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PRIVACY POLICY


OVERVIEW

Below you will find our Privacy Policy which tells you about how we will process
your personal data and about rights that you have under data protection. We
strongly recommend that you familiarize yourself with this Privacy Policy.
However, we understand that people have busy lives and so want to provide you
with a quick overview of how we will use your personal data – please remember
though that this first section is an overview only and should not be read
instead of reading the full Privacy Policy below.

We process your personal data for the purposes discussed in detail below, but
the two main purposes are to enable us to provide you with services and to
comply with our regulatory obligations, specifically:

 * On the first of these, in order for us to offer you with services we will
   need you to register a user account and provide bank details to deposit
   money.
 * On the regulatory aspect, we are required to monitor our customers and to
   keep records of transactions to ensure that we are offering a fair,
   responsible and safe service – and this includes verifying your age and
   monitoring our customers to ensure that they are gambling within their means.


INTRODUCTION

This Privacy Policy applies to our websites, applications, goods and services
that link to this policy or which do not have a separate privacy policy. The
purpose of this Privacy Policy is to provide you with information about how we
use your personal data. This Privacy Policy may be updated from time-to-time so
we recommend that you review it regularly, however where we make material
changes, we will make sure to alert you to this.


WHO IS THE CONTROLLER?

The controller (formerly known as data controller) of your personal data is TSG
Interactive Services (Ireland) Limited, Belfield Office Park, Beech Hill Road,
Clonskeagh, Dublin 4, Ireland. This is who we refer to in this Privacy Policy
when saying "TSG", "we", "our" and "us" etc.




AND, WHAT ABOUT THE DATA PROTECTION OFFICER, OR IS IT DPO?

Yes, we have appointed a Data Protection Officer (DPO). While our DPO can be
reached at dataprotection@flutterint.com, our Customer Service team will be your
initial point of contact if you wish to exercise your rights. Please see the
'Your Rights' section below.


WHAT IS MEANT BY THE "GROUP"?

Reference to the Group within this Privacy Policy means 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, Paddy Power, Betfair,
Timeform, Sportsbet, BetEasy, FanDuel, TVG, Adjarabet, Sky Betting and Gaming,
PokerStars, Junglee, Singular and Sisal.




HOW WE COLLECT YOUR PERSONAL DATA

In order to provide you services, you will need to create a user account. When
creating this user account, you will need to submit certain personal data such
as your name, age, address and email. Additional information will also be
required for you to utilize some of our services, such as your bank card
details.

We also collect information about the transactions you make, including your
gambling activity. We may collect personal data through surveys which we, or
companies engaged by us for such purpose, undertake. In addition, we collect
information about your use of our websites, mobile applications and services. We
will also collect other information necessary for us to process your personal
data for the purposes set out in this Privacy Policy.

Where you contact us, we will process any personal data you provide in these
communications.

We may also collect personal data from third party service providers, such as
credit reference agencies and fraud prevention companies.

Finally, we also use "cookies" and similar technologies which may collect
certain information about you, such as your devices' IP addresses and online
activity, some of which will constitute your personal data. You can learn more
about the cookies we use in the 'Cookies' section below.


HOW WILL WE USE YOUR PERSONAL DATA

In accordance with data protection laws, we will only process your personal data
when we have a lawful basis for doing so in respect of your personal data. We
process your personal data if: (i) it is necessary to provide services to you
under the performance of the contract we have with you; (ii) we are required to
do so in accordance with legal or regulatory obligations; (iii) you have given
your consent; or, (iv) it is in our legitimate interests to process your
personal data, provided that none of these interests prejudice your own rights,
freedoms and interests.

With the exception of limited circumstances, we do not process special
categories of personal data about you (such as personal data relating to your
health, ethnicity, religion, political persuasion, trade union membership or
sexuality) or personal data relating to criminal offences or convictions. For
the limited circumstances in which we process special categories of personal
data, we have set out the additional lawful basis required in italics below.

The following is a list of the purposes for which we process your personal data,
and the lawful basis on which it carries out such processing:

PurposeLawful BasisTo set-up, administer and manage your user account Necessary
for the performance of a contractTo provide you with our services (including to
allow you to play our games)Necessary for the performance of a contractTo
receive and respond to your communications and requestsNecessary for the
performance of a contract if the communication relates specifically to our
services, otherwise legitimate interests To notify you with important updates to
our websites, mobile applications and services Necessary for the performance of
a contractTo ensure that we are able to fulfil our regulatory obligations
regarding your use of our services, including by verifying the accuracy of any
information you provide us, verifying your identity and verifying your age
(which may involve us disclosing your personal data to third parties or
supplementing your personal data with information received from third parties
(such as credit reference agencies)) Necessary to comply with a legal or
regulatory obligationTo ascertain sources of funds and wealth, and to
determine your ability to afford the amount you spend Necessary to comply with a
legal or regulatory obligation To comply with our obligations under applicable
laws (including gambling legislation, and regulatory and licensing requirements
related to our gambling licenses) Necessary to comply with a legal or regulatory
obligationTo identify and disclose any suspected unlawful, fraudulent, or other
improper activity connected with our websites, mobile applications and services
(including money laundering) Necessary to comply with a legal or regulatory
obligation 

Substantial Public Interest: Preventing or detecting unlawful acts / protecting
the public against dishonesty / regulatory requirements relating to unlawful
acts and dishonesty / preventing fraud / suspicion of terrorist financing or
money laundering  To monitor gambling patterns and to identify possible
responsible gambling concerns Necessary to comply with a legal or regulatory
obligation 

Substantial Public Interest: Safeguarding of individuals at risk / safeguarding
of economic well-being of certain individuals  To prevent you from using our
websites, mobile applications and services if you have requested that we do so
(such as self-exclusion) Necessary to comply with a legal or regulatory
obligation 

Substantial Public Interest: Safeguarding of individuals at risk / safeguarding
of economic well-being of certain individuals  To comply with any deposit, spend
or loss limits that you have set or which have been applied to your user
account ConsentTo support any other purpose necessary for the performance of our
contractual obligations or specifically stated at the time at which you provide
your personal data Necessary for the performance of a contractTo identify any
fraudulent use of our servicesNecessary for a legal or regulatory obligationTo
identify any breach of our terms of use Necessary for the performance of a
contractTo carry out market research campaigns Legitimate interests of better
understanding the products and services that our customers most enjoy To send
out surveys to better understand our products and services Legitimate interests
of better understanding the products and services that our customers most
enjoy To review the results of surveys completed by you ConsentTo prepare
statistics relating to the use of our websites, mobile applications and services
by you and our other customers Legitimate interests of understanding the use of,
and therefore improving, our products and servicesTo send offers and promotions
relating to our services that you may be interested in ConsentTo record
telephone calls to and from, and live chats with, our customer services
representatives for training purposes  Legitimate interests of improving our
customer servicesTo record telephone calls to and from, and live chats with, our
customer services for security and regulatory purposes Necessary for a legal or
regulatory obligationTo use your name, image, username or location in publicity
and marketing, but only when you have provided express and informed consent for
us to do so ConsentSharing: To share your personal information with other
members of the Group who assist in providing the services to
customers Legitimate interests to allow us to provide servicesSharing: To share
your personal data with our professional advisors, such as lawyers and
consultants Legitimate interests to allow us to seek adviceSharing: To share
personal data with other members of the Group to ensure that responsible
gambling measures can be applied across the group Necessary for a legal or
regulatory obligationSharing: To share your personal data with social media
services to provide you with ads on social media sites, unless you have
requested not to receive such ads via your social media account Legitimate
interest of better advertising our products and servicesSharing: To share your
personal information with third parties for identity and geolocation
verification Necessary to comply with a legal or regulatory obligationSharing:
To share your personal information with third parties for fraud and anti-money
laundering detection purposes  Necessary to comply with a legal or regulatory
obligation 

Substantial Public Interest: Preventing or detecting unlawful acts / protecting
the public against dishonesty / regulatory requirements relating to unlawful
acts and dishonesty / preventing fraud / suspicion of terrorist financing or
money laundering  Sharing: To share your personal data with law enforcement
agencies for the prevention and detection of crime Legitimate interests of
helping to protect our services and our community 

Substantial Public Interest: Preventing or detecting unlawful acts / protecting
the public against dishonesty / regulatory requirements relating to unlawful
acts and dishonesty / preventing fraud / suspicion of terrorist financing or
money laundering  Sharing: To share your personal data with national
self-exclusion databases if you have self-excludedNecessary to comply with a
legal or regulatory obligation 

Substantial Public Interest: Safeguarding of individuals at risk / safeguarding
of economic well-being of certain individuals  Sharing: To share your personal
data with gambling regulators in order to assist and comply with any
investigation Necessary for a legal or regulatory obligationCookies: To operate
our websites and mobile applications, including allowing you to interact with
our websites and mobile applications and to recall selections as you move
between pages Legitimate interest of using a website with at least standard
functionality to provide our servicesCookies: To analyze your use of our
website, monitor our web audience and populate certain content on our website in
line with your usage ConsentCookies: To track your journey to and from our
website so we can understand how customers come to and from our website and give
effect to any commercial arrangements Consent Cookies: To comply with
regulations, including identifying multiple user accounts, attempts to login to
an unauthorized user account or potential fraud Necessary to comply with a legal
or regulatory obligationCookies: To present third party marketing Consent

In addition to the purposes set out above, we may also process your personal
data for other purposes that we deem compatible with those listed above. We will
update this Privacy Policy accordingly, when we do this.

Please note that the lawful bases set out above are those which will primarily
apply although it is possible that a change in circumstance may result in a
change in lawful basis – for example, if you close your user account with us we
will no longer process your personal data to perform a contract with you but
will continue to do so in order to comply with legal requirements.


INTRA-GROUP SHARING

We are part of the Group and there will be instances where your personal data is
shared with other members of the Group. This will occur in the following
circumstances:

 * to enable us to identify and replicate responsible gambling measures (such as
   self-exclusion) to players across the Group (necessary to comply with a
   legal/regulatory requirement);
 * to assist with account management, identification and verification of our
   customers as well as other regulatory checks (necessary to comply with a
   legal/regulatory requirement);
 * to help ensure that customer information is up-to-date and accurate
   (necessary to comply with a legal/regulatory obligation);
 * to identify customers who have committed or are suspected of fraud,
   money-laundering or other criminal acts (necessary to comply with a
   legal/regulatory requirement);
 * to identify customers who have breached our General Terms or other terms and
   conditions related to our services  (legitimate interests);
 * to send cross-brand marketing materials where customer has requested this
   (consent); and
 * to analyze and better understand our business, customers, products and
   services across the group (legitimate interests).

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

Please check this Privacy Policy frequently to learn of any updates to our
intra-group sharing.


DISCLOSING YOUR PERSONAL DATA

In addition to the purposes involving the sharing of your personal data listed
above, we will also disclose your personal data to processors we engage. We will
have a contract in place with each such processor to ensure your personal data
is kept secure.

We may also disclose your personal data in the following circumstances:

 * when required by applicable law or regulation (disclosure to a governmental,
   regulatory or enforcement authority);
 * in order to defend ourselves legally and/or in relation to legal proceedings;
   and
 * whilst negotiating a takeover, purchase or merger, and pursuant to the same.


TRANSFERRING YOUR PERSONAL DATA OUTSIDE OF THE EEA

We store your personal data in the Isle of Man, a territory that has received an
Adequacy Decision from the European Commission regarding its suitable data
protection laws. Your personal data may also be accessed by members of the Group
who are located outside of the European Union and in such cases we have
implemented standard contractual clauses to ensure adequate protection of your
personal data.

We may also share your personal data with third parties outside of the European
Union and in all such cases we will ensure that standard contractual clauses or
an Adequacy Decision is in place to protect your personal data.


SECURITY

We will take appropriate security, technical and organizational measures to
ensure that your personal data is kept secure and to prevent the theft, loss or
unauthorized access to your personal data. It is important to understand however
that security can never be guaranteed and you will not hold us liable save where
the security of your personal data is compromised due to our negligence.


MARKETING

If you have signed up to services offered by us we may send you direct marketing
in relation to other services offered by us or our Group provided that you have
given your consent to receive such marketing.

At any time you can manage your marketing consents via your user account. You
can also unsubscribe by using the tools in any marketing communication you
receive. Please note that if you unsubscribe from marketing it may take up to
five working days for this to take effect.


SOCIAL MEDIA MARKETING

We may also use information you provide to us to show you relevant advertising
and personalized content about our Group's services on certain third party
social media platforms (Social Media Sites) made available to us through
relevant service providers (e.g. Facebook, Twitter). If you do not wish to see
these advertisements, you can change your settings on the Social Media Sites. If
you do not want us to share this information with Social Media Sites you can
contact us directly.


COOKIES

In this Privacy Policy, we use the expression 'cookie' to refer to cookies and
similar technologies we use to store information (such as web beacons). A cookie
is a simple text file that is stored on your computer or mobile (or other)
device by a website's server, and only that server will be able to retrieve or
read the contents of that cookie. Each cookie is unique to your web browser. It
will contain some anonymous information, such as a unique identifier and the
website name and some digits and characters.

Almost all websites and applications you visit, including our websites, will use
cookies in order to improve your user experience by enabling that website and/or
application to 'remember' you, either for the duration of your visit (using a
'session cookie') or for repeat visits (using a 'persistent cookie').

Cookies are used to improve your use of a website or application, for example
through letting you navigate between pages efficiently and storing your
preferences. Cookies make the interaction between you and the website faster and
easier. If a website or application doesn't use cookies, it will think you are a
new visitor every time you move to a new page on the website. Cookies can also
be used to enable targeted advertising and analyzing your browsing of a website.

You can learn more about cookies generally and how to disable them on your
browser here.  

You can learn more about what advertising cookies exist on your device and you
can disable them directly by clicking here.


RETENTION OF YOUR PERSONAL DATA

We retain your personal data for six years. Six years is calculated from the
closure of your user account or where your user account has been dormant for
this period. There are some exceptions to this retention period, namely:

 * If you self-exclude from any of our services, we will retain this information
   indefinitely.
 * If you are under investigation or we have identified possible fraud,
   money-laundering, criminal activity we may retain your personal data for
   longer.
 * If there is a legal dispute, we will retain your personal data for the
   duration of the dispute and for six years thereafter.


UPDATING YOUR PERSONAL DATA

You can update some of your personal data at any time via your user account. We
request that when your personal data changes you update your user account as
soon as possible. If you are unable to change your information via your user
account, please contact Support. 


YOUR RIGHTS

You have the following rights in relation to your personal data:

 * a right to access your personal data held by us (also known as a subject
   access request);
 * a right to receive certain personal data in machine-readable format;
 * a right to have inaccurate or out-of-date personal data rectified;
 * where we have specifically requested your consent to process your personal
   data and have no other lawful conditions to rely on, you have the right to
   withdraw this consent;
 * a right to have certain personal data erased where it is no longer necessary
   for us to process it, if you have withdrawn your consent pursuant to the
   paragraph above, where you have objected pursuant to the paragraph below,
   where your personal data has been unlawfully processed, or where erasing your
   personal data is required in accordance with a legal obligation;
 * a right to object to the processing if the lawful basis is that it is in our
   legitimate interests to process your personal data, but please note that we
   may still process your personal data if there are other relevant lawful bases
   or if we have compelling grounds to continue processing your personal data in
   our interests which are not overridden by your rights, interests or freedoms;
 * a right to request an explanation of the logic involved if we make decisions
   about you solely through automated means; and
 * a right to object to direct marketing, which can be done by opting-out of
   direct marketing either through your user account or by opting out via the
   communication itself. You also have a right to object to any profiling to the
   extent that it relates to direct marketing only.

If you are unsure about your rights or are concerned about how your personal
data may be processed, you should contact our Support or your national data
protection supervisory authority.

If you would like to exercise any of your rights then you can do so by
contacting Support. Please be aware that while we will try to accommodate any
request you make in respect of your rights, they are not absolute rights. This
means that we may have to refuse your request or may only be able to comply with
it in part.

When you make a request in respect of your rights, we will require proof of
identification. We may also ask that you clarify your request. We will aim to
respond to any request within one month of verifying your identity, but it may
take longer (we will notify you if this is the case). If we receive repeated
requests, or have reason to believe requests are being made unreasonably, we
reserve the right not to respond.


SUPERVISORY AUTHORITIES

If you have any complaints you have the right to contact your own national data
protection supervisory authority however we do ask that you contact us in the
first instance to allow us the opportunity to address your concerns.


CONTACT US

If you have any questions regarding our use of your personal data, or you would
like to exercise any of your rights, please contact our Support in the first
instance. You can also contact our Data Protection Officer at
dataprotection@flutterint.com.

Privacy Policy last revised: July 26, 2023

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Copyright © 2001-2023, Rational Intellectual Holdings Limited. All rights
reserved.

Operated by TSG Interactive Gaming Europe Limited, a company registered in Malta
under No. C54266, with registered office at Spinola Park, Level 2, Triq Mikiel
Ang Borg, St Julians SPK 1000, Malta. License No. MGA/B2C/213/2011, awarded on
August 1, 2018. Maltese VAT-ID MT24413927. Online gambling is regulated
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Gambling can be harmful if not controlled and may lead to addiction!

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24/10/2023, 21:34:06



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PRIVACY PREFERENCE CENTER

We offer you an online product, we do not sell or broker personal data, we
primarily use the information you share with us to offer a great service and
customer experience. We value your privacy and give you the option to disable
certain cookies and similar technologies if you prefer. Although, doing this can
impact your user experience and the services we offer. You can choose the type
of cookies we use below.
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These cookies are necessary for the online service to function and cannot be
switched off in our systems. They are usually only set in response to actions
made by you which amount to a request for services, such as setting your privacy
preferences, logging in or filling in forms. You can set your browser or device
platform to block or alert you about these cookies, but some parts of the
product will not then work. These cookies and similar technologies generally do
not store any personally identifiable information.

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These cookies allow us to count visits and traffic sources so we can measure and
improve the performance of our site. They help us to know which pages are the
most and least popular and see how visitors and users move around the site or
app. All information these cookies collect is aggregated and therefore
anonymous. If you do not allow these cookies we will not know when you have
visited our site, and will not be able to monitor its performance.

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These cookies enable the websites and apps to provide enhanced functionality and
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