PRIVACY POLICY

This Privacy Policy Governs the Lucky Pants Bingo.com Website (“the Site”).

We have created this privacy and cookies policy to inform you how the Group (as defined below) manages, collects and uses your information through your use of the Site ("Privacy Policy"). This Privacy Policy explains how We collect your personal information on the Site, how We use and protect such information, our processing of and your choices concerning the use of such information. Please read this Privacy Policy carefully. For the purposes of this Privacy Policy, “We”, “Us” and “Our” means The Group.

1. ABOUT THE GROUP

1.1  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 as ‘Platforms’)

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

1.2 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 on a regular basis. 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.

1.3 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.

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

2.COLLECTION OF PERSONAL INFORMATION FROM YOU OR ABOUT YOU. 

2.1 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, e-mail address, address or telephone number, IP Address, copies of ID, proof of address, etc (“Personal Information”).

We collect the below types of Personal Information:

Information We Collect Directly from You.

Registration Details: you will be asked to provide us certain 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 credit card number (first 6 and last 4 digits) and bank account details.

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.

2.2 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:

2.2.1 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: 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 geo-location data (to comply with our anti money laundering policy). We use Google Analytics and comply with the Google Analytics Terms of Service and are subject to the Google Analytics Policies.

2.2.2 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.

2.2.3 Information We Collect About You From Other Sources: We may collect Personal Information about from other sources (e.g. third party service providers), such as information about your credit history from credit agencies and other financial information (but We do not collect your full credit card information) which is relevant to the provision of Our products and services as well as information which is gathered in order to verify your identity and prevent fraudulent or illegal activity.

3.COOKIES

3.1 Cookies are small pieces of data that sit on your computer that remember what you enter while you're browsing a website. We use cookies to help us customise your experience to show you the most relevant information when you return to Our Site.

3.2 Our Cookies 

We use the following types of cookies:

Strictly Necessary Cookies. These are cookies that are required for the operation of Our Site and under Our terms with you. They include, for example, cookies that enable you to log into secure areas of Our Site, use a shopping cart or make use of e-billing services.

Analytical/Performance Cookies. They allow us to recognise and count the number of visitors and to see how visitors move around Our Site when they are using it. This helps us for Our legitimate interests of improving the way Our Site works, for example, by ensuring that users are finding what they are looking for easily.

Functionality Cookies. These are used to recognise you when you return to Our Site. This enables us, subject to your choices and preferences, to personalise Our content, greet you by name and remember your preferences (for example, your choice of language or region).

Targeting/Advertising Cookies. These cookies record your visit to Our Site, the pages you have visited and the links you have followed. We will use this information subject to your choices and preferences to make Our Site and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

3.3 We may also work with advertising networks that gather information about the content on Our Site you visit and on information on other websites and services you visit. This may result in you seeing advertisements on/or through Our Site or Our advertisements when you visit other websites and services of third parties which we believe may be of interest to you. For more information about how to turn this feature off see below or visit http://www.youronlinechoices.com/uk/

3.4 Disabling Cookies

The effect of disabling cookies depends on which cookies you disable but, in general, the website may not operate properly if all cookies are switched off.  If you only disable third party cookies, you will not be prevented from making purchases on Our Site. If you disable all cookies, you will be unable to complete a purchase on Our Site.

3.5 If you want to disable cookies on Our Site, you need to change your website browser settings to reject cookies. How you can do this will depend on the browser you use.  Further details on how to disable cookies for the most popular browsers are set out below:

For Microsoft Internet Explorer:

1. Choose the menu “tools” then “Internet Options”
2. Click on the “privacy” tab
3. Select the setting the appropriate setting

For Google Chrome:

1. Choose Settings> Advanced
2. Under "Privacy and security," click “Content settings”.
3. Click “Cookies”

For Safari:

1. Choose Preferences > Privacy
2. Click on “Remove all Website Data”

For Mozilla Firefox:

1. Choose the menu “tools” then “Options”
2. Click on the icon “privacy”
3. Find the menu “cookie” and select the relevant options

For Opera 6.0 and Further:

1. Choose the menu Files”> “Preferences”
2. Privacy

3.6 Where you have not set your permissions, We may also separately prompt you regarding Our use of cookies on the Site. You can find more information about the individual cookies We use and the purposes for which We use them in the below table:

3.7 We use cookies to:

• Monitor traffic on the Site
• To obtain information for analysis purposes
• To better understand your preferences
• To offer with personalised advertising when you access the Site.

Some of the cookies used by the Site are set by us, hence third-party companies or advertisers may monitor and analyse your web access on Our behalf.

3.8 Most web and mobile device browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. You can also learn more about cookies by visiting www.allaboutcookies.org which includes additional useful information on cookies and how to block cookies using different types of browser or mobile device. Please note, however, that by blocking or deleting cookies used on the Site, you may not be able to take full advantage of the Site. 

4.PIXELS

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

5.USE OF INFORMATION COLLECTED

5.1 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 detect and prevent fraudulent activities
• As required by law, regulation or other governmental authority; 

5.2 We may also use other type of information for the purposes of monitoring Site usage in order to help us develop Our Site and the services and for these purposes.

6.DATA SHARING

6.1 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 

6.2 We may share your personal information with the below parties: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.
• 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.

7.DATA TRANSFERS

7.1 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.7.2 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.

8.DATA SECURITY

8.1 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.8.2 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.8.3 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.8.4 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

8.5 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.

9.PUBLIC FORMS

9.1 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.

10.CHILD SAFETY

10.1 Protecting the safety of children when they use the Internet is important to us.10.2 The Site is intended for use only by persons who are at least 18 years of age.10.3 By using the Site, you confirm to us that you meet this requirement.

11.UPDATES OR AMENDMENTS TO THE PRIVACY POLICY

11.1 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, in relation to substantive changes, will be notified to you by e-mail. 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 4 October 2019.

12.HOW TO CONTACT LUCKYPANTSBINGO.COM

12.1 We welcome your views about the Site and Our Privacy Policy. If you would like to contact Us with any queries or comments please send an e-mail ([email protected]) to Our customer services department or give us a call on 0808 238 6070 or via the live chat.

13.HOW LONG WE KEEP YOUR INFORMATION

13.1 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. 

14.YOUR RIGHTS

14.1 You can ask us: (a) 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; (b) To correct or erase your Personal Information where appropriate; (c) To restrict the processing of your Personal Information whilst We investigate your concern; (d) To object to direct marketing or in certain cases object more generally; (e) 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); (f) To withdraw your consent at any time when the processing relies upon consent.14.2 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)