May 2018

Membership Privacy Policy

The privacy and security of your personal data is of the utmost importance to Casino 36 Limited 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. Casino 36 Limited 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.

Casino 36 Limited 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.

Casino 36 Limited has a data specialist who is responsible for ensuring that personal data is managed responsibly throughout the company. You can contact the data specialist 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 torequest us to delete that data at any time.

1. Introduction



1.1 Casino 36 Limited 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 Casino 36 Limited (“we”, “us” or “Casino 36 Limited”), collects and processes Personal Information of ourclub members. Casino 36 Limited is registered for the purposes of data protection with the Information Commissioner’s Office in the UK (Registration Reference: ZA301476). 


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 sign up forms, online forms and when you email us your details. We also collect information about the transactions you undertakewhilst at our clubs. 


2.3 In addition, we may collect Personal Information through surveys which weundertake. 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 would result in a termination of your membership to Casino 36 Limited 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 Where it is necessary to comply with a legal obligation.


4.6 This consent can be withdrawn at any time by speaking to your local club or by contacting the Data Specialist using the details at the end of this policy. 


5. How we use your Personal Information


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, for example with credit reference agencies, fraud prevention agencies of for age verification purposes.• Comply with our obligations under applicable laws (including, but not limited to the Gambling Act 2005); examples include conducting checks against the Sense national self-exclusion scheme, carrying out checks during the course of your relationship with us to ensure that you are gambling legally.• 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);• Profiling & segmenting; to ensure our marketing is carried out in a socially responsible and non-invasive manner we need to fully understand your use of our services by analysing your preferred products and average spend alongside records that we hold about other customers. We will never use any special category personal data that we hold about you for marketing profiling purposes unless we have your explicit consent to do so. You are able to opt out at any time by either visiting reception, writing to the data specialist or on any email or text message that we send you.• Carry out market research campaigns;• We may need to provide your personal data to third parties in order to deliver certain aspects of our services to you. The majority of these are our service providers. Where we do this we will ensure that these third partiestake appropriate measures to secure your data.• 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


6.1 We may disclose your Personal Information to any of the following recipients:• Any casino within our organisation (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 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 by following the unsubscribe links and options on our emails and text communications.


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 specialist using the details below.


8.2 You may obtain a copy of your Personal Information held by us by writing to us at: The Data Specialist, Casino 36 Limited, 56-58 Temple Street, Wolverhampton, WV2 4AQ. 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 where deemed necessary by the data specialist 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, anti-money laundering policy or due diligence

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 Casino 36 Limited

Data retained for 5 years after data subjects’ most recent visit.

CCTV images

These are images captured for security and compliance purposes.

CCTV footage from our premises is generally retained for a maximum period of 30 days.

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 www.casino36.co.ukwww.casino36stockport.co.ukwww.castlecasino.co.uk 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. Complaints

Casino 36 Limited 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 specialist using the contact details below.

The Data Specialist, 

Casino 36 Limited,

56-58 Temple Street,

Wolverhampton,

WV2 4AQ

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

13. Contact information


Please contact us in writing to:

The Data Specialist, Casino 36 Limited, 56-58 Temple Street, Wolverhampton, WV2 4AQ.

Ends

Casino 36 Limited; Registered Number 6584831;

Registered Office, 56-58 Temple Street, Wolverhampton, WV2 4AQ