The Company (as defined in the User Agreement applicable to you), offers online gambling services (collectively, the “Services“). The Company forms part of the Broadway Gaming group of companies (the “Group“, “we“, “our” or “us“), which includes the entities specified below under “The Group” Section.
The Group includes the following companies:
- Broadway Gaming Limited (Registered in Malta with company number C 48904)
- Broadway Gaming UK Limited (Registered in England and Wales with company number 13455228)
- Game On Media Limited (Registered in Ireland with company number 496564)
The Group provides the Services through the following applications and platforms (collectively the “Platforms“):
- Internet websites;
- Downloadable applications and software (“Software”), such as native applications which are distributed through mobile application stores and PC and Mac desktop software which can be downloaded to your computer;
- Non-downloadable online applications (e.g. flash applications, HTML5 applications, etc.); and
- Facebook applications.
WHAT INFORMATION WE COLLECT?
We collect two types of information from our Users:
- Personal Information
The first type of information that we collect is information that identifies or may reasonably identify an individual reasonable effort (“Personal Information“). Personal Information that is being gathered may consist of the following:
- Account details: When you open an account and register to use the Services, you will be asked to provide us certain details about yourself, such as: first and last name, email address, gender, birth date, personal numeric code, age, physical address, ID number, fiscal code, phone number and occupation. In addition, we may collect certain information as required under various gambling regulations, as well as Know Your Client (“KYC“) and Anti-Money Laundering (“AML“) regulatory requirements, such as your source of funds.
- Governmental-issued ID: In certain instances, you will be required to provide a copy of a governmental-issued ID, for identity verification process. Please note that this information is required for certain features of our Services.
- Gaming information: in order for us to provide the Services, we automatically record different information related to your account and use of our Services, including with respect to your transactions, deposits, balances, bets, withdraws, bonuses and winnings. We also collect information regarding potential gambling problems or addictions, based on your patterns of gambling across our services, in order to ensure a responsible gaming environment and as required by law.
- Financial information: In order for you to enjoy all of the functions of the Services (e.g. place bets, perform purchases, play in tournaments, etc.), payment information will be collected from you, such as your currency, credit card number and bank account details.
- Voluntary information: We also collect information which you provide us voluntarily. For example, when you respond to communications from us, communicate with us via email or share additional information about yourself through your use of the Services, such as on the chat feature and in games. This includes information you are willing to share with us for the purpose of improving and developing our relationship with you, as well as for maintaining your stratification from our services (for example, information about your marital status and family, your hobbies and interests, and other information you share with us through surveys).
- Device information: We collect specific types of connection details and information with regard to your device, software or hardware that may identify you, such as: device’s unique identifiers (e.g. UDID, IMEI, MAC address), browser fingerprinting, IP address and geo-location data.
- Telephone calls: We record or monitor telephone calls for customer support, training and/or security purposes.
- Events: during our events, we conduct interview and take photos and videos, which may feature attendees, speakers, sponsors or exhibitors. Where photos and videos are taken that feature you as an attendee, speaker, sponsor or exhibitor, we may use those photos and videos for promotional purposes. We may also use your interview for promotional purposes (such as by quoting you).
- Social networks: When you register through your social network account (such as your Facebook account), to use the Services or connect your player account with such account, we will have access to basic information from your social network account, such as your name, birthdate, profile picture and friends’ list, as well as information you made publicly available on such account.
- Information we collect from third parties: We collect Personal Information from third party service providers, such as information about your credit history from credit agencies and other financial information which is relevant to the provision of the Services, as well as information which is gathered in order to verify your identity and prevent fraudulent or illegal activity.
- Non-personal information
The second type of information is un-identified and non-identifiable information pertaining to a User(s), which may be made available or gathered via the User’s use of the Services (“Non-Personal Information“).
Non-Personal Information which is being collected consists of technical information and aggregated usage information, and may contain, among other things, the User’s operating system, type of browser, screen resolution, browser and keyboard language, the User’s ‘click-stream’ and activities on the Services, the period of time the User visited the Services and related time stamps, etc.
For avoidance of doubt, any Non-personal Information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection or linkage exists.
Types of Non-personal Information we collect from or about you:
- Log-in history and technical information: In order to enhance the functionality of the Services and to provide you with a better user experience, we collect technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time and the domain name of the website from which you linked to the Services; etc.).
- Gameplay information: We record game play information including, amongst other things, your deposits, bets, bonuses, game session duration and your high scores. We may also share and publish such information through any of our Platforms.
- Device and connection information: If you download the Software to your device, we may collect information from the particular device you are using, for security and fraud detection and prevention purposes. For example, we may gather information with regard to other software which is running simultaneously with the Software for detecting if you are using software which is associated with fraudulent activity (e.g. robots, malware, etc.) or checking if the connection you are using is via a VPN or proxy.
- Analytics information: We collect information about your use of the Services, such as applications’ usage, log files, user activity (e.g. pages viewed, the amount of time spent on particular pages, online browsing, clicks, actions, etc.), time stamps, alerts, etc. This information is collected for amongst other things troubleshooting errors and bugs as well as for research and analytics purposes about your use of the Services.
CONDITIONS FOR PROCESSING PERSONAL INFORMATION
We will process your Personal Information for a variety of reasons, each of which is prescribed by relevant data protection laws.
- Fulfillment of a contract, compliance with a legal obligation
It is necessary for us to process your Personal Information where it is necessary for the performance of a contract (such as for the User Agreement) or in order for us to comply with our various legal and/or regulatory responsibilities, including, but not limited to, complying with the conditions of our gambling licenses and complying with any AML and KYC legislation.
- Legitimate interests
We also process your Personal Information where we deem such processing to be in our (or a third party’s) legitimate interests and provided always that such processing will not prejudice your interests, rights and freedoms. Examples of us processing in accordance with legitimate interests would include: (i) where we disclose your Personal Information to any one or more of our associate/subsidiary companies following a restructure or for internal administrative purposes; (ii) detection and retention of information pertaining to those with responsible gambling issues; (iii) processing for the purposes of ensuring network and information security, including preventing unauthorized access to our electronic communications network; (iv) safeguarding the integrity of our Services by combatting, reporting and sharing information related to suspicious betting patterns or fraudulent activities; (v) adhering to regulatory and statutory requirements; (vi) devising a tailored reward scheme for players; and (vii) sharing personal information with our advisers and professional services providers (such as auditors) for ensuring our compliance with regulatory requirements and industry best practices.
Our processing of your Personal Information will primarily be necessary for us to provide you with the Services. However, on certain occasions we may ask for your consent to processing Personal Information. In these instances your Personal Information will be processed in accordance with such consent and you will be able to withdraw this consent in writing at any time.
- Special Categories of Personal Data
Our processing of your Personal Information may also involve special categories of personal data, such as your racial or ethnic origin (as defined under Article 9 of the GDPR). We will disclose any relevant Personal Information to competent authorities (such as licensing bodies or law enforcement bodies), where it is necessary for the following purposes (to the extent permissible by applicable law): (i) prevention or detection of an unlawful act, (i) prevention of dishonesty, malpractice or other seriously improper conduct, provided that obtaining your consent may prejudice those purposes. In addition, we may process and disclose such information where it is necessary for the purposes of safeguarding your (or others’) economic well-being (such as detection and retention of information pertaining to those with responsible gambling issues).
The Services are not designed or directed to persons under the age of 18 with respect to the use of the Services (“Legally of Age“). If you are not Legally of Age, you should not download or use the Services nor provide any Personal Information to us.
We reserve the right to access and verify any Personal Information collected from you. In the event that we become aware that a user who is not Legally of Age has shared any information, we may discard such information unless it is needed to comply with any legal or statutory obligation binding upon us. If you have any reason to believe that a minor has shared any information with us, please contact us at (our contact details are available under the “HOW TO CONTACT US?” section).
HOW WE USE THE COLLECTED INFORMATION?
We use your Personal Information for the purposes listed below:
- To set up, manage and update your account;
- To provide and operate the Services (such as for betting and payment processing);
- To communicate with you and to keep you informed of our latest updates to our Services and special offers;
- To market our Services (see more below under “Marketing“), as well as to serve you advertisements, including behavioral advertising;
- To conduct analytics, statistical and research purposes, in order to improve and customize the Services to your needs and interests (such as by compiling aggregated reports about the usage of certain features of our Services);
- For customer relationship management purposes, and to support and troubleshoot the Services and to respond to your queries;
- To enable us to further develop, customize and improve the Services based on Users’ common preferences and uses;
- To provide you with a responsible gaming environment;
- To communicate with your and to process any of your requests to exercise your User Rights;
- To identify and authenticate your access to certain features of the Services;
- To detect and prevent fraudulent and illegal activity or any other type of activity that may jeopardize or negatively affect the integrity of the Services, including by identifying risks associated with your activity on our Services;
- To investigate violations of our policies and User Agreement as well as enforce our policies and the User Agreement;
- To investigate and resolve disputes in connection with your use of the Services; and
- To assist us with meeting our regulatory obligations or as required by law or regulation (such as gambling regulations, KYC and AML regulatory requirements), including for the purpose of ascertaining your source of funds or income, or as required by other governmental authorities, or to comply with a subpoena or similar legal process or respond to a government request; and
- In addition, we use your Personal Information upon your specific and informed consent, such as for certain marketing and promotional activities.
Where you have not consented (or have withdrawn your consent) to the processing of your Personal Information by us, we may continue to process your Personal Information (a) where processing is required for the performance of the contract (i.e. the User Agreement) between you and us; and/or (b) where processing is necessary for compliance with a legal obligation to which we are subject; (c) where processing is necessary for the purposes of a legitimate interest of the Group (including for marketing).
We will use your Personal Information, such as your name, home address, email address, telephone number etc., ourselves or by using our third party subcontractors for the purpose of providing you with promotional materials, concerning the Services as well as products, services, websites and applications which relate to: (i) other companies within the Group; or (ii) the Group’s business partners and affiliates (collectively: “Marketing Affiliates“), which we believe may interest you.
We may also share and disclose Personal Information with our Marketing Affiliates for the purpose of providing you different marketing offers, which we, or our Marketing Affiliates, believe are relevant for you. Our Marketing Affiliates may use this Personal Information for different marketing techniques, such as direct email, post, SMS and telephone marketing purposes.
We will use your Personal Information for the purpose of providing you with promotional materials solely where we have a legitimate interest in doing do, or where we have obtained your affirmative consent.
You may at any time decline receiving further marketing offers from us or from Marketing Affiliates by either: following the guidelines available on the marketing communications (such as selecting the opt-out link inserted in the promotional emails), via “My Account” page on the site or by contacting support (our contact details are available under the “HOW TO CONTACT US?” section). Please note that even if you unsubscribe from our marketing mailing list, we may continue to send you service-related updates and notifications.
Please note: you can control the delivery of certain advertising or social campaigns through the settings offered by the respective third party platforms (e.g. Facebook).
In addition, if you download any of our mobile applications to your device from the Apple AppStore or Google Play, the only way to prevent receipt of notifications is by changing the settings on the device itself.
We use third-party advertising technology to serve advertisements when you visit the Platform and use the Services. You may opt-out of many third-party ad networks, including those operated by members of the Network Advertising Initiative (“NAI“) and the Digital Advertising Alliance (“DAA“).
For more information regarding this practice by NAI members and DAA members, and your choices regarding having this information used by these companies, including how to opt-out of third-party ad networks operated by NAI and DAA members, please visit their respective websites: www.networkadvertising.org/optout_nonppii.asp und www.aboutads.info/choices.
WITH WHOM WE SHARE INFORMATION?
We share Personal Information with any of the following recipients:
- Any replacement service provider that we engage with to operate the Platforms;
- Companies within our Group and other affiliated companies;
- Gaming providers;
- Subcontractors and third party service providers, as well as their subcontractors, which by way of example include (but is not limited to) cloud computing companies, marketing affiliates, identity verification and fraud prevention services, and other data verifiers;
- Credit reporting agencies (“CRA(s)”) and credit reference bureaus, including for conducting name, address and age checks. In order to open an account for you, we will supply your personal information to credit reference agencies, and they will provide us information about you. This may include:
- Identity and contact data;
- Information from your credit application;
- Information about your financial situation and financial history;
- Public information (including the electoral register);
- Shared credit details; and
- Fraud prevention information.
We do so check your identity, manage your account and prevent criminal activity. The identities of the CRAs, their role as fraud prevention agencies, the data they hold, the ways in which they use and share personal information, their data retention periods and your data protection rights with the CRAs are explained in more detail at the websites below:
- Payment service providers, payment processors and banks;
- Any third parties who provides services in relation to the operation or promotion of the applicable Group’s brands;
- Any third party who provides you with a tangible prize;
- Any third parties who organize offline events or tournaments on behalf of or in conjunction with any companies within the Group;
- Hotels and flight companies (such as in the context of offline events and promotions);
- Auditors, contractors or legal/financial/other advisers of any of the Group’s business processes;
- Any third parties who investigate, detect or prevent fraudulent or illegal activity or enable us to enforce our policies, including in order to ascertain your source of income or funds (e.g. governmental authorities, law enforcement bodies, banks and other investigatory bodies);
- Gambling addictions bodies;
- Licensing authorities, governmental and regulatory bodies, in accordance with applicable laws and regulations; and
- Storing such information on our behalf, for example by using cloud computing service providers;
- Processing such information to assist us with our business operations (e.g. to process payments and your deposits; authenticate your access; auditing our operations; detect and prevent fraudulent or illegal activity; etc.);
- Performing research, technical diagnostics or analytics;
- Communicating targeted advertising, as well as promotional and informational materials, in accordance with our marketing policy (see above, in the section titled “Marketing”); and
INTERNATIONAL TRANSFER OF INFORMATION
For more information about the transfer of your personal data outside of the EEA, please contact us (our contact details are available under the “HOW TO CONTACT US?” section).
THIRD PARTY TRACKING TECHNOLOGIES
When you visit or access our Services (for example when you visit our websites), we use (and authorize third parties to use) web beacons, cookies, pixels, scripts, tags and other technologies (“Tracking Technologies“).
The Tracking Technologies allow us to automatically collect information about you and your online behavior, as well as your device (for example your computer or mobile device), for different purposes, such as in order to enhance your navigation on our Services, improve our Services’ performance and customize your experience on our Services. We also use this information to collect statistics about the usage of our Services, perform analytics, deliver content which is tailored to your interests and administer services to our Users, advertisers, publishers, customers and partners.
THIRD PARTY SERVICES
You should always review their privacy practices carefully before providing Personal Information to such third parties.
You are knowingly and voluntarily assuming all risks of using any third-party websites, services or applications. You agree that we shall have no liability whatsoever with respect to such third party sites and your usage of them.
RETENTION OF PERSONAL INFORMATION
If you have registered with an account through our Services, the Group will retain your Personal Information during the period your account is active. In addition, the Group will retain your Personal Information for additional periods, as strictly necessary to enable the Group to meet its legal obligations under applicable laws or regulations, such as the applicable gambling regulations, KYC and AML regulations as well as to meet the Group’s contractual obligations.
In addition, the Group may retain your Personal Information for longer periods, provided that retaining such information is strictly necessary for the Group’s legitimate interests, such as fraud prevention and record keeping, responsible gaming reasons, resolving or exercising claims regarding potential disputes, and where the Group is guided to do so by the applicable supervisory authority.
You may contact us at any time by email (our contact details are available under the “HOW TO CONTACT US?” section), and request:
- To access or delete any Personal Information relating to you;
- To change or update any Personal Information relating to you (for example, if you believe that your Personal Information is incorrect, you may ask to have it corrected or deleted). Note that you may also request that we will correct errors with regard to your Personal Information (except in cases where the information is required to be kept in its original format under any applicable laws and regulations);
- That we will restrict or cease any further use of your Personal Information;
- That we will provide the Personal Information you volunteered to us in a machine-readable format.
- To object to the processing of your Personal Information (such as for marketing purposes);
- To withdraw your consent to our processing activities (provided that such processing activities rely on your consent, and not on a different legal basis);
- To not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, except where such processing is necessary for the performance of the contract between you and us, or it is based on your explicit consent, as provided hereunder.
Please note that these rights are not absolute and requests are subject to any applicable legal requirements, including gambling regulations and other legal and ethical reporting or document retention obligations. We may also rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion, in accordance with our internal policies.
HOW WE KEEP YOUR INFORMATION SECURED
We take great care in implementing and maintaining the security of the Services and your information. We have put in place appropriate physical and technological safeguards to help prevent unauthorized access, to maintain data security, and to use correctly the information we collect online. These safeguards vary based on the sensitivity of the information that we collect and store.
We employ industry standard procedures and controls to ensure the safety of our users’ information, such as:
- Secure network topology, which includes intrusion prevention and Firewall systems;
- Encrypted communication;
- Authentication and Access Control;
- External and Internal audit tests; etc.
Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse the Services, and we make no warranty, express, implied or otherwise, that we will prevent such access.
HOW TO CONTACT US
If you have any general questions about the Services or the information that we collect about you and how we use it, please contact us via email at support@gbhlbrands or by sending a letter to: Grand Battery Holdings Limited – Attn: Data Protection Officer; Hospitality House, 16-20 Cumberland Street South Dublin, Ireland, D02Y 097
We will make an effort to reply within a reasonable timeframe. Please feel free to reach out to us at any time. If you are unsatisfied with our response, you can reach out to the applicable data protection supervisory authority.
Last revised: June 30th, 2022