This Privacy Notice describes how LC International Limited, ElectraWorks Limited and Martingale Europe Limited ('We', 'Our', 'Us', as appropriate) collects, use, stores, shares or keeps your personal information when you use our services through our website and mobile application. It also describes your data protection rights, including a right to object to some of the processing which We carry out.
Country of Residence
LC International Limited
Suite 6, Atlantic Suites, Europort Avenue, Gibraltar, GX11 1AA
Rest of the World, Canada
LC International Limited, ElectraWorks Limited and Martingale Europe Limited
Suite 6, Atlantic Suites, Europort Avenue, Gibraltar, GX11 1AA
EUROPE UNION and EEA
Martingale Europe Limited
Entain, Unit 6, 120, ST Business Centre, Triq ix-Xatt, Gzira, GZR 1027
- INFORMATION COLLECTED AND MEANS OF COLLECTING
- INFORMATION USE AND LEGAL BASIS
- AUTOMATED DECISION MAKING
- DISCLOSING YOUR PERSONAL INFORMATION
- INTERNATIONAL TRANSFERS
- YOUR RIGHTS
- RETENTION OF PERSONAL INFORMATION
- CHANGES TO OUR PRIVACY NOTICE
- WHO TO CONTACT
1 INFORMATION COLLECTED AND MEANS OF COLLECTING
We collect the following information about you:
1.1 Personal information you provide to us when you use our website or register for an account with us, this may include first and last name, date of birth, credit card information, username and password, proof of age and identity, billing address, home address, email address, phone number or other contact information;
1.2 Technical information about your device and the platform such as administrative and traffic information including but not limited to: source IP address, time of access, date of access, type of devise, web page(s) visited, language use, your location, roaming trace, software crash reports and type of browser used. This information is essential for the provision and quality of the Services.
1.3 Your public profile, including, name, photo and other information you make available to us when you like, post or otherwise interact with our social media pages such as Facebook, Twitter and Google+.
1.4 We keep records of communications when you contact us or otherwise interact with us, including via e-mail, letter, text message (SMS), online, messaging Apps such as WhatsApp and Skype, telephone or live chat function on our Website;
1.5 Other information from third parties databases to comply with our legal and regulatory obligations;
1.6 We may also receive your personal information from online vendors and service providers such as financial and shared liquidity services, and from customer lists lawfully acquired from third-party vendors;
1.7 We may collect additional information about you where you provide such information to us through your use of our services.
2. INFORMATION USE AND LEGAL BASIS
2.1 To provide a requested service or carry out a contract with you:
- Provide customer support and service messages, including messages requesting your feedback on our services and notifying you about changes to our website, services or changes to our terms, conditions and policies.
- To conduct security reviews at any time to validate your identity, age, the registration information provided by you and to verify your use of our services and your financial transactions for potential breach of our General Terms and Conditions and of applicable law. Security reviews may include for example, ordering a credit report and/or otherwise verifying the information you provide against third-party databases.
- To process any of your online transactions and payments (including disclosing your personal information to third party payment processors, ESPs, and other financial institutions as necessary).
2.2 To conduct our business and pursue our legitimate interests:
- To investigate and address enquiries, questions and complaints and respond to any feedback.
- To post in-game activity to your newsfeed and share content with other players which may lead to Loyalty Points, Points or Rewards (such posting of in-game activity can be controlled in your privacy settings).
- To assist your participation in third-party promotions, market research and events.
- Customer telephone and chat conversations may be recorded to allow us to improve the quality of our customer service and our products, train staff and to record what is said in the event of a subsequent complaint.
- Provide you with promotional offers and information where you have indicated or we have inferred an interest in our Products.
- We monitor use of our websites and online services, and use your personal information to help us improve and protect our content, services and websites, both online and offline.
- We use personal information to personalise our website and services for you.
- We monitor customer accounts to prevent the use of unfair practices in our website.
- We use personal information to investigate any complaints received from you or from others, about our websites or our services.
- We may be required to share your data with trusted third parties who provide us with services relevant to our provision our gambling services, including customer support, information security, payments, marketing, data analysis, research and surveys.
- We will use personal information in connection with legal claims, and for compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation).
- We use your personal information in order to build up a profile of your demographics, likely behaviours and preferences. This is used to inform the decisions we make in relation to the services, content and promotions we offer. We also report on the different contribution to our commercial performance from different customer profiles. We create profiles through manual or automated processes, including from third-party providers.
2.3 In accordance with your preferences:
- Subject to your marketing preferences (if applicable) , we will use your personal information to deliver marketing communications which may be of interest across various platforms, such as email, text message (which includes WhatsApp, and Skype instant messenger), telephone, mail post, online, inbox messaging, push notifications or other available channels to provide you with information regarding our products, services and promotions, including other gaming products (such as online poker, casino, betting and bingo services).
- To share your contact details with selected media partners and affiliates for the purposes of them being able to offer their own marketing services to you. We only do this where we have your consent and in line with your marketing preferences.
- To enter you into surveys or promotions you have agreed to.
- We place cookies and use similar technologies in accordance with our Cookies Notice for more information please refers to our Cookie Notice.
- On other occasions where we ask you for your permission, we will use your personal information for the purpose which we explain at that time.
- Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. You can opt-out of this at any time by updating you marketing preference.
2.4 For purposes which are required by law:
- In response to requests by government or law enforcement authorities conducting an investigation.
- Investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law.
3. AUTOMATED DECISION MAKING
We may use automated decision making (i.e. decisions taken without human intervention), including profiling to; create a description of your demographics, past behaviours, likely future behaviours and preferences.
This helps us;
- to provide you the personally targeted content and offers through our platform, and through our marketing communications;
- to provide differential services to customers related to payments and withdrawals, customer service and other operational services; and
- to comply with legal and regulatory regulations, fraud, anti-money laundering and responsible gaming.
If you disagree with the outcome of an automated decision please contact Us using the details in the Rights section and we will review the decision.
4. DISCLOSING YOUR PERSONAL INFORMATION
We may disclose information about you;
- to other companies in the Entain, which includes Entain and its direct and indirect subsidiary companies for internal reasons, primarily for business and operational purposes in line with this privacy notice;
- to third party service providers, who will process it on our behalf for the purposes identified above. Such third parties include providers of website hosting, maintenance, call centre operation, identity checking, information verification services, marketing, data analysis, research and surveys, third-party electronic payment processors and/or financial institutions to process financial transactions and other organisations that provide technical support, process your online transactions and maintain your account;
- with law enforcement and public authorities in order to comply with any legal obligation or where We believe we are under a duty to comply with an obligation.
- with other online gaming sites, banks, credit card companies, and appropriate agencies, where you are found to have cheated or attempted to defraud us or any other user of our services, which may include but not limited to game manipulation, payment fraud, or prohibited transaction (including money laundering); and
- with third parties in the event of sale, purchase of assets, merger, bankruptcy or reorganization proceeding.
- If you are based within the UK, when we check your identity when you first become a customer, or check your financial status as required by our License Conditions, we share information with a Credit Reference Agency and this will leave a “soft” footprint on your credit file. Further information about how this agency holds and uses your information can be found here: https://www.callcredit.co.uk/legal-information/bureau-privacy-notice
5. INTERNATIONAL TRANSFERS
We store your personal information on our servers located in the EEA.
As with any multinational organisation, we are often required to transfer data internationally. Accordingly, data about you may be transferred globally (if your data is collected within the European Economic Area, this means that your data may be transferred outside of it).
Where your personal information is transferred to a country or territory outside the European Economic Area, and where this is to a country that is not subject to an adequacy decision approved by the EU Commission, We will take steps with the aim of ensuring that the privacy of your information continue to be protected. For example, by using third party's Processor Binding Corporate Rules, Intra-group privacy agreements, EU Commission approved standard contractual clauses or verifying that third parties are certified under an approved certification mechanism according to international privacy rules.
6. YOUR RIGHTS
By law, you have a number of rights when it comes to your information. You can exercise any of these rights by contacting us through our contact information below.
- The right to object to processing. You have the right to object to certain types of processing, including processing for direct marketing.
- The right to be informed. You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights.
- The right of access. You have the right to obtain access to your information (if we’re processing it), and certain other information. This right is not an absolute right and must not be interpreted in isolation of the other provisions of the GDPR. There are lawful limitations to this right that it may apply, for instance, where other rights such as; confidentiality, the rights of others, legal privilege and/or the right to apply adversarial disclosure rules in the course of a potential claim or the defence or establishment of a claim are in scope and need to be balanced with the right of access.
- The right to rectification. You are entitled to have your information corrected if it is inaccurate or incomplete. You can request that we rectify any errors in information that we hold.
- The right to erasure. This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information that we hold. This right is not absolute and will not apply when legitimate and overriding reasons apply.
- The right to restrict processing. You have rights to ‘block’ or supress further use of your information. When processing is restricted, we can still store your information, but will not use it further.
- The right to data portability. You have rights to obtain and reuse your information for your own purposes across different services. This is not a general right however and there are exceptions.
- The right to lodge a complaint. You have the right to lodge a complaint about the way we handle or process your information with your national data protection regulator. See contact section above.
- The right to withdraw consent. If you have given your consent to anything we do with your information you can withdraw your consent to the processing of your information at any time.
We understand the importance of information security and the techniques needed to secure information. We use reasonable organisational, technical and administrative measures to protect your personal data from unauthorised access to or unauthorised alteration, disclosure or destruction of information that we hold and we take steps to ensure our subsidiaries, agents, affiliates and suppliers also employ adequate levels of security. In particular;
- Secure Firewalled Datacentres;
- Certified Encrypted Webpages; and
- ISO27001:2013 certified business practices.
8. RETENTION OF PERSONAL INFORMATION
The period for which we may retain data about you will depend on the purposes for which the data was collected, whether you have requested the deletion of the data, and whether any legal obligations require the retention of the data (for example, for regulatory compliance). We will retain data about you for at least as long as is necessary to fulfil the purposes for which the data was collected. Where We process your personal information for marketing purposes or with your consent, We process the personal information until you ask Us to stop and for a short period after this (to allow us to implement Your requests). We also keep a record of the fact that you have asked Us not to send you direct marketing or to process your personal information indefinitely so that We can respect your request in future.
Where We process your personal information for compliance with our legal obligations, We will do so in accordance with all retention periods specified by applicable law.
9. CHANGES TO OUR PRIVACY NOTICE
We may update this notice (and any supplemental privacy notice), from time to time. We will notify you of the changes where required by law to do so. We recommend that you revisit this Privacy Notice regularly.
10. WHO TO CONTACT
ElectraWorks Limited and LC International Limited is registered with the Gibraltar Regulatory Authority (GRA) and Martingale Europe Limited is registered with the Maltese Information and Data Protection Commissioner (IDPC)
If you would like to exercise any of your data protection rights, such as the right of access to your information or data deletion, directly by yourself or by a third party on your behalf, please contact firstname.lastname@example.org (or .de).
If you have any questions about this Notice or would like further information about your rights, our Data Protection Officer can be contacted by emailing: email@example.com.
Questions and comments regarding this privacy notice are welcomed.
*Please note that these channels are not monitored for any customer service-related queries.
Modified/Created November 2022