Contents

    1. OVERVIEW

1.1. Introduction to Paddy Power.

1.1.1. Controller details.

1.1.2. About the Flutter Group.

1.1.3. Contact details, including DPO.

1.2. Privacy and Data Protection at Paddy Power.

1.2.1. Our commitment.

1.2.2. Our key privacy and data protection principles.

1.3.How to navigate and read this document.

1.4.Changes to the Statement.

    2. PERSONAL DATA TYPES WE USE.

2.1.Data provided by you.

2.2.Data created by using our Services.

2.3.Data from other sources.

    3. HOW AND WHY WE USE YOUR PERSONAL DATA.

3.1. Site/App Performance, Localisation & Analysis.

3.1.1. Who the section applies to.

3.1.2. Overview.

3.1.3. The purpose and legal basis for processing your personal data.

3.1.4. Who we share your personal data with.

3.2. Registering & Verifying Your Account.

3.2.1. Who the section applies to.

3.2.2. Overview.

3.2.3. The purpose and legal basis for processing your personal data.

3.2.4. Who we share your personal data with.

3.3. Processing Your Payments.

3.3.1. Who the section applies to.

3.3.2. Overview.

3.3.3. The purpose and legal basis for processing your personal data.

3.3.4. Who we share your personal data with.

3.4. Delivery of the Services.

3.4.1. Who the section applies to.

3.4.2. Overview.

3.4.3. The purpose and legal basis for processing your personal data.

3.4.4. Who we share your personal data with.

3.5. Contacting Customer Operations.

3.5.1. Who the section applies to.

3.5.2. Overview.

3.5.3. The purpose and legal basis for processing your personal data.

3.5.4. Who we share your personal data with.

3.6. Marketing & Research.

3.6.1. Who the section applies to.

3.6.2. Overview.

3.6.3. The purpose and legal basis for processing your personal data.

3.6.4. Who we share your personal data with.

3.7. Fraud Prevention.

3.7.1. Who the section applies to:

3.7.2. Overview.

3.7.3. The purpose and legal basis for processing your personal data.

Reporting and Analysis.

3.7.4.Who we share your personal data with.

3.8. Safer Gambling.

3.8.1. Who the section applies to.

3.8.2. Overview.

3.8.3. The purpose and legal basis for processing your personal data.

3.8.4. Who we share your personal data with.

3.9. Anti-Money Laundering and Counter-Terrorist Financing.

3.9.1. Who the section applies to.

3.9.2. Overview.

3.9.3.The purpose and legal basis for processing your personal data.

3.9.4. Who we share your personal data with.

3.10. Integrity. 45

3.10.1. Who the section applies to.

3.10.2. Overview.

3.10.3. The purpose and legal basis for processing your personal data.

3.10.4. Who we share your personal data with.

3.11. Other Purposes.

3.11.1. Who the section applies to.

3.11.2. Overview.

3.11.3. The purpose and legal basis for processing your personal data.

3.11.4. Who we share your personal data with.

    4. GENERAL PROCESSING INFORMATION.

4.1. Group sharing.

4.2. International transfers.

4.3. Keeping your personal data secure.

4.4. How long we keep your personal data for.

    5. YOUR DATA SUBJECT RIGHTS.

5.1. Access.

5.2. Rectification.

5.3. Erasure, or 'Right to be Forgotten

5.4. Restriction.

5.5. Portability.

5.6. Object.

5.7. Rights relating to automated-decision-making and profiling.

5.8. Rights to complain to the regulator.

1.OVERVIEW

Welcome to the Paddy Power online privacy statement.

At Paddy Power, we like to make things easier for our customers and that includes being clear and open about how and why we use your personal data.We know theres nothing more off-putting than the sight of a lot of boring small print, so this privacy statement ("Statement") is designed for you to easily access the information you need, when you need it. Its also written in plain English, to make it clear, simple, and easy to read.

This Statement applies to personal data used in connection with our websites, applications, online products or services that link to this Statement or that do not have a separate privacy statement (collectively our "Services"). For information on personal data used in connection with the products and services made available through our network of Paddy Power retail shops and other physical locations, please see the Paddy Power Retail privacy policy and privacy statement.

In this first section of the Statement, we provide an Introduction to Paddy Power (including our contact details), we provide information on Privacy and Data Protection at Paddy Power, we explain How to navigate and read this document and we also explain how to stay abreast of Changes to the Statement.

We hope that you find this Statement helpful but if you have any concerns or questions please feel free to share feedback via the contact methods listed in the Contact details, including DPO section below.

1.1.Introduction to Paddy Power

1.1.1.Controller details

References in this document to "us", "our","we", Paddy Power or "PP" are references to

  • Power Leisure Bookmakers Limited, which is a company registered in Ireland with (registration number 906103) with offices located at Power Tower Blocks, 1-3, Belfield Office Park, Beech Hill Road, Clonskeagh, Dublin, Ireland, as the main establishment of the data controller making decisions on the purpose and means of processing covered by this Statement and
  • The other licenced legal entities with whom our customers in the UK or Ireland have a relationship, as set out in the "Who We Are" section of our customer terms and conditions.

For more company information in relation to licensed entities and regulatory matters, please refer to the Paddy Power Regulatory Information page.

Please note that this Statement does not cover the in-shop activities of our Paddy Power Retail shops or physical locations. For information on the use of personal data in this regard, please refer to the Paddy Power Retail privacy policy and privacy statement.

1.1.2.About the Flutter Group

Paddy Power is a member of the Flutter Group of Companies. Any reference to the "Group" within this Statement includes Flutter Entertainment plc and all or any of its direct or indirect subsidiary undertakings, joint venture partners, and their related companies wherever located in the world as may exist from time to time including, but not limited to, Betfair UKI, Sky Betting and Gaming, Tombola, Betfair International, Sportsbet, FanDuel, TVG, Adjarabet, Junglee Games, Sisal and PokerStars.

The Flutter Group is split into four regional divisions, namely UK & Ireland ("UK&I"), US, Australia and International, with each one housing a number of the abovementioned Flutter Group brands. Paddy Power is within the UK&I division, alongside Betfair UKI (UK and Ireland customers), Sky Betting and Gaming, and Tombola.

Please note that the Flutter Group also operates other gambling companies and your use of those products and services will be subject to privacy statements that may differ to the one contained herein. Any exercise of your privacy or data protection rights in accordance with this Statement will only relate to the personal data being processed by the Paddy Power companies listed in the Controller details section and will not apply in regard to any products or services operated directly by the Flutter Group unless otherwise stated in this Statement.

The Flutter Group operates separate privacy policies for their different brands, including:
PokerStars UK users: https://www.pokerstars.uk/privacy/

Betfair UK and Ireland users:

Betfair non-UK or Ireland users:
Sky Betting and Gaming: https://support.skybet.com/s/article/Privacy-Policy

Tombola:https://www.tombola.co.uk/privacy-policy

1.1.3.Contact details, including DPO

If you have any concerns about how Paddy Power handles your personal data, you can contact our Data Protection Officer (DPO) and Data Protection Team at:dataprotection@paddypowerbetfair.com. If you wish to exercise your Data Protection rights, please see YOUR DATA SUBJECT RIGHTS

1.2.Privacy and Data Protection at Paddy Power

Data protection is all about keeping your personal data safe and secure, and ensuring that your legal rights in relation to your data are respected. Privacy is a fundamental right, and you are entitled to have your personal data protected, used in a fair and legal way, and made available to you when you ask for a copy.

1.2.1.Our commitment

At Paddy Power, we take the protection of our customers personal data and privacy very seriously, and we never lose sight of the fact that your personal data is YOUR personal data.

We believe in using your personal data to make things simpler and better for you, and we will always keep your personal data safe using the highest standards of security.Well be clear and open with you about why we collect your personal data and how we use it, and where you have choices or rights, well explain them to you and respect your wishes.

Whats more, we manage customer personal data in a tightly controlled way to ensure we deliver our products in a safe and reliable fashion, to do all we can to proactively protect our customers from harm, and to ensure our business meets its legal and regulatory obligations and is protected against attack, crime or other potential risks.

1.2.2.Our key privacy and data protection principles

To meet these commitments, we employ the following 5 principles at Paddy Power. These principles are at the heart of everything we do and ensure that your rights are considered at every step.

  1. Keeping your data secure: We recognise that online security and data protection is an area of vital importance for all our customers, so it is important to us that you have confidence in the security of your personal details before you register an account. We are committed to employing best-in-class security measures to protect your information and our technological security solutions are governed by a mature framework.

  1. Data protection by design and default: We are committed to implementing technical and organisational measures, at the earliest stages of the design of our Services, in such a way that safeguards your privacy and data protection rights from the start ('data protection by design). By default, we ensure that personal data is processed with the highest levels of privacy protection and that data is made accessible only to those who need it ('data protection by default). We also routinely use pseudonymisation and encryption when processing your data internally and where data is shared externally.

  1. Transparency: Transparency is a key principle of data protection, and we believe in being up front and honest with you about how we use your data. Our Privacy Statement provides you with everything you need to know about how your information will be used by Paddy Power, and we embed ad-hoc privacy notices when you are using our sites to let you know when we might be using data in ways you dont expect.

  1. Giving you the choice: We believe that respecting your privacy begins with giving you a say in how it is used. Where you have rights in respect of the data we process relating to you, we will do everything we can to make it easy to exercise these choices. We also endeavour to give you real choice over how you hear from us, and how we use cookies and other technologies.

  1. Using your data to keep you safe: At Paddy Power we do all we can to proactively protect our customers from harm, and that includes using your data to identify, prevent and react risky behaviour. Using our industry-leading levels of customer insight and our passion to do the right thing by our customers, we are committed to using your data and patterns of play to ensure a safer experience for every person that engages with our brands.

1.3.How to navigate and read this document

We have designed this Statement so that you can easily access the information you need. It is split into four parts as follows:

  • PERSONAL DATA TYPES WE USE explains the different types of personal data that you provide to us when you use our Services, that is generated when you use our Services and that we collect from other sources.
  • HOW AND WHY WE USE YOUR PERSONAL DATA explains what we use your personal data for. It contains different sections for each type of personal data usage, with each section providing information on the purposes and legal basis for using the data, as well as on any sharing of the data that may occur. Our use of personal data is not the same for all types of individuals (e.g. website visitors, customers, etc.), so please see Who the section applies to at the beginning of each section to find out the ones that relate to you and your personal data.
  • GENERAL PROCESSING INFORMATION contains information about our personal data processing that is relevant to all individuals who engage with our Services.
  • YOUR DATA SUBJECT RIGHTS provides you with information on the rights you have in relation to your personal data and how to exercise those rights.

For information on cookies, please see our onsite Cookie Banners, onsite Privacy Preference centre (located at the bottom of our websites) or visit our Cookie Policy

1.4.Changes to the Statement

It is important to check back often for updates to this Statement. If we make material and important changes, we will let you know by placing a notice on the relevant Service and/or contacting you using other methods such as email.


2. PERSONAL DATA TYPES WE USE

We gather and use different types of personal data that you provide to us, that is generated through your use of our Services or is which we have collected from other sources. This data includes your registration information, verification and know your customer documentation, your interactions with our customer operations teams, payment information, betting and transactional information, financial information, safer gambling information, device, tracking and other online information, profiling and analytical information, as well as information from other sources including public sources and trusted third parties.

Below, you can find out more about the personal data submitted by you, the personal data generated from your use of our Services, and personal data obtained from other sources.

2.1.Data provided by you

When using our Services, we collect the following types of information provided by you:

Registration Information

When you register an account with us, you are required to provide us with your name, date of birth, gender, postal address, e-mail address, phone number, security questions, marketing preferences and any other details as might be requested from you for the purpose of registration and/or continued use of our Services.

As a condition to using our Services, we will ask you to share your precise geolocation so we can ensure that we are authorised to provide the Services to you in your location.

Verification and Know Your Customer ('KYC') Information

In order to verify your identity, you may be required to provide documents such as a copy of your passport or drivers licence, documentation establishing your address such as utility bills, or any other information we deem necessary to confirm your age and/or identity.

Interactions with Customer Operations

When you interact with our customer operations via live chat, phone, email or social media platforms we will retain a record of your conversations with our staff, as well as notes relating to these interactions and their outcomes.

Where you contact us through a social media account we will be provided with a copy of the social media profile details (name, profile photo and other information) you make available to us as well as the content of your messages to us.

Payment Information

Information in relation to your chosen payment method such as debit card details, cardholder name, e-wallet details, or information in relation to your alternative payment method.

Financial Information

Payslips or other documents proving your source of wealth and/or source of funds including but not limited to proof of earnings, bank statements and evidence of business ownership.

Safer Gambling Information

Data your provide to us in relation to concerns you may have about gambling risk, harm or safety, or as part of a vulnerability assessment. Some other Safer Gambling Information is also created while you use our Services see Data created by using our Services below.

Posts, Comments and Messages

Information about the way you contribute to and communicate with, and through, our Services, for exle when you post comments via our social media channels or chat functionalities such as forums, chat rooms and message boards, profile comments, blog post comments, in-game challenges and chat messaging with game operators or other users.

Responses to Surveys and Market Research

Responses to surveys or market research that we conduct.

Special Category Data

Special category data is personal data that needs more protection because it is sensitive. It includes biometric data that may be used for identification purposes, genetic data, data concerning an individuals health, sex life or sexual orientation, or personal data that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs.

In the course of your contacts with customer operations, if you provide information to us on health conditions that you may have, we may retain this information and use it to add further protections to your account, where appropriate.

Especially, where you have vulnerabilities which may affect your ability to safely use our Services, we may request further information or may take extra steps to enhance protection for you. This may involve health information.

We will only ever use special category data when absolutely necessary and where lawful to do so. Where possible, we will always ask for your consent before we proactively request or use this information. In limited circumstances where consent is not possible, we may need to use this information to protect your vital interests or for reasons of substantial public interests in accordance with law.

2.2.Data created by using our Services

Some of the personal data we process relating to you is generated by your use of the Services .

Betting and Transactional Information

Your betting, gaming, deposits, payments, and other account transactions.

Safer Gambling Information

Safer Gambling controls that you decide to apply through your use of our Services, such as deposit limits, cool off periods, or self exclusions, or controls that we pro-actively decide to apply in order to prevent harm, such as spend limits or enforced exclusions.

Device Information

Details relating to your device and communication data, including IP address, browser type, unique device identifier, Apples identifiers for advertisers ('IDFA), hardware model, operating system and version, software, preferred language, serial numbers, device motion information, mobile network information and location data.

Server Logs and Traffic Information

Information such as dates and times of access, the app features or pages you view, app crashes and other system activity, and the third-party site or service you were using immediately before visiting our site.

Cookie and Tracking Information

When you access or use our content, products, and Services, we may collect information from your devices through the use of 'cookies' and similar technologies.

These technologies can collect a wide variety of information about how you interact with our Services, such as your language preferences, pages visited and content viewed, links and buttons clicked, and URLs visited before and after you use our Services.

For further detail on cookies, please refer to our Cookie Policy. To manage your cookie preferences, please go to our onsite Privacy Preference centre (located at the bottom of our websites).

Information derived from Profiling and Analysis

We carry out profiling and analysis to understand our customers and business as best we can. The analysis and profiling is based on various different data points, which differ depending on what we are trying to understand. For exle, profiling and analysis to predict a customers risk of gambling related harm will be based on different data than the models used to provide you a more personalised version of our Services. The data used may include what we know about you, such as your age, location, betting and transactional information, interactions with us and our Services, etc., as well as other relevant data points such as aggregated (non-personal data) data or data about you that we have obtained from publicly or commercial available sources.

2.3.Data from other sources

Not all the personal data we hold about you will always come directly from you or from your use of our Services. As detailed below, we may also collect information from third parties such as our partners, service providers and publicly available websites (i.e. social media platforms), to comply with our legal and regulatory obligations, offer Services we think may be of interest, to help us maintain data accuracy and to provide and enhance the Services.

Social media profile details

Your name, profile photo and other information you make available to us when you connect with or contact us through your social media account.

Credit Reference Agencies

Data provided by trusted credit reference agencies who may perform a soft check for verification and affordability purposes which do not affect your credit score. A record of the outcome of these checks is provided back to us.

Publicly Available Sources

In accordance with our legal obligations, we may consult publicly available information about you such as your social media pages, information available on the world wide web, property ownership details, the electoral roll, publicly available company information , area deprevation information pr other information from national statistics offices, industry bodies of which you may be a member, County Court Judgments and insolvency registers.

From other Flutter brands

In some circumstances, as detailed in the HOW AND WHY WE USE YOUR PERSONAL DATA and Group sharing sections below, we may receive or get access to some personal data from other brands within our Flutter Group. For example, and as detailed in the Safer Gambling section below, we operate a cross brand self exclusion mechanism between the Flutter Group brands that operate in the UK whereby if you self exclude from Betfair UKI, Sky Betting and Gaming, Tombola or PokerStars, that data will be shared with us here in Paddy Power so that the exclusion can be applied to Paddy Power as well.

Information from your family, friends or contacts

Data may be received by us from third party contacts if you ask for a family member to support you with the management of an issue or complaint, if you have legal power of attorney representing you or if someone contacts us to tell us about a customer of ours who they have concerns about. In these instances we will have records of the third party contact details and recordings of the interactions. For the avoidance of doubt, we will also need to obtain and use contact information from these third party family members, friends or contacts in order to manage our communication with them strictly and only for the purposes mentioned above.

Information from law enforcement, courts or other bodies

Data about you may be received from law enforcement, courts, government bodies, regulatory bodies or other similar bodies as part of an information disclosure request we receive.


3. HOW AND WHY WE USE YOUR PERSONAL DATA

We only use your personal data where necessary and where it is lawful to do so. Our use of your personal data is needed to enable us to deliver the Services to you, to meet our legal or regulatory obligations, to meet or protect yours, ours, the wider publics or other third parties interests, and sometimes for other reasons only where we have your explicit consent to do so.

Below, we explain how and why we need to use your personal data, providing you with information on our different uses of your personal data. This includes detailed information on the reasons for using your data, the types of personal data we use and also information on the legal basis for using your data, which may include using your personal data:

  • To enter into or perform a contract with you ('Performance of a contract), such as delivering our Services in accordance with the the customer Terms & Conditions
  • To meet our legal or regulatory obligations ('Legal and regulatory obligations), such as our taxation, company or data protection law or our licencing obligations
  • To meet our own legitimate interests or those of a third party ('Legitimate interests), such as where we use data to protect our business assets or information, to improve our Services or to keep you safe while you use our Services
  • Where you have provided us with consent to do so ('Consent), such as where you have provided us with consent to provide you with marketing information
  • To perform tasks in the interests of the general public ('Public interests), such as safeguarding the public from gambling related harms or
  • To protect your or someone elses vital interests ('Vital interests)

Click on each different use of personal data below to find out more about how and why we use your personal data.

3.1.Site/App Performance, Localisation & Analysis

3.1.1.Who the section applies to

All visitors to Paddy Power websites, apps or other online assets that are covered by this Statement.

3.1.2.Overview

Site and app performance, diagnostics, research and development

We use your personal data to provide you with the Services and ensure that our sites and apps are functioning correctly.We use technical information about your device, operating system and browser version to present you with the correct version of our website or app and to keep it functioning securely. This information is also used to diagnose system problems, improve and test the features and functions of our Services, and carry out testing.

Site and app localisation

In order to abide by our legal and regulatory requirements, we will also check your location to ensure users are using our Services in licensed countries, and that the correct version of the site is presented to them.

Site and app analysis

We conduct analysis of the performance and usage of our website and apps to help improve your user experience. This analysis is based on cookies and similar tracking technologies, which are used subject to your consent. For further information on cookies, please refer to our Cookie Policy. If you are a customer of ours, this website and app analysis data may be combined with other personal data we hold about you and used as part of some of our wider customer analysis purposes, which are explained in other sections of this Statement.

3.1.3.The purpose and legal basis for processing your personal data

Purpose

Categories of PD

Legal basis

Site and app performance, diagnostics, research, and development:

To ensure our Services are operating correctly, to help diagnose system problems, to administer our websites and apps, to improve and test the features and functions of our Services, and to carry out testing and analysis.

Device Information

Server Logs and Traffic Information

Performance of a contract

Site Localisation

Verifying that you are using the site in a licenced jurisdiction and presenting you with the correct version of the site.

Registration Information

Device Information

Performance of a contract

Legal and Regulatory Obligations

Analysis

Statistics and analysis on how users interact with our Services.

Device Information

Server Logs and Traffic Information

Cookie and Tracking Information

Information derived from Profiling and Analysis

Consent, where required to use non-essential cookie or related information

3.1.4.Who we share your personal data with

  • We use a number of tools to assist with site and app performance, localisation and analytics, such as Cloudflare, Google Analytics, Google Tag Manager, Akamai and Quantum Metric.
  • Other companies within the Flutter Group, primarily Betfair UK&I and Sky Betting & Gaming who provide support services as part of the Flutter Groups UK&I division

3.2.Registering & Verifying Your Account

3.2.1.Who the section applies to

All customers that register and verify an account.

3.2.2.Overview

Account Registration

When you register an account with us, you are required to provide us with certain information in order to set up your account and begin the relationship with you as a customer.

Electronic Verification

As part of the registration process, we electronically check the information you provided to us at registration against trusted third party databases in order to verify your age, address and identity. This allows us to ensure that you are who you claim to be and that you are old enough to use the Services. This may include checks against publicly available available information, such as electoral rolls, to verify the accuracy of the details you have provided.

Document Verification

Unfortunately, the electronic verification checks are not perfect, and we cannot validate 100% of our customers electronically. This is not the fault of you, the customer, but a limitation of the databases we use. In these circumstances, you will be required to provide us with a copy of your photographic identification, such as passport or drivers licence. We may also ask you to provide us with proof of address, such as a copy of a recent utility bill.

Once you provide your identification documentation, we will perform matching checks against information entered when opening an account and if the match is confirmed, verification is successful. Where we have been unable to successfully match a customers details, an account suspension may be applied. The process is overseen by our Customer Operations teams. To allow quicker account registration, should you open a betting account with Paddy Power and you already have an account with Betfair UK&I, we may use the verification documents submitted to Paddy Power in order to complete the verification for your Paddy Power account (and vice versa). If you have any queries or concerns about the verification process or an account suspension, please get in touch and one of our advisors will be able to assist.

Additional Validation Checks

At the point of registration, several system checks are performed to prevent a customer opening duplicate accounts, prevent registration from prohibited jurisdictions and to prevent and protect our Services against risk, fraud and crime.

Affordability

To help us comply with our legal and regulatory obligations, we may perform an affordability check, to ensure you have no markers of financial vulnerability when you use our Services. This assessment is performed on our behalf by a trusted third-party, TransUnion, and will leave a search footprint which will not negatively impact your TransUnion credit score. For further information, please refer to TransUnions Privacy Statement: http://www.transunion.co.uk/legal-information/bureau-privacy-notice

3.2.3.The purpose and legal basis for processing your personal data

Purpose

Categories of PD

Legal basis

Account Registration

Gathering essential information from you in order to set up your account and begin the relationship with you.

Registration Information

Performance of a contract

Legal and regulatory obligations

Electronic Verification

Eletronic verification of a customers age, address and identity using trusted third parties.

Registration information

Verification and KYC Information

Publicly Available Information

Performance of a contract

Legal and regulatory obligations

Document Verification Verifying customers identification documents.

Registration Information

Verification and KYC Information

Performance of a contract

Legal and regulatory obligations

Additional Validation Checks

Checks to prevent fraud, crime and breach of our terms and conditions.

Registration Information

Verification and KYC Information

Device Information

Cookie and Tracking Information

Publicly Available Information

Performance of a contract

Legal and regulatory obligations

Affordability Check (UK Customers)

Checks, using a trusted Credit Reference Agency, Transunion, to verify how much you can afford to spend onsite.

Registration Information

Verification and KYC Information

Performance of a contract

Legal and regulatory obligations

3.2.4.Who we share your personal data with

  • Electronic verification We use third parties to verify that the details you have submitted are legitimate and that you are of legal age to gamble, including GB Group, TransUnion, Experian and Aristotle.
  • Document checking We use third parties to help in confirming the legitimacy of the documents you have submitted, including Jumio.
  • Additional validation checks via third party verification companies
  • Affordability checks using third parties, such as Transunion
  • Third party software providers who enable us to deliver the Services to you, including our customer communication software provider (e.g. Adobe, LivePerson) and customer management software providers (e.g. Zendesk, SaleForce) and
  • Other companies within the Flutter Group, primarily Betfair UK&I and Sky Betting and Gaming who provide customer registration and verification management and technical support services as part of the Flutter Groups UK&I division.

3.3.Processing Your Payments

3.3.1.Who the section applies to

All registered customers who add a payment method to, deposit to or withdraw from their account.

3.3.2.Overview

Processing payment method additions, deposits and withdrawals

In order to process your payment method addition, deposits and withdrawals, we will use information in relation to your chosen payment methods. These details are used to provide you with swift and secure deposits, to prevent, where possible, fraudulent use of your payment methods, and to monitor trends and performance in relation to our payment Services.

When you make a deposit and withdrawal to your account, your card details or details in relation to your bank or e-wallet provider will be used in order to process these transactions.

Investigating escalations and complaints relating to payments

If you have concerns in relation to a deposit or withdrawal that you have made, we will investigate your query promptly and may use further information in relation to your account to support this investigation. You may be asked to provide further information, and in certain circumstances, we may contact your bank or payment provider to resolve the issue.

Monitoring alerts and Reporting

We perform monitoring on all payment method additions, deposits or withdrawals made, and also on your location, IP address or device, in order to rapidly identify suspicious activity, including activity that may be in breach of our Services terms and conditions. These processes use the minimum personal data necessary to alert the relevant teams who may then investigate further.

Payment proof of ownership

In certain circumstances, where we have concerns over payments being made on customer accounts, we may perform additional due diligence to confirm that funds are being sent and received from the true owner of the account. We may examine details in relation to your location, IP address or device to confirm where payments are being made from. We may also require you to submit additional verification documentation to confirm your ownership of the payment method in question.

3.3.3.The purpose and legal basis for processing your personal data

Purpose

Categories of PD

Legal basis

Processing payment method additions, deposits and withdrawals

Using your payment details to process the transactions you request.

Registration Information

Payment Information

Device Information

Cookie and Tracking Information

Performance of a contract

Investigating escalations and complaints relating to payments.

Investigating concerns you or others may raise in relation to payments made on your account, or using your payment information.

Registration Information

Payment Information

Betting and Transactional Information

Device Information

Cookie and Tracking Information

Performance of a contract

Legal and regulatory obligations

Consent, where required to use non-essential cookie or related information

Monitoring alerts and Reporting

Real-time monitoring of deposits and withdrawals to identify trends and transactions requiring further review

Registration Information

Payment Information

Betting and Transactional Information

Device Information

Cookie and Tracking Information

Performance of a contract

Legal and regulatory obligations

Consent, where required to use non-essential cookie or related information

Payment proof of ownership

Confirming funds are being sent or received from owner that holds account with us

Registration Information

Payment Information

Betting and Transactional Information

Device Information

Cookie and Tracking Information

Verification and KYC Information

Legal and regulatory obligations

Performance of a contract

Consent, where required to use non-essential cookie or related information

3.3.4.Who we share your personal data with

  • Payment providers - Sharing details in order to process your transactions with your registered bank, e-wallet providers including Apple Pay, our payment providers such as WorldPay, Global Payments, AIBMS, PayPal and Paysafe Group (and their appointed third parties)
  • Fraud prevention service providers
  • Third party software providers who enable us to deliver the Services to you, including our gaming software providers (e.g. PlayTech, Evolution Gaming) and customer management software providers (e.g. SalesForce) and
  • Other companies within the Flutter Group, primarily Betfair UK&I and Sky Betting and Gaming who provide payment and Service delivery support as part of the Flutter Groups UK&I division.

3.4.Delivery of the Services

3.4.1.Who the section applies to

All registered customers who transact, view and place bets or play games on the website(s) or mobile app(s).

3.4.2.Overview

Providing our Services

We will use your information to deliver the Services and process the bets and transactions that you make. For these purposes, your betting and transactional information may be analyised in order to improve the Services we provide, in order to investigate and resolve issues with the functioning of the Services, and in order to fulfil promotions you have opted into. This processing is in line with the Services terms and conditions and any promotion terms and conditions which you have agreed to.

Onsite/In-App Personalisation

Where relevant, we use personal data to deliver and suggest tailored content to personalise your experience with our Services. This is processing which is necessary for the purpose of our legitimate interests in delivering or presenting relevant content to our customers.

Whichever Services you use, wherever and however you interact with us, we want to give you the same great level of service and make it personal to you. We will tailor your experience, personalising the layout and content of our sites according to what we know about you, your preferences and the way you like to play or bet. For exle, we will present you with features we know you have used or think you are likely to use or show you the type of score card or bet slip that best suits your style of betting.

We also look at aggregated (non-identifiable) data showing how our customers use our products and features and which games they tend to enjoy. We use this information to suggest games we think youll enjoy because they are popular with others who play the same games as you.

We believe this personalised experience makes betting and gaming better and we want to give you the best customer experience we can. Using your personal data in this way enables us to do that in a way that we believe does not have an impact on your privacy. If you dont want your data used in this way your option is to not use our Services and to close your account.

Please note that some aspects of your customer experience are provided via cookies. If you have provided consent for these cookies, we will personalise certain aspects of our site, such as remembering your user name and location. You can change these preferences at any time via our Cookie Management centre located at the bottom of our websites. For more information visit our Cookie Policy.

Risk Management

In order to provide the Services to you in accordance with the Services terms and conditions, and for our legitimate purposes, we process your personal data to evaluate our commercial performance and manage risks to our business.

Most people use our products and Services fairly, but we carry out monitoring of how our customers bet, play and interact with our products and Services, to identify behaviour that is not in line with our customer Terms & Conditions or that could be prejudicial to our commercial interests.

At our discretion, we have the right to use this information in making decisions about whether to place restrictions on peoples accounts or, on very rare occasions, to close their accounts.We take this very seriously, and consider a wide variety of factors in making such a decision, taking into the information we hold about you as well as any information obtained from industry databases. The processes may involve an element of profiling, upon which decisions to restrict or close an account may be made. These decisions are made in accordance with our terms and conditions. If you wish to query or challenge any restriction, you can do so by contacting our support teams.

Customer Analysis

We carry out analytics to help us understand, how, when, where and why our customers use our Services, and how our business is performing. This helps us monitor and plan everything from the effectiveness of our advertising through to ensuring we have enough staff available to handle queries at peak times. It also gives us a much clearer picture of our customers generally, the broad demographic groups they fit into (e.g. age group, gender, location, etc.), their commercial value to us as a business, and the products and Services they use, which in turn helps us to develop better and more relevant features, products and Services.

Chat Rooms, Messaging, Community Forums and Blogs

A number of our Services provide features including chat rooms, messaging, community forums and blogs for collaboration, peer connection, games, and information exchange purposes. Depending upon the Service, the personal data you choose to post, share, upload, or make available may be public and visible to others who use those Services. You should never post or share any information that is confidential or about others unless you have permission to do so. We may use information you provide in community and event profiles and forums to personalise your experience and to make content and peer connection recommendations. These Services may have their own terms of use and, where appropriate, their own privacy statements.

3.4.3.The purpose and legal basis for processing your personal data

Purpose

Categories of PD

Legal basis

Delivery of The Services

Providing the Services and processing the bets and transactions that you make

Registration Information

Payment Information

Betting and Transactional Information

Device Information

Cookie and Tracking Information

Performance of a contract

Consent, where required to use non-essential cookie or related information

Onsite/In-App Personalisation

Tailoring your onsite experience to match your preferences

Registration Information

Betting and Transactional Information

Cookie and Tracking Information

Device Information

Information derived from profiling and analysis

Legitimate Interests

Consent, where required to use non-essential cookie or related information

Risk Management

Manual and automated oversight of your activity to evaluate and manage commercial risk to our business. This may include, where appropriate, placing restrictions on your account or, on very rare occasions, closing your account.

Registration Information

Betting and Transactional Information

Posts, Comments and Messages

Device Information

Information derived from profiling and analysis

Performance of a contract

Customer Analysis

Monitoring and analysing customer behaviour to improve the performance of our business

Registration Information

Betting and Transactional Information

Device Information

Server Logs and Traffic Information

Cookie and Tracking Information

Information derived from profiling and analysis

Legitimate interests

Performance of a contract

Consent, where required to use non-essential cookie or related information

Chat rooms, messaging, and community forums

Provide chat, messaging, forum functionality or blog post comment capabilities as a component of certain elements of our Services

Registration Information

Device Information

Posts, Comments and Messages

Performance of a contract

3.4.4.Who we share your personal data with

  • Fraud prevention service providers we are contracted with
  • Third party software providers who enable us to deliver the Services to you, including our gaming software providers (e.g. PlayTech, Evolution Gaming), betting software providers (e.g. OpenBet), cloud software providers (e.g. Amazon) and customer management software providers (e.g. SalesForce)
  • Other companies within the Flutter Group, primarily Betfair UK&I and Sky Betting and Gaming who provide Service delivery and technical support as part of the Flutter Groups UK&I division.
  • Limited data is shared with other companies within the Flutter Group for risk management support purposes. However, this data is pseudonymised by Paddy Power, meaning the other members of the Flutter Group cannot identify you from the data.

3.5.Contacting Customer Operations

3.5.1.Who the section applies to

This section applies to any person that contacts Customer Operations via email, chat, phone, and social media.

3.5.2.Overview

Queries and account openings/closures

From time to time, you may experience issues with or have queries about your account or the Services. You may also need assistance in opening or closing an account with us.

When you contact our Customer Operations teams via the contact methods we offer, we will use information relating to your account and activity, as well as the information you provide to our staff, to investigate your query and work towards a resolution.

In order to process your query, you may be asked for additional information in relation to the issue you are facing. Any information you provide may be shared internally with other relevant operational teams. For exle, if you raise a concern in relation to Safer Gambling, your details may be shared with our Safer Gambling teams for further review.

Complaints and Alternative Dispute Resolutions

Should you decide to raise a complaint, a dedicated complaints procedure will be followed, including, where appropriate, escalation to our dedicated complaints team. If you remain dissatisfied by the final outcome of the investigation, and still wish to pursue a dispute or complaint, then you can raise a complaint with one of the Alternative Dispute Resolution ('ADR') providers, that Paddy Power engage with. In such circumstances, we may share any information we deem relevant to the dispute with the relevant ADR provider.

NOTE: For information about contacting Customer Operations for Safer Gambling reasons, please see the Safer Gambling section below.

3.5.3.The purpose and legal basis for processing your personal data

Purpose

Categories of PD

Legal basis

Queries amd account openings/closures

Resolving queries related to your account or the Services, or processing data to register or close accounts via our Customer Operations team.

Registration Information

Verification and KYC Information

Interactions with Customer Operations

Posts, Comments and Messages

Device Information

Betting and Transactional Information

Social media profile details

Legal and regulatory obligations

Performance of a contract

Complaints and Alternative Dispute Resolution

Investigate complaints and work towards a resolution. Sharing information to defend complaints made by you to ADR providers.

Registration Information

Verification and KYC Information

Interactions with Customer Operations

Posts, Comments and Messages

Device Information

Betting and Transactional Information

Social media profile details

Legal and regulatory obligations

Performance of a contract

3.5.4.Who we share your personal data with

  • Alternative Dispute Resolution Providers, including the IBAS (Independent Betting Adjudication Service) and eCOGRA
  • Social media partners, such as Twitter and Facebook, should you contact our Customer Support Social Media Teams
  • Third party software providers who enable us to deliver the Services to you, including our customer communication software provider (e.g. Adobe), gaming software providers (e.g. Playtech), social media communication management software (e.g. Verint), and customer management software providers (e.g. Zendesk, SaleForce, Live Person, IBM Watson) and
  • Other companies within the Flutter Group, primarily Betfair UK&I, Sky Betting and Gaming, and ,for queries only, Pokerstars, who provide customer support services as part of the Flutter Group

3.6.Marketing & Research

3.6.1.Who the section applies to

Anyone to whom Paddy Power / Betfair UKI directly or indirectly markets, promotes or advertises its products

3.6.2.Overview

Types of Marketing

(i) Direct Marketing

Subject to any consent preferences you have expressed (where applicable), we use personal data to deliver marketing and event communications to you across various platforms and methods, such as email, SMS, post, phone and push notification.

We will do this during the period of your relationship with us and, unless specifically instructed otherwise by you, for a maximum of 2 years after your account has been inactive in order to inform you about products, services, promotions and special offers which we think may be of interest to you.

If you wish to opt out of receiving direct marketing through specific channels (i.e. email, SMS, post, phone and push), about specific products (i.e. sports or gaming), or about products offered by other companies within the Flutter Group, you can do so by going to your MyAccount section when you login to your account and changing your channel, product or Flutter Group direct marketing preferences.

Please allow up to 28 days for any changes you make to your marketing preferences to be fully processed. Please remember that even if you opt out of receiving direct marketing, we may still send you important information related to the Services. Also, please note that if you opt out of direct marketing, you will still continue to receive bespoke offers and bonuses online while using the Services unless your personalised marketing preferences are updated – see ‘Personalised Marketing’ below. Also, please note that if you opt out of direct marketing, you will still continue to receive bespoke offers and bonuses online while using the Services unless your profiling preferences are updated see Marketing Personalisation below.

Please note that if you hold separate accounts within the Group, you should consider your marketing preferences for each separately. For exle, if you opted out of marketing for any other product within the Flutter Group and not Betfair UK&I, you will continue to receive marketing communications directly from Betfair UK&I unless updated.

(ii) Online and Social Marketing

We will work with social media companies (such as Facebook and Twitter), online advertising platforms (such as Google) and other trusted third parties and websites across the world wide web to provide you with information about our Services via their platforms.

Where these third parties accept information from advertisers like us and where you are not on a safer gambling related exclusion list, we may share limited personal data with those companies to enable us to send you information via their platforms or their partners, or market to audiences within their platforms who share similar characteristics to you. . The third parties may also obtain information about you from cookies placed on our domains, if you have opted-in to third party advertising cookies.

You can opt-out of personalised marketing and cookies at any time if you do not wish to receive targeted marketing like this online. An opt-out of personalised marketing means you will be excluded in the audience lists we share with social media platforms or trusted online advertising partners. An opt-out of cookies means you will be excluded from the information derived from cookies placed on our sites and apps by social media platforms or advertising partners. See the Personalised Marketing section for information on opting-out of personalised marketing. You can control the use of cookies via our onsite Cookie Banner or our onsite Privacy Preference centre (located at the bottom of our websites). For further information, please visit our Cookie Policy.

Please note that you may still see adverts from us online, even if you are opted-out of personalised marketing and opted-out of cookies. This type of display, non-targeted marketing is not based on any personal data held or controlled by Paddy Power. If you do not wish to see these adverts, you can control this easily by disabling preference-based marketing in the privacy and ad settings on each individual online platform, such as Facebook, Google, Bing or YouTube. Further information is provided in our Cookie Policy.

(iii) Onsite or In-App Marketing

We use our marketing audience information to provide you with personalised banner advertisements, bespoke offers and bonuses, and other forms of marketing while you are using our websites or apps. To remove yourself from such marketing audiences, you can opt-out of personalised marketing – see Personalised Marketing section for details. Some personalised banner adverts on our sites and apps are controlled separately through cookies, so you will need to adjust your cookie settings if you do not want to see them. You can control the use of cookies via our onsite Cookie Banner or our onsite Privacy Preference centre (located at the bottom of our websites). For further information, please visit our Cookie Policy

Other Marketing & Communication Information

Personalised Marketing

At Paddy Power we want to make betting and gaming better for you, so we want to be able to tell you about products, Services and features that you will find exciting and relevant, and we tailor the offers and information we send to suit you.To do this, we look at what we know about you - such as your, age, location, your interactions with our Services, the domain you arrived from if you clicked a link to our site, your betting and gaming history and patterns with us, your social media usage and how you interact with us - and we use it to build up a picture of you that helps us decide what youre most likely to want to hear about. For exle, if the majority of your bets are placed on horse racing, we will aim to primarily send you marketing material related to horse racing. We also combine this with information weve obtained from publicly or commercially available sources about the things people with similar characteristics to you (in terms of age, gender, location etc.) tend to be interested in so we can fine-tune the offers we present to you.

This data is used to build our marketing audiences, which are then used for the above targeted marketing purposes, enabling us to provide you with more personal and relevant marketing, including tailored offers and bonuses. We think this makes our marketing better both for you and for us. However, if you would prefer us not to use your profiled data to deliver personalised marketing to you, you can opt out at any time via your ‘My Account’ by opting out of Personalised Marketing. If you choose to opt out, you won’t be included in our audiences for direct marketing or for personalised online, social media or onsite marketing, and you won’t get to hear about bespoke offers and bonuses, but don’t worry – we will continue to personalise those aspects of your online experience that are not marketing related. So, for example, you will still see games you recently played. Please also note that the following activities are not impacted by an opt-out of personalised marketing:

  • We will still tailor the content of our Services to personalise your experience with us, according to what we know about you, your preferences and the way you like to play or bet. For further information on how we personalise your onsite and in-app experience, please visit the Onsite or In-App Personalisation section.
  • Some personalised banner adverts on our sites and other trusted sites and platforms are controlled separately through cookies, so you will need to adjust your cookies settings if you do not wish to see these adverts. You can control the use of cookies via our onsite Cookie Banner or our onsite Privacy Preference centre (located at the bottom of our websites). For further information, please visit our Cookie Policy
  • You may still see our adverts on other websites or social media platforms you visit, but these will not involve any sharing of your personal data with those websites or platforms and accordingly, will not be specifically targeted at you.

iOS Users

For iOS Users, every iOS device is assigned an Identifier for Advertisers (IDFA) which enables app owners and advertisers to track caigns and deliver personalised advertising. If you are an iOS user and have opted into tracking for Paddy Power, your IDFA (Identifier for Advertisers) is used to deliver you personalised advertising that is relevant to you (based on information we have about you, including browsing history, transactional information, demographic information and behavioural information, predictive information we create about you in each case in relation to our Services and advertising and information about what other people with similar interests, demographics and behaviours are looking at) and is used for attribution and analytics purposes to tell us when and how you have interacted with advertisements, including those that have been placed on a third party site or app, and so we can assess the effectiveness of our caigns. You can opt-out of this at any time by visiting your mobile settings (by going to Settings > Privacy > Advertising and turning on Limit Ad Tracking).

Promotional Content and Events


We may publish players aliases and/or chat names, along with any winnings and prizes received, on our websites in accordance with our legitimate interests. Similarly, where you attend an event that is organised or sponsored by us, we may, at our discretion, use footage recorded at such events as part of future promotional content.

Surveys and polls

If you choose to participate in a survey or poll, any personal data you provide may be used for marketing or market research purposes in accordance with our legitimate interests.

3.6.3.The purpose and legal basis for processing your personal data

Purpose

Categories of PD

Legal basis

Direct Marketing

Tailored marketing communications to you via email, SMS, post, phone or push based on the contact preferences you have selected.

Registration Information

Betting and Transactional Information

Device Information

Cookie and Tracking Information

Information derived from profiling and analysis

Safer Gambling Information (used only to prevent marketing to vulnerable individuals)

Consent

Online and Social Marketing

Advertising our Services through social media, online advertising platforms and other trusted third parties and websites across the world wide web.

Registration Information

Device Information

Cookie and Tracking Information

Information derived from profiling and analysis

Safer Gambling Information (used only to prevent marketing to vulnerable individuals)

Legitimate interests

Consent

(Where targeting is delivered using tracking technologies)

Onsite/In-App Marketing

Banner advertisements, offers and bonuses, and other forms of marketing while you are using our websites or apps

Registration Information

Device Information

Cookie and Tracking Information

Information derived from profiling and analysis

Safer Gambling Information (used only to prevent marketing to vulnerable individuals)

Legitimate interests

Consent

(Where targeting is delivered using tracking technologies)

Marketing Personalisation

Using information we hold on you to predict and offer you the type of content and offers that we believe you will enjoy.

Registration Information

Betting and Transaction Information

Device Identifiers

Cookie and Tracking Information

Betting and Transactional Information

Information derived from profiling and analysis

Safer Gambling Information (used only to prevent marketing to vulnerable individuals)

Legitimate interests

Consent

(Where targeting is delivered using tracking technologies)

Promotional Content

Publishing details of your alias and winnings, or footage from promotional events.

Registration Information

Betting and Transactional Information

Video Footage

Performance of a contract (publication of winners) Legitimate interests (events)

Surveys and Polls

Using your responses to surveys and requests for feedback to improve the Services we deliver.

Responses to Surveys and Market Research

Legitimate interests

3.6.4.Who we share your personal data with

  • Social media and online advertisers, such as Twitter, Facebook and Google.
  • Third party software providers who help us send our marketing communications (e.g. Adobe, IMI, Urban Airship, LiveR, and Moveable Ink), help us market to you onsite or in-app marketing (e.g. Playtech), help us manage data (e.g. Amazon) or help us deliver surveys and polls.
  • Third-party advertisers Where you have consented to third-party marketing or targeting cookies, data derived from the cookies placed on your device will be shared with a number of trusted third-party advertisers such as Meta, Twitter, Sportling Life, Timeform, Google, Apple and our affiliate and third party digital advertising partners networks. For more information on cookies, please see our onsite Cookie Banners, onsite Privacy Preference centre (located at the bottom of our websites) or visit our Cookie Policy
  • Other companies within the Flutter Group, primarily Betfair UK&I and Sky Betting and Gaming, who provide marketing operations support as part of the Flutter Groups UK&I division.

3.7.Fraud Prevention

3.7.1.Who the section applies to:

All customers of Paddy Power.

3.7.2.Overview

In order to protect our customers and the wider public from the harms caused by fraud, we employ a range of processes and tools to identify and prevent improper use of our Services.

These systems help us ensure that customers are genuine, havent registered more than once, and are not fraudulently trying to access accounts that dont belong to them.

Registration, Verification & Payment Process

As detailed in the Registering & Verifying Your Account, Processing Your Payments and Delivery of the Services sections above, when you set up an account with us, place bets or play our games, we carry out identity verification and fraud prevention checks. These checks help us confirm that you are old enough to use our Services and that the details you have provided are genuine.

Detection and Prevention

We review your use of the Services, including chargeback, card fraud, account takeover, and use of promotional offers and bonuses, to ensure they are in accordance with our customer Terms & Conditions.

We may share your personal data with organisations that verify details and transactions and identify potential indicators of illegal activity, which they make available to other organisations using their Services.Where necessary, we share your data with credit reference agencies or fraud prevention agencies, which keep a record of that information and make it available to other organisations for use in credit decisions, identification checks and fraud detection and prevention.

While using our Services, we monitor your activity to validate the authenticity of transactions and to ensure no fraudulent behaviours are occurring on our platform. For exle, if a login is detected from a device or location other than that normally used on your account, we may conduct a further review or request further information.

Escalations, Investigations and Restrictions

Where a suspected or actual incidence of fraud or account takeover ('ATO') has been identified or reported to us, we may apply withdrawal restrictions to your account(s) to prevent further fraudulent activity while we perform further investigations, including, where necessary, escalation to our fraud reporting teams, or we may suspend your account(s) and activity entirely. In such cases, we may request further information from you to validate the activity on your account. We may also use information such as your KYC information, device information, information sourced from third parties and publically available sources to support these investigations.

If you notice any suspicious activity in relation to your account, or wish to query or challenge a suspension or restriction on your account, please contact our Customer Operations team.

Cooperation with Regulators, Law Enforcement Agencies and similar bodies

Where required to do so, we will pass information to the police and other law enforcement agencies, regulators and other similar bodies.

Reporting and Analysis

Our fraud team perform regular reporting and analysis to identify trends in fraud activity on our Services, in order to provide the highest degree of protection to our customers. This helps ensure that our fraud prevention processes are performing as efficiently as possible.

3.7.3.The purpose and legal basis for processing your personal data

Purpose

Categories of PD

Legal basis

Detection and Prevention

Information required for analysis, reporting and prevention of fraud and financial crime. Personal data is utilised to validate the authenticity of customer transactions to ensure no fraudulent behaviours.

Registration Information

Verification and KYC InformationInteractions with Customer Operations

Payment Information

Financial Information

Betting and Transaction

Device Information

Device Information

Cookie and Tracking Information

Information derived from profilig and analysis

Credit reference agency information

Publicly available information

Legal and regulatory obligations Performance of a contract

Investigations, Escalations and Restrictions

Investigations, queries, escalations and application of restrictions in relation to account takeover and fraudulent activity.

Registration Information

Verification and KYC InformationInteractions with Customer Operations

Payment Information

Financial Information

Betting and Transaction

Device Information

Device Information

Cookie and Tracking Information

Information derived from profilig and analysis

Credit reference agency information

Publicly available information

Legal and regulatory obligations Performance of a contract

Cooperation with Regulators, Government Authorities and Law enforcement Agencies

Provide information to authorities, where required to do so.

Registration Information

Verification and KYC InformationInteractions with Customer Operations

Payment Information

Financial Information

Betting and Transaction

Device Information

Device Information

Cookie and Tracking Information

Information derived from profilig and analysis

Credit reference agency information

Publicly available information

Legal and regulatory obligations

Performance of a contract

Reporting and Analysis

Monitoring the performance and efficacy of our fraud processes and controls and trends in fraud threats

Registration Information

Verification and KYC InformationInteractions with Customer Operations

Payment Information

Financial Information

Betting and Transaction

Device Information

Device Information

Cookie and Tracking Information

Information derived from profilig and analysis

Credit reference agency information

Publicly available information

Legal and regulatory obligations Performance of a contract

3.7.4.Who we share your personal data with

  • Fraud prevention service providers
  • Regulatory Authorities and Law Enforcement Agencies
  • Third party software providers who enable us to deliver the Services to you, including our customer communication software provider (e.g. Adobe) and customer management software providers (e.g. Zendesk, SaleForce) and
  • Other companies within the Flutter Group, primarily Betfair UK&I and Sky Betting and Gaming who provide fraud prevention and management support as part of Flutter Groups UK&I division.

3.8.Safer Gambling

3.8.1.Who the section applies to

All online customers of Paddy Power.

3.8.2.Overview

At Paddy Power, our customers are at the heart of everything we do. We specifically design our products and Services with this in mind to facilitate a great customer experience, whilst also ensuring customers are protected.

Customer Monitoring and Interaction

As part of our Safer Gambling framework, we proactive monitor your activity on our sites in real time and retrospectively so as to identify potentially harmful play, and where necessary, take actions to ensure your safety onsite.

We use a combination of machine learning, automated detection systems and manual review to supervise customer activity for the purpose of identifying Safer Gambling risks, and we also have a dedicated team in Customer Operations to deal with any Safer Gambling concerns that may be flagged to us by you or other individuals connected to you, such as family or friends. Where potentially dangerous activities are flagged, we may take action. This can range from emailing or calling you to ensure you are comfortable with your level of spend to proactively closing your account for a period of time. Where we are unable to interact with you, we may need to take enforced action until such a point where we can communicate with you.

As part of these processes, we will use a range of data points taken from your behaviour and attributes to identify potentially problematic activity. We use elements of profiling and automated analysis techniques to identify such activity and to apply account limitations as and where appropriate. This is in accordance with our licensing requirements to conduct pro-active engagements to prevent gambling harm.

You can get in touch with our Customer Operations team at any stage if you have concerns about your gambling, concerns about another customer's gambling or if you wish to challenge any restrictions that have been placed on your account, including those that may have been applied as a result of our automated Safer Gambling processes. All Safer Gamling related matters are dealt with by a dedicated Safer Gambling team with our Customer Operations units. Please see the Contacting Customer Operations section above for information on how we use your data in this regard.

Requesting Supporting Information

While using our Services, you may be asked for additional information about yourself or the source of your account funding from our Safer Gambling team. This process assists us to ensure that we can get to know you and provide you with a safe customer experience, as well as helping us fulfil our licencing requirements.

We may ask for supporting evidence where a request is made to challenge Spend Limits (limits applied by us to cap the maximum spend on some accounts for certain customers), Global Deposit Limits (limits placed by us to cap the maximum amount that can be spent on all customer accounts) and as part of our standard Enhanced Due Diligence ('EDD') processes. Documents that may be requested include, but are not limited to proof of identity, proof of earnings, bank statements and evidence of business ownership. If You are unable to provide any of these documents, then we may suspend or restrict your account until you provide the requested information.

Vulnerability

If any specific vulnerabilities are identified throughout our standard interaction process, we may take extra steps to enhance protection for our customers. We will seek consent before we take such steps, and if obtained, we will ask the appropriate questions necessary to understand any vulnerabilities and impacts. Reasonable adjustments and protections may be agreed with you, to help best protect you from any potential harm caused by your specific vulnerabilities.

Such processing will always be performed with the highest regard to the privacy and security of your data, Any vulnerability assessment will be subject to customers consent. Customers will be clearly and specifically informed of the process and will have the choice to provide freely given consent. Customers may also withdraw any given consent at any time. If consent is obtained, the personal data will only be retained for as long as is necessary to meet our legal, regulatory or legitimate business requirements, or until such time as you withdraw your consent.

Customers are also free to withhold consent, at which point the assessment will not go ahead. However, in the event that specific vulnerabilities may fall under a wider scope within Safer Gambling concerns, the business may restrict your account. In other words, where consent is withheld but we still have Safer Gambling concerns, we may restrict your account.

Exclusions

Paddy Power offers you the facility to'Self-Exclude' from us as part of our Safer Gambling control tools. This feature allows you to block yourself from all or part of our Services for varying periods of time depending on your needs.

In certain circumstances, our staff may also make the decision to pro-actively exclude you from our Services, in order to ensure your safety.

Where you apply a Self-Exclusion with Paddy Power or where we decide to exclude you from our Services for Safer Gambling reasons, we will also share your exclusion information with the other Flutter Group brands that operate in the UK - Betfair UK&I, Sky Betting and Gaming and PokerStars .This action is performed by automatically checking whether accounts with your registered details are held on these other brands, and, where accounts are identified, they will be proactively closed. Such processing will always be performed with the highest regard to the privacy and security of your data, and you have the right to challenge if you wish to dispute the match. For further information, please visit our Safer Gambling Hub.

NB: Please note that in circumstances where you apply a permanent Self-Exclusion, your information will be retained indefinitely, in order to prevent you from accessing the Services.

GamStop

Upon registration, login and at regular intervals we perform checks against the database of the UK's national self-exclusion scheme, 'GamStop. Where a UK customer self-excludes through the GamStop scheme, our checks will pick this up and we use this to ensure their wish to self-exclude is applied across our sites and apps. To find out more, you can visit the GamStop website at https://www.gamstop.co.uk/ . We may in future subscribe to similar national self-exclusion schemes in any of the countries in which we operate, and we will update this Statement to let you know.

Grotect

Grotect is a trial project to ensure that people who display high-risk behaviours are protected from gambling related harm to their health. To do this, participating operators (which include Paddy Power and Betfair UK&I from the Flutter Group) that provide online gambling products will take steps to identify customers who they believe should not be gambling and share some key customer information with the Grotect system. Participating operators are the joint data controllers of the initiative and will use Grotect to identify whether the same customer has an account with them and proceed to close their account to reduce the potential for harm. For more information, please visit the full privacy statement on the Grotect website: https://www.grotect.co.uk/privacy

3.8.3.The purpose and legal basis for processing your personal data

Purpose

Categories of PD

Legal basis

SG Monitoring and Interactions

Manual and automated monitoring of customer activity to prevent potentially problematic play.

Proactive communications with you to ensure you are comfortable with current activity levels, and to make any required adjustments to your account.

Managing inbound contacts to our Customer Operations team in relation to safer gambling.

Registration Information

Verification and KYC Information

Betting and Transactional Information

Information derived from profiling and analysis

Customer Operations Interactions

Safer Gambling Information

Posts, Comments and Messages

Special Category Data

Information from family, friends or contacts

Legal and regulatory obligations

Performance of a contract

For Special Category Data, consent and, in limited circumstances, vital interests or public interests.

Requesting Supporting Information

We may ask for supporting information to help keep you safe and for evidence where a request is made to challenge spend or deposit limits applied by us or as part of our standard Customer Due Diligence processes.

Registration Information

Verification and KYC Information

Betting and Transactional Information

Customer Operations Interactions

Safer Gambling Information

Legal and regulatory obligations

Performance of a contract

Vulnerability:

We take extra steps to enhance protection for our customers with specific vulnerabilities. Reasonable adjustments and protections may then be agreed with the customer, or, in some circumstances, restrictions may be placed on the account by us.

Registration Information

Verification and KYC Information

Betting and Transactional Information

Customer Operations Interactions

Safer Gambling Information

Special Category Data

Legal and regulatory obligations

For Special Category Data, consent and, in limited circumstances, vital interests or public interests.

Exclusions:

Processing your data to ensure that you cannot access our Services where you elect to exclude from your account, or where an exclusion is proactively applied.

Registration Information

Verification and KYC Information

Betting and Transactional Information

Customer Operations Interactions

Safer Gambling Information

Special Category Data

Legal and regulatory obligations

Performance of a contract

For Special Category Data, consent and, in limited circumstances, vital interests or public interests.

GamStop:

Checks against the the GamStop UK national self-exclusion scheme database, and, where a customer has self-excluded through GamStop, use of that data to ensure their wish to self-exclude is applied across our sites and apps.

Registration Information

Betting and Transactional Information

Safer Gambling Information

Legal and regulatory obligations

Performance of a contract

Grotect:

A trial initiative between operators in the gambling industry to ensure that people who display high-risk behaviours are protected from gambling related harm to their health.

Registration Information

Safer Gambling Information

Special Category Data

Legitimate interests

For Special Category Data, public interests.

3.8.4.Who we share your personal data with

  • Trusted third party verification suppliers, such as TransUnion and GB Group, who we share data with as part of our Safer Gambling controls
  • Third party software providers who enable us to deliver the Services to you, including our customer communication software provider (e.g. Adobe, LivePerson) and customer management software providers (e.g. Zendesk, SalesForce) and
  • Other members of the Flutter Group, including Betfair UK&I and Sky Betting and Gaming who provide Paddy Power with Safer Gambling support, as part of the Flutter Groups UK&I division, and with Flutter Group members who operate in the UK where you apply a Self-Exclusion or we apply a Safer Gambling related exclusion to a Paddy Power account registered in the UK, British Crown Dependencies or Gibraltar
  • Other participating operators in Grotect, where you have been identified as a customer at risk of health-related problem gambling
  • Law enforcement and regulatory bodies, as required per our legal or regulatory obligations
  • In rare circumstances where there is a threat to life, we may act in order to protect an individuals vital interests and share personal data, including special category data, with the police

3.9.Anti-Money Laundering and Counter-Terrorist Financing

3.9.1.Who the section applies to

All customers of Paddy Power.

3.9.2.Overview

As a betting and gaming company we have certain legal obligationswe need to abide by.One set of such obligations requires that we do everything we can to prevent money laundering and crime. At Paddy Power , and in accordance with the terms and conditions of our Services, we will use your personal data to ensure the proceeds of crime are not being used by individuals using our Services, and to identify and tackle such behaviours.

KYC

We are required to gather certain information about you in order to verify your identity, as part of our KYC requirements. For this purpose you may be required to submit documentation establishing your identity and address, and where required, any other information as may be deemed necessary to confirm your identity. These processes are explained in more detail in the Electronic Verification and Document Verification within the Registering & Verifying Your Account section .

Enhanced Due Diligence

In order to meet requirements under applicable legislation, Paddy Power adopts a risk-based approach to compliance with its Anti-Money Laundering obligations, and, depending on your personal characteristics and activity levels, we may be required to gather further information on you. We may collect and store financial information in relation to you, as well as information gathered from publicly available sources (as explained in the Data from other sources section of this Statement). such as the land registry, publicly available company information and social media. We analyse this data, together with existing data we hold on you, to identify any potential risks of criminal activity.

Source of Wealth

In certain circumstances, we may require you to provide additional documents proving your source of wealth and/or source of funds including but not limited to proof of earnings, bank statements, payslips and evidence of business ownership. Such processing will always be conducted with due regard to your privacy.

Screening

As part of our obligations, we also regularly screen our customer base against databases of publically available information. This ensures that we are not offering our Services to individuals who have been the subject of sanctions, and allows us to identify individuals who are 'Politically Exposed Persons.'

Investigations and Taking Action

Where suspicious activities, behaviours or characteristics are identified, further investigation will be conducted, and where necessary, restrictive actions may be taken. Note that in certain circumstances where action has been taken on a customers account as a result of suspicious activities, we may need to retain data relating to those actions in order to prevent that customer from using our Services again.

3.9.3.The purpose and legal basis for processing your personal data

Purpose

Categories of PD

Legal basis

KYC

Verfiying your identity upon registration using documentation you submit

Registration Information

Verification and KYC Information

Publicly Available Information

Legal and regulatory obligations

Performance of a contract

Enhanced Due Diligence

Gathering further information on you and your financial background where higher levels of risk are identified.

Registration Information

Verification and KYC Information

Financial Information

Betting and Transactional Information

Publically Available Information

Information derived from profiling and analysis

Legal and regulatory obligations

Performance of a contract

Source of Wealth

Collecting information from you evidencing the source of funds used on our site

Financial Information

Registration Information

Verification and KYC Information

Legal and regulatory obligations

Performance of a contract

Screening

Comparing our customer database against publically available lists of individuals with sanctions or adverse media reports, and to identify politically exposed persons

Registration Information

Verification and KYC Information

Publically Available Information

Legal and regulatory obligations

Performance of a contract

Investigations and Taking Action

Investigating potential instances of money laundering, and where necessary, taking appropriate actions

Registration Information

Verification and KYC Information

Financial Information

Betting and Transactional Information

Information derived from profiling and analysis

Publically Available Information

Legal and regulatory obligations

Performance of a contract

3.9.4.Who we share your personal data with

  • Providers of databases, such as WorldCheck, and trusted third parties who assist with the screening those databases, such as Finscan
  • Third-parties who assist with KYC and ongoing due diligence, such as GB Group and TransUnion
  • Third party software providers who enable us to deliver the Services to you, including our customer communication software provider (e.g. Adobe) and customer management software providers (e.g. Zendesk, SaleForce) and
  • Other companies within the Flutter Group, primarily Betfair UK&I, Sky Betting and Gaming and PokerStars who provide Anti-Money Laundering support as part of the Flutter Groups UK&I division operations. We may also share information with the Flutter Group in order to help prevent fraud, money laundering and other criminal activity across our wider group.
  • Where appropriate, information may be passed to the police and other law enforcement agencies, and other similar bodies.

3.10.Integrity

3.10.1.Who the section applies to

All customers of Paddy Power.

3.10.2.Overview

Integrity monitoring and investigations

We are committed to helping to maintain the integrity of and prevent corruption or circumvention of rules or laws within the sports and other markets for which it offers our Services.

For these purposes, we routinely monitor customer activity onsite in order to identify unusual or suspicious activity and betting patterns. Where we identify such activity, we may also use your personal data including, but not limited to, your registration details, betting records, records of payments, device information and publically available information, to determine whether there are grounds for establishing whether an infringement has occurred.

Sharing information with relevant bodies

Your personal data may be disclosed, upon request or based on our own initiative, to any regulatory body, law enforcement body or sporting body (with whom the Group has agreements (Memoranda of Understanding or "MOUs") for the sharing of such data). This sharing may be in connection with

  • policing the integrity or enforcing the rules of a sport or game
  • prevention and detection of crime
  • where we consider that there are reasonable grounds to suspect that you may be involved in a breach of such rules or the law, have knowledge of a breach of such rules or the law or otherwise pose a threat to the integrity of the relevant sport or game based upon our assessment of your betting behaviours or information provided to us by a regulatory or sporting body.

Those bodies may then use your personal data to investigate and act on any such breaches in accordance with their procedures.

3.10.3.The purpose and legal basis for processing your personal data

Purpose

Categories of PD

Legal basis

Integrity Monitoring and Investigations

Monitoring and analysing onsite activity to identify and investigate breaches of the rules of any sport or game, or any law.

Registration Information

Verification and KYC Information

Payment Information

Financial Information

Betting and Transaction Information

Device Information

Publically Available Information

Legal and regulatory obligations

Performance of a contract

Sharing Information with relevant bodies

Providing information on request, or on our own initiative, to sports governing bodies, regulatory bodies or law enforcement authorities, where there are reasonable grounds to suspect a breach of the rules or a sport or game, or any relevant law

Registration Information

Verification and KYC Information

Payment Information

Financial Information

Betting and Transaction Information

Device Information

Publically Available Information

Legal and regulatory obligations

Performance of a contract

3.10.4.Who we share your personal data with

  • Sports governing bodies, regulatory bodies or law enforcement authorities involved in policing the integrity of sport or markets upon which our Services are based and provided.
  • Other companies within the Flutter Group, primarily Betfair UK&I and Sky Betting and Gaming who provide Integrity management support as part of the Flutter Groups UK&I division. We may also share information with the Flutter Group as part of specific integrity investigations across our wider group.

3.11.Other Purposes

3.11.1.Who the section applies to

All individuals who engage with Paddy Power or use its Services.

3.11.2.Overview

In addition to the purposes we described above, there are other circumstances in which we are required to process your personal data, as described below:

Information/Disclosure Requests and Regulatory Submissions

Apart from the functions set out in this Statement, we do not share your personal data with third parties except where we are compelled or permitted by law to do so. These circumstances are rare but may require us to share information in response to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include such authorities outside your country of residence.

Whenever we share personal data, and whatever the circumstances, we will always do so legally and with due regard to your privacy. If we receive a request from law enforcement or other statutory bodies, we do not disclose personal data without a warrant, court order or other legally valid proof of authority.

Protecting and defending our rights and interests


We will process your personal data where necessary to protect or defend our rights and interests, defend against legal claims, resolve disputes, respond to what we consider to be incorrect or misleading information provided to a media outlet, or enforce our agreements. For these purposes, we reserve the right to share personal data with regulators, external legal advisors, debt recovery and tracing agencies, and media outlets, although again these circumstances are rare.

Information Security and Loss Prevention

We are required to use personal data as part of our information security practices. These practices are deployed to protect ours and stakeholders rights, information, privacy, safety, or property, in accordance with our legal obligations (for exle, we are legally obliged under data protection law to secure and protect the personal data of customers, employees and all other individuals whose personal data we use) and with the performance of contracts in place with stakeholders (for exle, to ensure the security of the Services we provide to you per the terms and conditions in place with you).

Restructuring

If ownership of all or part of our business changes or we undergo a reorganisation or restructure, we will transfer your personal data to the new owner or successor company so we or they can continue to provide the Services you have requested.

Financial Reporting and Analysis

In accordance with our obligations under company law and other similar regulations we are required to keep a record of your transactions in order to maintain proper financial records to meet and to ensure all transactions are being performed in accordance with the Terms and Conditions of our Services.

3.11.3.The purpose and legal basis for processing your personal data

Purpose

Categories of PD

Legal basis

Information/Disclosure Requests and Regulatory Submissions

Responding to valid requests from courts, law enforcement agencies, regulatory agencies, auditors, and other public and government authorities, or submitting information to regulatory agencies.

Any personal data held, as required to meet the purpose

Legal and regulatory obligations

Performance of a contract

Protecting and defending our rights and interest

To protect or defend our rights and interests, defend against legal claims, resolve disputes, respond to what we consider to be incorrect or misleading information provided to a media outlet, or enforce our agreements.

Any personal data held, as required to meet the purpose

Legitimate interests

Legal and regulatory obligations

Performance of a contract

Information Security and Loss Prevention

Protecting our rights, privacy, safety, or property, or those of our stakeholders

Registration Information

Betting and Transactional Information

Device Information

Correspondence with Customer Operations

Performance of a contract

Legal and regulatory obligations

Restructuring

Transferring your personal data to the new owner or successor company so we or they can continue to provide the Services you have requested.

All personal data held

Performance of a contract

Financial Reporting and Analysis

Maintaining financial records in accordance with company law and ensuring transactions are performed in line with the Services T&Cs.

Registration Information

Betting and Transactional Information

Legal and regulatory obligations

Performance of a contract

3.11.4.Who we share your personal data with

  • Courts, law enforcement agencies, regulatory agencies, and other public and government authorities.
  • News and media outlets.
  • Other companies within the Flutter Group, including Betfair UKI and Sky Betting and Gaming who provide support services as part of the Flutter Groups UK&I division and other brands as may be required to fulfil the purposes detailed in this section.
  • If ownership of all or part of our business changes or we undergo a reorganisation or restructure, we may transfer your personal data to the new owner or successor company so we or they can continue to provide the Services you have requested.

4. GENERAL PROCESSING INFORMATION

This section provides you with some other important information you need to be aware of in relation to how we use your personal data, including information on how we share your personal data with the Flutter Group, international transfers of your personal data, how we keep your personal data secure and how long we need to keep your personal data for. Click any of the topics below for more details.

4.1.Group sharing


As explained in the About the Flutter Group section above, Paddy Power is part of the wider Flutter Group and sits within the UK&I division.

We have explicitly called out a number of specific situations in this Privacy Statement where the FlutterGroup companies may use your information, including where Betfair UK&I and/or Sky Betting and Gaming are providing support to Paddy Power as part of the UK&I divisions operations and to other Flutter Group members for marketing purposes, customer services purposes, the prevention of crime, helping to reduce gambling related harm, the provision of betting and gaming services, and to meet legal and regulatory obligations.

Additionally, we may share personal data with the Flutter Group as part of our group internal reporting and assurance .in order to facilitate business efficiency and improvements including, but not limited to research across our group, testing of systems and/or suppliers, risk management, the provision of technology, finance or security support, and the development of new products and tools.

We may also in the future share personal data with other members of the Flutter Group for purposes that are related to and compatible with those set out in this Statement. Finally, where we are required by law or regulation to share personal data to members of the Flutter Group for reasons beyond those set out in this Statement, we will be required to do this.

4.2.International transfers

Some of the third-party providers we use, as well as companies within the Flutter Group, are based in, or carry out their activities in, countries outside the European Economic Area ('EEA) and/or outside the UK.

Countries outside the EEA and UK do not always have strong data protection laws. This means that, unless your personal data is being transferred to a country where the European Commission or UK has determined there to be an adequate level of protection, we have to put in place additional protections to ensure that your personal data is protected to the same level as it is within Europe or the UK.

We put these additional protections in place by using standardised contractual clauses that have been approved by the European Commission (for transfers outside the EEA) and the Information Commissioners Office (for transfers outside the UK). Where necessary, we also put in place any additional contractual measures required by local law in any of the countries in which we operate. As and when required, we will also put additional technical or organisational measures in place to ensure that your data is kept safe.

4.3.Keeping your personal data secure

We recognise that online security and data protection is an area of vital importance for all our customers, so it is important to us that you have confidence in the security of your personal details before you register an account. We are committed to employing security measures to protect your information from access by unauthorised persons and to prevent accidental or unlawful processing, disclosure, destruction, loss, alteration and damage. Our technological security solutions are very advanced and are governed by a mature framework. Our approach is focused on preventing risks. In order to help us in this regard, we employ pseudonymisation and encryption whenever possible to reduce the impact of any potential incidents. As the security of some communications via the internet is not completely secure, we cannot guarantee the security of any information that you disclose using your internet connection. You accept the inherent security implications of using the internet and the Group will accept no liability for any direct, consequential, incidental, indirect, or punitive losses or damages arising out of such an occurrence.

4.4.How long we keep your personal data for

A key principle of data protection is 'storage limitation, which means that organisations should only hold onto your personal data for as long as is needed.

At Paddy Power, we have taken steps to ensure that we hold your personal data only as long as we have a valid legal basis or reason to do so, which includes providing you with the Services you have requested, meeting our legal and regulatory obligations, resolving disputes and enforcing our agreements.

The length of time for which we keep different types of personal data can vary, depending on why we originally obtained them, the reason we process them and the legal requirements that apply to them. When setting our data retention and deletion timescales we take into account a range of factors including applicable regulations and standards relating to gambling and gaming, anti-money laundering, taxation, payment processing and complaint handling, the need to prevent or detect crime or other misuses of our Services, and audit requirements.

To fulfil our requirements, some of your personal data will need to be retained for a period of time after you cease to be a customer. When we no longer need it to fulfil the purposes and legal bases set out in this Statement, we delete it securely. Subject to us not having a legal or regulatory requirement or a risk management reason for retaining your information for a longer period, your information will not be kept for longer than 7 years from your last login or expiry of a self-exclusion. This allows us to meet our record-keeping obligations in applicable legislation, as well as allowing us to defend ourselves against potential legal claims.

Please note that if you opt to apply an exclusion to your account, your data will be retained for the period of that exclusion, plus a further seven years from the date of the expiry of that exclusion.

In certain circumstances we may be required to retain your information indefinitely. For exle, where you elect to permanently exclude yourself from accessing our Services under our procedures on safer gambling, we are obliged to retain your data indefinitely to prevent you from creating new accounts.

We will take all necessary steps to ensure that the privacy of information is maintained for the period of retention. Where we wish to retain any information for analysis purposes, we first anonymise in accordance with the standards set by our relevant data protection regulators so that it can no longer be linked back to an individual.

5. YOUR DATA SUBJECT RIGHTS

Under data protection law, you have a number of rights which are detailed below. We want to be clear about what those rights mean in practice and how you can exercise them. Please note that some of these rights only apply in specific circumstances and are qualified in several respects by exemptions in Data Protection legislation. We will advise you in our response to your request if we are relying on any such exemptions.

To exercise any of the rights below, you can contact us at subjectrights@paddypower.com .

For any other queries related to your personal data, please feel free to contact us at dataprotection@paddypowerbetfair.com .

5.1.Access

You have a right to request a copy of the personal data that we hold about you. Should you wish to make such a request, you should submit a request to subjectrights@paddypower.com.

You will be asked to provide adequate information to identify yourself such as a copy of your photographic identification (ID Card, Driving License or Passport) and any other relevant information such as your account username and email address that will assist us in fulfilling your request.

We may also ask you to complete and return a form, which is not compulsory but helps us to help you by providing the information you are looking for.

Where you request a copy of your personal data, you will be provided with:

  • Your personal details that you provided to us upon registration
  • A copy of all deposits and transactions
  • A copy of your interactions with Customer Operations (including chats, emails, calls, complaints and notes)
  • Information on the safer gambling self-help tools that you have used (if any)
  • Marketing and opt-out information
  • A data processing summary.

If there is additional information that you believe we hold on you, please let us know and we will gladly investigate further.

We will fulfil requests wherever possible, but there are occasional situations in which the law requires or permits us to withhold some information (such as where it would involve disclosing information about another person or information which is commercially sensitive), If either of these applies, we will explain this to you.

We will provide our response within one month however if your request is unusually complex and likely to take longer than a month, we will inform you of this and how long the request will take to complete.

5.2.Rectification

You can request us to rectify and correct any personal data that we are processing about you that you believe is incorrect. To make things easier, we provide you with account settings and tools to access the information associated with your account.

You can update your personal details at any time by visiting your 'My Account' section when you log in.

If it is something you cannot correct yourself online, such as your name or date of birth (which, for identity verification, account security and fraud prevention reasons, cannot be changed using self-service methods), you should contact our Customer Operations team here . Alternatively, please email subjectrights@paddypower.com .

We'll update inaccuracies promptly, and within a month if you are requesting a more complex change.If we take the decision not to make a change you have requested, we will explain why and make a note on your account to show that you requested the change.If you disagree with our decision, you have the right to complain to the regulator.

5.3.Erasure, or Right to be Forgotten

You have the right to request us to erase your personal data where we have no compelling reasons to continue storing or processing your data, and specifically, where one of the following grounds applies:

  • Where the courts or our regulators have found us to be processing it unlawfully
  • Where our original purpose for collecting the data has been completed and we have no other valid legal grounds for continuing to hold it
  • Where you have withdrawn your consentfor processingand asked us to delete the information we previously used for those purposes or
  • Where you have successfully exercised your right to object and there are no overriding legitimate grounds to continue processing.

Please note this right only applies in certain circumstances, it is not a guaranteed or absolute right. Personal data on our customers is retained for as long as is reasonably required for our legitimate legal purposes. These include, but are not limited to

  • Anti-Money Laundering/Counter-Terrorist Financing
  • Defence of legal claims
  • Safer Gambling
  • Taxation

As is outlined in the How long we keep your personal data for section we have legal obligations and other lawful reasons to retain your data after your account is inactive. Generally, your data will be retained for a period of 7 years, so, if you request your data to be erased during this time, we may not be able to uphold your request.

If you still wish to exercise your right, you should contact us on subjectrights@paddypower.com . Alternatively, please contact our Customer Operations team here .

We will respond to your request within a month, and if we uphold your request and erase your data we will also notify any third parties to which the data has been passed, where we are able to do so, and tell you who they are. If we do not uphold your request, we will tell you why. If you disagree, you have the right to complain to the regulator.

5.4.Restriction

You have the right in certain circumstances to request that we suspend our processing of your personal data, where one of the following grounds applies:

  • The accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of the personal data
  • The processing is unlawful, and you oppose the erasure of the personal data and requests the restriction of their use instead
  • We no longer need your personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims or
  • You have objected to processing that we perform on the basis of our legitimate interests, and we are verifying whether our legitimate grounds override yours as a data subject

Where we suspend our processing of your personal data, we will still be permitted to store your personal data, but any other processing of this information will require your consent, subject to certain exemptions.

Where you have obtained the restriction of processing you will be informed by us before the restriction of processing is lifted.

In order to make a request for the restriction of your processing, please contact us on subjectrights@paddypower.com. Alternatively, please contact our Customer Operations team here .

You will receive a response within one month.

5.5.Portability

The right of portability allows you to re-use some of your personal data online by making it available in a commonly-used, machine-readable format that can be passed to and used by other organisations. This right applies to data that you have provided to us with your consent, or which was necessary for us to provide you with our products and Services.

You may also have the right to have your personal data transferred by us directly to the other organisation if this is technically feasible.

This is a new initiative, and it is not yet possible to 'port data directly between providers in the betting and gaming industry. If you wish to exercise this right, you should submit your requestto subjectrights@paddypower.com. Alternatively, please contact our Customer Operations team here and we will provide you with the following information as a CSV file:

    How long we keep your personal data for/ul>
  • the personal and contact details held in your online account
  • your betting and gaming history
  • A list of payments made and funds withdrawn

Before responding to your request, we will ask you to provide valid proof of identity, and we will provide our response within one month of receiving it.

In future, it may become possible to transfer (or 'port) data directly between organisations. In the meanwhile, if you would like to take your data to another provider you should first check that your chosen provider is able to upload data from a CSV file before making your request as above and passing the file to the provider yourself.

5.6.Object

You have the right to object to our use of your personal data which is processed on the basis of our legitimate interests. However, we may continue to process your personal data, despite your objection, where there are compelling legitimate grounds to do so or where we need to process your personal data in connection with any legal claims.

To exercise your right to object please contact us on subjectrights@paddypower.com Alternatively, please contact our Customer Operations team here

We will respond to you within one month. If we refuse to uphold your request and disagree with our decision on this, you have the right to complain to the regulator.

You also have the right to opt-out of having your information used to createa 'profile of you for marketing purposes. You may exercise this right by opting out via your 'My Account.

5.7.Rights relating to automated-decision-making and profiling

You have the right not to be subject to a decision which is based solely on automated processing (without human involvement) where that decision produces a legal effect or has a similarly significant affect on you. This right does not apply where you have provided your explicit consent for us to use your data in this way, where the decisions are needed to enter or perform a contract with us (for exle, the terms and conditions of our Services), or where the decision is needed to meet our legal or regulatory obligations.

Where the decisions are made based on your explicit consent, or they are needed to enter or perform a contract with us, you have the right to request human involvement in the decision, to express your point of view or to contest the decision made.

If you have any concerns in relation to automated processing that we may perform you can contact us at any time.

5.8.Rights to complain to the regulator

If you believe your data protection or privacy rights have been infringed, or you disagree with a decision we have made about your data protection or privacy rights, you have the right to complain to the data protection regulator.

If you are based in the UK, you should contact the Information Commissioners Office, but if you are based in Ireland, you should contact the Data Protection Commissioner. For your convenience, we have provided their contact details below:

Published on 04/16/2018