PRIVACY POLICY

This policy applies to personal information held about people who visit our websites, use our services, play our games, and our suppliers and prospective suppliers.

In this policy, “we,” “us,” and “our” means (i) Reality Gaming Group Limited, a company registered in Gibraltar with Company Number FC035724 and registered address 6.20 World Trade Centre 6 Bayside Road, Gibraltar, Gx111aa, Gibraltar; and (ii) Reality Plus UK Limited, a company registered in England and Wales with company number 10589824 and registered office of 77 Shaftesbury Avenue, London, W1D 5DU (together, “Reality Gaming“). This policy deals with where we are acting as a ‘data controller’ under the data protection legislation, which essentially means where we are responsible for deciding what personal information we collect and how we use it. We may also operate as a ‘data processor’, meaning that we are processing personal information on behalf of another entity. We talk about that a bit in this policy. When we refer to “personal information” we mean information relating to you personally or from which you can be identified. Some of the information mentioned in this policy is not ‘personal information’ as is meant under data protection legislation, but we may refer to it to help you understand what we do.

We are committed to protecting and respecting the personal information of everyone we deal with – that is important to us and we know it is important to you.

In this policy you will find information about what types of personal information we hold about visitors to our websites, how and why we collect it, how we use it, and how we keep it secure. You will also find here information about your rights and how you can exercise them.

Please read this policy carefully and if you need to contact us about anything that is in here, or for anything else related to your personal information, you can reach us by email at [email protected]

What information do we collect about you?

What information we hold will depend on our relationship with you. Typically, this may include the following:

Website users	If you use our website we may collect information regarding how you interact with the content on our website, which pages you visit etc. We may do this using cookies. Information we collect may include: Internet protocol (IP) address; Unique mobile device identification numbers (such as your Media Access Control (MAC) address); Identifier For Advertising (IDFA); International Mobile Equipment Identity (IMEI); Type of device, 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; Usage data including information about how you use our website, products and services; Marketing and communications data including your preferences in receiving marketing from us and our third parties and your communication preferences.
User of our Services and Players of our Games	If you create an account to play our games, take part in any prize draw/sweepstake, or use any of our other services, we will need to collect information about you in order to provide those services. We may collect some of this information using cookies. Information we collect may include: Name; Email address; Username and account details; Address or place of residence; Date of birth; Game profile data; Social media account details; Internet protocol (IP) address; Unique mobile device identification numbers (such as your Media Access Control (MAC) address); Identifier For Advertising (IDFA); International Mobile Equipment Identity (IMEI); Type of device, 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 the Services; Usage data including information about your gameplay and your use of our websites, and services; Marketing and communications data including your preferences in receiving marketing from us and our third parties and your communication preferences.
Our suppliers	We will collect contact information so that we can manage our relationship with you, and bank account details (to enable payment for services). When you provide services to us we may collect other information from you which is relevant to the provision of those services.
Job applicants	If you apply for a job with us, or send us your CV, we will collect information relevant to the position that you apply for and will keep a copy of your CV for as long as is necessary in order to assess your suitability for a position with us. This will be explained in more detail at the time you make any application.

How we collect information about you

We will collect this information in a variety of ways depending on how we interact with you.

Direct interactions 

You may give us your identity, contact or other information by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

Create an account with us or our Suppliers;
Use our products or services;
Interact with customer services;
Subscribe to our mailing lists;
Enter a competition, promotion, prize draw, sweepstake or survey;
Give us feedback;
Provide services to us.

Third parties or publicly available sources

We may receive personal data about you from various third parties and public sources as set out below:

From Suppliers that provide some of the services on our behalf – for example, we may engage a third party like Gleam to assist with the running of prize draws and sweepstakes. They will need to provide us with personal data about the entrants to those prize draws or sweepstakes.
Third party account ID, game profile and user ID – for example from your account with Facebook, Google, or Twitter.
Technical data from the following parties:

(a) analytics providers such as Google;
(b) advertising networks such as Facebook; and
(c) search information providers such as Google.

References and other information if you apply for a position with us.

Automated technologies or interactions

As you interact with our website we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, pixels, server logs and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies.

How we use your information

We use different information in different ways:

To provide our services to you, including the games we provide and the administration of any free prize draws or sweepstakes;
To send you communications related to our services, answer your enquiries or deal with your complaints;

Allowing you to participate in our website or app features;
Verifying and confirming payments;
Account verification and clearance;
Direct marketing letting you know about products and services that may be of particular interest to you;
Administering surveys and opinion polls;

Business and website analysis and improvement;
The provision of social features as part of our services;
Customising your personal experience;
To send you related information such as updates, security alerts and support messages;
On-site and in-app advertising and promotion of our goods and services and those of our service providers and trusted third parties;

Website, system administration and account verification;
To answer or satisfy legal or regulatory requirements; and
When you interact with third party social networking features to serve you with advertisements and engage with you on third party social networks (we encourage you to review the privacy notices/policies of these social networks to enable you to opt out of such activities).

Legal basis for processing

There are a number of different legal grounds for processing personal information. Which one is applicable will depend on how we are using your information and for what purpose. In the majority of cases this condition will be that:

You have provided your consent to us using your personal information in that way (for example where you provide us with consent to send you marketing communications about our products and services, or have provided your consent to the use of cookies);
Our use of your personal information is in our legitimate interest as a commercial organisation;
Our use of your personal information is necessary to perform a contract or take steps to enter into a contract with you (e.g. to manage your account); and/or
Our use of your personal information is necessary to comply with a relevant legal or regulatory obligation.

In relation to any ‘special categories’ of personal data (including information regarding your health, religious or political beliefs, ethnic background, sexual life and sexual orientation), we confirm that we do not collect and will not be processing any of this type of data.

Our websites and our services are not intended for children under 18 years old and we do not knowingly collect data relating to children under 18.

Sharing your information

The personal information you provide to us may be shared with third party companies, agents, contractors, service providers or affiliated companies if this is necessary to provide you with our services, respond to your inquiries or for any of the purposes described in this policy. This may include:

Our business partners and suppliers;
Sub-processors who store or process information on our behalf, in particular data analytics providers and data storage providers. Information shared with such providers is supplied in an anonymised format such that, that data cannot be linked to any particular individual and is therefore not considered to be ‘personal data’;
Our auditors, insurers, lawyers and other professional advisers;
Credit reference agencies;
Law enforcement agencies, other governmental agencies or third parties if we are required by law to do so;

Other business entities should we plan to merge with or be acquired by that business entity, or if we undergo a re-organisation with that entity.

Transferring your information outside Europe and the UK

Our Service is global by nature and your data can therefore be transferred to anywhere in the world. Because different countries may have different data protection laws than your own country, we take steps to ensure adequate safeguards are in place to protect your data as explained in this policy. Adequate safeguards that our partners may use include standard contractual clauses approved by EU Commission and/or the UK Government.

Your rights

Under EU data protection laws you have a number of rights in relation to your personal data. We respect and honour these rights and will help you to exercise them insofar as we are able.

You have the right:

To request access to a copy of any personal data which we hold about you;
To rectification of your personal data, if you consider that the information we are holding is inaccurate;
To ask us to delete your personal data, if you consider that we do not have the right to hold it;

To withdraw consent to our processing of your personal data (to the extent such processing is based on previously obtained consent);
To ask us to stop or start sending you marketing messages as described below in the marketing section;
To restrict processing of your personal data;
To data portability (moving some of your personal data elsewhere) in certain circumstances;
To object to your personal data being processed in certain circumstances; and

To not be subject to a decision based on automated processing and to have safeguards put in place if you are being profiled based on your personal data.

Please note that these rights are not absolute – in some cases they will not apply to you, or to the particular use that we are making of your data, and there are exceptions (for example if we have to process the data to comply with our own legal obligations) but if that is the case we will let you know if you make a request that we believe we cannot comply with.

Any request from you for access to or a copy of your personal data must be in writing and we will endeavour to respond within a reasonable period and in any event within one month in compliance with data protection legislation. We will comply with our legal obligations as regards your rights as a data subject.

We aim to ensure that the information we hold about you is accurate at all times. To assist us in ensuring that your information is up to date, do let us know if any of your personal details change at the following email address [email protected].

Marketing

If you are one of our customers or have otherwise agreed to be contacted for marketing purposes we may use your personal information to send you information about us and our services. You can unsubscribe from receiving direct marketing at any time and details of how to unsubscribe will be included in any marketing communications we send you. You also have the option of “unsubscribing” from our mailing list at any time thereby disabling any further such e-mail or other communication from being sent to you by emailing [email protected].

You can opt-out of interest-based advertising on mobile applications by checking the privacy settings of your Android or iOS device and selecting “limit ad tracking” (Apple iOS) or “opt-out of interest based ads” (Android).

We will action any opt out request from you as soon as we can.

How long will we keep your information?

We will only keep the information we collect about you for as long as required for the purposes set out in this notice or as required to comply with any legal obligations to which we are subject. This will involve us periodically reviewing our files to check that information is accurate, up-to-date and still required.

By law we have to keep basic information about our customers (including contact, identity, financial and transaction data) for six tax years plus current tax year after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see ”Your Rights” for further information.

Sometimes we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

If you opt out from marketing, we will retain your information to enable us to respect your wishes to not be contacted for marketing purposes.

Security

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect. Such measures will be appropriate to the nature of the data concerned and the level of risk. If you have been provided with a password to access any of our services you should not share that password with anyone else.

Links to Other Sites

Our websites may contain links to other sites, including via our social media buttons. While we try to link only to websites that share our high standards and respect for privacy, we are not responsible for the content, security, or privacy practices employed by other websites and a link does not constitute an endorsement of that website. Once you link to another website from our website you are subject to the terms and conditions of that website, including, but not limited to, its internet privacy policy and practices. Please check these policies before you submit any data to these websites.

Complaints

Questions, comments and requests regarding this policy are welcomed and should be addressed to [email protected].

If you have any concerns about our use of your information, you also have the right (if you are a UK resident) to make a complaint to the Information Commissioner’s Office, which regulates and supervises the use of personal data in the UK, via their helpline on 0303 123 1113.

How we use cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site.

A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the relevant website.

Changes to this policy

Any changes we make to our policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our policy.