PRIVACY POLICY FOR ACTIVE WIN MEDIA LIMITED
PRIVACY POLICY for www.buckybingo.co.uk and related mobile applications ("Website")
This Privacy Policy is effective from 7th January 2020. We may change this Privacy Policy at any time, and if we do so will post the changes to this page as well as the date that the changes take effect.
Our Privacy Policy below sets out in detail how we process your personal data, and we encourage and recommend that you read it in full. We understand that people have busy lives though, and so wanted to help you by providing a brief overview of how and why we process your personal data.
In general, we will only collect the personal data that we need from you to offer you our services. For example, if you want to gamble with us then we'll collect your name, username, contact details, date of birth and address in order to set you up with an account. We’ll process data on any games that you play so that we can identify if you have won and, of course, pay any winnings to you.
The other main reason we will process your personal data is to comply with our legal and regulatory obligations. As you may know, in order to provide you with gambling services we are required to have a licence. As such, we will need to comply with our licence, and this may involve us collecting additional information about you – for example, if you try to set up an account we need to verify your identity and age to make sure that you are who you say you are and that, of course, you are old enough to gamble. Our licence also requires that we make sure you gamble responsibly. This means that we will monitor your gambling activities to check that you are gambling within your means. If we have any concerns about your gambling then we are required to contact you to make sure everything is okay. We take social responsibility very seriously.
Ultimately, we aim to only process your personal data where it is necessary. We will always keep your personal data secure. Your enjoyment of our services and your safety are our primary concerns.
1.1 This Privacy Policy sets out the way in which Virtue Fusion (Alderney) Limited ("we" or "us"), a company incorporated and registered in Alderney collects and processes Personal Information (as defined in paragraph 2.1 below). If you have any questions about this Privacy Policy or the processing of your Personal Information please contact us at [email protected]
1.2. We operate the Website under a brand licence from ActiveWin Media Limited. We will share your Personal Information with Brand Owner in accordance with this Privacy Policy and our agreement with Brand Owner.
1.3. By using our Services, you acknowledge that [both] we ActiveWin Media Limited (and any companies in our [respective] Group[s], as well as any partners and subcontractors) will process your Personal Information in accordance with this Privacy Policy, including for the purposes set out in paragraph 5 below. If you do not wish to provide your Personal Information on the basis set out in this Privacy Policy, you should not enter the relevant information on the Website, or otherwise provide us with your Personal Information. However, if you do not provide your Personal Information, you may not be able to use all of the Services.
1.4. Capitalised terms not defined in this Privacy Policy are as defined in the Terms & Conditions. This Privacy Policy is incorporated into, and forms part of, the Terms & Conditions.
2.1. As part of operating the Website, we collect your Personal Information. "Personal Information" means any information from which you can be personally identified, including your name, email address, home address, telephone number, debit/credit card data, and date of birth.
2.2. We collect Personal Information which you provide to us, including when you register for an Account and information you provide in communications with us. We also collect information about the transactions you undertake, including details of payment cards used. We may also collect Personal Information through surveys which we, or companies engaged by us for such purpose, undertake. In addition, we collect information about your use of the Website and our Services. We will also collect other information necessary for us to process your Personal Information for the purposes set out in this Privacy Policy.
2.3. As a provider of gambling services, we aim to ensure that you always gamble responsibly. As such, we may collect information about your physical or mental health. To help ensure that our customers gamble responsibly, it’s important we understand why they self-exclude (or when they should be contacted about the possibility of self-excluding). We therefore only use this type of data to ensure that you are gambling responsibly, to contact you if we are concerned that you are not gambling responsibly, to enforce any self-exclusion request, and to help us to better identify any responsible gambling concerns in the future for our customers.
3.1 We collect information through "Cookies" and other similar technologies (e.g. pixel tags or links). This helps us to remember you when you visit the Website, and to improve your experience.
3.2 We also use information collected through "Cookies" and other similar technologies to detect any fraudulent behavior, improper transactions and/or abuse of our Website and Services, and to help verify your identity by registering and remembering your device information.
3.3 To find out more about "Cookies" and similar technologies please see paragraph 13 of this Privacy Policy. More information about the purposes of the "Cookies" we use can be found in paragraph 5.
We use information from third party service providers, such as fraud prevention companies. This information may be used in various ways, such as to help us: (i) decide whether to accept transactions from personal computers, mobile phones or other devices by checking whether these devices have been identified with fraudulent or abusive transactions in the past;
(ii) detect the inappropriate use of promotions we may run;
(iii) detect whether you have (or may have) cheated or colluded with others; and
(iv) investigate, mitigate and/or prevent identity theft, account takeovers or malware attacks. Third party service providers also help us verify your identity by registering and remembering your device information (such as the model, operating system, browser version and IP address), which is used to confirm device identification.
How we use your Personal Information
5.1. In accordance with data protection laws, we will only process your Personal Information where we have a lawful basis for doing so. In respect of your Personal Information, these bases are: (i) where it is necessary to provide services to you under the performance of the contract we have with you; (ii) where we are required to do so in accordance with legal or regulatory obligations; (iii) where you have given your consent; and, (iv) where it is in our legitimate interests to process your Personal Information, provided that none of these prejudice your own rights, freedoms and interests.
5.2. The following are a list of the "Purposes" for which we (including any of our agents, Group members, sub-contractors and/or employees) process your Personal Information, and the lawful basis on which we carry out such processing:
|
Purpose |
Lawful Basis |
|
To set-up, administer and manage your Account and records (including processing deposits and withdrawals) |
Necessary for the performance of a contract |
|
To provide and personalise our Services (including to allow you to wager and play our games, and (if applicable) to provide chat moderation) |
Necessary for the performance of a contract |
|
To receive and respond to your communications and requests |
Necessary for the performance of a contract where such communication relates specifically to our Services, otherwise consent |
|
To notify you about updates to our Website and Services |
Necessary for the performance of a contract |
|
To ensure that we are able to fulfil our regulatory obligations regarding your Account, including by verifying the accuracy of any information you provide us |
Necessary to comply with a legal or regulatory obligation |
|
To comply with our obligations under Applicable Laws (including the Gambling Act 2005) and to regulators in jurisdictions where we and members of our Group are licensed (including the Gambling Commission of Great Britain) |
Necessary to comply with a legal or regulatory obligation |
|
To investigate, and assist with the investigation of, suspected unlawful, fraudulent or other improper activity connected with our Website and Services (including, where applicable, dealing with requests from authorised entities (e.g. sports governing bodies and law enforcement agencies) for the sharing of information and disclosure to such authorised entities) |
Necessary to comply with a legal or regulatory obligation |
|
To use data for research analysis, behavioral monitoring and testing with the outcome to understand potential harm to players. To help encourage safe play and target interventions where necessary.
To carry out market research campaigns |
Necessary to comply with a legal or Regulatory Strategy
Legitimate interests so that we can better understand the products and services that our customers most enjoy |
|
To prepare statistics relating to the use of our Website and Services by you and other customers |
Legitimate interests so we can understand the use of, and therefore improve, our Website and Services
|
|
To provide you with information about, and support for, our Services, including changes to our Services, technical updates for the Website and changes to the Terms & Conditions (including this Privacy Policy) |
Necessary for the performance of a contact and necessary to comply with a legal or regulatory obligation |
|
To keep you informed of offers and promotions relating to our Services and those of other entities within our Group, provided that you don't "opt-out" from this option |
Legitimate interests so we can send you information about our Services (and promotions and offers) that you may be interested in |
|
To keep you informed of offers and promotions for which you have specifically opted-in |
Consent |
|
To grant Brand Owner the right to market its products and services, and those of other entities within its Group, provided that you don't "opt-out" from this option |
Consent |
|
To support any other purpose necessary for performance of our contractual obligations or specifically stated at the time at which you provided your Personal Information |
Necessary for the performance of a contract |
|
To record telephone calls to and from, and live chats with, our customer services representatives for training and security and identification purposes |
Legitimate interests in respect of training so that we improve our customer services, and necessary for a legal or regulatory obligation in respect of security and identification |
|
To monitor gambling patterns and to identify possible responsible gambling concerns |
Necessary to comply with a legal or regulatory obligation |
|
To prevent you from using our Website and Services if you have requested that we do so |
Necessary to comply with a legal or regulatory obligation |
|
To comply with any deposit, spend or loss limits that you have set |
Necessary to comply with a legal or regulatory obligation |
|
To use your name, image, username or location in publicity and marketing, but only where you have provided your express and informed consent for us to do so |
Consent |
|
Cookies: Those that are necessary for the operation of the Website, including allowing you to interact with our Website and to recall selections as you move between pages |
Necessary for the performance of the contract |
|
Cookies: Those that analyse your use of our Website, monitor our web audience and populate certain content on our Website in line with your usage |
Legitimate interest so we can continue to analyse and improve our Website and Services |
|
Cookies: Those that track your journey to and from our Website |
Legitimate interest so we can understand how players come to and from our Website and give effect to any commercial arrangements |
|
Cookies: Those that are necessary for regulatory compliance, including identifying multiple accounts, false logins or potential fraud |
Necessary to comply with a legal or regulatory obligation |
|
Cookies: Those that are used for third party marketing |
Consent |
6.1. We may, for the Purposes, disclose your Personal Information to any of the following recipients:
6.1.1. any company within our Group (including to its employees and sub-contractors) which assists us in providing our Services or which otherwise has a need to know such information;
6.1.2. any third party which assists us in providing our Services, including (but not limited to) payment processors, customer services representatives and chat moderators;
6.1.3. any third party which can assist us in verifying the accuracy of your Personal Information, including financial institutions and credit reference agencies (a record of the search may be retained by such third party);
6.1.4. any third party which assists us in monitoring use of our Services, including the detection and prevention of fraud and collusion,
6.1.5. to Brand Owner;
6.1.6. any contractors or other advisers auditing any of our business processes or who have the need to access such information for the purpose of advising us;
6.1.7. any law enforcement body which may have any reasonable requirement to access your Personal Information;
6.1.8. any regulatory body or authorised entity (e.g. a sporting body or law enforcement agency) which may have any reasonable requirement to access your Personal Information; and
6.1.9. any potential purchaser of our business or any investors in it or in any company within our Group (including in the event of insolvency).
6.2. If at any time you wish us to stop processing your Personal Information for the above Purposes, you should contact us and we will take the appropriate steps to stop doing so. Please note that this may mean that your Account will be closed.
Marketing Preferences
7.1. [Neither we nor Brand Owner (or, if relevant, any company in our respective Groups) will not end you unsolicited information regarding any third party's products or services.
7.2. As part of the Account registration process, you will have the opportunity to choose whether or not to receive information on our offers and promotions [, and those of Active Win Media Limited] (and those of any company in our [respective] Group[s]).
7.3. Unless you have informed us at the time of setting up your Account that you do not wish to receive promotional text messages and/or emails, we will send you such communications until you inform us that you no longer wish to receive them. You may update your marketing preferences at any time by:
7.3.1. if you are receiving emails, clicking on the "unsubscribe" link in an email and following the instructions;
7.3.2. if you are receiving text messages, by following the instructions to unsubscribe; or
7.3.3. contacting our Customer Services team.
Your Personal Information will be transferred outside of the European Economic Area, both to us and other members of our Group. This includes, but is not limited to Israel, Guernsey, and Ukraine. Where we transfer your personal data outside of the EEA, we will put in place adequate measures to ensure that your Personal Information is kept secure (and such adequate measures shall include:
(i) transferring to a jurisdiction which the European Commission recognises as providing adequate protection for the rights and freedoms of data subjects in connection with the processing of their personal data; and
(ii) transfers pursuant to standard contractual clauses in accordance with European Commission decisions on transferring personal data).
For transferring data to service providers outside the EEA, we will ensure that such transfers are absolutely necessary in order for us as data controller to either adhere to a regulatory requirements (such as AML/KYC checks) or perform a contract/service agreement between ourselves and our players. We will also ensure that such transfers are necessary for us as data controller to perform a contract with another party that is in our players interest. We will ensure that the non-EEA countries used for a transfer and processing of personal data are either fulfilling EU adequacy requirements or where needed we will apply the appropriate contractual safeguards in the form of EU Model Clause agreements with our suppliers in line with EU GDPR requirements.
You may update or delete your Personal Information at any time via the Website or by contacting our Customer Services team.
Your rights
10.1. You have the following rights in relation to your Personal Information:
10.1.1. a right to access your Personal Information as held by us (also known as a subject access request);
10.1.2. a right to receive certain Personal Information in machine-readable format;
10.1.3. a right to object to processing where the lawful basis is that it is in our legitimate interests, but please note that we may still process your Personal Information where there are other relevant lawful bases or where we have compelling grounds to continue processing your Personal Information in our interests which are not overridden by your rights, interests or freedoms;
10.1.4. a right to have inaccurate Personal Information rectified;
10.1.5. a right to have certain Personal Information erased where it is no longer necessary for us to process it, where you have withdrawn your consent pursuant to paragraph 10.1.8, where you have objected pursuant to paragraph 10.1.3, where your Personal Information has been unlawfully processed, or where erasing your Personal Information is required in accordance with a legal obligation;
10.1.6. a right to request an explanation of the logic involved where we make decisions about you solely through automated means;
10.1.7. a right to complain to your national data protection supervisory authority ;
10.1.8. where we have specifically requested your consent to process your Personal Information and have no other lawful conditions to rely on, you have the right to withdraw this consent; and
10.1.9. a right to object to direct marketing, which can be done by opting-out of direct marketing either through your Account or by opting out via the communication itself. You also have a right to object to any profiling to the extent that it relates to direct marketing only.
10.2. If you are unsure about your rights or are concerned about how your Personal Information may be processed, you should contact your national data protection regulator.
10.3. If you would like to exercise any of your rights then you can do so by contacting us as described below. Please be aware that while 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.
10.4. 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. We will aim to respond to any request within one month of verifying your identity. If we receive repeated requests, or have reason to believe requests are being made unreasonably, we reserve the right not to respond.
11. Retention of your Personal Information
We will retain your Personal Information for the period necessary for us to provide you with our Services and to comply with our legal and regulatory responsibilities. Accordingly, your Personal Information will be retained for a minimum of five years following [the closure of your Account (if applicable) or the last contact with us emanating from you]. Where it is no longer necessary for us to process your Personal Information, we will delete it sooner. If you request that you should not be able to access our Website and Services (i.e. self-exclude), we will retain this information for a minimum of seven years.
12. Contacting Us
12.1. You can contact our Customer Services team using the details here .
12.2. If at any time you believe that we have not adhered to this Privacy Policy, please contact our privacy team at [email protected]
You may update or delete your Personal Information at any time via the Website or by contacting our Customer Services team.
13. Advertising and use of Cookies
13.1. We may collect anonymous information about your use of the Website using "cookies", pixel tags and similar functionality. A "cookie" is a small file of text which is downloaded onto your computer when you access the Website, and it allows us to recognise when you come back to the Website. We use cookies for the operation of the Website, including (for example) to allow you to remain logged in as you move between different parts of the Website. We also use cookies for our own analytical purposes so that we can identify where customers have encountered technical problems on the Website, and therefore help us improve our customers' experiences. We also use services provided by third parties for fraud prevention purposes. For these purposes, Cookies are placed on your device to identify it in the future when you visit our Website or connect with our applications.
The cookies used on this Website are either set by us or by our third party service providers, and fall into the following categories:
1) Strictly Necessary - these cookies are essential in order to enable you to move around the Website and use its features. If you remove or disable these Cookies, we cannot guarantee that you will be able to use our Websites or benefit from all our security features.
2) Performance - these Cookies collect information about how visitors use our Website. They allow us to recognise and count the number of visitors and to see how visitors move around our Website.
3) Functionality - these Cookies are used to provide services or to remember choices you make so we can personalise our content for you. We use this information to customise your experience of our Website to meet your preferences for content layout, text size etc. You can manage these Cookies using your browser settings. However, if you block them we may not be able to offer you certain services that you have chosen
4) Targeting - these Cookies record the fact that you have visited our Website, including which web pages you have accessed, which device you have accessed them from and which links you have followed. We use this information to make our Website relevant to your interests and for fraud and website abuse detection purposes, including detecting players who have abused bonus schemes or other promotions.
Some of these are "session cookies", which stay in place only for the duration of your visit to our website and are deleted at the end of your browsing session. Others are "persistent cookies", which remain on your device for a period of time after you have left the Website.
13.2. Most browsers have cookies enabled by default, but you are able to change your cookies settings, which are usually found in the 'options' or 'preferences' menu of your internet browser. You can block any cookies from any website by activating the setting on your browser that allows you to refuse the setting of some or all cookies. However, if you block all cookies you may not be able to access all or part of our Website. You can also use your browser settings to delete cookies. For more information about how to disable cookies in your browser please visit www.allaboutcookies.org.
13.3. As part of the Website's operation, and for our own statistical analysis of site traffic, our Website automatically logs internet IP addresses. We do NOT log any e-mail address of visitors to the Website. Our advertising system logs IP addresses to supply more accurate advertising features, such as language-specific banners.
13.4. While the Website may contain links to websites operated by parties other than us, we are not responsible for the privacy practices or content of such websites.
14. Security
14.1. We are committed to ensuring that your Personal Information is secure. In order to prevent unauthorized access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the Personal Information that we collect.
14.2. All the Personal Information that you provide us is stored in a secure computing environment protected by secure firewalls to prevent unauthorized access. We control access so that only people who need to access the Personal Information can. All staff are provided security training and are required to adhere to a comprehensive set of security policies, procedures, and standards related to their jobs.
14.3. When you use secure areas of our Website, we use SSL with 256 -bit encryption. This means that all the information sent between your computer and our secure computer environment is encrypted or scrambled so that no one can read it in transit. Secure areas of the site have a time-out feature. If you leave your secure session inactive for some time, it times-out to prevent unauthorized access.
14.4. Where your Personal Information needs to be disclosed to our service providers, we require them to process and protect your Personal Information in a manner consistent with this Privacy Policy and applicable laws.
Occasionally, we may share limited personal data to test a new third-party service or new software providers, to improve our capabilities to adhere regulatory requirements. Any personal data shared will be fully restricted for the purpose of testing of services, new software, new third-party providers capabilities. This is a mandatory aspect of continuous improvement of services we offer to players and clients.
Any data shared to conduct these tests will be deleted promptly at the end of the testing period.
For the majority of our bingo players, gambling is entertainment and a way to chat to some of your online friends. But unfortunately, gambling can become a serious problem for some. We want you to enjoy your online gambling experience and advise you to follow these guidelines:
Privacy Policy and Data Protection Consent
BY AGREEING TO THESE TERMS YOU AGREE TO THE TERMS OF OUR DATA PRIVACY POLICY AND DATA CONSENT. SUCH POLICY AND CONSENT IS INCORPORATED IN AND FORMS PART OF THESE TERMS.
Information on what (if any) data is held about you can be obtained by contacting us as follows -
The Data Protection Officer
Virtue Fusion (Alderney) Limited
2nd Floor
St George’s Court
Upper Church Street
Douglas
Isle of Man
IM1 1EE
In accordance with applicable Alderney and Guernsey data protection legislation we reserve the right to charge a fee for providing such information.
The Service provider sharing data with the relevant authorities in the event of suspected fraudulent or suspicious behaviour on a player account or misuse of the casino software.
Privacy Policy
This Policy
This Privacy Policy relates to the web sites, which Bucky Bingo ('we', and 'us') operates. This Privacy Policy incorporates the User Terms which govern the use of this Website. The User Terms which govern the use of this Website incorporate this Privacy Policy. We may change this privacy policy at any time. We will post the changed policy to this page so you are always aware of the information we collect through this Web Site, how we use it and under what circumstances we disclose it.
Information we collect.
We may collect personal information that you send to the Web Site when you register to use parts of the Web Site, use services (including subscriptions, chat rooms, forums and bulletin boards) or enter promotions or competitions available on the Web Site (collectively Web Site Services), send material for inclusion on the Web Site, send communications to us, generate material by interacting with the Web Site (and other Web Site users) and otherwise allow us to collect your personal information.
We may collect anonymous information about your use of this website using cookies, pixel tags and similar functionality. Uses of your Data
We may use your personal data and match anonymous information we collect with any personal data you have given us to provide and/or process the relevant Web Site Service you wish to use, respond to any communications you send to us, fulfil our obligations under any contracts you enter with us through the Web Site, personalise the Web Site for your use, improve the way the Web Site works, send you marketing communications (only where you have specifically consented) and maintain our user and customer records. We may disclose your personal data to any contractors, agents or other persons providing services to us for these purposes.
A cookie is a short piece of data which a web server sends to a web browser when that browser visits the server's site. Pixel tags read cookies. Most browsers automatically accept cookies. You can set your browser so you will not receive cookies and you can also delete existing cookies from your browser.
The Web Site may include marketing consent boxes (or other forms of consent capture) on certain pages where you provide your personal information. These will give you the opportunity to consent to specified uses of your personal information for marketing purposes. We will send you marketing communications ourselves only if you consent to receive such communications. We will share your information with trusted third parties for marketing purposes only if you consent to such use of your information. If you would like details of who these companies are, please e-mail [email protected]
If you click on links and banner advertisements on the Web Site you may transfer to third party web sites. Third party web sites may have different data protection practices from those of Bucky Bingo. You should consult the terms and conditions of use and privacy policies of any third party site you visit through our Web Site. We are not responsible for, and have no control over, information that you send to third party web sites or that they collect.
Your choices
You can change your computer settings to limit anonymous information we can collect about your use of the Web Site. The 'Help' menu on the menu bar of most browsers will guide you in preventing your browser from accepting new cookies, having your browser tell you when you receive a new cookie, and disabling cookies. You may find some parts of the site will not work properly if you limit anonymous information we can collect about your use of the Web Site. Please also see 'Use of your Data' section of this Privacy Policy.You may choose not to send your personal information to us. If you do not send personal information you may not be able to take advantage of all the functions the site and marketing offers.If you do not want to receive e-mail or other communications from us and/or trusted third parties, you should not consent to uses of your personal information that allow such communications. However, if you do not consent to receive marketing communications, on relevant web pages, you will miss out on receiving important information on new offers from us and from our trusted partners.
Even if you choose not to receive notices about User Terms, this Privacy Policy and other legal notices from us, those notices will still govern your use of the Web Site and it is your responsibility to review them for changes.You can review your transaction history in the 'My Account' area or alternatively you can email Customer Services to request that your transaction history be sent to you.You have the right to request a copy of the personal information we hold about you and to have any mistakes corrected. If you wish to request a copy of the personal information we hold about you please write to Virtue Fusion Data Department VFA Support Department, 2nd Floor, St George’s Court, Upper Church Street, Douglas, Isle of Man, IM1 1EE or e-mail [email protected] If you request a copy of the personal information we hold about you we may ask you to verify you identity to our satisfaction, and we may charge a nominal fee.
Regulatory
Bucky Bingo will treat your personal information with the utmost respect and is subject to Directive 95/46/EC on the protection of individuals with regard to processing of personal data and on the free movement of such data, The Data Protection (Bailiwick of Guernsey) Law, 2001 (registration number 011655), and any other applicable data protection laws and regulations. You can find out more about The Data Protection (Bailiwick of Guernsey) Law, 2001 on The Official Guernsey Government website: https://www.gov.gg/DP
All gaming is controlled and operated by Virtue Fusion (Alderney) Limited.
This is licenced and regulated under Alderney Gambling Control Commission licence number 40 C1 & C2 and the Gambling Commission under licence 38838. For Online Dispute Resolution please click on the following link; ODR
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