Privacy Policy

About Us

Smartodds Limited is a company registered in England and Wales under number 05108548 with its registered office at Unit 520, Highgate Studios, 53 – 79 Highgate Road, London NW5 1TL. When we refer to Smartodds/”we”/”us”/”our” we are referring to Smartodds Limited.

Smartodds is a privately owned company providing statistical research and sports modelling and prediction services to our clients. In carrying out these activities we collect and analyse data related to sports clubs and professionals. This data is collected by researchers from publicly available sources or provided to us by third party data suppliers, and is used by our analysts, statisticians and software developers to develop and build analysis models and software applications which enable Smartodds to create predictions for the outcome of sporting events and provide performance analysis for use by our customers. The personal information we process and how we use it is set out in more detail below.

For purpose of the data protection legislation, Smartodds is the data controller of the personal data referred to in this policy. If you need to contact us you can do so by writing to us at the address above, or by email at privacy@smartodds.co.uk. We take our compliance obligations seriously, including the requirements of the General Data Protection Regulation (2016/679 EU) (“GDPR”) and the Data Protection Act 2018 (“DPA”) .

In this policy you will find information about what types of information we hold about you, how and why we collect it, how we use it, and how we keep it secure. This policy also tells you about your rights and how you can exercise them and how the law protects you. Please read it carefully to understand our practices regarding your personal data.

What personal information we collect and where we collect it from

Job applicants

Smartodds is always looking to recruit talented new employees, and as part of our recruitment process we collect and process personal data relating to job applicants.

This may include:

• right to work documents
• identification details (name, age, gender)
• contact details (email, phone, home address)
• information about your current remuneration and benefits
• details of your skills, qualifications and employment history

If you decide not to provide us with some or all of this data, then we may not be able to process your application.

We may also collect and process other personal information that you voluntarily provide to us but is not necessary to process your application. Whether you provide such additional information is up to you.

We collect your personal information:

• when you provide it to us when you make any job application
• from your appointed referees
• from recruitment agencies that you have engaged
• when you otherwise interact with us

Sports professionals

We collect and process information regarding sports professionals to assist in our research and analysis. This information includes information gathered from public domain sources and from third party data providers. An example of the data we collect in respect of football players and managers is set out below:

Players

• Name, gender, date of birth, age, height, weight, nationality, left/right foot preference
• Contractual history, if applicable
• Squad number
• Match information: availability/suspensions, games played, position, minutes played

Managers

• Name, date of birth, nationality
• Style preferences
• Fixtures managed and results

We collect similar data in relation to other sports (such as cricket, tennis and baseball).

Data licenced from third party sports data providers comprises numerous data points related to player and team performance from observation of public sporting events and matches. In football this includes:

• Playing event information such as pass, tackle, header, shots, corner, throw-in, offside etc.
• Fixtures involved in
• Whether the player was captain on the day.

We licence similar information in relation to other sporting events and professionals.

How we process your personal information

Job applicants

Your data will be stored on our IT systems and will only be accessed by persons who need to view it for the purposes of processing your application. If you have made a job application, we use your information to assess your suitability to work for Smartodds and, if applicable, when providing you with an employment contract.

Sports Professionals

In the case of sports professionals, we use personal information to create and develop our sports research. Information related to players is used to create our own rating, and our own and third party data for player/manager career and performance is used by analysts, statisticians, and software developers to build statistical models and software applications which assist Smartodds in predicting the outcome of sporting events and provide insights on individual and team performance.

How we share your personal information

Job applicants

If you have made a job application, your data may be shared internally within Smartodds amongst our HR team and others involved in the recruitment process. It will not be shared with third parties during the assessment process, although we may subsequently share your data as necessary with third parties such as former employers to obtain references and to conduct other background checks.

Sports Professionals

In the case of sports professionals, your data may be shared internally or with our limited client base for the purposes of predicting the outcome of sporting events and analysing player and manager performance (as applicable). Our clients comprise a small number of individuals and affiliated companies involved in betting on sporting events, and two football clubs.

We may also share your personal information with:

• law enforcement agencies, other governmental agencies or third parties if we are required by law to do so or if necessary to prevent fraud or investigate crime or to protect or enforce our legal rights;
• our professional advisers;
• other business entities should we plan to merge with or be acquired by that business entity, or if we undergo a re-organisation with that entity.

We will not otherwise share your personal information with third parties unless we have your permission or are otherwise permitted or required to do so by law.

Legal basis for processing

There are a number of different legal grounds for processing personal information. Which one is applicable will depend on precisely how we are processing your information and for what purpose.

Most commonly we will be processing your information where:

• it is necessary to pursue our legitimate business interests and where there is no undue adverse impact on you. We rely on legitimate business interests in relation to the processing of personal information for the purposes of recruitment, and for the processing of personal information for our statistical research and sports modelling and prediction services;
• it is necessary to perform our contractual obligations with an individual;
• it is necessary to comply with our legal obligations; or
• because you have consented to the processing that we are carrying out.

We do not generally process ‘special category’ data. Where we do so we will seek your consent unless such information has manifestly been made public by you or the processing is necessary for employment or where there is another legal basis for processing.

International Data Transfers

We are primarily a UK business and do not routinely transfer personal information outside the EEA. We do work with a small number of consultants and contractors outside the UK who may have access to your personal information in order provide their services (such as research and analysis). If you are based in the UK we may transfer your personal information to other countries within the EEA, in which case your personal information will be protected by EU data protection laws which the UK ICO has determined provide an adequate level of protection. We may also transfer your personal information to other countries which have also been approved by the ICO as providing an adequate level of protection (like Canada). If we transfer your personal information to countries which have not been deemed to provide an adequate level of protection we will ensure that we put in place appropriate safeguards to protect your personal information. This may include, for example, entering into approved forms of contract with the recipients of such personal information which ensure that obligations are imposed on those recipients to protect your information to the standard required in the UK. We may also transfer your information where you have consented to the transfer.

How long will we keep your information?

We will only keep the information we collect about you for as long as required for the purposes set out above or as required to comply with any legal obligations to which we are subject. This will involve us periodically reviewing our files to check that information is accurate, up-to-date and still required.

If you have applied for a job and your application is unsuccessful, your data will be kept on file for up to 6 years in case there are future employment opportunities for which you may be suited, and for which we may wish to contact you directly. If you do not want us to retain your information if you are unsuccessful, please let us know.

For sports professionals we may retain player data beyond the player’s retirement because historical data assists the Company in accordance with good research standards to develop its models and in creating informed predictions and analysis. For example, historic player data enables the Company to analyse a current football player’s metrics against another football player’s metrics when he was the same age or stage of his career to assess how his or others performance may develop over time.

Security

To prevent unauthorised access, disclosure or loss of data, we have put in place suitable procedures to safeguard and secure the information we collect and store about you. We have procedures in place to deal with any suspected data security breach and will notify you and the Information Commissioner’s Officer of any suspected or actual data security breach where we are legally required to do so.

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Your Rights

Under data protection laws you have a number of rights in relation to your personal data. We respect and honour these rights and will help you to exercise them. These rights are not absolute – in some cases they will not apply to you, or may not apply to the particular use that we are making of your data, and there are exceptions (for example if, despite your objection, we have to process the data to comply with our own legal obligations).

Your rights include the right to:

• Access and obtain a copy of your personal information on request (via what is commonly known as a “data subject access request”);
• Require us to correct any mistakes in your information which we hold;
• Receive the personal information that we hold concerning you;
• Object to decisions being taken by automated means (including profiling) which produce legal effects concerning you or similarly significantly affect you;
• Object in certain other situations to our continued processing of your personal information (but please not that if, for example, you require us to delete or stop processing your job application data we may be unable to continue our review of your application);
• Otherwise restrict our processing of your personal information in certain circumstances.

If you wish to access a copy of your personal data or exercise any of your other rights your request must be in writing. We will endeavour to respond within a reasonable period and in any event within one month or as required by GDPR and the DPA. We will require you to provide evidence of your identity before we can process any such request. All such requests should be emailed to us at privacy@smartodds.co.uk.

We aim to ensure that the information we hold about you is accurate at all times. To assist us in ensuring that your information is up to date, if you are a job applicant, do let us know if any of your personal details change by emailing us at privacy@smartodds.co.uk.

Changes to this policy

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

Contact us

If you have any questions or comments about this policy, please contact at privacy@smartodds.co.uk.

We hope that we can resolve any concerns you may have regarding your personal data with you directly, but if you do have any concerns about our use of your information, you also have the right (as a UK resident) to make a complaint to the Information Commissioner’s Office, which regulates and supervises the use of personal data in the UK, via their helpline on 0303 123 1113. See https://ico.org.uk/ for more information.