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1.0 - Introduction

This privacy policy aims to give you information on how PocketBet collects and processes your personal data through your use of this website, including any data you may provide when you subscribe for or use any of our services.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

This Policy will be reviewed at least annually and in the below circumstances as required;

  • In line with any updates to legislation or regulator guidance
  • In light of any correspondence with the UK Gambling Commission, the Gibraltar Regulatory Authority (GRA) or the UK's ICO.
  • In light of any issues noted and escalated due to internal review.
  • Following feedback from any assessment or audit, either internal or external.
  • In the event we change how we handle personal data.

The responsibility for maintenance of this policy sits with the Neal Luke who is Head of Risk and Compliance. For any questions related to this policy you can contact them at support@pocketbet.com.

 

2.0 - Website Privacy Policy

Privacy Policy

 

I. Introduction

PocketBet Limited ("PocketBet", "we", "us", "our") is committed to protecting and respecting your privacy. PocketBet is the controller and responsible for your personal data. We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below:

  • Full name of legal entity: PocketBet Limited
  • Email address: support@pocketbet.com
  • Postal address: 3.4 Waterport Place, Gibraltar, GX11 1AA

In addition individuals in the United Kingdom can also get in touch with our UK data protection representative as follows:

  • Full name of legal entity: Outplayed World Wide Services Limited
  • Email address: support@outplayed.com
  • Postal address: 71-75 Shelton Street, London, WC2H 9JQ

As an online business, we place great importance on ensuring the quality, confidentiality, integrity, and availability of the data we hold and in meeting our data protection obligations when processing personal data. PocketBet are committed to protecting the security of your personal data. We use a variety of technical and organisational measures to help protect your personal data from unauthorised access, use or disclosure.

Since we may update this privacy notice from time to time please review this privacy notice periodically to check for updates. In the event of material changes we will let you know before hand by email what those changes will be. This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

 

II. What information do we process?

Personal data is any information relating to an identified or identifiable natural person. We process the information you give us, whether through interactions with our website or by any other form of correspondence or engagement with us.

We may collect, use, store and transfer different kinds of personal information about you which we have grouped together as follows:

  • Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and gender including copies of your ID and proofs of address.

  • Contact Data includes billing address, email address and telephone numbers.

  • Financial Data includes bank account and payment card details. We may also collect information required under various gambling regulations and Know Your Customer and Anti-Money Laundering regulations such as information related to affordability and source of funds.

  • Transaction Data includes details about payments to and from you and other details of our services or products you have used.

  • 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, information relating to your account activity and patterns of play, your interests, preferences, feedback and survey responses.

  • Usage Data includes information about how you use our website, products and services.

  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

How is your information 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 filling in forms or by corresponding with us in writing or on the phone This includes personal data you provide when you:

  • apply for our products or services;

  • create an account with us;

  • subscribe for products, services or publications;

  • request marketing to be sent to you;

  • enter a competition, promotion or survey; or

  • give us feedback or contact us.

  • Automated technologies or interactions. As you interact with our website, we will 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 will receive personal data about you from various third parties and public sources as set out below:

Technical Data from the following parties:

(a) analytics providers such as Google based inside or outside the UK;

(b) search information providers such as Google based inside OR outside the UK

(c) Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as emerchant pay, checkout.com and Worldline based inside OR outside the UK

(d) dentity and Contact Data from data brokers or aggregators such as Hooyu] based inside the UK

(e) Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.

We may use tools to personalise the user experience, which may be disabled at any time using the Privacy Settings on your device or on our website.

 

III. Purposes and bases for processing your personal data

We may use your data for the following purposes and on the following lawful bases:

  • Purpose: To register you as a customer
  • Relevant Categories of Personal Data: Identity, Contact, Financial, Usage
  • Lawful Bases for Processing: It is necessary to process your personal data to facilitate performance of the service contract
  • Purpose: Delivery and performance of our services in accordance with our Terms and Conditions
  • Relevant Categories of Personal Data: Identity, Contact, Financial, Transaction, Technical, Profile, Usage
  • Lawful Bases for Processing: It is necessary to process your personal data to facilitate performance of the service contract
  • Purpose: Providing information on your account, such as transaction history, gaming history and spending trends
  • Relevant Categories of Personal Data: Financial, Transaction, Technical, Profile, Usage
  • Lawful Bases for Processing: It is necessary to process your personal data to facilitate performance of the service contract
  • Purpose: Prevention and detection of crime including money laundering, fraud or other crimes.
  • Relevant Categories of Personal Data: Identity, Contact, Financial, Transaction, Technical, Profile, Usage
  • Lawful Bases for Processing: We have a legal obligation to report any such activity to the relevant authorities and regulators
  • Purpose: Compliance with sector-specific laws, regulations, and guidelines
  • Relevant Categories of Personal Data: Identity, Contact, Financial, Transaction, Technical, Profile, Usage
  • Lawful Bases for Processing: We have a legal obligation to provide our services within the law and regulations set down by our Regulators
  • Purpose: Providing you with updates about our product, additional features, and (where we have appropriate consent) providing you with exclusive promotions and deals.
  • Relevant Categories of Personal Data: Identity, Contact, Profile, Usage, Marketing, and Communications
  • Lawful Bases for Processing: It is necessary for our legitimate interests to provide accurate and up to date information to our users and to improve and expand the services we provide as well as the available features in order to grow our business and to inform our marketing strategy.
  • Purpose: Marketing of our products and services and the products of selected partners including, betting and gaming products (where we have appropriate consent).
  • Relevant Categories of Personal Data: Identity, Contact, Technical, Usage, Profile, Marketing and Communications
  • Lawful Bases for Processing: When carrying out direct marketing, we do so based on customer consent. This consent may be withdrawn at any time by emailing customerservices@pocketbet.com
  • Purpose: Delivering the benefits of our products by connecting you to the services and products of our merchants
  • Relevant Categories of Personal Data: Identity, Contact, Financial Transaction, Profile, Usage
  • Lawful Bases for Processing: It is our legitimate interest to promote similar services and products
  • Purpose: Improving our products and website and the overall App user and website visitor experience
  • Relevant Categories of Personal Data: Technical, Profile, Usage
  • Lawful Bases for Processing: It is our legitimate interest to allow analytics and search engine providers to help improve and optimise our website
  • Purpose: Ensure maintenance of a secure connection between our website and your device
  • Relevant Categories of Personal Data: Technical, Profile
  • Lawful Bases for Processing: Necessary to comply with our legal obligationsIt is our legitimate interest to ensure the integrity and security of personal data flowing through our systems
  • Purpose: Initiate action against any user who acts outside any laws, regulations or our Terms and Conditions or Terms of Use policies
  • Relevant Categories of Personal Data: Identity, Contact, Financial, Transaction, Marketing and Communications
  • Lawful Bases for Processing: Necessary for the performance of our contract with you.It is our legitimate interest to ensure protection of our company products, services, and reputation
  • Purpose: Analyse and track use of the website or App for reporting and analytical purposes
  • Relevant Categories of Personal Data: Technical, Usage, Profile
  • Lawful Bases for Processing: It is our legitimate interest to monitor website usage in order to continually improve the user experience

Where personal data is processed because it is necessary for the performance of a contract to which you are a party, we will be unable to provide our services without the required information. If this is the case we will inform you.

Special Category Data

Additionally we may also collect and process certain personal information categorized as "special category data". This may include information revealing records of criminal offences and convictions as well as allegations of criminal offences.

We will not collect or use these types of information without your consent unless the law allows us to. If we do it will only be when it is necessary:

  • For reasons of substantial public interest for example, to help, prevent, detect, and prosecute financial crime, fraudulent behaviour and unlawful acts
  • Where we are obliged to do so as a matter of law or to comply with our legal or regulatory obligations, for example when we need to forward your information to a regulator; or
  • To establish, exercise or defend legal claims.

 

IV. Marketing

You will receive marketing communications from us if you have asked us to send you marketing and you have not withdrawn your consent. You can withdraw consent at any time by clicking unsubscribe whenever we do send you marketing.

 

V. Sharing your information

We will share your personal data outside Gibraltar or the United Kingdom (UK) . We may do this where this is necessary for the purposes of providing our services to you, but we will only share it where appropriate safeguards are in place to ensure your personal data is protected to the same standard expected within Gibraltar and the UK.

We may share your data with service providers and suppliers to our business who process data on our behalf. In such cases, our service providers and suppliers are data processors and may only use the data in line with our instructions and not for any other purpose. This and other obligations are agreed in the contract between PocketBet and the service providers and suppliers.

Our website includes links to our social media pages which enable you to view our content through selected sites. These sites may collect your IP address or Device ID and may set a cookie on your device. When you use one of these links, you are sharing information to another website or service and this Policy will no longer apply. Please read the privacy policies provided by the particular social media website you are sharing through before posting any personal information using these links.

Please see the below list of key external providers with whom we share your data, the purpose of this sharing and where possible a link to their privacy policy.

  • Provider: Worldpay
  • Purpose of sharing: We share payment and personal details relating to your account and payment methods. This is necessary to process payments to and from customer accounts and in order to facilitate the product and contract.
  • Privacy policy: www.fisglobal.com/en-gb/privacy
  • Relevant Categories of Personal Data: Identity
  • Provider: Hooyu
  • Purpose of sharing: We share your personal details relating to your account. This is necessary to satisfy our legal obligations to know our customers.
  • Privacy policy: Privacy Policy (hooyu.com)
  • Relevant Categories of Personal Data: Identity
  • Provider: Emerchant Pay
  • Purpose of sharing: We share payment and personal details relating to your account and payment methods. This is necessary to process payments to and from customer accounts and in order to facilitate the product and contract
  • Privacy policy: Privacy Policy - emerchantpay
  • Relevant Categories of Personal Data: Identity
  • Provider: Checkout.com
  • Purpose of sharing: We share payment and personal details relating to your account and payment methods. This is necessary to process payments to and from customer accounts and in order to facilitate the product and contract
  • Privacy policy: Privacy Policy - Checkout.com
  • Relevant Categories of Personal Data: Identity
  • Provider: W2 Global Data
  • Purpose of sharing: We share your personal details relating to your account. This is necessary to satisfy our legal obligations to know our customers.
  • Privacy policy: Privacy Policy - W2 Global Data
  • Relevant Categories of Personal Data: Identity
  • Provider: Facebook
  • Purpose of sharing: We use Facebook to display adverts based on site usage. Facebook pixels are used for behavioral targeting service. As per Facebook terms and conditions, we're obliged to tell you that (a) third parties may use cookies, web beacons, and similar technologies to collect or receive information from this website and elsewhere on the internet and use that information to provide measurement services and target ads, (b) to opt-out of the collection and use of information for ad targeting, and (c) to access a mechanism for exercising such choice, please visit www.aboutads.info/choices.
  • Privacy policy: Privacy Policy - Facebook
  • Relevant Categories of Personal Data: Identity
  • Provider: Outplayed
  • Purpose of sharing: We share personal details relating to your account and your activity with Outplayed (part of the PocketBet group of companies) to improve and facilitate the services of both products, including allowing you to benefit from our 0% commission promotion, and allowing you to place bets from the Outplayed software. This data is used to allow Outplayed to optimise its advertising to you. If you choose to integrate your account, Outplayed will also be able to view your betting history and account balance.
  • Privacy policy: Privacy Policy - Outplayed
  • Relevant Categories of Personal Data: Identity

 

VI. Sharing or transferring Personal Data outside Gibraltar or the UK

Countries outside Gibraltar and the UK have differing data protection laws, some of which may provide lower levels of protection of privacy. It is sometimes necessary for us to transfer your personal data to countries outside Gibraltar and the UK. In those cases we will comply with relevant Gibraltar and UK data protection laws designed to ensure the privacy of your personal data.

Under data protection laws, we can only transfer your personal data to a country outside Gibraltar or the UK

where the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an 'adequacy regulation') further to Article 45 of the UK GDPR. We rely on adequacy regulations for transfers to the following countries:

  • where there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or

  • a specific exception applies under relevant data protection law for example in order to provide you with a particular service such as making a payment to a non Gibraltar, UK or EEA country.

Where we transfer your personal data outside Gibraltar, the UK or the EEA, we do so usually on the basis of an adequacy regulation or adequacy decision or (where this is not available) through the use of legally-approved standard data protection clauses recognised or issued further to Article 46(2) of the Gibraltar GDPR.

In the event we cannot or choose not to continue to rely on either of those mechanisms at any time, we will not transfer your personal data outside Gibraltar or the UK unless we can do so on the basis of an alternative mechanism or exception provided by relevant Gibraltar data protection laws and reflected in an update to this policy.

Any changes to the destinations to which we send personal data or in the transfer mechanisms we rely on to transfer personal data internationally will be notified to you in accordance with the section on 'Changes to this privacy policy' below.

 

VII. Your rights

The GDPR provides you with certain rights in relation to the processing of your personal data, including to:

  • Request access to personal data about you (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 rectification, correction, or updating to any of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected
  • Request personal data provided by you to be transferred in machine-readable format ("data portability")
  • Request erasure of 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 personal data where you have exercised your right to object to processing (see below)
  • Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you (e.g. if you want us to establish its accuracy or the reason for processing it)
  • Object to the processing of your personal data in certain circumstances. This right may apply where the processing of your personal data is based on the legitimate interests of PocketBet
  • Complain to your local supervisory authority if you are not satisfied with the way we are handling your data. For UK residents, you can complain to the ICO here.

Some of these rights are not absolute and are subject to various conditions under applicable data protection and privacy legislation and the laws and regulations to which we are subject. If at any time you decide that you no longer wish to be contacted for marketing purposes, or if you would like to exercise any of your rights as set out above, you can contact us at customerservices@pocketbet.com .You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

 

VIII. Data retention period

We will retain your personal data for as long as is necessary to provide you with our products and ongoing services and for a reasonable period thereafter, to enable us to meet our contractual and legal obligations and to deal with complaints and claims.

In some circumstances we are legally obliged to retain information to comply with legal obligations relating to crime prevention or gambling-specific regulations.

At the end of the retention period, your personal data will be securely deleted in accordance with the PocketBet Personal Data Retention and Destruction Policy and Schedule.

 

IX. Contact

You can contact PocketBet in relation to data protection and this privacy notice by emailing support@pocketbet.com.

QUESTIONS ABOUT THIS POLICY

For questions or comments regarding our Policy, you can email us at support@pocketbet.com.

Version 2.1: Last Updated: 16 November 2023