Effective Date – 23 May 2018
For further information, please go to paragraph 1.
What kind of personal data do we collect about you?We might collect data from and about you.
In particular, the Company may collect (1) registration data, (2) public data and posts, (3) data that you have permitted social media to share with the Company and (4) activity data.
However, we do not collect either financial information from a payment service provider or sensitive data relating to you.
For further information, please go to paragraph 2
How do we use your personal data?The main reason why we collect data about you is to provide you with Company Services and to allow you to interact with those services.
In addition, with your prior consent, we can send you offers, promotions and marketing communications, also based on your personal preferences and habits.
For further information, please go to paragraph 3.
On what basis do we use your personal data?Your personal data is mainly collected in order to provide you with Company Services.
Your personal data is also necessarily collected to comply with legal obligations or to pursue the legitimate interests of the Company.
If you don’t provide the data we won’t be able to offer you the Company Services.
When your personal data is collected for marketing purposes, you have the option not to provide the Company with your personal data.
For further information, please go to paragraph 4.
How do we process your personal data?The security of your data is a priority for us. We have implemented adequate administrative, technical and physical measures designed to safeguard your personal data against loss, theft and unauthorised use, disclosure or modification.
For further information, please go to paragraph 5.
Who can access to your personal data?
We might share your personal data with: (i) service providers; (ii) our affiliated companies; and (iii) national authorities, when allowed by the applicable laws.
For further information, please go to paragraph 6.
Is your personal data transferred abroad?Your personal data might be transferred to other countries within or outside the European Economic Area. We always make sure that appropriate and suitable safeguards compliant with applicable laws are in place to protect your personal data.
For further information, please go to paragraph 7.
What are your rights with regard to your personal data?You have a number of rights with regard to your personal data and these include the right to access, complete, update, amend and delete your personal data.
For further information, please go to paragraph 8.
Retention period applying to your personal dataThe personal data we collect is retained for only for the period necessary to fulfill the purposes for which that data is collected.
For further information, please go to paragraph 9.
How can I contact you with regard to the processing of my personal data?You can contact us at the following email address firstname.lastname@example.org.
The Company Services are for a general audience, are not targeted at children, and do not knowingly collect personal data from children under 16 years of age.
2. WHAT KIND OF PERSONAL DATA DO WE COLLECT ABOUT YOU?
The Company collects the following types of data from and about you:
1. Registration data is the information you submit to register for a Company Service (if made available by the Company), for example to create an account, post comments, receive a newsletter, or enter a contest. This data may include, for example, name, surname, email address, gender, country, postcode and age.
2. Public data and posts are comments or content that you post on the Company Services and the personal data about you that accompanies those posts or content, which may include a name, user name, comments, likes, status, profile information and picture. Public information and posts are always public, which means they are available to everyone and may be displayed in search results on external search engines.
5. Information from Other Sources. We may supplement the information we collect with information from other sources, such as publicly available information about your online and offline activity from social media services and commercially available sources.
6. Information from you. If you supply us with your contact information or any other information as part of any customer support we provide you with or if you make a complaint or enquiry or provide other feedback to the Company we will collect that too.
We do not collect:
2. Sensitive Information: We ask that you do not send us, and you do not disclose, any sensitive personal data (such as national insurance numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership) on or through the Company Services or otherwise.
3. HOW DO WE USE YOUR PERSONAL DATA?
We use the personal data we collect from and about you to:
a) Provide the Company Services and features to you;
b) Measure, analyze and improve those Company Services and features;
c) Improve your experience with both online and off-line Company Services by delivering content you may find relevant and interesting;
d) Allow you to comment on content, and participate in online games, contests, or rewards programmes;
e) Provide you with customer support and to respond to inquiries;
g) Comply with applicable laws or legal process and/or respond to requests from public and government authorities;
h) Complete a corporate transaction, such as a proposed or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Company business, assets or stock (including in connection with any bankruptcy or similar proceedings). For example, if the Company is involved in a merger or transfer of all or a material part of its business, the Company may disclose and transfer your personal data to the party or parties involved in the transaction as part of that transaction;
i) Allow social sharing functionality; if you log in with or connect a social media service account with the Company Services, we may share your user name, picture, and likes, as well as your activities and comments with other Company Services users and with your friends associated with your social media service. We may also share the same personal data with the social media service provider;
j) With your prior consent, send you (via email, SMS, telephone, chat and social media) offers, promotions and other marketing communications regarding the Company Services, other services/products of the Company and/or Company Affiliates and/or third parties operating in the gaming and gambling sector (where you are aged 18 or over and reside within a territory where it is lawful to send you information about that sector) including group companies and co-branded services or features, such as contests or other promotions arranged together with a third party or Company Affiliate that may be hosted on the Company Services or on the Company Affiliate or third party’s service;
k) With your prior consent, send to you marketing communications customized to your interests and needs by means of the channels of communication set out under letter j) above.
We may use anonymised information or information that no longer identifies you personally, even indirectly (e.g. statistics) for any purpose or share it with third parties.
4. ON WHAT LEGAL BASIS DO WE PROCESS YOUR PERSONAL DATA?
The processing of your personal data for the purposes of:
The processing of your personal data for the other purposes of:
• Paragraph 3, letter i), is discretionary, but, without your consent, it is impossible to connect a social media service account with the Company Service so that you will have to log to the Company Service using a different mechanism;
• Paragraph 3, letters j) and k), is discretionary, but, without your consent, it is impossible for the Company and/or third parties to provide you with our generic marketing communications and those related to third parties services/products based on your interests and needs and to provide co-branded services.
You can revoke your consent to the processing of your personal data for the purposes of Paragraph 3, letters i) to k) at any time by sending a communication to the email address described in Paragraph of 11 below.
5. HOW DO WE PROCESS YOUR PERSONAL DATA?
We process your personal data through both electronic and manual means. It is protected by adequate security measures, taking into account the state of art, the costs of implementation and the nature, scope, context and purpose of processing as well as the risk to the rights and freedoms of individuals. In particular, we use appropriate administrative, technical, personnel and physical measures to safeguard personal data of yours in the Company’s possession against loss, theft and unauthorised use, disclosure or modification.
6. WHO CAN HAVE ACCESS TO YOUR PERSONAL DATA?
We may share your personal data for the purposes set out in Paragraph 3 to the following categories of recipients located within the European Union or outside of the European Union in compliance with and within the limits of the provisions of Paragraph 7:
a) Third party service providers entrusted with processing activities and duly appointed as processors when required by applicable laws e.g. cloud service providers, other entities of the group, providers of services instrumental to or supporting the Company Service including for companies that provide IT services, experts, consultants, lawyers and companies resulting from possible mergers, demergers, or other transformations;
b) Company Affiliates in their capacity as data controllers or data processors;
c) Business partners after your prior consent, the Company may share your personal data with business partners operating in the sectors named within that specific consent to permit them to send you marketing communications; and
d) Competent authorities in order to comply with applicable laws and regulations.
The Company may use a third party, Campaign Monitor, to send you marketing emails (if you have opted in to receive them). They are our data processor and your email address is transferred to the USA in order to use their service. We have procedures in place with Campaign Monitor to ensure your personal information receives the same protection as if it were being processed inside the EEA.
7. IS YOUR PERSONAL DATA TRANSFERRED ABROAD?
Your personal data may be transferred to other countries (including countries other than where you are based that have a different data protection regime than the one existing in the country where you are based). If you are located in the European Economic Area (EEA), this may include countries outside of the EEA and in particular the United States. You can find the list of member states by clicking on the following link: https://europa.eu/european-union/about-eu/countries/member-countries_en. We have adopted appropriate safeguards to protect your personal data regardless of where it resides. Further information can be provided by filing a request to the Company as in Paragraph 11 of this Privacy Notice.
8. WHAT ARE YOUR RIGHTS WITH REGARD TO YOUR PERSONAL DATA?
You have the right to:
a) Obtain confirmation as to whether or not your personal data exists and to be informed of its content and source, verify its accuracy and request its rectification, update or amendment;
b) Request the deletion, anonymisation or restriction of the processing of your personal data processed in breach of applicable law;
c) Object to or request the limiting of the processing, in all cases, of your personal data for legitimate reasons;
d) Receive an electronic copy of your personal data, if you would like to port the personal data, which you have provided to us, to yourself or to a different provider (data portability), when the personal data is processed by automatic means and the processing is either (i) based upon your consent or (ii) necessary for the provision of the Company Service; and
e) Lodge a complaint with the relevant data protection regulatory authority.
You may send your request to the address indicated under Paragraph 11. In your request, please include your email address, name, address, and telephone number and specify clearly which information you would like to access, change, update, suppress, or delete.
Remember that even after you cancel your registration (if applicable) or if you ask us to delete your personal data, copies of that information from your registration may remain viewable in some circumstances where, for example, you have shared information with social media or other services or, for example, when retention of copies is necessary to comply with legal obligation or legal defence. Because of the nature of caching technology, your registration may not be instantly inaccessible to others. We may also retain backups of your personal data on our servers for some time after cancellation or your request for deletion, to comply with applicable law.
Where your personal data is used for marketing purposes you may revoke your consent for:
9. RETENTION RIGHTS
We will retain your data only for the period necessary to fulfill the purposes for which the data was collected. The following retention periods will apply to the processing of your personal data:
• Data collected for the purpose as per Paragraph 3, letters j) and k) are retained for as long as is necessary to send you the marketing communications you’ve opted in to receive.
At the end of the retention period your personal data will be either cancelled, anonymised or aggregated.
11. CONTACT US