How this Policy Works
This Policy is intended to explain when, why, and how we use and process information that may relate to you (“personal data”). It also gives you information about your statutory rights. It does not override the terms of any contract you have with us, nor rights you may have under data protection laws.
- Who Is Responsible For Overseeing Your Personal Data
- What Personal Data We Collect And Process
- How We Use Your Personal Data And When We Process It
- With Whom We Share Your Personal Data
- Non-eu Transfers
- Direct Marketing
- How Long We Retain Personal Data
- Your Rights
1. Who Is Responsible For Overseeing Your Personal Data
XXXXXX having its registered address as XXXXXXXXXXXXXXXXXXXXXXXXXX, is principally responsible for looking after your personal data (your Data Controller). Data Controller means the company that determines the means and purposes of processing of personal data.
Please note that, although we are the Data Controller, with principal responsibility for looking after your personal data, such data might be accessible by other companies. In such cases, those companies are required to comply with the standards set out in this Policy.
XXXXXXXX is a group of companies, with subsidiaries based and operating in several other countries and jurisdictions.
2. What Personal Data We Collect And Process
The following personal information may be collected and processed by us:
- Data of birth
- Email address
- Phone number
- IP address
- Location data
- Website usage
- Content submitted by you, for example: posts, personal preferences and setting, opinions, comments, complaints, chats and other communications
- If you submit a complaint, the account name, or username, and email address registered with the casino or gaming operator against which the complaint is directed
- Miscellaneous information you share directly with us, or other information we may ask you for. This could include information you provide us with in the process of handling a complaint you have submitted, or content submitted to the forum, or via live chat or other communication.
3. How We Use Your Personal Data And When We Process It
XXXXXXX collects information directly from you, or your device, whenever you use our services, or visit any of our websites. We use your personal data to enable us to provide you with our services in the following ways:
- To create and manage your account
- To check if you are eligible to claim our bonuses and offers
- To enable effective communications with you, respond to your enquiries, or provide assistance via our Livechat or Support features
- To provide you with promotional emails relating to products and services, subject to the information contained in Section 6 on Direct Marketing
- To perform analysis of our systems and databases, which enables us to improve our business and websites based on user preferences
- To ensure we can provide appropriate, targeted advertisements
- To register you on a chat forum or community, enabling you to interact and participate
- To enable the handling and appropriate routing of a complaint you have submitted, with the goal of providing a fair, honest, and independent complaints resolution service
- To meet or exercise any of our legal obligations and/or rights
We will strive to only use and process your personal data for the purposes set out in this Section 3, and where we are reasonably satisfied that you have given your consent for us to use the data in such a way, or where our use of your personal data is necessary to enable and/or support ‘legitimate interests’ relating to our business. Examples of this would be to improve our products and services, for analytical purposes, or to help deliver a fair and independent complaints resolution service between players and gaming or betting operators, in a way that is proportionate and appropriate and respects your privacy.
4. With Whom We Share Your Personal Data
In order to deliver our products and services, and ensure the best possible user experience, we work with several third party companies. From time to time, when necessary and justified, these companies may require access to your personal data. Below is a non-exhaustive list to give you a better idea of these third parties:
- Mailing application service providers
- Service providers or data processors. For example, cloud services and authentication providers.
- Gaming or betting operators (in the event of a complaint being submitted)
- Subsidiaries of XXXXXXXXXXX located inside and outside of the EU/EEA. Any personal data transfers between group subsidiaries will be subject to the XXXXXXXXX intra group data transfer agreements
- Government, regulatory, legal, or law enforcement bodies, if we are under a duty to disclose or comply with a legal obligation or to protect our interests or security
- Parties involved with the sale, acquisition, or re-organisation of any of our businesses or assets, including prospective sellers or buyers
5. Non-EU/EEA Transfers
Non-EU/EEA transfers refers to the transfer of personal data to a jurisdiction outside of the European Union/European Economic Area. As set out in Section 4 above, we may provide access to your personal data to third parties located outside of the European Union/European Economic Area. Such third parties may also include foreign law enforcement or regulatory bodies upon receipt of a valid request (to protect your rights, we will always check all such requests to ensure their legitimacy, before transferring information).
We will take appropriate steps to ensure all such information transfers are managed in a way that protects your rights and interests. You are entitled to request further information regarding the safeguards put in place to protect your rights and privacy. Please contact us for further information.
6. Direct Marketing
We may use your personal information in order to provide you with direct marketing communications. Such communications may include products and services offered by ourselves or our partners, for example; online casino, sports betting, financial, and informational services or products. Such marketing communications may take the form of email, targeted online advertising in various formats (graphical banners, pop-ups, videos, text ads etc), push notifications, and others.
The use of personal data for marketing purposes will be based on our legitimate interests (see Section 3 above). When required by specific laws, it will be based on your explicit or implied consent, as appropriate. You are entitled to opt out of direct marketing at any time. You can conveniently do this by using the opt-out links provided in all direct marketing communications. Should the links be missing or non-functional, or if you prefer, you are welcome to contact us directly.
We make every effort to ensure our marketing communications are reasonable and proportionate, and are of interest or relevance to you based on the information we have. If you feel any communications do not meet the above criteria, or that they have been sent due to a technical error, please do not hesitate to let us know so that we can rectify the situation.
7. How Long We Retain Personal Data
Our normal practice is to retain your personal data for as long as reasonably necessary for the purposes listed in Section 3 above. Information may be retained for periods specified by regulators or legal bodies for the purposes of legal, tax, accounting, or other official requirements. A data retention policy is in place for personal data in our care. If your data is no longer required, we will securely delete it from our systems, or render it anonymous so that it can only be used for appropriate statistical purposes, but is no longer identifiable.
8. Your Rights
Your specific rights relating to your personal data are detailed below. You are entitled to exercise these rights at any time, and can do so by sending an email to XXXXXXX@XXXXXX or by writing to XXXXXXXXXXXXX at the address provided in Section 1 above.
You can ask us to:
- Confirm if we are holding and processing your personal data
- Provide a copy of your personal data
- Provide further information regarding your personal data, for example, what we use it for, who has access to it, if we have transferred it outside of the EU/EAA and how it is being protected, how long it will be kept for, your rights, how you can file a complaint, where we got the data from, if we have carried out any Automated Decision Making or Profiling etc.
You can ask us to rectify any inaccurate information. Please note that we may require verification before we amend any data.
You have the right to request the erasure of your personal information, subject to the following conditions:
- It is no longer needed for the purposes it was collected for
- The data was subject to processing by consent, and you withdraw your consent
- Following a successful right to object (see ‘Objection’ below)
- That data has been processed unlawfully
- To comply with a legal obligation
Please be aware that we are not required to comply with a request to erase personal data if the processing of that personal data is deemed necessary for certain specific circumstances, including but not limited to:
- To comply with a legal obligation
- For the establishment, exercise or defence of any legal claims
You may ask us to keep your data, but restrict its use, in the following circumstances:
- The data is no longer needed for the purposes it was originally collectorate for, but we still need to retain it to establish, exercise, or defend legal claims
- The processing has been deemed unlawful, but you do not want us to erase or anonymise it
- You are contesting its accuracy (see RECTIFICATION), and we need to retain it to verify its accuracy
- You have exercised your right to object, and the verification of overriding grounds is still pending.
In the following circumstances we may continue to use your personal data, even after a request for restriction:
- You have provided consent
- We need to in order to establish, exercise, or defend legal claims
- We need to in order to protect the rights of another natural or legal person or entity
You are entitled to have your personal data provided to you in a structured, widely used, machine-readable format, or have the information ‘ported’ to another Data Controller, in cases where:
- The processing is based on your consent, or on the performance of a contract with you
- The processing of information is carried out by automatic means
If you believe your fundamental rights and freedoms outweigh our ‘legitimate interests’ as a legal basis for processing your personal data, you are entitled to file an objection. In such cases, we reserve the right to demonstrate that our ‘legitimate interests’ override your rights and freedoms.
You may request a copy of, or reference to, the safeguards that cover any transfers of your personal data to jurisdictions outside of the European Union or European Economic Area.
Please note that, for reasons of commercial sensitivity and security, we may redact data transfer agreements or related documents (censor certain information).
You have the right to file a complaint with the appropriate local supervisory authority regarding our processing of your personal data at any time. However, in the interests of addressing your concerns as quickly and effectively as possible, we do ask that you contact us first.