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Privacy Policy

Last revised: 20 March 2020

This Privacy policy ("Privacy Policy") together with our Terms of Service("Terms of Service") sets out the basis on which any Personal Information we collect from you ("you", "your", or "customer"), or that you provide to us, will be processed by us. By "Personal Information", we mean any information which, either alone or in combination with other data, enables you to be directly or indirectly identified, for example your name, email address, username, contact details or any unique identifier such as an IP address, device ID or other online identifier.

Please read the following carefully to understand what data we collect, how that data is used and the ways it can be shared by us. If you do not wish for your Personal Information to be used in the ways described within this Privacy Policy then you should not access or use the Site or use the services, functions, or features offered from time to time on the Site ("Services").

The latest Privacy Policy has incorporated elements from the General Data Protection Regulation (GDPR) as we act in accordance to its personal information processing rules within the European Economic Area (EEA).

1. General information policy

1.1. Information you give us

This is information about you that you give us by:

  • registering for a StackOfStake account;
  • undergoing user identity authentication;
  • corresponding with us by phone, e-mail or otherwise;

The Personal Information most often collected and maintained in a customer file includes customer identification, transaction history including records of payments made.

1.2. Information we collect about you

Each time you use the Services, we may automatically collect the following information, which may be considered to be Personal Information when combined with other information about you:

  • technical information, including the Internet protocol (IP) address used to connect your computer or other device to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
  • information about your visit, including the dates and times you use the Site length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call the contact phone number provided on our Site.

Similar to other websites, our Sites utilize browser cookies, web beacons and similar tracking technologies (collectively, “Cookies”) to collect and store certain information when you use, access, or interact with our services. Details are set out in paragraph 14.

1.3. Information we do NOT collect about you

We do not collect any special categories of Personal Information 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).

1.4. Information we may collect from third party sources

We may receive information about you from other sources, including third parties that help us update, expand, and analyze our records; prevent or detect fraud; process payments; or analyze your use of our Services. Our Services may also include integrated content or links to content provided by third parties (such as live chat, social media content, plug-ins and applications). Additional third parties may include our affiliated entities.

2. Purposes for which we collect your Personal Information

If you wish to transact on and use the Site or use the Services, StackOfStake will collect information about you for the purposes set out below.

Information you provide to us may be used to:

  1. 2.1. establish and maintain a responsible commercial relationship with you;
  2. 2.2. understand your needs and your eligibility for products and services;
  3. 2.3. inform you about Site or Services features;
  4. 2.4. provide information to you about developments and new products, including changes and enhancements to the Site;
  5. 2.5. develop, enhance, and market products and services, and provide products and services to you;
  6. 2.6. process billing and collection of any fees;
  7. 2.7. conduct surveys and get feedback from you;
  8. 2.8. deliver products and services to you;
  9. 2.10. as we believe reasonably necessary, advisable or appropriate to comply with our legal or regulatory obligations and to respond to legal, regulatory, arbitration or government process or requests for information issued by government authorities or other third parties or to protect your, our, or others’ rights;

3. Legal bases on which we process your Personal Information

We will process your Personal Information on the following grounds:

  • where it is necessary for us to perform pursuant to our contract with you or in your interests;
  • 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. Legitimate interests mean the interests of our organization to conduct and manage our business to enable us to better serve you and provide you with a secure experience on the Site;
  • as may be required to comply with any legal or regulatory obligations that may apply to us, for instance under anti-money laundering and sanctions regimes.

We ensure that we balance any potential impact on you and your rights before we process your Personal Information for our legitimate interests. We do not use your Personal Information 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.

Generally, we do not rely on consent as a legal basis for processing your Personal Information other than in relation to our use of cookies or when we send third party direct marketing communications to you via email or text message.

4. Security and confidentiality.

  1. 4.1. StackOfStake is committed to protecting your privacy. Internally, only people with a business need to know Personal Information, or whose duties reasonably require access to it, are granted access to customers’ Personal Information. Such individuals will only process your Personal Information on our instructions and are subject to a duty of confidentiality.
  2. 4.2. The Site’s systems and data are reviewed periodically to ensure that you are getting a quality service and that leading security features are in place. We have put in place procedures to deal with any actual or suspected data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
  3. 4.3. However, no information system can be 100% secure. So, we cannot guarantee the absolute security of your information. Moreover, we are not responsible for the security of information you transmit to us over networks that we do not control, including the internet and wireless networks.

5. Disclosures

You agree that we have the right to share your Personal Information with:

  • Our service providers, to the extent necessary to supply the Services to you.
  • Selected third parties, including analytics and search engine providers that assist us in the improvement and optimization of the Services.
  • Authorities and law enforcement agencies worldwide either when ordered to do so or on a voluntary basis if this appears reasonable and necessary to us (please refer to our Law Enforcement Requests Policy).

6. Your Personal Information protection

StackOfStake takes all reasonable endeavors to protect and safeguard Personal Information, but there are protective measures you should take, as well. Do not share your Personal Information with others unless you clearly understand the purpose of their request for it and you know with whom you are dealing. Do not keep sensitive Personal Information in your e-mail inbox or on Webmail. If you are asked to assign passwords to connect you to your Personal Information, you should use a secure password and always use two-factor authentication (2FA), where available. You should change your password regularly.

7. Changes To Our Privacy Policy

Any changes we make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our Privacy Policy.

8. Contact

Questions, comments and requests regarding this Privacy Policy should be addressed to [email protected]

9. Cookies

The Site may use “cookies”. A cookie is a small text file containing a unique identification number that identifies a customer’s browser each time that customer visits a website. The use of cookies is industry standard practice and many major browsers are initially set up to accept them.

We set cookies (first party cookies) on web pages, however, where we require additional information, we may also allow other companies to host cookies on our Site (third party cookies). These companies have been carefully selected by us and are required to meet contractual obligations they have with us.

The cookies on the Site may be from any of the following categories:

  • Strictly Necessary cookies - these are used for technical reasons and are necessary to enable the Site to operate efficiently so that you can navigate the Site with ease and use specific features. These include, for example, cookies that help us to debug any errors. If these cookies are blocked or disabled, some of the Site may not operate effectively.
  • Functionality cookies - these are used to improve the functionality of the Site and make it easier to use. They help us to identify you as a repeat user of the Site and help us remember your preferences (for example, your choice of language or region).
  • Analytical - these record your visit to our Site, the pages you have visited and the links you have followed. We will use this information to make the Site and the advertising displayed on it (if any) more relevant to your interests. We may also share this information with third parties for this purpose.