Definitions and interpretation
Data collectively all information that you submit to Startz Ltd via the Website. This definition incorporates, where applicable, the definitions provided in the General Data Protection Regulation 2018 (GDPR);
Cookies a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below (Cookies);
DPA 2018 The Data Protection Act 2018 as amended from time to time
or ‘us’, ‘we’ etc Startz Ltd, (of which Carpy.UK is a trading name), is a company incorporated in England with registered number 12478049 whose registered office is at 3 Stucley Place, LONDON, NW1 8NS;
UK and EU Cookie
Law the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011;
User or you any third party that accesses the Website and is not either (i) employed by Startz Ltd and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Startz Ltd and accessing the Website in connection with the provision of such services; and
Website the website that you are currently using, Carpy.UK, and any sub-domains of this site unless expressly excluded by their own terms and conditions.
a. the singular includes the plural and vice versa;
c. a reference to a person includes firms, companies, government entities, trusts and partnerships;
d. "including" is understood to mean "including without limitation";
e. reference to any statutory provision includes any modification or amendment of it;
4. We collect personal Data directly from you via our websites or via other communications between us when you make enquiries with us or engage with our services or place a bet with us. We may collect the following Data, which includes personal Data, from you:
a) Your personal details, such as your name, email address, postal address, telephone or mobile number, gender or date of birth;
b) Photographic identification and proof of address documents (to carry out due diligence)
c) Banking and financial details (to establish the source of funds where a transaction is involved)
d) Your account login details, such as your username and password (it is your responsibility to keep these safe).
6. We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Our use of Data
7. For the purposes of GDPR 2018 and the DPA 2018, Startz Ltd is the " controller" of Data. This means that, under the DPA 2018 and the GDPR 2018, we may control and process your personal data.
8. We will only retain your Data for only so long as is needed in accordance with our retention policy. Ordinarily, this is six years, unless you consent to receive marketing materials, in
which case we shall retain your Personal Data until such a time as the business ceases to operate, or you withdraw your consent to be contacted.
9. Unless we are obliged or permitted by law to do so, and subject to any third party disclosures specifically set out in this policy, your Data will not be disclosed to third parties, save for the purposes and on the occasions identified in this policy.
10. All personal Data is stored securely in accordance with the principles of the GDPR. For more details on security see the clause below (Security).
Our Obligations to You
11. As the ‘controller’ of your personal information, we will ensure that the personal information we hold about you is:
a) used lawfully, fairly and in a transparent way;
b) collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
c) relevant to the purposes we have told you about and limited only to those purposes;
d) accurate and kept up to date.
e) kept only as long as necessary for the purposes we have told you about.
f) kept securely.
Legal basis for Use of your Data
12. We can only process your personal information where we have a legal right to do so under the DPA 2018 or the GDPR 2018. Generally, we rely on the following grounds:
· Article 6(1)(a) – processing is conducted with your consent to process personal data for specified purposes
· Article 6(1)(b) – processing is necessary for the performance of our contract to provide services to you, or for preparing to enter into such a contract with you
· Article 6(1)(c) – processing is necessary for us to demonstrate compliance with the law
· Article 6(1)(f) – to process your personal data in pursuit of our legitimate interests
13. Below, we have set out the primary reasons why your Data is processed by us and the legal basis for doing so. There may circumstances where another legal basis for processing data may also apply to the reason for processing:
No. Reasons for Processing Legal Basis
1 Internal record keeping Legitimate interests
2 Improvement of our products / services Legitimate interests
3 transmission by email of promotional materials that may be of interest to you Consent
4 contact for market research purposes which may be done using email, telephone, fax or mail. Such information may be used to customise or update the Website Consent
6 to deter, prevent, or detect any activities conducted in breach of the Startz Ltd T&Cs. Legitimate interests
7 to make sure we offer our services to eligible persons Legal obligation
8 crime detection, prevention, and prosecution Legitimate interests
9 to verify your identity and establish the source of funding in any transaction As part of our contract with you
10 to carry out appropriate anti-fraud checks (by conducting online searches using a third-party identity provider). Please note that this will not affect your credit rating As part of our contract with you
Third party websites and services
14. Startz Ltd may, from time to time, employ the services of other parties for dealing with certain processes necessary for the operation of the Website. The providers of such services do not have access to certain personal Data provided by Users of this Website.
Links to other websites
Changes of business ownership and control
16. Startz Ltd may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Startz Ltd. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the
17. We may also disclose Data to a prospective purchaser of our business or any part of it.
18. In the above instances, we will take steps with the aim of ensuring your privacy is protected.
19. Startz Ltd has a policy of ‘privacy by design’, and your data will not be used for the purposes of direct marketing, unless you specifically request to receive such materials. Startz Ltd will not share your data with third parties without specific consent from you for marketing purposes. We will not contact you for the purposes of direct marketing unless you have asked us to do so. However, if you have asked us to do so and later your change your mind, you can opt-out at any time with no hassle. To do this, just let us know. See further 'Your rights' below for details about how to contact us.
Transferring your information outside of Europe
20. We may store your data temporarily on our cloud service operated by Amazon. We have taken appropriate steps to satisfy ourselves that your data will be secure during this process; we have a contractual relationship with Amazon that underpins this. As part of that security, Amazon may store your data in one or more or its international data centres, meaning that your data may be stored temporarily outside of the European Economic Area. If you have any concerns about this, please contact us using the details below.
Sharing Data with Third Parties
21. We will only share your data with third parties if you have given express consent for us to do so or there is a legal basis for doing so. In certain circumstances, it may be in our legitimate interests to pass your Data to a third party for certain limited reasons. This may include:
· Our website provider to enable us and them to deliver their service to us, carry out analysis and research on demographics, interests and behaviour of our users and supporters to help us gain a better understanding of them to enable us to improve our services. This may include connecting data we receive from you on the website to data available from other sources. Your personally identifiable data will only be used where it is necessary for the analysis required, and where your interests for privacy are not deemed to outweigh their legitimate interests in developing new services for us.
· Our professional advisors and agents for the purposes of advising and representing us in any matter connected with your account or your use of the Website upon which we legitimately consider that advice or representation is needed.
· We share transaction data with our payment services providers, but only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds
· Credit reference agencies. To enable us to make decisions about you and for fraud prevention and money laundering purposes, we (or our agents) may search the files of credit reference and fraud prevention agencies (who will record the search). We may disclose information about how you conduct your account to such agencies and your information may be linked to records relating to other people living at the same address with whom you are financially linked. Other credit grantors may use this information to make credit decisions about you and the people with whom you are financially associated, as well as for fraud prevention, debtor tracing and money laundering purposes. If you provide false or inaccurate information and we suspect fraud, we will record this.
Functionality of the Website
22. To use all features and functions available on the Website, you may be required to submit certain Data.
24. You have the right to ask for a copy of any of your personal Data held by Startz Ltd (where such Data is held), as is your right to access under GDPR. There will be no charge for this provision (except where requests are repetitious or unreasonable), and we will provide the data within 30 days of receipt of your request.
· Any requests for Access or restriction must be made in writing to the Data Protection Officer through our postal address,
25. You have various rights under the Act and the GDPR 2018 and the DPA 2018, including the following rights:
· Right to object: If we are using your data because we deem it necessary for our legitimate interests to do so, and you do not agree, you have the right to object. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases). Generally, we will only disagree with you if certain limited conditions apply.
· Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example, providing you with services), or consent to market to you, you may withdraw your consent at any time.
· Data Subject Access Requests (DSAR): Just so it's clear, you have the right to ask us to confirm what information we hold about you at any time, and you may ask us to
modify, update or delete such information. At this point we may comply with your request or, additionally do one of the following:
- we may ask you to verify your identity, or ask for more information about your request; and
- where we are legally permitted to do so, we may decline your request, but we will explain why if we do so.
· Right to erasure: In certain situations (for example, where we have processed your data unlawfully), you have the right to request us to "erase" your personal data. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases) and will only disagree with you if certain limited conditions apply.
· Right of data portability: If you wish, you have the right to transfer your data from us to another data controller. We will help with this – either by directly transferring your data for you, or by providing you with a copy in a commonly used machine-readable format.
· Right to lodge a complaint with a supervisory authority: You also have the right to lodge a complaint with your local supervisory authority, details of which can be found below.
· Any requests for Access, or to exercise any other right in connection with your Data, must be made in writing to the Data Protection Officer through our postal address,
26. We may ask you to provide us with proof or your identity. Please do not be offended; this may occur even if we know you. It is a requirement of the GDPR in some cases.
27. Data security is of great importance to Startz Ltd and to protect your Data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure Data collected via this Website.
28. If password access is required for certain parts of the Website, you are responsible for keeping this password confidential.
29. We endeavour to do our best to protect your personal Data. However, transmission of information over the internet is not entirely secure and is done at your own risk. We cannot ensure the security of your Data transmitted to the Website.
31. All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.
32. Before the Website places Cookies on your computer, you will be presented with a pop-up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling Startz Ltd to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.
33. This Website may place the following Cookies:
· Strictly necessary cookies
These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, or make use of e-billing services.
· Analytical/performance cookies
They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
· Functionality cookies
These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
34. You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.
35. You can choose to delete Cookies at any time; however, you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.
36. It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.
39. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
40. This Policy will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.
Automated Decision Making
42. We sometimes use systems to make automated decisions based on your personal Data. This helps us to make sure our decisions are quick, fair, efficient and correct, based on what we know. These automated decisions can affect the products, services or features we may offer you now or in the future, or the ability to use our services.
43. We may use automate decisions making in the following situations:
a) tailoring products and services – we may place you in groups with similar customers (segments) to study and learn about preferences and your needs, and offer more tailored experience for you;
b) detecting fraud - we use your personal information to help decide and detect if your account may be being used for fraud or money-laundering. If we think there is a risk of fraud, we may block or suspend the account;
c) opening account - when you open an account with us, we check that the product or service is relevant for you, based on what we know. We also check that you meet the conditions needed to open the account. This may include checking age, residency, nationality or financial position;
d) performing and analysing risk assessments connected to your bet.
44. Data protection law seeks to safeguard individuals against harm that may arise from decision-making - including profiling - that takes place without human intervention. You have the right not to be subject to a decision - including profiling - when it is based on the automated processing of your personal information and it has a legal effect or a similarly significant effect on you.
45. Please note that the right does not apply when the processing is:
a) necessary for entering into or for the performance of a contract with you; or
b) when it is authorised by law; or
c) when it is based on your explicit consent.
46. If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can complain to the Information Commissioner’s Office (ICO) by contacting them on 0303 123 1113 or visiting https://ico.org.uk/.
Data Protection Officer
3 Stucley Place, LONDON, NW1 8NS