Updated: 10 May 2018
We take your privacy seriously and know how important personal information is to everyone. That’s why we’re committed to protecting your privacy and keeping your personal information safe. In this policy we will outline why we collect your data and how we make sure your rights and wishes are always protected.
Data Protection Officer
If you have any concerns about how we handle your personal information, or if you want to submit a ‘subject access request’ or a request to exercise any of your rights, please contact our Data Protection Officer at: firstname.lastname@example.org
Our services are not intended for or directed at persons under the age of eighteen (18) (or the lawful age in their respective jurisdiction). Any person who provides their information to us through any part of the services represents to us that they are eighteen (18) years of age (or the lawful age in their respective jurisdiction) or older. It is our policy to uncover attempts by minors to access our services. This may involve accessing and verifying your personal information. If we become aware that a minor has attempted to, or has, submitted personal information via the services, we will not accept this information and will take steps to remove such information from our records.
Collecting information about you
We collect personal information about you whenever you use our services. Some of this information you give us directly. For example, when you create an account with us.
Other information is collected as you interact with us. For example, when you contact our customer services team. We also collect information about the way you access, view, share, contribute to and communicate with and through our services. For example, when you interact with us on social media. We collect information from the devices you use to use our content, products and services. This includes, but is not limited to, the following:
Your IP address (a number that identifies a specific device on the internet and is required for your device to communicate with websites), hardware model, operating system and version, software, preferred language, serial numbers, device motion information, mobile network information and location data,
server logs, which include information such as dates and times of access, the app features or pages you view, app crashes and other system activity, and the third party site or service you were using immediately before visiting our site.
Information we get via Cookies
'Cookies' are small text files stored in your web browser that let us recognise your computer when you visit one of our websites. Cookies are essential to keep certain parts of our websites functioning correctly and securely. We also use them to make improvements to our website by understanding how you use it. Cookies can also be used to present you with tailored advertising content.
The cookies we use fall into the following categories:
Strictly necessary cookies:
These cookies make our website work, they are essential so that you can move around the site and log in to the secure areas. They also enable us to deliver content in a way that works for your device.
Functionality cookies to enable the features of the website:
These Cookies allow our websites to remember choices you have made, such as your user name. They help us keep you logged into your account as you navigate around our websites, and enable you to use certain features.
Analytical cookies to monitor the performance of our website:
These Cookies collect information about how people use our websites and how the sites are performing.
Targeting Cookies for marketing and advertising:
These cookies are used to deliver adverts and content that are more relevant to you. They also limit the number of times you see a particular advertisement and measure the effectiveness of advertising campaigns.
All modern browsers allow you to see what cookies you have, and to clear them individually or in their entirety by changing your cookie settings. Cookie settings are typically found in the 'options' or 'preferences' menu of your browser, otherwise you should use the 'Help' option in your browser for more details.
How and why we use your personal information
Data protection law gives you rights over your personal data, which differ according to which category your data falls into. Below we explain more about each category, your rights, how to exercise them and what that means in practice.
We use the information we hold about you in different ways, below are the main areas:
- Things we need to do to provide you with the products or service you have asked for
- Things we need to do to meet legal or regulatory obligations
- Things that enable us to run our business effectively and efficiently
- Things we do with your consent for marketing purposes
Providing our products and services:
We use your personal information to enable you to use our sites, to set up your account, to respond to queries and to contact you. We use technical information about your device, such as operating system, browser version and location to present you with the correct version of our website or app and keep it functioning securely and correctly.
Like most organisations, to provide our products and services we share your information with external organisations working on our behalf such as partypoker.
You do have the right to opt out of having your data used in this way. If you don’t wish for your data to be used in this way then the only option is to stop using our services and to close your account.
Meeting our obligations for legal and regulatory requirements:
We need to comply with a range of legal and regulatory requirements, some of which involve the use of personal information.
If you do not wish for your data to be used for legal and regulatory requirements then the only option is to stop using our services and to close your account.
Running our business effectively and efficiently:
Data protection law gives you the ‘right of objection’ to the activities in this category if your right to privacy outweighs our legitimate business interest in doing them. You always have the option to exercise this right but, as explained below in more detail, these activities are essential to our business, so if you if you do not wish for your data to be used in this way then the only option is to stop using our services and to close your account. We carry out basic analytics to help us understand, how, when, where and why our customers use our services, and how our business is performing. This helps us monitor and plan everything we do within our business. We do this analysis in a way that does not identify individual customers, so there is no impact on the privacy of any one person.
Things we do with your consent for marketing purposes:
We will send you offers and information only if you have given your consent, in which case we will contact you by email, post, SMS or online about any of our products and services. We will not share your data with companies outside of our group for them to use for their own marketing.
How long do we keep your information?
We hold your personal information only as long as we have a valid legal reason to do so, which includes providing you with the services you have requested, meeting our legal and regulatory obligations, resolving disputes and enforcing our agreements.
The length of time for which we keep different types of personal information can vary, depending on why we originally obtained them, the reason we process them and the legal requirements that apply to them. To fulfil our requirements, some of your personal data will need to be retained for a period of time after you cease to be a customer. When we no longer need it to fulfil the above requirements, we delete it securely. Where we wish to retain any information for analytical purposes, we first anonymise it. Please note that if you opt out of receiving marketing from us, we will still need to keep your contact details in order to suppress them from future marketing activity.
How do I exercise my ‘right to be forgotten?’
Please contact us at email@example.com and we will respond to your request within a month. If we uphold your request and erase your data we will also notify any third parties to which the data has been passed, where we are able to do so, and tell you who they are. If we do not uphold your request, we will tell you why. If you disagree, you have the right to complain to the privacy regulation.
The right to access the data we hold about you
If you would like a copy of the personal information we hold about you, you should request by emailing firstname.lastname@example.org We will ask you to complete and return a form, which is not compulsory but helps us to help you by providing the information you are looking for. Before we respond to your request, we will ask you for valid proof of identity and once we’ve received it we will provide our response within one month.
If you believe your privacy rights have been infringed, or you disagree with a decision we have made about your privacy rights, you have the right to complain to the privacy regulator. We are based in the UK, our principal data protection regulator is the UK’s ICO
- In the UK, ICO https://ico.org.uk/
Links to Third Party Sites
Keeping your data secure
We understand the importance of information security and the techniques needed to secure information. We store all of the Personal Information we receive directly from you in a password-protected database residing within our secure network behind active state-of-the-art firewall software. Our hosting solution encrypts all data in transit and all sensitive data in transit and at rest and is compliant with the following industry leading standards:
- ISO 27001
- SOC 1 and SOC 2/SSAE 16/ISAE 3402 (Previously SAS 70 Type II)
- PCI Level 1
- FISMA Moderate
- Sarbanes-Oxley (SOX)
We take active steps to ensure our subsidiaries, agents, affiliates and suppliers also employ adequate levels of security manages risk and undergoes recurring assessments to ensure compliance with industry standards.
Your privacy and shared computers
If you log in to one of our websites from a shared computer, cookies may cause your email address or user name to display in the login field to anyone who uses the site on that computer after you. You can avoid this by clearing the Cookies stored by the web browser. The option to do this is normally in the ‘Tools’ dropdown menu at the top of the browser window. If you have opted to stay logged in, remember that another person using the same device could access your account unless you log out.
Passwords and PINs
Remember to keep your passwords and PINS secret, choose complex passwords, change them periodically and never use the same password or PIN on multiple websites.