The Website / Apps (defined as playnbrag.com), the company (Playnbrag Limited) is the operating company.
Playnbrag Limited (Company number 539269) is incorporated under the laws of Ireland and regulated by the UK Gambling Commission (Combined Remote Operating Licence) (licence number – 000-037501-R-319610-001), registered address of Playnbrag Limited, is Loch Na Gar, Carrigart, Letterkenny, Co. Donegal, Ireland.
General Data Protection Regulations that comes into force from 25th of May 2018 in the European Union
Please ensure You read the following information on how Your personal data is used & processed on our Platform in this section - 1.3 - & what Your rights are –
How we use Your data -
a) Use of Your personal data - (Also refer to sections 2, 3 & 4)
All personal data such as names, emails, date of births, photos, identity verification documentation, and any other related images posted on the User’s profile are also saved on our Database. This information is only *disclosed to a 3rd party when -
For example, if the User is suspected of any criminal or illegal activity such as (but without limitation) under age activity, collusion, game manipulation, money laundering, any type of fraudulent activity, suspected terrorist activity or users that appear on international sanctions list. We will then conduct a full internal investigation & if our findings are inconclusive and suspicion remains the respective User’s personal information will be passed on to the relevant authorities.
Account setup, verification and management –
We use personal information such as Your name, email address, phone number, and information about Your device to set up and administer Your account, provide technical and customer support and training, verify Your identity, process payment information and send important account and Service information.
Additional information that we collect from You when You use our Service –
Traffic information, *location data, and other communication data (including IP address and browser type) are collected by Your availing of the Service;
Device information including unique device identified;
Information from third party databases to comply with our legal and regulatory obligations.
Your social media profile details (name, profile photo and other information You make available to us) when You connect or register with Us through a social media account / platform (Facebook / Google)
*Your location data is required upon accessing our Service to ensure that You are authorised to use the Service from the jurisdiction You are accessing it from. Due to it been a betting Service We are only allowed to offer it in certain jurisdictions.
Third Party and Publicly Available Sources
Not all the personal information We hold about You will always come directly from You. We may also collect information from third parties such as our partners, service providers and publicly available websites (i.e. social media platforms), to comply with our legal and regulatory obligations, offer Services we think may be of interest, to help us maintain data accuracy and provide and enhance the Service.
If You log into our Service through Facebook or Google, Facebook and Google provides Us with some of Your Facebook or Google User details. We may use these details for the purposes of our registration process and to market our offerings and Service to You.
b) Age verification & ID verification data -
Your Date of Birth is required upon initial sign up process when using our Platform and You are requested to submit photo identification (that is recognised by your government) upon first cash withdrawal. We accept National ID Cards, Driver’s Licences, Passports and any other photo id that is recognised by the government in your jurisdiction. This data is stored securely on our Database and is not disclosed to any 3rd parties except for the *exception outlined above in section 3.
This information is used to verify Your age and accuracy of Your user account details. This is required for the purpose of Us complying with our legal obligations.
We may also use any other personal information to verify Your identity to ensure that we are fully compliant.
c) User Payment & Betting Activity –
We also collect all payment & betting activity data such as Your deposit and withdrawal history, Bets / leagues created and joined, and any other User related activity within the Platform. This is to ensure that We are able to monitor User activity to deliver the best possible experience for You while also been able to assist You where ever necessary if You contact Us with a query or issue.
We also track and monitor all User activity within our Platform to adhere to our gambling licencing obligations & requirements, such as anti-money laundering, responsible gambling, collusion, and all other activities that are covered under our gambling licencing requirements.
d) Sensitive financial card data –
Your sensitive card data is protected on our payment partner’s servers (Secure Trading) whereby We use tokenisation protocol for deposits & withdrawal payments from our server to theirs. Therefore Your card details are saved on our Platform (on Secure Trading’s server) for You to be able to withdraw funds back to Your card.
e) Billing information & transaction history –
We also have access to Your billing information & transaction history on our payment portal. Details We have access to include Your billing address and all Your transaction activity within our Platform. We do not have access to any of Your sensitive card details information. This portal is used to monitor all transaction activity for accounts & security purposes for the daily operations of our Platform.
f) Marketing and events – (Also refer to section 4.3)
Subject to any preferences you have expressed (where applicable), We use personal information to deliver marketing to You across various platforms, such as email, sms (text messaging), push notification or otherwise. We will do this during the period of Your relationship with Us and, unless specifically instructed otherwise by You, for a reasonable period of time after the relationship has ended in order to inform You about our service, promotions and any new or special offerings which We think may be of interest to You.
g) Risk Management –
In order to provide the Service to You and for our legitimate purposes, We process personal data to evaluate and manage risks to our business.
h) Show and measure ads and Services –
We use a combination of information collected such as advertising cookies, Your email address, Your onsite activity, and facebook pixels to target and re-target You with relevant ads on a selection of websites on the web and social media websites. This information can also be used to measure and analyse the effectiveness and reach of these ads & campaigns, to help Us improve and refine our marketing strategy in accordance with our legitimate interests.
i) Personalisation –
We use personal information to deliver customised content based on Your Personal Preferences to personalise your experience with our Service. This is processing which is necessary for the purpose of our legitimate interests in delivering or presenting relevant content to You, our customer.
j) Surveys and polls – (Also refer to section 4.2)
If You choose to participate in a survey or poll, any personal information You provide may be used for marketing or market research purposes in accordance with our legitimate interests in assisting Us in promoting or improving our Service.
k) Diagnostics, research and development –
We use personal information for internal research and development purposes, to help diagnose system problems, to administer our Service, to improve and test the features and functions of our Service, to develop new content, and offerings. To carry out testing and analysis. This processing is necessary for the purpose of our legitimate interests, the security of the Service and to deliver an optimum Service to You, the end User.
l) Comment feature, and community forums –
Our Service provides features including a community forum (on the website) & a “comment” feature in the My Leagues section (both Private & Public League sections) on both the website & apps. The personal information you choose to post, share, upload, or make available is public and visible to others who use those features. You should never post or share any information that is confidential or about others unless you have permission to do so.
m) Legal and regulatory obligations – (Also refer to section 2.5 & 2.6)
We may be required to use and retain personal information for legal and compliance reasons, such as the prevention, detection, or investigation of a crime; or fraud. We may also use personal information to meet our internal and external audit requirements, information security purposes, and as We otherwise believe to be necessary or appropriate: (a) under applicable law, which may include laws outside Your country of residence; and (b) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include such authorities outside Your country of residence
n) Profiling –
In accordance with our legitimate interests detailed below or to comply with our legal obligations, we carry out profiling and analysis based upon Your location data, age, betting and gameplay activity, interests and behaviours for the following purposes:
a. Customer segmentation of Your sport preferences so as to offer You customised interests & offerings through push notifications and email, so as to provide You with more relevant marketing. For example, if the majority of Your bets are placed on the English Premier League, we will aim to primarily send You marketing material related to the Premier League. Likewise, when selecting Your preferred sports notifications on the app we will send you notifications based on Your sports preferences.
b. Risk and trading analysis; and
c. Licensing and legal obligations i.e. Responsible Gambling, Anti Money Laundering, Age Verification, prevention of fraud and to ensure the integrity of sporting events.
o) Other purposes: We may be required to use and retain personal information for; loss prevention; and to protect our rights, privacy, safety, or property, or those of other persons in accordance with our legitimate interests.
We process Your personal information so that We can deliver a secure, sound and reliable Service to You while also ensuring that we comply fully with our licencing obligations & requirements.
Our third-party service providers & partners:
Our Service, from time to time, retain trusted third parties to process Your information to provide Us with services globally, including for customer support, information technology, transaction & payments (refer to section 4.5), marketing, data analysis, research and surveys.
Third parties for legal reasons: (Also refer to section 2.4, 2.5 & 4.6)
We will share personal information when we believe it is required, such as:
To protect our rights, Users, systems, and Service
To comply with legal obligations and respond to requests from government agencies, including law enforcement and other public authorities, which may include such authorities outside Your country of residence;
In the event of a merger, sale, restructure, acquisition, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings);
Regulatory or Sporting body (Also refer to section 2.6)
Your personal information including, but not limited to, Your registration details, betting records, records of payments, device information etc., may also be disclosed to any regulatory or sporting body in connection with policing the integrity or enforcing the rules of a sport or game and/or prevention and detection of crime and where We consider that there are reasonable grounds to suspect that You may be involved in a breach of such rules or the law, have knowledge of a breach of such rules or the law or otherwise pose a threat to the integrity of the relevant sport or game based upon our assessment of Your betting behaviours or it may be based on information provided to Us by a regulatory or sporting body. Those bodies may then use Your personal information to investigate and act on any such breaches in accordance with their procedures.
If at any point our Platform is breached and any personal User data related to PlaynBrag has been compromised You will be notified within 72 hours of Us been made aware of the event if an adverse impact is determined.
Right to Access
You can easily access all of Your personal details that are saved on the PlaynBrag’s Platform by accessing the “My Profile” section of Your account on all related PlaynBrag platforms – website and associated apps.
You also have a right to request a copy of the personal information that we hold about You. Should you wish to make such a request, please send a request under the” Contact Us” Section.
You should include adequate information to identify yourself and such other relevant information that will reasonably assist Us in fulfilling Your request. Your request will be dealt with as soon as possible.
You can also submit a request to Us via “Contact us” page to change any information provided to Us or mark any information to prohibit future use, provided evidence is provided to support such changes.
Right to Erasure
You can request Us to erase Your personal data where there is no compelling reason to continue processing. You can do so by emailing Us under the “Contact Us” and go to “Help / Issues” - “Delete info” and We will erase Your personal data within a reasonable time frame from when the request is submitted.
Note: Upon such a request the User must withdraw any existing cash funds before We delete their personal data. To add, we may request ID verification if there is cash funds in the account to confirm the identity of the User before we can proceed to erase their personal data.
This right only applies in certain circumstances; it is not a guaranteed or absolute right. For instance if the account is under investigation we will be unable to delete Your personal data as we must adhere to our licencing obligations & requirements.
Right to data portability
This right allows You to obtain Your personal data that you have provided to Us with Your consent or which was necessary for Us to provide You with our Service in a format which enables You to transfer that personal data to another organisation. You may have the right to have Your personal data transferred by Us directly to the other organisation, if this is technically feasible.
Right to restrict processing of personal data
You have the right in certain circumstances to request that We suspend our processing of Your personal data. Where We suspend our processing of Your personal data we will still be permitted to store Your personal data, but any other processing of this information will require Your consent, subject to certain exemptions.
Right to object to processing of personal data
You have the right to object to our use of Your personal data which is processed on the basis of our legitimate interests. However, We may continue to process Your personal data, despite Your objection, where there are compelling legitimate grounds to do so or We need to process Your personal data in connection with any legal claims.
Right to withdraw consent
Where We have relied upon Your consent to process Your personal data, You have the right to withdraw that consent.
To opt out of marketing, You can request to be removed from our email marketing list by going to Contact us / Help Issues / Stop sending updates / notifications.
When installing any PlaynBrag apps We require Your consent to send push notifications to Your phone / device / tablet. At this stage if You decide to allow Us to send You push notifications via our app on Your device and at any subsequent point You want to opt out & stop Us sending You push notifications You must do the following:
Go to Settings > Notifications > scroll down to “Playnbrag” app > click on it > and turn off notifications
Privacy by Design
Information security is important to Us and We understand the techniques required to secure Your personal data. Security measures are in place to protect Your personal data from access by unauthorised persons and to prevent unlawful processing, accidental loss, destruction and damage.
Data on our secure pages is encrypted using Secure Sockets Layer ("SSL") technology. Personal information received directly from You will be stored in a password-protected Database located within our secure network behind active state of the art firewall software.
Personal User data is only used internally when required – such as age verification / ID verification – to assist in PlaynBrag operating it’s Platform in a legitimate and safe environment for its users while also ensuring We meet our licencing obligations & requirements.
The Data Controller is Playnbrag Limited, Loch Na Gar, Carrigart, Letterkenny, Co. Donegal, F92RF6F, Ireland.
Data Protection Officer
A Data Protection Officer has been assigned internally to monitor and conduct regular checks to ensure We are compliant with the recent changes to data protection regulatory requirements.
If You have any queries or want to submit a complaint regarding the use of Your personal information Please email Your query or complaint to the Data Protection Officer at firstname.lastname@example.org
We retain personal information for as long as We reasonably require it for legal or business purposes. For the unregulated jurisdictions in which We operate, and subject to Us not having a legal or regulatory requirement or a risk management reason for retaining Your information for a longer period, Your information will not be kept for longer than 7 years post account closure. Please note that We may be required in certain circumstances to retain Your information indefinitely (for example under our procedures on responsible gambling and self-exclusion). We will take all necessary steps to ensure that the privacy of Your information is maintained for the period of retention.
2.1 Personal information which may be used to identify an individual could include the following:
first and last name;
date of birth;
credit or debit card information;
home or other physical address;
e-mail address; and/or
phone number or other contact information.
2.2 Personal information may be requested during account registration or at other times, when using the Service. The personal information collected may include:
contact information, for example a telephone number;
Identification verification such as a passport or driver’s licence of your native country / country you reside in, or a national ID Card;;
all related user betting activity
Website / Apps preferences; and/or
feedback regarding the service.
2.3 This information is held by Us on servers located on our cloud Platform & our payment gateway provider. Our servers also keep a log of general user activities (web traffic) which is essential for the quality and provision of the Service, although this information is not collected without Your knowledge. This activity log includes administrative and traffic information such as:
source IP address;
time and date of access;
web page/s visited;
software crash reports; and
type of browser used.
2.4 If there is a legal requirement, or We believe such action is necessary, We may reveal Your personal information for the following reasons:
to comply with any legal process served on Us, the Website / Apps or the Service;
to protect and defend Our rights of property or the interests of sporting or other qualified bodies; or
to protect the personal safety of Users of the Service or the public.
2.5 We may decide to share Your information and identity with the relevant authorities, banks, credit card companies and appropriate government agencies, if You are found to have undertaken the following:
cheated or attempted to defraud Us or any other User of the Service in any way, including but not limited to:
game manipulation or payment fraud;
suspicion of fraudulent payment, including use of stolen credit cards;
any other fraudulent activity, including any chargebacks or other reversal of payment; or
prohibited transactions, including money laundering.
2.6 We may share Your personal information with regulators, sports' governing bodies and other authorised bodies, including the police, for the purposes of investigating any actual or suspected criminal activity or other regulatory matters.
3.1 As detailed in section 2, We may automatically collect certain data and receive personal information via Your use of our Service or offerings within the Platform. Personal information may be used for by customer services to aid You, the customer, in bringing You the best possible service & experience.
3.2 Third-party service providers may be appointed to provide technical support & process Your online transactions while the PlaynBrag web team will maintain Your online accounts. We may have access to any information provided to such vendors, service providers and third party e-commerce services and We will use the personal information as detailed in section 4 below.
3.3 This information may only be revealed to our staff and third parties involved in the transaction process and the support of Your use of the Service, as detailed in section 4 below. Our arrangements with third-party service providers and online vendors should ensure that Your privacy is protected.
4.1 The personal information collected from You will be used:
to deliver the Service;
to provide customer support;
to undertake necessary security and identity verification checks;
to meet certain business requirements so that the Service can operate at an optimum level; and
for any other purpose related to the operation of the Service.
4.2 We may occasionally request information from You using surveys. Participation is completely voluntary and You therefore have the choice of whether or not to disclose such information. Information requested may include:
contact information, such as name, correspondence address and telephone number; and
demographic information such as postal code or age.
4.3 Personal information, such as e-mail address and telephone number, may also be used where You have agreed to receive updates or notifications of upcoming events. This will provide You with details of any similar upcoming events and anything else that might be of interest to You on our Service.
We use all reasonable endeavours to ensure that our arrangements with ESP's protect Your privacy.
4.6 You agree that We are permitted to share personal information and all other information You may have provided by using the Service, to potential and subsequent business and merger partners, if We undertake the following:
file for bankruptcy;
acquisition by a third party;
merge with a third party;
sell all or part of Our assets; or
Explained in detail in section - 1.3 INFORMATION ON CHANGES TO GDPR
6.1 You should be aware that when You access or use our Service, We may collect information from Your devices through the use of 'cookies'. Cookies perform various different functions, and the purpose of this section is to give You a clearer understanding of:
What cookies are
6.2 Cookies are text files containing a small amount of information that are downloaded to Your device when You visit a website. Your browser makes cookies available each time You visit our website.
Cookies are used by our website to improve Your online experience and to ensure that relevant content and functions are delivered and used more effectively.
We use both session cookies and persistent cookies to perform various functions across our site.
Session cookies are downloaded to Your device temporarily for the period that You browse a particular website; these cookies might allow You to navigate between pages more efficiently or enable websites to remember the preferences You select. Persistent cookies can be used to help websites remember You as a returning visitor or ensure the online ads You receive are more relevant to Your interests.
When You visit our website, Cookies will be placed on Your device in two ways. Cookies placed by Us, as the site operator, are called "first party" Cookies. Cookie may also be placed on Your device by a party other than PlaynBrag, such cookies are known as "third party” cookies. Examples of the uses of third party cookies include collecting information about browser habits and providing customised content to You.
While there are many different uses for first and third party cookies, the cookies used by us all fall into one of the following four main categories of cookies:
Strictly Necessary Cookies
Third Party Marketing / Targeting Cookies
You can amend Your browser settings to block some or all cookies. To do this, follow the instructions provided by Your preferred web browser. For Your ease of reference We have provided the links below which provide instructions on how to remove and delete cookies for some of the more common web browsers. Please be aware that if You block cookies from the websites, some or all the website's functions may not perform as intended:
Mobile phone users may have to refer to their handset manual for details on how to block cookies using their mobile browser. For more information about online behavioural advertising cookies and opt-out controls, please go to http://www.youronlinechoices.eu/ More information regarding opting out of platform based advertising can be found at http://appnexus.com/platform-policy#choices.
7.1 We may conduct a security review at any time to confirm Your identity, age and the registration data provided by You. This information will be used to verify use of Your account and financial transactions for potential breach of our terms and of applicable law. This is in accordance with our gambling licence obligations & requirements and assists in making our Platform more secure for our customers.
7.3 Security reviews may include, but are not limited to, ordering a credit report and/or confirming supplied information against third party databases. In addition information or documentation may be requested to assist with these security reviews.
8.1 Information security is important to Us and We understand the techniques required to secure this information. Security measures are in place to protect Your information from access by unauthorised persons and to prevent unlawful processing, accidental loss, destruction and damage. Our technological security solutions are advanced and we employ a diligent, thorough set of processes & procedures. Our approach is focused on risk prevention through constant testing and vulnerability testing methodology.
8.2 Data on Our secure pages is encrypted using Secure Sockets Layer ("SSL") technology. Personal information received directly from You will be stored in a password-protected Database located within our secure network behind active state of the art firewall software.
8.3 Unfortunately the sending of information via the internet cannot be completely secure at all times. Although We will make every reasonable effort to protect Your personal information, We cannot guarantee the security of any information disclosed online. In opening an account with Us, You accept the inherent security implications of using the internet and that PlaynBrag will accept no liability for any direct, consequential, incidental, indirect, or punitive losses or damages arising out of such an occurrence.
For Your own privacy protection please do not include any sensitive personal or payment information, for example credit/debit card details in any emails sent to us.
8.4 The Service operates "AS-IS" and "AS-AVAILABLE," without liability of any kind. Whilst We have implemented appropriate technical and organisational measures to ensure the safety of Your personal information, due to the continually evolving state of technology and business, coupled with its complexity, We are not able to guarantee error free performance in relation to the privacy of Your personal information.
8.5 Protection of any information or images provided to a third-party online site that links to or from the service, cannot be guaranteed. This includes information collected by any third party managing any future affiliate program we may have with them or any other program, as these third-party online sites are owned and operated independently of Us.
8.7 We are not responsible or liable for:
the actions or policies of these third parties; or
the content or privacy practices of these online sites.
9.1 Personal information collected on the Service may be stored and processed in any country in which We or any of our partners or future affiliates, suppliers, subsidiaries or agents have facilities. By using the Service, You agree to the transfer of Your personal information outside of Your country, including to countries which may have a different set of privacy laws and requirements. Nevertheless, all reasonable processes are in place to ensure that any of our partners or future affiliates, agents, subsidiaries and suppliers comply with our privacy standards, irrespective of location.
by clicking the box next to "I agree to your Terms of Service and Data Use Policy" at the bottom of the Sign Up Form page on the website & associated apps ;