Castle Leisure Membership
Privacy Policy
The
privacy and security of your personal data is of the utmost importance to
Castle Leisure, and we invest heavily into measures that help protect your data
protection rights. This policy describes how and why we collect, store, process
and manage the personal data we hold from our members. The term ‘Personal Data’
refers to any information relating to an identifiable individual or his or her
personal identity. This policy outlines how your data will be processed
lawfully, fairly and in a transparent manner. Castle Leisure does not sell or
rent your personal data to third parties for marketing purposes whatsoever.
We
will ensure that the personal data we process is accurate, adequate, relevant and not excessive, given the purpose for which it
was obtained. We will not process personal data obtained for one purpose for
any unconnected purpose unless the person has agreed to this or would otherwise
reasonably expect this.
Castle
Leisure collects your personal data in order to manage
your membership of our clubs. We also collect your data so that we can send you
marketing information regarding our products, promotions
and services.
Castle
Leisure has appointed a Data Protection Officer (DPO) who is responsible for
ensuring that personal data is managed responsibly throughout the company. You
can contact the DPO using the details listed at the end of this document. You
have the right to see the data we hold on you, rectify
that data and also for requesting us to delete that data at any time.
1.0 Introduction
1.1
Castle Leisure is defined as the data controller with regard
to all of the information contained within this document.
1.2
This Privacy policy sets out the way in which Castle Leisure Limited (“we”,
“us” or “Castle Bingo”), collects and processes Personal Information of our
club members. Castle Leisure is registered for the purposes of data protection
with the Information Commissioner’s Office in the UK (Registration Reference
Z879812X).
1.3
By using our Services and registering for membership, you acknowledge that you
have read, and understand the terms of this Privacy Policy in relation to our
lawful basis of processing.
2.0 The information we collect
2.1
As part of maintaining your membership we collect your Personal Information.
“Personal Information” means any information from which you, as a ‘data
subject’, can be personally identified, including (for example) your name,
email address, home address, telephone number, debit/credit card data or date
of birth.
2.2
We collect your Personal Information when you register for membership at a club,
sign up and use the App and when you email us your details. We also collect
information about the transactions you undertake whilst at our clubs.
2.3
In addition, we may collect Personal Information through surveys which we
undertake. Such surveys are voluntary and are anonymous where possible.
3.0 Your rights as a ‘data subject’
3.1
Under data protection law you retain the following rights over your personal
data outlined in paragraph 3.2.
3.2
The right to access the data we hold about you
The
right to rectification of any data that is inaccurate or incomplete.
The
right to erasure of your data (also known as ‘the right to be forgotten’)
The
right to restrict processing of your data
The
right to data portability
The
right to object to the processing of your data
Rights
in relation to automated decision making and profiling.
3.3
If you exercise your right to be forgotten, this would
result in a termination of your membership to Castle Bingo clubs. This means
you would no longer be able to visit or play at our clubs unless you were to
rejoin as a member.
4.0 Our basis for processing personal data
4.1
For the purpose of managing a regulated business within the Gambling Industry
it is important for us to maintain a membership database. This database allows
us to achieve our regulatory compliance responsibilities and safeguard the
security of our members.
4.2
It is a requirement of our Terms and Conditions that any person who wishes to
attend or partake in the services offered at our premises must register as a
member.
4.3
Information collected and processed for the purposes of becoming and remaining
a member is necessary for compliance with a legal obligation to which Castle
Leisure is subject to. Castle Leisure is regulated by the Gambling Commission,
and under the Gambling Act 2005, must fulfil the primary conditions set out in
the Licence Conditions Codes of Practise (LCCP). This includes [A] To prevent
gambling from being a source of crime and disorder, being associated with crime
or disorder or being used to support crime. [B] To ensure that gambling is
conducted in a fair and open way. [C] To protect children and other vulnerable
persons from being harmed or exploited by gambling.
4.4
In order to keep you up to date with our news and promotional events we create
and send regular marketing information via direct marketing, SMS, email and app notifications. In order to
send you this information we will gain your consent. This is usually obtained
at the point of registration.
4.5
This consent can be withdrawn at any time by speaking to your local club, by
making a request via the app or by contacting the Data Protection Officer using
the details at the end of this policy.
5.0 How we use your Personal Information
5.1
Your Personal Information is processed by us to provide you with the products
and services relating to our business. In particular, we
collect your Personal Information in order to enable us to:
6.0 Disclosure of your Personal Information
6.1
We may disclose your Personal Information to any of the following recipients:
7.0 Marketing Preferences
7.1
We will not send you unsolicited information regarding any third party’s
products or services.
7.2
For new member registration from May 11th 2018, as
part of the Account registration process, you will have the opportunity to
choose whether or not to receive information on our offers and promotions. This
consent is subject to the data retention periods defined within this policy.
7.3
For existing members who registered prior to May 11th 2018,
you were provided with an ‘opt out’ of receiving marketing communication at the
time of registration, and if you have not opted out, we will assume legitimate
business purpose in sending marketing communication. We will include the option
to opt out every time such communications are sent out to you. The product, service or ideals we are marketing to you are the same or
similar to those that you originally consented to receive marketing at time of
registration, and therefore it is reasonable for you to receive marketing
material from us.
7.4
App users have the ability to manage marketing
preferences via the App.
7.5
We will send you promotional marketing information and updates until such time
that you inform us that you do not wish to continue to receive them or do not
refresh your consent upon our request at the end of 5 years from the date of
your consent. You may update your marketing preferences at any time by
contacting your local club, using the App, or through the contact form on our
website (https://castle.bingo).
8.0 Accessing and Updating your Personal
Information
8.1
You may update your Personal Information at any time by contacting your local
club or the company data protection officer using the details below.
8.2
You may obtain a copy of your Personal Information held by us through the
following channels, by contacting our Customer Services team in club, by
writing to us at The Data Protection Officer, Castle
Leisure,
1 City Road, Cardiff, CF24 3TQ, or online via email at data@castlebingo.co.uk. Requests for access to your personal
data are free of charge, and we require one calendar month in
order to respond to such requests.
9.0 How long do we keep your data for
9.1
We retain your data for no longer than is necessary for compliance with a legal
obligation as defined in 4.3. This length of time is different for each type of
personal data that we hold. These retention periods are subject to change only where deemed necessary by the Data Protection Officer where
there is a defined vital interest under data protection law. Life of
membership, infrequent nature of visit patterns.
9.2
Data retention periods:
|
Membership
information |
This
is the information we collect at the point of registration |
Due to lapsed
and infrequent visit profiles, data retained for 10 years after data
subjects’ most recent visit. |
|
Marketing
Preferences |
These
are the marketing channels you give consent for us to contact you by |
|
|
Information required
by legislation |
This
includes data which relates to social responsibility or anti-money laundering
policy |
Data
retained for 10 years after data subjects’ most recent visit. |
|
Data relating
to spend information |
This
includes information on cash or card transactions which take place on or
around our premises in exchange for products or services provided by Castle
Leisure |
Data
retained for 6 years after data subjects’ most recent visit. |
Figure
1.1 data retention periods
10. Advertising and use of Cookies
10.1
We may collect anonymous information about your use of the Website (‘the
website’ refers specifically to www.castlebingo.co.uk) using “cookies”, pixel
tags and similar functionality. We use cookies for the operation of the
Website. We also use cookies for our own analytical purposes so that we can
improve our customers’ experience.
10.2
If you object to cookies or want to delete any cookies that are already stored
on your computer, you should follow the instructions for deleting existing
cookies and disabling future cookies on your web browser or equivalent
software. Further information is available at www.aboutcookies.org.
10.3
As part of the Website’s operation, and for our own statistical analysis of
site traffic, our Website automatically logs internet
IP addresses.
11. Security
11.1
We use a number of methods to ensure that all customer
information remains confidential. We have developed a comprehensive policy for
data protection management which is reviewed and updated as necessary.
12. Complaints
12.1
Castle Leisure takes the personal data we hold very seriously and is happy to
receive any queries or concerns you may have. If you believe that we have not
adhered to this policy or that your data has been handled in a way which you
feel is not in accordance with your wishes then you
may complain to the Data Protection Officer using the contact details below.
The
Data Protection Officer, Castle Leisure, 1 City Road, Cardiff, CF24 3TQ
02920
48 44 22
Alternatively you may contact the Information
Commissioners Officer (ICO) directly who are the body responsible for managing
data protection compliance in the UK.
You
can contact the ICO at the following address: Information Commissioner's Office
Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF
casework@ico.org.uk
0303 123 1113
13. Contact
information
Please
contact us via the contact form on our website or in writing at;
The
Data Protection Officer, Castle Leisure, 1 City Road, Cardiff, CF24 3TQ
02920
48 44 22