Clubwin Privacy Policy

 

Contents:

1. Overview 

2. Information We May Collect from And About You

3. Collection of Information

4. Account

5. Failure to provide information

6. Uses Made of Your Information

7. What is the legal basis on which we rely to process your data?

8. Privacy Rights: Can I object to having my personal information used in this way?

9. Disclosure of your information

10. Where we store your personal information

11. Parents and Guardians

12. Marketing

13. Contact and further information

14. Changes

15. Who is responsible for your data?

16. How long do we keep data?

17. Your rights

1. Overview:

This Privacy Policy explains how we collect and process your personal data through your use of this website and the choices you can make about the way your information is collected and used. We are committed to protecting and respecting your privacy.

This policy applies to ‘https://*clubwin.co.uk’ (the “Services as defined by General Data Protection Regulations (“GDPR”) and may be referred to as “we”, “us” and “our”.

This policy sets out the basis on which any personal information we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal information and how we will treat it. By accessing and using the Service which is made available via our website or through our apps, or any mobile versions thereto, or by continuing to use our Service, you are accepting and consenting to the practices described in this Privacy Policy.

2. Information We May Collect from and About You:

There are a number of direct interactions that we may have with you which may result in your data being collected, including the following:

● When you register with us.

● When you enter such information while using the Service.

● When you interact with our Customer Services team.

● When you participate in marketing promotions.

● When you set preferences in the ‘My Account’ section of the Service’s website;

● When you otherwise provide information to us through the Service or elsewhere.

3. Collection of Information:

We, whether directly or through third party suppliers, may collect information regarding your use of our Service, including but not limited to:

● Your name, username and password;

● Your personalised account details;

● Your contact details, including your email address, phone numbers and/or billing address;

● Information regarding your use of the Service;

● The language choices made by you in relation to your use of the Service which may include information relating to your location when using the Service;

● Your entry details for any competition or promotion;

● Device IDs or unique identifiers, device and software characteristics (such as type and configuration), connection information, statistics on page views, referral URLs, ad data, IP address and standard web log information;

● With your consent, the location of your device;

● Information collected via the use of cookies, web beacons and other technologies. See our Cookies Policy for more details;

● Any website that referred you to the Service, together with any online and email marketing campaigns that related to the Service; 

● The types of devices you use to view the Service;

● Behaviour on our Service as you click around the website or application;

● Online and email marketing campaigns you receive or subscribe to in relation to the Service.

4. Account

There are certain services you will only be able to access by registering with us. To register with us, you must provide us with at least your first name, surname, email address, date of birth, username and a password.

5. Failure to provide information:

Where you are signing up to a betting or gaming service, Unibet will be required to collect and process certain data about you (including your home address) in order to meet its legal obligations in providing the Services. If you fail to provide that information – such as copies of documents to confirm your identity – we may be unable to provide your requested service.

6. Uses Made of Your Information:

We may use the personal information you provide to us to do some or all of the following, in each case to the extent permitted by applicable data protection laws:

● administer our website and apps;

● provide the service you have requested;

● improving your browsing experience by personalising the Services for you (subject to your settings in the cookies section);

● recommend goods, services or promotions which may be of interest to you or contact you in order to conduct market research (but only where you have requested us to do so);

● prevent, detect and investigate potentially prohibited or illegal activities, including fraud, and enforce our terms;

● notify you about changes to our Services;

● contact you in order to conduct market research (but only where you have provided your consent for us to do so);

● send out email alerts, text messages or device notifications you may have opted into;

● send you prizes won via our website or apps, and supply to you services purchased via our website or apps;

● provide third parties with statistical information about our users;

● to enable us to comply with any legal, regulatory and compliance requirements, including under the Gambling Act 2005 and the Gambling (Licensing and Advertising) Act 2014 and to meet any obligations we have with the Gambling Commission of Great Britain and any other competent authority;

● responding to any call or emails from you; and

● to understand customer trends and patterns.

7. What is the legal basis on which we rely to process your data?

On some occasions, we process your data with your consent (for example, when you agree that we may place cookies or process information that you input into our website).

On other occasions, we process your data when we need to do this to fulfil a contract with you (for example, for billing purposes) or where we are required to do this by law (for example, where we have to fulfil anti-money laundering requirements).

We also process your data when it is in our legitimate interests to do this and when these interests are not overridden by your data protection rights. Examples of this include processing your data to provide us with information on how our website is used and can be improved and ensuring compliance with our terms and conditions.

8. Privacy Rights: Can I object to having my personal information used in this way?

This category covers activities we are obliged to do in order to provide our services legally, responsibly, and in accordance with the requirements of our regulators, and ultimately to protect our customers and our business. We cannot provide you with our services without carrying out these activities, and if you don’t want your data used in this way, your option is to not use our services and close your account.

9. Disclosure of your information:

We may share your information with selected third parties including:

● Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.

● Advertisers and advertising networks that require the data to select and serve relevant adverts to you.

● Analytics and search engine providers that assist us in the improvement and optimisation of our site.

● Regulatory or Sporting in connection with policing the integrity or enforcing the rules of a sport or game and/or prevention and detection of crime and where we consider that there are reasonable grounds to suspect that you may be involved in a breach of such rules or the law, have knowledge of a breach of such rules or the law or otherwise pose a threat to the integrity of the relevant sport or game based upon our assessment of your betting behaviours or it may be based on information provided to us by a regulatory or sporting body. Those bodies may then use your personal information to investigate and act on any such breaches in accordance with their procedures.

● Credit and Fraud-Prevention Agencies: for ID verification and the prevention of fraud, money laundering and other illegal use of our pay-to-play services, we use commercially-available tools or services provided by Credit Reference and Fraud Prevention Agencies and service providers.

We may also share your information in the following circumstances:

● In the event of a merger, sale, restructure, acquisition, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

● If we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our terms of use.

● In any of the above circumstances, 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.

10. Where we store your personal information:

Security:

We understand that the security of your personal information is important to you. When handling personal information, security is paramount, and we seek to ensure that personal information is adequately protected. We use reasonable administrative, logical and physical controls, including password protection, to safeguard your personal information against loss, theft and unauthorised access, use or modification. However, some limited personal Information provided to us is transmitted using unencrypted protocols.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your personal information.

International Data Transfers:

Information that we collect may be stored and processed in and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this Privacy Policy.

Information which you provide may be transferred to our group companies, commercial partners, suppliers or agents located in countries which do not have data protection laws equivalent to those in force in the European Economic Area (the “EEA”).

We will only send your data outside of the European Economic Area (‘EEA’) to:

(i) follow your instructions;

(ii) comply with a legal duty; or

(iii) work with our agents and advisers who we use to help run your accounts and services.

If we do transfer information to our agents or advisers outside of the EEA, we will make sure that it is protected in the same way as if it was being used in the EEA. We’ll use one of these safeguards:

(i) transfer it to a non-EEA country with privacy laws that give the same protection as the EEA. Learn more on the European Commission Justice website;

(ii) put in place a contract with the recipient that means they must protect it to the same standards as the EEA. Read more about this here on the European Commission Justice website;

(iii) transfer it to organisations that are part of Privacy Shield. This is a framework that sets privacy standards for data sent between the US and EU countries. It makes sure those standards are similar to what is used within the EEA. You can find out more about the Privacy Shield on the European Commission Justice website.

You are deemed to accept and agree to this by using this website and submitting information to us.

11. Parents and Guardians:

Our Service is a general audience service. The Service is not intended for or directed at persons under 18 years of age. By providing your information to us via the website or app or otherwise you represent to us that you are at least 18 years old and acknowledge that your information can be used to verify that this is the case.

12. Marketing:

As mentioned above, we and/or selected third parties may contact you with information about offers, products and services that might be of interest to you (but only if you have consented to receive such marketing). If you have consented to receiving marketing communication by either (i) ticking the marketing box when you signed up or (ii) electing to opt-in within the My Account section of our website.

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 settings within the My Account section of our website.

13. Contact and further information:

Questions, comments and requests regarding this privacy policy should be addressed to enquiries@clubwin.co.uk

14. Changes:

We reserve the right to change the practices described in this Policy at any time. Any changes will be posted on the website and you will be deemed to have accepted the terms of the Privacy Policy on your first use of the website following the alterations. We recommend that you check this page regularly to keep up-to-date.

15. Who is responsible for your data?

The data controller for your information is:

Unibet

Suite 2B,

143 Main Street,

Gibraltar

GX11 1AA Gibraltar.

The data processor for your information is:

Clubwin.co.uk Limited

2nd Floor Quadrant House

47 Croydon Road

Caterham

Surrey

CR3 6PB

16. How long do we keep data?

We retain personal information for as long as we reasonably require it for legal, accounting or business purposes. Subject to us not having a legal or regulatory requirement or a risk management reason for retaining your information for a longer period, your information will not be kept for longer than 6 years after you have closed your account. Please note that we may be required in certain circumstances to retain your information indefinitely (for example under our procedures on responsible gambling and self-exclusion). We will take all necessary steps to ensure that the privacy of information is maintained for the period of retention.

17. Your rights:

Under the GDPR, you, as a data subject have a number of rights which are detailed below. Some of these only apply in specific circumstances and are qualified in several respects by legal exemptions. We will advise you in our response to your request if we are relying on any such exemptions.

Access to personal data:

You have a right to request a copy of the personal information that we hold about you. Should you wish to make such a request, please see the Contact Us section for information on how to contact us.

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. If you do wish to make an access request, no fee is payable under the GDPR.

Correction of personal data:

You can ask us to rectify and correct any personal data that we are processing about you which is incorrect by sending an email to enquiries@clubwin.co.uk

Right to withdraw consent:

Where we have relied upon your consent to process your personal data, you have the right to withdraw that consent.

To opt out of marketing, you can use the unsubscribe link found in the marketing communication you receive from us. For other marketing preferences, you can visit the My Account tab when you log into your account.

Right of erasure:

You can request us to erase your personal data where there is no compelling reason to continue processing. This right only applies in certain circumstances; it is not a guaranteed or absolute right.

Right to data portability:

This right allows you to obtain your personal data that you have provided to us with your consent or which was necessary for us to provide you with our products and services in a format which enables you to transfer that personal data to another organisation. You may have the right to have your personal data transferred by us directly to the other organisation, if this is technically feasible.

Right to restrict processing of personal data:

You have the right in certain circumstances to request that we suspend our processing of your personal data. Where we suspend our processing of your personal data we will still be permitted to store your personal data, but any other processing of this information will require your consent, subject to certain exemptions.

Right to object to processing of personal data:

You have the right to object to our use of your personal data which is processed on the basis of our legitimate interests. However, we may continue to process your personal data, despite your objection, where there are compelling legitimate grounds to do so or we need to process your personal data in connection with any legal claims.

Note that exercising your right of objection will usually mean you need to close your account and stop using our Services.

Rights relating to automated decision making and profiling:

You have the right not to be subject to a decision which is based solely on automated processing (without human involvement) where that decision produces a legal effect or otherwise significantly affects you. This right means you can request that we involve one of our employees or representatives in the decision-making process. We are satisfied that we do not make automated decisions of this nature.

We hope that we can satisfy queries you may have about the way we process your data. If you have any questions or concerns, or wish to exercise any of your rights, you can contact us at enquiries@clubwin.co.uk. However, if you have unresolved concerns you also have the right to complain to our supervisory authority (the UK Information Commissioner).