How your personal information is used by Small Screen Casinos Ltd and its brands.

Your information will be held by Small Screen Casinos Limited (“SSC”). The full list of licensed UK brands is available on the Gambling Commission Website. The full list of international licensed brands is available on the Alderney Gambling Control Commissions website

How we use your personal information

This privacy notice is to let you know how brands within SSC promise to look after your personal information. This includes what you tell us about yourself, what we learn by having you as a customer, and the choices you give us about what marketing you want us to send you.

This notice explains how we do this and tells you about your privacy rights and how the law protects you.

Our Privacy Promise

We promise:

• To keep your data safe and private;
• Not to sell your data; and
• To give you ways to manage and review your marketing choices at any time.

If you have any questions or want more details about how we use your personal information, you can ask us. See contact us for all the options.

How the law protects you

As well as our Privacy Policy, your privacy is protected by law. This section explains how that works.

Data Protection law says that we are allowed to use personal information only if we have a proper reason to do so. This includes sharing it outside of SSC.

The law says we must have one or more of these reasons:

• To fulfil a contract we have with you, or
• When it is our legal duty, or
• When it is in our legitimate interest, or
• When you consent to it.

A legitimate interest is when we have a business or commercial reason to use your information. But even then, it must not unfairly go againstwhat is right and best for you. If we rely on our legitimate interest, we will tell you what that is.

Here is a list of all the ways that we may use your personal information, and which of the reasons we rely on to do so.This is also where we tell you what our legitimate interests are.

What we use your personal information for	Our reasons	Our legitimate interests
To manage our relationship with you. To develop new ways to meet our customers’ needs and to grow our business. To develop and carry out marketing activities. To study how our customers, use products and services from us and other organisations. To provide advice or guidance about our products and services and external help groups	Your consent. Fulfilling contracts. Our legitimate interests. Our legal duty.	Keeping our records up to date, working out which of our products and services may interest you and telling you about them. Developing products and services, and marketing them to you. Defining types of customers for new products or services. Seeking your consent when we need it to contact you. Being efficient about how we fulfil our legal duties.
To develop and manage our brands, products and services. To test new products. To manage how we work with other companies that provide services to us and our customers.	Fulfilling contracts. Our legitimate interests. Our legal duty.	Developing products and services, and marketing them to you. Defining types of customers for new products or services. Being efficient about how we fulfil our legal, regulatory and contractual duties.
To deliver of our products and services. To make and manage customer deposits and payments. To manage customer accounts.	Fulfilling contracts. Our legitimate interests. Our legal duty.	Being efficient about how we fulfil our legal, regulatory and contractual duties. Complying with regulations that apply to us.
To detect, investigate, report, and seek to prevent the proceeds of crime entering our business and the industry. To manage risk for us and our customers. To obey laws and regulations that apply to us. To respond to complaints and seek to resolve them.	Fulfilling contracts. Our legitimate interests. Our legal duty.	Developing and improving how we deal with financial crime, as well as doing our legal duties in this respect. Complying with regulations that apply to us. Being efficient about how we fulfil our legal, regulatory and contractual duties.
To run our business in an efficient and proper way. This includes managing our financial position, business capability, planning, communications, corporate governance, and audit.	Our legitimate interests. Our legal duty.	Complying with regulations that apply to us. Being efficient about how we fulfil our legal, regulatory and contractual duties.
To exercise our rights set out in agreements or contracts.	Fulfilling contracts.	Complying with contractual duties.

Groups of Personal Information

We use many kinds of personal information, and group them together like this.

Type	Group
Financial	Your financial position, source of funds and wealth, status and history.
Contact	Where you live and how to contact you.
Socio-Demographic	This includes details about your work or profession, nationality, education and where you fit into general social or income groupings.
Transactional	Details about payments and deposits to and from your accounts with us, and queries / complaints you make.
Contractual	Details about the products or services we provide to you.
Locational	Data we get about where you are, such as may come from your mobile phone, the address where you connect a computer to the internet or with your card or other deposit mechanism.
Behavioural	Details about how you use our products and services.
Technical	Details on the devices and technology you use.
Communications	What we learn about you from letters, emails, and conversations between us.
Social Relationships	Your family, friends, and other relationships.
Open Data and Public Records	Details about you that are in public records such as (but not exclusively), the Electoral Register, and information about you that is openly available on the internet.
Usage Data	Other data about how you use our products and services.
Documentary Data	Details about you that are stored in documents in different formats, or copies of them. This could include things like your passport, drivers licence, or other identification documents requested from time to time.

Special types of data

The law and other regulations treat some types of personal information as special. We will only collect and use these types of data if the law allows us to do so:

• Racial or ethnic origin;
• Religious or philosophical beliefs;
• Trade union membership;
• Genetic and bio-metric data;
• Health data including gender; and
• Criminal convictions and offences.

Consents

Any permissions, consents, or preferences that you give us. This includes things like how you want us to contact you.

National Identifier

A number or code given to you by a government to identify who you are, such as a National Insurance number.

Where we collect personal information from

We collect information about you when you engage with our website, customer services or use our applications. We only collect information which is necessary, relevant and adequate for the purpose you are providing it for. Some of this information does not identify you personally but provides us with information about how you use our services and engage with us (we use this information to improve our services and make them more useful to you). The information we collect includes some or all of the following:

1. Name (including title);
2. Address;
3. Phone number;
4. Date of birth;
5. Email address;
6. The date and time you used our services;
7. The pages you visited on our website and how long you visited us for;
8. Your IP address;
9. Your GPS location (where you have permitted access to this);
10. The internet browser and devices you are using;
11. Cookie, Pixels or Beacon information (for more information please see our cookie policy);
12. The website address from which you accessed our website;
13. Details of any transactions between you and us as well as Source of Income or Source of Wealth information;
14. Where you engage with us in a business context, we may collect your job title, company contact details (including email addresses), and company details (some of which we may obtain from an online or public business directories);
15. “Live chat” records; and
16. Any information within correspondence you send to us.

Data from third parties we work with:

• Companies that introduce you to us;
• Financial advisers;
• Card associations;
• Credit reference agencies;
• Insurers;
• Merchants and or banks and banking institutions;
• GamStop website;
• Social networks and social media;
• Fraud prevention agencies;
• Payroll service providers;
• Land agents;
• Public information sources such as Companies House;
• Loyalty scheme operators;
• Agents and affiliates working on our behalf;
• Market researchers;
• Government, law enforcement and other regulatory agencies.

Who we share your personal information with

We may share your personal information with companies and brands within the Small Screen Casinos Group and these organisations:

• Agents, advisers and specific companies (i.e. banks, customer services and technical developers) who we use to help run your account and our services, collect and pay what you have deposited and what we owe you, respectively, and explore new ways of doing business;
• HM Revenue & Customs, regulators and other authorities;
• IBAS and any other relevant arbitration or customer resolution scheme / authority, as advised;
• Credit reference agencies;
• Fraud prevention agencies;
• Companies we have a joint venture or agreement to co-operate with;
• Organisations that introduce you to us;
• Companies that we introduce you to;
• Companies that offer ways to Identify you and those connected to you as well as and those that allow us to increase deposit / withdrawal limits for you;
• Companies you ask us to share your data with.

We may need to share your personal information with other organisations to provide you with the product or service you have chosen:

• If you have a debit, credit or charge card registered with us, we will share transaction details with companies which help us to provide this service (such as Visa and Mastercard);
• If you use a product which has a loyalty, jackpot or refer a friend element, we will share your data with those parties;
• If you use bank transfers, we will share your data with the banking providers;
• If you make a complaint, information you give to us or the complaint resolution provider may be put on a register of complaints. This will be shared with other related businesses.

We may also share your personal information if the make-up of Small Screen Casinos changes in the future:

• We may choose to sell, transfer, or merge parts of our business, or our assets. Or we may seek to acquire other businesses or merge with them.
• During any such process, we may share your data with other parties. We’ll only do this if they agree to keep your data safe and private.
• If the change to our Group happens, then other parties may use your data in the same way as set out in this notice.

How we use your information to make automated decisions

We sometimes use systems to make automated decisions based on personal information we have – or are allowed to collect from others – about you. This helps us to make sure our decisions are quick, fair, efficient and correct, based on what we know. These automated decisions can affect the products, services or features we may offer you now or in the future, or the restrictions and limits that apply to your account.

Here are the types of automated decisions we make:

Opening new accounts

When you register / create an account with us, we check that the product or service is relevant for you, based on what we know. We also check that you meet the conditions needed to open the account. This may include checking age, residency, nationality, political status or financial position.

Limits and restrictions

We may decide to impose limits or restrictions for some products and services based on what we know.

Tailoring products and services

We may place you in groups with similar customers. These are called customer segments. We use these to study and learn about our customers’ needs, and to make decisions based on what we learn. This helps us to design products and services for different customer segments, and to manage our relationships with them.

Detecting fraud and risk assessment

We use your personal information to help create a risk profile and decide if your account may be being used for fraud or money-laundering. We may detect that an account is being used in ways that fraudsters work. Or we may notice that an account is being used in a way that is unusual for you or our business relationship. If we think there is a risk of fraud, we may stop activity on the accounts or refuse access to them.

Risk profiling as well as limit and restriction setting uses data from these sources:

• Your application form,
• Source of funds and wealth;
• Credit reference agencies;
• Data we may already hold.

It gives an overall assessment. We use this to help us make responsible gaming decisions that are fair and informed and relevant to you.

Credit scoring methods are tested regularly to make sure they are fair and unbiased.

Your rights

As a person you have rights over automated decisions.

• You can ask that we do not make our decision based on the automated profiling / assessment alone.
• You can object to an automated decision and ask that a more senior person reviews it.

We carry out credit and identity checks when you register an account. We may use Credit Reference Agencies (“CRAs”) to help us with this.

If you use our services, from time to time we may also search information that the CRAs have, to help us manage those accounts.

We will share your personal information with CRAs and they will give us information about you. The data we exchange can include:

• Name, address and date of birth
• Credit application
• Financial situation and history
• Public information, from sources such as the electoral register and Companies House.

We’ll use this data to:

• Assess whether you are able to afford to gamble;
• Make sure what you’ve told us is true and correct;
• Help detect and prevent financial crime;
• Manage accounts with us;
• Trace and recover debts in the case of frauds; and
• Make sure that we tell you about relevant offers.

We will go on sharing your personal information with CRAs for as long as you are a customer.

When we ask CRAs about you, they may note it on your credit file. This is called a credit search.

We use CRAs to prevent duplicate accounts being opened and to comply with our regulatory requirements.

You can find out more about the CRAs on their websites, in the Credit Reference Agency Information Notice. This includes details about:

• Who they are
• Their role as fraud prevention agencies
• The data they hold and how they use it
• How they share personal information
• How long they can keep data
• Your data protection rights.

Here are links to the information notice for each of the three main Credit Reference Agencies:

• Callcredit
• Equifax
• Experian

Fraud Prevention Agencies (FPAs)

We may need to confirm your identity before we provide you with access to our products or services. Once you have registered as a customer of ours, we will also share your personal information as needed to help detect fraud and money-laundering risks. We use Fraud Prevention Agencies to help us with this.

Both we and fraud prevention agencies can only use your personal information if we have a proper reason to do so. It must be needed either for us to obey the law, or for a ‘legitimate interest’.

A legitimate interest is when we have a business or commercial reason to use your information. This must not unfairly go against what is right and best for.

We will use the information to:

• Confirm identities
• Help prevent fraud and money-laundering
• Fulfil any contracts you or your business has with us.

We or an FPA may allow law enforcement agencies to access your personal information. This is to support their duty to detect, investigate, prevent and prosecute crime.

FPAs can keep personal information for different lengths of time. They can keep your data for up to six years if they find a risk of fraud or money-laundering.

If you choose not to give personal information

We may need to collect personal information by law, or under the terms of a contract we have with you.

If you choose not to give us this personal information, it may delay or prevent us from meeting our obligations. It may also mean that we cannot register your account and therefore cancel a product or service you have with us.

Any data collection that is optional would be made clear at the point of collection.

Marketing

We may use your personal information to tell you about relevant products and offers that are fun (play for free), gambling, skill gaming or casino, sports and lotto related. This is what we mean when we talk about ‘marketing’.

The personal information we have for you is made up of what you tell us, and data we collect when you use our services, or from third parties we work with.

We study this 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.

We can only use your personal information to send you marketing messages if we have either your "consent" (through an opt-in) or a ‘legitimate interest’. That is when we have a business or commercial reason to use your information. It must not unfairly go against what is right and best for you.

You can ask us to stop sending you marketing messages by contacting us at any time.

Whatever you choose, you can still access your account, and other important information such as your account information and data as well as existing products and services.

We may ask you to confirm or update your choices, if you use any new products or services with us in future. We will also ask you to do this if there are changes in the law, regulation, or the structure of our business.

If you change your mind you can update your choices at any time by contacting us.

How long we keep your personal information

We will keep your personal information for as long as you are a customer of SSC and its brands.

After you stop being a customer, we may keep your data for up to 6 years for one of these reasons:

• To respond to any questions or complaints.
• To show that we treated you fairly.
• To maintain records according to rules that apply to us.
• To establish, bring or defend legal claims.

The only exceptions to the periods mentioned above are where:

• the law requires us to hold your personal information for a longer period, or delete it sooner;
• Where you have raised a complaint or concern regarding a product or service offered by us, in which case we will retain your information for a period of 6 years following the date of that complaint or query; or you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law

How to get a copy of your personal information

You can access your personal information we hold contacting [email protected]

Letting us know if your personal information is incorrect

You have the right to question any information we have about you that you think is wrong or incomplete. Please contact us if you want to do this.

If you do, we will take reasonable steps to check its accuracy and correct it.

What if you want us to stop using your personal information?

You have the right to object to our use of your personal information, or to ask us to delete, remove, or stop using your personal information if there is no need for us to keep it. This is known as the ‘right to object’ and ‘right to erasure’, or the ‘right to be forgotten’.

There may be legal or other official reasons why we need to keep or use your data. But please tell us if you think that we should not be using it.

We may sometimes be able to restrict the use of your data. This means that it can only be used for certain things, such as legal claims or to exercise legal rights. In this situation, we would not use or share your information in other ways while it is restricted.

You can ask us to restrict the use of your personal information if:

• It is not accurate.
• It has been used unlawfully but you don’t want us to delete it.
• It not relevant any more, but you want us to keep it for use in legal claims.
• You have already asked us to stop using your data, but you are waiting for us to tell you if we are allowed to keep on using it.

If you want to object to how we use your data or ask us to delete it or restrict how we use it or, please contact us.

How to withdraw your consent

You can withdraw your consent at any time. Please contact us if you want to do so.

If you withdraw your consent, we may not be able to provide certain products or services to you. If this is so, we will tell you.

How to complain

Please let us know if you are unhappy with how we have used your personal information. Please contact support.

You also have the right to complain to the Information Commissioner’s Office. Find out on their website how to report a concern.

Cookies

Most websites you visit will use cookies in order to improve your user experience by enabling that website to "remember" you, either for the duration of your visit (using a "session cookie") or for repeat visits (using a "persistent cookie").

Cookies do lots of different jobs, like letting you navigate between pages efficiently, storing your preferences, and generally improving your experience of a website.

Cookies make the interaction between you and the website faster and easier. If a website doesn"t use cookies, it will think you are a new visitor every time you move to a new page on the site - for example, when you enter your login details and move to another page it won"t recognise you and it won"t be able to keep you logged in. Some websites will also use cookies to enable them to target their advertising or marketing messages based for example, on your location and/or browsing habits.

Cookies may be set by the website you are visiting ("first party cookies") or they may be set by other websites who run content on the page you are viewing ("third party cookies").

What is in a Cookie?

A cookie is a simple text file that is stored on your computer or mobile device by a website"s server and only that server will be able to retrieve or read the contents of that cookie. Each cookie is unique to your web browser. It will contain some anonymous information such as a unique identifier and the site name and some digits and numbers. It allows a website to remember things like your preferences or what"s in your shopping basket.

What to do if you don"t want cookies to be set Some people find the idea of a website storing information on their computer or mobile device a bit intrusive, particularly when this information is stored and used by a third party without them knowing. Although this is generally quite harmless if you prefer, it is possible to block some or all cookies or even to delete cookies that have already been set; but you need to be aware that you might lose some functions of that website.

Web Browser Cookies

If you don"t want to receive cookies, you can modify your browser so that it notifies you when cookies are sent to it or you can refuse cookies altogether. You can also delete cookies that have already been set. If you wish to restrict or block web browser cookies which are set on your device, then you can do this through your browser settings; the Help function within your browser should tell you how.

Alternatively, you may wish to visit www.aboutcookies.org, which contains comprehensive information on how to do this on a wide variety of desktop browsers. You can choose whether to accept cookies that are set by us at any time. If you do so however you will lose some features and functionality if you choose to disable cookies. For example, we won"t be able to remember you.