Betgenius Limited – Connextra Privacy Policy

Updated: March 2020

Betgenius Limited (“Betgenius”, “we”, “us” or “our”) is committed to protecting the privacy of our clients (and anyone who uses of our services). This policy refers specifically to our ad-serving technologies (“Connextra”). Any information you submit to us or that we collect in relation to Connextra, will be used only for the purposes set out in this policy.

For the purpose of the EU General Data Protection Regulation 2016/679 (“GDPR”) and national laws implementing GDPR, the data controller is Betgenius Limited, a company registered in England and Wales, our registered office is 9th Floor 10 Bloomsbury Way, Holborn, London, England, WC1A 2SL. References in this Privacy Policy to our group of companies is to Genius Sports Group Limited and its trading subsidiaries.

This Privacy Policy describes the types of personal data we process when using Connextra. It also describes the purposes for which we process your data and the ways in which it is handled.


Information We May Collect

As part of the Connextra service, we may process the following information whenever you visit a website upon which our technology has been deployed:

We may also receive technology information about your device or your interaction with the host website, including:

If you have given consent for us or one of our customers to deliver personalised digital marketing messages to your device, we may also collect information about your betting activity, including:

Cookies are set to expire between 24 hours and 365 days depending on the reporting requirements of advertisers for whom we work.

We do not collect your name, address, phone number, email address or any other information that might allow us to identify you.


How We Use Your Personal Information

Connextra buys advertising space on websites and places ads for our customers to help them promote their services.

Adverts may encourage you to visit a customer’s website or return to a website you have visited. When deciding whether to serve an advert to you, we consider:

We may choose not to show you an advert if we have recently shown you a related advert, if you have already accessed the advertised service or if you or the advertiser has asked us not to show you adverts.

If you have given consent for one of our customers to deliver personalised digital marketing messages to your device, we may show you adverts based on your betting activity or browsing history.

Your data may also be used to record advert serving impressions, record advert clicks, to analyse the effectiveness of a campaign and to report ad-serving activity and results to our customers.


How We Share Your Personal Information

We may send your details to others to help run our organisation. These are:

We may share your personal information with third parties where required by law, where it is necessary for our working relationship or where we have another legitimate interest in doing so.

We work with a number of trusted third parties to provide our services, these currently include:


Transfer of Information Outside the EEA

By using our third party providers we may transfer the personal information we collect about you to the USA, if this is necessary, in order to perform our contract with you, or in accordance with any legitimate interests of Betgenius. Our third party providers, including MediaMath, Akamai Technologies and AppNexus, and our US entity (Genius Sports Media Inc) are registered with the US Privacy Shield. This means that those organisations within the USA have been deemed by the European Commission to provide an adequate level of protection for your personal information.

We also transfer your personal data to our employees in Medellin (Colombia). There is not an adequacy decision by the European Commission in respect of that country. This means that Colombia is not deemed to provide an adequate level of protection for your personal information.

However, to ensure that your personal information does receive an adequate level of protection we are putting in place approved standard contractual clauses between us and our Colombian entity as an appropriate measure to ensure that your personal information is treated by our employees in Colombia in a way that is consistent with and which respects the EU and UK laws on data protection.


The Legal Basis for Processing your Personal Information

Connextra gathers and processes your personal data to deliver adverts to your device. Depending on the type of advert, we rely on one of two legal bases for processing:


Your Rights on the Information We Hold About You

You are entitled to know what personal information we hold about you and how that information is processed, which means you can ask us to do any of the following things:

  1. to provide access to your data;
  2. to rectify any mistakes relating to your data;
  3. to erase your data;
  4. to stop processing your data;
  5. to receive an electronic copy of your data;
  6. to object to our processing of your data;
  7. to object to any automated decision making that we may do using your personal data; and
  8. (automatic) to receive a notification of any breach of your personal data.

Just let us know (see Contact section below) if you’d like to exercise any of your rights.

You may also use the Connextra ad-serving opt-out cookie to restrict any Connextra profiling or personalisation activities that you might have consented to. Click here to set an opt-out cookie. The cookie will apply to the specific browser you are using; if you wish to opt-out for other browsers or computers that you use, you must repeat the process using those browsers or computers. All other cookies associated with your browser will remain intact and your opt-out will be effective with respect to the browser used as long as you do not delete the cookie file from your hard drive. This opt-out process will erase the cookie ID but not the cookie. It is necessary for the Connextra system to store this "keep out" cookie on your computer in order to recognise you as an opt-out user. Please note that if you erase all cookies from your computer, you will also erase our opt-out cookie and will need to repeat the process of opting out.


Complaints

If you’re unhappy with how any access request has been dealt with, you have the right to complain to the Information Commissioner by calling their helpline: 0303 123 1113 or starting a live chat at https://ico.org.uk/concerns/.


How Long We Will Hold Your Information

We will retain your personal data only while we perform the purposes described above.

All personal data processed by Connextra will be deleted, aggregated or anonymised no more than 13 months after collection.


Changes to this notice

We may update this privacy notice from time to time. When we change this notice in a material way, we will update the date at the top of this page. For significant changes to this notice we will try to give you reasonable notice unless we are prevented from doing so. Where required by law we will seek your consent to changes in the way we use your personal information.


Contact

We welcome any queries or enquiries or requests in respect of this notice, you can contact us by sending us an email on: DPO@geniussports.com.

Our company registration details are as follows:

Betgenius Limited (company registration number 04062777) 9th Floor, 10 Bloomsbury Way, Holborn, London, England, WC1A 2SL