We may modify this Policy from time to time. Any changes to our Policy will become effective upon posting of the revised Policy on the Website.
Our legal status under data protection law is that of a data controller and in this capacity we will securely store and process your personal data which you have provided to us. Data controller is a legal term used to signify the organisation that controls what to do with any given personal data.
The steps we take to protect your personal data and how you can review and correct your personal data are also covered here.
2. Information we collect about you
We may collect and process the following information about you which may include personal data:
• your name;
• email address;
• phone number;
• bank account information;
• any other information provided at the time of registering to use our Website, subscribing to any of our services (including promotions about products), posting material or requesting further services;
• location data;
• information you provide when entering a promotion or competition, making a Customer Support enquiry or complaint or when you report a problem with our Website; • records of correspondence if you contact us about any matters;
• your responses to any optional surveys we conduct for research purposes;
• your Marketing preferences;
• details of bets, gaming, payments and other transactions that you conduct on our Website and details of the fulfilment of such transactions;
details of your visits to our Website including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise, and the • web pages and resources that you access;
• information and communication on forums on the Website including any responsible gaming enquiries, for example, live chat; and
your telephone conversations may be recorded both to assist us in training and in quality management, and to allow for the speedy resolution of queries.
You are not required to provide any of this information, but if you do not, we may not be able to provide you the requested services.
We may also observe your use of the Website and derive certain information from this which may include personal data.
3. Use of your information
We will process your personal data for the purposes set out below. We may also process personal data within our Group and share the Information with our third-party data processors, all of whom adhere to this Policy, and who only process your personal data on our behalf for the purposes set out below:
• setting up, re-activating, operating and managing your account, including providing the services that you request from us (including with our white label licensees);
building up personal profiles of our players;
• providing you with information about promotional offers, but only where you have consented to receive such offers;
verifying the accuracy of the information collected from you, including disclosing your personal data to third parties (such as financial institutions, credit reporting agencies and age verification agencies) regarding such verification;
• complying with our legal and regulatory duties and responsibilities to the relevant licensing and regulatory authorities;
• processing card and on-line payments relating to our services (including our Affiliate Programs);
• conducting data cleansing, verification and enhancement exercises (for example, verifying your information against third party databases);
• any other purpose which is necessary for the performance of our contractual obligations to you;
• training and quality management;
• providing key information to potential purchasers or investors in any of the companies within the Group;
• storing such Information on our behalf, for example by using cloud computing service providers; and
• undertaking research, conducting surveys, technical diagnostics, research analyses and obtaining feedback from our players.
There are a number of different grounds on which we will process your personal data, depending on the type of data and the purpose. Generally, we will process your personal data because it is necessary to do so in order to provide you with the services that you have requested from us. In addition, we have certain legal obligations which will require us to process your personal data (such as verifying your identify when you register with our service). On occasion we may process your personal data because you have consented to us doing so (such as where you request marketing communications). If none of the foregoing apply then we may still process your personal data where it is in our legitimate interests but only where such processing is in line with the purposes set out in this Policy and where such process does not prejudice your rights and freedoms.
We may use non-personal information (which is non-identifiable information that, when taken alone, cannot be used to identify or contact you). This could include gameplay information, technical information and analytics information. As such, we are not aware of the identity of the user from which the non-personal information was collected. We use such information for different purposes, such as advertising, improvement of our services, preventing fraud and performing web analytics. We may gather such information, either independently or through the help of our third-party service providers.
4. Data transfer
Since we operate globally, it may be necessary to transfer your Information to countries outside the European Union. The data protection and other laws of these countries may not be as comprehensive as those in the European Union − in these instances we will take steps to ensure that an adequate level of protection is given to your personal data.
We, as a Group, may use your information, such as your name, home address, email address, telephone number etc, ourselves or by using our third party subcontractors for the purpose of providing you with promotional materials, concerning our Website as well as products, services, websites and applications which relate to: (i) other companies within the Group; (ii) White Label Brands; or (iii) Group's business partners and affiliates (together the ‘Marketing Affiliates’), which we believe may interest you.
We may also share and disclose Information with our Marketing Affiliates for the purpose of providing you different marketing offers, which we, or our Marketing Affiliates, believe are relevant for you. Our Marketing Affiliates may use this information for different marketing techniques, such as direct email, post, SMS and telephone marketing purposes.
We, or our Marketing Affiliates acting on our behalf, will only send you marketing communications where you have consented to receive such communications. You may at any time decline receiving further marketing offers from us or from our business partners and Marketing Affiliates by contacting us or following the link in the relevant communication to unsubscribe. Please note that even if you unsubscribe from our marketing mailing list, we may continue to send you service-related updates and notifications.
6. Monitoring transactions
All bets, gaming and account transactions are recorded on our computer system. We also carry out routine monitoring of all transactions as they take place to assist us in improving the service that we provide to you and to comply with our licensing and regulatory obligations.
We employ security measures to protect your personal data from access by unauthorised persons and to prevent unlawful processing, accidental loss, destruction and damage. These safeguards vary based on the sensitivity of the information that we collect and store. Protection of your personal data, including your registration details and any debit or credit card information you provide to us, is a priority for us.
Data on our secure pages is encrypted using Secure Sockets Layer (SSL) technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Websites, you are responsible for keeping this password confidential.
Any personal data which identifies you will always be encrypted whilst in transit over the internet. SSL is a special protocol that automatically encrypts any information sent by you on our secure pages. Our server then reads the information using a private key. This means that your personal data, be it debit or credit card information or any other personal details, is turned into a code that can only be decoded with the private key or password. If your browser is suitably configured, you will receive a warning message when you first access any secure page on the Website. This is simply information to advise you that the Website is protecting your Information.
Unfortunately, the transmission of Information via the internet is not completely secure. Although we will do our best to protect your Information, we cannot guarantee the security of any personal data that you disclose online. You accept the inherent security implications of using the internet and will not hold us responsible for any breach of security unless we have failed in our obligations under data protection legislation. For your own privacy protection, we encourage you not to include sensitive Information (such as credit/debit card numbers) in any emails you may send to us.
8. Cookies and pixels
A 'cookie' is a small text file containing small amounts of information which is downloaded to your device when you visit a website or use applications. The cookie enables the server to collect information from the browser. We may use the following types of cookies:
PERSISTENT COOKIES: These are saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, so the correct language is presented and to improve our users’ experience of the Website as well as present different marketing messages and advertisements for existing users;
FUNCTIONAL COOKIES: Functional cookies are used to remember your preferences on our Website, enhancing the user experience. This can have a range of functions such as remembering your username or recording that you have read a site message so you don’t need to view it again;
SESSION COOKIES: Session cookies are used by the server to store information about user page activities so users can easily pick up where they left off on the server's pages.
We use a number of different cookies on this Website to help us to recognise you, track your activity and improve your use and experience of the Website. In addition, we use a number of third party service providers, who also set cookies on this Website, in order to deliver the services that they are providing to us. Such services include, but are not limited to, helping us to improve your use and experience of the Website by tracking your activity on the Website, measuring the effectiveness of the Website and the effectiveness of our marketing campaigns.
Some people find the idea of a website storing information on their computer or mobile (or other) device intrusive, particularly when this information is stored and used by a third party without them knowing. Although this is generally quite harmless, you may not, for example, want to see advertising that has been targeted to your interests. If you prefer, it is possible to block some or all cookies, or even to delete cookies that have already been set but you need to be aware that you might lose some functions of that website. Most online browsers automatically accept cookies. However, if you wish to restrict or block cookies you can modify your browser settings. Information on deleting or controlling cookies is available at https://ico.org.uk/for-the-public/online/cookies/.
We also use pixel based tracking to track a visit or event on the platform and to track advertisements' impressions. This information is also used by us for remarketing purposes and for tracking conversions that are used to optimize our marketing activities. We may share such information (which is non-personal information) with our advertising and marketing partners. Please see specific information about our marketing practices in section 5.
By accessing and using the Website and services, you consent to the placement of cookies and pixels on your device in accordance with this Policy.
9. Accuracy and changes to information
We will take all reasonable steps to ensure that any personal data that we collect from you is accurate and has been verified. We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion
If you are in ever concerned with the accuracy of the personal data provided by you, or would like your personal data to be changed or removed from your account records, you can use the tools made available on the Website to update or remove these details. However, please remember that deleting information from your account may result in access to areas of the Website to be restricted, particularly where we are no longer able to verify your identity. Please note that we will not provide refunds for prepaid services that may become inaccessible due to the deletion of your information.
10. Your rights
You have the following rights in relation to your personal data:
• a right of access to a copy of the information comprised in your personal data;
• a right to request a copy of your personal data in machine-readable format and have this provided to you or to a third party data controller;
• a right to object to processing that is likely to cause or is causing damage or distress;
• a right to object to decisions being taken by automated means;
• a right in certain circumstances to have inaccurate personal data rectified, blocked, erased or destroyed; and
• a right to claim compensation for damages caused by a breach of data protection legislation.
If you are unsure about your rights or are concerned about how your personal data may be processed you should contact the Information Commission's Office.
If you contact us in relation to your rights we will do our best to accommodate your request or objection. Please note, however, that not all rights are absolute.
If you request a copy of personal data that we hold about you, we may require ID and we may charge an administrative fee to meet our costs in complying with this request.
11. Retention of information
We will hold your personal data for so long as you use our service and for no more than five years after (unless required to be kept longer in accordance with legal and regulatory requirements). We will endeavour to delete any personal data sooner where it is not necessary for us to hold this, but please be aware that we may hold personal data for longer if we are under a legal obligation to do so or where we have a reasonable belief that it is necessary to do so for business or legal reasons.
From time to time, we may use player contact details to send you information about our services, which you accessed or subscribed to, including, but not limited to news about product updates, events, promotional materials and contests. You can opt out of these communications should you wish. Additionally, it is also possible to discontinue all general communications whilst receiving important update messages. For ease, each communication from us will include instructions for discontinuing the receipt of further communications. Please note that we may send you e-mails on certain topics which you will not be eligible to unsubscribe from as we consider them an essential part of the service.
13. Third party collection of information
Please keep in mind that this Policy does not apply to any third-party websites, services or applications, even if they are accessible, downloadable, or otherwise distributed through the Website. You should always review their privacy practices carefully before providing personal information to such third parties. You are knowingly and voluntarily assuming all risks of using any third-party websites, services or applications. You agree that we shall have no liability whatsoever with respect to such third-party sites and your usage of them.
14. Corporate transaction
We may share Information in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, reorganization, bankruptcy, consolidation or asset sale of an asset or transfer in the operation thereof) in relation to any company within the Group. In the event of the above, the acquiring company or transferee will assume the rights and obligations as described in this Policy.
15. Disclosure for legal reasons
We may occasionally be required by law, court order or governmental authority to disclose certain types of personal data. Examples of the type of situation where this would occur would be:
in the administration of justice; or
where we have to defend ourselves legally.
Date: Last updated on 1st November 2017