Introduction

Stanleybet Holdings Limited, trading as (“Stanleybet”) provides retail and online gaming services to customers, through its wholly owned licensed companies; located in designated EU countries. In addition, Stanleybet Holdings Limited is responsible for delivering licensed software and associated services to other licensed gaming operators through Magellan Robotech Limited.

Companies owned by Stanleybet Holdings Limited (the Group):

• Magellan Robotech Limited (IT solutions and services operating from the UK)
• Stanleybet Belgium N.V. (Retail and online gaming operator in Belgium)
• Stanleybet Danmark ApS (Retail gaming operator in Denmark)
• Stanleybet Malta Limited (Retail and online gaming operator in Italy and Cyprus (retail only))
• Stanleybet Services Limited (Support services provider operating from the UK)
• Stanleybet Compliance Services Limited (Compliance services provider operating from the Bailiwick of Guernsey)
• Romania Service Center (Helpdesk and support services provider operating from Romania)

Stanleybet Holdings Limited and the companies within its Group apply this privacy policy, incorporating any specific local privacy standards; defined by individual European Union countries where the Group companies are located to safeguard personal data.

Data Controllers

We are the data controllers where we decide the purpose and means for processing your personal information.

For example:

Stanleybet Belgium decides the means and purposes for processing personal information for Belgian online customers.  

If you have any questions about how we handle your personal information, who are the data controllers or have a question about this Privacy Policy or would like to submit a subject access request or a request to exercise any of your rights, you can contact us by email:  privacy@stanleybet.com.

Data Processors

Occasionally your data will be disclosed to third party organisations with whom we contract to provide services on our behalf. These services will only be carried out under contract which will contain our instructions and expectations in respect of how your data will be protected and processed.

Example of data processor

Software Partner

We use other IT Solutions Company with whom we contract to integrate our internal and external IT solutions to provide better online gaming platform and associated services.

To Whom this Notice Applies

This notice applies to you if you use our services in a retail store, over the phone, online, through our mobile applications, by using any of our websites or interact with us on social media or otherwise participate in a competition or obtain information about our services during a commercial event. This privacy notice applies to our customers, external third parties, internal contractors and employees and underpins our commitment to protecting your personal information. This notice has been adopted by all of the companies and brands within our Group.

Our Commitment

We are committed to safeguarding the privacy and the security of your personal information. This notice explains what we do with your information and how we keep it secure. It further explains where and how we may collect your personal information, as well as your rights over any personal information we hold about you.

Security

We take the security of all the data we hold very seriously. We adhere to internationally recognised security safeguards to ensure that personal data remains confidential and subject to internal and external security. We continue to monitor and review our data security standards and where necessary make improvements.

Third Parties

We consider all companies, individuals, and businesses to be third parties, if they are not part of Stanleybet Holdings Limited or within the Stanleybet Group. If we receive your personal information from a third party, we shall continue to apply the same safeguards and security as we would to any other personal information we obtain directly.

How we collect your personal information

We collect your personal information when you use our services or provide your personal information to us for some of the reasons outlined below:

• You want to know about our offers/promotions.
• You want to know about our services.
• You want to become our customer or continue to remain our customer.
• You want to sell your services to us.
• You want to work with us.
• You want to participate in group discussions, events, or comment on services we provide.
• You want us to contact you to answer your queries/questions.
• We want to know more about you as customer, service provider, business, contractor, supplier or gaming operator.
• You provide personal information to us as required by law or regulations in the European Union Countries.

Using our Website

If you use our website, we will ask you to provide personal information in order that you can register for an account and use our services. You will also be asked to accept our terms and conditions.

When you use our website, we collect some information about you using cookies. Please refer to our Cookie policy.

Writing to us

If you write to us either by letter or email, we will keep a record of your information, such as name, address, email address, telephone number and details of your enquiry and our response to you.

Contact us by Telephone

If you contact us, we will request you to be identified and we shall determine the nature of your call so that you can be served by most the appropriate person or department in the Group.

Contacting us via Live Chat

If you use our ‘Live chat’ Service, the following information is collected: your name, username/password, date of birth, postcode, email address and content of the live chat session.

CCTV on Stanleybet Premises

We may record CCTV Images of people who visit Stanleybet premises or staff who work in Stanleybet premises. The CCTV images will not be shared with any other person or organisation, unless you have given your consent or if we are allowed by law, (for example, to prevent or detect crime). We may also use the images to identify people who are subject to exclusion or otherwise present risk of money laundering and terrorist financing.

If you are a customer in a Stanleybet authorised shop

We may seek to establish your age, if we believe you should not be in our premises. We do not seek to offend you but must record this information so that we can demonstrate that we have complied with our age verification process.

We shall collect the following personal information from you when deemed necessary by us due to our legal obligations, which include for Italian retail customers, when transactions reach 2,000 Euro limits (whether stakes, winnings or combination of the two):

• Copy of your valid identification document;
• Transaction receipt/ticket;
• Details of a payment method used to perform a transaction or to receive payment;
• Any other information deemed necessary to meet our legal obligations.

Finally, we will collect personal data when using the bet-booking service. In particular, personal identification and contact data will be processed (such as, for example name, surname, email address, mobile phone), as well as the data relating to the bets subject to the bet-booking, the bet-booking code and the data necessary for the payment of the bet winnings. In order to acquire your willingness to present a bet-booking, a video recording with your instructions will be recorded. Upon completion of the bet-booking forwarding operation, you will receive an email containing the betslip or an information note with the reasons for non-acceptance.

If you apply for a job with us

We use the information you provide to us to process your application for employment. Information about unsuccessful applicants will be retained for six months in accordance with our retention policy.

If you are an employee of ours

Your personal information is processed to meet the conditions of your employment contract and will be kept for the duration of your employment. If you leave our employment, your information is kept in line with our retention policy. We may share your personal information with your future employer if required by law or requested by you.

If you are a Supplier or Contractor

Your information is used to manage the provision of goods and services to us. Depending upon the nature of the service, this may include the use of personal information to identify and verify the owners of a business, as may be required by law prior to establishing a business relationship.

Promotion or Competition

If you enter competitions or take part in promotions, we will collect information from you to be able to process your competition entry or application. Only when you have indicated that you would like to receive future promotional material will we retain your personal information for this purpose. If you have indicated that you would not like future promotional material, then the information will be deleted after the competition/promotion has ended.

Marketing

We also ask you if you consent to marketing, and if so, what your marketing preferences are. This information will be shared with our marketing department to provide you with generic, targeted, and specific products and services, which we believe might be of interest to you.

Should you choose not to receive marketing information, which may include promotions, up and coming events, company updates, competition, please let us know via email at privacy@stanleybet.com.

Social Media and Information already in the public domain

Where it is reasonable for us to do so and not detrimental to your rights and freedoms, we also collect Personal Data from publicly available sources such as internet searches, social media and Companies House.

Self-Exclusion and responsible gambling

In the interests of responsible gambling, your personal information may be shared between other operators, following your agreement to self-exclude. This is part of our compliance policy and forms part of licence conditions, which apply to our business.

For the purposes of prevention or detection of crime as well as responsible gambling, we may also supplement the information about you with information that we receive from third parties or collate by accessing third party sources, including information published on the internet about you or by you (for example on social media and social networking sites).

Why do we collect your personal information?

Mostly, we collect your personal information to meet the following obligations:

• To comply with our legal obligations.
• To fulfil our contractual obligations to you and others.
• To observe and apply legal and licensing requirements to our business.
• To monitor the quality of services being rendered.
• To establish and maintain a relationship consistent with our legitimate business interests.

What is meant by “Our Legitimate Business Interests?”

Your information may also be used to help us make decisions about how your gambling behaviour affects our business. Any such decisions are based upon our legitimate business interests and might reasonably be expected as part of running our business and does not materially impact your rights, freedoms or interests. These are things we do to help us operate as a commercial organisation. If we make decisions based on these grounds, then you have a right to object. However compelling grounds for processing such information, may over-ride your right to object.

What legal Safeguards apply in protecting personal Information?

To ensure transparency and commitment to lawful processing of your personal data, we apply the following principles as prescribed by law:

Consent

In certain situations we collect and process your information with your consent.  An example of this is where you have opted into receiving direct marketing from us.

Contractual Obligations

We sometimes collect information from you to perform our duties under a contract. An example of this would be when you enter into a contract of employment with us to process your monthly pay. Another example is when you sign up to an account for one of our services and accept our terms and conditions.

Legal and Regulatory Compliance

We may process information about you for the investigation of unlawful, fraudulent or any other improper activity connected with our services. Personal information may also be used to report a crime, a suspected crime, including but not limited to money laundering and terrorist financing.

As an accountable organisation, we may also collect information about you to ensure that we meet our obligations in respect of responsible gambling. This information is processed to enable us to comply with any legal or regulatory requirements as determined by Gambling Regulatory Bodies, which regulate the gambling business.

What are your rights?

Below is an overview of your rights in relation to your personal information that we process.

To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.

If you need to contact us in relation to any request you wish to make under your data subject rights, you can do this by emailing or writing to the Data Protection Liaison Office (contact details are listed towards the end of this privacy policy).

Right of Access (Subject Access)

You have the right to obtain confirmation that your personal information is being processed, how and why it is being processed, and access to your personal information. If you would like to request a copy of the personal information we hold about you, you should contact the Data Protection Liaison Office. We will ask you to complete and return a form. This is not compulsory but helps us to identify you to provide the information you are looking for.

Right to Rectification

You have the right to have inaccurate personal information rectified. If you cannot amend any inaccuracies yourself through your on-line account for example, your request will be reviewed and where we can, we will update any inaccuracies. If, however, we take the decision not to make a change you have requested, we will explain this to you in writing.

Right to Erasure

This is sometimes referred to as ‘the right to be forgotten’. You have the right to have your personal information erased if:

• The personal information is no longer necessary for the purpose which we originally collected or processed it for;
• You gave your consent to the processing in the first place and you withdraw your consent and we have no other legal basis to rely upon to process the information;
• Your request will be looked at and where we can we will erase the personal information requested. If however we take the decision not to comply with the request as we have a lawful basis to continue the processing, we will explain this to you in writing.

Right to Restrict Processing

You have the right to restrict the processing of your personal information in certain circumstances. This could be because you have issues with the content of the information we hold or how we have processed your information at a certain time. Your request will be looked at and where we can comply with the request we will and for the duration of the restriction time scale you have indicated. If however we take the decision not to comply with the request, we will explain this to you in writing.

Right to Data Portability

The right to data portability only applies:

• to personal data you have provided to us;
• where the processing is based on your consent or for the performance of a contract; and
• when processing is carried out by automated means.

If you meet the above criteria and still would like to make a request, you will need to do this in writing as stated above and we will provide you with information in an appropriate file. In the future it may become possible to transfer your information directly to another provider. It is unlikely that we will be able to do this at the present time but we will try to accommodate requests where we can.

Right to object

You have the right to object to:

• processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling);
• direct marketing (including profiling); and processing for purposes of scientific/historical research and statistics.

Your request will be reviewed and where we can comply with the request we will. If we take the decision not to comply with the request, we will explain this to you in writing

How long will we keep your personal information?

Whenever we collect or process your personal information, we’ll only keep it for as long as is necessary for the purpose for which it was collected. At the end of the retention period, your information will be permanently and securely deleted.

Some examples of our retention periods are below;

• If you use our live chat service, your information is retained for a period of two years in the live system after which time it is archived and permanently and securely deleted after 5 years.
• All images captured on any of our CCTV are kept for a period of between 7 and 30 days after which time the images are overwritten.
• If you make a complaint and the complaint is escalated through our complaints procedure, we will keep all information in relation to the complaint for 3 years after the issue has been closed.
• When the bet-booking service is used, the personal data collected – including video recording – are processed exclusively for the purpose of managing the bet proposal, and are immediately cancelled as soon as the bet is accepted or the bet-booking proposal is rejected.

To fulfil our requirements, some of your personal information will need to be retained for a period of time after you cease to be a customer. When we no longer need it to fulfil the above requirements, we delete it securely.

Who do we share your personal information with?

Regulators/Law Enforcement agencies and other authorities

Some of your personal information may have to be shared with appropriate Gambling Regulatory bodies, such as: ADM (Italy), MGA (Malta), BGC (Belgium), NBA (Cyprus), DGA (Denmark) and the Gambling Commission (UK), as well as the Advertising Standards Authority, Independent Betting Adjudication Service and the Information Commissioners, located in each of the associated countries.

Data can also be disclosed to:

(i) operators and fellow members of suspicious betting activity detection platforms (currently Stanleybet reports only to the IBIA platform and accordingly IBIA and all of its members will have access to and process all suspicious betting activity alerts Stanleybet might raise and might report such data themselves to other interested parties, such as those noted in the remainder of this clause);

(ii) gambling regulators;

(iii) police and prosecuting authorities (for prosecution of offenders);

(iv) sports governing bodies (for example, ITIA for Tennis).

In most circumstances, we will not disclose your personal information, unless you have given consent or we are allowed to or required to do so by law. However, when we investigate a complaint, for example, we may need to share personal information with the organisation concerned and with other relevant bodies.

Credit Reference Agencies/Identity Verification Agencies

We may need to conduct verification checks which could include sharing information with third party organisations, such as credit reference agencies, sanctions check services.

Shop Agent indicated

In case of use of the bet-booking service, your personal data (including the video recording with instructions) will be transmitted to the shop agent indicated by you and immediately cancelled as soon as the bet is accepted or the bet-booking proposal is rejected.

Overseas transfers of your information

Your personal information may be processed in any country in which we and/or our data processors have facilities. Where your personal information is sent to a country outside of the European Economic Area (EEA), by using the service, you are consenting for such a transfer to take place. We will ensure that adequate measures are in place to protect your information and to treat it as securely as it would have been had it remained in the EEA. If of course, you are not happy with any of your personal information being processed outside of EEA, you must let us know immediately in writing.

Role of the Data Protection Regulators

Each European Member State has its own designated Data Protection Regulator responsible for upholding the information rights in the public interest. This includes investigating reported data breaches and providing guidance and assistance to individuals as to their rights. Where a data controller identifies a breach it shall be solely responsible for determining and notifying the most suitable Data Protection Regulator within the EU Member States.

Contacting the Regulator

If after contacting us, you remain unhappy about how we handle your personal data, customers located in the United Kingdom may contact the Information Commissioners Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF or visit https://ico.org.uk/.

Please Note:

This Privacy Notice was last updated in March 2021 and will be updated from time to time if any changes are made that could affect you.