Mobile Gaming Technologies, Inc., CashBet Alderney Limited and all affiliated entities (We, us, our) are committed to protecting and respecting your privacy and are subject to the Principles regarding all personal data received from the EU and/or Switzerland in reliance on Privacy Shield.
For the purpose of the Data Protection Act 1998 (the Act) and the General Data Protection Regulation (GDPR), the data controller is CashBet Alderney Limited of Inchalla, Le Val, Alderney GY9 3UL. CashBet has been certified by Privacy Shield and is GDPR compliant. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/. This policy is effective as of May 25, 2018. To learn more about the GDPR and the privacy rights it affirms, see https://www.eugdpr.org/eugdpr.org.html.
We take our players’ privacy rights seriously. We’ve expanded our protections on your behalf and in accord with the rights described in the EU’s General Data Protection Requirement (GDPR). GDPR grants the right of access and the right to be informed. These broadly mean people will have the right to know who is processing their data and why.
We summarise the rights that you have under data protection law below. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights. For more, please see the GDPR’s Chapter 3 Rights of the Data Subject here: https://gdpr-info.eu/chapter-3/.
Your principal rights under the GDPR-enhanced data protection law are:
– the right to access personal data that is stored and processed by CashBet
– the right to rectification should you find and establish inaccuracies in CashBet personal data
– the right to erasure – subject to CashBet legal obligations
– the right to restrict processing including direct marketing and subject to CashBet legal obligations
– the right to object to processing
– the right to data portability – you can request that CashBet transfer your personal data to a service of your choice
– the right to complain about a CashBet-related personal data policy or incident to a supervisory authority – in the UK, that is the Information Commissioner’s Office (ICO) https://ico.org.uk. For a list of each EU state authority, see: http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.
– the right to withdraw consent subject to CashBet legal obligations
CashBet is legally obligated by Anti-Money Laundering and Terrorist Financing laws to collect and evaluate personal information from players with whom CashBet has a legitimate “business relationship.”
Our licensing is contingent on full support for the Action Task Force (FATF)-compliant Know Your Customer (KYC) and Anti-Money Laundering (AML) protocols. CashBet is compelled to store and update personal data, including some that is contingently processed or collected when deposit and withdrawal amounts trigger enhanced customer due diligence.
In support of the identity theft protocols noted above, CashBet currently maintains player information on account for 5 years. CashBet has a process in place to automatically erase player personal data 5 years after the account is closed. This policy is compliant with the GDPR.
You have the right to confirmation as to whether or not we process your personal data and where we do, and access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access your personal data by requesting it from CashBet as described below.
You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: [the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed]. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary for compliance with CashBet’s legal obligation as described above; or for the establishment, exercise or defence of legal claims.
In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise, or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
You have the right to receive your personal data from us in a structured, commonly used and machine-readable format.
If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement. For the United Kingdom, you may lodge a complaint with UK-designated supervisory authority: the Information Commissioner’s Office (ICO) https://ico.org.uk.
In addition, you may seek independent dispute resolution from other appropriate bodies designated to address complaints and provide appropriate recourse free of charge to you. For individuals protected under the EU-U.S. Privacy Shield, contact the European data protection bodies listed here. For individuals protected under the Swiss-U.S. Privacy Shield, you may contact the Swiss Federal Data Protection and Information Commissioner, here. We are subject to the investigatory and enforcement powers of the US Federal Trade Commission (FTC).
We comply with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. We certify that we adhere to the Privacy Shield Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal. Nor will it affect the legal obligations that govern CashBet’s legitimate interest in retaining certain types of personal data.
You may exercise any of your rights in relation to your personal data the methods described in the Contact section below and here:
– During registration you will be apprised of CashBet personal data requests and prompted for consent
We may collect and process the following data about you:
– Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform,
– Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time), bets or wagers you placed, web pages you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
We use information held about you in the following ways:
– Carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us,
– Provide you with information about other goods and services we offer that are similar to those that you have already used,
– Notify you about changes to our service,
– Ensure that content from our site is presented in the most effective manner for you and for your computer.
– To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes,
– To improve our site to ensure that content is presented in the most effective manner for you and for your computer,
– To allow you to participate in interactive features of our service, when you choose to do so,
– As part of our efforts to keep our site safe and secure,
– To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you,
– To make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
We may share your information with selected third parties including:
– The Alderney Gambling Control Commission or the Gambling Commission or the Independent Betting Adjudication Service to comply with our regulatory obligations and/or in connection with any application for arbitration concerning your relationship with us.
– Our business partners, suppliers and sub-contractors for the performance of any contract we enter into with them.
– Credit reference agencies or other third party service providers who will check or authenticate you.
– Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience.
– Analytics and search engine providers that assist us in the improvement and optimisation of our site.
We may disclose your personal information to third parties:
– In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets. CashBet will notify you of such an event well in advance, and affirm GDPR compliance on any such buyers.
– If CashBet Alderney Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site, any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.