1 Get to know us!
2 Our Data Protection Officer
GOL is part of the Gamesys Group. The Gamesys Group has appointed a data protection officer (“DPO”). If you have any questions about this privacy policy and want to know more about how we handle your Personal Data when you use our Website, please contact the Gamesys Group DPO:
By mail to:
The Data Protection Officer
Bally’s/Gamesys Operations Limited
70 Berners Street, London
W1T 3NL (UK)
If you want to know how to contact us to exercise your legal rights in respect of the information we hold about you, please see section 7 “Your Rights ” below.
3 What Personal Data do we collect about you?
When you use our Website, we may collect Personal Data about you. We have set out below what data we collect and how we collect it.
You are under no obligation to provide Personal Data to us. However, certain Personal Data is essential for the provision of and the quality of the products and services we offer , we need certain Personal Data to fulfil our legal and regulatory obligations (including anti-money laundering requirements, responsible gaming requirements and the requirements of the Gambling Commission in the UK, the Gibraltar Gambling Commission, and other relevant gambling regulators to which we are subject as a gambling operator). We are subject to the terms of the Licence Conditions and Codes of Practice (“LCCP”) both in the UK and the Remote Technical and Operating Standards (“RTOS”) for the Gambling Commission in Gibraltar which require us to carry out age and identity verification before you can access our Website to play our games (including free-to-play games). If you refuse to provide your Personal Data where law or regulation requires us to collect it from you, we cannot allow you to access our Website.
3.1 Information you directly provide to us
When you use our Website, we collect the following kinds of information from you:
Email communications:
We collect and store all copies of emails you send to us and our replies to your emails.
Usage Data:
We collect information about how you use the Website, pages visited, and content viewed, links and buttons clicked.
We use these terms throughout this document where we describe how these types of data are used.
3.2 Information we collect from your device (“Device Data”)
We collect the following information from your device when you connect to our Website: information about your device’s hardware and software, use of the Website, traffic information, IP address, time of access, date of access, web page(s) visited, language(s) used, software crash reports, device information including the unique device identifier.
3.3 Information we collect through Cookies
We collect information using cookies to protect our Website, offer you a personalised experience with us, tailor our marketing services and improve our Website. For more information about the cookies we use and how to manage your cookie preferences please see our Cookie Policy.
3.4 Information we collect from third parties
In order to operate our Website, we collect information about you from third party service providers for various reasons such as making sure our Website is safe, to offer a good level of service and also to comply with our legal and regulatory obligations as per the requirements of the Gambling Commission in the UK, the Gibraltar Gambling Commission, and other relevant gambling regulators. We collect information about you from the following categories of third-party service providers:
Hosting providers
We collect information about you from our hosting service providers which host our Website.
Analytical providers
We collect information about you from our network of analytical providers who provide us tools to understand our audience and improve our Website.
4 How we use your Personal Data
We will only use your Personal Data as permitted by law. Most commonly, we will use your Personal Data in the following circumstances:
To perform the contract we are about to enter into or have entered into with you.
For our legitimate interests (or those of a third party), provided that your interests and fundamental rights do not override those legitimate interests.
Where we need to comply with a legal or regulatory obligation, or the processing is authorised by law.
Where you have consented to our use of your Personal Data.
In the public interest.
Click here to find out more about the types of lawful basis that we will rely on to process your Personal Data.
4.1 Purposes for which we use your Personal Data
We have set out below, a description of all the ways we may use your Personal Data, and which legal basis we rely on to do so. We have also identified what our legitimate interests are where appropriate.
We may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your information. Please contact our DPO (see section 2) if you need details about the specific legal ground we are relying on to process your Personal Information.
| Purpose | Type of Data | Lawful basis for processing |
|---|---|---|
| To manage our relationship with you as a user of the Website which includes notifying you about changes to our Website and the products and services we offer, terms and conditions or privacy policy. | Identity and contact details | Entering into and performing a contract with you. To comply with our legal obligations. As necessary for our legitimate interest (to keep our records updated and to study how customers use our products and services). |
| To provide various supporting customer services to you (such as where you contact us with a question in connection with our Website and/or request certain information from us). | Identity and contact details | As necessary for our legitimate interests (to deal with customer service requests and respond to communications). If you do not provide us with the Personal Data we request from you for customer services purposes, we may not be able to fully answer your queries. |
| To administer and protect our business and our Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). | Identity and contact details Usage Data Device Data | As necessary for our legitimate interests (to run our business, administration and IT services, network security, to prevent fraud or abuse and in the context of a business reorganisation or corporate restructuring exercise). As necessary to comply with a legal obligation. |
| To improve our Website, products/services performance, customer relationships and experiences. | Usage Data Device Data | As necessary for our legitimate interests (to define categories of customers for our games and services, to keep our Website updated and relevant, to develop our business and to inform our marketing strategy) and for the legitimate interest of third parties providing games and services to us. |
| To use data analytics to improve our Website and experiences. | Usage Data Device Data | As necessary for our legitimate interests (to keep our Website updated and relevant, to develop our business). |
5 How we share your Personal Data
We may share your information with the following categories of third parties, who may be Controllers or Processors in respect of your Personal Data, for the purposes explained in section 4
5.1 Sharing your personal data with Gamesys Group Limited
Your Personal Data will be disclosed to companies within the Gamesys Group in accordance with applicable Data Protection Laws and the terms of this privacy policy, for the purposes set out in section 4 above (e.g. to provide you with customer support services, to manage any risks to our Website and to our business, to comply with any applicable legal and regulatory obligations, etc.).
In addition, we use Personal Data in relation to the customers of the Website for the following purposes:
· Overseeing the performance of the Website and making strategic decisions regarding the commercial operation of the Website.
5.2 Sharing your personal data with our service providers
We use service providers in connection with the operation of our Website to ensure we deliver the best possible services. We enter into contracts with our service providers to ensure they take good care of your Personal Data when we share it with them for those purposes. We are committed to protecting your Personal Data and we oblige our service providers to handle your Personal Data in accordance with applicable Data Protection Laws and the terms of this Privacy Policy.
We engage service providers for the following services:
· Hosting our Website: we use hosting providers such as Gibtelecom (Republic of Ireland), Interxion (UK) and BMIT (Malta);
· IT services and security services: we use services such as Neustar, Akamai and Digicert
· Customer support software service providers: we use providers such as Zendesk;
· Data storage services: we use providers such as Google Cloud Platform and Amazon Web Services ;
· Data analytics services to measure and understand our audience, tailor our marketing services, improve your website experience and data cleansing services to suppress our marketing lists; and
· Audit, legal and compliance services.
5.3 Sharing your personal data with statutory authorities
We will share your Personal Data (including Special Categories of Personal Data) when it is required by applicable law in the following cases:
· To comply with a request for information from a governmental body such as law enforcement (police) or other public authorities (e.g., Insolvency Service);
· To comply with a court order to disclose your Personal Data; and/or
· To comply with a regulatory investigation from a relevant gambling authority (e.g. the Gambling Commission in the UK or the Gibraltar Gambling Commission) or a relevant data protection authority (e.g. the Information Commissioner’s Office in the UK) or any other applicable regulatory authority.
· The establishment, exercise or defence of a legal claim (including in connection with an investigation or enquiry by a competent regulatory authority).
5.4 Sharing your personal data in other circumstances
The Gamesys Group may transfer all your Personal Data to a third party if the operator of the Website changes, or if there is a sale of all or any part of its respective business or its assets. In the event of any of these transfers occurring, the party who acquires the data will assume the rights and obligations described in this Privacy Policy.
Keeping your personal data safe
What we do to keep your Personal Data safe:
We have appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Where appropriate, we employ encryption, pseudonymisation and anonymisation solutions to reduce the impact of any security incident to Personal Data. Although, the nature of the internet means that transmission of information may not be totally secured, we have deployed end to end encryption security measures to protect the transmission of your Personal Data when you use our Website.
In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions or otherwise in compliance with applicable laws, and they are subject to a duty of confidentiality.
Managing security incidents relating to Personal Data:
We have procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Where we transfer your Personal Data
We primarily store and process our Member Account data within the UK and European Economic Area (“EEA”).
· However, in the following cases we can transfer your Personal Data outside the UK and/or EEA or between the UK and EEA:
· If we have a legal or regulatory reason to do so;
· If we use third parties service providers located outside of the UK and/or EEA; or
· If you have consented to this transfer.
Third parties service providers
To operate our Website, we may use third party service providers which are based outside the UK and/or EEA, so their processing of your Personal Data will involve a transfer of data outside the UK and/or EEA.
Whenever we transfer your Personal Data to a service provider outside of the UK and/or EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
· We will only transfer your Personal Data to countries where this is permitted pursuant to an adequacy ruling by the relevant regulator(s).
· We may contract with the service provider on terms that are approved by the relevant regulator(s) to aim to give Personal Data the same protection it has in UK and/or Europe as relevant.
· If you want further information on the specific mechanism used by us when transferring your Personal Data outside of the UK and/or EEA, please contact our DPO (see section 2 of this Privacy Policy).
6 Data Retention
We will not keep your Personal Data for longer than required. To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and what the law requires us to do.
When we no longer need to keep your Personal Data, we anonymise it securely and this process cannot be reversed. In certain cases, we need to securely retain certain Personal Data to fulfil our legal and regulatory obligations (including anti-money laundering requirements, responsible gaming requirements and the requirements of the Gambling Commission in the UK and the Gibraltar Gambling Commission to which we are subject as a gambling operator.
Additionally, where we decide to retain your information for analytics purposes, we will fully anonymise it in accordance with applicable security standards, so it can never be linked back to an individual.
Please contact the DPO (see section 2 above) if you need any further information.
7 Your Rights
The law gives you legal rights in respect of the Personal Data we hold about you. You can exercise your legal rights for free except where this Privacy Policy states otherwise. We may need to request specific Personal Data from you from time to time to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that your Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month of receipt. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Below is a summary of the legal rights you have, what we do to protect them and how you can exercise them:
8 What happens when you visit other websites?
Our Website may contain links to websites where information practices may be different to ours. You should read the other websites' privacy notices, as we are not responsible for and have no control over information that is submitted to, or collected by, these websites when you visit them.
9 Contacting us about this privacy policy
10 Changes to this privacy policy
We may, from time to time, change or update this privacy policy. All changes to this privacy policy will be published on this page of the Website. Each change will become effective on publication. We recommend that you revisit and read this privacy policy regularly to ensure that you are up-to-date with the current terms.
11 Glossary
We may, from time to time, change or update this privacy policy. All changes to this privacy policy will be published on this page of the Website. Each change will become effective on publication. We recommend that you revisit and read this privacy policy regularly to ensure that you are up-to-date with the current terms.