This Privacy Policy is effective from 18 October 2017.
1.1 This Privacy Policy sets out the ways and the manner in which, we, the Operator, may collect and use personal information that we may obtain about You.
1.2 In the UK, we are a registered Data Controller under the UK Data Protection Act 1998. Details of our registration can be found in the UK Regulatory Authority public register of data controllers at X for "HighStakes".
1.3 We ask that You read this Privacy Policy carefully as it contains important information about what to expect as to how we collect and use personal information about You.
1.4 Unless the context otherwise requires, capitalised terms not defined in this Privacy Policy shall be as defined in the General Terms, which, for the avoidance of doubt, also apply and You will need to read and understand the General Terms in addition to this Privacy Policy.
'2.1. Your personal data (meaning any information about You from which You can be personally identified, such as Your name, address, telephone number or email address, and which is referred to in this Privacy Policy as "Your Information", will be processed by us (including any of our agents and/or employees), and (where appropriate) any other company in our company Group and/or our partners and subcontractors, in accordance with this Privacy Policy.
2.2. By registering as a user of our Services (or by partially completing the registration form), using the Services, otherwise using the Website, or submitting a query to us via the Website or by telephone, You acknowledge that You have read and agree to the terms of this Privacy Policy and that You consent to the use of Your Information by us and (where appropriate) any other company in our company Group and/or our partners and subcontractors, in accordance with this Privacy Policy.
2.3. If You do not wish to provide Your Information on the basis set out in this Privacy Policy, You should not enter the relevant information in the spaces provided on any relevant part of our Website, or provide any of Your Information to us by telephone or otherwise. However, if You do not provide such information, You may not be permitted or able to make full use of the relevant part of the Services.
2.4. If at any time You wish us to stop processing Your Information for any of the purposes set out in this Privacy Policy, then You must contact us and we will take the appropriate steps to stop doing so. Please note that this may mean that Your Account will have to be closed.
2.5. Please note that while the Services may contain links to websites and applications operated by parties other than us (for example the Alderney Gambling Control Commission website), we (and/or any other company in our company Group) are not responsible for the privacy practices or content of any such websites or applications.
2.6. As part of the account registration process, we also offer visitors registering with us the opportunity to "opt out" from keeping them informed of future events, offers and promotions from us (and any other company in our company Group). Visitors who wish to take the option should 'untick' the relevant box in the registration process. You may update Your marketing preferences at any time through 'My Account/Update Marketing Preferences' (where available) or by contacting Customer Services. If (where available) You have chosen to receive information on future events, offers and promotions by SMS message to Your cellular telephone, You may "opt out" of receiving such information at any time by replying with the word "STOP". To opt out of third party analytics please email us at [email protected] and include Your device identifier, and once processed, our third party analytics provider will discontinue any analytics on that particular device.
2.7. When You choose to download Software pursuant to our Services, notification software may also be downloaded onto Your Access Device. This allows us to send notifications to You about our Services directly to Your Access Device, for example to inform You about new features, updates, service communications, offers and promotions. By downloading such Software, You consent to receiving notifications. If You would prefer not to receive these notifications, You will need to manually uninstall the notification software from Your Access Device (for example by clicking the "what's this" link on a notification You receive and following the 'how to remove' instructions", or by following the applicable "Settings" and "Notification Centre" uninstall instructions on Your Access Device). "opt out"
3.1. We collect Your Information in order to:
3.1.1. enable us to set up Your Account so that You can make full use of all of the features of the Services, including crediting Your Account with funds, placing bets and playing games;
3.1.2. enable us to receive questions and comments from You through our Online Help Centre, and for us to be able to respond to them;
3.1.3. comply with relevant regulations regarding Your registration, for example completing age verification checks; and
3.1.4. (provided that You do not "opt out" from this option), to keep You informed of future events, offers and promotions from us (and any other company in our company Group).
3.2. In addition to the broad purposes identified in paragraph 3.1 above, we (and any other company in our company Group) will use Your Information, including sharing Your Information with our third party partners and subcontractors who process data (including, where appropriate, Your Information) on our behalf, for:
3.2.1. setting up, operating and managing Your Account;
3.2.2. providing any of the Services which are requested of us, and for any proper purpose connected with such provision;
3.2.3. verifying the accuracy of Your Information, including disclosure of such information to third parties (including financial institutions, age verification, and credit reporting agencies) in connection with such purposes (a record of the search will be retained and the third party may use the information to assist other companies for verification purposes);
3.2.4. preparing statistics, providing analytical reports and analysis relating to the use of the Services by You and other customers;
3.2.5. analysing and recording Your use of the Services and the Websites in order to improve our products and the way we deliver the Services.
3.2.6. preparing and displaying appropriate individualised marketing material and content;
3.2.7. periodically sending written communications to You to announce important service changes, technical issue updates and changes to the General Terms (which includes this Privacy Policy);
3.2.8. complying with our regulatory duties, obligations and responsibilities: including under the UK Data Protection Act 1998, UK Gambling Act 2005 and UK Gambling (Licensing and Advertising) Act 2014, The Gambling (Alderney) Law, 1999, The Alderney eGambling Ordinance, 2009, The Alderney eGambling Regulations, 2009 ; and under any other valid and applicable legislation and to any other competent authority (meaning any authority having any governmental, judicial or regulatory jurisdiction over us or any other company in our company Group);
3.2.9. conforming to legal requirements or complying with legal processes or acting to protect the interests of sporting bodies or other qualified bodies;
3.2.10. the investigation of suspected unlawful, fraudulent or other improper activity connected with the Services;
3.2.11. the reporting of a crime or suspected crime, including money laundering or any fraud; and
3.2.12. any other purpose which is necessary for the performance of our contractual obligations to You.
3.3. We may store and process Your information on our own information technology systems or on systems owned by third parties that may store and process Your information on our behalf.
3.4. We (and any other company in our company Group) will not send You unsolicited information regarding any third party commercial offers or advertisements.
3.5. We (and any other company in our company Group) may use Your username and/or first name and region for advertising or promotional purposes.
3.6. Communications to and from our Customer Services Department are recorded for training and security purposes.
3.7. For the purposes of prevention or detection of crime as well as responsible gambling, we may supplement the information that You provide to us with information that we receive from third parties or collate by accessing third party sources, including (without limitation) information published on the internet about or by You, for example on social media and social networking sites.
4.1. In connection with the provision of Services, we may need to transfer data (including Your Information) to:
4.1.1. other companies in our company Group; and
4.1.2. our partners and subcontractors,
who maybe based outside the European Economic Area ("EEA").
4.2. If Your Information is transferred by us outside the EEA in accordance with paragraph 4.1 above, we will take all reasonable steps possible to ensure that Your data is treated as securely as it is within the EEA and in accordance with this Privacy Policy.
5.1. You may update or delete Your Information at any time from within Your Account through 'My Account/Update Account Details' (where available) or by contacting Customer Services. However, we may be required to continue to retain records containing Your information for legitimate business, regulatory, compliance and/ or legal purposes.
5.2. You may obtain a copy of Your information held by us by contacting Customer Services. We do require up to twenty eight days' notice to enable us to comply with such a request. Any such request is subject to a fee of £10 to meet our administrative costs in providing You with details of the information we hold about You.
5.3. We may reject requests for disclosure or deletion of Your Information that are unreasonable or extremely impractical (e.g. because they require disproportionate human or technical effort or require significant changes to our processes and technology and impact our ability to provide the Services).
We strive to protect Your Information and our Services from unauthorised access to or alteration of Your Information. This includes use of various security measures to protect Your Information held by or on behalf of us and ongoing review of our information collection, storage and processing practices.
Subject to the uses described in this Privacy Policy, we will endeavour to treat all of Your information in strict confidence and endeavour to take all reasonable steps to keep Your personal information secure once it has been transferred to our systems. However, the internet is not a secure medium and we cannot guarantee the security of any data You disclose online. You accept the inherent security risks of providing information and dealing online over the internet and will not hold us responsible for any breach of security unless this is due to our negligence or wilful default.
Your browser also generates other information, including which language the Website is displayed in, and Your Internet Protocol address ("IP address"). An IP address is a set of numbers which is assigned to Your computer during a browsing session whenever You log on to the internet via Your internet service provider or Your network (if You access the internet from, for example, a computer at work). Your IP address is automatically logged by our servers and used to collect traffic data about visitors to our Website. We also use Your IP address to help diagnose problems with our server, and to administer our Website. We do not use Your IP address to identify You personally.
If at any time You believe that we have not adhered to the provisions set out within this Privacy Policy, please notify us by contacting Customer Services and we will use all commercially reasonable efforts to promptly determine and (where relevant) correct any issue.