We will receive personal data about you from various third parties as follows:
    • analytics providers such as Google; and/or
    • Social Media Platforms such as Instagram, Facebook and Twitter
  • How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform our obligations in accordance with our terms and conditions.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. you have the right to withdraw consent to marketing at any time by contacting us.

  • Purposes for use of your personal data

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal grounds we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/ActivityType of dataLawful basis for processing including basis of legitimate interest
To register you as a new customer(a) Identity (b) ContactPerformance of a contract with you
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey(a) Identity (b) Contact (c) Profile (d) Marketing and Communications(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

Where:

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). you can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of obligations in virtue of our terms and conditions which you have signed up to.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms

Promotional offers from us

You will receive marketing communications from us if you have requested information from us.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

you can ask us or third parties to stop sending you marketing messages by contacting us at any time.

Change of purpose

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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

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.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. 

  • Data Recipients
  • The processing of your Personal Data by our Data Processors is done under a contract compelling Data Processors to the same level of data protection provided under this Privacy Policy in accordance with applicable laws.
  • We will not disclose your Personal Data with any third parties outside of the European Union. However, in the event that such a data transfer occurs, we will take all reasonable steps possible to ensure that your data is treated as securely as it is within the European Union and in accordance with this Privacy Policy and applicable legislation. Additionally, we will update this Privacy Policy to reflect the cross-border data transfer and the relevant safeguards for your privacy.
  • In the event that we are required by a court or other administrative authority, pursuant to an investigation relating to unlawful activities such as money laundering and in any other case that we are legally bound to do so, we may transfer your Personal Data to public authorities to the extent specified by applicable law.
  1. Data Security and Confidentiality
  2. In order to ensure the proper use and integrity of your Personal Data and to prevent unauthorised or accidental access, processing, deletion, alteration or other use, we apply appropriate internal policies and takes all appropriate organizational, technical and procedural security measures, as well as technical standards, in accordance with applicable laws and regulations.
  • The processing of your Personal Data is conducted in a manner that ensures confidentiality and security, taking into account the latest developments, implementation costs and the nature, scope, context and purposes of the processing, as well as the risks for your rights and freedoms, which are applicable in each circumstance.
  • Your Personal Data is processed solely by authorised personnel, bound by strict obligations of confidentiality.
  1. Retention of Personal Data
  • We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
  • 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, regulatory, tax, accounting or other requirements.
  • In some circumstances you can ask us to delete your data: see Section 10 below for further information.
  • In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
  • Your Legal Rights

You have the right to:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. you also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. you also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
    • If you want us to establish the data’s accuracy.
    • Where our use of the data is unlawful but you do not want us to erase it.
    • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
    • you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

We will respond to any of your requests within one (1) month from their receipt. Upon prior notice, this period may be extended by a further two (2) months if necessary, taking into account the complexity of the request and the number of any other pending requests. In case of rejection of your request, we will provide relevant justification.

If your request does not meet the requirements of applicable law, or is unfounded, repetitive or excessive, we reserve the right either to: (a) impose a reasonable fee, taking into account the administrative costs of providing the information or communicating or executing the requested action, or (b) reject your request.

If there are any doubts as to the identity of the individual submitting the request, we reserve the right to request the provision of additional information necessary to confirm their identity.

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