WHAT IS THIS PRIVACY POLICY FOR?

When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

Twenty3, as served by All Sports Whispers Ltd, cares about your privacy. We build a range of services that help millions of people to explore and interact with sports related content. These services include:

Website (https://www.footballwhispers.com/ and https://www.twenty3.sport/ )

Mobile apps (Football Whispers)

Products we create such as widgets, components, and graphics

The Content Toolbox (toolbox.twenty3.sport)

We collect and use personal information only as needed in order to provide you with these services.

When you use these services you’re trusting us with your information. We take this responsibility seriously and this Privacy Policy is meant to help you understand what information we collect, why we collect it, and how you can update, manage, export, and delete your information.

If you have any questions about this Privacy Policy you can contact us here privacy@twenty3.sport.

Twenty3 and its owners take a proactive approach to user privacy and ensure the necessary steps are taken to protect your privacy throughout your visiting experience. The Twenty3 websites and apps comply to all UK national laws and requirements for user privacy.

An anonymised string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service Privacy Policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

TWENTY3 AS A DATA PROCESSOR

If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Our valid lawful bases for the processing of personal data are:

  • consistent with your consent, which you may withdraw or revoke at any time by contacting us on privacy@twenty3.sport.
  • as necessary for the purposes of the legitimate interests pursued by the controller or by a third party unless such interests are overridden by the interests or fundamental rights and freedoms of the data subject, which require protection of personal data, in particular if the data subject is a child.

AGE RESTRICTIONS

Our Services are currently available only for those over the age of 16. Our Services are not targeted to, intended to be consumed by or designed to entice individuals under the age of 16. If you know of or have reason to believe anyone under the age of 16 has provided us with any personal data, please contact us on privacy@twenty3.sport.

WHAT DATA DOES TWENTY3 COLLECT?

YOUR USAGE

We collect information about how you use our Products, such as the types of content you view or engage with; the features you use; the actions you take; and the time, frequency and duration of your activities. For example, we log when you’re using and have last used our Products, and what posts you view and which features you use on our Products.

SUBSCRIBERS

For users who have logged into the website / app we store:

First name

Last name

Email

Facebook user ID

Firebase user ID

We also keep a record of the teams / players you follow, and your votes on whispers.

HOW DOES TWENTY3 USE THIS DATA?

Our websites and apps collect data to provide better services to our users; we will use any information submitted to provide you with further information about the products / services we offer or to assist you in answering any questions or queries you may have submitted.

This includes using your details to subscribe you to any email newsletter program the websites operate but only where this was made clear to you and your express permission was granted by choosing to opt-in and give your informed consent when submitting any form to email process.

Your details are not passed on to any third parties except where we have agreements with trusted third party service providers (sub processors) as necessary for them to perform services on our behalf. These are:

  • Amazon Web Services
  • Auth0
  • Mixpanel
  • Google Analytics (within which all data is aggregated and anonymised)
  • No personal details are passed on to any other third parties nor shared with companies / people outside of the company that operates these websites.

EMAIL NEWSLETTER

The Football Whispers website and apps operate an email newsletter program, used to inform subscribers about products and services supplied by this website. You can subscribe through an online automated process should you wish to do so, but do so at your own discretion and provide your consent at time of subscription.

Subscriptions are taken in compliance with UK spam laws detailed in the relevant privacy and electronic communications regulations. All personal details relating to subscriptions are held securely and in accordance with the relevant legislation. Your personal details will never be shared outside of the terms of Email marketing campaigns published by the Football Whispers website, apps or its owners may contain tracking facilities within the actual email. Subscriber activity is tracked and stored in a database for future analysis and evaluation. These databases are from trusted third party service providers (sub processors) with whom we have signed contracts stating compliance with the General Data Protection Regulation.

This information is used to refine future email campaigns and supply you with more relevant content based around your activity. In compliance with UK spam laws and privacy and electronic communications regulations subscribers are given the opportunity to unsubscribe at any time through an automated system. This process is detailed at the footer of each email campaign. Alternatively you can email us on privacy@twenty3.com

USE OF COOKIES

Our websites use cookies to better your experience while visiting the websites. Where applicable the websites use a cookie control system allowing you on your first visit to the website to allow or disallow the use of cookies on your computer / device. This complies with recent legislation requirements for websites to obtain explicit consent from users before leaving behind or reading files such as cookies on a user’s computer / device.

Cookies are small files saved to your computer’s hard drive that track, save and store information about your interactions and usage of the website. This allows the website, through its server to provide you with a tailored experience within this website.

If you wish to deny the use and saving of cookies from this website on to your computer’s hard drive, you should take necessary steps within your web browsers security settings to block all cookies from this website and its external serving vendors.

The websites use tracking software to monitor their visitors to better understand how they use them. This software is provided by Google Analytics which uses cookies to track visitor usage. The software will save a cookie to your computer’s hard drive in order to track and monitor your engagement and usage of the website, but will not store, save or collect personal information. You can read Google’s privacy policy here for further information http://www.google.com/privacy.html.

Other cookies may be stored to your computers hard drive by external vendors when this website uses referral programs, sponsored links or adverts. Such cookies are used for conversion and referral tracking and typically expire after 30 days, though some may take longer. No personal information is stored, saved or collected.

If you wish to find out more about how to opt out of interest-based advertising click here [or if located in the European Union click here]. Please note you will continue to receive generic ads.

CONTACT & COMMUNICATION

Users contacting our websites and/or their owners do so at their own discretion and provide any such personal details requested at their own risk. Your personal information is kept private and stored securely until a time it is no longer required or has no use, as detailed in relevant UK legislation. Every effort has been made to ensure a safe and secure form to email submission process but advise users using such form to email processes that they do so at their own risk.

SUBJECT ACCESS REQUEST

Under new legislation you may request a copy of personal information held about you by Twenty3 for free and within 40 days. If you would like a copy of the information held on you please contact us by emailing privacy@twenty3.sport.

RIGHT OF ERASURE

You may also exercise your ‘right to be forgotten’ which we will honour by deleting all your personal data within one month of the request. Please contact us with any requests to be forgotten on privacy@twenty3.sport.

EXTERNAL LINKS

Although the Football Whispers and Twenty3 websites only look to include quality, safe and relevant external links, you are advised to adopt a policy of caution before clicking any external web links mentioned throughout these websites. (External links are clickable text / banner / image links to other websites, similar to; www.websitename.co.uk.)

The owners of these websites cannot guarantee or verify the contents of any externally linked website despite their best efforts. You should therefore note that you click on external links at your own risk and these websites and their owners cannot be held liable for any damages or implications caused by visiting any external links mentioned.

ADVERTS AND SPONSORED LINKS

The websites may contain sponsored links and adverts. These will typically be served through our advertising partner, Snack Media, who have a detailed privacy policy relating directly to the adverts they serve – you can see this here. Clicking on any such adverts will send you to the advertiser’s website through a referral program which may use cookies and will track the number of referrals sent from this website. This may include the use of cookies which may in turn be saved on your computer’s hard drive. You should therefore note that you click on sponsored external links at your own risk and these websites and their owners cannot be held liable for any damages or implications caused by visiting any external links mentioned.

SOCIAL MEDIA PLATFORMS

Communication, engagement and actions taken through external social media platforms that these websites and their owners participate on are custom to the terms and conditions as well as the privacy policies held with each social media platform respectively.

You are advised to use social media platforms wisely and communicate / engage upon them with due care and caution in regard to your own privacy and personal details. Neither the Twenty3 website or the Football Whispers website and apps, nor their owners will ever ask for personal or sensitive information through social media platforms and encourage users wishing to discuss sensitive details to contact them through privacy@twenty3.sport.

The Twenty3 website and Football Whispers website and apps may use social sharing buttons which help share web content directly from web pages to the social media platform in question. Users are advised before using such social sharing buttons that they do so at their own discretion and note that the social media platform may track and save your request to share a page respectively through your social media platform account.

SHORTENED LINKS IN SOCIAL MEDIA

The Twenty3 website and Football Whispers website, apps and their owners through their social media platform accounts may share web links to relevant web pages. By default some social media platforms shorten lengthy urls web addresses (this is an example: http://goo.gl/KYkxeS). Users are advised to take caution and good judgement before clicking any shortened urls published on social media platforms by these websites and their owners. Despite the best efforts to ensure only genuine urls are published many social media platforms are prone to spam and hacking and therefore these websites and their owners cannot be held liable for any damages or implications caused by visiting any shortened links.

COMPLIANCE & COOPERATION WITH REGULATORS

We regularly review this Privacy Policy and make sure that we process your information in ways that comply with it. We change this Privacy Policy from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent. We always indicate the date the last changes were published and we offer access to archived versions – please contact us on privacy@twenty3.sport. If changes are significant, we’ll provide a more prominent notice (including, for certain services, email notification of Privacy Policy changes).

Last updated: 3 June 2019