The Financial Trading Comparison and Cashback Website!

Introduction

Spread Cashback (SCB) respects your privacy and is committed to protecting your personal data.

This version of the Privacy Policy comes into effect on the 24th May 2018.

1. Important information and who we are

Purpose of this Privacy Notice

This privacy notice aims to give you information on how SCB collects and processes your personal data through your use of the website at www.spreadcashback.com or any subdomains, whether accessed via a computer, telephone, mobile or any other device.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements any other notices and is not intended to override them.

Who we are

Spread Cashback (SCB) is a trading name of Atomic Trading Solutions Limited, a UK incorporated company registered in England and Wales with company number 8511003.

Third Party Links

This website includes links to third-party websites. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy notice of every website you visit.

Sometimes we may include services on the Website that are provided by licensed third-party gambling operators. Through providing these services to you these third parties may collect your information, and for certain purposes, they will be responsible for their collection and use of your information. These third parties may need to retain and use your information for the purpose of complying with applicable gambling laws and the terms of their gambling licences. We will always inform you before you receive any service on the Website that is provided by a third-party gambling operator and we will explain how they collect and use your information.

 2. The Data we collect about you 

General

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

• Identity Data includes first name, last name, username or similar identifier, title, date of birth and country of residence.
• Contact Data includes address, email address and telephone numbers.
• Financial Data includes bank account and online payments system details.
• Transaction Data includes details about payments to you and other information about your bets placed with us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data includes your username and password, and your transactional history
• Marketing and Communications Data includes your preferences in receiving marketing from us your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).

 3. How is your Personal Data collected? 

We use different methods to collect data from and about you, including through:

Direct interactions

You may give us your Identity, Contact, Transaction or Financial Data by filling in forms or by corresponding with us via our website, email or otherwise. This includes personal data you provide when you:

• apply or create an account with us;
• modify or update an account you hold with us;
• enter a competition, promotion or survey;
• provide us with feedback; or
• contact or communicate with us directly for any reason

Automated technologies or interactions

As you interact with SCB, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other Sites employing our cookies. Please see our Cookie Policy for further details. As you navigate our Site, we may collect Usage Data, Profile Data and Marketing and Communications Data as specified by you from time to time. 

Essential Third parties

In order to facilitate the cashback service, we need to receive personal data about you from our Broker Partners based both inside and outside the EU. This information includes your name, account number, and transactional data.

To help improve the service we provide and the functionality of our service, we may receive personal data about you from various third parties as set out below:

a) Technical Data from analytics providers such as Google based outside the EU;

b) Contact and Technical Data where you join our Site as a result of our marketing activities involving third parties.

4. How we use your Personal Data 

 Overview

We will only use your personal data when the law allows permits us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you. You have the right to withdraw consent to marketing at any time by Contacting us at support@spreadcashback.com

Purposes for which we will use your Personal Data

These are the legal bases we have for holding and processing your personal data:

• Contract: To enter into or perform a contract with you
• Legitimate Interest: For our (or third parties’) legitimate interests, as long as they aren’t overridden by your interests and rights
• Consent: Your consent
• Obligation: To comply with our legal obligations

And here is how we use your personal data, and our relevant legal basis for doing so:

When you register with us, we obtain your Identity and Contact Data. That Identity and Contact Data may be supplemented over time with other information, such as Transaction Data, and additional or updated Identity and Contact Data. We use this information to maintain your registration with SCB and administer our relationship with you. Our basis: Contract.

If you enter into a transaction with SCB, or provide us with details of a transaction (such as where you are seeking to obtain Cashback on a Broker Account, we may use your Identity, Contact, Financial and Transaction Data to track your transaction and to receive and process Referral Fees. Our basis: Contract and Legitimate Interest (to receive payment of sums owed to us and you).

We use the Cashback Payout Method you have registered in your Account as part of your Financial Data to process and distribute Cashback to you. Our basis: Contract

Where a claim or complaint is raised as to Cashback that may be owed, we may use your Identity, Contact, Financial and Transaction Data, to process that claim or complaint. Our basis: Contract and Legitimate Interest (to receive payment of sums owed to us and you).

We will also use Identity and Contact Data, Payment Data and Transaction Data to monitor transactions with the objective of helping to prevent fraud. Our basis: Legitimate Interest (fraud-prevention).

Where you opt to receive marketing communications from us, we will use your relevant Marketing and Communications Data to communicate that marketing to you. Our basis: Consent.

We retain records of our financial transactions and contracts with you in order to maintain adequate accounting records and meet legal requirements. Our basis: Obligation.

We will use your Marketing and Communications Data and Identity and Contact Data to keep you informed of important changes to our relationship with you, such as by notifying you of changes to this Privacy Policy. Our basis: Contract, Obligation and Legitimate Interest (in maintaining a compliant relationship with you).

We use Customer Service Contact Data, and your Identity and Contact Data, to deal with and investigate issues you raise with us, to communicate with you about them and (in the case of Customer Service Contact Data that we pseudonymise for the purpose) to improve SCB Services. Our basis: Contract; Legitimate Interest (improving Service).

Legal and Regulatory Obligations

Regulators, government bodies, law enforcement and courts have powers to order us to provide information and, like any other organisation, we sometimes have to comply with their requests.

We may share your personal data with law enforcement, regulators or any other relevant third party in order to aid the investigation of suspected unlawful, fraudulent or other improper activity connected with the use of the website and to report a crime or suspected crime, including money laundering or fraud.

Promotional Offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which offers may be relevant for you (we refer to this as marketing).

You will receive marketing communications from us if you have requested information from us, opened an account, or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Opting Out

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by Contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of opening an account with us. For example, we may be required to processes personal data to meet legal or regulatory obligations.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please select this link for our Cookie Policy. 

Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 5. Disclosures of your Personal Data

We may have to share your personal data with the parties set out below for the purposes set out in section 4 above:

a) External Third Parties as set out below

b) Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

External Third Parties

• Service providers who provide IT and system administration services, some of which may be outside the EU
• Partner Brokers who track your selections made via our website, some of which may be outside the EU
• Partner Brokers where in rare circumstances your tracking through to the Broker directly has failed
• Regulators and other governmental authorities, some of which may be based outside the EU, request information
• Various payout providers, some of these providers may be based outside the EU
• Depending on your marketing preferences, we may engage third party email providers
• Social media publishers
• Various tracking agencies where you have joined our service as a result of a third party referrer

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

 6. International Transfers

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: 

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield. 

Please contact us at support@spreadcashback.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

 7. Data Security 

Overview

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Protect your Account Online

It is vital that you keep your personal details and password confidential and secure. If you have any reason to suspect that your password has become known by someone else, you should change your password and contact us immediately at support@spreadcashback.com

We are in no way responsible for any loss or damage which is due to any failure or oversight by you to protect your password and other account details, or you fail to take reasonable measures to guard against your personal data being lost or shared.

 8. Data Retention  

How long will you keep my personal data for? 

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 

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.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for five years after they cease being customers for tax or regulatory purposes.

In some circumstances, you can ask us to delete your data: see Request erasure below for further information.

In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. Your Legal Rights 

General

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please Contact us at support@spreadcashback.com.

No Fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 10. Glossary 

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

11. Your Legal Rights 

You have the right to: 

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific reasons, including lawful purposes described above which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party, and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a CSV format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.