Privacy Notice

We are committed to respecting your privacy and to complying with applicable data protection and privacy laws. This privacy notice is provided to help you understand how we collect, use, share, protect, and otherwise deal with your personal information.

Who we are

The data controller for our site and app is DIGICEL CARIBBEAN LIMITED (“Digicel”) a company incorporated in St Lucia, having its registered office at 20 Micoud Street, Castries St Lucia.

Our contact details

For customer support, to report a problem or to send us your feedback, please contact us through the customer support chat feature or visit the “Contact Us” option on the App.

Information we collect about you 
We currently collect and process the following information:

- Contact information such as your name, address, mobile number and email address;

- Account information, such as the subscriptions you use, account identifier or other information related to your account;

- Your billing information, place of residence and any other information you provide for the provision of payment services, administration and billing processes;

- The country in which your subscription is registered;

- Details of your device(s), for example, IP address, the unique device ID, the device model, and operating system; and

- When you post information or comment publicly on our website, the information you post and your username are publicly accessible. We strongly recommend you avoid sharing any personal details, and especially information that can be used to identify you directly such as your name, age, and address.

We will not process sensitive personal data (in some countries referred to as “special categories of data”) in any use of the services.

How we get that information and why we have it

Most of the information that we process is provided to us by you:

1)    When you register, browse and use the services or via our App;

2)    When you get in touch with us; or

3)    Directly from our affiliates with your consent.

We will use the information that you have given us to:

1)    verify your identity and validate your subscription;

2)    maintain and provide the services you have requested;

3)    assist with service related issues, account management, customer care and technical support;

4)    improve the performance of the service, product and service development, and customer care;

5)    carry out marketing analysis to tailor the services to your preferences – sending you country specific content and information, and administering competitions;

6)    market our services (and that of third parties) with your consent; and

7)    carry out statistical analysis such as analysing the performance of our sites and apps and to understand how visitors use them.

Legal basis for using your information

We will only use your personal data where we have a legal ground to do so. In every case, the legal ground will be one of the following:

·         Where you give us your consent, for example where you have given your consent to send you marketing notifications. You can withdraw your consent at any time by contacting us via our contact details or by changing your preferences under your device settings;

·         For our legitimate business interest, where it is necessary for us to understand how users use our apps, and to analyse what content has been viewed, for marketing and improving our services;

·         For the performance of our contract with you, for example where you have purchased a subscription from us, we need to process your personal information to provide you with our services and content; or

·         To comply with our legal and regulatory obligations.

International Transfer of Data

In order to provide the services to you, we transfer your information internationally to our parent company, affiliates and suppliers.

The following countries to which we may transfer personal information have been assessed by the European Commission as providing an adequate level of protection for personal information: USA (based on the Privacy Shield).

If you would like further information please contact us via ‘Our Contact Details’ above.

Who we share your information with

We share your information with:

·         our subsidiaries and affiliates; and

·         partners and suppliers involved on our behalf in delivering the services to you (that includes our payment gateway and subscription management provider, website developer, app developer, engagement platform provider and Google LLC;

We ensure there is a data processing agreement in place so that your personal information is only processed for a specified purpose and that it is protected in accordance with privacy laws.

How we store your information 

We take all the appropriate technical and organisational security measures to protect your personal information against unauthorised access and unlawful processing, accidental loss, damage or destruction.

We keep your personal information for no more than is necessary for the purposes set out in this privacy notice unless we are required to so for a longer period to comply with legal, tax or regulatory reasons. When we no longer need or are not required to keep your information we will securely delete your information and ensure all recipients of your data also comply with the same.

Where you have given us your consent to use your data and you decide to withdraw that consent, we will delete your personal data. However, when you withdraw your consent to receive marketing communications, we may need to keep a piece of your information for example your email address or account identifier in our records to ensure we do not send you any further marketing communications in the future.

We keep your posted comments and any information you post on our chat for 24 hours or less (where it is deleted by us at our sole discretion or if you have violated our terms and conditions of use). It will then be automatically deleted through our automated system. As a general guideline, we will delete all other personal data after 2 years unless we are required to keep it as detailed above.

Your data protection rights

You can do the following at any time by contacting us:

• Request to see a copy of the information we have about you;
• Request to update any incorrect or inaccurate information we have about you;
• Object to us processing your information in certain circumstances;
• Have us delete any information we have about you in certain circumstances;
• Object to us profiling or using analytical tools to analyse your preferences;
• Transfer the information you gave us to another organisation, or to you, in certain circumstances; and
• Express any concern you have about our use of your information.

Children

We do not allow Users under the age of 16 to register or share any Personal Data with us and we do not solicit, collect or process in any way any Personal Data of a User under the age of 16.  If you believe we have inadvertently processed Personal Data of a Player under the age of 16, please contact us at the details provided.  If we discover that we have inadvertently processed the Personal Data of any Player under the age of 16, we will permanently delete such Personal Data from all of our systems as soon as possible.

Automated Decision Making

We do not use Personal Data to make automated decisions about you.

Links

Our App may contain links to other third party websites. Please be aware that we are not responsible for the content or privacy practices of such other websites. We encourage you to read the privacy statements and cookie policies of these third party websites before you use or give them your personal information.

Changes to our privacy notice

This privacy notice was last updated on October 2020.

We may change this privacy notice from time to time, when we do we will inform you via our App.