Alea Gaming Ltd (We, Us, Our) are committed to protecting and respecting your privacy.
This policy sets out the basis on which any information We collect from you, or that you provide to Us, will be processed by Us. Please read the following carefully to understand Our views and practices regarding your information and how We will treat it.
SCOPE OF POLICY
This policy forms part of Our General Terms and Conditions and applies to your use of:
- The Ladylucks.co.uk website (Website) accessed via web browsers on desktop, tablet, or mobile device and any of the services accessible through the Website.
For the purpose of the Data Protection Act 1998, the data controller is Alea Gaming Ltd incorporated and registered in Malta, with company registration number C-63119. Our registered office is at Sky Offices, 2C, Marina Street, Pieta, PTA2904, Malta. We are regulated and licensed to provide online betting and gaming under a Remote Gaming Licence issued in the UK to Our parent company, Alea Gaming Group, by the UK Gambling Commission. You may visit the UK Gambling Commission’s website at www.gamblingcommission.gov.uk to view that licence.
INFORMATION WE MAY COLLECT FROM YOU
We may collect and process the following data about you:
- Information you give Us (Submitted Information): You may give Us information about you by filling in forms on the Website, or by corresponding with Us (for example, by e-mail, or chat). This includes information you provide or that is generated through the use of the Services when you register to use Our Sites; subscribe to any of Our Services; deposit funds; wager money; enter a competition; promotion or survey; interact with Our customer facing staff; and when you report a problem with Our Services or any of Our Sites. The information you give Us may include your name, address, age, username, personal description and photograph, e-mail address and phone number, your Device's phone number, and other registration information, financial and credit card information.
- Information We collect about you and your Device. Each time you visit or use one of Our Sites or Services, We may automatically collect the following information:
- technical information, including the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device or user ID), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting (third party advertising providers may also collect some information about your device through their placement of their content (for example IP address, device type, login IDs and associated information) (Device Information);
- details of your use of, or your visits to, any of Our Sites; including, but not limited to, traffic data, location data, weblogs and other communication data and payment information supplied in order to make use of Our Services, whether this is required for Our own billing purposes or otherwise.
- In addition, We may also collect information about You by using “pixel tags”, “web beacons”, “clear GIFs” or similar means (collectively, “Pixel Tags”) that allow Us to know when you visit Our Sites or use the Services and to understand how you interact with Our e-mails and/or advertisements. Through Pixel Tags, We obtain non-personal information or aggregate information (for example, the domain name, the areas of Our Sites or Services you visit, your operating system, your browser version and the URL you came from) which can be used to enhance your experience of Our Sites or Services and to understand website traffic patterns.
- Location Information. We may also collect additional information to determine your current location. Some of Our Services may be restricted to certain jurisdictions and We require your information to prevent access from any restricted jurisdiction. If you wish to use the particular feature or service, you may be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by changing the settings on your Device, however you may not be able to continue to access Our Services if you do so.
- Information We receive from other sources (Third Party Information). We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies and third party marketing services providers) and may receive information about you from them.
If you contact Us, We may keep a record of that correspondence.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your device if you agree. Cookies contain information that is transferred to your device's hard drive.
We use the following cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
- Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.
Except for essential cookies, all cookies will expire after 24 months.
For more information on deleting or controlling cookies, you may visit http://www.aboutcookies.org/.
USES MADE OF THE INFORMATION
We may use information held about you in order to facilitate the provision of Our Services or the use of our Sites, including specifically in the following ways:
We may use the Submitted Information for the purposes of:
- setting up, re-activating, operating and managing your account;
- carrying out player identity and account verification checks (a process also known as “Know Your Customer”) which may include disclosing your information to third parties (for example financial institutions, credit reporting agencies and age verification agencies);
- performing anti-fraud and anti-money laundering verification and complying with Our legal and regulatory obligations in this respect;
- selection and provision of marketing services and materials advertising Our Sites and/or Services by Us or selected third parties;
- data analysis and player profiling in order to build up individual and aggregate profiles of Our customers. We may share anonymised or pseudonymised data for data analysis and profiling purposes with third parties;
- preventing fraud and money laundering; ensuring compliance with Our General Terms and Conditions; reducing Our financial risk, which may require Us to disclose your information and gaming history to third parties such as the relevant regulator, gaming bodies, financial institutions, agencies responsible for verifying age, the police and credit reporting agencies;
- conducting data cleansing, enhancement and verification activities (for example, verifying your information against third party databases relating to 'movers', 'goneaways' and recent deaths);
- processing card and online payments in connection with Our Services.
We may use any Location Information primarily for the purpose of ensuring that Our Services are not accessed from any restricted territories.
We may also use any Location Information, Device Information or Log Information for customer profiling and data analysis as well as player and device verification purposes. Certain Device Information and generalised Location Information may be used by Us or shared with 3rd party partners (without disclosing your exact details or location) to facilitate player profiling and marketing of Our Sites and Services.
We may receive Third Party Information falling into any of the above categories and We will use such information in accordance with this policy.
We may also use any of the above information:
- to comply with Our legal and regulatory duties and responsibilities to the relevant licensing and regulatory authorities as well as all duties and responsibilities owed under any other applicable legislation and to any other applicable regulators in other jurisdictions;
- to enforce or apply Our General Terms and Conditions and other agreements, and to protect Our rights, property or safety or those of other members of Our corporate group, Our customers or third parties;
- to undertake research, conduct surveys, research analyses and obtain feedback from customers; and
- for any other lawful purpose which is necessary for the performance of Our contractual obligations to you.
We may associate any category of information with any other category of information and will treat the combined information as information in accordance with this policy for as long as it is combined.
Except as provided below in this policy, We do not disclose information about identifiable individuals to Our advertisers, but We may provide them with anonymous aggregate information about Our users (for example, We may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the information We have collected from you to enable Us to comply with Our advertisers' wishes by displaying their advertisement to that target audience.
We may use the information held about you to provide you with bespoke material and content (directly or indirectly via third parties or appointed agencies) and to facilitate the improvement and optimisation of advertising and marketing activities related to the Services, Our Sites or the services of any other company in Our corporate group.
Your information may also be used for data-matching purposes in respect of your use of Our Services and your use of certain third party services (such as social media networks or search engine operators). This may include certain information submitted on registering or any subsequent updates of your profile information.
DISCLOSURE OF YOUR INFORMATION
We may disclose your information to any member of Our group, which means Our subsidiaries, Our ultimate holding company and its subsidiaries.
We may disclose your information to third parties:
- In the event that We sell or buy any business or assets, in which case We may disclose your information to the prospective seller or buyer of such business or assets.
- If Alea Gaming Ltd or substantially all of its assets are acquired by a third party, in which case information held by it about its customers will be one of the transferred assets.
- If We are under a duty to disclose or share your information in order to comply with any legal or regulatory obligation or request.
- In order to:
- enforce or apply Our General Terms and Conditions and other agreements or to investigate potential breaches;
- protect the rights, property or safety of Alea Gaming Ltd, Our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction; or
- receive and facilitate the provision of services to Us by reputable third parties (such as agencies, suppliers, partners or sub-contractors) in connection with the operation of Our Sites or Services (for example email and communication services providers or payment services providers), or for the performance, improvement and optimisation of advertising and marketing activities related to Our Sites or Services, and for the execution of any contract or arrangement We enter into with any such parties in relation to the activities related to the provision of the Services.
WHERE WE STORE YOUR INFORMATION
We work to protect the security of all the information you provide to Us, implementing a set of security measures at an organizational, technical and physical level. During transmission, all personal data you input and your information about gaming/payment transactions are protected by using cryptographic protocols as Transport Layer Security (TLS), continuously aligned to the latest standards.
Where you have chosen a password that enables you to access certain parts of Our sites, you are responsible for keeping this password confidential. We ask you not to share passwords with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although We will do Our best to protect your information, We cannot guarantee the security of your data transmitted to Our Sites; any transmission is at your own risk. Once We have received your information, We will use reasonable procedures and security features to prevent unauthorised access. We may collect and store information on your Device using application data caches and browser web storage (including HTML 5).
Certain Services include social networking, chat room or forum features. Ensure when using these features that you do not submit any information that you do not want to be seen, collected or used by other users.
You have the right to ask Us not to process your information in order to send you marketing communications. You can exercise your right to prevent such processing by checking certain boxes on the forms We use to collect your data. You can also exercise this right at any time by changing your marketing preferences in the “Communication settings” tab of your Account Services or by contacting Us at [email protected].
Our Sites may, from time to time, contain links to and from the websites of Our partner networks, advertisers and affiliates (including, but not limited to, websites on which Our Sites or Our Services are advertised). If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies, and that We do not accept any responsibility or liability for these policies or for any information that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any information to these websites or use these services.
We may retain your information and any data collected about you for as long as you use or have access to Our Services and We may continue to process such information and data for lawful purposes (including, but not limited to, to comply with Our legal and regulatory obligations) for a reasonable time following the closure or termination of your account for any reason.
You acknowledge that the information provided by you may amount to personal or sensitive data under the Data Protection Act 1998 and you give your consent to your data being processed as set out in this policy.
ACCESS TO INFORMATION
The Data Protection Act 1998 gives you the right to access information held about you. Your right of access can be exercised in accordance with that Act. Any access request may be subject to a fee of £10 to meet Our costs in providing you with details of the information We hold about you.
You can also access information held about you and you may correct, update or delete it by contacting Us in writing. We will endeavour to respond to you as soon as reasonably possible in accordance with the applicable legislation.