Daub Alderney Limited Privacy Policy

1. Introduction

At the Rank Group plc, we are committed to protecting and respecting your privacy. This policy explains the basis on which personal data we collect about you will be processed by us. Where we decide the purpose, or means, for which personal data is processed, we are the 'Data Controller'. We will comply with all applicable data protection laws, including the Data Protection Act 2018 and the UK General Data Protection Regulation (“UK GDPR”).

This policy explains the following:

• What personal information we collect;
• How we use that information;
• Who we may disclose that information to; and
• Your rights.

Our services contain hyperlinks to websites operated by third parties. These third-party websites will have their own privacy policies and we recommend you review them. They will govern the use of personal information you submit, or which are collected by cookies whilst visiting those websites. We do not accept any responsibility or liability for them and your use of them is at your own risk.

This policy was updated in May 2021. We will update it from time to time and if we make changes that could affect you, we’ll let you know beforehand.

Who are we?

These online services are provided by Rank Interactive Gaming Limited, a company registered In Gibraltar under company number 109659, ("Rank", "we", "us" or "our" in this policy). We are registered as a Data Controller with the Information Commissioners Office (ICO) and details are published on a public register on the ICO website at https://ico.org.uk.

We are 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, Mecca Bingo and YoBingo brands and other associated and subsidiary companies.

Our data protection officer

If you have any concerns about how your personal data is used or to exercise any of your rights, including submitting a subject access request, please contact us on the following:

Email: dataprotection@rank.com

Post: Data Protection Officer, Rank Interactive Gaming Limited, c/o TOR, Saint-Cloud Way, Maidenhead, Berkshire SL6 BBN

2. Collecting Information about you

We collect and process the following information which may include your personal data.

Information you provide to us

We collect information about you whenever you use our services. Some of it is provided directly when you register for an account with us, deposit funds or play one of our games. Other information will be collected as you interact with us, such as requesting to join our mailing lists, taking part in market research or customer satisfaction surveys or dealing with our customer services team. We also collect information about the way you interact with us through our social media channels or chat functionality.

In addition, we are required to comply with anti-money laundering and responsible gambling legislation so we may request proof of identity and source of funds information from you from time to time, which you must provide to us promptly.

This information will include your name, username, age, date of birth, gender, address, image, telephone number, e-mail address, password and other identity or source of funds information.

Information we collect from your device

We collect information from your device relating to the web address that you arrive from or click through to, pages viewed, page response times, download errors, the length of time you spend on certain pages, page interaction information such as scrolling, clicks, wagers, and methods used to browse away from our pages.

We use technology to determine your current location, verify your identity, ensure that your location is within our permitted territories, and to display relevant advertisements and promotions to you.

This information includes your IP and MAC address, hardware model, operating system and version, browser type, time-zone and browser plug-in details.

Payment information

In order for you to use all the functions of our services, we collect payment information from you including your debit or credit card number and bank account details.

Information collected from external companies

To help us comply with our legal and regulatory obligations when you open an account with us, we obtain information from external companies to verify your identity, check your age or determine the source of funds. This information is used to reduce risk or prevent fraud or other illegal activities.

Our providers may check the details we supply against any particulars held 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.

The service providers we use for these purposes include but are not limited to:

• C6 Intelligence Information Systems
• Experian GB Group
• Kroll Associates

Where a customer self-excludes through the Gamstop national self-exclusion scheme, we will receive a notification of this, which will only be used to ensure their wish to self-exclude is applied across our sites and app as appropriate. We may subscribe to additional self-exclusion schemes in future and will update this policy accordingly.

Affordability - what we use the data for

To ensure that your details are up to date, we may supplement the information we hold about you with data from companies such as GB Group or Royal Mail that collate and update address and household information for a range of sources. We will only work with companies that obtain this data in compliance with data protection legislation. This data will not be used to market to you without your prior consent.

To understand more about how we use your personal information to determine your affordability profile, please click here.

Publicly available information

We must comply with legal obligations to promote responsible gambling, consider our customers financial ability to gamble and prevent our services from being used for illegal purposes. If we identify activity on your account that could present a risk or we believe you have provided false information, we will look at publicly available information about you such as social media accounts (Facebook, Instagram, Twitter etc.) property ownership details, the electoral roll, Companies House and insolvency registers to verify the information provided to us.

3. How and why we use your personal information

To provide the services to you

As applicable, we will use information about you for delivering our service under the agreement between us, including responding to your enquiries; to contact you about matters requiring your attention and providing you with a responsible gaming environment. We may use third parties to assist us with this.

All our services' financial transactions are handled through our payment services providers, who will have access to your payment information.

The service providers we use for these purposes may Include:

• Safecharge International
• Worldpay
• Barclays
• Paysafe Group
• Paypal

In order to provide the games to you, we may share your user ID, country code, username, full name, date of birth and gender with various third-party game providers.

For more information about these service providers, please contact us using the details in section 1.

To prevent fraud and illegal activity

We process personal data for our legitimate interests of ensuring that your use of our online services Is lawful and non-fraudulent, does not disrupt the operation of our services, does not harass our staff or other individuals, and to enforce our legal rights and comply with our legal obligations.

We may use third-party providers to assist us with this. To do so they may check the details we supply against any particulars held 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.

The service providers we use for these purposes may include but are not limited to:

• C6 Intelligence Information Systems
• Experian
• GB Group

To personalise our services

We will use information about you (in particular, how you use our services), to optimise and tailor our services to you and allow us to cater to your preferences. This may mean that when you are accessing our website through your account, the website looks different than when another person accesses it through their account.

We process personal data in this way for the legitimate interests of ensuring that you and other users have the best experience when using our services.

Marketing

Direct Marketing: We might send you marketing e-mails about products or services which are similar to or related to those available via our online services, or contact you by phone, SMS or post. We do this in our legitimate interest of marketing our business and we only do this in accordance with the laws relating to marketing directly to individuals.

Group Marketing: With your consent, we may use various forms of marketing to provide you with promotional materials about the services of other companies in the Rank Group.

Targeted Marketing: With your consent, we may use the information we collect about you to serve you targeted advertisements via our own channels (i.e. our websites, apps, display advertising) and third-party channels, including across multiple devices or browsers. We do this to provide you with more relevant advertising content.

The third-party channels we use for these purposes may include:

• Facebook
• Twitter
• Instagram
• LinkedIn
• Snapchat
• Google Bing
• App Store
• Affiliate networks and partner channels
• Wi-Fi, Bluetooth and near field communication

We may use third-party providers to assist us with our marketing. To re-set your consent preferences at any time please see section 5.

To understand how our services are used

We process information to understand how visitors use our website and to compile statistical reports regarding that activity. This processing is necessary for us to pursue our legitimate interests of improving our services, and providing a better and more personalised experience to our users.

We use third-party analytics providers who may include:

• Adobe
• Tealium
• Optimisely
• Optimove
• Monetate
• DoubleClick
• Google Services
• Decibel Insights

4. Use of Special Category data

On occasion, you may provide us directly or indirectly, with information about your physical or mental health or situation and talk to us about problems with gambling. We recognise that this is sensitive information and will only use it to provide you with the support you have asked for or to signpost you to appropriate sources of help. We will also share this information with other companies within Rank Group to ensure that you are provided with the appropriate support.

You may indirectly provide us with other sensitive information about yourself such as nationality or ethnicity through the identity verification process. We will only ask for this information where we are required to do so to meet a legal or regulatory requirement and will not use it for any other purpose without your permission.

5. Your consent preferences

From time to time you will be asked if you would like to consent to your information being used for specific purposes, including marketing. Please note that we will continue to send you information about your account and other service messages even if you do not provide consent for marketing.

If you wish to alter your consent preferences at any time you can do so in the My Account section of this site or by contacting us using the details in section 1. It may take us a short time to action these preferences.

6. Sharing your information

We share your Information with third parties only in the ways that are described in this privacy policy. If you would like to find out more about how the third parties listed in this policy use your Information, this should be set out in their respective privacy policies.

We keep your information confidential but may disclose it to our personnel, other companies within the Rank Group, suppliers, or subcontractors insofar as it is reasonably necessary for the purposes set out in this privacy policy. We carry out checks to ensure that the companies we work with will provide the same level of safeguards to protect your data as we do, and we put contractual measures in place to reinforce those obligations.

In addition to the third parties already listed in this policy, examples of the types of third parties we work with are:

• IT companies who support our IT systems;
• Direct Marketing companies that help us deliver our service to you;
• Data insight companies to help us ensure your details are correct and up to date; and
• Third-party sites such as Google and Facebook which might advertise our services.

We may disclose your information where we are required to do so by law. This may include to the police, or other law enforcement agencies, the courts, statutory authorities and sporting bodies (in connection with sporting integrity issues). Where necessary, we will share personal data with our regulators or external legal advisors in order to protect or defend our rights and interests.

If we are involved in a merger, acquisition, or sale of all or a portion of our assets, you will be notified via email, account message and/or a prominent notice on our website of any change in ownership or uses of this information, as well as any choices you may have regarding this information.

We share some of your personal data, including your name, date of birth 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.

We will ensure that we only share your data legally and with due regard to your privacy. Any request from law enforcement or other statutory bodies will only be fulfilled with a warrant, court order or other legally valid proof of authority.

Sending Personal Information outside of the UK or Europe

Some of our providers are based outside or carry out their activities outside of the UK or European Economic Area (EEA). In order to protect your information, unless the country has been deemed to provide an appropriate level of protection for Personal Data by the ICO, we will put in place additional legal protection through the use of standard data protection (model) clauses and other legal mechanisms. This is to ensure that appropriate safeguards are in place to protect your personal data.

7. Your Rights

You have the following rights over the way we process personal data relating to you. We aim to respond without undue delay, and within one month at the latest. To make a request, please see our contact details at section 1.

Ask for a copy of your data and have inaccuracies corrected

You have the right to request a copy of the personal information we hold about you and to have any inaccuracies corrected. We will use reasonable efforts to the extent required by law to supply, correct personal information held about you on our files (and with any third parties to whom it has been disclosed to). If your request is unusually complex and likely to take longer than a month, we will let you know as soon as we can and tell you how long we think it will take.

There are occasional situations where data protection law requires or permits us to withhold some information (such as where it would involve disclosing information about someone else or information that is commercially sensitive), or permits us to charge for the information requested. If these circumstances apply, we will explain this to you.

Object to us processing your data or ask for your data to be deleted

You can ask us to restrict, stop processing, or to delete your personal data if:

• You consented to Rank Group processing the personal data, and have withdrawn that consent;
• Rank Group no longer needs to process that personal data for the reason it was collected;
• Rank Group is processing that personal data because it is in the public interest or it is in order to pursue a legitimate interest of Rank Group, you don’t agree with that processing, and there is no overriding legitimate interest for us to continue processing it;
• The personal data was unlawfully processed; or
• You need the personal data to be deleted in order to comply with a legal obligation.

If we are unable to carry out your request, we will explain it to you. Please be aware that in exercising these rights, you will need to close your account with us and stop using our services. If you are unhappy with our decision on this, you have the right to complain to the ICO.

Obtain a machine-readable copy of your data, which you can use with another service provider

If we are processing data to perform our obligations to you, or because you consented, if that processing is carried out by automated means, we will help you to move, copy or transfer your personal data to other IT systems.

If you request, Rank Group will supply you with the relevant personal data in CSV format. Where it is technically feasible, you can ask us to send this information directly to another IT system provider if you prefer.

Make a complaint to a Supervisory Authority

If you do not agree with the way we have processed your data or responded to your concerns, an alternative is to submit a complaint to a Data Protection Supervisory Authority, which for UK customers is the Information Commissioner’s Office.

8. How long do we keep your information?

We will cease use of your data for marketing purposes no more than two years after your last transaction with us. We typically retain your data for seven years from when our relationship ends to satisfy our regulatory obligations, including anti-money laundering regulations. If we hold any information relating to problem gambling matters or any suspension or termination of your account, we may hold this for a longer period, as we reasonably deem necessary.

9. Use of our service by children

We do not knowingly solicit data from or market to children under the age of 18. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, they should contact us at Information.Centre@rank.com. We will delete such information from our files within a reasonable time.

10.How do we keep your data safe?

We will take all reasonable technical and organisational precautions to prevent the loss or misuse of your personal information. Please be aware that, although we endeavour to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.

11. Changes to this policy

We will notify you of any significant changes to this policy by email, notice on the site or by account message.