Customer Privacy Notice

• Who are we
• The information we collect about you
• How we use your Personal data  
• Who we may pass your data on to
• Meeting our responsible gambling obligations
• Single Customer View (Great Britain and Northern Ireland Players only)
• How long we retain your data
• Location that we may transfer your personal data to
• Security
• Cookies
• Marketing
• Your rights 
• How to contact us / Our Data Protection Officer 
• Changes to this Policy

Who we are

LC International Limited are member of Entain Group of companies and this Notice explains what your personal data will be used for.

Where we use the term “we” or “us”, this includes the entity and Brands (https://entaingroup.com/about/business-overview/our-brands/) and other companies within the Entain Group group.

We are committed to protecting your personal data when you use our services through our website and mobile application and take the security of your information very seriously. We have strict security measures in place to protect your personal data which includes robust security procedures which are regularly tested and reviewed. If you have any concerns about the way in which we process or protect your personal data or would like to contact us about any aspect of this policy, please get in touch through the contact details at the bottom of this statement.

This privacy notice should be read in conjunction with our cookies notice, any notices or terms located within the stores and our site terms of use / terms and conditions.

The information we collect about you

We will collect personal data about you from the following sources:

• When you register for an account with us
• When you visit our website or our social media sites
• Through surveys you complete
• When you communicate with us (by email, mail, phone, in store or through chat or social media)
• When we undertake analysis of your interaction with us
• From our other group companies for internal reasons, primarily for business and operational purposes
• From public sources of information such as public records or social media postings
• From cookies and tracking devices on your devices where you have permitted their use.
• From third parties' databases to comply with our legal and regulatory obligations;
• From online vendors and service providers such as financial and shared liquidity services, and from customer lists lawfully acquired from third-party vendors.

What We Use your Personal Data for

Much of the information we collect about you is required to meet our legal and regulatory obligations, such as Gambling Act and Money Laundering, however, where we ask for your consent to process your personal data, you are not required to provide it, however, if you do not do so, you may not be able to take advantage of our services.

We may also store more sensitive personal data about you (often referred to as “special categories of personal data”) which may come directly from you, from other sources as described above or from decisions we have made about you.

Some of these decisions or actions we may take in managing your account or meeting our legal obligations may involve fully automated decisions. We will however always provide you with contact details where you can ask for a review of the decision or get further information from us.

Who we share your data with

We may need to share personal information with other organisations to ensure that we meet our legal obligations or where we need support in meeting your needs or our contractual obligations. We may also share information with other organisations where we consider it to be in the public interest or in the legitimate interest of ourselves or these other parties. These other parties are typically:

• business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
• our affiliates and selected third parties, where you have expressly opted-out of receiving marketing from us / third parties, have been barred or self-excluded, in which case we may share suppression lists with our affiliates and selected third parties, to ensure you do not receive unsolicited marketing;
• members of the Entain Group and third party suppliers and service providers for any of the purposes identified in the table above; third party suppliers and service providers to the extent they assist the Entain Group with its legal / regulatory obligations e.g. providers of services in respect of anti-money laundering, fraud, verification etc.;
• selected third parties so that they can contact you with details of the services that they provide, where you have expressly opted-in/consented to the disclosure of your personal data for these purposes;
• analytics and search engine providers that assist us in the improvement and optimization of our site and other selected third parties;
• other 3rd party organisations who ask, encourage or collate feedback and any online views of your experiences with us to help us improve and optimize our services.  
• Banks, credit card companies and relevant agencies who may share with third parties for the purpose of investigating and safeguarding against underage, fraudulent, criminal or suspicious activity or safer gambling (or other activities we are bound by law, regulation or guidance to investigate and safeguard against) or if we have reason to believe that you have undertaken such activity; and
• our regulators, law enforcement or fraud prevention agencies, as well as our legal advisers, courts, applicable independent adjudication services and betting integrity organisations and any other authorised bodies, for the purposes of investigating any actual or suspected criminal activity, maintaining standards of behaviour in gaming or other regulatory or legal matters

We may share your personal information with other members of the Entain Group for marketing purposes. We will not share it with other 3rd party organisations however unless you have expressly opted-in/consented to the disclosure of your personal data for these purposes.

We may also disclose your personal information to third parties in the following circumstances:

• in the event that we consider selling or buying any business or assets, in which case we will disclose your personal data to any prospective sellers or buyers of such business or assets;
• in the event of any insolvency situation (e.g. the administration or liquidation) of Entain Group plc, or a data controller or any of its group entities;
• if we, or substantially all of our assets, are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;
• in order to enforce or apply our website terms of use;
• to protect the rights, property, or safety of us, our staff, our customers, or others.  This includes exchanging information with other companies and organisations (including without limitation, other gambling operators and the local police or other local law enforcement agencies) for the purposes of staff and customer safety, crime prevention, fraud protection and credit risk reduction;
• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or regulatory requirements, or otherwise for the prevention or detection of fraud or crime;
• If you are based within the UK, when we check your identity when you first become a customer, or check your financial status as required by our License Conditions, we share information with a Credit Reference Agency and this will leave a “soft” footprint on your credit file. Further information about how this agency holds and uses your information can be found here: https://www.callcredit.co.uk/legal-information/bureau-privacy-notice; and
• Where you have self-excluded yourself from gambling, we may share this information with our regulators or other companies in our field where we believe it is important to support your exclusion.

Meeting our Responsible Gambling Obligations

• We take responsible gambling very seriously at Entain. We may share your information across our brands in the Entain Group, and where required with other organisations to meet our responsible gambling commitments.
• We have an obligation to identify those at harm from gambling as early as we can and help them stop gambling by placing certain limits on accounts; this could include deposit limits, product limits, limiting the ability of an account to gamble certain products / times / periods.In order to meet these obligations, we continuously analyse customer’s transactions and evaluate behaviour or financial status across all of our products and brands, which may lead us to make decisions on your account(s).Please see the Affordability section on our website for more information.
• We are also constantly looking at innovative ways to help spot players who may be on a path to difficulties and identify them digitally.This means that we may use systems that identify customers (such as cookies on player's devices or images sent by you) and internally we have developed systems to understand your play to better communicate any risks concerning your activity. We may also share or receive player data with other organisations who help evaluate risks or assess affordability by looking at how you may interact with other gambling operators or help individuals directly.

In all these cases, please be assured that we take our obligations very seriously, in helping customers gamble responsibly and in protecting your personal information. We will always ensure that we take the most appropriate measures and controls to protect your data.  

If you are a customer in Great Britain or Northern Ireland, the following initiative called “Single Customer View” applies to you.

Single Customer View

Single Customer View, Trial 1, is a project to ensure that people who display high-risk behaviours are protected from gambling related harm to their health. To do this Participating Operators that provide online gambling products will take steps to identify customers who they believe should not be gambling and share some key customer information with the GamProtect system. Participating Operators will use GamProtect to identify whether the same customer has an account with them and proceed to close their account to reduce the potential for harm.

This privacy notice explains how Participating Operators in the Single Customer View trial project use your personal data. Please note that from 08/02/2023 for a period of approximately 12 weeks Participating Operators will share customer personal data but not take any action on the data. This is so the Participating Operators can evaluate the effectiveness of the technical solution. You can see which operators are participating in the Single Customer View trial project by going to the Participating Operators section of this notice.

There are 3 key players in this process:

1. The “Closing Operator”: this is the Participating Operator that closes your account and can be any of the Participating Operators.
2. “GamProtect”: this is the system that allows for secure data sharing between all operators in a way that ensures privacy. They will receive customer data from the Participating Operators on a daily basis.
3. The “Receiving Operators”: these are the Participating Operators who receive a match from the data that is shared by the Closing Operator to GamProtect and the Receiving Operator’s own customer database. If the Receiving Operator and the Closing Operator have the same customer, then they will take a similar action to protect their shared customer e.g., closing the customer’s account.

The Receiving Operator will not know the specific reason why the Closing Operator has shared data with them via GamProtect. If your personal data has been shared with GamProtect and you would like to find out why, please contact the Closing Operator. You will receive an email from the Closing Operator informing you that your details will be shared with GamProtect.

How does the Single Customer View trial work?

Risk Identification

Participating Operators will identify a player as at risk of health-related problem gambling if the player indicates that they:

• Have a gambling problem or addiction.
• Are seeking external support or treatment for gambling problems.
• Will harm themselves or someone else.
• Should not be gambling because they have a medical condition.

• Want to stop gambling forever due to problems with their gambling.

Initial Account Closure

• Once a Participating Operator has identified a player as at risk of health-related problem gambling, it will close all of the player’s accounts and exclude the player from all of its gambling services.
• It will also inform the player that they will be added to GamProtect due to issues with health-related problem gambling.

 Registration

The Participating Operator will add the following Registration Data about the player to GamProtect:

• Forename
• Surname
• Date of Birth
• Postcode
• Email address
• Telephone number
• Unique Customer ID set by Participating Operators

 Matching  

• Each Participating Operator will routinely check all their current players’ details against the details of the players previously added to GamProtect by scanning their customer database against the system.
• If a player who is playing with one Participating Operator has been previously added to GamProtect by another Participating Operator, GamProtect will provide the Participating Operator carrying out the GamProtect check with the following information about the player (GamProtect Response):
  • Status as added to GamProtect.
  • Category of health-related problem gambling risk (see Risk Identification box above).
  • Name of Participating Operator that added the player to GamProtect.

Further Account Closures

• When a Participating Operator is informed by GamProtect that a player has been identified as being at risk of issues with health-related problem gambling, it will close all the player’s accounts with the company.

Initial active Period

• A player will remain on GamProtect and subject to the matching process initially for a period of [five years] from the date they were first added by a Participating Operator. This is known as the initialactive period.
• During the active period all Participating Operators will exclude the player from their gambling services.
• The player cannot remove themselves from GamProtect during the active period.
• However, if a player thinks they have been added to GamProtect incorrectly, they can follow the GamProtect redress process explained below.

Further Active Period

• At the end of the active period (if the player is not removed from GamProtect by the redress process), the player will remain on GamProtect and subject to the matching process for a further active period.
• During this further active period all the Participating Operators will continue to exclude the player from their gambling services.
• The player can remove themselves from GamProtect at any time during the further active period by contacting the Participating Operator that has prevented them from accessing gambling services using the contact details below.
• However, if the player does not remove themselves from GamProtect, the further active period will continue (and they will remain excluded from all Participating Operators’ gambling services) for a period of 35 years.

Archive Period

• Following the end of the further active period (either by request or expiry), the player’s details will be held for an archive period of seven years.

Reidentification of Risk

• If during a further active period or archive period a Participating Operator re-identifies a player as at risk of health-related problem gambling, the Participating Operator will re-add the player to GamProtect and the active period will restart.

Categories of personal data to be processed as part of the Single Customer View trial

Purpose & Legal Basis for this Initiative

Participating Operators will process customer’s personal data for the primary purpose of identifying customers with health-related issues with problem gambling that are common to any other Participating Operator and attempting to protect extremely vulnerable people from gambling related harm across those common Operators. This involves:

• Communicating with a customer to identify a potential harm.
• Closing, suspending or restricting the customer’s account.
• Sharing customer personal data with GamProtect.
• Searching for customers who have been registered on GamProtect.
• Evaluating the ongoing effectiveness of the GamProtect solution.

The legal basis for the purpose we have described is the Participating Operator’s legitimate interests in protecting customers from harm. Specifically, these interests are:

• To improve intervention for people suffering from health-related problem gambling issues.
• To share the identification of players who are suffering health-related problem gambling issues.
• To provide greater insight into effective ways of reducing people in the UK from suffering health-related problem gambling issues.
• A proportionate approach to the identification of people in the UK from suffering health-related problem gambling issues and protect customers without unduly infringing their rights and freedoms.

Special category personal data is personal data that can reveal health data and other sensitive information about a person. As the scheme is designed to detect and prevent health-related problem gambling the Single Customer View trial data is considered to be special category personal data. Where the processing of customer data involves special category data the legal basis for the Participating Operator’s processing this data is substantial public interests. The substantial public interests are outlined in the UK Data Protection Act 2018 as: safeguarding of children and of individuals at risk.

Recipients of the data

Customer data will be shared with the GamProtect system which is owned and provided by Tutelar Limited. (“TUTELAR”) and its subcontractors The Data Shed Limited and Amazon Web Services. We can be compelled to share information within GamProtect with regulators and law enforcement agencies at their request. Participating Operators will also share the flag indicating a health-related problem gambling issue associated with a customer with other Participating Operators. If a Participating Operator ceases to exist, they will share the specific reasons why a customer’s data has been shared to GamProtect with another Participating Operator.

We will transfer your personal data to GamProtect who will then confirm matches with the other Participating Operators. We have implemented Standard Contractual Clauses with appropriate addendums to protect the personal data during the transfer.

Data Retention for Single Customer View

Your rights under this Initiative

Redress process

If you believe you have been added to GamProtect incorrectly, please contact the Participating Operator that is preventing you from accessing online gambling services using the contact details below. The Participating Operator will then take you through these steps –

• If that Participating Operator added you to GamProtect, it will consider your concerns and decide whether or not to remove you from GamProtect.
• If the Participating Operator that is preventing you from accessing gambling services did not add you to GamProtect, it will provide you with the contact details of the Participating Operator that did add your details to GamProtect.
• The Participating Operator that did add your details to GamProtect will then consider your concerns and decide whether or not to remove you from GamProtect.

If the company which added your details is no longer participating in GamProtect, you can instead follow the redress process with the Participating Operator whose gambling services you wish to access.

Removal from GamProtect

In addition to the redress process, following the end of the active period, you can ask to be removed from GamProtect at any time by contacting the Participating Operator that has prevented you from accessing gambling services using the contact details below. 

Please note that even after your removal from GamProtect, individual Participating Operators may still independently decide to prevent you from accessing their gambling services.

Data Protection Rights

You have the following rights in respect of your personal data processed for the purposes of GamProtect –

• Access to your personal data
• Correct or update your personal data
• Object to the use of your personal data
• Erasure of your personal data
• Restriction of the use of your personal data
• Complain to the Information Commissioner’s Office

You should be aware that these rights are not absolute and do not apply in every situation. You can find out more information about these rights on the website of the Information Commissioner’s Office here.

If you would like to exercise any of these rights, please contact the Participating Operator that has prevented you from accessing gambling services using the contact details below.

If you would like to make a complaint, you can send a letter or email to the relevant address above or contact the Information Commissioner’s Office.

GamProtect does not involve processing of solely automated decisions that produce legal or similarly significant affects.

The Participating Operators in GamProtect are:

Scope

This notice only applies to the use of personal data for GamProtect. For further information about how Participating Operators use personal data more generally, please see the privacy policies in the ‘contact’ section above.

Changes to this policy

We may need to update this notice from time to time, including as we develop GamProtect with the other Participating Operators. Where this notice changes, we will take appropriate steps to bring the change to your attention. You can also see the date of the notice along with the date of its latest update below.

How long we retain your personal data

The above retention times may be extended for example where it is needed to meet a specific regulatory obligation, investigate a crime, handle a claim or resolve a complaint

Locations that we may transfer your personal data

From time to time, service providers, members of the Entain Group and organisations with whom we work with, may be located outside the UK or European Economic Area in countries that do not have the same standards of protection for personal data as the UK or EEA Countries. We will, however, always use every reasonable effort to ensure sufficient protections are in place to safeguard your personal data. We will also ensure that our service providers enter into compliant processing agreements with us to ensure that your personal data is processed in accordance with applicable data protection legislation. Further information about the mechanisms we will apply can be found here but please contact us on the email address below if you have any specific questions regarding international transfers: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_en.

Security

We take compliance with security regulations, standards, guidelines and privacy laws very seriously and promote security measures that will maintain the confidentiality, integrity and availability of personal data. We use reasonable organisational, technical and administrative measures to protect customer personal data from unauthorised access, alteration, disclosure or destruction of personal data that we hold.

As a business, we have secure firewalled datacentres, certified encrypted webpages and we are ISO27001:2013 certified. We also take steps to ensure our subsidiaries, agents, affiliates and suppliers employ adequate levels of security across the business.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to prevent unauthorised access attempts.

Cookies

We use cookies for various purposes including making your experience of our website better. For more information on our use of cookies, please see our Cookies Notice.

Marketing Communications and your choices

When we first collect your personal data, we’ll ask you to tell us how you would like to hear from us in future about our other products and services. It’ will normally be via a tick boxes on forms or web page and you can opt-out at any time.

What is 'Opting Out'?

The term opt out refers to several methods by which individuals can avoid receiving unsolicited product or service information. This ability is usually associated with direct marketing campaigns such as telemarketing, e-mail marketing, or direct mail.

*Please consider that 'opting out' will not prevent any essential customer correspondence e.g. bet or account correspondence.

How can I opt out of marketing correspondence?

If you do not wish to receive any offers, promotions, information on events and tailored communications based on your account activity, you can request to be made un-contactable by:

• Using the “unsubscribe” option provided in any marketing communication you receive
• changing your preferences on your account settings
• contacting our Customer Support department.

What details do you require from me?

We would need as much of the following as possible, to ensure that you are not sent any further unwanted correspondence:

• Your full name
• Your account number
• How we contacted you, i.e. email, SMS, or post
• The mobile number or email/postal address we contacted you on
• The mobile number or email address that the message came from
• The date(s) and time(s) you were contacted
• A copy of the message you were sent (e.g. a screenshot or a forwarded email sent to our customer care team)

Your rights

Contact Us or Our Data Protection Officer

If you have any questions about this notice or would like further information about your rights, please contact by one of the following means:

dataprotection@entaingroup.com.

Our Data Protection Officer be also be contacted at the above address or by emailing dataprotectionofficer@entaingroup.com.

Questions, comments and requests regarding this privacy policy are welcomed

Changes to this Privacy Policy

Any changes to this privacy policy in the future will be posted on this page, and where appropriate, notified to you by email. Please check back frequently to see any updates or changes to this privacy policy.

This policy was last reviewed and updated:January 2023