1. IMPORTANT INFORMATION AND COMPANY INFORMATION
Our full details are:
Paxson Marketing Ltd
6 Louki Akrita
You have the right to lodge a complaint at any time to the regulatory body, the Kahnawake Gaming Commission, using their Central Dispute System (CDS). You can do this from their website here.
However we would appreciate the chance to deal with your concerns and resolve any issues before you approach the Kahnawake Gaming Commission so please contact our support team at firstname.lastname@example.org with any queries in the first instance.
It is important that the personal data we hold about you is accurate and current. We request that you please keep us informed if your personal data changes during your membership with us. If any of your personal details are incorrect, you can update them by sending an email to our support team at email@example.com
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information. This refers any information about an individual from which that person can be identified. Not including data where the identity has been removed. i.e anonymous data.
We may collect, use, store and transfer different kinds of personal data about you which has been grouped together as follows:
• Identity Data which includes: first name, last name, username, title, date of birth and gender.
• Contact Data which includes: address, email address and telephone numbers.
• Financial Data which includes: bank account and payment card details.
• Transaction Data which includes: details about payments to and from you and other details of bets placed and games played.
• Technical Data which includes: internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and other technology on the devices you use to access our website, software or app.
• Profile Data which includes your username and password, preferences and feedback.
• Usage Data which includes information about how you use our website, software or app, bets placed and games played.
• Marketing and Communications Data which includes your preferences in receiving marketing from us and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal any identity information. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature or game.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
SHOULD YOU FAIL TO PROVIDE PERSONAL DATA
Where we are required to collect personal data by law, or under the terms of a contract we have with you and you fail to provide such data as requested, we may not be able to perform the services as expected or fulfill our agreement with you. In such a case, it may be required to terminate your account or cancel a bet you have placed with us. In any such cases you will be notified of this.
3. HOW IS YOUR PERSONAL DATA COLLECTED
We use different methods to collect data from and about you including:
• Direct interactions. You may give us your Identity, Contact and Financial Data by completing forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
1. Place a bet with us or play a game;
2. create an account with us;
3. request marketing materials to be sent to you;
4. or give us some feedback.
• Automated technologies or interactions. As you interact with our website or app, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies (such as Google Analytics). We may also receive Technical Data about you if you visit other websites employing our cookies.
• Third parties or publicly available sources. We may also receive personal data about you from various third parties and publicly available sources and utilize this information for things such carrying out further identification checks to minimize fraud or money laundering risks to the business.
4. 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:
• Performance of contract – the processing of personal data is necessary for the performance of contractual obligations we enter into with you and which you are a party to (i.e. the Terms and Conditions)
• Legitimate interest – when relying on this legal ground, it means that we process your data in the interest of conducting and managing our business to ultimately provide you the best service and experience we possibly could. Before relying on this ground, we ensure that we evaluate the potential impact such processing may have on you and your rights. Therefore, we do not rely on this ground where your rights and interests as a data subject override our interests to process such data;.
• Legal Obligations – Where we need to comply with a legal or regulatory obligation.
• Consent – Where consent is used as a legal basis for processing your data, we only process your data in such a manner for as long as we have your consent to do so. If, at any time, you feel that you no longer wish for us to process your data in such a manner, we will no longer do so. However, this will not affect any processing of personal data that we carried out with your consent prior to the removal of your consent.
We may use identity data and contact data from the registration form when you sign up to send you further information and notifications. No information will be sold, given or in any way transmitted to any external entity, person or business outside our corporation or group of contracted service providers.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out a description of the ways we use your personal data, and which of the legal bases we rely on to do so below. We have also identified what our legitimate interests are where appropriate.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer,||(a) Identity Data||
|to verify your age and to ensure you are not gambling from a restricted country.||(b) Contact Data|
|To process your bet and to enable you to play games including:||(a) Identity||(1) Marketing and Communications|
|(a) Manage payments from you, and pay your winnings||(b) Contact||(2) Performance of a contract with you|
|(b) Collect and recover money owed to us including any fees and charges||(c) Financial||(3) Necessary for our legitimate interests (to recover debts due to us)|
|To manage our relationship with you which will include:||(a) Identity||(1) Marketing and Communications|
|(b) Asking you to leave a review or take a survey.||(c) Profile||(3) Necessary to comply with a legal obligation|
|(c) to enable you to interact with our Customer Care team via email, phone and live chat.||(4) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)|
|To enable you to partake in a prize draw, competition or complete a survey||(a) Identity||(1) Marketing and Communications|
|(b) Contact||(2) Performance of a contract with you|
|(c) Profile||(3) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)|
|To administer and protect our business and the security of our website/app||(a) Identity||(1) Necessary for our legitimate interests (for running our business, provision of administration and IT services, exercise|
|(including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(b) Contact||network security, to prevent fraud and in the context of a business reorganisation or group restructuring )|
|(c) Technical||(2) Necessary to comply with a legal obligation|
|To deliver relevant website/app content and advertisements to you and measure or understand||(a) Identity||(1) Marketing and Communications|
|the effectiveness of the advertising we serve to you||(b) Contact||(2) Technical|
|Necessary for our legitimate interests (to study how customers use our products/services,||(a) Technical||
|to develop them, to grow our business and to inform our marketing strategy)||(b) Usage|
|To use data analytics to improve our website/app, products/services, marketing,|
|customer relationships and experiences|
|Necessary for our legitimate interests (to define types of customers for our products and services,||(a) Identity||
|to keep our website/app updated and relevant, to develop our business and to inform our marketing strategy)||(b) Contact|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||(c) Technical|
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.
We strive to provide you with choices and a personalized online betting experience, so you can receive offers or betting products that are relevant for you, in accordance with your marketing preferences.
You can opt out and unsubscribe and stop receiving personalized offers via email and SMS by clicking the unsubscribe link within each email or SMS that you may receive from us.
PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical, Usage 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 referred to as marketing).
You will receive marketing communications from us if you have requested information from us or purchased a bet or played a game or if you provided us with your details when you created your account with us and in each case have not opted out of receiving marketing materials from us.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes as set out above.
• Other companies in the White Lotus Group acting as joint controllers or processors and who provide customer services, IT and system administration services.
• Fraud prevention agencies used to provide customer due diligence including, money laundering, fraud checks.
• Service providers who provide IT and system administration services.
• Professional advisers, including lawyers, banking institutions and auditors who provide consultancy, banking, legal and accounting services to White Lotus.
• Regulators and other authorities who require reporting of processing activities in certain circumstance.
• Payments providers and related service providers – similarly, we may share some of your personal data with the payment providers you use to make and receive payments on our website;
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.
Credit card or any other financial transaction or information dissemination cannot take place without prior authorization by way of entering usernames and passwords. Our e-commerce partners require specific details to be supplied and confirmed before any financial transactions are processed. They also employ Fraud Prevention departments which ensure the security and integrity of customer's details.
6. INTERNATIONAL TRANSFERS OF DATA
Some processing, Anti Money Laundering or Anti Fraud service providers may be based in countries which do not form part of the European Economic Area (“EEA”). This may mean that your data may be stored in a location outside of the EEA. Whenever any transfers of your personal data are made to Data Processors located outside of the EEA, we always ensure that your data is protected in the same way as it is in the EEA. In order to ensure the protection of your data, we implement at least one of the following safeguards:
a) Adequacy decision – we ensure that we transfer your personal data to countries providing an adequate level of protection according to the European Commission;
b) Standard clauses – where the Data Processor is not based in a country benefiting from an adequacy decision we may use specific contracts, known as standard contract clauses, which are model contracts approved by the European Commission. These contracts also ensure that the personal data is afforded the same protection as it is in the EEA.
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way or altered or disclosed. In addition, we limit access to your personal data to those employees or other parties who have a business need to know. Such individuals will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have stringent measures and procedures in place 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.
8. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized 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 requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for five years after they cease being customers for money laundering purposes.
9. YOUR LEGAL RIGHTS
At any point while we are in possession of or processing your personal data, you have the following rights:
• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. If you still wish to exercise your right to object, we may have to terminate your account or cancel a bet you have placed with us but we will notify you if this is the case at the time.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us verify 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 may take us longer than this 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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