Effective as of 8 July 2018
Under the Act, “Personal Information” is defined as: “Information or an opinion about an identified individual, or an individual who is reasonably identifiable:
(a) whether the information or opinion is true or not; and
(b) whether the information or opinion is recorded in a material form or not.”
1. ABOUT AFE
AFE is the provider of a real time fantasy sports app, websites and social prediction platform (collectively ‘AFE Platform’) through which individual Users participate in dynamic, skill based predicting competitions related to specific sporting codes.
In providing the AFE Platform, we are sensitive to Users’ concerns about the safety of their Personal Information.
In essence, AFE will typically only:
AFE has developed our privacy framework to assist Users, and to comply with privacy legislation and regulations applicable to us and our management of your Personal Information.
2. HOW AFE COLLECTS YOUR PERSONAL INFORMATION
AFE collects Personal Information from individuals in one of three main ways:
The specifics of Personal Information collected in each situation is discussed further below.
3. WHEN AFE COLLECTS INFORMATION FROM USERS AND WHAT WE COLLECT
(a) Personal Information collected directly
When Users sign up and use the AFE Platform we collect the following types of Personal Information directly and consensually from you:
We will collect the following types of information from Users as they use the AFE Platform:
If a User decides to purchase All Football Expert Coins or other virtual tokens we will collect:
If a User wins a competition we will collect the following types of Personal Information directly and consensually from you:
If you make an enquiry or sends us unsolicited feedback we may collect the following types of Personal Information directly and consensually from you:
When you respond to a survey we may directly and consensually collect the Personal Information disclaimed on the survey form.
When you make an application for employment at AFE, we may collect any Personal Information provided within that application, such as the contents of a personal statement made in support of your application.
(b) Personal Information collected passively
As you interact with the AFE Platform or advertisements, we may collect the following types of Personal Information about your usage:
(c) Personal Information collected from third-parties
In certain specific situations, AFE will collect Personal Information about you from third-parties. The types of Personal Information collected include:
4. WHY AFE COLLECTS YOUR PERSONAL INFORMATION AND WHAT WE USE IT FOR
Although AFE collects Personal Information from Users in a number of circumstances, AFE will only collect this information in order to provide and develop the AFE Platform. Here are the main ways we use Personal Information to achieve these objectives:
Communicating with Users
AFE will use basic User, account and contact to communicate with individuals about their feedback or issues with the AFE Platform.
AFE will also use prize delivery information to verify the identity of competition winners, and winner’s interview information to congratulate winners of our competitions over the AFE Platform.
If Users have consented, AFE will also use these types of Personal Information to share relevant news and updates about AFE and the AFE Platform.
Administration and delivery of AFE Platform
AFE will use basic User and account information, as well as other basic preferences to provide you with the baseline experience over the AFE Platform (e.g. allowing you to participate in competitions and accrue points and All Football Expert Coins).
If you have registered using third-party service or platform information AFE will also use this for the same reasons.
AFE will use your basic User information for simple administrative tasks, such as resetting account passwords.
AFE will use your payment related information to allow you to purchase All Football Expert Coins (or other virtual tokens when applicable).
AFE will use your sporting preferences to tailor your in-app experience in using the AFE Platform.
Ensuring User safety
AFE will also use any type of information collected to prevent and address risks to all Users (e.g. AFE will use information to investigate suspicious or threatening activity).
Research and development
AFE will use the following types of information to develop, test and improve the AFE Platform:
Together these types of Personal Information are used to provide us with an overview of how the AFE Platform is being used, any AFE comings it may have, and subsequently to highlight what will be the best means of improving the experience for all Users.
AFE’s preference will be to de-identify these types information first, and then use it for this purpose in conjunction with de-identified browser and device information (see section 6 below for an explanation of what we mean by “de-identified”).
Where Users have expressly consented, AFE will use basic contact, enquiry and account information to provide Users with relevant marketing materials and offers. Users can always opt out of this through the functionality provided in each marketing communication (e.g. by clicking “unsubscribe” at the bottom of an email).
Where applicable AFE will use winner’s interview information to encourage continued participation in our competitions.
5. AFE’S DISCLOSURE OF PERSONAL INFORMATION
Generally, AFE does not disclose Personal Information to any third-parties except:
Some of the third-parties AFE discloses Personal Information to are located overseas. This is particularly the case for our third-party software and cloud service providers which are currently located in the United States and China.
Sometimes we may also disclose the Personal Information of Users to our third-party partners located in specific jurisdictions such as Indonesia. Typically, the Personal Information disclosed in these circumstances will only relate to Users who access and use the AFE Platform from the relevant jurisdiction.
As with disclosures to third-party service providers, overseas disclosures are always made once AFE has taken all reasonable steps to determine the information will be treated at least as favourably under the Act and other applicable privacy laws.
6. AFE’S TREATMENT AND STORAGE OF INFORMATION
AFE’s general approach
AFE will keep your Personal Information confidential and not sell or knowingly divulge User information to any external third-parties, unless:
AFE seeks the informed and voluntary consent of individuals whenever it collects their information, or as soon as possible after.
Users can always refuse or revoke this consent, but sometimes this will affect AFE’s ability to provide them with the AFE Platform. AFE will advise Users if this is the case.
De-identified information refers to information that cannot reasonably be used to identify a particular individual.
De-identified information that will never be able to personally identify particular individuals is referred to as anonymised information (e.g. statistics that AFE 90% of Users were happy with the AFE Platform). Additionally, de-identified information that can identify individuals only if it is combined with another, separate piece of information is referred to as pseudonymised information (e.g. account ID numbers).
Where possible AFE will aim to collect, store and use anonymised information as a first preference, and if not, then pseudonymised information.
However, sometimes it will be impractical for User information to be de-identified or treated in this way, and in this case, AFE will continue to use and hold the information in a personally identifiable state. For example, if AFE needs to reply to a User enquiry we will have to use the contact information provided.
AFE is committed to information security. We will use all reasonable endeavours to keep the Personal Information we collect, hold and use in a secure environment. To this end we have implemented technical, organisational and physical security measures that are designed to protect Personal Information, and to respond appropriately if it is ever breached (e.g. AFE has developed an extensive Data Breach Response Plan which we use to prepare and respond to data breaches).
When information collected or used by AFE is stored on third-party service providers (e.g. Azure or AWS cloud servers), AFE takes reasonable steps to ensure these third-parties use industry standard security measures that meet the level of information security AFE owes Users.
As part of our privacy framework we endeavour to routinely review these security procedures and consider the appropriateness of new technologies and methods.
In the circumstances where AFE suffers a data breach that contains Personal Information, we will endeavour to take all necessary steps to comply with the Notifiable Data Breach Scheme outlined under the Act.
7. AFE’S RETENTION OF INFORMATION
AFE retains Personal Information until it is no longer needed to provide or develop the AFE Platform, or until the individual who the Personal Information concerns asks us to delete it, whichever comes first. It may take up to 30 days to delete Personal Information from our systems following a valid request for deletion.
However, AFE will retain:
8. SPECIFIC RIGHTS OF EUROPEAN RESIDENTS
Users who are habitually located in the European Union (‘EU Residents’) have additional rights in respect of their Personal Data (a term that is fundamentally interchangeable with Personal Information).
9. MANAGING PERSONAL INFORMATION YOUR INFORMATION
Accessing and ensuring the accuracy of Personal Information
AFE takes reasonable steps to ensure that the Personal Information we collect and hold is accurate, up to date and complete.
Users have a right to access and request the correction of any of Personal Information we hold about them at any time. Any such requests AFEuld be made by directly contacting us at the details set out below. AFE will grant access to the extent required or authorised by the Act and applicable laws, and will take all reasonable steps to correct the relevant Personal Information where appropriate.
There may be circumstances in which AFE cannot provide Users with access to information. We will advise you of these reasons if this is the case.
AFE has appointed a Privacy Officer to be the first point of contact for all privacy related matters and to assist in ensuring our compliance with our privacy obligations.
Anugerah Futuristik Universal
Rukan Puri Mutiara No. 38
If you have any queries or wish to make a complaint about a breach of this policy or the Act you can contact or lodge a complaint to our Privacy Officer using the contact details above. You will need to provide sufficient details regarding your complaint as well as any supporting evidence and/or information.