Data Controllers

Under the Isle of Man Data Protection Act 2018 and UK Data Protection Act 2018 the contracting brand (“White Label”), together with TGP Europe Limited, a company incorporated in the Isle of Man with Registered Number 122698C having its Registered Office at 22A Castle Street, Douglas, Isle of Man, IM1 2EZ (“TGPE”, “Us, Our, We”), are classified as the data controllers. This means We and the White Label determine the purposes and means of processing personal data of White Label consumers.

We take the privacy of consumer information very seriously and ask consumers of the White Label to read the Privacy Notice available on the website of the White Label carefully as it contains important information on:

• The personal information We collect and why
• What We do with consumer information
• The measures applied to ensure the security of consumers personal data
• Who consumers information might be shared with

What is personal data and special category data?

Under the General Data Protection Regulation (“GDPR”), personal data is defined as any information relating to an identified or identifiable natural person. It can include obvious identifiers like a name but also identification numbers, online identifiers and/or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that person. Special category data includes data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and genetic data, biometric data, data concerning health or data concerning a person’s sex life or sexual orientation.

What information do We collect, for what purpose, and the legal basis for collection?

We collect and process personal data based on one or more of the following legal bases:

Consent: the individual has given clear consent for Us to process their personal data for a specific purpose

Contract: the processing is necessary for a contract We have with the individual or their organisation, or because they have asked Us to take specific steps before entering into a contract

Legal obligation: the processing is necessary for Us to comply with the law (not including contractual obligations)

By using Our websites or by contacting Us by phone, email, or in writing, the consumer may be providing Us with the following information when they open an account with Us or interact with Our gaming platform:

• Name(s)
• Date of birth
• Current address and proof of address
• Proof of identity
• Email address
• Mobile and telephone numbers
• Financial debit card information (in line with current Payment Card Industry Data Security Standard)
• Recordings of telephone calls and email or message communications

When consumers visit Our websites, We may automatically collect the following information:

• Technical information used to connect a computer to the internet
• Login information, geographic location, browser type and version
• Browser types operating system and platforms
• Information about visits
• Financial transactions
• Gaming activities

Cookies

Cookies are small text files that are stored on a computer or equipment when consumers visit certain pages of a website that record certain preferences. We use cookies to track consumers use of the website and services. We may also use cookies to monitor traffic to the website and services and make it easier/more relevant to use.

Information with relevance to cookies may be obtained from third parties (such as financial institutions, identification verification agencies, credit providers, credit reference agencies) for Us to follow legal gaming requirements (e.g. to identify consumers, Anti-Money Laundering, Anti-Fraud, prevention of terrorist financing). These third parties have all been thoroughly vetted as part of Our Information Security Controls and in accordance with the requirements of Our remote gambling licence.

Learn more on cookies by visiting www.allaboutcookies.org

Why do We use consumer information?

We require consumer information to:

• Set up, manage, and administer accounts
• Provide Our services (make/settle/pay Bets, playing games, etc.)
• Improve the quality or service and gaming experience
• Comply with contractual obligations
• Comply with legal, licensing, and regulatory requirements

Consumers personal data may also be used by Us for customer modelling, statistical and trend analysis, with the aim of developing and improving Our products and services. If consumer data is used in this way, then it will be anonymised.

We will only contact consumers about Our products and services if We have their consent to do so. Consumers can freely manage their consent at any time via Our tools within personal details on the White Labels website.

We use personal information in an endeavour to personalise interactions and experiences with Our services. Personalisation or user profiling is necessary for the purpose of delivering and displaying relevant content to Our players which We deem to be Our legitimate interest.

Do We share consumer information?

We may share the personal data We hold about consumers across Our platform to enable Us to better understand their needs and run accounts in the efficient way that is expected.

To ensure We follow legal obligations set by the gaming industry, We may be required to disclose information with specific third parties (e.g. to identify consumers, Anti-Money Laundering, Anti-Fraud, prevention of terrorist financing). As detailed above, these third parties have all been thoroughly vetted as part of Our Information Security Controls, which We are required to follow as part of gaming requirements.

We will not share/sell consumer information outside of Our Platform (e.g. to other gaming companies, or unrelated companies), as this is not part of Our scope of business.

We may need to disclose consumer information to a third party if required by law. In this case, We would follow the law’s strict rules on sharing information.

How long do We retain consumer information?

We will ensure personal data is not kept for longer than is necessary. We will always follow the below controls to ensure that the storage of personal data conforms to this:

• Review the length of time personal data is retained
• Review and consider the purpose for retaining the personal data
• Securely delete personal data which is no longer required
• Ensure personal data held is updated and, when appropriate, is archived securely

What do We do with consumer information?

We are the controllers of the information collected and will only use consumers personal data in the course of provision of services.

We will take all steps reasonably necessary to ensure that consumer data is treated securely.

Information and transactions are transmitted using encryption technology and securely stored in line with Our Information Security Policies.

If consumers are required to send Us debit card information, any card details will always be transmitted securely. Any debit card information stored by Us is in encrypted form and can only be viewed by employees with the appropriate level of security clearance.

The data collected from consumers (including recorded calls) will be transferred, processed and stored at Our dedicated secured offices and data centres. By submitting personal data, consumers agree to the transfer, processing and storing of personal data.

Where We have given consumers a password which enables them to access certain parts of any of Our websites, they are responsible for keeping this password confidential, including not sharing it with other persons. Unfortunately, the transmission of information via the Internet is not completely secure. Although We will do Our best to protect personal data, We cannot guarantee the security of data transmitted to any of Our websites. In addition to the steps that We take to protect personal data, consumers should take steps to help protect themselves against Internet fraud.

Communications & additional information

Outside of Our website, We may communicate any service and transactional information with consumers via email, SMS, phone call or post via the contact details consumers provide upon registering with a TGPE White Label. Any marketing communications will only be sent to the channels consumers have selected in their marketing preferences, which can be found in the Account Settings of the White Label website.

Any communications with files and confidential information transmitted to and from the official communication channels of the White Label may be privileged or contain confidential information which is solely intended for the consumer and for the purpose of the business relationship between the consumer and Us. This may include proof of identity, address, and affordability requests in line with Our internal policies. As touched upon, We will take all steps reasonably necessary to ensure that consumers data is treated securely.

If the consumer is not the intended recipient of any communications sent by Us, please be aware that any disclosure, copying, distribution or use of confidential contents is strictly prohibited and may be illegal. If consumers have received any communications in error with confidential information, they are required to delete the communication and notify Us immediately via the support channels set out by the White Label.

Use of Our communication systems is monitored to secure its effectiveness and for other lawful purposes. Communications will be monitored and may be recorded to secure effective operation and for other lawful business purposes.

We do not accept responsibility for changes made to communications after they are sent. Consumers are advised to scan communications for viruses as We cannot accept liability for any loss or damage which may be caused because of any computer virus. Consumers should take steps to help protect themselves against Internet fraud.

Personal Data Rights

Under the GDPR consumers have several rights to their personal data, which are detailed below:

Right to Access personal data: Consumers have a right to request a copy of their personal information that We hold. We will respond to such a request within one month.

Right to Erasure: Consumers can request for Us to erase their personal data where there is no lawful basis requiring Us to continue processing this personal data. This right only applies in certain circumstances given that Our legal obligations include data retention periods.

Right to Rectification of Personal data: Consumers can request that We correct any personal data that We are processing about them which is incorrect.

Right to be informed: Where the application of a personal data right has impacted on consumers personal data, they have the right to be informed.

Right to data portability: Similar to the right to access personal data, this right allows consumers to obtain personal data in an electronic format that would enable them to transfer that personal data to another organisation, should it be relevant.

Right to restrict / object to processing of personal data: In certain circumstances consumers have the right to object to or restrict the processing of personal data, where this processing is based on consent, contractual obligation or Our legitimate interest.

However, where there are compelling legitimate grounds or legal obligations, We have the right to continue to process consumers personal data.

Rights relating to automated decision making and profiling: Consumers have the right to not be subject to a decision which is based only on automated processing, i.e. without human involvement. In instances where a decision has a legal impact or otherwise significantly affects a consumer, particularly. We confirm that We do not make automated decisions of this nature.

As referred to above, consumers also have the general right to withdraw the consent given Us to process any personal data and where this processing is based on what We deem to be Our legitimate interest.

Consumers have a right to opt-out of any marketing communications, which they can do by opting-out through the Account Settings on the website of the White Label.

Consumers must inform Us of any changes to their information to ensure accuracy is maintained. Consumers can do this by contacting the support teams of the White Label through their website.

If consumers require further information regarding personal data or want to make a complaint, they can contact Us in writing at:

TGP Europe Ltd, 22A Castle Street, Douglas, Isle of Man, IM1 2EZ

Terms of use

Terms of use will be set our in the Terms & Conditions on the website of the White Label after contracting with TGP Europe. These Terms & Conditions would need to be agreed to by the consumer prior to registering and before using our services if there are any version changes.

Support & Complaints

TGP Europe will provide support for all White Labels they contract with, and support channels will be detailed on the website of the White Label, along with a complaint’s procedure.

As part of the licence conditions, TGP Europe are required to provide an independent third party or Alternate Dispute Resolution provider (ADR) should consumers feel that any complaints have not been resolved in a fair, open, and transparent matter. TGP Europe have appointed the Independent Betting Adjudication Services (IBAS) as an approved ADR, however, consumers may wish to raise complaints to alternative ADR’s, provided they are approved under the licence conditions.