Privacy Notice
What data do we collect about you?
For what purposes do we use data about you, and on what legal basis?
Who do we share your data with, and for what purposes?
Who might we receive your data from?
Where might data about you be sent?
How do we protect data about you?
How long will data about you be kept?
What rights and options do you have?
Who should you contact with questions?
Changes to this notice

Privacy Notice

This website and mobile application (the “Website”) is provided to you jointly by ElectraWorks Limited of Suite 6, Atlantic Suites, Europort Avenue, Gibraltar, GX11 1AA (“Operator”) and 8Ball Games Ltd of the Copper Room,Deva Centre, Trinity Way, Manchester, M3 7BG (“Website Owner”) ("we", “us” or “our”).
We are committed to protecting and respecting the privacy of users of the Website (“you” or “your”). This privacy notice sets out how we may use the personal data that we collect from you, or that you provide to us in the course of you using our Website to participate in our gaming and gambling services.  This policy should be read in conjunction with our Cookie Notice, any terms or notices located on the Website and our Terms and Conditions.

What data do we collect about you?

When you are using our Website we may collect certain data about you, such as:
•    Basic contact information that you provide to us
•    Your account details and account profile
•    Your payment details if you make a deposit on the Website
•    Technical information about your device and Website usage
•    Records of how you use our services
•    Records of communications you have with us
•    Other information that you may provide to us voluntarily

The Operator will also collect certain additional data about you in order to comply with its regulatory obligations as the operator of this Website, such as:
•    Proof of age and identity
•    Sensitive information such as any relevant health conditions
•    Information relating to criminal or civil offences
•    Information we obtain from public sources
•    Information from third party databases to comply with our legal and regulatory obligations

Basic contact information
If you decide to register for an account on our Website, then we will collect your name and various contact details such as your home address, country of residence, email address and telephone number during the sign-up process and retain this information as part of your records. You also may provide us with additional contact information (e.g. your mobile number) if you contact our customer support team.

Your account details and account profile
When you setup an account you will provide us with your chosen username and password. You may also provide us with certain additional information about yourself which forms part of your account profile, such as your gender and a profile picture that you choose to upload. You may provide us further information or edit your existing information during the course of using your account.

Proof of age and identity
In order for the Operator to verify your eligibility to use the Website, the Operator collects your age and date of birth. The Operator will also require proof of your identity and address such as a copy of your passport or driving licence along with other documentation such as your citizen card, electoral card or birth certificate and a proof of address such as a utility bill or bank statement.

Your payment details
If you wish to deposit money in order to participate in real-money games on the Website then you will need to provide us with your credit/debit card information. We will also use the same details to pay out your winnings.

Technical information about your device and Website usage
When you use our Website we will collect certain technical information including:
•    Details about your device including IP address, device type, operating system, platform, location data, the browser type and version (including any plug-ins you may be using) and your time zone setting.
•    Information relating to your use of the Website, including page response times, the pages of our Website that you visit, the links that you click on, any products you viewed or searched for, interaction information (such as scrolling, clicks and mouse-overs), methods used to browse away from the page and any download errors.

Records of how you use our services
This may include a log of your betting, gaming and wagering history, deposits you have made, payment methods you have used, your session durations and other transactions made on your account.  We will also hold records of any consent you provide to participate in marketing campaigns or promotions offered by us or through third party suppliers.

Sensitive information
This may include records of any suspected or known gambling addictions or associated health issues that you may have.

Offence information
The Operator may hold information regarding criminal or civil offences you may have committed, where the Operator has been notified by the police or other authority in connection with any potential criminal activity.

Public sources
Where the Operator detects suspicious activity on your account or identify some other regulatory risk, then the Operator may examine and collect information about you from online sources, such as your publicly available social media profiles. This may include your name, occupation, social media profile, and other information you make available to the Operator when you connect with or contact us through a social media account for verification purposes.

Records of communications you have with us
If you contact us with a question or to provide feedback, for instance, we will collect records of your communications with us through chat, email, support tickets that you raise, telephone, and live chat conversations.

Other information that you provide to us voluntarily
This may include data that you provide to us if you enter a competition or prize draw on our Website or the details of any feedback that you provide to one of our online surveys or focus groups.

For what purposes do we use data about you, and on what legal basis?

We use your data for various purposes connected with the Website, including:
•    to setup and manage your account with us
•    to facilitate your use of our gaming and gambling services
•    to administer deposits that you make and to pay your winnings
•    to communicate with you in relation to your use of the Website and provide you with customer support
•    for internal management, administrative and organisational reasons
•    to share information with our suppliers and other third parties where required
•    to perform data analytics and benchmarking

The Website Owner also uses your data to send you offers, promotions or other marketing which we think you may like.
The Operator also uses your data for the following additional purposes:
•    in order for the Operator to carry out the required checks on your identity and enable you to use the Website
•    to monitor your use of the Website for legal/regulatory purposes and fulfil the Operator’s obligations as a responsible operator (e.g. detecting gambling addiction)

In order to use your data we must have a legal basis for doing so. The legal bases that we rely upon are explained further in the “find out more” section below. Except when using any of your sensitive data (e.g. criminal records history) we will only use your data where it is necessary for:
•    the performance of an agreement to which you are a party
•    compliance with a legal obligation to which we are subject
•    a legitimate business interest that is not overridden by your interests, rights and freedoms
where none of the above applies, we will generally request your consent (which we will ask for before we process the data). For sensitive data or information relating to criminal offences, the legal basis that we will rely upon is set out in the below section.

The table below sets out further information about the purposes for which we use data about you, with the corresponding methods of collection and legal basis that we rely upon for its use.

Purpose Method of collection and legal basis for processing
We use your data in the following ways:  
To setup and manage an account with us
•    to collect the data required to set up your account when you register on the Website
•    to identify you each time you login to the Website and retain your account profile information
Method of collection
This information will be provided by you directly when you first setup an account with us and then during the course of using our services.

Legal basis
Necessary for the performance of the contract between you and us in relation to the gambling services.

To facilitate your use of our gambling services
•    to give you access to gambling services available on our Websites and allow you to be identified
•    to retain records of the games you have played along with your playing statistics
Method of collection
This information will be provided by you directly when you first setup an account with us and then collected by us during the course of using our services. We may also collect certain information indirectly from your device or web browser.

Legal basis
Necessary for the performance of the contract between you and us in relation to the gambling services and in all other cases it is necessary to fulfil our legitimate business interests.

To administer deposits that you make and to pay your winnings
•    to process cash deposits that you may decide to make
•    to retain records of the amounts you have deposited and won while playing on our site.
•    to allow you to place stakes and withdraw winnings
Method of collection
The information will be provided by you when you first choose to make a deposit on the Website.

Legal basis
Necessary for the performance of the contract between you and us in relation to the gaming and gambling services.

To communicate with you
•    to provide you with customer support and answers and/or respond to any queries or feedback that you send to us
•    to inform you when you have been awarded winnings
•    to assist you with any technical problems you have with the Website
•    to update you with any changes to our terms and conditions/ other policies
Method of collection
This information is collected when we communicate with you or you communicate with us.

Legal basis
It is our legitimate business interest to respond to communications that you send to us and inform you of relevant information in relation to the services that we provide.
We may also need to inform you of updates to our terms and conditions and other policies (such as this privacy notice) because it is necessary for compliance with a legal obligation to which we are subject.

Internal management, administrative and organisational reasons
•    to manage the traffic on our Website
•    to improve the functionality of the Website
•    to inform decisions as to new products available on the Website
•    to defend ourselves against any future legal actions
Method of collection
This information is collected from you both directly and indirectly.

Legal basis
It is our legitimate business interest to improve our services and defend ourselves against legal claims.

To share information with service providers 
•    see the section Who do we share your data with, and for what purposes? for more information
Method of collection
This may include any of the information we hold about you, whether collected by direct or indirect means.

Legal basis
It is our legitimate business interest to share your data with trusted third parties who provide us with services relevant to our provision of the Website and our gambling services, including customer support, information technology, payments, marketing, data analysis, research and surveys.

The Operator uses your data in the following additional ways:  
To perform data analytics and benchmarking
•    to analyse your use of the Website and preferences in order to send you tailored promotions and offer you a personalised service
•    to understand how the Website is used and in order to personalise and improve your experience with the Website, including by aggregating your data with that of other customers
Method of collection
This information is collected across your interactions with the Website.

Legal basis
It is the Operator’s legitimate business interest to improve our Website and services for our customers improved experience.

Identity and age verification checks
•    to carry out the required checks on your identity for regulatory purposes
•    to confirm you are of the required legal age to use the Operator’s gaming and gambling services and place stakes
Method of collection
This information will be provided by you directly when you first setup an account with us and supplemented by information we receive from certain third parties.

Legal basis
Necessary for compliance with a legal obligation to which the Operator is subject. To facilitate a smooth account registration process, if you open another betting account with the GVC Group, we will use the same verification documents and checks to comply with our legal and regulatory requirements.

To monitor your use of the Website for legal/regulatory purposes
•    to collect data necessary to verify your financial transactions on the Website for any potential breach of our terms of use or any applicable regulations
•    to conduct appropriate anti-fraud checks/audits, which shall take place each month for all players and with new accounts being included in the audits upon their first deposit
•    to analyse your use of the Website and your pattern of play, in order to identify if you are considered to be vulnerable to gambling addictions
•    to identify whether you have chosen to self-exclude yourself from gambling services and therefore should be prevented from using our gambling services
Method of collection
This information is collected indirectly by the Operator through the use of cookies and other tracking technologies that we install on your device and through records we keep of your use of the services.

Legal basis
Necessary for compliance with a legal obligation to which we are subject.

The Website Owner uses your data in the following additional ways:  
To send you offers, promotions or other marketing
•    to send you promotions, offers and bonuses that you may be interested in which relate to the Website Owner’s gambling and gaming services, including from the Website Owner’s other brands and group companies (where you have opted into receiving that type of promotion)
•    via email, post, telephone,  SMS (which includes WhatsApp messenger), push notifications, online inbox or otherwise in accordance with your specified preferences (if applicable)
•    to send you similar information through your account which can be accessed through the Website (including the mobile app)
Method of collection
Your contact details will be collected when you first setup an account with us and may be updated (along with your preferences) from time to time.

Legal basis
It is the Website Owner’s legitimate business interest to send you marketing and promotional materials from time to time.
Where the Website Owner has obtained your consent to send marketing then the Website Owner will instead rely on consent as the legal basis.
If the Website Owner sends you a marketing email or SMS, it will include details on how to unsubscribe from receiving similar marketing messages in the future.  You can also manage your information and update your marketing preferences through the ‘My Account’ section.   Please allow up to 48 hours for any opt out request to be processed.  We may continue to send you relevant service messages about your account and our services if you have unsubscribed from emails or SMS.

To perform data analytics and benchmarking
•    to analyse trends relating to how you and other players use the Website and you and their preferences in order for us to tailor our services more effectively. This may include, for instance, promoting certain games on the Website to accord with current player tastes
•    to analyse your use of the Website and preferences in order to send you tailored promotions and offer you a personalised service
Method of collection
This information is collected across your interactions with the Website.

Legal basis
It is the Website Owner’s legitimate business interest to:
•    improve the Website and services in order to improve your customer experience
•    to send you tailored promotions which are in line with your preferences
•    undertake internal administration for the Website Owner’s financial purposes

In some instances, we may intend to use your data in ways that are not described above. However, we will seek to inform you before doing so.

Who do we share your data with, and for what purposes?

•    The Operator and the Website Owner may share your data between ourselves in order to achieve the purposes outlined above. We may also share data about you with: Certain members of the Operator’s group of companies
•    E-verification companies
•    Payment processors
•    Marketing and data analytics companies
•    Gaming providers
•    IT suppliers
•    Risk and fraud monitoring providers
•    Regulators and other government agencies
•    Any successor service provider that replaces the Operator
•    Other users of the Website and associated Websites

Certain members of our Group
The Operator is a subsidiary of the wider GVC Group (or “Group”) which includes GVC Holdings Plc and all of its direct and indirect subsidiary companies. We may need to share your data with certain members of the Operator’s Group. For instance, we share your data with certain group companies who are involved in providing assistance related to customer relationship management, fraud detection, compliance, customer support, marketing, data analytics, compliance and risk services.

E-verification companies
We use e-verification companies to confirm your eligibility to use the gambling services on our Website when you first register. Our current e-verification provider is called CAMS. As part of this process, your personal data will need to be transferred outside the EEA to Los Angeles, USA (please see below for more details about transfer of your personal data outside the EEA).

Payment processors
We use certain third parties such as payment processors and financial institutions to administer and process payments to and from you.

Marketing
To send you marketing communications in accordance with your stated preferences, we may share your email address with email service providers, SMS providers and mailing houses.

Data analytics
We may use Google Analytics and other data analytics companies to track your Website usage and behaviours, in order to perform an analysis based upon your location, age, betting activity, and preferences in order to provide an enhanced player experience, and for risk and regulatory purposes.

Gaming providers
Many of the games that we host on our Website are developed and managed by third party gaming providers. We will share certain limited data about you with gaming providers to help to provide you with a smooth gaming experience.

IT suppliers
We make use of certain IT providers to support our business, including for services such as customer support, live chat, push notifications, and to send emails.

Risk and fraud monitoring providers
We conduct regular anti-fraud audits and may be required to provide results of these checks to a credit reference or fraud prevention agency or law enforcement.

Regulators and other government agencies
To comply with our legal and regulatory requirements, we may share your data with various government agencies including, but not limited to, verification agencies, public authorities, regulators (including the Gibraltar and UK Gambling Commissions) and law enforcement agencies.

Any successor service provider
The Operator is contracted to provide the gaming and gambling services to the Website Owner. If the relationship between the Operator and Website Owner ends for any reason, then your data may be transferred by the Website Owner to a replacement service provider. You will be notified before this takes place. Alternatively, the Operator may ask if you would like to be transferred to one of its other gaming websites.

Other users of the Website and associated Websites
When you join a gaming room, your username (and nothing else) will be shared with other players who have also joined. These players may be members of the same Website or one of our associated Websites.
If you would like to receive a full list of our suppliers and other third parties who we share your data with then you can get in touch with us using the details provided in the section Who should you contact with questions?

Who might we receive your data from?

Sometimes we may receive information about you from third parties. These third parties may include:
•    Law enforcement agencies
•    Financial services companies such as payment processors and banks
•    Public sources such as social media companies as outlined above
•    E-verification companies
•    Risk and fraud monitoring providers Any gambling support body, such as the UK’s GAMSTOP initiative, that you may have been in touch with (e.g. to help you restrict your gambling activities)
•    Alternative Dispute resolution providers, such as eCogra

Where might data about you be sent?

The Operator stores your data on servers located in Gibraltar and this is accessible by the Website Owner. The Website Owner may also store your data on their own servers.
As with any multinational organisation, the Operator and the Website Owner are both often required to transfer data internationally. Accordingly, data about you may be transferred globally (if your data is collected within the European Union, this means that your data may be transferred outside of it). This includes transfers that have been identified in the previous section: Who do we share your data with and for what purposes.

When using data as described in this notice, data about you may be transferred either within or outside the country or territory where it was collected, including to a country, territory or international organisation that may not have UK and/or EU equivalent data protection standards.

For example, the Operator may transfer your data to our vendors based outside the European Union and the Website Owner may store your data outside of the EU. In all cases, the transfer will be on the basis of a European Commission adequacy decision or we will implement adequate measures, for example the EU Model Contracts, and including appropriate security measures, for the protection of personal data in those countries, territories or international organisations in accordance with applicable data protection laws. If you would like more information about any of the data transfer measures on which we rely please contact us using the details provided in the section Who should you contact with questions?.

How do we protect data about you?

The Operator implements appropriate technical and organisational measures to protect personal data that the Operator holds from unauthorised disclosure, use, alteration or destruction. Where appropriate, the Operator uses encryption and other technologies that can assist in securing the data you provide. The Operator also requires its service providers to comply with strict data privacy requirements. the Operator is ISO27001 certified.

How long will data about you be kept?

The period for which we may retain data about you will depend on the purposes for which the data was collected, whether you have requested the deletion of the data, and whether any legal obligations require the retention of the data (for example, for regulatory compliance). We will not retain data about you for longer than is necessary to fulfil the purposes for which the data was collected.

What rights and options do you have?

UK and EU
You may have some or all of the following rights in respect of data about you that we hold:
•    request us to give you access to it
•    request us to rectify it, update it, or erase it
•    request us to restrict our using it, in certain circumstances
•    object to our using it, in certain circumstances
•    withdraw your consent to our using it
•    data portability, in certain circumstances
•    opt out from our using it for direct marketing; and
•    lodge a complaint with the supervisory authority in your country (if there is one).
You are able to exercise these rights by contacting us using the details set out at Who should you contact with questions? below.

You have the rights set out in the table below:

Right in respect of the data about you that we hold Further detail (note: certain legal limits to all these rights apply)
•    to request us to give you access to it This is confirmation of:
•    whether or not we process data about you;
•    our name and contact details;
•    the purpose of the processing;
•    the categories of data concerned;
•    the categories of persons with whom we share the data and, where any person is outside the EU and does not benefit from a European Commission adequacy decision, the appropriate safeguards for protecting the data;
•    (if we have it) the source of the data, if we did not collect it from you;
•    (to the extent we do any, which will have been brought to your attention) the existence of automated decision-making, including profiling, that produces legal effects concerning you, or significantly affects you in a similar way, and information about the logic involved, as well as the significance and the envisaged consequences of such processing for you; and
•    the criteria for determining the period for which we will store the data.
On your request we will provide you with a copy of the data we hold.
•    to request us to rectify or update it This applies if the data we hold is inaccurate or incomplete.
•    to request us to erase it This applies if:
•    the data we hold is no longer necessary in relation to the purposes for which we use it;
•    we use the data on the basis of your consent and you withdraw your consent (in this case, we will remember not to contact you again, unless you tell us you want us to delete all data about you in which case we will respect your wishes);
•    we use the data on the basis of legitimate interest and we find that, following your objection, we do not have an overriding interest in continuing to use it;
•    the data was unlawfully obtained or used; or
•    to comply with a legal obligation.
•    to request us to restrict our processing of it This right applies, temporarily while we look into your case, if you:
•    contest the accuracy of the data we use; or
•    have objected to our using the data on the basis of legitimate interest
(if you make use of your right in these cases, we will tell you before we use the data again).
This right applies also if:
•    our use is unlawful and you oppose the erasure of the data; or
•    we no longer need the data, but you require it to establish a legal case.
•    to object to our processing it •    to object to our processing it
You have two rights here:
(i)    if we use data about you for direct marketing: you can “opt out” (without the need to justify it) and we will comply with your request; and
(ii)    if we use the data about you on the basis of legitimate interest for purposes other than direct marketing, you can object to our using it for those purposes, giving an explanation of your particular situation, and we will consider your objection.
•    to withdraw your consent to our using it This right applies to any data which we have collected and process based on your consent.
You have the right at any time to withdraw the consent you have provided to us.
•    to data portability This right applies:
(i)    to data that you have provided to us; and
(ii)    if we use that data on the basis either of your consent, or on the basis of discharging our contractual obligations to you.
If both (i) and (ii) apply, you have the right to receive the data back from us in a commonly used format, and the right to require us to transmit the data to someone else if it is technically feasible.
•    to lodge a complaint with the supervisory authority in your country Each European Union country must provide for one or more public authorities for this purpose.
You can find their contact details here:
http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm

Who should you contact with questions?

For the purpose of data protection legislation, the data controllers are ElectraWorks Limited (the Operator) with our principal address at Suite 6, Atlantic Suites, Europort Avenue, Gibraltar, GX11 1AA and 8Ball Games Ltd (the Website Owner) at The Copper Room, Deva Centre, Trinity Way, Manchester, M3 7BG. ElectraWorks Limited is registered with the Gibraltar Regulatory Authority (GRA) and the Operator’s registration number is DP 012717 and you can access the Operator’s data protection register entry http://www.gra.gi/data-protection/rights-register-search/company/428.

If you have any questions, or wish to exercise any of your rights, you can contact Electraworks Limited at dpo@livebingonetwork.co.uk and 8Ball Games Ltd at info@stridegaming.com.

If your country has a data protection authority, you have a right to contact it with any questions or concerns. If we cannot resolve your questions or concerns, you also have the right to seek judicial remedy before a national court

Changes to this notice

We may update this notice (and any supplemental privacy notice), from time to time. We will notify of the changes where required by law to do so.
Last modified 24th May 2018.