Privacy Policy
Last updated: April 20, 2026
1. Introduction and Who We Are
ACTXION Ltd (company registration number to be inserted), whose registered office is at 6 Claremont Street, London, E16 2LW, United Kingdom (referred to in this Privacy Policy as "ACTXION", "we", "us", or "our") is the data controller responsible for the personal information we collect and process about you.
We are committed to protecting your privacy and handling your personal data with transparency, integrity, and in full compliance with applicable data protection legislation, including the UK General Data Protection Regulation ("UK GDPR"), the Data Protection Act 2018, and, where relevant to users in the European Economic Area, the EU General Data Protection Regulation (Regulation (EU) 2016/679) (together, the "Data Protection Laws").
This Privacy Policy explains what personal data we collect about you when you use the ACTXION mobile application, website, and all related features, campaigns, and services (collectively, the "Platform"), how we use it, who we share it with, how long we retain it, and what rights you have in relation to it. Please read this Privacy Policy carefully. By accessing or using the Platform, you confirm that you have read and understood this Privacy Policy.
This Privacy Policy should be read alongside our Terms and Conditions, which govern your use of the Platform and are available at www.actxion.com. Where we use capitalised terms in this Privacy Policy that are not defined here, they have the meanings given to them in our Terms and Conditions.
2. Personal Data We Collect About You
2.1 Data You Provide Directly
When you register for an account, use the Platform, participate in campaigns (including the Fan Ball Relay), or communicate with us, you may provide us with personal data directly. This includes your full name and display name or username; your email address; your telephone number; your date of birth (used for age verification purposes); your profile photograph or avatar; your country of residence; your preferences, interests, and favourite sports teams or athletes; your responses to surveys, polls, competitions, and prediction features; the content of any communications you send us, including support enquiries and feedback; and any other information you choose to provide when completing forms on the Platform or in correspondence with us.
2.2 Data Collected Automatically
When you access and use the Platform, we automatically collect certain technical and usage data. This includes your device type, model, operating system and version; your IP address and approximate geographic location derived from it; your mobile device unique identifier and advertising identifier; browser type and version; the pages, features, and content you access on the Platform; the time and date of your visits and the duration of your sessions; referral sources and search terms that led you to the Platform; details of any crashes or errors encountered during use; and network connection type and speed. This data is collected using cookies, web beacons, SDK integrations, and similar tracking technologies, as described further in Section 7 of this Privacy Policy.
2.3 Data from Third-Party Social Media and Sign-In Services
You may choose to register for or log in to the Platform using a third-party social media or authentication service, including Apple and Google. Where you do so, we will receive certain personal data from that third party in accordance with its own privacy policy and your account settings with it. The data we receive typically includes your name, email address, profile photograph, and certain public profile information. You can control what data is shared with us through your settings on the relevant third-party platform. We are not responsible for the data practices of any third-party social media or authentication provider.
2.4 Data from Your Device's Camera and Photo Library
Certain features of the Platform may request access to your device's camera and photo library in order to allow you to upload a profile photograph, share content, or use other image-related features. We will always request your explicit permission before accessing your device's camera or photo library. You may grant or revoke this permission at any time through your device settings. Where you provide images, we will process them solely for the purposes described in this Privacy Policy.
2.5 Data from Third-Party Data Providers and Partners
We may receive personal data about you from third-party partners, including analytics providers, advertising networks, sports data aggregators, and our business partners. This may include data about your interests and behaviour across other platforms, aggregated demographic data, and information about your engagement with third-party content or services that is relevant to the services we provide to you. Where we receive such data, we will handle it in accordance with this Privacy Policy and the terms on which we received it.
2.6 Data Inferred or Derived by Us
We may derive or infer additional information about you based on the data we hold, for example inferring your likely sports preferences, your engagement patterns, or your geographic location from your usage behaviour. This inferred data is used to personalise your experience and improve the Platform.
3. How We Use Your Personal Data
3.1 To Provide and Operate the Platform
The primary purpose for which we process your personal data is to provide you with the Platform and the services and features available through it. This includes creating and managing your account; authenticating your identity when you log in; enabling your participation in gamification features, prediction games, leaderboards, points systems, and promotional campaigns including the Fan Ball Relay; delivering personalised sports content, feeds, match summaries, and insights; processing payments and managing subscriptions where applicable; sending you service-related communications including notifications, updates, and security alerts; and providing customer support. The legal basis for this processing is the performance of a contract with you (Article 6(1)(b) UK GDPR) and, where applicable, our legitimate interests in operating a functional and effective platform (Article 6(1)(f) UK GDPR).
3.2 To Improve and Develop the Platform
We process personal data, including usage and technical data, to analyse how users interact with the Platform, identify usage trends and patterns, diagnose and fix technical issues, develop and test new features, and conduct research and analytics to improve our products and services. This processing is carried out on the basis of our legitimate interests in continuously improving the Platform and delivering a high-quality user experience. Where we use your data for research and analytics, we will, where practicable, use aggregated or anonymised data that does not identify you individually.
3.3 Personalisation and AI-Powered Features
We use your personal data, including your preferences, usage behaviour, and content interactions, to personalise your experience of the Platform. This includes curating personalised content feeds, generating AI-powered match predictions and insights, tailoring notifications to your interests, and recommending teams, leagues, or features that may be of interest to you. Some of this personalisation may involve automated processing, including profiling. Where any automated decision-making has a legal or similarly significant effect on you, we will ensure we have an appropriate legal basis and provide you with the ability to seek human review, as required by Data Protection Laws. The legal basis for personalisation is our legitimate interests, balanced against your rights and interests.
3.4 Marketing and Promotional Communications
With your consent, we may use your personal data to send you marketing communications about ACTXION products, services, features, offers, campaigns, and events that we believe may be of interest to you. We may send these communications by email, push notification, in-app messaging, or SMS. You can withdraw your consent to marketing communications at any time by using the unsubscribe link in any marketing email, adjusting your notification preferences in your account settings, or contacting us directly at dataprotection@actxion.com. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal. Please note that we may continue to send you non-marketing service communications even if you opt out of marketing.
3.5 Gamification, Campaigns, and Promotions
If you participate in any of our gamification features, promotional campaigns, competitions, or events (including the Fan Ball Relay), we will process your personal data to administer your participation, verify your eligibility, record your entries, determine and notify winners, distribute prizes, and publish results as permitted by the applicable campaign rules. We may also process your personal data for publicity purposes in connection with any campaign, as described in our Terms and Conditions. The legal basis for this processing is the performance of a contract with you and our legitimate interests in administering our promotional activities.
3.6 Safety, Security, and Fraud Prevention
We process personal data to protect the security and integrity of the Platform, detect and prevent fraud, abuse, and other harmful or unlawful activity, enforce our Terms and Conditions, and protect the rights, property, and safety of ACTXION, our users, and the public. This may include monitoring usage patterns for signs of suspicious activity, verifying account information, and investigating reported violations. The legal basis for this processing is our legitimate interests in maintaining a safe and secure platform and, where required by law, compliance with a legal obligation.
3.7 Legal Compliance and Regulatory Obligations
We may process your personal data where it is necessary to comply with our legal obligations, including responding to lawful requests from courts, regulators, law enforcement agencies, and other public authorities; preventing and detecting crime; meeting our obligations under tax, accounting, and corporate governance legislation; and exercising or defending legal claims. The legal basis for this processing is compliance with a legal obligation (Article 6(1)(c) UK GDPR) and, where relevant, our legitimate interests in protecting our legal position.
3.8 Business Transfers
In the event that ACTXION is involved in a merger, acquisition, restructuring, sale of assets, or similar business transaction, your personal data may be transferred to the relevant third party as part of that transaction, subject to equivalent confidentiality and data protection obligations. We will take reasonable steps to notify you of any such transfer that materially affects the processing of your personal data.
4. How We Share Your Personal Data
4.1 Service Providers and Data Processors
We share your personal data with carefully selected third-party service providers who process data on our behalf in order to deliver the Platform and our services. These providers are subject to contractual obligations that require them to process personal data only on our documented instructions, to maintain appropriate technical and organisational security measures, and to comply with Data Protection Laws. Our service providers include cloud hosting and infrastructure providers; analytics and performance monitoring tools; payment processing and subscription management platforms; customer relationship management and marketing automation platforms; sports data aggregators and feed providers; identity verification and fraud detection services; push notification and communication delivery services; and artificial intelligence and machine learning infrastructure providers.
4.2 Business Partners
We may share certain personal data with trusted business partners, including sports clubs, leagues, broadcasters, and commercial sponsors, where you have consented to such sharing or where it is necessary to fulfil a campaign or promotion you have chosen to participate in. Where we share your data with business partners, we will ensure appropriate data sharing agreements are in place and that those partners process your data only for agreed purposes and in accordance with Data Protection Laws.
4.3 Other Users
Certain information that you choose to share on the Platform, such as your username, profile photograph, Points balance, leaderboard ranking, predictions, and public activity, will be visible to other users of the Platform. You should be aware that any content you post publicly on the Platform may be viewed, shared, or copied by other users. Please exercise care when deciding what personal information to include in public-facing content on the Platform.
4.4 Third-Party Social Media and Connected Services
If you connect your ACTXION account to a third-party social media service or choose to share content from the Platform to a third-party platform, certain data may be shared with or become visible to that third-party platform and its users. We are not responsible for the data practices of third-party platforms and encourage you to review their respective privacy policies before connecting your accounts.
4.5 Law Enforcement and Regulatory Authorities
We may disclose your personal data to law enforcement agencies, regulatory bodies, courts, or other public authorities where we are required to do so by law, where we receive a lawful request for disclosure, or where we believe in good faith that such disclosure is necessary to comply with a legal obligation, to protect the rights or safety of ACTXION, our users, or others, or to investigate potential fraud or misuse of the Platform.
4.6 Professional Advisers
We may share your personal data with our lawyers, accountants, auditors, insurers, and other professional advisers where it is necessary for them to provide services to us, subject to obligations of confidentiality.
4.7 Business Transactions
As described in Section 3.8 above, in connection with any merger, acquisition, or sale of assets, your personal data may be shared with the relevant counterparty or their advisers, subject to appropriate confidentiality arrangements.
5. International Transfers of Personal Data
ACTXION operates globally and may transfer your personal data to countries outside the United Kingdom and the European Economic Area ("EEA"). Some of our service providers and partners are also located outside the UK and EEA. Not all countries outside the UK and EEA have data protection laws that provide the same level of protection as UK or EU law.
Where we transfer personal data outside the UK or EEA, we take steps to ensure that appropriate safeguards are in place to protect it. These safeguards may include transfers to countries that have been recognised by the UK Government or European Commission as providing an adequate level of data protection; the use of standard contractual clauses approved by the UK Information Commissioner's Office or the European Commission; or other legally approved transfer mechanisms.
By using the Platform, you acknowledge that your personal data may be transferred to and processed in countries outside the UK and EEA. If you would like further information about the safeguards we apply to international transfers, please contact us using the details set out in Section 13 of this Privacy Policy.
6. How Long We Keep Your Personal Data
We retain your personal data for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting obligations. The specific retention period for any category of data depends on the nature of the data, the purpose for which it was collected, and any applicable legal requirements.
Your account data and associated profile information are retained for the duration of your account with us and for a period of up to six years following account deletion or termination, to enable us to comply with our legal obligations, resolve disputes, and enforce our agreements. Financial transaction records are retained for a minimum of seven years in accordance with applicable tax and accounting legislation. Usage data and analytics are generally retained for up to two years, unless a longer retention period is necessary for the purposes of improving the Platform or complying with legal obligations. Communications you send to us, including customer support records, are retained for a period of five years.
Where we rely on your consent as the legal basis for processing, we will retain your data until you withdraw consent or as otherwise stated at the time consent is given. Where data is no longer required for any of the purposes described in this Privacy Policy and there is no legal basis for its continued retention, we will securely delete or anonymise it.
7. Cookies and Tracking Technologies
The Platform uses cookies, web beacons, software development kits (SDKs), pixel tags, local storage objects, and similar tracking technologies (collectively, "Cookies") to collect information about your use of the Platform, remember your preferences, and deliver a personalised experience.
Strictly necessary Cookies are essential to the operation of the Platform and enable core functions such as user authentication, session management, and security. These Cookies cannot be disabled without impairing the functionality of the Platform. Performance and analytics Cookies allow us to understand how users interact with the Platform, which pages are visited most frequently, and where errors occur. This information is used in aggregate to improve the Platform. Functionality Cookies allow the Platform to remember choices you have made, such as your language preference, notification settings, and display preferences, in order to provide you with a more personalised experience. Advertising and targeting Cookies may be used to deliver advertisements and promotional content that are relevant to your interests, to limit how many times you see an advertisement, and to measure the effectiveness of our advertising campaigns.
When you first access the Platform, you will be presented with a cookie consent notice that allows you to manage your Cookie preferences. You can also manage Cookies through your browser or device settings. Please note that disabling certain Cookies may affect the functionality or performance of the Platform. For further information about the specific Cookies we use, please refer to our Cookie Policy available at www.actxion.com.
8. Your Rights in Relation to Your Personal Data
Subject to applicable Data Protection Laws and certain conditions, you have a number of rights in relation to the personal data we hold about you. We will respond to any request you make in relation to these rights within one calendar month of receipt, although we may extend this period by a further two months where the request is complex or where we receive a large number of requests, in which case we will notify you of the extension.
You have the right to be informed about how we collect and use your personal data, which is the purpose of this Privacy Policy. You have the right of access to obtain a copy of the personal data we hold about you, together with information about how and why we are processing it. You have the right to rectification to require us to correct any inaccurate personal data we hold about you and to complete any incomplete data. You have the right to erasure (also known as the right to be forgotten) to request that we delete your personal data in certain circumstances, for example where it is no longer necessary for the purposes for which it was collected, where you withdraw consent and there is no other legal basis for processing, or where you object to processing and there are no overriding legitimate grounds. We may not always be able to comply with a request for erasure where we have a legal obligation to retain data.
You have the right to restriction of processing to request that we restrict the processing of your personal data in certain circumstances, for example while we are verifying the accuracy of data you have disputed or considering an objection you have raised. You have the right to data portability to receive a copy of personal data you have provided to us in a structured, commonly used, and machine-readable format, and to have that data transmitted directly to another controller where technically feasible, where the processing is based on your consent or the performance of a contract and is carried out by automated means. You have the right to object to processing based on our legitimate interests or for direct marketing purposes. Where you object to processing for direct marketing, we will always honour that request. Where you object to processing based on legitimate interests, we will cease processing unless we can demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or where processing is necessary for the establishment, exercise, or defence of legal claims.
Where we process your personal data on the basis of your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal. You also have the right not to be subject to solely automated decision-making, including profiling, that produces legal effects or similarly significantly affects you, unless it is necessary for a contract, authorised by law, or based on your explicit consent. You have the right to lodge a complaint with the UK Information Commissioner's Office ("ICO") if you believe we have processed your personal data in breach of Data Protection Laws. The ICO's contact details and information about how to make a complaint are available at www.ico.org.uk.
To exercise any of your rights, please contact our Data Protection contact at dataprotection@actxion.com. We may need to verify your identity before processing any request. There is generally no charge for making a request, although we reserve the right to charge a reasonable fee for requests that are manifestly unfounded or excessive.
9. Children's Privacy
The Platform is not directed at children under the age of thirteen (13), and we do not knowingly collect personal data from children under this age. If you are under thirteen, you must not use the Platform or provide any personal data to us. Users between the ages of thirteen (13) and seventeen (17) may use the Platform only with the prior consent of a parent or legal guardian, and by using the Platform they represent that such consent has been obtained.
If we become aware that we have inadvertently collected personal data from a child under the age of thirteen without appropriate consent, we will take prompt steps to delete that data from our systems. If you are a parent or guardian and believe that your child has provided us with personal data without your consent, please contact us immediately at dataprotection@actxion.com.
In jurisdictions where a higher minimum age applies for the lawful processing of children's personal data, we will comply with those higher age requirements. Where we are required to obtain parental or guardian consent for the processing of data relating to a child, we will take reasonable steps to verify that such consent has been obtained.
10. Security of Your Personal Data
The security of your personal data is of paramount importance to us. We implement and maintain a range of technical and organisational security measures designed to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include encryption of data in transit using industry-standard TLS protocols; encryption of data at rest; access controls that restrict access to personal data to authorised personnel on a need-to-know basis; regular security assessments and penetration testing; monitoring and logging of access to systems that hold personal data; staff training on data protection and information security; and incident response procedures for managing data breaches.
Notwithstanding the above, no method of transmission over the internet or method of electronic storage is completely secure, and we cannot guarantee the absolute security of your personal data. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority without undue delay and, where required by Data Protection Laws, we will also notify you directly.
You also play an important role in keeping your personal data secure. You should keep your account password and credentials confidential, use a strong and unique password for your ACTXION account, and notify us immediately if you suspect any unauthorised access to your account.
11. Third-Party Websites and Services
The Platform may contain links to, or integrations with, third-party websites, applications, and services that are not operated or controlled by ACTXION. This Privacy Policy does not apply to those third-party services and we are not responsible for their content, privacy practices, or policies. We encourage you to review the privacy policy of every third-party website or service you visit or use. The inclusion of a link to a third-party website does not imply any endorsement by ACTXION of that website or its operators.
12. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our data practices, the features and services available on the Platform, or changes in applicable law. When we make material changes, we will use reasonable endeavours to provide you with notice in advance of the change taking effect, whether through a prominent notice on the Platform, an in-app notification, or by email to the address associated with your account. The updated Privacy Policy will always display the date on which it was last revised at the top of the document.
Your continued use of the Platform following the effective date of any updated Privacy Policy constitutes your acknowledgement of the updated version. We encourage you to review this Privacy Policy periodically so that you remain informed about how we are protecting your personal data.
13. How to Contact Us
If you have any questions, concerns, or requests in relation to this Privacy Policy or our data practices, or if you wish to exercise any of your rights under Data Protection Laws, please contact our Data Protection contact using the details below. We will make every effort to address your enquiry promptly and thoroughly.
Website: www.actxion.com
If you are not satisfied with our response, you have the right to lodge a complaint with the UK Information Commissioner's Office (ICO) at www.ico.org.uk or by calling 0303 123 1113. If you are located in the EEA, you may also lodge a complaint with the supervisory authority in your country of residence.