Privacy Policy

Definitions and Interpretation

1. In this Privacy Policy, the following definitions are used:

   Data

   collectively all information that you submit to Field Level Tech Ltd via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;

   Data Protection Laws

   any applicable law relating to the processing of personal Data, including but not limited to the UK GDPR, and any national implementing and supplementary laws, regulations and secondary legislation;

   UK GDPR

   the UK General Data Protection Regulation;

   Field Level Tech Ltd, we or us

   Field Level Tech Ltd, a company incorporated in England and Wales with registered number 16126242 whose registered office is at 20 Wenlock Road, London, N1 7GU;

   User or you

   any third party that accesses the Website and is not either (i) employed by Field Level Tech Ltd and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Field Level Tech Ltd and accessing the Website in connection with the provision of such services; and

   Website

   the website that you are currently using, called-it.uk, and any sub-domains of this site unless expressly excluded by their own terms and conditions.

2. In this Privacy Policy, unless the context requires a different interpretation:
   1. the singular includes the plural and vice versa;
   2. references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this Privacy Policy;
   3. a reference to a person includes firms, companies, government entities, trusts and partnerships;
   4. "including" is understood to mean "including without limitation";
   5. reference to any statutory provision includes any modification or amendment of it;
   6. the headings and sub-headings do not form part of this Privacy Policy.

Scope of this Privacy Policy

3. This Privacy Policy applies only to the actions of Field Level Tech Ltd and Users with respect to this Website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites or external election information sources.
4. For purposes of the applicable Data Protection Laws, Field Level Tech Ltd is the "data controller". This means that Field Level Tech Ltd determines the purposes for which, and the manner in which, your Data is processed.

Data Collected

5. We may collect the following Data, which includes personal Data, from you:
   1. your email address (used to sign you in);
   2. your chosen display name (this may be a nickname; it does not need to be your real name);
   3. your predictions, league memberships, and scores generated through your use of the game;
   4. your marketing preferences (whether you have opted in to receive updates from us);
   5. technical information about your visit (see "Data That is Collected Automatically" below);
   in each case, in accordance with this Privacy Policy.

How We Collect Data

6. We collect Data in the following ways:
   1. data is given to us by you;
   2. data is collected automatically.

Data That is Given to Us by You

7. Field Level Tech Ltd will collect your Data in a number of ways, for example:
   1. when you sign up for an account by entering your email address;
   2. when you choose a display name;
   3. when you make predictions, join or create leagues, or otherwise use the game;
   4. when you contact us by email;
   5. when you opt in (or out) of marketing communications from us;
   in each case, in accordance with this Privacy Policy.

Data That is Collected Automatically

8. To the extent that you access the Website, we will collect some Data automatically, for example:
   1. technical information such as your IP address, browser type, device type, and the date and time of your visit, which passes through our hosting provider's infrastructure and is retained in server logs for security and diagnostic purposes;
   2. information about how you interact with the Website (e.g. the pages you visit) insofar as this is captured in server logs.
   We do not use third-party analytics or tracking services on this Website.

Cookies

9. This Website uses one strictly-necessary cookie: an encrypted session cookie that keeps you signed in after you log in with a magic link. Without this cookie, the Website cannot remember that you are logged in and you would need to sign in on every page.
10. We do not use advertising cookies, third-party tracking cookies, or analytics cookies. Because the session cookie is strictly necessary for the service to work, we do not display a cookie banner.

Our Use of Data

11. Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:
    1. to allow you to create and sign in to an account;
    2. to run the game — storing your predictions, calculating your scores, and showing your league standings;
    3. to send you transactional emails required for the service (for example, your magic sign-in link);
    4. to keep the Website secure and investigate suspected misuse;
    5. to improve the Website and fix bugs;
    6. if you have opted in, to send you occasional marketing updates about Fantasy Politics (see "Marketing" below);
    in each case, in accordance with this Privacy Policy.
12. We rely on the following lawful bases under the UK GDPR:
    1. Contract — for everything needed to operate your account and run the game.
    2. Legitimate interests — for security, fraud prevention, debugging, and service improvement.
    3. Consent — for marketing emails. You can withdraw this consent at any time (see "Your Rights" below).

Marketing

13. We will only send you marketing emails if you have explicitly opted in by ticking a consent box at sign-up or in your account settings. The wording of the consent is:

    I want to receive occasional updates about Fantasy Politics

    "Fantasy Politics" refers to the family of political prediction games operated by Field Level Tech Ltd, of which Called It is one. If you opt in, we may use your email address to tell you about new games, significant new features, or other updates within the Fantasy Politics family.
14. Every marketing email we send will contain a clear unsubscribe link. You can also withdraw your consent at any time by changing your preference in your account settings or by emailing us at contact@fieldleveltech.org. Transactional emails (such as your magic sign-in link) will continue regardless, as they are required to operate your account.

Who We Share Data With

15. We share limited Data with the following third-party service providers who help us run the Website:
    1. Resend (resend.com) — our transactional email provider, used to deliver magic sign-in links and, if you have opted in, marketing emails. Your email address is shared with Resend for this purpose.
    2. Cloudflare — our hosting and infrastructure provider. The Website runs on Cloudflare Workers and uses Cloudflare D1 (a managed database) for storage. Cloudflare therefore processes all Data you send to or receive from the Website.
16. We do not sell your Data to anyone, and we do not share it with advertisers.
17. We may also share your Data with our employees, agents and professional advisors where necessary and in accordance with this Privacy Policy.

Keeping Data Secure

18. We will use technical and organisational measures to safeguard your Data, for example:
    1. access to your account is controlled by magic-link sign-in — we do not store passwords, reducing the risk of password leaks;
    2. your session cookie is encrypted;
    3. we store your Data on secure infrastructure provided by Cloudflare;
    4. all communication between you and the Website is encrypted using HTTPS.
19. Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: contact@fieldleveltech.org.
20. If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

Data Retention

21. Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this Privacy Policy or until you request that the Data be deleted.
22. Server logs containing technical information such as IP addresses are kept for a short period (typically no longer than 30 days) for security and diagnostic purposes.
23. Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.

Your Rights

24. You have the following rights in relation to your Data:
    1. Right to access — the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is "manifestly unfounded or excessive." Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
    2. Right to correct — the right to have your Data rectified if it is inaccurate or incomplete.
    3. Right to erase — the right to request that we delete or remove your Data from our systems.
    4. Right to restrict our use of your Data — the right to "block" us from using your Data or limit the way in which we can use it.
    5. Right to data portability — the right to request that we move, copy or transfer your Data.
    6. Right to object — the right to object to our use of your Data including where we use it for our legitimate interests.
25. To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: contact@fieldleveltech.org.
26. If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner's Office (ICO). The ICO's contact details can be found on their website at https://ico.org.uk/.
27. It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.

Children

28. Called It is not intended for children under the age of 13. We do not knowingly collect personal Data from children under 13. If you are under 13, please do not sign up for an account. If we become aware that we have collected personal Data from a child under 13 without verifiable parental consent, we will take steps to delete that information.

Transfers Outside the United Kingdom and European Economic Area

29. Data which we collect from you may be stored and processed in and transferred to countries outside of the UK and European Economic Area (EEA). In particular, both Cloudflare and Resend are US-based service providers, and your Data may be processed on servers outside the UK or EEA.
30. We will only transfer Data outside the UK or EEA where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, e.g. by way of the UK International Data Transfer Agreement or the current standard contractual clauses adopted by the European Commission.
31. To ensure that your Data receives an adequate level of protection, we have put in place appropriate safeguards and procedures with the third parties we share your Data with. This ensures your Data is treated by those third parties in a way that is consistent with the Data Protection Laws.

Links to Other Websites

32. This Website may, from time to time, provide links to other websites, including official election information sources and social media platforms. We have no control over such websites and are not responsible for the content of these websites. This Privacy Policy does not extend to your use of such websites. You are advised to read the Privacy Policy or statement of other websites prior to using them.

Changes of Business Ownership and Control

33. Field Level Tech Ltd may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Field Level Tech Ltd. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the Data for the purposes for which it was originally supplied to us.
34. We may also disclose Data to a prospective purchaser of our business or any part of it.
35. In the above instances, we will take steps with the aim of ensuring your privacy is protected.

General

36. You may not transfer any of your rights under this Privacy Policy to any other person. We may transfer our rights under this Privacy Policy where we reasonably believe your rights will not be affected.
37. If any court or competent authority finds that any provision of this Privacy Policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this Privacy Policy will not be affected.
38. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
39. This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.

Changes to This Privacy Policy

40. Field Level Tech Ltd reserves the right to change this Privacy Policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the Privacy Policy on your first use of the Website following the alterations.

You may contact Field Level Tech Ltd by email at contact@fieldleveltech.org.