This website and mobile application (the “Website”) is provided to you by ElectraWorks Limited of Suite 6, Atlantic Suites, Europort Avenue, Gibraltar, GX11 1AA ("we", “us” or “our”).
We are committed to protecting and respecting the privacy of users of the Website (“you” or “your”). This privacy notice sets out how we may use the personal data that we collect from you, or that you provide to us in the course of you using our Website to participate in our gaming and gambling services. This policy should be read in conjunction with our Cookie Notice, any terms or notices located on the Website and our Terms and Conditions.
WHAT DATA DO WE COLLECT ABOUT YOU?
When you are using our Website we may collect and process certain data about you, such as:
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Basic contact information
If you decide to register for an account on our website, then we will collect your name and various contact details such as your home address, country of residence, email address, telephone number, gender and date of birth during the sign-up process and retain this information as part of your records. You also may provide us with additional contact information (e.g. your mobile number) if you contact our customer support team.
Your account details and account profile
When you set up an account you will provide us with your chosen username and password. You may provide us further information or edit your existing information during the course of using your account.
Proof of age and identity
We may request proof of (a) your age and your identity by requesting documents such as a copy of your passport or driving licence, citizen card, electoral card or birth certificate and (b) address, by requesting documents such as a utility bill or bank statement.
Your payment details
If you wish to deposit money in order to participate in real-money games on the Website then you will need to provide us with preferred payment details (for example credit/ debit card details, Sofort, Neteller, Skrill). We will use the same details to pay out your winnings.
Technical information about your device and Website usage
When you use our Website we will collect certain technical information including:
Records of how you use our services
This may include a log of your betting, gaming and wagering history, deposits you have made, payment methods you have used, your session durations and other transactions made on your player report. We will also hold records of any responses you provide to marketing campaigns offered by us or through third party suppliers.
This may include records of any suspected or known gambling addictions or associated health issues that you may have. In addition, we will also hold records of any time-outs, exclusions or deposit limits you impose upon yourself, whether current or historic.
Information related to criminal or civil offences
This may include information regarding criminal or civil offences you may have committed, where we are notified by the police or other authority in connection with any potential criminal activity.
We may in certain circumstances collect information from online sources, such as your publicly available social media profiles. This may include your name and the profile information.
Information collected from third parties
We are legally obliged to carry out anti-money laundering (AML) checks. As part of the AML, we engage GB Group and Aristotle to provide us with the necessary information about you in order to complete these checks.
Records of communications you have with us
If you contact us with a question or to provide feedback, for instance, we will collect records of your communications with us through email, support tickets that you raise, telephone, and live chat conversations.
Other information that you provide to us voluntarily
This may include data that you provide to us if you enter a competition or prize draw on our Website or the details of any feedback that you provide to one of our online surveys or focus groups.
FOR WHAT PURPOSES DO WE USE DATA ABOUT YOU, AND ON WHAT LEGAL BASIS?
We use your data for various purposes connected with the Website, including:
In order to use your data we must have a legal basis for doing so. The legal bases that we rely upon are explained further in the “find out more” section below. Except when using any of your sensitive data or information relating to your criminal or civil offences we will only use your data where it is necessary for:
Where none of the above applies, we will request your consent (which we will ask for before we process the data). For sensitive data or information relating to criminal offences, the legal basis that we will rely upon is set out in the “find out more” section.
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The table below sets out further information about the purposes for which we use data about you, with the corresponding methods of collection and legal basis that we rely upon for its use.
|Purpose||Method of collection and legal basis for processing|
|To setup and manage an account with us||Method of collection|
This information will be provided by you directly when you first setup an account with us and then during the course of using our services.
Necessary for the performance of the contract between you and us in relation to the gambling services
|To facilitate your use of our gambling services||Method of collection|
This information will be provided by you directly when you first setup an account with us and then collected by us during the course of using our services. We may also collect certain information indirectly from your device or web browser.
Necessary for the performance of the contract between you and us in relation to the gambling services and in all other cases it is necessary to fulfil our legitimate business interests.
|To administer deposits that you make and to pay your winnings||Method of collection|
The information will be provided by you when you first choose to make a deposit on the Website.
Necessary for the performance of the contract between you and us in relation to the casino services.
|Identity and age verification checks||Method of collection|
This information will be provided by you directly when you first setup an account with us and supplemented by information we receive from certain third parties.
Necessary for compliance with a legal obligation to which we are subject.
|To monitor your use of the Website for legal/regulatory purposes||Method of collection|
Necessary for the performance of the contract between you and us in relation to the gambling services and legal obligations (e.g. AML)
|To communicate with you||Method of collection|
This information is collected when we communicate with you or you communicate with us.
It is our legitimate business interest to respond to communications that you send to us and inform you of relevant information in relation to the services that we provide.
|Internal management, administrative and organisational reasons||Method of collection|
This information is collected from you both directly and indirectly
It is our legitimate business interest to improve our services and defend ourselves against legal claims
|To share information with service providers||Method of collection|
This may include any of the information we hold about you, whether collected by direct or indirect means.
It is our legitimate business interest to share your data with trusted third parties who provide us with services relevant to our provision of the Website and our gambling services, including customer support, information technology, payments, marketing, data analysis, research and surveys.
|To send you offers, promotions or other marketing||Method of collection|
Your contact details will be collected when you first setup an account with us and may be updated (along with your preferences) from time to time.
It is our legitimate business interest to send you marketing and promotional materials from time to time
Where we have obtained your consent to send marketing then we instead rely on consent as the legal basis
If we send you a marketing email or SMS, it will include details on how to unsubscribe from receiving similar marketing messages in the future. You can also manage your information and update your marketing preferences through the ‘My Account’ section or by contacting customer service. Please allow up to 48 hours for any opt out request to be processed. We may continue to send you relevant service messages about your account and our services if you have unsubscribed from emails or SMS.
|To perform data analytics and benchmarking||Method of collection|
This information is collected across your interactions with the Website.
It is our legitimate business interest to improve our Website and services for our customers improved experience.
WHO DO WE SHARE YOUR DATA WITH, AND FOR WHAT PURPOSES?
We may share data about you with:
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Certain members of our Group
We are a subsidiary of the wider GVC Group (or “Group”) which includes GVC Holdings Plc and all of its direct and indirect subsidiary companies. We may need to share your data with certain members of our Group. For instance, we share your data with certain group companies who are involved in providing assistance we our customer relationship management, fraud detection, compliance, customer support, marketing, data analytics, compliance and risk services.
We use a software hosting provider to host and manage the services on our behalf. The provider is called Playtech (“Software Provider”).
We use e-verification companies to confirm your eligibility to use the gambling services on our Website when you first register. Our current e-verification providers are called GB Group, Aristotle.
We use certain third parties such as payment processors and financial institutions to administer and process payments to and from you. Our payment processor is called Safecharge.
Database management companies
We use certain third parties to manage and administer our customer database, such as:
To send you marketing communications in accordance with your stated preferences, we may share your email address with email service providers, SMS providers and mailing houses. These are as follows: Media Hut – to send out postal and other offline correspondence on our behalf.
Silverpop – to send out email correspondence on our behalf
Optimove – to administer and manage our marketing campaigns
Dynamic Messaging – to make automated phone calls
Mobivate – to send out SMS correspondence on our behalf
We may use Google Analytics, Mouseflow and other data analytics companies to track your Website usage and behaviours, in order to perform an analysis based upon your location, age, betting activity, and preferences in order to provide an enhanced player experience, and for risk and regulatory purposes.
Many of the games that we host on our Website are developed and managed by third party gaming providers. We will share certain limited data about you with gaming providers to help to provide you with a smooth gaming experience.
Risk and fraud monitoring providers
We conduct regular anti-fraud audits and may be required to provide results of these checks to a credit reference or fraud prevention agency or law enforcement.
Regulators and other government agencies
To comply with our legal and regulatory requirements, we may share your data with various government agencies including, but not limited to, verification agencies, public authorities, regulators (including the Gibraltar and UK Gambling Commissions) and law enforcement agencies.
Other users of the Website and associated Websites
When you join a casino game, your nickname (and nothing else) will be shared with other players who have also joined. These players may be members of the same Website or one of our associated Websites or members of websites hosted by the Software Provider.
If you would like to receive a full list of our suppliers and other third parties who we share your data with then you can get in touch with us using the details provided in the “Customer Support” section.
WHO MIGHT WE RECEIVE YOUR DATA FROM?
Sometimes we may receive information about you from third parties. These third parties may include:
WHERE MIGHT DATA ABOUT YOU BE SENT?
We store your data on servers located in Gibraltar.
As with any multinational organisation, we are often required to transfer data internationally. Accordingly, data about you may be transferred globally (if your data is collected within the European Union, this means that your data may be transferred outside of it). This includes transfers that have been identified in the previous section: Who do we share your data with and for what purposes.
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When using data as described in this notice, data about you may be transferred either within or outside the country or territory where it was collected, including to a country, territory or international organisation that may not have EU equivalent data protection standards.
For example, we may transfer your personal data to our vendors outside of the European Union where the vendor is based outside the European Union. In all cases, the transfer will be on the basis of a European Commission adequacy decision or we will implement adequate measures, for example the EU Model Contracts, and including appropriate security measures, for the protection of personal data in those countries, territories or international organisations in accordance with applicable data protection laws. If you would like more information about any of the data transfer measures on which we rely please contact us at firstname.lastname@example.org.
HOW DO WE PROTECT DATA ABOUT YOU?
We implement appropriate technical and organisational measures to protect personal data that we hold from unauthorised disclosure, use, alteration or destruction. Where appropriate, we use encryption, dual authentication VPN and other technologies that can assist in securing the data you provide. We also require our service providers to comply with strict data privacy requirements.
HOW LONG WILL DATA ABOUT YOU BE KEPT?
The period for which we may retain data about you will depend on the purposes for which the data was collected, whether you have requested the deletion of the data, and whether any legal obligations require the retention of the data (for example, for regulatory compliance). We will not retain data about you for longer than is necessary to fulfil the purposes for which the data was collected.
WHAT RIGHTS AND OPTIONS DO YOU HAVE?
You may have some or all of the following rights in respect of data about you that we hold:
You are able to exercise these rights by contacting us using the details set out at Who should you contact with questions? below.
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You have the rights set out in the table below:
|Right in respect of the data about you that we hold||Further detail (note: certain legal limits to all these rights apply)|
|to request us to give you access to it||This is confirmation of:|
|to request us to rectify or update it||This applies if the data we hold is inaccurate or incomplete.|
|to request us to erase it||This applies if:|
|to request us to restrict our processing of it||This right applies, temporarily while we look into your case, if you:|
|to object to our processing it||You have two rights here:|
|to withdraw your consent to our using it||This right applies to any data which we have collected and process based on your consent. You have the right at any time to withdraw the consent you have provided to us.|
|to data portability||This right applies:|
|to lodge a complaint with the supervisory authority in your country||Each European Union country must provide for one or more public authorities for this purpose.|
You can find their contact details here:
WHO SHOULD YOU CONTACT WITH QUESTIONS?
The data controller is ElectraWorks Limited and our principal address at Suite 6, Atlantic Suites, Europort Avenue, Gibraltar, GX11 1AA. We are registered with the Gibraltar Regulatory Authority (GRA) and our registration number is DP 012717 and you can access our data protection register entry http://www.gra.gi/data-protection/rights-register-search/company/428.
If you have any questions, or wish to exercise any of your rights, please contact us at email@example.com.
If your country has a supervisory authority responsible for data protection, you have a right to contact it with any questions or concerns. If we cannot resolve your questions or concerns, you also have the right to seek judicial remedy before a national court.
CHANGES TO THIS NOTICE
We may update this notice (and any supplemental privacy notice), from time to time. We will notify of the changes where required by law to do so.
Last modified 21st May 2018