Privacy policy

  1. Introduction

    This Privacy Policy is entered into between You and the Probability Group ('We', 'Us', 'Our' as appropriate). Please read the following carefully to understand Our views and practices regarding Your personal data and how We will collect, use and process it. By visiting Our Website and accessing Our Services, You are accepting and consenting to the practices described in this Privacy Policy.

    For the purpose of the Data Protection Act 1998 (the Act), the joint data controllers are the following: 1.Probability (Gibraltar) Limited of Suite 975, Europort, Europort Avenue, Gibraltar; and 2. Lady Lucks GTECH UK Interactive Limited is 4th Floor, 70 Chancery Lane, London WC2A 1AF

    Unless otherwise stated, terms used in this Privacy Policy shall have the same meaning as set out in the General Terms and Conditions.

  2. Privacy

    We are committed to protecting and respecting Your privacy. This Privacy Policy (together with Our General Terms and Conditions and other terms and conditions and policies We may publish from time to time) sets out the basis on which any personal data We collect from You, or that You provide to Us, will be used and processed by Us.

    We may periodically make changes to this Privacy Policy and will notify You of these changes by posting the modified terms on Our Website. We recommend that You revisit this Privacy Policy regularly.

  3. Information collection

    We may collect and process the following data about You:

    1. Information You provide to Us

      You may provide Us with information about You by filling in forms on Our Website or by corresponding with Us by telephone, e-mail or otherwise. This includes information You provide when You register to use Our Website, subscribe to Our Services, participate in chat or other social media functions on Our Website, participate in promotional activities and when You report a problem with Our Website. The information You give Us may include, but is not limited to, Your name, address, e-mail address and phone number, financial and credit card information, personal description and photograph.

    2. Information We collect about You.

      With regard to each of Your visits to Our Website We may automatically collect

      technical information, including the Internet protocol (IP) address used to connect Your computer to the Internet, Your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

      information about Your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from Our Website (including date and time); products Your viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page, transaction history, website usage preference and any phone number used to call Us.

    3. Information We receive from other sources

      We may receive information about You if You use any of the other websites We operate or the other services We provide. We also work 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 may receive information about You from them, including customer lists lawfully acquired from any third party vendors.

      Our Website also uses cookies to distinguish You from other users of Our Website. This helps Us to provide You with a good experience when You browse Our Website and also allows Us to improve Our Website. For detailed information on the cookies We use and the purposes for which We use them please refer to Clause 8 below.

      In addition, We may also collect data 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 Website and to understand how You interact with Our emails and/ or advertisements. Through pixel tags, We obtain non-personal information or aggregate information (for example, the domain name, the areas Our Website You visit, Your operating system, Your browser version, and the URL You came from) which can be used to enhance Your online experience and understand traffic patterns.

  4. INFORMATION USE

    We use information held about You in the following ways:

    1. Information You provide to Us.

      We will use this information:

      1. to carry out Our obligations arising from any contracts entered into between You and Us and to provide You with the information, products and services that You request from Us;
      2. to provide You with information about other goods and services We offer that are similar to those that You have already purchased or enquired about (including, but not limited to, other gaming products and services);
      3. to provide You, or permit selected third parties to provide You, with information about goods or services We feel may interest You (including, but not limited to, other gaming services).
      4. If You are an existing customer, We will only contact You by electronic means (e-mail or SMS) with information about goods and services similar to those which Were the subject of a previous sale or negotiations of a sale to You. If You are a new customer, and where We permit selected third parties to use Your data, We (or they) will contact You by electronic means only if You have consented to this. If You do not want Us to use Your data in this way, or to pass Your details on to third parties for marketing purposes, please use the relevant box situated on the form on which We collect Your data to make Your preference known to Us.
      5. to notify You about changes to Our Services; and
      6. to ensure that content from Our Website is presented in the most effective manner for You and for Your computer.
    2. Information We collect about You.

      We will use this information:

      1. to administer Our Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
      2. to improve Our Website to ensure that content is presented in the most effective manner for You and for Your computer;
      3. to allow You to participate in interactive features of Our Services, when You choose to do so;
      4. as part of Our efforts to keep Our Website safe and secure;
      5. to measure or understand the effectiveness of advertising We serve to You and others, and to deliver relevant advertising to You;
      6. to make suggestions and recommendations to You and other users of Our Website about goods or services that may interest You or them.
    3. Information We receive from other sources.

      We may combine this information with information You give to Us and information We collect about You. We may use this information and the combined information for the purposes set out above (depending on the types of information We receive).

  5. DISCLOSURE OF YOUR INFORMATION

    We may share Your personal information with any member of Our Group, which means Our subsidiaries, Our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

    In order to play real money games on Our Services, You will be required to send money to and receive money from Us. We may use third-party electronic payment processors and/or financial institutions ('ESPs') to process such financial transactions. By accepting this Privacy Policy, You expressly consent to any personal information necessary for the processing of transactions being shared with ESPs, including, where necessary, the transfer of information outside of Your country. We ensure that Our arrangements with ESPs protect Your privacy. In particular, when providing Your data to ESPs, We use separate, secured and encrypted protocol to communicate with ESPs using single port communication to process Your financial personal data and Your non-financial personal data.

    We may also share Your information with selected third parties including but not limited to: business partners, suppliers and sub-contractors for the performance of any contract We enter into with them or You; advertisers and advertising networks that require the data to select and serve relevant adverts to You and others; analytics and search engine providers that assist Us in the improvement and optimisation of Our Website; and with credit reference agencies for the purpose of assessing Your credit score where this is a condition of Us entering into a contract with You.

    We may also disclose Your personal information to third parties:

    1. In the event that We sell or buy any business or assets, in which case We may disclose Your personal data to the prospective seller or buyer of such business or assets.
    2. If any member of our Group or all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
    3. If We are under a duty to disclose or share Your personal data in order to comply with any legal obligation, or in order to enforce or apply Our General Terms and Conditions and other agreements or to protect Our rights, property, or safety, Our customers, or others.
    4. If we have reasonable grounds to believe that You have cheated or otherwise attempted to defraud Us, Our Group, or any other user of the Services in any way including but not limited to game manipulation or payment fraud, or if We suspect You of fraudulent payment, including use of stolen credit cards, or any other fraudulent activity (including any chargeback or other reversal of a payment) or prohibited transaction (including money laundering), in which case We reserve the right to share this information (together with Your identity) with other online gaming sites, banks, credit card companies, for the purpose of research on the prevention of addiction, data can be made anonymous and passed on to the respective institutions and appropriate agencies.
  6. STORAGE OF YOUR INFORMATION

    The data that We collect from You may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for Us or for one of Our suppliers. Such staff maybe engaged in, among other things, the fulfilment of provision of Our Services to You, the processing of Your payment details and the provision of support services. By submitting Your personal data, You agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy.

    All information You provide to Us is stored on Our secure servers. Any payment transactions will be encrypted Using SSL technology. Where We have given You (or where You have chosen) a password which enables You to access certain parts of Our Website, You are responsible for keeping this password confidential. In accordance with the General Terms and Conditions, please do not to share Your password with any third party.

  7. INFORMATION UPDATES AND ACCESS

    1. Consent and updates to information

      You have the right to ask Us not to process Your personal data for marketing purposes. We will usually inform You (before collecting Your data) if We intend to use Your data for such purposes or if We intend to disclose Your information to any third party for such purposes. You can exercise Your right to prevent such processing by expressing Your preferences using tick boxes on the forms We use to collect Your data. You can also exercise the right at any time by contacting Us at Gtech UK Interactive Limited, 70 Chancery Lane, London WC2A 1AF or by emailing us at support@ladylucks.co.uk. In addition, You may contact Us at this address if You: 1) want to confirm the accuracy of the personal data We have collected about You; 2) would like to update Your personal data; and/or 3) have any complaint regarding Our use of Your personal data. If requested, We will (a) update any information You have provided to Us, provided that You provide evidence as We may reasonably require for such changes, or (b) mark any information to prohibit future use for marketing purposes. For the avoidance of doubt, nothing in this Privacy Policy shall prevent Us from retaining Your personal data where We are required to do so by law.

    2. Subject access requests

      The Act gives You the right to access information held about You. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee to meet Our costs in providing You with details of the information We hold about You.

  8. COOKIES

    1. Information placed on Your device(s)

      We may store some information on Your computer, laptop, tablet or mobile device when You look at Our Website, mobile sites or mobile apps. We use cookies, which are small text files that are stored on Your computer or equipment when Your visit certain online pages that record Your preferences. We also use Local Shared Objects or 'flash cookies'. 'Flash cookies' are similar to browser cookies. They allow Us to remember things about Your visits across Our Website but cannot access or use other information on Your computer. We do not use flash cookies to remember or use directly identifying personal information about You such as Your name or email address. We only use flash cookies across Our own websites and no others. We use cookies and flash cookies to track use of Our Website. We also may use cookies and third party cookies to monitor traffic to the site, improve the Services and make it easier and/or more relevant for Your use. We use flash cookies and third party cookies to help Us to show Your advertisements which are relevant to Your interests based on Your use of Our Website.

    2. Our cookies.

      You can find more information about the individual cookies We may use and the purposes for which We use them in the table below.

      STRICTLY NECESSARY COOKIES

      Strictly necessary cookies are essential to allow You and other users to move around Our Website and use its features, such as accessing secure areas of the Website, or shopping basket. Without these cookies, We would not be able to make Our Website work efficiently

      1st Party

      COOKIE NAMEPURPOSE
      GatekeeperThis cookie is used to track user sessions with various gaming modules. It is deployed when users log into Our Services. This cookie is necessary as it is required to authenticate users.

      3rd Party Cookies:

      With a 3rd Party cookie the tracking cookie is set and recorded by a 3rd Party

      COOKIE NAMEPURPOSE
      Income Access/AffiliateThis cookie is used to track the source of visitors to Our Website. This cookie is required to track the user source and incentivize our marketing partners.

      PERFORMANCE COOKIES

      Performance cookies allow Us to collect information about Website usage. These cookies collect anonymous information that does not identify a visitor. The information collected is used to improve how Our Website works and how We can improve it. For example,

      Web Analytics;
      Ad response rates;
      Error Management
      Testing Designs

      COOKIE NAMEPURPOSE
      Google Analytics or tag managerThis cookie is required to monitor visitor activity on Our Website, providing data such as: visitor source channel, content view, page views, time spent on pages, entry and exit of the site content, etc. This is used to optimise and improve Our Website performance.

      FUNCTIONALITY COOKIES

      Functionality cookies allow a Website to remember the choices that You and other users make (for example, username, language or location) and it allows the Website to provide a more enhanced service. The information these cookies collect may be anonymised and cannot track individual browsing activity. For example,

      Remembering user settings;

      Detecting that a service has already been offered; and

      Fulfilling a user request

      1st Party

      COOKIE NAMEPURPOSE
      Web Portal cookiesPortal cookies are deployed to monitor user visits to Our Website and to offer relevant content.
    3. When We use cookies.

      For visitors to Our Website, We use cookies to collect information. Our servers use two different types of cookies:

      A 'session-based' cookie: This type of cookie is only allocated to Your computer for the duration of Your visit to Our Website. A session-based cookie helps You move around Our Website faster and, if You are a registered customer, it allows Us to give You information that is more relevant to You. This cookie automatically expires when You close Your browser.

      A 'persistent' cookie: This type of cookie will remain on Your computer for a period of time set for each cookie. Flash cookies are also persistent.

      Analytical' cookies 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 You can what You are looking for easily.

    4. Cookies allow Us to:

      1. better understand Your preferences and offer You more relevant promotional offers;
      2. distinguish You from other users of Our Website, which helps Us to provide You with a good experience when You browse Our Website and also allows Us to improve Our Website;
      3. identify Your preferences when tailoring content or functionality for You;
      4. confirm You are a registered user and save Your log-in details when accessing certain Services on Our Website;
      5. show Your advertisements which are relevant to Your interests based on Your use of Our Website;
      6. collect statistics on the use of Our Services.

      We may also use cookies and Web beacons to ensure that Our mailing tools are working properly.

    5. How can I refuse or opt out of cookies?

      You have the ability to accept or decline cookies. The majority of web browsers automatically accept cookies, but, if You prefer, You can Usually modify Your browser setting to decline cookies. The 'Help' menu on the menu bar of most browsers will tell You how to prevent Your browser from accepting new cookies, how to have the browser notify You when You receive a new cookie and how to disable cookies altogether.

      In the event that we use flash cookies, You will be able to modify Your Flash Player settings to prevent the use of flash cookies. The Settings Manager of Your Flash Player allows Your manage Your preferences. To disallow flash cookies from all third party content go to the 'Global Storage Settings' panel of the Settings Manager and de-select the check box labelled 'Allow third party flash content to store information on Your computer' and close the Settings Manager. Alternatively You can also adjust Your settings for specific Website You visit through the 'Website Storage Settings' panel which is also found in the Settings Manager.

      If You are using an old version of Flash Player or an older Web browser, the Settings Manager may not be available to You. We recommend that You ensure that Your refresh Your Flash Player and browser to the latest available versions.

      If You choose to decline cookies, You may not be able to experience all of the interactive features on Our Website.

      For more information on deleting or controlling cookies, You can visit http://www.aboutcookies.org/Pleas.e note that by deleting Our cookies or disabling future cookies, You may not be able to access certain areas or features of Our Website.

  9. CONSENT TO SECURITY REVIEW

    We reserve the right to conduct a security review at any time to validate Your identity, age, the registration data provided by You and to verify Your use Our Service and Your financial transactions for potential breach of Our General Terms and Conditions and of applicable law. By accepting Our General Terms and Conditions, You authorise Us, Our staff, agents and suppliers to use Your personal information and to disclose Your personal information to third parties for the purposes of validating the information You provide to Us in the course of using the Services, including, where necessary, the transfer of information outside of Your country. Security reviews may include but are not limited to ordering a credit report and/or otherwise verifying the information You provide against third-party databases. In addition, to facilitate these security reviews, You agree to provide such information or documentation as We may request.

  10. LIABILITY

    The Services operate 'AS-IS' and 'AS-AVAILABLE,' without liability of any kind. We are not responsible for events beyond Our direct control. Because of the complex and constantly changing nature of Our technology and business, We cannot guarantee nor do We represent that there will be error-free performance regarding the privacy of Your Personal Information, and We will not be liable for any indirect, incidental, consequential or punitive damages relating to the use or release of Personal Information. Please refer to Our General Terms and Conditions for information on our liability to You.

  11. ACCEPTANCE OF PRIVACY POLICY

    By clicking 'Submit' or 'I agree' during the registration process or by Your continued use of Our Services following the posting of this Privacy Policy (as applicable), You agree to this Privacy Policy. This is Our entire and exclusive Privacy Policy and it supersedes any earlier version. This Privacy Policy should be read in conjunction with Our General Terms and Conditions and any applicable terms posted on Our Website or otherwise made available to You on Our Services.