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Privacy Policy

Privacy Policy

Personal data protection policy

1. Who are we?

Betfair Romania Development SRL, a company incorporated under the laws of Romania, having its registered office at Cluj County, Cluj-Napoca Municipality, 21 Decembrie 1989 street, no. 77, A-F buildings, floor 4, registered under company number J2007003396127, and fiscal code RO22201773.

2. Personal data that we process

Betfair Romania Development SRL collect the following types of personal data of all participants:

  • IP address
  • Name and surname
  • Email address
  • Phone number
  • The selected package
  • The team name
  • The company you work for
  • Country of domicile/residence
  • Time zone
  • Data on the number of steps or distance performed
  • Screenshots
  • Shipping address used for the delivery of the package

 

Each of the following companies:

 

Betfair Limited, a company incorporated under the laws of the United Kingdom, with its registered office at One Chamberlain Cs, Birmingham, B3 3AX, United Kingdom and with company number 05140986

Hestview Limited, a company incorporated under the laws of the United Kingdom, with its registered office at One Chamberlain Cs, Birmingham, B3 3AX, United Kingdom and with company number 01100741

Flutter Entertainment Plc, a company incorporated under the laws of Ireland, with its registered office at Belfield office park, Beech Hill Road, Clonskeagh, Dublin 4, D04V972, Ireland and with company number 16956

Flutter Entertainment India LLP, having its registered address at Spire Tower 100, Plot No. 4, Survey No. 83/1, Hyderabad Knowledge City, Raidurg Village, Serilingampally Mandal, R.R. District, Telangana, 500084, India, identification Number: AAH-7004

Stars Interactive Services (Bulgaria) EOOD, UIC 204473764, with seat and management address: 1750 Sofia, Mladost region, 56A Tzarigradsko Shose Blvd

Tsed, Unipessoal LDA, based in Portugal, with registered office at Avenida de Camilo, no. 72 to 112, 4300-095 Porto, legal person number 510148301, registered at the Commercial Registry Office of Porto, under the same number,

processes the following categories of personal data, collected by Betfair Romania Development SRL solely in relation to participants registered in the country in which it has its registered office and does not process the personal data of participants from other jurisdictions/related to another entity herein mentioned:

  • Name and surname
  • Email address
  • The selected package
  • The team’s name
  • The company you work for
  • Data on the number of steps or distance performed
  • Screenshots

 

3. Why do we need this data

We need your personal information to provide you with the following services, under the legal basis of the execution of the provisions of the Walking Month competition Regulation:

 

Using the Walking Month app

Name and surname – we need this data to identify you in the system

Email – we use your email address to log you into our systems and to keep in touch during the competition and afterwards regarding competition results, fundraising results, and the implementation of the funded project

The team’s name – we need this data to identify you in the system

 

Phone number – we will contact you if there are any problems using the application

Country of domicile/residence – we need this data to identify you in the system, to enable registration for the competition and to award the prizes described in the Walking Month competition Regulation and those made available by the contest partners

The company you work for – this information is used either to enable registration for the competition, to award the prizes described in the Walking Month competition Regulation, or for the competition between companies

The selected package – for the delivery of the premium package

Time zone – we use this information to synchronize with the time zone of the IoT devices used

Data on the number of steps or distance performed – to maintain the evolution of your performance and to determine your place in the competition

 

Delivery of the Premium package:

Name – name of a contact person who will receive the delivery

Email – to identify you in the Walking Month app

Phone number – to contact you with details about package delivery

Shipping address – to deliver the package

 

Based on the legitimate interest of the operator to protect its IT infrastructure:

Operation of the Walking Month application

IP address – filtering and detecting internet attacks

 

With your consent, we would also like to process the following personal data:

Screenshot – we use this information only for support – when there is an incident, you can send us a screenshot to detail the problem

Browsing history – we share this information with our partners, as described in the cookies policy, to deliver personalised offers. More information can be found on our cookies page at https://walkingmonth.ro/politica-de-cookies/

 

Data on the number of steps performed

The Walking Month app reads the number of steps from Apple Health for iOS devices and from Health Connect for Android devices

Participants whose fitness trackers sync data automatically with Health Connect or Apple Health will see their steps automatically appear in the WM app, should they grant the necessary permissions

Participants whose fitness trackers do not communicate with Health Connect or Apple Health will manually input the values (number of daily steps) in the Walking Month app, as reported by their tracker app

The data is used to establish the competition leaderboard to award the prizes described in the Walking Month competition Regulation and those made available by the contest partners. See the full rules in the related section of the Walking Month competition Regulation.

 

4. What do we do with this data

Your personal data is processed within the company BETFAIR ROMANIA DEVELOPMENT S.R.L., located in Romania. Your data is hosted and stored by Google, which acts as a processor.

Your personal data is shared with the other organisers, as indicated in the present document, and our partners for the following reasons:

  • Organisers:

Betfair Limited – for the execution of the provisions of the Walking Month competition Regulation, and for using the Walking Month app

Hestview Limited – for the execution of the provisions of the Walking Month competition Regulation and for using the Walking Month app

Flutter Entertainment Plc – for the execution of the provisions of the Walking Month competition Regulation, and for using the Walking Month app

Flutter Entertainment India LLP – for the execution of the provisions of the Walking Month competition Regulation, and for using the Walking Month app

Stars Interactive Services (Bulgaria) EOOD – for the execution of the provisions of the Walking Month competition Regulation, and for using the Walking Month app

Tsed, Unipessoal LDA – for the execution of the provisions of the Walking Month competition Regulation, and for using the Walking Month app

 

  • Partners:

Vitrina Advertising – manages event logistics, comms and delivery of Premium packages on Betfair Romania Development SRL behalf

Stripe – an independent operator that processes the personal data necessary for processing payments securely

Sameday SRL – for delivery of Premium Packages in Romania

Asociatia Educalise – a non-profit association. They are signing contracts with all the participating companies in the companies challenge, ensuring financial transparency and compliance and to keep you up to date with the use of funds offered

Sendgrid – sends essential comms (payment confirmations, invitations, updates via newsletter)

 

Your personal browsing history data is transmitted to our partners, as described in the cookie policy. Please see the description of these partners

 

5. For how long do we keep this data

Your personal data, from those that are included in the financial-accounting documents or in documents that are annexed to the financial-accounting documents, will be kept for 10 years according to the provisions of the article 38 of Annex 1 to Order no. 2634/2015 on financial-accounting documents, issued by the Ministry of Public Finance and will not be accessed for any purpose other than the legal purpose for which they are archived. After 10 years, these data will be destroyed. Your personal data from cookies is kept for the lifespan of the cookie or until you delete them from your device.

Your personal data from the Walking Month account will be kept for 3 years since your last account activity, based on the operator’s legitimate interest in keeping users in-app for the following editions of Walking Month, as well as to be able to respond to any requests submitted by participants after the conclusion of the competition.

 

6. Data protection

Security procedures are in place to protect the confidentiality of your data. All communication between the app and the server is encrypted.

 

  • the user (name, daily number of steps, total number of steps, daily steps from the previous competition, total number of steps from the previous competition)
  • team from which the user is part of (name, daily number of steps, total number of steps)
  • all competition users (total number of steps for the leaderboard)
  • Walking Moth authenticated administrators (name, email address, daily number of steps, total number of steps, daily steps from the previous competition, total number of steps from the previous competition)

 

7. Your rights

If you have reason to believe that any personal data we hold about you is incorrect or incomplete, you have the following rights:

  • Right of access – you have the right to request access to the personal data we hold about you. To submit an access request, you may send an email to dp@flutter.com with the subject line „Access Request”, including your full name and the email address associated with your account. We may request additional information to verify your identity. Upon receipt of your request, we will respond within 30 days.
  • Right to rectification – you have the right to request the correction of inaccurate or incomplete personal data. To submit a rectification request, please contact us at dp@flutter.com with the subject line „Rectification Request”, specifying the data you wish to correct and providing supporting information where applicable. We will respond within 30 days.
  • Right to erasure (right to be forgotten) – you have the right to request the deletion of your personal data at any time. To submit a data deletion request, you may send a request to dp@flutter.comwith the subject line „Data Deletion Request”, including your full name and the email address associated with your account. Upon receipt of your request, we will confirm deletion within 30 days. Please note that certain data may be retained where we are required to do so by law (e.g., financial accounting records retained for 10 years, as outlined above).
  • Right to restriction of processing – you have the right to request the restriction of processing of your personal data in certain circumstances (e.g. where you contest the accuracy of the data or object to processing). To request a restriction, please email dp@flutter.com with the subject line „Restriction Request”, including relevant details. We will inform you once the restriction is applied.
  • Right to object – you have the right to object to the processing of your personal data where such processing is based on legitimate interests or for direct marketing purposes. To exercise this right, please contact us at dp@flutter.com with the subject line „Objection Request”, specifying the processing you object to. We will assess your request and respond within 30 days.
  • Right to data portability – you have the right to receive your personal data in a structured, commonly used and machine-readable format, and to request its transmission to another controller where technically feasible. To submit a data portability request, please email dp@flutter.com with the subject line „Data Portability Request”, including your full name and account details. We will respond within 30 days.

To withdraw consent given for the processing of screenshots, please contact us at dp@flutter.com.

If you would like to file a complaint about how we have processed your personal data, please contact your data protection officer at the following email address: dp@flutter.com. The Data Protection Officer will contact you to resolve the issue outlined above.

You can also contact the following authorities and file a complaint:

  • For Romania: National Authority for the Supervision of Personal Data Processing at dataprotection.ro, or at the following address: B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, postal code 010336, Bucuresti, Romania, email address: anspdcp@dataprotection.ro, dpo@dataprotection.ro, or phone number: +40.318.059.211, +40.318.059.212