Welcome to our privacy notice. This document details what data that we as GiG collect about you and how we use it.
WHO ARE WE?
This site and related apps (together, the “site”) is operated on behalf of SkyCity Malta Limited, (Level G (Office 1/1270), Quantum House 75, Abate Rigord Street, Ta’ Xbiex XBX 1120, Malta) by Gaming Innovation Group p.l.c. (“GiG”, “we”, “us” and “our”). As such, in addition to sharing your personal data with Skycity Malta Limited, GiG (GIG Beach, Triq id-Dragunara, St. Julians, STJ3148, Malta.) will also store and process your personal data in its capacity as an independent data controller. This document outlines how GiG collects, processes and stores your personal data.
Any questions about the operation of this policy or any concerns around personal data collection at SkyCity Casino, and usage should be referred to our data protection officer.
HOW DO WE COLLECT PERSONAL INFORMATION ABOUT YOU?
We may collect information about you from the following sources:
- Information you give us. This is information about you that you give to us by using the site, registering on the site, making use of our services or corresponding with us by phone, e-mail or otherwise. As GiG operates the site on our behalf, it will share that information with us. You do not have to provide your personal data to GiG. However, where we need to collect personal data by law or in order to provide our services, we may not be able to provide our full range of services to you if you do not provide such personal data.
- Information we receive about you from other sources. you use other sites and services provided by us or our Group, we may receive information you provided in respect of that other service. GiG or we may also receive information about you from our publishers, advertisers, data providers and other partners that we work with to help us deliver personalized content to you, improve our services and comply with our legal and regulatory obligations.
We might use information that is publicly available on the internet while we proceed with regulatory and compliance checks related to your account. This information will be used as an indication but not for decision-making purposes.
WHAT PERSONAL INFORMATION DO WE COLLECT ABOUT YOU?
We may collect and process the following types of information about you:
- Identity Data, including your first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, employment status, occupation and photograph.
- Contact Data, including your residential address, email address and telephone numbers.
- Financial Data, including details of your salary, details of the sources of funds used to deposit with us, your bank account details, your payment card or payment account details, your bank statements, your payslips and similar documentation.
- Self-Exclusion Data, data pertaining to your self-exclusions and duration of your self-exclusion.
- Transaction Data, including details about your deposits and withdrawals, wagering and other details of games you have played on our site.
- Technical Data, including your internet protocol (IP) address, login details, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other information on the device(s) you use to access this site.
- Usage Data, including information about how you use our site and services, your username and password (encrypted), games played, login and logout times, duration of play, bonuses and promotions claimed.
- Marketing Communications Data, including your preferences in receiving marketing from us and our third parties and customer communication preferences.
- Other communications Data, communications with you including email communication and chat logs.
WHAT DO WE USE YOUR PERSONAL INFORMATION FOR?
We will use your personal information for the following purposes:
- Operate our site and services. we will use your personal information to allow you to make full use of the site and services operated by GiG on our behalf.
- Improve our site and services. We will use your personal information to gather information about our customer base and how our customers use our site and services and improve the quality of our site and services (for example, by troubleshooting our site or collating usage data about our site).
- Comply with our legal obligations. We will use your personal information to comply with our legal and regulatory obligations, including in respect of fraud prevention, anti-money laundering measures and ‘problem gambling’ prevention. As an example: when you register your account we might process your personal data to ensure that our services are not used for money laundering purposes.
WHAT IS OUR LAWFUL BASIS FOR COLLECTING AND USING YOUR PERSONAL INFORMATION?
We have set out below, a description of the ways we use your personal data and what legal bases we rely on to do so. We have identified what our legitimate interests are where appropriate.
To register you as a new customer and create a user account we collect and process your identity data (to perform as per the contract with you), contact data and usage data (to comply with legal obligations). If you fail to provide this information, you won’t be able to use our services.
To provide gaming services to you and manage your deposits and withdrawals we collect and process your identity data (to perform as per the contract with you), your contact, financial, transaction and marketing data (to comply with legal obligations). If you fail to provide this information, you won’t be able to use our services.
To maintain your player account with us we collect and process your identity data (to perform as per the contract with you), contact data (our legitimate interest to keep our records updated), usage and marketing data (to comply with legal obligations). If you fail to provide this information, you won’t be able to use our services.
To manage our relationship with you we collect and process your identity data (to perform as per the contract with you), your contact and usage data (our legitimate interest to understand how customers use our services). If you fail to provide this information we won’t be able to identify your account and offer personalized services for you.
To inform you about a promotion/bonus or other offers we collect and process your identity data (based on your explicit consent), contact, usage and marketing data (our legitimate interest to update existing players on our services). Without your explicit consent, we won’t share promotions or bonus offers with you.
To protect our business and this website from any illegitimate activities we collect and process your identity, contact, technical and transactional data (to comply with our legal obligations). If we don’t collect and process this information, you won’t be able to use our services.
To improve our site and services we collect and process identity (our legitimate interest to improve our site and services), contact and technical data ((to comply with our legal obligations and to safeguard client funds). Without this data, we wouldn’t be able to deliver high quality, personalized services for you.
To deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you we collect and process your identity, contact, usage, marketing and technical data (our legitimate interest to deliver relevant products to you through the site). Without this data, we wouldn’t be able to deliver high quality, personalized services for you.
To use data analytics to improve our site, products and marketing we collect and process usage and technical data (our legitimate interest is to define types of customers for our products, to keep our website updated and relevant and to develop our business). Without this data, we wouldn’t be able to deliver high quality, personalized services for you.
To carry out analysis and segmentation of our player base we collect and process your identity, contact, usage and technical data (our legitimate interest to understand our customer base and tailor our services). Without this data we wouldn’t be able to deliver high quality, personalized services for you.
DO WE SHARE YOUR PERSONAL INFORMATION WITH ANYONE?
We may share your personal information with:
- Other companies within our Group.We may share your personal information with other companies within our Group which require access to it in order to provide the services you request or to comply with their legal obligations (for example, in respect of preventing ‘problem gambling’). This may include companies within our Group that provide physical gambling facilities in New Zealand and elsewhere.
- Our service providers. We may share your personal information with selected third parties, including:
- game suppliers who deliver gaming products on our site and require access to your personal information to allow you to participate in a game;
- analytics, business intelligence and search engine providers that assist us in the improvement and optimisation of our site and services; and
- our lawyers, advisors and consultants who advise on any matter which requires them to gain access to personal information.
- with any person, company, NGO, governmental body, or regulatory authority that maintains a register of problem gamblers or for any other responsible gaming purpose.
- with any person, company, NGO, governmental body, or regulatory authority that maintains a register or database having the objective of preventing crime, money laundering or terrorist and proliferation financing.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions and other agreements; or to protect our rights, property, or safety. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction
- In the event that we agree to transfer our business relating to this site, in which case we will disclose your personal data to the prospective buyer or their lawyers, consultants, financial advisers and employees both during the due diligence process and also as part of the transfer of the business. This includes any transfer of data required under any agreement between us and the owner and/or operator of the site on termination of our services by the owner and/or operator of the site.
- When data sharing is not essential to provide our services or comply with our legal obligations, we will always rely on your consent prior to sharing your personal data with third parties.
WHERE DO WE STORE YOUR PERSONAL INFORMATION?
We will primarily store and process your personal information in Malta therefore within the European Union which provides the same safeguards as New Zealand.
Your personal information may sometimes be transferred to recipients which might be located outside of the European Economic Area (“EEA”) to countries that do not benefit from an adequate decision from the European Commission. Where that is the case, we will ensure that your personal information is subject to the same protections as it would be inside the EEA by adopting appropriate safeguards which comply with privacy laws. When transferring data outside of EEA/EU or adequate countries we mainly rely on Standard Contractual Clauses which are approved by The European Commission and offer sufficient safeguards on data protection for the data to be transferred internationally.
HOW DO WE PROTECT YOUR PERSONAL INFORMATION?
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who genuinely need access to it. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality.
HOW LONG DO WE RETAIN YOUR PERSONAL INFORMATION FOR?
We have to retain your Contact Data, Identity Data, Financial Data, Technical and Transaction Data required by the law (such as AML or Gambling laws) for at least five (5) years after you close your account with us. We are also required to keep your data for the purposes of defending ourselves against any current or future legal claims. We will not retain your personal information for longer than is necessary to achieve the purpose of that data.
You can ask us to delete your data by closing your account. In that case, where feasible, we will immediately delete all information aside from that which we are required to maintain to fulfil our legal obligations as indicated above. In case you choose to permanently self-exclude yourself we will keep your identity and contact data indefinitely in line with the applicable regulations.
In some circumstances, we may anonymise your personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you
WHAT ARE YOUR RIGHTS IN RESPECT OF YOUR PERSONAL INFORMATION?
You have rights under privacy laws in relation to your personal information which we detail below. Please note that these rights are not absolute and there are limitations.
- Right of access. You have the right to access the information we hold about you. Some of the personal information we hold about you can be accessed by logging into your account. Additional information may be requested by contacting us.
- Right to rectification. Where the information we hold about you is inaccurate or outdated, you have the right to ask us to correct it.
- Right to erasure. You have the right to ask us to delete any information we hold about you where there is no good reason for us to continue processing it. There may be legal obligations or other legitimate reasons which prevent us from deleting all or some information held about you (such as anti-money laundering legislation).
- Right to object to processing. You have the right to object to our processing of your personal information in a certain way or for a specific purpose. In that case, we will store a copy of your personal information but will stop using it for that purpose, unless there is a legitimate reason for us to continue doing so.
- Right to restrict processing. This enables you to ask us to suspend the processing of your personal information. In that case, we will store a copy of your personal information but will stop using it at all, unless there is a legitimate reason for us to continue doing so.
- Right to portability. You have the right to ask us to provide a copy of the personal information we hold on you. We will provide you with a copy of your personal data in a structured, commonly used, machine-readable format.
- Right to opt out of marketing communications. You have the right at any time to ask us to stop sending marketing content to you. You can exercise that right by accessing your account and changing your marketing preferences, or by contacting customer support. You may also unsubscribe by using the ‘Unsubscribe’ link at the bottom of our marketing emails. Please allow up to 48 hours for any changes you make to your marketing preferences to be fully processed.
- Right to complain. If you believe that we are using your personal information unlawfully, you have the right to complain about our practices by lodging a complaint with your local data protection regulator.
You can exercise your rights at any time by contacting us. We may verify your identity prior to responding to any request.
AUTOMATED DECISION MAKING
We currently do not make any automated decision making, but going forward we will be implementing KYCP (i.e. collecting information about the data subject and creating a risk rating about the customer – this can be considered to be profiling) and such decisions will be considered to be automated.
We shall however make sure that any automated decision making and profiling is done only where:necessary for the entry into or performance of a contract; orauthorised by Union or Member state law applicable to the controller; orbased on your explicit consent.
How to control Cookies
You can manage cookie usage through your browser settings. The help function in your preferred browser should provide you with the correct information. Some browsers provide helpful cookie guides:
- Internet Explorer
- Safari 5 for Mac
N.B. In the case of some mobile devices, it may be necessary to consult the device’s instruction manual to manage cookies effectively.
Strictly necessary cookies: these cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website. Blocking these cookies will prevent registration/authentication to the site and will make some content/functions unavailable.
Performance cookies: these cookies collect information about how customers use a website, for instance, which pages customers go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous.
Functionality cookies: these cookies allow the website to remember choices you make such as your username, language or the region you are in and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages you can customise. They may also be used to provide services you have asked for such as watching videos or commenting on a blog. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
Targeting/advertising cookies: these cookies record your visit, the pages you have visited, the games you have played, the financial transactions you have made, and your general behaviour on the Website. These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. We will use this information to make our website and the advertising displayed or received by you more relevant to your interests. We may also share this information with third parties for this purpose who assist us in analytics.
Session cookies are created temporarily when a user visits a website. Once the user leaves the site/closes the browser, the session cookie is deleted.
A persistent cookie file remains on the user’s device and is re-activated when the user visits the website that created that particular cookie. These cookies expire after a certain period (set in the file), or can be removed manually.
We use both Session and Persistent Cookies as indicated under the section “Cookies Used” in the column Expiration Time.
CHANGES TO THIS PRIVACY AND COOKIE NOTICE
We may update this privacy and cookie notice from time to time, to reflect changes in how we use your personal information or to comply with new legal obligations.
Any changes we make to this privacy notice will be posted on this page and, where appropriate, notified to you by e-mail.
We recommend that you revisit this privacy notice regularly.