1.0 - Introduction
This Policy will be reviewed at least annually and in the below circumstances as required;
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 email@example.com.
In addition individuals in the United Kingdom can also get in touch with our UK data protection representative as follows:
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.
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.
We may use your data for the following purposes and on the following lawful bases:
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:
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.
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.
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.
The GDPR provides you with certain rights in relation to the processing of your personal data, including to:
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 firstname.lastname@example.org .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.
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.
You can contact PocketBet in relation to data protection and this privacy notice by emailing email@example.com.
QUESTIONS ABOUT THIS POLICY
For questions or comments regarding our Policy, you can email us at firstname.lastname@example.org.
Version 2.1: Last Updated: 16 November 2023