Privacy Notice

ITV Odds Finder (the “App”) is operated by funteron Limited (“funteron”, “we”, “us” or “our”).

funteron Limited is a company registered in Northern Ireland with company number NI725325, registered office at Unit A4 Harbour Court, 3 Heron Road, Belfast, Northern Ireland, BT3 9HB. funteron is registered with the Information Commissioner’s Office under registration ZC384757.

ITV Odds Finder name and associated trade marks are owned by ITV Broadcasting Limited (an ITV group company) and are used by funteron under licence. ITV plc is not the operator of the App and is not the data controller for personal data collected through the App, except where you choose to receive marketing from ITV (see section 2.3 below).

If you have any questions about this Notice or your personal data, please contact us at dataprotection@funteron.com.

This Notice involves three controller relationships.

2.1 funteron as Independent Data Controller

funteron is the Independent Data Controller for personal data collected through the App, except as set out in sections 2.2 and 2.3 below.

2.2 Endava in two capacities

Endava (UK) Limited (“Endava”), our technology services provider, acts in two distinct capacities in respect of personal data processed through the App:

• As funteron’s processor for cloud infrastructure, hosting, database management, security monitoring and engineering activities, under a Data Processing Agreement with funteron. In this capacity Endava acts on funteron’s instructions.
• As joint controller with funteron for limited platform analytics and product design activities, under a Joint Controller Agreement with funteron. In this capacity funteron and Endava jointly determine the purposes and means of processing for these activities.

A summary of the joint controller arrangement, as required by Article 26(2) UK GDPR, is set out at section 13.

2.3 ITV as Independent Data Controller (only if you opt in)

If you choose to opt in to receive marketing from ITV at registration, your contact details will be shared with ITV plc and ITV will process those details as an Independent Data Controller for its own marketing purposes, in accordance with the ITV Privacy Notice (Marketing). funteron does not share your data with ITV unless you actively opt in.

2.4 Operators

When you click through from the App to a licensed gambling operator, that operator collects any further personal data directly under its own privacy policy, as Independent Data Controller. funteron has no joint control over the processing of data collected by operators following a click-through.

3.1 Registration data

• First name and surname
• Email address
• Mobile telephone number
• Postcode or region
• Date of birth (for age verification)
• Marketing consent preferences
• Unique user identifier

3.2 Usage and referral data

• Device type and browser type
• IP address
• Interactions with App features
• Click-through activity to operator sites
• Referral source and attribution data
• Session timestamps and navigation data

3.3 Communications data

• Customer support enquiries
• Feedback and complaint records

4.1 To provide the App

Lawful basis: performance of a contract (Article 6(1)(b) UK GDPR).

Account registration and management, authentication and security, customer support.

4.2 Age verification

Lawful basis: performance of a contract and compliance with a legal obligation (Articles 6(1)(b) and 6(1)(c) UK GDPR).

We process your date of birth to confirm you are 18 or over before allowing access to the App.

4.3 Referral tracking and revenue attribution

Lawful basis: legitimate interests (Article 6(1)(f) UK GDPR).

We track click-through activity to operators in order to attribute referral commissions and to report referral data to operators for billing and reconciliation. We have assessed that this processing does not override your interests, rights and freedoms, taking into account the nature of the App and your reasonable expectations as a user of a free odds comparison service. A Legitimate Interests Assessment is held on file.

4.4 funteron marketing communications

Lawful basis: consent (Article 6(1)(a) UK GDPR and Regulation 22 PECR).

We will only send you marketing about the App, betting odds, promotions and related services if you have given specific consent at registration (see section 6). You can withdraw consent at any time.

4.5 ITV data sharing for ITV marketing (only if you opt in)

Lawful basis: consent (Article 6(1)(a) UK GDPR).

We will only share your name, email address and mobile number with ITV if you have given specific consent at registration (see section 6). If you do, ITV will use your data as an Independent Data Controller in accordance with the ITV Privacy Notice (Marketing). You can withdraw consent at any time.

4.6 Platform analytics and service improvement

Lawful basis: legitimate interests (Article 6(1)(f) UK GDPR).

funteron and Endava (acting as joint controllers, see section 2.2) process pseudonymised engagement and usage data to understand how the App is used and to improve it. We have assessed that this processing does not override your interests, rights and freedoms. A Legitimate Interests Assessment is held on file.

4.7 Legal and regulatory compliance

Lawful basis: compliance with a legal obligation (Article 6(1)(c) UK GDPR).

We may process or disclose data where required to comply with applicable law, regulatory requirements, court orders or law enforcement requests.

The App uses cookies and similar tracking technologies in compliance with the Privacy and Electronic Communications Regulations 2003 (PECR) and the UK GDPR.

Strictly necessary cookies are set without consent on the basis of contract or legitimate interests, as appropriate. These are required for the App to function.

Non-essential cookies, including tracking technologies, software development kits, pixels and analytics tags, are set only where you have given specific consent through our consent management platform. You can review your preferences at any time through the cookie preferences link in the App or on our website.

Where marketing consent is required, we obtain it via separate, unticked checkboxes at the point of registration.

Consent A (funteron marketing) and Consent B (ITV data sharing for ITV marketing) are separate, specific and unbundled. You can give one, both or neither, and your choice does not affect access to the App.

You can withdraw either consent at any time by emailing dataprotection@funteron.com or by using the unsubscribe link in any marketing communication you receive. Withdrawal of consent does not affect the lawfulness of any marketing carried out previously.

We retain records of the date and time of consent, the wording shown at the time and the channels consented to, in line with our Data Retention Schedule (see section 9).

We do not sell your personal data. We share it only in the following circumstances:

7.1 Endava (UK) Limited

In the dual capacity described in section 2.2.

7.2 Amazon Web Services EMEA SARL

Provides cloud infrastructure, hosting and database services as funteron’s processor. Processing takes place in the AWS eu-west-1 region in Dublin, Ireland.

7.3 ITV

Only if you have given Consent B (see section 4.5).

7.4 Licensed gambling operators

When you click through to an operator, referral attribution data is shared with that operator for the purpose of tracking and paying referral commissions. The operator collects any further data directly under its own privacy policy.

7.5 Regulators and law enforcement

Where required by law or by a competent regulator, including the Information Commissioner’s Office and any applicable gambling regulator.

Personal data is processed within the United Kingdom and the European Economic Area only. funteron and Endava operate from the United Kingdom. Cloud infrastructure is provided by Amazon Web Services EMEA SARL and processing takes place in the AWS eu-west-1 region in Dublin, Ireland.

Transfers between the United Kingdom and the European Economic Area are covered by the European Commission’s adequacy decision for the United Kingdom of 28 June 2021 and by the United Kingdom’s adequacy regulations recognising the European Economic Area.

We do not transfer your personal data to any country outside the United Kingdom and the European Economic Area in connection with the App.

We retain personal data only for as long as necessary for the purposes set out in this Notice or as required by law. The following periods apply in line with the funteron Data Retention Schedule:

• Account and registration data, age verification data: account life plus 6 years. We are required to keep account records under the standard limitation period for contract claims under the Limitation Act 1980.
• Hashed authentication credentials: account life only.
• PECR Consent A and B records, including consent withdrawal records: account life plus 6 years from the date of consent or withdrawal. We retain these for evidence of valid consent at the time any marketing was sent.
• Pseudonymised platform analytics: retained in identifiable form for a defined period. After that period, data is anonymised or deleted.
• Anonymised analytic aggregates: indefinitely. Anonymised data is not personal data under UK GDPR.
• Referral attribution data: 6 years from the date of referral, for commercial reconciliation and audit purposes.
• Customer support correspondence: 24 months from matter closure.
• Personal data breach records, Data Subject Request records: 3 years minimum.

If you delete your account, we will delete or anonymise your personal data within a reasonable period, except where we are required to retain it by law or by a legal hold.

Under the UK GDPR you have the following rights:

To exercise any right, email dataprotection@funteron.com. We will respond within one calendar month. We may extend this by a further two months for complex requests, in which case we will tell you within the first month.

We may request reasonable information to verify your identity before acting on a request, in line with Article 12(2) UK GDPR. We may refuse a request or charge a reasonable fee where it is manifestly unfounded or excessive.

We implement appropriate technical and organisational measures to protect your personal data, including:

• encryption in transit and at rest
• role-based access controls
• multi-factor authentication
• logging and monitoring
• regular security testing
• contractual security commitments from our processors

Our information security framework is aligned with recognised standards. Further detail is set out in our Internal Data Handling Policy.

If we become aware that we have inadvertently collected personal data from a person under 18, we will delete that data without delay. If you become aware that this may have occurred, contact us at dataprotection@funteron.com so that we can investigate and delete the data.

As required by Article 26(2) UK GDPR, the following is a summary of the essential terms of the Joint Controller Agreement between funteron and Endava:

• Joint controllers: funteron Limited and Endava (UK) Limited.
• Scope of joint control: product design, releases and platform analytics. This relates exclusively to funteron’s instructions in those areas. It does not extend to other processing activities, for which Endava acts as funteron’s processor.
• Primary contact for data subjects: funteron (contact dataprotection@funteron.com). You may also exercise your rights against either joint controller, but funteron will act as the primary point of contact.
• Lead notifier to the Information Commissioner’s Office for personal data breaches: funteron Limited.

You may request a copy of the essence of the full Joint Controller Agreement by emailing dataprotection@funteron.com.

If you are concerned about your gambling or that of someone you know, the following free and confidential services are available:

• National Gambling Helpline: 0808 8020 133 (24 hours, 7 days a week)
• BeGambleAware: www.begambleaware.org
• GamCare: www.gamcare.org.uk
• GAMSTOP: www.gamstop.co.uk (national self-exclusion, Great Britain)
• Gambling Therapy: www.gamblingtherapy.org

If you are unhappy with how we have handled your personal data, please contact us first at dataprotection@funteron.com and we will look into the matter. You have a right to lodge a complaint with the Information Commissioner’s Office at any time:

Information Commissioner’s Office: www.ico.org.uk · 0303 123 1113

We may update this Notice from time to time. Material changes will be notified within the App or by email before the change takes effect. The date of the most recent change is shown at the top of this Notice.

For any privacy-related questions or to exercise your rights, please contact us using the details below.