This policy applies to applications which are operated by Daub Alderney Limited (‘Daub’) (Bailiwick of Guernsey) which is a company registered in Alderney and licensed by the Alderney Gambling Control Commission (AGCC) and by the UK Gambling Commission (UKGC) to provide its online gaming products and services to its customers. Daub is a data controller and is registered with the Office of the Data Protection Commissioner in the Bailiwick of Guernsey.
Daub is part of The Rank Group Plc group of companies (‘Rank Group’) which operates gaming venues in Europe and digital gaming sites, including the Bella Casino, Enracha, Grosvenor Casino, Luda Bingo and Mecca Bingo brands.
In order to provide our products and services to our customers we need to process personal data about them. The processing activities that we may carry out in relation to your personal data include requesting it, collecting it, storing it, analysing it and sharing it.
Personal data is information about you and that identifies you or may reasonably identify you (in conjunction with any other information that we hold about you) for example, your name, e-mail address, address or telephone number, IP address, copies of ID, proof of address, etc.)
The personal data that we may collect, and process includes information within the following categories:
Personal data collected directly from data subjects:
Personal data collected from other sources:
Occasionally, we may be provided with or request the provision of personal data by or from a third party or alternative source which is not the data subject. Examples include:
Special categories of personal data are specific categories of personal data related to a person’s profile: race or ethnicity; political, religious or philosophical beliefs; sexual life or sexual orientation; health; genetic or biometric data; or trade union membership.
We process the following Special Categories of Personal Data:
We may process these special categories of personal information in order to comply with any legal, regulatory and social protection obligations to which we are subject.
We process personal data for a number of legal reasons or grounds which may include:
Where the processing of personal data about you is necessary for the furtherance of our legitimate interests, that processing is conditional upon those legitimate interests not being overridden by your interests or by your fundamental rights and freedoms. You are entitled to request information from us concerning the decisions that we may have made to process your personal data for the purposes of our legitimate interests.
There are cases where in order to process your personal data, we need your consent to do so. However, we are under legal and regulatory obligations to obtain certain personal data from you before we can provide our products and services to you. Accordingly, while you may not be obliged to provide us with your personal data, if you do not do so, we may be unable to provide you with products and services.
Where the legal basis for processing personal data about you is your consent (for example, to send you marketing materials), then you may at any time withdraw your consent by contacting the website support centre for the application(s) concerned, by changing the settings in your account or changing the settings of your cookies. Where you withdraw your consent for us to process personal data about you, we may not be able to provide you, or continue to provide you, with certain products and services.
Where you have not provided consent and/or have withdrawn your consent to certain processing activities (for example, marketing activities) we may need to continue to process your personal data for other legal reasons which may include: other aspects of performance in relation to the contract between us, for a legitimate interest, or in connection with legal or regulatory obligations to which we are subject.
We use personal data for the following purposes:
Subject to customer consent, we share personal data with carefully selected third parties engaged in the business of providing marketing and promotional services. We do this in order to improve customer experience of our products and services, to make additional and promotional products and services, to develop new and improved services, and to offer promotions and rewards.
Where you have provided your consent to further marketing activities you may receive advertisements and other promotional materials about the products and/or services of third parties which may be of interest to you. In order to ensure that we offer our users carefully selected additional products and services we use data analysis techniques, including profiling, in order to analyse your age, location, playing patterns and behaviour, preferences and interests. The conclusions that we make, having undertaken such customer analysis, enables us to ensure that you receive marketing, promotional and other additional material which is uniquely tailored to you.
You may at any time object to and/or withdraw your consent to the any further marketing activities by checking and updating your contact details within your account or selecting the ‘unsubscribe’ link at the end of our marketing and promotional update communications to you, or by contact us. If you decide to withdraw your consent for the use of your personal data for marketing purposes, we will cease to process personal data concerning you for such purposes.
The sharing of personal data about our customers between entities within the Rank Group is governed by a binding corporate agreement pursuant to which all members of the Rank Group have agreed to adhere to the standards of GDPR.
We may also be required to disclose personal data in certain circumstances which may include:
Automated individual decision making refers to a decision made solely on the basis of automated processing of your personal data, without human involvement. Profiling is defined as automated processing of personal data to evaluate certain things about an individual.
We conduct automated decision making to verify your identity before we allow you to play on our game sites. You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly affects you, as long as the decision is not necessary for entering into, or the performance of, a contract between you and us; or is not based on your explicit consent.
The Rank Group operates globally. The sharing of personal data about our customers between entities within the Rank Group is governed by a binding corporate agreement pursuant to which all members of the Rank Group, regardless of their geographic location, have agreed to adhere to the standards of GDPR. We need to transfer personal data within and between the Rank Group in order to provide and support the products and services that we provide to our customers.
It is the case that some countries outside of the European Economic Area (‘EEA’) may not protect personal data to standards equivalent to those applicable under GDPR. Where we need to transfer personal data outside of the EEA, we will take all appropriate steps to ensure that personal data is transferred only where subject to appropriate safeguards which are designed to ensure the protection of personal data and the enforceability of personal data rights. We will, for example, seek to rely on a recognised legal adequacy mechanism, on a binding and enforceable instrument or to transfer only on the basis of standard data protection clauses.
110 INFORMATION TECHNOLOGY AND DATA SECURITY
All personal data held by us is stored on secure servers. We use strict procedures and security features to maintain the security of our systems and the personal data and other information stored in them. We take cyber-security very seriously and implement multiple different layers of physical and technological controls to prevent unauthorised access and to ensure data security, integrity and privacy. Systems and controls include, but are not limited to:
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our applications you are responsible for keeping your password(s) confidential. We will never ask you to disclose your password to us and we would ask you not to share your password with anyone.
The websites contain places that are public such as chat rooms, message boards, news groups and/or other forums. Any information that you disclose in these areas becomes public information. You should therefore exercise caution when using these public areas and avoid posting any personal data on them. Any information that you communicate in these public places may be viewed and utilised by third parties, for example to send you messages, to send you advertising or for any other purposes. We are unable to control the activities and behaviours of third parties in public areas. Accordingly, if you disclose personal data in public spaces, you do so at your own risk. We recommend that you review the privacy policies of any relevant third parties before disclosing your personal data on their websites or platforms.
Protecting the safety of children when they use the internet is important to us. Our websites are intended for use only by persons who are at least 18 years of age. By using the products and services available on the websites you confirm to us that you meet this minimum age requirement. If you are not at least 18 years old, then you should not use any of the products or services that we offer nor provide us with any of your personal data. We may verify personal data provided by you. If we are unable to verify minimum age of 18 years, we will deal with any information, including personal data that has been provided to us in accordance with applicable legal and/or regulatory obligations. If you have reason to suspect that a minor has transacted with us, please contact us.
We retain personal data for as long as necessary for the purpose(s) for which the personal data was collected. For example:
We may retain aggregate information for longer periods in order to conduct market research and to help us to continue to develop and improve our services. You cannot be identified from aggregate information retained or used for these purposes.
Periodically we review the personal data that we hold on all of our customers in order to ensure that we are not retaining it for any longer than is necessary.
GDPR provides data subjects with a number of rights. We are significantly invested in protecting data subject rights and upholding the protections of GDPR. A data subject about whom we hold personal data may approach us at any time to request to review the personal data that we hold in relation to them, ask us to amend it, request that we erase it, ask us to cease using it, or request that it be transferred to another party. In summary, your rights in relation to your personal data may include the following rights:
Any data subject who wishes to exercise rights under GDPR in relation to Daub should send their request to our Data Protection Officer in writing.
We will deal with your request within one month of receiving it, save that in certain circumstances we have the right to seek an extension to this period, and free of charge (unless your requests are for some reason repetitive, unfounded or otherwise excessive).
Where a data subject has reason to make a complaint in relation to the Daub’s processing of their personal data or the protection of their data protection rights, they may make a complaint, in writing, to the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF Tel: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number.
GDPR provides for a data subject who has reason to complain about the handling of their complaint by a data protection authority to appeal to court where specified grounds exist.
There are circumstances where certain data rights may not be applicable. These circumstances may include cases where to apply a data subject right may conflict with other legal obligations. For example, your right to erasure of personal data may not be applicable where we are under an obligation to retain the personal data concerned in order to comply with applicable legislation or regulation, to comply with a legal or a licensing requirement or in connection with legal proceedings. Further, we may be able to demonstrate compelling legitimate grounds for the processing of your personal data which override your personal data rights.
If you would like to contact us with any queries or comments concerning data protection, our contact details are as follows:
Data Protection Officer
Daub Alderney Limited
St Peter Port
Telephone: 0845 565 2059