IMPORTANT INFORMATION AND WHO WE ARE
This website is not intended for children, and we do not knowingly collect data relating to children.
Our full details are: c/o Legal Department, In Touch Games Limited, Fountain House, Great Cornbow, Halesowen, B63 3BL.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
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.
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 follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, and image
- Contact Data includes billing address, delivery address, email address and telephone numbers
- Financial Data includes bank account, payment card details, Mobile billing, and PayPal transactions
- Transaction Data includes details about payments to and from you
- Financial Vulnerability & Affordability Data includes financial commitments and history to assess your affordability
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website
- Profile Data includes your username and password, deposit methods made by you, your interests, preferences, feedback, and survey responses, please note game logs are only stored for a period of 12 months
- Usage Data includes information about how you use our website and games
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences
To understand how credit reference agencies operate, or if you wish to dispute an affordability decision, you can make contact with the credit the credit refence agencies and obtain a copy of your credit report. Please follow the link Privacy Centre (transunion.co.uk).
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). Due to our regulatory requirements, we will collect information about criminal convictions and offences as part of our PEP and sanction procedures. We may also refer information to the national fraud database and National Crime Agency for the purpose of crime prevention. This information is only shared for the purpose of our regulatory requirements and fraud prevention.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, 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 perform the contract we have or are trying to enter with you (for example, to provide you with gambling services). In this case, we may have to close account(s) you have with us, but we will notify you if this is the case at the time.
HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your identity, contact and financial data by logging in to your account, filling in forms or by corresponding with us by post, phone, email, live chat, video/ audio conferencing or otherwise. This includes personal data you provide when you:
- Register an account
- Contact us by telephone, email, video/ audio conferencing or live support facility
- Request marketing to be sent to you
- Enter a competition, promotion, or survey; or
- Give us some feedback.
- Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
(a) analytics providers such as Google based outside the EU
(b) search information providers based inside the EU such as
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Fonix based inside the EU.
- Identity and Contact Data from data brokers or aggregators such as GB Group and TransUnion based inside the EU.
- Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
- Fraud prevention agencies such as Cifas based inside the EU.
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:
- Enabling us to set up your account so that you can make full use of all the features of the services, including crediting your account with funds, and playing games
- Complying with relevant regulations regarding your registration, for example, completing age verification checks
- (Provided that you do not opt out of receiving marketing materials), Keeping you informed of future events, offers and promotions from us (and any other company in our group)
- Setting up, operating, and managing your account
- Providing any of the services which are requested of us, and for any proper purpose connected with such provision
- Verifying the accuracy of your information, including disclosure of such information to third parties (including financial institutions, age verification and credit reporting agencies)
- Preparing statistics, providing analytical reports and analysis relating to the use of the services by you and other customers
- Analysing and recording your use of services and websites to improve our products and the way we deliver the services
- Preparing and displaying appropriate individualised marketing material and content
- Conforming to regulatory and legal requirements or complying with legal processes
- The investigation of suspected unlawful, fraudulent, or other improper activity connected with the services
- The reporting of a crime or suspected crime, including money laundering, proceeds of crime, terror financing or any fraud and
- Any other purpose which is necessary for the performance of our contractual obligations to you or our legal and regulatory obligations
You have the right to withdraw consent to marketing at any time by:
- Telephone or live chat, via the Support Button on the Website: or
- Using the unsubscribe feature in the marketing material.
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, where appropriate, what our legitimate interests are.
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 and choose whether to give explicit consent or not to receiving free bonuses and exclusive offer news from ITG.||(a) Identity (b) Contact (c) Marketing and Communications||Performance of a contract with you; Processing and disclosure of your Personal Information for the purposes of sending relevant marketing material, promotions, and prizes to you.|
|To process and deliver your transactions including: (a) Manage payments, fees, and charges (b) Collect and recover money owed to us||(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications||(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)|
|To enable you to partake in a prize draw, promotion, competition or complete a survey||(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications||(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our services, to develop them and grow our business)|
|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|
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you. To remove individuals from external marketing campaigns via exemption lists.||(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical||Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, services, marketing, customer relationships and experiences and Responsible Gambling requirements||(a) Identity (b) Contact (c) Profile (d) Usage (e) Technical (f) Usage||Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy and to ensure we comply with our Social Responsibility Requirements)|
|To make suggestions and recommendations to you about our new games, promotions and depositing methods that may be of interest to you||(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile||Necessary for our legitimate interests (to develop our services and grow our business)|
The personal information we have collected from you will be shared with fraud/crime prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity. If fraud is detected, you could be refused certain services.
Before we provide services to you, we undertake checks for the purposes of preventing fraud and money laundering, and to verify your identity. These checks require us to process personal data about you.
The personal data you have provided, we have collected from you, or we have received from third parties will be used to prevent fraud and money laundering, and to verify your identity.
Details of the personal information that will be processed include, for example: name, address, date of birth, contact details, financial information, employment details and device identifiers including IP address.
We and fraud/crime prevention agencies may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime.
We process your personal data on the basis that we have a legitimate interest in preventing fraud and money laundering, and to verify identity, in order to protect our business and to comply with laws that apply to us. Such processing is also a contractual requirement of the services you have requested.
Fraud/crime prevention agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years.
CONSEQUENCES OF PROCESSING
If we, or a fraud/crime prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services you have requested, or we may stop providing existing services to you.
A record of any fraud or money laundering risk will be retained by the fraud/crime prevention agencies, and may result in others refusing to provide services, financing, or employment to you. If you have any questions about this, please contact us on the details above.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
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 how we decide which services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not agreed to receive that marketing. We may also use this information to stop certain individuals receiving external promotional content.
Where you have agreed to receive such communications, ITG may contact you for marketing purposes by SMS, email, or phone. These marketing messages will provide you with various information about our new games, promotions, and other services.
We may also send push notifications to your mobile device to provide game updates, account communications, promotions, or other relevant messages.
We will get your express opt-in consent before we share your personal data with any company outside the ITG group of companies for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us.
Your browser also generates other information, including which language the website is displayed in, and your Internet Protocol address (“IP address”). An IP address is a set of numbers which is assigned to your computer during a browsing session whenever you log on to the internet via your internet service provider or your network (if you access the internet from, for example a computer at work). Your IP address is automatically logged by our servers and used to collect traffic data about visitors to our website. We also use your IP address to help diagnose problems with our server, and to administer our website.
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 law.
DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table above.
Where required by law, your personal information may also be disclosed to an applicable governmental, regulatory or enforcement authority. Additionally, in circumstances where we deem it appropriate, your personal information may be disclosed to any regulatory authority which has issued any company within the Group with a gambling operator licence.
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.
We have a duty of care to our employees, our players, and the general public – and as a result we may share your personal data with law enforcement and/or other emergency services, if we feel that it is necessary to do so. Examples of our concerns include, but are not limited to, self-harm, harm to others, and harm to children. We are warranted to share this information under GDPR should it impact any vital interest.
We share your personal data within the ITG Group. This may involve transferring some of your data outside the European Economic Area (EEA).
Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever fraud prevention agencies transfer your personal data outside of the European Economic Area, they impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the European Economic Area. They may also require the recipient to subscribe to ‘international frameworks’ intended to enable secure data sharing.
Whenever we transfer your personal data out of the EEA, we will ensure personal data has a similar degree of protection that it would have in Europe.
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.
All data on our secure websites is encrypted using Secure Sockets Layer (“SSL”) technology. Where we have given you (or where you have chosen) a password which enables you to access your account, you are responsible for keeping this password confidential.
Any data which contains personal information which identifies you will be encrypted at all times whilst in transit over the internet. SSL is a special protocol that automatically encrypts any information sent by you on our secure pages. Our server then reads the information using a private key. This means that your information, be it debit card information or any other personal details, is turned into code that can only be decoded with the private key or password.
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.
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfil 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 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 requirements.
By law to maintain our compliance with AML regulations we are required to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for a period of at least five years after the relationship with the customer has ended. The date the relationship with the customer ends is the last date on which they visit or use our services.
YOUR LEGAL RIGHTS
You have the right to:
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 continuing to process 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 local 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.
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.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
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.
Should you require to exercise any of your legal rights as per above, then you should contact us via email at: firstname.lastname@example.org
Should you wish to make a Subject Access Request you should contact us in writing at: Subject Access Request c/o Legal Department, In Touch Games Limited, Fountain House, Great Cornbow, Halesowen, B63 3BL. Or via email at: email@example.com
You should include adequate information to identify yourself and such other relevant information that will reasonably assist us in fulfilling your request. Your request will be dealt with as soon as possible. Under the GDPR, we may charge an ‘reasonable fee’ for the administration costs for processing such requests. This administration fee is to cover the cost and time involved with gathering the relevant data and administration services such as photocopying and postage and will be no more than £10.
We may reject requests for disclosure or deletion of your information that are unreasonable or extremely impractical such as it requires a disproportionate human or technical effort or require significant changes to our processes and technology and impact our ability to provide the services.
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 may 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.