Effective: June 1st 2018
Spotlight Online Gaming understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this Website, (“Our Website”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
Information About Us
|“Account”||means your account with us as is required to access and/or use certain areas and features of Our Website;|
|“Cookie”||means a small text file placed on your computer or device by Our Website when you visit certain parts of Our Website and/or when you use certain features of Our Website. Details of the Cookies used by Our Website are set out in section 13, below;|
|“Cookie Law”||means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;|
|“personal data”||means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Website. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and|
|“We/Us/Our”||means Spotlight Online Gaming, 10 South Parade, Third Floor, Leeds, LS1 5QS.|
2.1 Our Website is owned and operated by Us.
What Does This Policy Cover?
4.1 As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
4.1.1 the right to be informed about Our collection and use of personal data;
4.1.2 the right of access to the personal data We hold about you (see section 12);
4.1.3 the right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14);
4.1.4 (subject to section 6.5) the right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you;
4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;
4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
4.1.7 The right to object to Us using your personal data for particular purposes; and
4.1.8 Rights with respect to automated decision making and profiling.
4.2 If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
What Data Do We Collect?
5.2 date of birth;
5.4 contact information such as email addresses and telephone numbers;
5.5 demographic information such as postcode, preferences and interests;
5.6 financial information such as credit / debit card numbers;
5.7 IP address;
5.8 web browser type and version;
5.9 operating system;
How Do We Use Your Data?
6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.
6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
6.2.1 Providing and managing your Account;
6.2.2 Providing and managing your access to Our Website;
6.2.3 Personalising and tailoring your experience on Our Website;
6.2.4 Supplying Our services to you (please note that We require your personal data in order to enter into a contract with you);
6.2.5 Personalising and tailoring Our services for you;
6.2.6 Replying to calls or emails from you;
6.2.7 Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by adjusting your setting in your Account);
6.2.8 Market research;
6.2.9 Analysing your use of Our Website to enable Us to continually improve Our Website and your user experience;
6.2.10 Complying with our regulatory duties, obligations and responsibilities including under the Gibraltar Gambling Act 2005, UK Gambling Act 2005 and UK Gambling (Licensing and Advertising) Act 2014 to the Gibraltar Gambling Commissioner and the Gambling Commission and under any other valid and applicable legislation and to any other competent authority;
6.3 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email, telephone, text message, post with information, news and offers on Our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
6.5. In certain circumstances, We may not be able to comply with your request to be forgotten and we may refuse to comply with any such request for erasure where your personal data is being processed for the following reasons:
- (a) to exercise the right of freedom of expression and information
- (b) to comply with a legal obligation for the performance of a public interest task or exercise of official authority.
- (c) for public health purposes in the public interest;
- (d) archiving purposes in the public interest, scientific research historical research or statistical purposes; or
- (e) the exercise or defence of legal claims.
For example, We are required by the Gambling Commission to retain your personal data for a period of one (1) year after you have closed your Account in order to deal with unsettled wagers or complaints.
How and Where Do We Store Your Data?
7.1 We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it. However, we may be required to continue to retain records containing Your information for legitimate business, regulatory, compliance and/ or legal purposes.
7.2 Some or all of your data may be stored outside of the European Economic Area (“the EEA”) including but not limited to India. You are deemed to accept and agree to this by using Our Website and submitting information to Us. If We do store data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR.
7.3 Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Website.
Do We Share Your Data?
8.1 We may share your data with other companies in Our group for data processing purposes. This includes Our holding company and its subsidiaries.
8.2 We may sometimes contract with third parties to supply services to you on Our behalf. These may include age verification, payment processing, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under applicable laws.
8.3 We may compile statistics about the use of Our Website including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of applicable laws.
8.4 We may sometimes use third party data processors that are located outside of the European Economic Area (“the EEA”). When We transfer any personal data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR.
8.5 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.
What Happens If Our Business Changes Hands?
How Can You Control Your Data?
10.1 When you submit personal data via Our Website, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details and by managing your Account).
10.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
Your Right to Withhold Information
11.1 You may access certain areas of Our Website without providing any data at all. However, to use all features and functions available on Our Website you may be required to submit or allow for the collection of certain data.
How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details using the contact details below in section 14.
13.2 All Cookies used by and on Our Website are used in accordance with current Cookie Law.
13.3 Before Cookies are placed on your computer or device, you will be shown a pop-up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Website may not function fully or as intended.
13.4 Certain features of Our Website depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in section 13.5. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 13.9, but please be aware that Our Website may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
13.5 The following first party Cookies may be placed on your computer or device:
|Type of Cookie||Purpose||Additional Information|
|Strictly Necessary Cookies||These cookies are strictly necessary to enable you to navigate the Website and use features you have requested. They are used to provide you with Our consent, products and services that you have requested.||These cookies collect Personal Data about you, such as user name, last login date and identify you as being logged into the Website. These Cookies are deleted when you close your web browser (session cookies)|
|Functionality Cookies||These cookies are used to recognise you when you return to the Website and allow Us to remember your choices and preferences (such as language) in order to allow Us to provide you with improved and customised features.||These cookies collect Personal Data about you, such as your language preferences, the games you play and marketing preferences. |
These cookies survive the closing of your web browser and last until their applicable expiry time.
|Performance Cookies||These cookies are used to provide aggregated statistics in respect of the performance of the Website and to test and improve such performance, in order to provide better user experience; in addition, they allow us to carry out analytical functions on the website.||These cookies collect anonymised data which is not relating to an identified or identifiable natural person. |
These cookies are valid for varying periods; some are deleted once you close your browser, while others have an indefinite validity period.
|Third Party Marketing / Targeting Cookies||These cookies are used to deliver ads and marketing communications, and to make the website displayed, in a manner which is more relevant to you, based on your interests and actions; they are also used to measure the effectiveness of an advertising campaign. These cookies record your visit to the website, the pages you have visited and the products and services you used.||Some of these cookies are provided and used by third parties. |
These cookies are valid for varying periods; some are deleted once you close your browser, while others have an indefinite validity period.
13.7 The analytics service(s) used by Our Website use(s) Cookies to gather the required information.
13.8 In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third-party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
13.9 You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Website more quickly and efficiently including, but not limited to, login and personalisation settings.
13.10 It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.