Capital Entertainment & Leisure trading as Jack Pott’s Bingo.
The privacy and security of your personal data is of the utmost
importance to Capital Entertainment & Leisure, and we invest heavily in
measures that help to 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. Capital Entertainment & 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 particular purpose for any unconnected purpose unless the person has
agreed to this or would otherwise reasonably expect this.
Capital Entertainment & 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 for which you may
have provided your consent by specifying your choice of medium for receiving
the communication.
Capital Entertainment & 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 to you, rectify that
data and also to request us to delete that data at any
time.
1. Introduction
1.1 Capital
Entertainment & 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 Capital Entertainment & Leisure (“we”,
“us” or “Capital Entertainment & Leisure”), collects and processes Personal
Information of our club members. Capital Entertainment & Leisure is registered
for the purposes of data protection with the Information Commissioner’s Office
in Ireland, 18 Lower Leeson Street, Dublin 2, D02 HE97.
1.3 By using our
Services and registering for membership, you acknowledge that you have read,
and agree to the terms of this Privacy Policy in relation to processing under
legitimate interests.
1.4 This Privacy
Policy is incorporated into, and forms part of our terms & conditions of
membership.
2. 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, through the use of
online forms 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. 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 will result in a termination of your
membership to Capital Entertainment & Leisure clubs. This means you would
no longer be able to visit or play at our clubs unless you were to re-join as a
member.
4. 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
on basis of a legitimate interest. The justification for this is outlined in
4.1 above.
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
and email channels. 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 or by contacting
the Data Protection Officer using the details at the end of this policy.
5. How we use your
Personal Information
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:
• Set-up, administer and manage your
membership, associated accounts and records;
• Receive and respond to your communications and requests;
• Notify you about promotional offers and general marketing;
• Ensure that we are able to fulfil our regulatory obligations regarding your
account, including by verifying the accuracy of any information you give us;
• Comply with our obligations under applicable laws (including, but not limited
to the Gaming and Lotteries Acts);
• Investigate, and assist with the investigation of, suspected unlawful,
fraudulent or other improper activity connected with the services (including,
where appropriate, dealing with requests from regulatory bodies for the sharing
of information);
• Carry out market research campaigns;
• In the event that we sell or buy any business, assets or shares in part or
whole we may disclose your personal details to such relevant third parties
involved.
6. Disclosure of your
Personal Information
We may disclose your Personal Information to any of the following recipients:
• Any company within our Group (including to
its employees and sub-contractors) which assists us in providing the services
or which otherwise has a need to know such information.
• Any contractors or other advisers auditing any of our business processes or
who have the need to access such information for the purpose of advising us.
• Any data processor which enables us to manage systems or processes as part of
any service or promotion offered to our members.
• Any law enforcement or regulatory body which may have any reasonable
requirement to access your Personal Information.
• In the event that we sell or buy any business, assets or shares in part or
whole we may disclose your personal details to such relevant third parties
involved.
7. Marketing
Preferences
7.1 We will not
send you unsolicited information regarding any third party’s products or
services.
7.2 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 Existing
members who registered prior to April 1st 2018 and have not provided explicit
consent to receive marketing information will cease to receive marketing
materials after 25th May 2019.
7.4 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 venue or by emailing dpo@celeisure.com. In addition, requests may be
made in writing to the Data Protection Officer, Capital Entertainment &
Leisure, Barclay House, Pembroke Place, Dublin 2.
8. 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 by contacting
dpo@celeisure.com or by writing to us at: The Data Protection Officer, Capital
Entertainment & Leisure, Barclay House, Pembroke Place, Dublin 2.
We require up to one month in order to respond to such requests.
8.3 Requests for
access to your personal data are free of charge.
9. How long do we keep
your data for?
9.1 We retain
your data for no longer than is necessary. This length of time is different for
each type of personal data that we hold. These retention periods are subject to
change only were deemed necessary by the Data Protection Officer where there is
a defined vital interest under data protection law.
9.2 Data
retention periods:
• Membership information This is the
information we collect at the point of registration Data retained for 5 years
after data subjects’ most recent visit.
• Marketing Preferences These are the marketing channels you give consent
for us to contact you by Data retained for 5 years from consent being given.
• 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 Capital Entertainment & Leisure Data
retained for 5 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 our website (the website’
refers specifically to jackpotts.ie), if appropriate 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. Links from Our App
Our app may contain
links to other websites. Please note that we have no control of websites
outside of www.jackpotts.ie
domain. If a subscriber provides data to a website to which we link, we are not
responsible for its protection and privacy. Always be wary when submitting data
to websites. Read the sites data protection and privacy policies fully.
13. Complaints
Capital Entertainment & Leisure takes the responsibility of
holding personal data 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,
Capital Entertainment & Leisure
Email: dpo@celeisure.com
Barclay House, Pembroke Place, Dublin 2, Ireland
Phone: +353 1 623 6698
Alternatively, you may contact the Information
Commissioners Officer (ICO) directly who are the body responsible for managing
data protection compliance in Ireland.
You can contact the ICO at the following address:
Information Commissioner’s Office
18 Lower Leeson Street,
Dublin 2,
D02 HE97.
Email: info@oic.ie
Phone: +353 1 639 5689