- Who are we
- The information we collect about you
- How we use your personal data
- Who we may pass your data on to
- Location that we may transfer your personal data to
- The use of IESNARE Technology
- Your rights
- How to contact us / Our Data Protection Officer
- Business Partners (Inc, Partners & Sole Traders)
- Changes to this Policy
Who are we
Ladbrokes Betting and Gaming Limited is a member of GVC Group of companies and is committed to protecting your privacy.
This policy explains what your personal data will be used for.
Where we use the term “we” or “us”, this includes the entity mentioned about and other companies within the GVC group - some of which have multiple “brands”1.
We are committed to protecting your personal data and take the security of your information very seriously. We have strict security measures in place to protect your personal data which includes robust security procedures which are regularly tested and reviewed. If you have any concerns about the way in which we process or protect your personal data or would like to contact us about any aspect of this policy, please get in touch through the contact details at the bottom of this statement.
The Information we collect about you
We will collect personal data about you from the following sources:
- When you visit us in our betting shops
- When you visit our website or our social media sites
- Through surveys you complete
- When you communicate with us (by email, mail, phone, in store or through social media)
- When we undertake analysis of your interaction with us
- From public sources of information such as public records or social media postings
- From cookies and tracking devices on your devices where you have permitted their use.
We will collect the following types of information:
|Type of Data||Description|
|Your personal and contact details||Such as your name, home or email address, telephone number or online identity|
|Account information||Such as information about your account with us, including your login details for our websites and mobile applications, age, gender, date of birth, unique account number, unique customer identification, marketing preferences, complaints details and notes added to your account|
|Visual Images||Such as photographs or CCTV recordings and records of shops you have visited visits|
|Financial information||Such as information that allows us to understand your creditworthiness and financial position or your bank account or payment card details|
|Transactions, bets and account history||Such as records relating to the products and services which you have purchased or used|
|Lifestyle and demographic insight information||Such as how you use our services and other information about your demography, your preferences and habits|
|Responses to surveys, competitions and promotions||Such as records of any surveys you respond to or your entry into any competitions we run|
|Records of your discussions with our customer services teams,||Including call recordings, webchat and emails. Such as when you share comments and opinions with us, ask us questions or make a complaint|
|How you use mobile applications and websites||We use technology such as cookies (subject to your cookie preferences) when you use our applications or websites, we collect information about the pages you look at and how you use them|
|Location information||Your smartphone or computer's IP address may tell us an approximate location when you connect to our websites but this will be no more precise than the city, state or country you are using your device in|
|Device and machine information||Such as information about the computer hardware and software on your computers and smartphones that is used to connect or communicate with us|
|Advertising and direct marketing preferences and responses||Such as information about how you respond, or interact with, any direct marketing or advertising communications directed to you, including any requests for these communications to stop.|
|Nom-de-plume:||We may hold a physical description or profile of you where your personal details are unknown to us to help us meet our regulatory obligations and business initiatives|
Much of the information we collect about you is required to meet our legal and regulatory obligations, however, where we ask for your consent to process your personal data, you are not required to provide it, however, if you do not do so, you may not be able to take advantage of our services.
We may also store more sensitive personal data about you (often referred to as “special categories of personal data”) which may come directly from you, from other sources as described above or from decisions we have made about you:
|Type of Data||Description|
|Heath Information||Information about a gambling addiction or specific vulnerability or disability|
|Biometric data||Derived from your image (e.g. photography or CCTV image)|
|Offences or suspected Offences||Where we know or suspect a fraud or theft or other offence|
This personal data is required to ensure we meet our legal obligations or for the prevention or detection of crime.
How we use your personal data
We will use your personal data for the following reasons
|What we use your personal data for||How we justify the use of your personal data|
|To meet our obligations arising from any agreements entered into between you and us and provide you with the information, products and services that you request from us||We need to process this data to meet our contractual obligations|
|To provide you with customer services, answer your questions or address your complaints or concerns.||We need to process this data to meet our contractual obligations|
To discharge our legal and regulatory obligations and duties which include (but are not limited to) Gambling, Anti-money Laundering, Anti-fraud & Anti-terrorism laws.
|We need to process this data to meet our legal and regulatory obligations|
To meet our Social Gambling obligations (such as recording self-excluders and where we believe a customer has a gambling problem).
|We need to process this data to meet our legal and regulatory obligations|
|To check your or validate your identity and protect your information||We need to process this data to meet our contractual obligations|
To invite you to take part in competitions or take up promotions or to keep you informed about products of services which may be of interest to you.
To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.
You may opt out of receiving direct marketing communications at any time.
This is in our legitimate business interest to engage with you in this way and measure that such communications are relevant to you.
We may also ask for your consent to share your information with 3rd parties for marketing purposes
|To build a profile of you, your preferences and your habits to better understand your interests.||It is in our legitimate business interest to better understand your needs and interests|
|To ensure that content from the site is presented in the most effective manner for you and for your computer, maintain and improve our products and services, optimise business processes, quality assurance purposes, support efficient management of our staff, analyse performance of webpages and provide relevant content to you||It is in our legitimate business interest to ensure our business operates efficiently and that our websites content is relevant to our customers|
To prevent or detect fraud, theft or loss to our business and our customers
To protect our staff and other individuals from harm or loss
We need to process this data to meet our legal and regulatory obligations
In addition it is in our legitimate business interest to protect ourselves from loss
|To exercise or defend legal claims or acquiring or selling a business||it is in our legitimate business interest to protect ourselves by exercising our legal rights, defending against claims and acquiring or selling parts of our business|
Who we may pass your data on to
We may need to share personal information with other organisations to ensure that we meet our legal obligations or where we need support in meeting your needs or our contractual obligations. These other parties are typically:
- business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
- our affiliates and selected third parties, where you have expressly opted-out of receiving marketing from us / third parties, have been barred or self-excluded, in which case we may share suppression lists with our affiliates and selected third parties, to ensure you do not receive unsolicited marketing;
- members of the GVC Group and third party suppliers and service providers for the purposes identified above;
- third party suppliers and service providers to the extent they assist the GVC Group with its legal / regulatory obligations e.g. providers of services in respect of anti-money laundering, fraud, verification etc.;
- selected third parties so that they can contact you with details of the services that they provide, where you have expressly opted-in/consented to the disclosure of your personal data for these purposes;
- analytics and search engine providers that assist us in the improvement and optimization of our site and other selected third parties;
- other gambling operators, banks, credit card companies, ESP's (defined below) and appropriate agencies for the purpose of investigating and safeguarding against underage, fraudulent, criminal or suspicious activity (or other activities we are bound by law, regulation or guidance to investigate and safeguard against) or if we have reason to believe that you have undertaken such activity; and
- our regulators, law enforcement or fraud prevention agencies, as well as our legal advisers, courts, applicable independent adjudication services, sports' governing bodies and betting integrity organisations and any other authorised bodies, for the purposes of investigating any actual or suspected criminal activity or other regulatory or legal matters
We may share your personal information with other members of the GVC Group for marketing purposes. We will not share it with other 3rd party organisations however unless you have expressly opted-in/consented to the disclosure of your personal data for these purposes.
We may also disclose your personal information to third parties in the following circumstances:
- in the event that we consider selling or buying any business or assets, in which case we will disclose your personal data to any prospective sellers or buyers of such business or assets;
- in the event of any insolvency situation (e.g. the administration or liquidation) of GVC Group plc, or a data controller or any of its group entities;
- if we, or substantially all of our assets, are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;
- to protect the rights, property, or safety of us, our staff, our customers, or others. This includes exchanging information with other companies and organisations (including without limitation, other gambling operators and the local police or other local law enforcement agencies) for the purposes of staff and customer safety, crime prevention, fraud protection and credit risk reduction;
- if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or regulatory requirements, or otherwise for the prevention or detection of fraud or crime; and
- Where you have self-excluded yourself from gambling, we may share this information with our regulators or other companies in our field where we believe it is important to support your exclusion
How long we retain your personal data
|Type of Data||Typical Retention Time||Information|
|Marketing consents||24 months||Unless consent is refreshed|
|Customer Call recordings||9 months||An extended retention may be applied on a case by case basis|
|CCTV||3 months||An extended retention may be applied on a case by case basis|
|Business Contacts||At end of business relationship|
|Customer Data||A seven year retention period which starts to run from the date your account is closed||We will only continue to hold personal data relating to your account as permitted under data protection legislation (i) where we are under a legal requirement under gambling or tax legislation to retain your data; and (ii) to exercise or defend our legal rights|
The above retention times may be extended for example where it is needed to meet a specific regulatory obligation, investigate a crime, handle a claim or resolve a complaint
Locations that we may transfer your personal data
From time to time, service providers, members of the GVC Group and organisations with whom we work, may be located outside the European Economic Area in countries that do not have the same standards of protection for personal data as the UK. We will, however, always use every reasonable effort to ensure sufficient protections are in place to safeguard your personal data. We will also ensure that our service providers enter into compliant processing agreements with us to ensure that your personal data is processed in accordance with applicable data protection legislation.
We implement technical and organisational measures which take into account the harm that may be suffered, to protect your personal data. All information you provide to us is stored on our secure servers. 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.
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.
Marketing Communications and your choices
When we first collect your personal data we’ll ask you to tell us how you would like to hear from us in future about our other products and services. It’ will normally be via a tick boxes on forms or web page and you can change your mind at any time through “unsubscribing” or changing your preferences on your account settings.
|DESCRIPTION OF RIGHT|
|Right 1||A right to access personal data held by us about you.|
|Right 2||A right to require us to rectify any inaccurate personal data held by us about you.|
|Right 3||A right to require us to erase personal data held by us about you. This right will only apply where (for example): we no longer need to use the personal data to achieve the purpose we collected it for; or where you withdraw your consent if we are using your personal data based on your consent; or where you object to the way we process your data (in line with Right 6 below).|
|Right 4||In certain circumstances, a right to restrict our processing of personal data held by us about you. This right will only apply where (for example): you dispute the accuracy of the personal data held by us; or where you would have the right to require us to erase the personal data but would prefer that our processing is restricted instead; or where we no longer need to use the personal data to achieve the purpose we collected it for, but you require the data for the purposes of dealing with legal claims.|
|Right 5||In certain circumstances, a right to receive personal data, which you have provided to us, in a structured, commonly used and machine readable format. You also have the right to require us to transfer this personal data to another organisation, at your request.|
|Right 6||A right to object to our processing of personal data held by us about you where the processing of such data is necessary for the purposes of our legitimate interests, unless we are able to demonstrate, on balance, legitimate grounds for continuing to process personal data which override your rights or which are for the establishment, exercise or defence of legal claims.|
|Right 7||A right for you not to be subject to a decision based solely on an automated process, including profiling, which produces legal effects concerning you or similarly significantly affect you.|
|Right 8||A right to withdraw your consent, where we are relying on it to use your personal data (for example, to provide you with marketing information about our services or products).|
|Right 9||You have the right to complain to the relevant Data Protection Supervisory Authority. In the UK, this is the Information Commissioner’s Office.|
Contact Us or Our Data Protection Officer
If you have any questions about this notice or would like further information about your rights, please contact our Data Protection Officer be emailing firstname.lastname@example.org.
This policy was last reviewed and updated: September 2018