v.22.08.2024
Customer Privacy Notice
- Who are we
- The information we collect about you
- How we use your personal data
- Who we may pass your data on to
- Location that we may transfer your personal data to
- Your rights
- How to contact us / Our Data Protection Officer
- Business Partners (Inc. Partners & Sole Traders)
- Changes to this Policy
Who are we:
The BETDAQ website and mobile application are operated by Exchange Platform Solutions Limited (“EPS”) and this Notice explains what your personal data will be used for.
Where we use the term “we” or “us”, this refers to EPS and any direct or indirect subsidies.
EPS is the data controller of your personal data and is subject to the EU General Data Protection Regulation 2016/679 (the GDPR) and the Data Protection (Bailiwick of Guernsey) Law 2017 (together with the GDPR, the Data Protection Legislation).
EPS are committed to protecting your personal data when you use our services through our website and mobile application and take the security of your information very seriously. We have strict security measures in place to protect your personal data which includes robust security procedures which are regularly tested and reviewed. If you have any concerns about the way in which we process or protect your personal data or would like to contact us about any aspect of this policy, please get in touch through the contact details at the bottom of this statement.
This privacy policy should be read in conjunction with our cookies notice, any notices or terms located within the stores and our site terms of use / terms and conditions.
The Information we collect about you
- We will collect personal data about you from the following sources:
- When you register for an account with us
- When you visit our website or our social media sites
- Through surveys you complete
- When you communicate with us (by email, mail, phone, in store or through chat or social media)
- When we undertake analysis of your interaction with us
- From our other group companies for internal reasons, primarily for business and operational purposes
- From public sources of information such as public records or social media postings
- From cookies and tracking devices on your devices where you have permitted their use
- From third parties’ databases to comply with our legal and regulatory obligations
- From online vendors and service providers such as financial and shared liquidity services, and from customer lists lawfully acquired from third-party vendors.
What We Use your Personal Data for
| What we use your Personal Data for | Typical Personal Data | Further information | Legal basis |
|
Provision of products or services |
• Your name, home or email address, telephone number or online identity or other contact information you provide to us. • Your Date of Birth, Gender • Log in information • Game Transactional information and payment methods |
To meet our obligations arising from any agreements entered into between you and us and provide you with the information, products and services that you request from us, including information about changes to our website, services or our terms, conditions and policies. | • Performance of contract • Legal obligations |
| Customer Service matters | • Name, online identity, Player ID • Contact Information • Account notes and communications, call recordings • Game Transactional information and payment methods IP Address, MAC address, Device type, apps, location |
To provide you with customer services, answer your questions or address your complaints or concerns. | • Performance of contract • Legitimate interests in player satisfaction, protecting our business and our customers in relation to responsible gambling |
| Meeting our legal and regulatory obligations | • Name, Online Identity, Player ID, Contact Information • Games played, bets, winnings and losses, credits and withdrawals, payment methods • Online images of play and screenshots • IP Address, MAC address, Device type, apps, location |
To discharge our legal and regulatory obligations and duties which include (but are not limited to) Gambling Act and Responsible Gambling obligations, Anti-money Laundering, Anti-fraud & Anti-terrorism laws. This may include electronic methods of identifying you, such as through the use of cookies and images on online play | • Legal obligation • Protect the vital interests of data subjects and others • Performance of a task carried out in the public interest • Legitimate interests in protecting our business, staff and customers |
|
Responsible Gambling and Self-Exclusion
|
• Name, Online Identity, Player ID, Contact Information, date of birth and gender • Affordability checks which may include obtaining data from other sources such as public domain information or credit history |
To meet our Responsible Gambling obligations (such as recording self-excluders and where we believe a customer has a gambling problem). This may include electronic methods of identifying you, such as through the use of cookies |
• Consent • Performance of contract • Legal obligation • Protect the vital interests of data subjects and others • Performance of a task carried out in the public interest |
| Undertake Surveys competitions and promotions | • Name or online identity • Contact details, Home address, Email or phone number • Contact preferences • Responses to surveys, click through on marketing, preferred products, feedback you provide |
To invite you to take part in competitions, to provide us with feedback on your experiences, take up promotions or to keep you informed about products of services which may be of interest to you. To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you. You may opt out of receiving direct marketing communications at any time. |
• Consent • Legitimate interests to understand our customer’s views and encourage greater interaction with our customers. |
| Lifestyle and demographic Insight and Profiling | • Contact preferences • Responses to surveys, click through on marketing, preferred products, feedback you provide • Interests and habits |
To build a profile of you, your preferences and your habits to better understand your interests and how you play. | • Legal obligation • Performance of a task carried out in the public interest • Legitimate interests |
| Improve our services and ensure our systems are secure and up to date | • Player ID • Log in details, websites and webpages visited • Games played, • IP Address, MAC address, Device type, apps, location • How you use mobile applications and websites |
To ensure that content from the site is presented in the most effective manner for you and for your computer, maintain and improve our products and services, optimise business processes, ensure the integrity of our systems and manage our Information Technology estate, undertake quality assurance, support efficient management of our staff, analyse performance of webpages or promotions and provide content that is relevant to you | • Legitimate interests to ensure that our interaction with customers is appropriate, working and efficient |
|
Prevention and Detection of Crime, Protection of staff and customers |
• Name, Online Identity, Player ID, Contact Information • Games played, bets, winnings and losses, credits and withdrawals, payment methods |
To prevent or detect fraud, theft or loss to our business and our customers and prevent the use of unfair practices in our websites or potential breach of our General Terms and Conditions and of applicable law. To protect our staff and other individuals from harm or loss This may include monitoring online activity, electronic methods of identifying you, such as through the use of cookies, your online transactions and payments |
• Performance of a task carried out in the public interest • Legitimate interests to protect our customers, business and workers. |
| Business sale, acquisition and rights | • Name, Online Identity, Player ID, Contact Information • Log in details, websites and webpages visited • Games played, bets, winnings and losses, credits and withdrawals, payment methods • Online images of play and screenshots • IP Address, MAC address, Device type, apps, location • Risk scores, profile classifications • Historic communications and account notes |
To exercise or defend legal claims or acquiring or selling a business | Legitimate interests to protect and defend our business |
Much of the information we collect about you is required to meet our legal and regulatory obligations, such as Gambling Act and Money Laundering, however, where we ask for your consent to process your personal data, you are not required to provide it, however, if you do not do so, you may not be able to take advantage of our services.
We may also store more sensitive personal data about you (often referred to as “special categories of personal data”) which may come directly from you, from other sources as described above or from decisions we have made about you.
Some of these decisions or actions we may take in managing your account or meeting our legal obligations may involve fully automated decisions. We will however always provide you with contact details where you can ask for a review of the decision or get further information from us.
Who we share your data with
We may need to share personal information with other organisations to ensure that we meet our legal obligations or where we need support in meeting your needs or our contractual obligations. We may also share information with other organisations where we consider it to be in the public interest or in the legitimate interest of ourselves or these other parties. These other parties are typically:
- business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
- our affiliates and selected third parties, where you have expressly opted-out of receiving marketing from us / third parties, have been barred or self-excluded, in which case we may share suppression lists with our affiliates and selected third parties, to ensure you do not receive unsolicited marketing;
- third party suppliers and service providers for any of the purposes identified in the table above; third party suppliers and service providers to the extent they assist EPS with its legal / regulatory obligations e.g. providers of services in respect of anti-money laundering, fraud, verification etc.;
- selected third parties so that they can contact you with details of the services that they provide, where you have expressly opted-in/consented to the disclosure of your personal data for these purposes;
- analytics and search engine providers that assist us in the improvement and optimization of our site and other selected third parties;
- other 3rd party organisations who ask, encourage or collate feedback and any online views of your experiences with us to help us improve and optimize our services.
- other gambling operators, banks, credit card companies, Sports Governing Bodies and appropriate agencies for the purpose of investigating and safeguarding against underage, fraudulent, criminal or suspicious activity (or other activities we are bound by law, regulation or guidance to investigate and safeguard against) or if we have reason to believe that you have undertaken such activity; and
- our regulators, law enforcement or fraud prevention agencies, as well as our legal advisers, courts, applicable independent adjudication services, sports' governing bodies and betting integrity organisations and any other authorised bodies, for the purposes of investigating any actual or suspected criminal activity, maintaining standards of behaviour in sport or other regulatory or legal matters
We will not share your personal information with other 3rd party organisations unless you have expressly opted-in/consented to the disclosure of your personal data for these purposes.
We may also disclose your personal information to third parties in the following circumstances:
- in the event that we consider selling or buying any business or assets, in which case we will disclose your personal data to any prospective sellers or buyers of such business or assets;
- in the event of any insolvency situation (e.g. the administration or liquidation) of EPS, or a data controller or any of its group entities;
- if we, or substantially all of our assets, are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;
- in order to enforce or apply our website terms of use;
- to protect the rights, property, or safety of us, our staff, our customers, or others. This includes exchanging information with other companies and organisations (including without limitation, other gambling operators and the local police or other local law enforcement agencies) for the purposes of staff and customer safety, crime prevention, fraud protection and credit risk reduction;
- if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or regulatory requirements, or otherwise for the prevention or detection of fraud or crime;
- If you are based within the UK, when we check your identity when you first become a customer, or check your financial status as required by our License Conditions, we share information with a Credit Reference Agency and this will leave a “soft” footprint on your credit file. Further information about how this agency holds and uses your information can be found here: https://www.controlrisks.com/-/media/corporate/files/legal/trust-centre/data-protection-narrative.pdf ; and
- Where you have self-excluded yourself from gambling, we may share this information with our regulators or other companies in our field where we believe it is important to support your exclusion.
Meeting our Responsible Gambling Obligations
- We take responsible gambling very seriously at EPS. Where required, we may share your information with other organisations to meet our responsible gambling commitments.
- We have an obligation to identify those at harm from gambling as early as we can and help them stop gambling by limiting accounts, suspending accounts or, if applicable, stopping them entering our shops. In order to meet these obligations, we continuously analyse customer’s transactions and evaluate behaviour or financial status on a Group level.
- We are also constantly looking at innovative ways to help spot players who may be on a path to difficulties or identify them digitally and within shops. This means that we may use systems that identify customers (such as cookies on player’s devices). We may also share or receive player data with other organisations who help evaluate risks or assess affordability by looking at how you may interact with other gambling operators or help individuals directly.
In all these cases, please be assured that we take our obligations - both in helping customers gamble responsibly and of protecting personal information- very seriously and we will always ensure that we take the most appropriate measures and controls to protect your data.
|
Type of Data |
Typical Retention Time |
Information |
|
Customer Call recordings |
12 Months | An extended retention may be applied on a case by case basis |
|
Customer Data |
A 7-year retention period which starts to run from the date your account is closed |
We will only continue to hold personal data relating to your account as permitted under data protection legislation (i) where we are under a legal requirement under gambling or tax legislation to retain your data; and (ii) to exercise or defend our legal rights If you register under the self-exclusion scheme, whilst the self-exclusion itself may have a shorter duration, a record of this will be retained as part of your customer profile in line with this retention policy. |
The above retention times may be extended for example where it is needed to meet a specific regulatory obligation, investigate a crime, handle a claim or resolve a complaint.
Locations that we may transfer your personal data
From time to time, service providers and organisations with whom we work with, may be located outside the UK or European Economic Area in countries that do not have the same standards of protection for personal data as the UK or EEA Countries. We will, however, always use every reasonable effort to ensure sufficient protections are in place to safeguard your personal data. We will also ensure that our service providers enter into compliant processing agreements with us to ensure that your personal data is processed in accordance with applicable data protection legislation. Further information about the mechanisms we will apply can be found here but please contact us at the “dataprotection” email address below if you have any specific questions regarding international transfers: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_en.
Security
We implement technical and organisational measures which take into account the harm that may be suffered, to protect your personal data. All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Cookies
We use cookies for various purposes including making your experience of our website better. For more information on our use of cookies, please see our Cookies Policy.
Marketing Communications and your choices
When we first collect your personal data we’ll ask you to tell us how you would like to hear from us in future about our other products and services. It’ will normally be via a tick boxes on forms or web page and you can opt-out at any time.
What is 'Opting Out'?
The term opt out refers to several methods by which individuals can avoid receiving unsolicited product or service information. This ability is usually associated with direct marketing campaigns such as telemarketing, e-mail marketing, or direct mail.
*Please consider that 'opting out' will not prevent any essential customer correspondence e.g. bet or account correspondence.
How can I opt out of marketing correspondence?
If you do not wish to receive any offers, promotions, information on events and tailored communications based on your account activity, you can request to be made un-contactable by:
- Using the “unsubscribe” option provided in any marketing communication you receive
- changing your preferences on your account settings
- contacting our Customer Support.
What details do you require from me?
We would need as much of the following as possible, to ensure that you are not sent any further unwanted correspondence:
- Your full name
- How we contacted you, i.e. email, SMS, or post
- The mobile number or email/postal address we contacted you on
- The mobile number or email address that the message came from
- The date(s) and time(s) you were contacted
- A copy of the message you were sent (e.g. a screenshot or a forwarded email sent to our customer care team)
Your rights
| Description of Right | |
|
Right 1 The right of access |
You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. |
|
Right 2 The right to be informed |
A right to access personal data held by us about you. |
|
Right 3 The right to rectification |
A right to require us to rectify any inaccurate personal data held by us about you. |
|
Right 4 The right to erasure |
A right to require us to erase personal data held by us about you. This right will only apply where (for example): we no longer need to use the personal data to achieve the purpose we collected it for; or where you withdraw your consent if we are using your personal data based on your consent; or where you object to the way we process your data (in line with Right 6 below). This right is not absolute and will not apply when legitimate and overriding reasons apply. |
|
Right 5 The right to object to processing |
In certain circumstances, a right to restrict our processing of personal data held by us about you. This right will only apply where (for example): you dispute the accuracy of the personal data held by us; or where you would have the right to require us to erase the personal data but would prefer that our processing is restricted instead; or where we no longer need to use the personal data to achieve the purpose we collected it for, but you require the data for the purposes of dealing with legal claims. |
|
Right 6 The right to data portability |
In certain circumstances, a right to receive personal data, which you have provided to us, in a structured, commonly used and machine readable format. You also have the right to require us to transfer this personal data to another organisation, at your request. |
|
Right 7 The right to object processing |
A right to object to our processing of personal data held by us about you where the processing of such data is necessary for the purposes of our legitimate interests, unless we are able to demonstrate, on balance, legitimate grounds for continuing to process personal data which override your rights or which are for the establishment, exercise or defence of legal claims. |
|
Right 8 The right not to be subject to automated decisions including profiling |
A right for you not to be subject to a decision based solely on an automated process, including profiling, which produces legal effects concerning you or similarly significantly affect you. |
|
Right 9 The right to withdraw consent |
A right to withdraw your consent, where we are relying on it to use your personal data (for example, to provide you with marketing information about our services or products). |
|
Right 10 The right to lodge a complaint |
You have the right to complain to your relevant Data Protection Supervisory Authority. |
Contact Us
If you have any questions about this notice or would like further information about your rights, please contact by one of the following means:
By email: dataprotection@betdaq.com
Or
Contact: Guernsey Data Protection Commissioner
By email: info@odpa.gg
By writing:
Guernsey Data Protection Commissioner
Data Protection Office,
Block A
Lefebvre Court
Lefebvre Street
St Peter Port
GY1 2JP
Changes to this Privacy Policy
Any changes to this privacy policy in the future will be posted on this page, and where appropriate, notified to you by email. Please check back frequently to see any updates or changes to this privacy policy.
This policy was last reviewed and updated: 22nd August 2024.
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