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PRIVACY POLICY

At “Fantastec” (Fantastec Sports Technology Ltd), we take your privacy seriously. This Policy applies to your use of the Fantastec SWAP mobile application (the “SWAP App”). 

 

Please read this Policy carefully to understand:

  • what information we collect about you;
  • how we use and share that information; and
  • your rights and choices relating to that information.

If you are using any of our other games or services, please see the relevant privacy policy for those games or services.

 

TOPICS COVERED:

 

THE SWAP APP

TERMS WHICH APPLY TO YOU

INFORMATION WE COLLECT (INCLUDING WHEN AND HOW WE COLLECT IT)

HOW AND WHY WE USE YOUR INFORMATION (AND OUR LEGAL BASIS FOR DOING SO)

SHARING YOUR INFORMATION

RETAINING YOUR INFORMATION

TRANSFERRING YOUR INFORMATION OVERSEAS

KEEPING YOUR INFORMATION SECURE

UPDATING AND ACCESSING YOUR INFORMATION

DEVICE IDENTIFICATION TECHNOLOGIES

YOUR RIGHTS

MARKETING

OTHER WEBSITES

CHANGES TO THIS POLICY

HOW TO CONTACT US

The swap app

 

The SWAP App enables you to buy, download, store and swap digital collectibles relating to sports clubs and players (“Collectibles”).  You can buy and download Collectibles as part of a “Pack”, and you can swap individual Collectibles with other users.

TERMS WHICH APPLY TO YOU

 

This Policy applies to you if you visit or use the SWAP App. 

In order to use the SWAP App, we will ask you to register.  We will also ask you (or your parent / guardian if you are under 16) to read and accept the SWAP App ‘Licence Terms. These Licence Terms set out the rules which apply when you use the SWAP App.

INFORMATION WE COLLECT (INCLUDING WHEN AND HOW WE COLLECT IT)

 

We collect the following personal information from and about you:

  1. Information you give to us
  2. Information we collect about you 
  3. Information provided by third parties

 

1. Information you give to us. You may give us information:

  • if you register to use the SWAP App;
  • if you use the SWAP App (including when you complete your user profile and when you invite your friends to use the SWAP App);
  • if you upload or transmit any content such as opinions or comments that contain personal information;
  • if you complete a survey or provide feedback on the SWAP App;
  • if you report a problem with the SWAP App; and
  • if you contact or correspond with us (through the SWAP App, by e-mail or otherwise) for any other reason.

 

When you register for and create an account within the SWAP App, you:

  • must provide us with your valid e-mail address and date of birth.  You must also choose a username and password.
  • may provide your first and last name, country, favourite football club(s) and favourite football player(s), and how long you’ve been a fan of your chosen club, and a mini-bio of yourself.

 

When you use the SWAP App, you:

  • may provide us with the e-mail addresses of your friends when you invite them to use the SWAP App.

 

After you have used the SWAP App, you:

  • may provide us with feedback, comments or complaints about the SWAP App, including in any interviews and/or online surveys.

 

2. Information we collect about you.

When you use the SWAP App, we will collect details about your interactions and transactions on the SWAP App.  For example, we will collect information when you buy and download Packs, when you swap or perform other actions with your Collectibles, when you connect with other users, and when you complete a challenge and earn trophies or rewards.

Depending on the access restrictions on your device (your mobile phone, computer or tablet, etc), when you use the SWAP App, we may also collect:

  • certain technical information, for example, the type of device you use to access the SWAP App (including its unique device identifier), the internet protocol (IP) address used to connect your device to the internet, your login information, browser type and version (if applicable), time zone setting, operating system, mobile platform and network information;
  • log data from your device, including the full Uniform Resource Locators (URL), clickstream to, through and from the SWAP App (including date and time), parts of the SWAP App you viewed, response times, length of visits to certain parts of the SWAP App, information about your interaction with the SWAP App (such as scrolling and clicks); and
  • certain Device Identification Technologies (see DEVICE IDENTIFICATION TECHNOLOGIES to understand which Device Identification Technologies the SWAP App uses).]

 

3. Information provided by others. 

When you use the SWAP App we may receive information about you from other companies.  For example, some companies such as Cognito, Mixpanel, Google Analytics, and Zoho provide us with analytics services (which means they give us statistics and insights) that tell us about how you use the SWAP App.  In addition, if you buy and download Packs, we may receive confirmation of those in-app purchases from the app store which processes your payment, for example the Apple App Store or Google Play Store (but we will not receive any financial information about you).

We may also receive information about you from other users, for example if they contact us about your use of the SWAP App.

HOW AND WHY WE USE YOUR INFORMATION (AND OUR LEGAL BASIS FOR DOING SO)

 

We collect information about you so that we can operate the SWAP App effectively and provide you with the best possible service.

The information we collect and use depends on how you interact with us. It also depends on the choices you make, for example the consents you (or your parent / guardian if you are under 16) provide, the functions you use and the privacy settings you (or your parent / guardian) select on your device.

You (or your parent / guardian) may choose not to provide or allow us to collect certain information. If this is the case, you may not be able to use some parts of the SWAP App (where we need that information for you to do so).

Learn more below about how and why we use your information (and our legal basis for doing so) if you are:

  • Under 16
  • Over 16

If you are under 16:

Types of information we process

Why we process this information

Our legal basis for processing this information

  • Your date of birth

To enable us to verify your age so that we can comply with our obligations under data protection laws

To enable us to comply with our obligations under data protection laws

  • Your name
  • Your e-mail address
  • Your username

To help us to identify you and your account

To enable us to provide the SWAP App to you

To enable us to send you information which you will need to be able to use the SWAP App

Your parent or guardian’s consent

  • Your account password

To keep your account secure

Your parent or guardian’s consent

  • Your interactions and transactions on the SWAP App (including your Packs, Collectibles, rewards and trophies)
  • Your username
  • Your country
  • Other relevant information you choose to include on your profile

To enable us to share your profile and details of your interactions and transactions on the SWAP App with other users (including swapping Collectibles and viewing the “owner history” of any given Collectible)

To improve users’ experience of the SWAP App

Your parent or guardian’s consent

  • Your date of birth
  • Your country

To enable us to understand the demographic of SWAP App users and so that we can tailor our information, products and services to you

Your parent or guardian’s consent

  • Your friends’ e-mail addresses

To invite your friends to use the SWAP App

Your friends’ consent (or, if they are under 16, their parents’ or guardians’ consent)

  • Your name
  • Your e-mail address
  • Information in any feedback, comments or complaints you make or provide about the SWAP App
  • Any other personal information you choose to give us

To deal with any enquiries, correspondence, concerns or complaints from you and to improve our products and services (e.g. our apps and games)

Your parent or guardian’s consent

  • Your name
  • Your e-mail address

To enable us to send you information about the SWAP App and/or other products or services of ours which may be of interest to you

To enable us to keep in touch with you after you have used the SWAP App or for legal / admin purposes

Your parent or guardian’s consent

  • Your name
  • Your e-mail address
 To enable football clubs to send you information about products or services of theirs which may be of interest to you  Your parent or guardian’s consent
  • Confirmation of any Packs you buy as in-app purchases
 To enable us to confirm when you have made an in-app purchase  To allow us to perform our obligations under our agreement with you

Information we collect from your device when you use the SWAP App (including analytical and usage information provided by other companies), such as:

  • Technical information
  • Log data
  • Device Identification Technologies

To allow us to test the SWAP App and to analyse how it works (for example by carrying out research, statistical analysis and troubleshooting)

To ensure that the SWAP App is presented in the best way for you and for your device

To enable us to understand how you use the SWAP App

To keep the SWAP App secure and to prevent fraud

To enable us to pursue our legitimate interests to:

  • understand how the SWAP App is used;
  • improve the SWAP App;
  • keep the SWAP App secure; and
  • prevent fraud

or, in the case of Device Identification Technologies which are not “strictly necessary”, your parent or guardian’s consent. 

 

If you are over 16:

Types of information we process

Why we process this information

Our legal basis for processing this information

  • Your date of birth

To enable us to verify your age so that we can comply with our obligations under data protection laws

To enable us to comply with our obligations under data protection laws

  • Your name
  • Your e-mail address
  • Your username

To help us to identify you and your account

To enable us to provide the SWAP App to you

To enable us to send you information which you will need to be able to use the SWAP App

To allow us to perform our obligations under our agreement with you, and/or to take steps at your request prior to entering into our agreement with you

  • Your account password

To keep your SWAP Trial account secure

To enable us to pursue our legitimate interests to keep the SWAP App secure

  • Your interactions and transactions on the SWAP App (including your Packs, Collectibles, rewards and trophies)
  • Your username
  • Your country
  • Other relevant information you choose to include on your profile

To enable us to share your profile and details of your interactions and transactions on the SWAP App with other users (including swapping Collectibles and viewing the “owner history” of any given Collectible)

To improve users’ experience of the SWAP App

To enable us to pursue our legitimate interests to allow you to connect and interact with other users of the SWAP App

  • Your date of birth
  • Your country

To enable us to understand the demographic of SWAP App users and so that we can tailor our information, products and services to you

To enable us to pursue our legitimate interests to understand the demographic of SWAP App users and so that we can tailor our information, products and services to you

  • Your friends’ e-mail addresses

To invite your friends to use the SWAP App

Your friends’ consent (or, if they are under 16, their parents’ or guardians’ consent)

  • Your name
  • Your e-mail address
  • Information in any feedback, comments or complaints you make or provide about the SWAP App
  • Any other personal information you choose to give us

To deal with any enquiries, correspondence, concerns or complaints from you and to improve our products and services (e.g. our apps and games)

To enable us to pursue our legitimate interests to:

  • understand your experience of the SWAP App;
  • deal with enquiries, concerns or complaints regarding our products and services; and
  • improve our products and services
  • Your name
  • Your e-mail address

To enable us to keep in touch with you after you have used the SWAP App or for legal / admin purposes

To enable us to pursue our legitimate interests to understand your experience of the SWAP App and/or so that we can comply with a legal obligation

  • Your name
  • Your e-mail address

To enable us to send you information about the SWAP App and/or other products or services of ours which may be of interest to you

Your consent

  • Your name
  • Your e-mail address

To enable football clubs to send you information about products or services of theirs which may be of interest to you

Your consent

  • Confirmation of any Packs you buy as in-app purchases

To enable us to confirm when you have made an in-app purchase

To allow us to perform our obligations under our agreement with you

Information we collect from your device when you use the SWAP App (including analytical and usage information provided by other companies), such as:

  • Technical information
  • Log data
  • Device Identification Technologies

To allow us to test the SWAP App and to analyse how it works (for example by carrying out research, statistical analysis and troubleshooting)

To ensure that the SWAP App is presented in the best way for you and for your device

To enable us to understand how you use the SWAP App

To keep the SWAP App secure and to prevent fraud

To enable us to pursue our legitimate interests to:

  • understand how the SWAP App is used;
  • improve the SWAP App;
  • keep the SWAP App secure; and
  • prevent fraud

or, in the case of Device Identification Technologies which are not “strictly necessary”, your consent. 


More about the information we use and why

Where we have a legal basis to use your personal information without consent (as we have explained in the tables above), this Policy fulfils our duty to use that information fairly and lawfully and in a way that you would expect bearing in mind the services we are providing to you. It is intended to give you proper notice and explanation of the way in which your personal information will be used.

Where we need consent to use your information, we will ask you (or your parent / guardian if you are under 16) to tick the appropriate consent box or otherwise let us know that you consent.

Where you provide us with other people’s personal information (for example, if you provide us with your friends’ names and email addresses to invite them to take part in the SWAP Trial), you must obtain their consent before doing so. 

If you have any questions or you need any further information regarding how we use your information, please contact us (see HOW TO CONTACT US).

SHARING YOUR INFORMATION

When and why might you share my personal information with others?

We may share your information with your consent (or the consent of your parent / guardian if you are under 16) or as is necessary with selected companies that help us to perform the activities set out in the tables above.  See below for more details.

We make sure that these other people or companies take security measures to protect your information in line with our policies.  We do not allow them to use your personal information for their own purposes and we only permit them to process your personal information for specified purposes in accordance with our instructions.

In some circumstances, we may need to share your personal information with a data protection regulator or in order to comply with the law or a legal process (including law enforcement or government agencies).  We may also do so where we have another legitimate interest that is not overridden by your interests and fundamental rights (for example, to maintain the security of our computer systems).

Who will you share my personal information with?

  • we will share certain information about you (including your first and last name, [email address], date of birth and country, as well as some of your interactions and transactions on the SWAP App) with other SWAP App users.  We do this so that users can connect and interact on the SWAP App;
  • if you invite your friends to use the SWAP App, we will tell them your name so that they know who has sent that invitation; and
  • we may need to give certain information about you to government or other law enforcement agencies in connection with the investigation of unlawful activities or for other legal reasons.

Who else might obtain my personal information?

  • if you buy any Packs, the app store which processes your payment will receive any financial information or details you provide to make that in-app purchase (although we ourselves will never receive this);
  • we ask analytics companies (including Cognito, Mixpanel, Google Analytics, and Zoho) to tell us about your use of the SWAP App.  They may access or receive certain information about you so that they can provide us with statistics and insights.  This is necessary so that we can improve the SWAP App and understand how it is used; and
  • other companies who provide services to us may also access or receive some of your information.  For example, we use companies including Google to help us collect and transfer your information to where it is needed so that we can make the SWAP App work effectively.

RETAINING YOUR INFORMATION

We will only keep your personal information for as long as we need to in order to fulfil the purposes for which we collected it.  This includes keeping it for any legal, accounting, or reporting purposes.

To decide how long we keep your information, we consider the type and amount of information you give to us or which we collect, and how sensitive that information is.  We also consider the risk of harm that might occur if the information went missing or if somebody used it in a way they were not supposed to, for example, and the reasons why we are using your information in the first place.

In some circumstances, we may anonymise your information, which means that it is no longer connected to, or about, you.  If we do this, we may use this information without any further permission from you (or your parent / guardian).  Even if you ask us to delete your information, we may still need to keep it in a form that does not identify you (see YOUR RIGHTS).

We will keep your information for the following periods, unless we tell you otherwise (or you ask us to delete your information):

  • if you are registered user of the SWAP App, we will delete your personal information within one year of the date on which your agreement with us under our Licence Terms ends for any reason.  We may need to keep certain information (for example, your name and basic contact details) for a period of seven years from the date on which those Licence Terms end for archive, administrative or legal reasons;
  • if you are a visitor to the SWAP App (and not a registered user) and you do not access the SWAP App for one year, then we will delete your personal information.

We may also keep certain information (for example, your name, username and basic contact details) for longer periods than those stated above if you have agreed to us using it, for example, for keeping in touch about our other products or services, or for our promotional purposes.

Please contact us if you would like further details on how long we keep your information (see HOW TO CONTACT US).

TRANSFERRING YOUR INFORMATION OVERSEAS

 

If you use the SWAP App, we will need to transfer your information overseas. This is because:

  • users of the SWAP App are based all over the world; and
  • some of the companies that provide services to us in order for us to operate the SWAP App (as described above) may be based in, or run their services from, a different country.

If you are based in the European Economic Area, this means we may need to transfer your information outside the European Economic Area.  We will take all steps reasonably necessary to ensure that your information will receive an adequate level of protection and that it will be treated in a way which is consistent with European data protection laws.

KEEPING YOUR INFORMATION SECURE

 

We have designed the SWAP App keeping in mind the safety of your personal information. All information that you provide to us is stored on secure servers.  We have put in place (and make sure that anyone we share your information with has put in place) measures to protect your information.

However, information which is sent via an app or the internet can never be completely secure. While we do our best to protect your information, we cannot guarantee the security of any information which is sent by email or via the SWAP App.  This is done at your own risk.

If you are worried that your account or your information might be at risk (for example, if somebody else has found out your password), please contact us (see HOW TO CONTACT US).

UPDATING AND ACCESSING YOUR INFORMATION

 

If you are based in the European Economic Area, you have the right under European data protection laws to access personal information held about you, subject to certain conditions, and to ask for it to be changed or deleted.

You will be able to change or delete the personal information which we hold about you (other than your email address) via the SWAP App.  If you would like to change the email address connected with your account, you should e-mail us (or otherwise contact us) directly (see HOW TO CONTACT US).

To learn more about the rights you may have in relation to your personal information see YOUR RIGHTS.

DEVICE IDENTIFICATION TECHNOLOGIES

 

We use cookies and/or similar technologies such as unique IDs and tokens (as set out below) on the SWAP App to collect and track information in order to analyse and improve the SWAP App and our related services. These are small text files that are placed onto your device when you use the SWAP App.  We refer to these as “Device Identification Technologies”.

We use the following Device Identification Technologies.  They may be set by us or by third parties such as Google Analytics and MixPanel, on our behalf:

  • Strictly necessary Device Identification Technologies – these are required for the operation of the SWAP App. They include, for example, Device Identification Technologies that enable you to login to the SWAP App.
  • Analytical/performance Device Identification Technologies – these allow us to recognise and count visitors and to see how visitors move around the SWAP App when they are using it. This helps us to assess performance and analytics, and to improve the way our apps work.
  • Functionality Device Identification Technologies – these allow the SWAP App to remember the choices you make (such as your SWAP App login details).

 

You can find more information about the individual Device Identification Technologies we set on your device and the purposes for which we use them in the table below:

Device Identification Technology

Description

Purpose

AWS Amplify Authentication

A Device Identification Technology that enables your device to remember the email address of the person who most recently logged into their SWAP account on your device

We set this Device Identification Technology on your device so that you don’t have to re-enter your login details each time you open the SWAP App

Referral invitation ID

A unique ID which is generated when you invite a friend to use the SWAP App

We use this unique ID so that we can provide you with a free promotional Pack when you introduce a friend and they register for and create an account within the SWAP App

On-boarding activity completion flag(s)

A “flag” which indicates to us whether or not you have seen and/or completed each on-boarding activity

We use these flags to avoid repeatedly showing you the same on-boarding activities

Authentication token

A string of letters and numbers which enables us to confirm that you are an authenticated user of the SWAP App

As above, we set this token on your device so that you don’t have to re-enter your login details each time you open the SWAP App

Profile ID

A string of letters and numbers that identifies your user profile in our SWAP App database

We use this ID so that the SWAP App can recall and display specific information about you, such as your favourite club and favourite player

 

Consent to use Device Identification Technologies

When you first access the SWAP App, we will ask for your consent to place Device Identification Technologies on your device. 

 

Managing and refusing the use of Device Identification Technologies

Most devices will allow you to choose whether you wish to accept Device Identification Technologies.   However, if you do not want to accept the Device Identification Technologies which we set, the SWAP App will not function properly on your device and you will be unable to use it.  If this is the case, please do not download, install or use the SWAP App.

For further information about Device Identification Technologies and how to disable them, please go to the Information Commissioner’s webpage: https://ico.org.uk/for-the-public/online/cookies/.

YOUR RIGHTS

 

This section only applies if you are within the EEA. European data protection law says that you have the right to:

  • request access to your personal information (commonly known as a “data subject access request”).  This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing (or using) it.  We will need you to prove your identity before we release any personal information to you;
  • request correction or deletion of your personal information (unless we have the legal right to retain it).  You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below);
  • object to processing (or use) of your personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing (or use) of your information on this ground.  You also have the right to object where we are processing (or using) your personal information for direct marketing purposes;
  • request the restriction of processing (or use) of your personal information.  You can ask us to temporarily stop processing (or using) personal information about you, for example if you want us to establish that it is accurate or the reason for processing (or using) it;
  • request the transfer of personal information that you have provided to us to someone else; or
  • change your information preferences at any time (where this specifically relates to marketing messages, see MARKETING).

 

You should be aware that if you ask us to stop processing (or using) your personal information in a certain way or if you ask us to delete your information, and we need to use that information to provide the SWAP App to you, then you may not be able to continue to use it.  This does not include your right to object to direct marketing, which can be exercised at any time without restriction.

If you want to exercise any of the rights listed above, please contact us (see HOW TO CONTACT US).

 

No fee usually required to access your personal information

You will not normally have to pay a fee to access your personal information (or to exercise any of the other rights set out above).  However, we may charge a reasonable fee if your request for access is manifestly unfounded or excessive.  Alternatively, in such circumstances we are entitled to refuse to comply with the request.

 

What we may need from you

We may need to request specific information from you to confirm your identity and verify your right to access the information (or to exercise any of your other rights).  This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

 

Right to withdraw consent

Where you have consented to the collection, use or transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing (or use) at any time.  To withdraw your consent, please contact us (see HOW TO CONTACT US).  Once we have received notification that you have withdrawn your consent, we will no longer process (or use) your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

MARKETING

 

Marketing from us

We will only send you marketing messages by email and/or via the SWAP App if you (or your parent / guardian if you are under 16) consent to this.  These messages will only ever relate to our products or services which may be of interest to you (including, for example, promotional materials and updates).

We will ask whether you would like to receive marketing messages from us when you first complete your profile.

 

Marketing from football clubs

We may also, with your (or your parent / guardian’s) consent, provide your first and last name, email address, country and date of birth to a relevant football club or clubs so that they can send you marketing messages by email which relate to their products or services which may be of interest to you.

If applicable, we will ask whether you would like to receive marketing messages from the relevant football club(s) when you tell us that you are a fan of that club.

You have the right at any time to stop us or any football club from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, you can unsubscribe by using the “unsubscribe” link at the bottom of any marketing message or by contacting us (see HOW TO CONTACT US) or the relevant football club.

We will not provide your personal information to any other businesses for marketing purposes. 

OTHER WEBSITES AND APPS

 

The SWAP App may contain links to websites and apps run by other companies, such as Twitter, Instagram, Google and LinkedIn.  This Policy only applies to the SWAP App, so when you link to other websites or apps, you should read the privacy policies of those other companies to find out how they will handle your information.

CHANGES TO THIS POLICY

 

This Policy was last updated in [January] 2019.

We will update this Policy from time to time and will post any updates on this page.  If you don’t agree with those changes, you can always stop using the SWAP App and stop giving us any more of your information.

HOW TO CONTACT US

 

If you have any questions about this Policy or how we handle your personal information you can contact us at swap.support@fantastec.io or The White Collar Building, 1 Old Street Yard, London, EC1Y 8AF, UK.

 

Fantastec Sports Technology Ltd is the “data controller” when it comes to the handling of your personal information for the purpose of using the SWAP App. Fantastec is registered with the UK Information Commissioner’s Office with the registration number: ZA326960.

 

Complaints

If, for any reason, you are not happy with the way that we have handled your personal information please contact us by clicking here.  If you are still not happy (and you live in the UK), you have the right to make a make a complaint to the UK Information Commissioner’s Office. Please see: https://ico.org.uk/global/contact-us/.

Copyright © 2019 Fantastec.
All rights reserved.