MERKUR Bingo and Casino Entertainment UK LTD
Membership Privacy Policy
The privacy and
security of your personal data is of the utmost importance to MERKUR Bingo 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. MERKUR Bingo Ltd 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.
MERKUR Bingo
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 have provided your consent
by specifying your choice of medium for receiving the communication.
MERKUR Bingo 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 to request us
to delete that data at any time.
1.1
MERKUR Bingo 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 MERKUR Bingo, collects and
processes Personal Information of our club members. MERKUR Bingo is registered
for the purposes of data protection with the Information Commissioner’s Office
in the UK (Registration Reference: Z6052826).
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.
2.1
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.
3.1
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 MERKUR Bingo 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.
4.1
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
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.
4.3
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.
4.4
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.
5.1
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:
·
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 Gambling Act 2005);
·
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.
6.1
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.
7.1
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
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 or emailing dataprotection@merkur-casino.com
8.1
You may update your Personal Information at any time by contacting your
local club or the company data protection officer at dataprotection@merkur-casino.com
8.2
You may obtain a copy of your Personal Information held by us by contacting
our Customer Services team or by writing to us at: The Data Protection Officer, MERKUR Bingo,
Seebeck House, 1A Seebeck Place, Milton Keynes, MK5 8FR. 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.
9.1
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 where 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 MERKUR Bingo |
Data retained for 5 years after data subjects’ most recent visit. |
Figure 1.1 data retention periods
10.1
We may collect anonymous information about your use of our website (www.merkurbingo.com),
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.
11.1
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.
MERKUR Bingo 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.
Data Protection Officer,
MERKUR Bingo
Seebeck House
1A Seebeck Place,
Milton Keynes
MK5 8FR
Or email dataprotection@merkur-casino.com
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
Please contact us
via the address above in Milton Keynes or email us at dataprotection@merkur-casino.com