1. WHO WE ARE
1.2. Eight Central Limited N.V. operates and control the Le Club website (hereinafter referred to as ‘the Website’) referred to hereinafter as the ‘Services’.
1.4. We may process and hold information relating to you according to Data Protection Laws. Data Protection Laws include the Privacy and Electronic Communications (EC Directive) Regulations 2003, including but not limited to personal data as defined in the national laws implementing the EU Data Protection Directive 95/46/EC until 25 May 2018 and the General Data Protection Regulation (EU) 2016/679 (“GDPR” and collectively the foregoing “EU Data Protection Laws”) on and from 25 May 2018; Data Protection Act 1988 and the Data Protection (Amendment) Act 2003, in an electronic database or manual format for account administration and marketing purposes and also in order to satisfy legal, regulatory and statutory requirements.
1.5. When we refer to ‘Processor’ this means a natural or legal person, public authority, agency or any other body which processes personal data on behalf of us.
2.2. Please read this policy carefully so as to ensure that you understand our values, views and practices regarding the capture, retention, processing, use and transfer where applicable of your information.
4. WHAT INFORMATION DO WE NEED AND WHAT WE MAY DO WITH IT
4.1. We may automatically collect, record, store and process information that is not personally identifiable about you when you access the website including but not limited to the type of internet browser and computer operating system you are using, the domain name of the website from which you came, the number of visits, the average time spent and the pages viewed on our website. We may use this information within our Company to measure the use of our website and improve its contents.
4.2. In addition to the information set out above, in the event that you apply to open an account with us we may collect, record, store and process additional information about you including but not limited to the following:
a) Your contact information, which includes but is not limited to your name (first and last name), your date of birth, your gender, your physical address, your email address, your IP address and your telephone numbers.
b) Your financial information, which includes but is not limited to your billing information, payment card details and details of transactions you carry out through our website.
c) Other information about you that is available from publicly available sources (for example, the Electoral Register and the appropriate register of court judgements) which may be relevant to your use of the services. We may combine it with the information you have provided to us to assist us in assessing your application for credit with us and verifying your identity to detect and prevent crime and money laundering. For more information please refer to our Terms and Conditions.
d) Other mandatory details that may be requested from you for the purpose of applying to open an account with us.
4.3. We may also collect, record, store and process data about you including but not limited to:
a) Details of your visits to our services together with the resources and web pages that you access, including but not limited to traffic data, location data, IP address(es) and other communications data.
b) Technical information about the device(s) that you use to access our services.
c) All communications correspondence you have with us whether in writing, by telephone, email or in any other form.
d) Your betting, payments and other account transactions which will be routinely analysed so as to assist us in improving the service that we provide to you.
e) Information about how you use our services and/or selected third party websites from cookies stored on your device. (For further information on cookies, see clause 9 below.)
4.4. All telephone conversations including calls in relation to betting with us and client service calls may be recorded both to assist us in training and quality management and to facilitate the speedy resolution of any disputes.
4.5. We will only use the information that we collect to process your transactions and requests or for any other purpose detailed in this policy. This processing may include sharing your information with our third party data processors and with the professional advisers who assist us with the performance of the services we offer. Your information may be processed for one or more of the following legitimate interests reasons:
a) To set up, operate and manage your account.
b) To provide you with betting services.
c) To process your transactions via your banking service provider.
d) To respond to any enquiry from you regarding a transaction you have made with us.
e) To enforce or apply our Client Agreement and other agreements with you (including our Terms and Conditions of Use for the Eight Central Limited N.V. Website).
f) To enhance our client services and provide a more personalised service.
g) To keep you informed of future events, offers and promotions from us via SMS, email, telephone and/or post.
h) To carry out customer research, analysis and testing.
i) To carry out risk management.
j) To assist in diagnosing system problems and administering the website.
k) Any other purpose which is necessary for the performance of our contractual obligations to you.
4.6. Your information may be also be processed to comply with our legal obligations for one or more of the following reasons:
a) To verify your age, identity and the accuracy of your application details, including obtaining information from third parties such as financial institutions and credit reference agencies.
b) To comply with our legal and regulatory duties, obligations and responsibilities.
c) To investigate suspected unlawful, fraudulent or other improper activity connected with use of the website and to report a crime or suspected crime, including money laundering or fraud
d) To meet our obligations towards individuals who self-exclude from our services or who apply responsible gambling restrictions to their accounts.
5. WHO WE SHARE YOUR DATA WITH
5.1. We may share your information with third parties to verify the accuracy of the information you provide to us and to comply with our legal and regulatory duties, obligations and responsibilities. This may include sharing your information with third party companies and organisations for the purposes of fraud protection, credit risk reduction and verifying the information you provide to us (including your age). Examples of this include but are not limited to:
a) Sharing your information when making enquiries with a credit reference agency.
b) Sharing the information you have given us with a third party organisation to verify the accuracy of it.
c) Passing your information to a debt collection agency if we need to collect outstanding debts from you because you do not make payments due to us in good time.
d) Passing your information to legal advisers should we need assistance in enforcing our legal rights against you.
e) Disclosing any of your information that we are legally required or permitted to do, without prior notice to you, in relation to suspected unlawful, fraudulent or other improper activity connected with use of the website and/or to report a crime or suspected crime, including money laundering or fraud.
5.2. If Eight Central Limited N.V. or substantially all of its assets should be acquired by a third party, all personal data held by us may be one of the assets transferred.
6. MAKING ENQUIRIES WITH CREDIT REFERENCE AGENCIES
6.1. The information held by credit reference agencies and fraud prevention agencies may be searched by us and other organisations on our behalf and used to make assessments and decisions regarding credit and credit-related services, verify your identity, manage your accounts including updating and maintain the accuracy of your records, trace your whereabouts, recover debts that you owe us and prevent crime, fraud and money laundering. Your credit rating may be affected by these searches and any records shared with credit reference agencies will remain on their files for 6 years after they are closed.
7.1. We may use your information to send you targeted marketing material from time to time relating to our services such as future events, other promotional activities and information about special offers that we feel may be of interest to you. Your information will not be disclosed to any external third parties for marketing purposes.
7.2. We may communicate with you by the following methods – email, SMS (commonly known as text), post and telephone. You have the right to stop receiving our marketing communications at any time. If you no longer want to receive these communications or would like to change your marketing preferences you can inform us by clicking on the relevant link in our marketing emails to you, and these communications will be stopped or modified as soon as reasonably practicable. If you would like to opt out of all of our marketing communications, you may also tell us by written email to email@example.com.
8. INTERNATIONAL DATA TRANSFERS AND SECURITY
8.2. We recognize the importance of online security for all our clients and we take precautions to ensure the security of your personal information and strive to keep it accurate. To ensure the security of personal data we maintain appropriate administrative, technical and physical safeguards to protect against accidental or unlawful destruction, loss, corruption, unauthorised disclosure, access and all other unlawful forms of processing of the personal data in our possession. Any payment transactions will be encrypted using SSL technology.
8.3. 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 any data you transmit to our site and you do so at your own risk. Once we have received your information we will use strict procedures and security features to try to prevent unauthorised access.
9. DEVICE MONITORING AND COOKIES
9.1. We may collect information about the device(s) you use to access our services for anti-fraud monitoring purposes. This information includes but is not limited to the Internet Protocol (IP) address, memory and operating system of the device is not personally identifiable information.
9.4. The following are examples of some of the types of cookies we may use from time to time:
a) Visitor identification cookies. These are anonymous identifiers used to recognise a visitor across visits which may be used to identify repeat visits and analyse cross-visit behaviour.
b) Tracking cookies. These are account-related identification cookies used to recognise you as a client and maintain your session on the website. They may be used to link site usage information with transactional information when analysing and optimising your user experience.
c) Customisation cookies. These uniquely identify you, recognise you as a returning visitor and are used to customise your experiences on the website.
d) Testing cookies. These are anonymous cookies used to randomly generate variants of content and maintain the visitor’s view of that content. They may be used to record a variant’s performance in achieving goals such as helping visitors to register.
e) Analytical cookies. These are used to collect information about how visitors use our website. This information is then used to compile reports and to assist us in improving the website.
10. LINKS TO THIRD PARTY WEBSITES
11. AUTOMATED DECISION MAKING
11.1. In accordance with our responsible gambling and social responsibility obligations and for the benefit of our player, we will monitor gambling / deposit patterns that may indicate concern in respect of responsible gambling. We may use automated decision-making processes to help us to identify such patterns (for example, our systems will automatically prevent you from depositing beyond limits set by you and identification, verification and credit checks carried out by our processors are done so on an automated basis). These decisions enable us to help you gamble responsibly (necessary to comply with a legal obligation).
11.2. Rights relating to automated decision making and profiling: You have the right not to be subject to a decision which is based solely on automated processing (without human involvement) where that decision produces a legal effect or otherwise significantly affects you. This right means you can request that we involve one of our employees or representatives in the decision-making process. We are satisfied that we do not make automated decisions of this nature.
12. YOUR RIGHTS
12.1. You have the following rights in relation to your personal data:
a) a right to access your personal data held by us and receive certain personal data in machine-readable format such as Microsoft Excel or Adobe Acrobat or equivalent.
b) a right to object to processing where lawful basis is that it is in our legitimate interests although we may still process your personal data where there are other relevant lawful bases or where we have compelling grounds to continue processing your personal data in our interests which are not overridden by your rights, interests or freedoms;
c) a right to have inaccurate personal data rectified;
d) a right to request an explanation of the logic involved where we make decisions about you solely through automated means;
e) a right to complain to your national data protection regulator;
f) If you are unsure about your rights or are concerned about how your personal data may be processed you should contact your national data protection regulator.
g) a right to object to direct marketing, which can be done by opting-out of direct marketing either unsubscribing via email or by emailing us with a request to firstname.lastname@example.org. You also have a right to object to any profiling to the extent that it relates to direct marketing only.
h) If you would like to exercise any of your rights then you can do so by emailing us at email@example.com. Please be aware that whilst we will try to accommodate any request you make in respect of your rights they are not absolute rights. This means that we may have to refuse your request or may only be able to comply with it in part.
i) Where you make a request in respect of your rights we will require proof of identification. We may also ask that you clarify your request. If we receive repeated requests or have reason to believe requests are being made unreasonably we reserve the right not to respond.
13. HOW LONG WE HOLD YOUR INFORMATION
13.1. We will only keep your information for as long as is necessary to supply you with products and services or as required by law. We may be required in certain circumstances to retain your information indefinitely, for example under our procedures to maintain responsible gambling and self-exclusion.
13.2. When personal information is no longer required it will be destroyed either by shredding it or by another approved destruction method to prevent unauthorised parties from gaining access to the information.
14. CONCERNS OR COMPLAINTS
14.1 For any questions, concerns or complaints, you may contact our designated Data Protection Officer directly at firstname.lastname@example.org.