This is Poker Detox Limited’s privacy notice. In this notice, references to “us” “we” and/or “the Company” are references to Poker Detox Limited.
This privacy notice describes how we collect and use personal information about you during and after your working relationship with us, in accordance with the General Data Protection Regulation (“GDPR”) and the Data Protection Act 2004 (the “DPA”). In this privacy notice, references to the “data protection legislation” are references to the DPA and the GDPR.
This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and complete one of our online application forms and tell you about your privacy rights and how the data protection legislation protects you.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Alternatively, you can download a pdf version of the notice here: Poker Detox Privacy Notice. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
1. Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how we collect and process your personal data through your use of this website, or your engagement of our services including any data you may provide through this website when you apply to engage us to provide you with our services. This notice applies to anyone who uses our website (irrespective of whether or not your application for our services is successful).
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements other notices and privacy notices and is not intended to override them.
We are a “controller” for the purposes of the data protection legislation. This means that we are responsible for deciding how we hold and use personal information about you. We are required under the data protection legislation to notify you of the information contained in this privacy notice.
Our contact details are:
Poker Detox Limited
5-9 Main Street
Data Protection Management Team
If you have any questions about this privacy notice or our privacy practices, please contact our data privacy team in the following ways:
Email address: firstname.lastname@example.org
Att: Data Privacy Team
Poker Detox Limited
5-9 Main Street
Our Supervisory Authority
Our supervisory authority is:
The Gibraltar Regulatory Authority
1 Europort Road
Tel: (+350) 20074636
You have the right to make a complaint at any time to the Gibraltar Regulatory Authority (“GRA”), the Gibraltar supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the GRA so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
We keep our privacy notice under regular review. We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. This version was last updated on 27th October 2020.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. Data Protection Principles
The following are the basic principles that set out our core obligations to you as a controller of your personal information. These principles provide that the personal information we hold about you must be:
3. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Special Categories of Personal Data
There are certain types of more sensitive personal data which require a higher level of protection, such as information about a person’s health or sexual orientation – these are Special Categories of Personal Data. Information about criminal convictions also warrants this higher level of protection.
Whilst we do not habitually collect any Special Categories of Personal Data about you, we may occasionally seek to obtain information on any health issues which you have as a means of understanding whether and how it would affect your ability to comply with your obligations with us. We do not collect any information about criminal convictions and offences.
If you fail to provide personal data
You are not obliged to provide us with any personal data. However, where we need to collect personal data by law, or under the application form, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to process your application, perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
4. How is your personal data collected?
We use different methods to collect data from and about you including through:
5. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. In limited circumstances, we may approach you for your written consent to allow us to process certain data. If we do so, we will provide you with full details of the information that we would need and the reason we need it, so that you can carefully consider whether you wish to provide your consent.
You are not obliged to provide consent and it is not a condition of your contract with us that you agree to any request for consent from us. In the event that you do provide your consent to any processing, you may withdraw that consent at any time after that.
You have the right to withdraw consent to at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Please note that this list is not intended to be exhaustive and is subject to change from time to time, in accordance with any changes in our relationship with you or any changes in the law.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer||(a) Identity (b) Contact (c) Financial||(a) legal obligation – complying with customer due diligence protocols. (b) entering into a contract with you for the provision of our services.|
|To provide our services to you:||(a) Identity (b) Contact (c) Financial (d) Transaction (e) Profile||(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)|
|To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy notice; (b) Asking you to leave a review or take a survey; (c) Manage payments, fees and charges; (d) Collect and recover money owed to us; (e) monitoring performance in poker games; and (f) contacting you and correspondence.||(a) Identity (b) Contact (c) Financial (d) Transaction (e) Profile||(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to:|
|To allow us to contact you for research purposes so that we can better understand our services and how they are perceived by our customers. Such communication will be for research only and will not contain any marketing. We will offer you the opportunity to opt-out of future research in any communication we send to you.||(a) Identity (b) Contact (c) Financial (d) Transaction (e) Profile||Necessary for our legitimate interests (to assess the performance of the provision of our own services and how to improve or otherwise change working practices with a view to providing such services to all customers).|
|Preparation of accounts and financial reporting.||(a) Transaction||(a) Necessary to comply with a legal obligation|
|Preparation and publication of promotional material e.g. where a customer wins a poker game as a result of the services provided by us to the customer (not direct marketing). Nothing will not be published without your prior consent.||(a) Identity (b) Transaction (c) Profile||(a) Necessary for our legitimate interests (to promote the services provided by us by way of business) (b) Consent|
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity (b) Contact (c) Technical||(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation|
We may use your Identity, Contact, Technical and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you. You may receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
You can ask us to stop sending you marketing messages at any time by logging into our website and checking or unchecking relevant boxes to adjust your marketing preferences.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by data protection legislation.
6. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table (Purposes for which we will use your personal data) above.
Such third parties can include (please note that this list is not exhaustive):
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
7. International transfers
We share your personal data with third parties that are based outside of the European Economic Area (EEA).
In circumstances where we do transfer your personal data outside of the EEA, we will ensure that a similar degree of protection is afforded to your personal data by ensuring that at least one of the following safeguards are in place:
The type of safeguard will vary in respect of each transfer outside of the EEA (if any) and the appropriate measure will be considered on a case by case basis.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
8. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
We operate a base retention period of 7 years following the termination of our contract with you. However, we may also consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements for exceptional circumstances.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
10. Your legal rights
Under certain circumstances, by law you have the right to:
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a fee if your request for access is clearly unfounded or excessive. In such circumstances we will inform you and provide details of the costs that are envisaged before proceeding to incur the fees. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
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