Daub Alderney Limited (‘Daub’) (Bailiwick of Guernsey) is part of The Rank Group Plc group of companies (‘Rank Group’) which operates gaming venues in Europe and digital gaming sites, including the Bella Casino, Enracha, Grosvenor Casino, and Mecca Bingo brands and other associated and subsidiary companies. For the purposes of this Privacy Policy, the data controller is Daub Alderney Limited whose address is Inchalla, Le Val, Alderney, GY9 3UL. The Group provides services on the Site through various software and/or platforms (collectively referred to as ‘Platforms’)

• Websites
• Mobile applications
• Downloadable applications
• Non- Downloadable applications
• Social Media Networks

This Privacy Policy represents Our current data collection and usage practices. We will from time to time, review and revise these practices. We will post any changes to this Privacy Policy here. Please refer to this Privacy Policy regularly. If We make material changes to this Privacy Policy, we will notify you before they take effect either through the Site or by sending you a notification. Any such material changes will only apply to Personal Information (as defined below) collected after the revised Privacy Policy took effect.

We encourage you to read the Privacy Policy carefully and use it to make informed decisions. This Privacy Policy only applies to information collected by the Site.

By engaging with Our Site you acknowledge you have read and understood this Privacy Policy.

Definition of Personal Information. 

Personal information is information about you and that identifies you or can be used to identify you (in conjunction with any other information We have about you) e.g. your name, email address, address or telephone number, IP Address, copies of ID, proof of address, etc (“Personal Information”).

We collect the types of Personal Information outlined below:

Information We Collect Directly from You:

Registration Details 

You will be asked to provide details about yourself, such as first and last name, email address, full name and gender, birth data, physical address, ID number, phone number, etc. when you register an account.

Payment Information

Payment information may be collected from you, such as your bank card number (first 6 and last 4 digits) PayPal account, bank account details etc.

Identity and Verification information

This includes documents which can verify your identity such as your passport, driving license, utility bills etc. We may also ask for additional information regarding account funding and your affordability.

Voluntary Information

When you respond to communications from us, communicate with us via email or share additional information about yourself through your use of the Platforms, such as on the chat feature, in games, enter a competition, promotion or survey, submit a query, and when you report a problem with our Site.

Information We Collect About You from Your Use of Our Site

We will automatically collect information from you each time you visit or otherwise use Our site. This includes:

Technical and Device Information

We may collect specific types of connection details and information with regard to your device, software or hardware that may identify you, such as a device’s unique identifiers, IP address used to connect your device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and geolocation data (to comply with our anti-money laundering policy). We use Google Analytics and abide by the Google Analytics Terms of Service and are subject to the Google Analytics Policies.

Social Networks

 When you register through your social network account (such as your Facebook account), to use our services or connect your player account with such account, we will have access to basic information from your social network account, such as your name, birthdate, profile picture and friends’ list, as well as information you made publicly available on such account.

Information We Collect About You From Other Sources

We may collect information about you from third-party service providers or information that is publicly available. This may include information to check your age, identity, affordability and to reduce risk or prevent fraud or other illegal activities.

Our providers may check the details we supply against any particulars on any database (public or otherwise) to which they have access. They may also use your details in the future to assist other companies for verification purposes. A record of the search will be retained.

We use and share Personal Information for the following purposes:

• To register your account with us;
• To update your account;
• To access Our Games;
• To provide you with bingo games, casino games, any other games and betting services offered on the Platforms;
• To communicate with you and to keep you informed of Our latest updates and special offers;
• Where permitted in Our legitimate interest or with your prior consent where required by law, a member of our Group, will use your Personal Information for marketing analysis and to provide you with promotional update communications by email, post, telephone, direct messaging, direct mail and other digital channels  (pop-ups, push notification, banner advertising, etc.) about Our or their products/services,  promotional materials,  as well as products, services, websites and applications which relate to products and services from companies (other than Daub) within the Group and our Trusted Partners which We believe may interest you. You may at any time object to further marketing by checking and updating your contact details within your account or selecting the “unsubscribe” link at the end of all Our marketing and promotional update communications to you, or by sending us an email to [email protected]
• Our selected third parties with whom We may share your Personal Information with (see section 6 below) may send you advertisements promotional materials and communications about their products or services which may be of interest to you, with your prior consent where required by law;
• To assist you with your queries;
• To process any of your requests for information;
• To notify you about updates to Our software and/or services;
• To investigate and resolve disputes about your use of Our services;
• To comply with Our licence conditions with the UK Gambling Commission and the Alderney Gambling Control Commission;
• To conduct credit searches;
• To improve your user experience through data collected through analytics;
• To carry Our due diligence;
• To ensure that the quality and accuracy of the data we process.
• To detect and prevent fraudulent activities
• As required by law, regulation or other governmental authority; 

We may also use other types of information to monitor Site usage to help us develop Our Site and the services and for these purposes.

USE OF SPECIAL CATEGORY DATA

We may process very sensitive information relating to your health or mental health such as a disclosure to staff of a gambling problem. 

We do not sell or share your Personal Information with third parties except as described in this Privacy Policy. The Personal Information will be disclosed to a third party only to the extent required for the specific purpose, as stipulated in this Privacy Policy 

Who your information may be shared with:

Your information may be shared with any member of Our Group (as defined in this Privacy Policy), who support Our processing of Personal Information under this Privacy Policy. If any of these parties are using your information for direct marketing purposes, we will only transfer the information to them for that purpose with your prior consent. Our selected third parties may include:

• Organisations which process your Personal Information on Our behalf and in accordance with Our instructions and applicable data protection laws. This includes in supporting the services We offer through the Site, in particular, those providing website and data hosting services, providing fulfilment services, distributing any communications We send, supporting or updating marketing lists, facilitating feedback on Our services and providing IT support services from time to time, to third parties who provide services in relation to the operation or promotion of the Site, organize events on behalf of the Group. These organisations (which may include Our third-party suppliers, agents, sub-contractors, auditors, advisors, investors, potential buyers and/or other companies in Our Group) will only use your Personal Information to the extent necessary to perform their support functions.
• We may share some of your personal data, including your first name, last name, DOB and address with a Credit Reference Agency (TransUnion) so that we can carry out an affordability check on you, in certain circumstances. This check may leave a search footprint, but please note that this will not affect your credit score. For any further information about how TransUnion holds and uses your information please click here: https://www.transunion.co.uk/legal-information/bureau-privacy-notice
• Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to Our advertisers, but We will provide them with aggregate information about our users. We may also use such aggregate information to help advertisers reach the kind of audience they want to target. We may make use of the Personal Information we have collected from you to enable us to comply with Our advertisers’ wishes by displaying their advertisement to that target audience and subject to the cookie section of this Privacy Policy.
• Business partners who provide services to you and with whom We have entered into agreements in relation to the processing of your Personal Information.
• Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
• Payment processing providers who provide secure payment processing services.

We will disclose your personal information to third parties:

• In the event that We sell or buy any business or assets, in which case We will disclose your Personal Information to a prospective seller or buyer of such business or assets subject to the terms of this Privacy Policy.
• If Daub or a member of the Group substantially all of its assets are acquired by a third party, in which case Personal 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 Personal Information in order to comply with any legal obligation, or in order to enforce or apply our terms of supply terms and other agreements with you; or to protect the rights, property, or safety of Our Group, Our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction and to prevent cybercrime.

The Group operates globally and the Personal Information that We collect may be transferred to, and stored at, a destination outside the European Economic Area ("EEA") that may not be subject to equivalent Data Protection Law.

We may transfer your personal information outside the EEA:

• In order to store it.
• In order to enable us to provide goods or services to you and fulfil Our contract with you. This includes order fulfilment, processing of payment details, and the provision of support services.
• Where We are legally required to do so.
• In order to facilitate the operation of Our Group, where it is in Our legitimate interests and We have concluded these are not overridden by your rights. In these instances, We will take all steps reasonably necessary to ensure that your Personal Information is subject to appropriate safeguards, such as relying on a recognised legal adequacy mechanism, and that it 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 Site you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

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 your data transmitted to Our Site; any transmission is at your own risk. Once We have received your information, We will use strict procedures and security features to try to prevent unauthorised access.

We take cyber-security very seriously, not only to protect us, but also our clients and their data. We implement different layers of physical and technological controls to prevent unauthorised access and to ensure data security, integrity and privacy.

Controls include, but are not limited to:

• Firewalls, Network Segmentation, Intrusion Detection and Prevention Systems
• Penetration Testing and Vulnerability Remediation
• Encryption protocols for data at rest or in transit
• Strict Access control and authentication procedures
• Regular Cyber-Security Audits

Our Site may, from time to time, contain links to external sites. We are not responsible for the privacy policies or the content of such sites.

The Site may, from time to time, make chat rooms, message boards, news groups and/or other public forums available to its users. Any information that is disclosed in these areas becomes public information and you should exercise caution when using these and avoid posting any personal information.

Protecting the safety of children when they use the Internet is important to us.  The Site is intended for use only by persons who are at least 18 years of age.

By using the Site, you confirm to us that you meet this requirement.

We may revise this Privacy Policy from time to time, in Our sole discretion, and the most current version will always be posted on this Site and substantive changes will be notified to you by email. Your continued use of Our services, following the notification of such amendments on this Site, constitutes your acknowledgement of such amendments to the Privacy Policy.

This Privacy Policy was last updated on 25 March 2020.

The data protection team can be contacted at:

By Email:             [email protected]

By Post:               Data Protection Officer

Daub Alderney Limited

Turing House

La Gibauderie

St Peter Port

Guernsey

GY1 1XN

By Phone:           0845 565 2059

We retain Personal Information for as long as you have an account with us in order to meet Our contractual obligations to you and to comply with Our licence conditions with the UK Gambling Commission and Alderney Gambling Control Commission and 5 years after your business relationship with Us ends. We may also retain aggregate information beyond this time for research purposes and to help us develop and improve Our services. You cannot be identified from aggregate information retained or used for these purposes. 

You can ask us:

• To access all the Personal Information about you held by us. On request, We will provide you with a copy of this information. We reserve the right to charge a reasonable fee taking into account the administrative costs of providing the information or taking the action requested;
• To correct or erase your Personal Information where appropriate;
• To restrict the processing of your Personal Information whilst We investigate your concern;
• To object to direct marketing or in certain cases object more generally;
• Where your processing is based on your consent, to receive your Personal Information in a commonly used electronic format or ask We move the data in that format to another provider where your request relates to the data that you gave us direct and where technically possible (data portability);
• To withdraw your consent at any time when the processing relies upon consent.

If you remain unhappy with a response you receive you can also refer the matter to your data protection supervisory authority (see https://ec.europa.eu/info/law/law-topic/data-protection_en)

When you visit any web site, it may store or retrieve information on your browser, mostly in the form of cookies. Cookies are small text files containing small amounts of information which are downloaded on your device when you visit a website. This information might be about you, your preferences or your device and is mostly used to make the site work as you expect it to. The information does not usually directly identify you, but it can give you a more personalized web experience. Because we respect your right to privacy, you can choose not to allow some types of cookies.

Cookies set by the website owner (Us) are called “first party cookies”. Cookies set by other parties are called “third party cookies”. Third-party cookies enable third party features or functionality to be provided on or through the website (e.g. like advertising, interactive content and analytics). The parties that set these third party cookies can recognise your computer both when it visits the website in question and also when it visits certain other websites.

Why do we use cookies?

There are different types of cookies.  Some cookies are “strictly necessary” which enable you to access and use our entertainment services.

We also use functional, performance and advertising cookies to make your experience more enjoyable. You can switch these on or off at any time and you can always change your mind. We’ll only use them if you have agreed to them.

The last type of cookie which may be used are those from other companies. These “third-party cookies” might track how you use different websites, including ours. For example, you might get a social media company’s cookie when you see the option to share something. You can turn them off, but not through us. 

How long do cookies last?

Some are erased when you close the browser on your website or app. Others stay longer, sometimes forever, and are saved onto your device so that they’re there when you come back.

We use the following types of cookies:

How do I control my cookies and tracking?

When you visit us for the first time we will ask you if you wish to accept the cookies we use. 

You can choose whether or not to accept cookies by activating a setting on your browser which allows you to refuse the setting of cookies. If you choose to reject cookies, you may still use our Website however access to some functionality and areas of our Website may be restricted.

You can learn more about cookies by visiting www.allaboutcookies.org which provides useful information on cookies and further information on how to block cookies using different types of browser or mobile device.  You may also find the following links helpful:

• https://www.aboutcookies.org/ (contains information about cookies on a wide variety of desktop browsers.)
• Cookie settings in Internet Explorer
• Cookie settings in Firefox
• Cookie settings in Chrome
• Cookie settings in Safari
• Cookie settings in Edge

Please note, however, that by blocking or deleting cookies used on the platforms, you may not be able to take full advantage of the products and services that are on offer. 

What about other tracking technologies?

Cookies are not the only way to recognise or track visitors to a website. We may use other, similar technologies from time to time, like web beacons (sometimes called “tracking pixels” or “clear gifs”). These are tiny graphics files that contain a unique identifier that enable us to recognise when someone has visited our Website (or opened an email that we have sent them). This allows us, for example, to monitor the traffic patterns of users from one page within our Website to another, to deliver or communicate with Cookies, to understand whether you have come to our Website from an online advertisement displayed on a third-party website, to improve site performance, and to measure the success of email marketing campaigns. In many instances, these technologies are reliant on Cookies to function properly, and so declining cookies will impair their functioning.

Google Analytics

This Website uses Google Analytics, a web analysis service from Google Inc. (“Google”). Google Analytics uses cookies or text files. These are saved on your computer and allow your usage of the Website to be analysed. The information generated by the cookie about your usage of this Website is generally sent to a Google server in the USA and saved there. However, if IP anonymisation is activated on this Website, your IP address is shortened by Google within the member states of the EU or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases is the full IP address sent to a Google server in the USA and shortened there. Google will use this information on behalf of the operator of this Website to evaluate your usage of the Website, to compile reports about the Website activities and to perform further services connected to Website usage and Internet usage in its dealings with the Website operator. The IP address sent by your browser as part of Google Analytics is not combined together with other data by Google.

You can prevent these cookies from being saved by making an appropriate setting in your browser software. However, you may then not be able to use all the Website’s functions to their full extent.

You can also prevent the data (incl. your IP address) generated by the cookie and related to your usage of the Website from being sent to Google and processed by Google by using the above-mentioned opt-out links. More information is available at analytics.google.com.

Pixels

We use pixel-based tracking to track a visit or event on the Platforms and to track advertisement.