Recast Privacy Policy

Last Updated: July 2020

1. Introduction

This privacy policy (“Privacy Policy”) applies to the use of Recast Sports Ltd's (“Recast”, “we”, “us” or “our”) platform and website available at https://the.recast.app (the “Service”) and in relation to any query or communication that you may send to us, or that we may collect about you when you use the Service. Our registered office is at 36 Spital Square, Fourth Floor, London, United Kingdom, E1 6DY. We are a company registered in England and Wales, with company number 11507205.

If you have any questions or comments about this Privacy Policy, please contact us at privacy@recast.app.

We are committed to protecting and respecting your privacy. This Privacy Policy explains the basis on which personal data we collect from you will be processed by us or on our behalf. Where we decide the purpose and means for which personal data you supply through this Service is processed, we are the “controller” for the purposes of the General Data Protection Regulation 2016/679 (GDPR) and the UK Data Protection Act 2018.

Please read this Privacy Policy carefully as it contains important information about the following:

This Privacy Policy should be read in conjunction with our terms and conditions (“Terms”), available here https://recast.app/about/terms.

The Service may contain hyperlinks to services owned and operated by third parties. These third party services may have their own privacy policies and we recommend that you review them. They will govern the use of personal data that you submit or which is collected by cookies and other tracking technologies whilst using these services. We do not accept any responsibility or liability for the privacy practices of such third party services and your use of these is at your own risk.

We may make changes to this Privacy Policy in the future, which will be made available here. You should check here from time to time to ensure you are aware of any changes. Where appropriate, we may notify you of changes by email or through the Service.

2. Personal Data We May Collect About You

We may collect and process the following personal data from you when you use our Service:

Information provided by you when creating an Account on the Service (“Submitted Information”)

Information that may be provided by you when you contact us for support (“Contact Information”)

Payment Information

When you deposit Funds into your Account to purchase Casts, when we send you a refund or when we execute your withdrawal request, we use the following third-party payment systems, which transact all our payments. We have no access to your card payment information. See their websites to find out more about the way they collect and process this information:

Content Information

When Users upload Content to the Platform, the Content may contain personal and non-personal information. This could include information in or about the Content, such as the location of a photo, video or live stream or the date a file was created, or anything else you decide to communicate by using our Service.

Information collected by Cookies and similar Technologies (“Analytics”)

Our Service uses cookies, and other similar mechanisms to collect log and analytical information, to help analyse how visitors use the Service, to compile statistical reports on Service activity, improve our marketing function and personalise the content and advertisement you see.

Please see our cookie policy at Cookies for more information.

When you visit our Service, our analytics service providers may collect the following data, which will almost always be anonymised and aggregated before reporting back to us:

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, please see our cookie policy.

Information collected via our Social Media channels

(“Social Media Information”) The Service contains links to our channels on Facebook, Instagram, Twitter, LinkedIn, TikTok and Snapchat. These third-party websites have their own respective privacy policies (which we would advise you to read) for which those sites are solely responsible. Should you visit our social media pages and choose to follow or connect with us on social media, we may receive personal information from the social media providers (depending on your social media privacy settings), including:

Job Applications

As part of any recruitment process, we collect and process personal data relating to job applicants. Such data may include:

We may collect this information in a variety of ways. For example, personal data might be contained in application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment, including online tests.

3. How we use your personal data?

To provide the Service to you

We will process data about you (including the Submitted Information) to process your account registrations and to deliver our Service to you under the Terms.

The processing of information in this way is necessary, for us to provide you with updated parts of the Service (such as for security patches or content updates) and to ensure the Service delivers the features promised and functions properly. For these purposes, we rely upon the legal basis of performance of a contract (being performance of the Terms) and our legitimate interests (being our commercial interests in providing enhanced services and functionality to you).

To respond to your enquiries and requests for support

We will process personal data about you (including your Contact Information) so that we are able to properly respond to your enquiries and support requests, in accordance with the Terms.

For the above purposes, we rely upon the legal basis of performance of a contract (being our Terms) and our legitimate interests, being our commercial interests to respond to your queries and requests for support.

To keep you up to date about Content and our Service

Where you have consented, or where it is otherwise lawful for us to do so, we may use your personal data (including your interests and Content that you view) to send you push notification, SMS and/or emails in order to keep you informed with news and updates about Content and our Service.

In line with the legitimate interest we have in promoting our business, we will use the email address you gave us via the Service to provide you with this information.

There may also be circumstances where we will ask you for your prior consent in respect of our use of your personal data for direct marketing concerning our Service and the services of our partners. For example, we may run partnerships with other companies and brands in the sports and ticketing space with whom we may share your personal data subject to your prior consent.

Where we rely upon your consent to do these activities, you can withdraw your consent at any time upon email to privacy@recast.app.

We hope that you would like to receive our updates, but we do not want to send you emails that are not of interest for you. If you would like to be removed from our mailing list please let us know by clicking unsubscribe at the bottom of any marketing email that you receive from us.

Operating our Social Media channels

We may process personal data (including the Social Media Information), to engage with users on our social media channels and to find out how users interact with our social media channels.

We process this personal data on the basis of our legitimate interests, being our interests in engaging with our users and promoting the commercial success of our Service (including by improving our advertising and marketing).

Analytics

We may process personal data (including the Analytics), to find out how users visit and interact and use our Service.

We process this personal data on the basis of your consent (where applicable) or our legitimate interests, being our interests in promoting and improving our Service and their commercial success (including by improving our advertising and marketing).

To prevent fraudulent or illegal activity and other unacceptable activity

We will process personal data about you for our legitimate interests of ensuring that your use of our Service is lawful and in compliance with our Terms, to prevent disruption to our Service, to enforce our rights, to protect any individual or otherwise to ensure our compliance with our legal obligations.

To help us to understand usage of the Service, improve the Service and to help us to fix any problems

We may process personal data (including your interests) about you so that we can understand usage of our Service, analyse and improve our Service and develop new services or new parts thereof.

This processing is necessary for us to pursue our legitimate interests, being our commercial interests in:

Where our processing activity relates to detecting and fixing problems with the Service, we also rely upon the legal basis of performance of a contract (being our Terms).

To help us personalise your experience of the Service

We may process personal data (including Submitted Information, Analytics and Contact Information) to personalise your experience, interaction and use our Service. By doing so, we can provide you with editorial content and/or advertising that we believe is more relevant to your interests. This includes showing you advertisements for third party services. You can adjust your settings at any point.

Please note that we use third party providers of adverts and the adverts’ content is provided by these third parties and not us. Analytics information may be shared with advertisers on an anonymous aggregate basis. We may also publicise anonymous, aggregate statistics through our website or other channels although this will not include your personal data.

We will ask you for your prior consent in respect of these activities. If you prefer that we do not use your data in this way, you can withdraw your consent at any time upon email to privacy@recast.app

Recruitment

If you apply for a job with us, we will use your personal data to conduct our recruitment process, including assessing your skills, qualifications and suitability for the role and/or communicating with you about the recruitment process.

We need to process this information to take steps at your request prior to entering into a contract with you.

In some cases, we need to process personal data to ensure that we are complying with our legal obligations. For example, we are required to check a successful applicant’s eligibility to work in the location of our offices before employment starts.

We also have a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows us to manage the recruitment process, assess and confirm an applicant’s suitability for employment and decide to whom to offer a job.

4. Data sharing

We will share your information with third parties only in the ways that are described in this Privacy Policy

Group members, personnel, suppliers or subcontractors: We keep your information confidential, but may disclose it to any member of our group (which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006), our personnel, suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this Privacy Policy. However, this is on the basis that they do not make independent use of the information and have agreed to safeguard it.

Merger or acquisition: If we are involved in a merger, acquisition, or sale of all or a portion of its assets, any third party to which we sell or transfer our assets to will have the right to continue to use the personal and other information that you provide us in the manner set out in this Privacy Policy.

Required by law: In addition, we may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).

Enforcement: We may also disclose your personal information to third parties in order to enforce or apply the terms of agreements, to investigate potential breaches, or to protect the rights, property or safety of FTG, our customers, or others.

Marketing partners: We may share your personal information with third parties for targeted advertising purposes, including for measurement and analytics on campaign performance, personalization, modelling, on-boarding and linkage. These include Google Ad Manager and ESB Connect

Data management providers: We may share your personal information with our data management providers to analyses and organise data into user groups and audiences, based on factors such as age, gender, geography, interests and online actions to deliver a personalised user experience. These includes Lotame

5. YOUR RIGHTS IN RELATION TO PERSONAL DATA WHICH WE PROCESS RELATING TO YOU

You have the following rights over the way we process personal data relating to you, as set out in the table below. We aim to comply without undue delay, and within one month at the latest.

Please send your requests to privacy@recast.app.

Ask for a copy of data we are processing about you and have inaccuracies corrected

You have the right to request a copy of the personal information we hold about you and to have any inaccuracies corrected. If we provide you with such information, we will not charge you for this, unless your request is “manifestly unfounded or excessive.” Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.

Object to us processing data about you

You can ask us to restrict, stop processing, or to delete your personal data if:

Obtain a machine readable copy of your personal data, which you can use with another service provider

Make a complaint to a Supervisory Authority

6. DATA RETENTION

In accordance with data protection laws and good commercial practice, we do not retain data in a form that permits identification of the person(s) to whom it relates for any longer than is necessary.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

We delete accounts that have been dormant for a period 24 months.

7. CHILDREN

We do not use our Service to knowingly solicit information from, or market to, children under the age sixteen (16).

As further set out in our Terms, you’re only allowed to use the Service and send personal information to us if you are either sixteen (16) years or older. If you are between sixteen (16) and eighteen (18) years old you, you must review our Terms with your parent or guardian, have them accept it on your behalf, as well as approve your use of the Service.

In the event that we learn that we have collected personal data from children under the age sixteen (16), we will delete that information as quickly as possible. If you believe that we might have any information from or about children under the age sixteen (16), please contact us at privacy@recast.app.

8. SECURITY

We will take reasonable and appropriate technical and organisational measures to ensure a level of security appropriate to the risk that could be encountered via the use of our Service, taking into account the likelihood and severity those risks might pose to your rights and freedoms.

In particular, we will take precautions to protect against the accidental or unlawful destruction, loss or alteration, and unauthorised disclosure of or access to the personal data transmitted, stored or otherwise processed by us.

Please be aware that, while we make the security of our Service and your personal data a high priority, no security system can prevent all security breaches.

Unfortunately, the transmission of information via the internet is not completely secure. We do our best to protect your personal data, but we cannot always guarantee the complete security of your data transmitted through our Service. Subject to applicable law, the sharing of your personal data with us and any transmission of the data is at your own risk.

9. INTERNATIONAL DATA TRANSFERS

The data we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff that operate outside the EEA and work for us or our suppliers. These staff may be engaged in the maintenance of the Service, and the provision of support services. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

Where your personal data is transferred outside of the EEA to a territory not subject to an adequacy decision by the European Commission, we have agreements in place with the relevant parties which include either (i) standard data protection clauses adopted by the relevant data protection regulator and approved by the European Commission or (ii) standard data protection clauses adopted by the European Commission, to ensure that appropriate safeguards are used to protect your personal data. Alternatively, we may put in place other appropriate safeguards. If you require more information about these safeguards, you can contact us at privacy@recast.app.

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