Privacy and Cookies Policy

Our Promise

We are committed to protecting and respecting your personal data and your privacy. This Policy explains when and why we collect & use your personal information, how we use it, the conditions under which we may disclose it to others and how we keep it secure. It also explains your rights as a customer.

By registering as a customer, you agree to the terms set out in this policy. We reserve the right to update and amend this policy at any time, however when we do we shall notify you on our website via pop ups and where possible by email. Continued use of the service after we’ve notified you of any changes confirms your agreement of the policy.

Who We Are

We are Bear Group Ltd, a UK and Alderney licenced gambling company based in Guernsey. Bear Group is a wholly owned subsidiary of Gaming Realms PLC (“Gaming Realms”), a UK company listed on the London Stock Exchange. For the purposes of data protection, Gaming Realms is the ‘data controller’ in respect to your personal data, and any referral to ‘we’ throughout this policy refers to Gaming Realms and its subsidiaries.

Information We Collect About You

To provide a great gaming experience and comply with our legal and regulatory obligations, we need to collect and store your personal data when you create an account and use our service. We can collect this via the various methods set out below.

Information you provide to us

We collect personal information that you provide directly to us, for example on registration or updating your account details, via customer support, when you report a problem, via chat or when you agree to receive our marketing communications. We observe and collect information as you use our service such as playing our games, making a deposit or interacting with our site.

We will also store information such as dates and times of your play, logs of errors and crashes and other system activity as you use our services.

From time to time, with your consent we will also collect information from you via customer satisfaction surveys or feedback on social media and emails.

Information we get from your device

We collect information directly from the device you use to access our service, for example the following: your IP address, device ID, operating system, browser information and location data. We may also collect logs of crash data (observed when using our service) direct from your device. With regard to your visits to this website and all associated Gaming Realms websites we automatically collect the following information:

  • technical information, including the Internet Protocol (IP) address used to connect your computer to the internet, browser type and version, time zone setting, browser plug-in types and operating system;
  • information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); 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.

Information provided by cookies

We collect information from cookies and use them frequently around the site for personalisation, marketing and troubleshooting. Please read our Cookies section further down to find out all about how we use cookies.

Information From Other Companies

To comply with our legal and regulatory obligations, we sometimes need to collect information from other sources.

We will do this when we need to verify information you have given us and to confirm you are over 18 years of age and will do so by using services such as GB Group Plc and Experian. In some cases we may need to verify further information as you continue with us as a customer, to do this we use other organisations and companies who collate information to help with the prevention of crime and fraud.

We will also consult publicly available information such as council registers, post office data, companies house and social media to confirm information we may need.

To comply with our obligations in relation to responsible gambling we will receive information about you if you’ve registered with the Gamstop National Exclusion Scheme.

How We Use Your Personal Information

In order to provide a service

We require your personal information in order to provide you with an account, deal with queries and allow you to access games and our content. Technical information that we gather is used to provide correct versions of software and to help troubleshoot any issues you may have. We may use your information to:

  • ensure that content from our Websites are presented in the most effective manner for you and for your computer;
  • administer our Websites and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • allow you to participate in interactive features of our products and services (where applicable), when you choose to do so;
  • keep our Websites safe and secure; send you communications which you have requested and that may be of interest;
  • complete certain transactions with you.

If you object to your data being used for this reason, your option is to not use our service and request your account to be closed.

To comply with Legal and regulatory obligations

We are regulated by both the UK Gambling Commission and the Alderney Gambling Control Commission, and to comply with both agencies we are obliged to ensure that all of our customers play legally and responsibly. This is done via regular checks on customers, audits and regulatory reporting. These regulations also set out some of the timescales that we need to hold onto your information for.

We are committed to responsible gambling, and as such we monitor customers’ gambling behaviour and use various sets of information such as age, gender, location and deposit patterns in order to identify common issues. It’s vital that we’re able to do this work, which allows us to detect problem gamblers at an earlier stage and help them with support.

As an industry, we are highly aware of the risks of fraud, money laundering and other crimes. As such we carry out verification at various stages of the customer journey, validating information you’ve provided against various other databases and information from fraud prevention agencies. Where we detect any potential fraudulent activity and suspicious transactions, we will share data with the required regulators. Where necessary we will pass information onto law enforcement agencies and other official organisations.

If you object to your data being used for this reason, your option is to not use our service and request your account to be closed.

To improve the quality of our service to all customers

We use customer information to help personalise and give the best experience possible while using our services, and it’s within our legitimate interests to do so. This includes providing suggestions of games you would like to play, customising offers that might be appropriate to you and tracking which parts of the service players use most. It is a core part of our business to ensure that our service is constantly improved and is ran effectively and efficiently, and we require your data in order to do so.

If you object to your data being used for this reason, your option is to not use our service and request your account to be closed.

Direct Marketing

To keep you up to date with all our site offers and new games, we love getting in touch with all our customers via email, text, phone or post. You have a choice about whether or not you wish to hear from us. You will need to opt-in to all marketing preferences and if you decide you don’t want to hear from us you can select not to receive this communication either at registration or at any time from your Contact Preferences within your Manage Account section. You can also opt out directly from an email campaign by clicking ‘unsubscribe’ or replying to an SMS with the correct STOP message detailed inside. Alternatively you can request this via customer support, who will update your preferences for you at any time. We will not contact you for marketing purposes unless you have given us your express prior consent to do so.

Please note that we may still need to send you important information regarding your account via these methods, these controls are for marketing and promotions only.

Social Media

We often use Social Media such as Facebook and Twitter to advertise our services. Although you may have opted out of direct marketing, in order to not see generic adverts from us you can change your settings within each social media platform to customise which adverts you do not want to see.

Push notifications

If you use our services via one of our apps, we may send push notifications from time to time. You can change whether or not you wish to see these when you first install the app, or at any time after through your device settings.

3rd Party Marketing and Partner Sites

With your prior consent, we may pass your information onto one of our business partners or to other selected third parties to enable them to send you information which may be of interest to you, but only if you have given us permission to do so.

Cookies

Cookies are small text files that are stored in your browser when you visit websites. They are essential to keep certain parts of our site running correctly and securely. They are also used to personalise your online experience to make it more relevant to you and also to provide usage data back to us. They can also be used to present you with more tailored advertising content. For them to work as required, some personal information must be used from you when you use our site. You can choose whether to accept or reject some or all types of cookies and control this through your device’s browser settings and we also make you aware of this by showing you our cookie banner when you visit our site. By using our site without restricting them in your browser, the types of cookies we use are outlined below:

Necessary and Functionality Cookies

These Cookies are essential for you to navigate the site correctly and log in to the secure areas. They also enable us to deliver content specific to your device.These Cookies allow our websites to remember choices you have made, such as your username or region. They help us keep you logged into your account as you navigate around our website. We also use them to personalise your experience by, for example, showing more relevant onsite content. Without these cookies you may not be able to access your account or play games so they are vital to keep the site functioning as intended.

Analytical cookies

These Cookies collect information about visitor activity on the website so that we can monitor performance. For example how many people visit certain pages, the number of people who see specific content. They also ensure we can pay our marketing partners correctly for users they refer to us. Without these cookies you will still be able to login and play on the site without an effect on your online experience.

Targeting Cookies

These cookies are used to deliver adverts and content that are more relevant to you as well as to limit the number of times you see a particular advertisement and to measure the effectiveness of advertising campaigns. The Cookies remember that you have visited a website, and we share this information with other organisations for advertising purposes. We also use them to test and improve our products and services by, for example, testing out different product experiences with different groups of customers to see which is most popular. Without these cookies you will still be able to login and play on the site but may not receive the most relevant content.

Tracking Cookies

We use cookies placed by third parties to collect personal information about your browsing activity, which they then group with data about what other people with similar interests in similar demographic groups are looking at. The resulting information is used to show you online adverts based on those interests (this is known as ‘online behavioural advertising’). will still be presented with advertising but it is unlikely to be relevant to you. Without these cookies you will still be able to login and play on the site without any effect on your experience.

Controlling my cookies

All modern browsers allow you to see what cookies you have, and to clear them individually or in their entirety by changing your cookie settings. Cookie settings are typically found in the 'options' or 'preferences' menu of your browser, otherwise you should use the 'Help' option in your browser for more details. You may also find the links below helpful:

How We Might Share Your Information

Companies that provide us with a service

As a very standard approach, we share your data with other companies who provide a service to us in order to fulfil our agreement with you. All of these companies have been vetted to ensure they offer the same level of protection to your personal data and are covered by contracts to confirm that they will not misuse or pass on your data.

The types of companies we share your data with are:

  • Direct Marketing tools (to send emails, texts and print marketing)
  • Other Gaming Realms subsidiaries (for support, marketing functions, customer insights)
  • Online advertising tools
  • Payment processing
  • Game suppliers (for both gameplay and tournaments/competitions)
  • Verification checks, ID checks and anti-fraud detection
  • Web hosting & data storage services
  • Data analytics
  • Customer feedback tools and market research
  • Regulatory bodies & law enforcement agencies
  • Gamstop (National Self Exclusion scheme)

Fraud detection and legal bodies

As covered in ‘Legal and regulatory obligations’ above we may need to share your information with agencies who help detect fraud and verify details, and if necessary any regulatory body or law enforcement agency when required.

Although exceedingly rare, If we do receive a request for your data from a law enforcement or other body of authority, we will not pass on any information until we’ve received correct documentation, such as a court order, warrant or other valid proof of authority.

Sending information outside of the EU

While transferring data to and from our group companies or to third parties, we may transfer your data outside of the EU. However, we will only do this when we are assured that the company we are transferring to will meet the same data protection standards as those in based the EU.

Publicity

We will not use your personal data for any publicity without your consent. If we wish to publicise a large win and you don’t wish to take part, we will only use vague demographics that cannot be tracked back to you, such as gender and city location.

Other circumstances

If you play multiplayer games such as Slingo Boom or multiplayer poker, your username will be public and shared to other players in the room. This is also true if you take part in leaderboard tournaments. We will never use your real name for these features.

In the case of an ownership change or part or all of our business, we would transfer your data to the new owner to ensure a smooth transition of the service. We will ensure that your privacy rights are protected during this time, and any movement of data is done securely.

If we need to share your data for any another reason than mentioned above on an ongoing basis, we will update this privacy policy to reflect that.

How Long We Store Your Information

We store your data only as long as necessary to provide a service to you, and to comply with our legal and regulatory obligations during this time and after our relationship has ended. Once you have stopped using the service, we are required to hold onto your data for a period of time in order to satisfy various requirements, such as but not limited to: anti-money laundering, audit requirements, compliant handling, licence requirements and protection of problem gamblers.

As soon as your data is not covered by any of these requirements and we have no valid reason to hold onto it, we will delete any personal data that can be used to identify you. We may continue to store transactional and behavioural data for reporting purposes such as helping with responsible gambling, however we will anonymise any data we keep for this purpose.

Your Privacy Rights – how you can access and update your information

As the personal data belongs to you, you have certain rights when it comes to what we do or provide with your data. For all privacy requests that you cannot do from your account, please send through your query to customer support with as much detail as possible.

For any requests where we are providing data back to you, updating or amending records we will ask for valid proof of identity to confirm you are the correct account holder. Once we have this, we will comply with your request within 30 days, or inform you why we are unable to do so.

Right of access

You have a right to see and understand what personal information we store on you. If at any point you would like a copy of this information, please send a request through to customer support.

Your Right to rectification

We are obliged to make sure the personal information we store on you is correct, so if you know anything is out of date or an error, please contact customer support as soon as possible. In some cases we may need to keep records of previous personal information.

Your right to erasure

You have the right to request erasure of your personal data, for example if you believe we are storing it unlawfully or without valid grounds to continue to hold it. While we will always comply with requests where we can, we are unable to delete information which we are required to hold for legal, financial and regulatory requirements.

If we are unable to erase your information due to this, we will close your account and make sure that no marketing or behavioural processing happens. However, we will continue to store the data securely until our licence no longer requires us to do so, or we are instructed to do so by the courts or our regulators.

Your right to data portability

If at any point you would like a machine-readable format (such as a csv) of your personal data, this can be arranged for you. Please specify what data you are looking for to customer support and we’ll arrange to have this transferred to you. If you wish for us to transfer this directly to a different company, you must state this in writing via post or email to us so we have your consent to do so.

Your right to object

If at any point you object to how we are processing your data for any reason, you may object. Where we can comply we will stop processing, however please note that for core processing activities our only way to comply may be to close your account. Please contact customer support if you have any queries regarding this.

Links To/From Other Websites

We may provide links from our websites to other organisations or companies from time to time. This Policy applies only to our Websites. Please note that other organisations will have their own privacy policies, which we advise you read and understand before providing any personal data to them. We are not responsible for the policies of any third party links, and you should direct any queries regarding their policies or use of data to the site’s owner.

In addition, if you linked to our Website/s from another third party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party site and recommend that you check their privacy policies.

How We Keep Your Data Secure

When you provide us with personal information, we take steps to ensure that it’s treated securely. We use strict procedures and security features to try to prevent unauthorised access.

We have implemented secure technology and policies to safeguard your privacy from unauthorised access and improper use, and continuously evaluate our procedures. We abide by ISO27001 principles, are PCI compliant and undergo a regular security standards audit as part of our UK licence obligations.

What You Can Do To Keep Your Data Safe

If you use our services while on a shared device, remember to log out securely and if on a public computer we advise that you clear cookies from the web browser used. Never let anyone else share your account and keep your password safe, not even our customer support agents will ask you for your password at any time. You are responsible for keeping the password confidential and we ask you not to share your password with anyone. When you set your password, remember to choose something complex and never use the same passwords on multiple websites.

How To Contact Us

In order to exercise any of your rights described above or for general queries please contact customer support.

For all queries relating to this Policy or if you wish for further technical detail around our data protection principles, please contact below:

Email: dataprotection@gamingrealms.com

Post:
Data Protection
Gaming Realms Plc
One Valentine Place
London, SE18QH

Complaints

You have the right to lodge a complaint with the Information Commissioner’s Office in the UK if you think we have acted improperly in relation to your personal data. You can find a link to the Information Commissioner’s website here: www.ico.org.uk

REVIEW OF THIS POLICY

We keep this Policy under regular review. This Policy was last updated on: 22nd May 2018


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