This policy sets out how Genting Alderney Limited, a company incorporated in Alderney (Company Number 1664) (“Genting”) will use your personal data.
For the purposes of this policy your “personal data” means data which relates to you and from which you can be personally identified.
We keep this policy under regular review. If we change this policy we will display the current version on this website to ensure that you are aware of and consent to relevant changes.
This policy as updated from time to time, shall continue to apply in respect of processing of your personal data and by providing your personal data to your personal data to Genting and/or using the services you consent to the processing of your personal data as set out in the current version of this policy.
This policy applies to all websites operated by Genting from time to time, including but not limited to, gentingcasinos, PCH Prizes, DTDPoker, and gentingpoker.com (the “Sites”)
1. THE PERSONAL DATA WE COLLECT ABOUT YOU
- 1.1 We may collect personal data relating to you, including but not limited to:-
- 1.1.1 name and date of birth;
- 1.1.2 postal address, email address, telephone number, credit or other card payment details;
- 1.1.3 copies of proof of identity / proof of address;
- 1.1.4 financial status and spend and Genting Reward point spend;
- 1.1.5 details of your gaming and financial activity on the Sites,
- 1.1.6 details of your visits to our Sites including traffic data, location data, weblogs and other communication data;
- 1.1.7 records of correspondence, or our business or payment providers;
- 1.1.8 gender nationality and ethnic origin;
- 1.1.9 CCTV and audio recordings or photographs;
- 1.1.10 Gambling activity and use of other Genting services;
- 1.1.11 Your use of social media, the identifiers you use for those purposes (e.g. Twitter handles) and personal information you or others publish on social media channels.
- 1.2 We obtain this personal data from you:-
- 1.2.1 Directly when you register on our Sites, participate in social media channels, or participate in promotions and competitions which we run;
- 1.2.2 indirectly via Genting Casinos UK Limited, operator of landbased casino facilities in the UK where you instruct them to open an online account for you.
- 1.3 We may process personal data about you received from third parties, including but not limited to personal data received from “Genting Group Companies” (which means Genting Berhad and Genting Hong Kong Limited and their subsidiary companies, jointly controlled entities and associated companies) credit reference bodies, regulatory and law enforcement authorities, and other casino operators, for reasons including the prevention and detection of crime, for the delivery of our services (for example conducting appropriate checks and risk assessments to facilitate the provision of services) to maintain our regulatory accreditation and/or otherwise comply with our legal and regulatory obligations.
- 1.4 We may also obtain personal information from third parties which we use for marketing purposes.
2. USE OF YOUR INFORMATION
- 2.1 We may process your personal data:-
- 2.1.1 to offer and provide services;
- 2.1.2 to verify, set up, activate operate and/or manage your account on the Site(s) on an ongoing basis;
- 2.1.3 to verify your details, carry out security or financial checks and to conduct risk assessments and/or the provision of information to appropriate third parties for identification or verification checks and/or to facilitate the processing of your transactions on an ongoing basis;
- 2.1.4 to contact you by post, email, text, telephone, social media or other means about existing or future services, products and promotional offers and loyalty incentives, or to inform you of service changes and/or Genting activities or those of Genting Group Companies;
- 2.1.5 to maintain our records, including but not limited to transaction records required for audit and regulatory compliance, and to monitor player activity;
- 2.1.6 to compile and aggregate data for monitoring and analysing Site and service usage. We may also provide such aggregate data to third parties;
- 2.1.7 to send you important communications to inform you of important service changes, technical updates, account changes, or changes to our terms and conditions;
- 2.1.8 to customise services, products, communications and casino experiences to you, including through the use of ethnic origin data and financial details;
- 2.1.9 to make any disclosure required by law;
- 2.1.10 by providing your personal data to other casino operators, service providers, banks, or financial institutions, the International Association of Casino Security and similar bodies and associations in the interests of security, good practice, or safety reasons as well as the prevention and detection of crime, cheating, fraud, money laundering or other impropriety or risk;
- 2.1.11 by providing your personal data to regulatory, judicial, and other authorities for security or safety reasons, including but not limited to the prevention and detection of crime, cheating, fraud, money laundering, or other impropriety or risk;
- 2.1.12 generally and on an ongoing basis to prevent fraud, cheating, money laundering or other financial risk and/or to uphold gaming integrity;
- 2.1.13 by providing your personal data to our customer service and marketing agencies for research and analysis purposes, so that we can improve and monitor the goods and services we provide and tailor them to your preferences/activities;
- 2.1.14 by providing your personal data to our service providers who help us to provide you with services and marketing, for example a mailing house used to distribute promotional material;
- 2.1.15 by providing your personal data (typically basic information such as your name and contact information to social media operators including but not limited to Facebook and twitter to facilitate Genting marketing to you via the social media channels you participate in. Use by those social media operators for that purpose will be subject to the privacy policies and terms they provide to you and where applicable the privacy settings you have selected on those channels and the consents you have given those operators in relation to the use of your personal data.;
- 2.1.16 to verify details, account setup, operation or management;
3 OPT OUT
- 3.1 You have the right at any time to “opt out” of the receipt of marketing communications from Genting and can tell us you wish to do this as follows:-
- 3.1.1 You can opt out of email marketing updates and offers by clicking the “unsubscribe” link in relevant email communications; or
- 3.1.2 You can opt out by informing us of your wish to opt out of receipt of marketing communications by writing to us at:- firstname.lastname@example.org.
- 3.2 If you use social media, you may also be able to opt out of receipt of tailored marketing from the social media operator by adjusting your privacy settings or preferences on the relevant social media channel. You should check the relevant social media channel for details of how to do that.
- 4.1 Cookies are text files placed on your computer to collect standard internet log personal data and visitor behaviour personal data. The personal data is used to track visitor use of the website and to compile statistical reports on website activity. For further information about cookies visit, www.aboutcookies.org, or www.allaboutcookies.org.
- 4.2.1 to authenticate you and your account on our Sites so we can provide our services to you;
- 4.2.2 to allow you to login to the Sites and check that your computer is still logged in to the same session and to enable browsing from page to page;
- 4.2.3 to automatically collect information about bets and account transactions on our Sites for marketing and/or regulatory purposes;
- 4.2.4 for analytical purposes to improve the performance of the Sites;
- 4.2.5 to deliver content and service adverts appropriate to your preferences;
- 4.2.6 to compile reports on website activity and usage, either for ourselves or third parties.
- 4.4 You can stop the tracking cookies by altering your browsers privacy settings to block third party cookies. To find out about how to manage cookies please visit www.aboutcookies.org. Note however, that disabling cookies on your browser may impair the function and/or availability of features of our Sites.
5 HOW WE PROTECT YOUR PERSONAL DATA
- 5.1 Genting is committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure we have put in place internal control procedures to safeguard your information. Your information will be stored electronically, protected by firewall and encryption technology. Data on our secure pages is also encrypted using Secure Sockets Layer (“SSL”);
- 5.2 We have put in place the following security procedures and technical and organisational measures to protect your personal data processed by Genting:-
- 5.2.1 all processing of personal data is protected using ISO27001 compliant procedures. Physical and logical security measures are deployed so as to strictly limit data access to authorised personnel and include the use of firewall software and hardware, and a minimum of 256 bit encryption for all transfer of data. Physical access to our database servers is permitted only by fingerprint scanning for named personnel;
- 5.2.2 firewalls: the server on which the data resides is protected by a firewall;
- 5.2.3 browser certification technology;
- 5.2.4 limited access: The internal procedures of Genting cover the storage access and disclosure of your personal data.
- 5.3 Unfortunately, Genting cannot and does not guarantee the security of information disclosed online. You accept the security implications of using the internet and will not hold us responsible for any breach of security unless we have been negligent. Further you acknowledge and agree (as per our terms and conditions of account sign up) that you are responsible for maintaining the secrecy of your account ID and password on the Sites and that Genting cannot and will not be held responsible for any failure by you (or others) to ensure the continued secrecy of this information.
6 OVERSEAS TRANSFERS
- 6.1 Owing to the global nature of our services and the parties we engage to help deliver those services, from time to time, your personal data may be transferred to countries outside of the European Economic Area (“EEA”) or white listed jurisdictions and/or to jurisdictions that do not have similar protections in place regarding your personal data and restrictions on its use as set out in this policy (including but not limited to transfer to Genting Group Companies). In such instances we may transfer your data outside of the European Economic Area and/or white listed jurisdictions, subject to our taking reasonable steps to ensure that adequate protections are in place to ensure the security of your personal data. Genting Group companies will process your personal data in accordance with ISO27001 compliant procedures.
7 ACCESS TO AND UPDATE OF YOUR PERSONAL DATA
- 7.1 You have the right to request a copy of the personal data that we hold about you. You may make a data subject access request by writing to: The General Counsel, Genting Alderney Limited, Genting Club Star City, Watson Road, Birmingham, B7 5SA. We may make a small charge for this service. You should also be aware that any disclosure will be subject to the requirements of the Data Protection Act and we are not obliged in all instances to provide all personal data held, notwithstanding the request and/or payment of our nominal fee.
- 7.2 We want to ensure that your personal data is accurate and up to date. If any of the personal data that you have provided to Genting changes, including but not limited to your name, address, contact or financial details, then please inform Genting of your updated details by visiting your nearest casino, or by completing the “Contact Us”.
8 OTHER SITES AND THIRD PARTY ORGANISATIONS
- 8.1 Our Sites may contain links to other websites not owned or operated by Genting and we may also provide marketing communications to you through other websites (for example social media channels) or through the placement of marketing materials and links to our Sites on other websites. This policy only applies to Genting’s use of your personal data, so when you access other websites you should read the terms and policies that apply in respect of those websites to understand how the operator of that website uses your personal data, Genting accepts no liability in respect of those websites and their operators’ use of your personal data
- 8.2 We may offer you opportunities to agree to receive information directly from third party organisations which offer products or services which we feel may be of interest to you.
Genting Alderney, [13.01.2015]