At Virgin Bet, we understand that your privacy is important. We respect and value the privacy of everyone who visits www.virginbet.com (the “Site”) or uses any of our application on their devices (“Apps”). We only collect and use your Data as described in this Privacy Policy (the “Policy”) and as permitted by Data Protection Legislation.
Please read this Policy carefully and ensure that you understand it. To navigate through our Privacy Notice just click on the links below. Capitalised terms used in this Policy are defined in the Glossary below.
Please note that our Site and Apps are not intended for use by individuals under 18 years old.
Our Site and Apps are owned and operated by Virgin Bet Limited, a company registered in Gibraltar at Madison Building, Midtown, Gibraltar GX11 1AA (“Virgin Bet”, or “we”, “us” or “our”). We are a member of the LiveScore Group of companies. For the purposes of the Data Protection Legislation, we are the data controller which means that we are responsible for determining the purposes for which and means of how your Data is Processed.
If you have any concerns about how we Process or protect your Data or would like to contact us about any aspect of this Policy, please get in touch with our Group Data Protection Officer, who oversees our handling of Data, and who can be contacted at dpo@virginbet.com.
This Policy should be read together with our Cookie Policy, and our Site and Apps terms of use . You can find most information in our FAQs .
We will collect Data about you from the following sources:
* From you (for example, when you create an account, make a payment, tell us about your preferences or respond to our campaigns, communicate with us, or use our Site or Apps);
* From when we host social events;
* From public sources of information such as public records or social media postings;
* From providers about your interactions on the Site and Apps and from cookies and tracking devices on your devices where you have permitted their use;
* from third parties, such as social media platforms when you interact with us over social media, advertisers, and other companies in the LiveScore Group. We may also receive information if you register with GAMSTOP and from other parties in accordance with our responsibilities as a gambling operator.
We will collect the following types of information:
We use your Data in the following ways, and for the following reasons:
In some cases, we may share your Data with third parties in order to support your needs, to provide you with services, or to comply with our legal obligations. We may also share Data with third parties if it is in the public interest or the sharing is in our legitimate interest or the legitimate interest of another organisation.
We check your identity when you first become a customer, we share information with a TransUnion and this will leave a note on your credit file. This check involves automated decision making, as detailed in Section 5.
The other organisations we may share your Data with are typically:
* Members of the LiveScore Group for the purposes in section 3 above.
* Third-party suppliers and service providers for the purposes identified above – in particular we work with platform services (to provide betting and account management functions), content providers such as SportRadar (to provide geolocation specific streaming content) – for more information on how SportRadar treat personal data, please see their Privacy Notice, cloud providers (to host the Site and Apps), affiliate platform services, customer support software services, data storage services, payment service providers, know-your-customer and anti-money laundering services as well as enhanced due diligence and anti-fraud services, gambling restriction service providers (such as GAMSTOP), data matching services (to ensure we receive accurate information if you register for GAMSTOP) and click fraud detection and protection services.
* Business partners and other organisations to help us meet our contractual and regulatory obligations, including audit, legal and compliance services.
* Affiliates and third parties which you have opted out of marketing communications with, have been barred or have self-excluded, so that we can ensure that you do not receive unsolicited promotional material.
* Identity verification and fraud prevention agencies such as other gambling operators, banks, credit card companies and similar agencies which investigate and prevent underage, fraudulent, criminal or suspicious activity, or any other behaviour we are legally required to investigate. We will also pass on your information if we have reason to believe you have undertaken such activity.
* Analytics and search engine providers and other selected organisations which provide us with feedback about our Site or Apps and aid us in improving their optimisation.
* Statutory authorities when we are required to comply with a request for information, a court order disclose your Data, a regulatory investigation from a relevant governmental or gambling or regulatory authority, our legal obligations including our requirement to report suspicious behaviour.
* Sporting integrity organisations to comply with our legal obligation to protect the integrity of sport and to ensure that betting markets are fair and free from corruption.
* Regulator, law enforcement or fraud prevention agencies as well as legal professionals, courts and other adjudication services to investigate any actual or suspected criminal activity.
We may also share your Data to third parties:
* If we consider selling or acquiring businesses or assets, in which case we will share your Data with the counterparty.
* If the LiveScore Group, or any of its group companies, becomes insolvent (i.e. becomes subject to administration or liquidation processes).
* If we, or substantially all of our assets, are acquired by a non-LiveScore Group entity.
* When we check your identity when you first become a customer, we share information with TransUnion 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.transunion.co.uk/legal-information/bureau-privacy-notice.
* If we need to enforce our terms and conditions.
* To protect our safety, rights or property, or the safety, rights or property of our customers, staff and others by sharing information with other companies and organisations such as the local police.
* Where we are trying to support your decision to self-exclude , we may share your Data with regulators or other gambling organisations.
We may share aggregated or anonymised Data to gambling addiction prevention organisations such as GAMSTOP or academic institutions to allow them to conduct research into problem gambling and inform our business practices and better protect vulnerable people.
'Automated Decision Making' refers to a decision which is taken solely on the basis of automated processing of your personal data. This means processing using, for example, software code or an algorithm, which does not involve human intervention.
As profiling uses automated processing, it is sometimes connected with automated decision making. Not all profiling results in automated decision making, but it can do.
As a customer of Virgin Bet, we use automated decision making to carry out a credit reference on you regarding your account and certain deposit and withdrawal transactions. This is used to verify your age, identity, or any other information that you provide to us. In performing these checks, TransUnion may process your publicly available data (which may include insolvency/bankruptcy events or court judgments entered against you); and may keep a record of your information. A credit check is not performed and your credit rating will be unaffected. These checks enable your Account to be opened, reduce the need to obtain age and identification documents and assist us with our age and identity verification licensing obligations and our crime and fraud prevention policies.
Where you have chosen to self-exclude in accordance with our responsible gambling policies, we may use this information as part of the automated decision making. This may involve the processing of special category data.
We will only use automated decision making if it is authorized by legislation, if you have provided an explicit consent or (for non-special category data) if it is necessary for the performance of a contract. You have certain rights in respect of automated decision making, where that decision has significant effects on you, including where it produces a legal effect on you. See Section 11 for more information about your rights.
We will not keep your Data for longer than is required for the purposes for which we collected it, including for the purposes of satisfying any legal requirements. The length of time for which we retain your Data will depend on what we are using it for as set out in this Policy, the nature of the Data and how sensitive it is. For example, we will keep you email address while dealing with your enquiries but, even when you unsubscribe, we are required to continue to retain your email address to ensure that we do not send you any email communications in the future and for our know-your-customer (“KYC”) purposes.
Please note, however, that we may be subject to legal and regulatory requirements to keep your Data for a longer period. We may also extend the retention times where the Data is needed to investigate a crime, handle a claim or resolve a complaint. As a general rule, we keep your Data based on the criteria below:
Where it is no longer necessary to Process your Data, we will delete it or anonymise or aggregate it by removing all details that identify you in accordance with Data Protection Legislation.
We primarily store and Process our Account data within the European Economic Area (“EEA”). However, if we transfer your Data outside of the EEA, we ensure a similar degree of protection is afforded to it to safeguard your Data in accordance with Data Protection Legislation, which can include by: (i) ensuring that your Data is only processed in countries which provide adequate data protection laws (in accordance with the Data Protection Legislation); (ii) requiring recipients to sign up to strong contractual commitments that ensure the protection of your Personal Data (such as the EU Model Clauses); and/or (iii) taking any other measures that comply with Data Protection Legislation.
While the nature of the internet means that the transmission of information may not be totally secure, we have implemented security measures to prevent your Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Where you use a password to access certain services or features of our Site or Apps, please keep this confidential and do not share with anyone. Unfortunately, we cannot guarantee the complete security of the information transmitted via the internet. While we have implemented security measures, any transmission is at your own risk.
We use Cookies on our Site and Apps for the purposes above. For more information, please see our Cookies Policy.
Social Media Marketing. We may also use information you provide to us to show you relevant advertising and personalised content on certain third party social media platforms made available to us through those services (e.g. Facebook, Twitter, Instagram). We do not control the way these social media platforms operate and collect your information and you should read their respective privacy notices online to understand how they use your personal information. If you no longer want to receive personalised and targeted advertisements from the social media platforms, you can manage your advertising preferences and decide what you want or do not want to see using the settings in your relevant social media platform account.
In addition to the use of cookies we also build profiles on Facebook by using your email address and other personal data. These profiles are used to create lists of users that are more likely to respond to targeted digital display adverts. We do this by creating what are called Custom Audiences and Lookalike Audiences, using Facebook as our Data Processor.
To achieve this, your data is hashed on our local system before being shared with a third party. Hashing turns the Personal Data in a file into short fingerprints of code that cannot be reversed. This pseudonymised data is more secure as no third party can decrypt it.
To test the effectiveness of our campaigns we may also make use of Facebook’s Offline Conversions function, where customer sales data is hashed similar to the above and compared to hashed Facebook users that were served an advert. This function then informs us to whether there is any correlation between the advert and the subsequent purchase.
When we process your personal data for our legitimate interests in this way we take great care to consider and balance any potential impact on you and your rights.
If you wish to object to the processing of Personal Data being used in any of the ways listed above or you simply have questions about this, please contact us via dpo@virginbet.com .
However, the nature of Detailed Targeting via Facebook means that some of our adverts can still reach you (even if we have not used your Personal Data to create Custom or Lookalike Audiences). In this scenario Facebook is the Data Controller and will provide options within its privacy settings to allow you to opt out.
Research: To determine the effectiveness of promotional campaigns and advertising and to develop our products, services, systems and relationships with you.
You can tell us whether or not you wish to be contacted for marketing purposes and, if so, how we can contact you. We will obtain this information from you when we first collect your Data and we will ask you what kind of communication you would like to receive from us.
You can opt-out from receiving marketing communications from us at any time by following the instructions below:
* Email marketing: to opt-out from emails, use the unsubscribe link provided within any email you receive or manage your preferences through the “Account Details” section of the Site or App.
* SMS Marketing: to opt-out from SMS, you can use the STOP code provided in any SMS you receive or manage your preferences through the “Account Details” section of the Site or App.
* Call Marketing: to opt-out from being contacted by telephone for marketing purposes, you can manage your preferences through the “Account Details” section of the Site or App.
* Post Marketing: to opt-out from receiving marketing by post, you can manage your preferences through the “Account Details” section of the Site or App.
Push notifications: to opt-out from receiving push notifications, you can disable push notifications on your device or browser settings.
Please be aware it may take up to 28 days for your request to take effect. Please note you will still receive other important information about our product and services.
Under Data Protection Legislation, you have a number of rights in relation to your Data. We have listed these below, but please note that some only apply in certain specific circumstances (detailed in the Data Protection Legislation):
Our Site or Apps may contain links to other websites. This Policy only applies to our Site and Apps. If you click on a link to another website, you should read their privacy and cookie policies to understand how they Process your information.
We may, from time to time, change or update this Privacy Policy in line with legal requirements or if our business changes. All changes to this Privacy Notice will be published on this page of the Site or in the relevant section of the App. Each change will become effective on publication. We recommend that you revisit and read this Privacy Policy regularly to ensure that you are up-to-date with the current terms.
This policy was last reviewed and updated in February 2023.
If you have any questions or comments about this Policy, want to know more about how we use your Data, or want more information on your rights, please contact our Data Protection Officer by emailing: dpo@virginbet.com.
If you have a complaint about how we Process your Data, please contact us at dpo@virginbet.com and will try to resolve this. However, if you feel that we haven’t addressed your concern in a satisfactory manner, you have the right to complain to the Information Commission (“ICO”) (www.ico.org.uk) or the Gibraltar Regulatory Authority (www.gra.gi).
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Please read this Policy carefully and ensure that you understand it. To navigate through our Privacy Notice just click on the links below. Capitalised terms used in this Policy are defined in the Glossary below.
Please note that our Site and Apps are not intended for use by individuals under 18 years old.
1. Who are we?
Our Site and Apps are owned and operated by Virgin Bet Limited, a company registered in Gibraltar at Madison Building, Midtown, Gibraltar GX11 1AA (“Virgin Bet”, or “we”, “us” or “our”). We are a member of the LiveScore Group of companies. For the purposes of the Data Protection Legislation, we are the data controller which means that we are responsible for determining the purposes for which and means of how your Data is Processed.
If you have any concerns about how we Process or protect your Data or would like to contact us about any aspect of this Policy, please get in touch with our Group Data Protection Officer, who oversees our handling of Data, and who can be contacted at dpo@virginbet.com.
This Policy should be read together with our Cookie Policy, and our Site and Apps terms of use . You can find most information in our FAQs .
2. What Data do we collect about you?
We will collect Data about you from the following sources:
* From you (for example, when you create an account, make a payment, tell us about your preferences or respond to our campaigns, communicate with us, or use our Site or Apps);
* From when we host social events;
* From public sources of information such as public records or social media postings;
* From providers about your interactions on the Site and Apps and from cookies and tracking devices on your devices where you have permitted their use;
* from third parties, such as social media platforms when you interact with us over social media, advertisers, and other companies in the LiveScore Group. We may also receive information if you register with GAMSTOP and from other parties in accordance with our responsibilities as a gambling operator.
We will collect the following types of information:
| Type of Data | Description |
|---|---|
| Your personal and contact details | Information including as your name, home address, email address, telephone number, username and password. |
| Account information | Information about your account with us, including your login details for our Site and Apps, date of birth, unique account number, unique customer identification, payment method information, marketing preferences, complaints details and any notes added to your account. |
| Visual images | Such as videos and photographs of you provided in your interactions with us in social events we host and your profile image on social media if you choose to enable this through your social media account. |
| Financial information | Such as information that allows us to understand your creditworthiness or your payment method, including bank account or payment card details. |
| Transactions, bets and account history | Such as which bets you have placed, what games you have participated in, and which transactions you have made. We will also receive information about you when you register with GAMSTOP to restrict your gambling activities to understand your gambling behaviour to ensure you gamble responsibly |
| Lifestyle and demographic | Such as information available publicly on your social media profile where you connect with or contact us through your social media account. |
| Your communications via our Site and Apps | Such as chat conversations via the Site and Apps, your recorded telephone conversations with our customer support staff and emails. |
| How you use the Site and Apps | Such as which pages you visit, which content you view and what links and buttons you click. This information may be collected through cookies or similar technologies. For more information, please see our Cookie Policy. |
| General Location information | The device or computer you use to access the Site or the Apps will provide us with your IP address. The IP address tells us which city, state or country you are accessing the Site or Apps from, but does not give us detailed information about your location. |
| Device and other technical information | Such as the unique device identifier and logs of installation and deletion of the Apps, and other information about the device’s hardware and software. |
| Advertising and direct marketing preferences and responses | Such as your interaction with offers and competitions, including any requests to stop receiving marketing communications. This information may be collected through cookies or similar technologies. For more information, please see our Cookie Policy. |
| Sensitive Information | We may also Process Data about you that is sensitive in order to meet our legal and regulatory obligations and to protect our business. This includes Data as required by the License Conditions and Codes of Practice, the Gibraltar Gambling Commissioner License Conditions, the Anti-Money Laundering Regulations and the Proceeds of Crime Act and otherwise to fulfil our legal and regulatory obligations as a gambling operator (including allowing you to self-exclude from our Site and Apps and otherwise in accordance with responsible gambling policies). This also includes biometric data (such as through photograph and CCTV) and information about suspected fraud, theft or offences. If you come to an event that we host, this also includes information you provide (such as dietary preferences or disability information). |
3. How we use your Data?
We use your Data in the following ways, and for the following reasons:
| What we use your Data for | The basis on which we can use your Data |
|---|---|
| To register you as a new user on the Site or Apps. | We need to Process this information to meet our contractual obligations. |
| To allow you to use our services (including managing your payments). | We need to Process this information to meet our contractual obligations and to comply with our legal and regulatory obligations. |
| To communicate with you about updates to the Site or Apps, our services, and any changes to our terms and conditions or Privacy Policy. | We need to Process this Data to meet our contractual obligations; to comply with our legal and regulatory obligations; and it is in our legitimate business interests to keep accurate records. |
| To receive feedback from you on our products and services. | We need to Process this Data to meet our contractual obligations and it is in our legitimate business interests to understand how we can improve our products and services. You do not have to provide us with this information. |
| To run our loyalty and VIP schemes, and other promotional events such as competitions and offers which may be of interest to you. We may send you marketing material about our offers and events via email or text. You may opt out of direct marketing at any time (see below). |
We need to Process this Data as it is in our legitimate business interests to provide you with a personalised experience when you use our services. Where necessary, we Process this Data based on your consent. |
| To provide customer support services. | It is in our legitimate business interests to respond to any communications we receive from you. If you do not wish to provide us with this information, we may not be able to respond fully to your queries. |
| To train our staff (for example our call staff). | It is in our legitimate business interests to provide you with a helpful service. |
| To maintain and administer our Site and Apps. | It is in our legitimate business interests to maintain our IT services, network security, to maintain our system; and we need to Process this information to comply with our legal and regulatory obligations. |
| To improve our Site and Apps, products and services, and experiences, such as by understanding analytics. | It is in our legitimate business interests to better understand your preferences, update our Site and Apps, and develop our business strategy. |
| To link your accounts with other sites within LiveScore Group | It is in our legitimate business interests to link your betting account to your accounts on other sites within LiveScore Group (LiveScore.com) to simplify your log in journey. |
| To comply with our legal and regulatory obligations as a gambling operator. This may involve verifying you identity and age. |
We need to Process this information to comply with our legal and regulatory obligations and it is in our legitimate business interests to prevent fraud and illegal activities on our Site and Apps. |
| To protect our business from money laundering, terrorist financing and other illegal activities. We may identify you electronically using technology such as cookies. |
We need to Process this information to comply with our legal and regulatory obligations under gambling, anti-money laundering, anti-fraud and anti-terrorism laws. We also Process this information in the public interest and it is in our legitimate business interests to protect our business from any illegal or abusive use of our Site or Apps. |
| To provide you with advertising which is relevant to you, and to understand your advertising preferences. | It is in our legitimate business interests to understand how you use our Site or Apps, and partner Site and Apps (LiveScore), and how we should develop our marketing strategy. |
| To comply with our responsible gaming policies and to protect you from any irresponsible gambling, including administering self-exclusion. We may identify you electronically using technology such as cookies to identify self-excluders and any customers who we believe may have a gambling problem. |
We need to Process this information to comply with our legal and regulatory obligations and it is in our legitimate business interests to protect you from irresponsible gambling. |
| To comply with our responsible gaming policies and to protect you from any irresponsible gambling, including administering self-exclusion. We may identify you electronically using technology such as cookies to identify self-excluders and any customers who we believe may have a gambling problem. |
We need to Process this information to comply with our legal and regulatory obligations and it is in our legitimate business interests to protect you from irresponsible gambling. |
| In relation with a legal action, or when acquiring or selling a business. | It is in our legitimate business interest to be able to protect ourselves through legal action and to develop the business through acquiring or selling parts of our business. |
| Social Media Marketing | We may also use information you provide to us to show you relevant advertising and personalised content on certain third party social media platforms made available to us through those services (e.g. Facebook, Twitter, Instagram). We do not control the way these social media platforms operate and collect your information and you should read their respective privacy notices online to understand how they use your personal information. If you no longer want to receive personalised and targeted advertisements from the social media platforms, you can manage your advertising preferences and decide what you want or do not want to see using the settings in your relevant social media platform account. |
4. Who do we share your Data with?
In some cases, we may share your Data with third parties in order to support your needs, to provide you with services, or to comply with our legal obligations. We may also share Data with third parties if it is in the public interest or the sharing is in our legitimate interest or the legitimate interest of another organisation.
We check your identity when you first become a customer, we share information with a TransUnion and this will leave a note on your credit file. This check involves automated decision making, as detailed in Section 5.
The other organisations we may share your Data with are typically:
* Members of the LiveScore Group for the purposes in section 3 above.
* Third-party suppliers and service providers for the purposes identified above – in particular we work with platform services (to provide betting and account management functions), content providers such as SportRadar (to provide geolocation specific streaming content) – for more information on how SportRadar treat personal data, please see their Privacy Notice, cloud providers (to host the Site and Apps), affiliate platform services, customer support software services, data storage services, payment service providers, know-your-customer and anti-money laundering services as well as enhanced due diligence and anti-fraud services, gambling restriction service providers (such as GAMSTOP), data matching services (to ensure we receive accurate information if you register for GAMSTOP) and click fraud detection and protection services.
* Business partners and other organisations to help us meet our contractual and regulatory obligations, including audit, legal and compliance services.
* Affiliates and third parties which you have opted out of marketing communications with, have been barred or have self-excluded, so that we can ensure that you do not receive unsolicited promotional material.
* Identity verification and fraud prevention agencies such as other gambling operators, banks, credit card companies and similar agencies which investigate and prevent underage, fraudulent, criminal or suspicious activity, or any other behaviour we are legally required to investigate. We will also pass on your information if we have reason to believe you have undertaken such activity.
* Analytics and search engine providers and other selected organisations which provide us with feedback about our Site or Apps and aid us in improving their optimisation.
* Statutory authorities when we are required to comply with a request for information, a court order disclose your Data, a regulatory investigation from a relevant governmental or gambling or regulatory authority, our legal obligations including our requirement to report suspicious behaviour.
* Sporting integrity organisations to comply with our legal obligation to protect the integrity of sport and to ensure that betting markets are fair and free from corruption.
* Regulator, law enforcement or fraud prevention agencies as well as legal professionals, courts and other adjudication services to investigate any actual or suspected criminal activity.
We may also share your Data to third parties:
* If we consider selling or acquiring businesses or assets, in which case we will share your Data with the counterparty.
* If the LiveScore Group, or any of its group companies, becomes insolvent (i.e. becomes subject to administration or liquidation processes).
* If we, or substantially all of our assets, are acquired by a non-LiveScore Group entity.
* When we check your identity when you first become a customer, we share information with TransUnion 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.transunion.co.uk/legal-information/bureau-privacy-notice.
* If we need to enforce our terms and conditions.
* To protect our safety, rights or property, or the safety, rights or property of our customers, staff and others by sharing information with other companies and organisations such as the local police.
* Where we are trying to support your decision to self-exclude , we may share your Data with regulators or other gambling organisations.
We may share aggregated or anonymised Data to gambling addiction prevention organisations such as GAMSTOP or academic institutions to allow them to conduct research into problem gambling and inform our business practices and better protect vulnerable people.
5. Automated Decision Making
'Automated Decision Making' refers to a decision which is taken solely on the basis of automated processing of your personal data. This means processing using, for example, software code or an algorithm, which does not involve human intervention.
As profiling uses automated processing, it is sometimes connected with automated decision making. Not all profiling results in automated decision making, but it can do.
As a customer of Virgin Bet, we use automated decision making to carry out a credit reference on you regarding your account and certain deposit and withdrawal transactions. This is used to verify your age, identity, or any other information that you provide to us. In performing these checks, TransUnion may process your publicly available data (which may include insolvency/bankruptcy events or court judgments entered against you); and may keep a record of your information. A credit check is not performed and your credit rating will be unaffected. These checks enable your Account to be opened, reduce the need to obtain age and identification documents and assist us with our age and identity verification licensing obligations and our crime and fraud prevention policies.
Where you have chosen to self-exclude in accordance with our responsible gambling policies, we may use this information as part of the automated decision making. This may involve the processing of special category data.
We will only use automated decision making if it is authorized by legislation, if you have provided an explicit consent or (for non-special category data) if it is necessary for the performance of a contract. You have certain rights in respect of automated decision making, where that decision has significant effects on you, including where it produces a legal effect on you. See Section 11 for more information about your rights.
6. How long do we retain your Data?
We will not keep your Data for longer than is required for the purposes for which we collected it, including for the purposes of satisfying any legal requirements. The length of time for which we retain your Data will depend on what we are using it for as set out in this Policy, the nature of the Data and how sensitive it is. For example, we will keep you email address while dealing with your enquiries but, even when you unsubscribe, we are required to continue to retain your email address to ensure that we do not send you any email communications in the future and for our know-your-customer (“KYC”) purposes.
Please note, however, that we may be subject to legal and regulatory requirements to keep your Data for a longer period. We may also extend the retention times where the Data is needed to investigate a crime, handle a claim or resolve a complaint. As a general rule, we keep your Data based on the criteria below:
| Type of Data | Typical Retention Time | Information |
|---|---|---|
| Marketing consents | Until you no longer consent | If you withdraw consent, we will keep this information on a ‘suppression list’ so we don’t contact you |
| Customer call recordings | 7 Years | An extended retention may be applied on a case by case basis |
| Customer Data | Seven years from the date your account is closed | We will only continue to retain this Data where this is: * Legally required under gambling or tax legislation or regulations; or * Required to exercise or defend our legal rights |
Where it is no longer necessary to Process your Data, we will delete it or anonymise or aggregate it by removing all details that identify you in accordance with Data Protection Legislation.
7. Where do we transfer your Data?
We primarily store and Process our Account data within the European Economic Area (“EEA”). However, if we transfer your Data outside of the EEA, we ensure a similar degree of protection is afforded to it to safeguard your Data in accordance with Data Protection Legislation, which can include by: (i) ensuring that your Data is only processed in countries which provide adequate data protection laws (in accordance with the Data Protection Legislation); (ii) requiring recipients to sign up to strong contractual commitments that ensure the protection of your Personal Data (such as the EU Model Clauses); and/or (iii) taking any other measures that comply with Data Protection Legislation.
8. Keeping your Data safe
While the nature of the internet means that the transmission of information may not be totally secure, we have implemented security measures to prevent your Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Where you use a password to access certain services or features of our Site or Apps, please keep this confidential and do not share with anyone. Unfortunately, we cannot guarantee the complete security of the information transmitted via the internet. While we have implemented security measures, any transmission is at your own risk.
9. Cookies
We use Cookies on our Site and Apps for the purposes above. For more information, please see our Cookies Policy.
10. Marketing
Social Media Marketing. We may also use information you provide to us to show you relevant advertising and personalised content on certain third party social media platforms made available to us through those services (e.g. Facebook, Twitter, Instagram). We do not control the way these social media platforms operate and collect your information and you should read their respective privacy notices online to understand how they use your personal information. If you no longer want to receive personalised and targeted advertisements from the social media platforms, you can manage your advertising preferences and decide what you want or do not want to see using the settings in your relevant social media platform account.
In addition to the use of cookies we also build profiles on Facebook by using your email address and other personal data. These profiles are used to create lists of users that are more likely to respond to targeted digital display adverts. We do this by creating what are called Custom Audiences and Lookalike Audiences, using Facebook as our Data Processor.
To achieve this, your data is hashed on our local system before being shared with a third party. Hashing turns the Personal Data in a file into short fingerprints of code that cannot be reversed. This pseudonymised data is more secure as no third party can decrypt it.
To test the effectiveness of our campaigns we may also make use of Facebook’s Offline Conversions function, where customer sales data is hashed similar to the above and compared to hashed Facebook users that were served an advert. This function then informs us to whether there is any correlation between the advert and the subsequent purchase.
When we process your personal data for our legitimate interests in this way we take great care to consider and balance any potential impact on you and your rights.
If you wish to object to the processing of Personal Data being used in any of the ways listed above or you simply have questions about this, please contact us via dpo@virginbet.com .
However, the nature of Detailed Targeting via Facebook means that some of our adverts can still reach you (even if we have not used your Personal Data to create Custom or Lookalike Audiences). In this scenario Facebook is the Data Controller and will provide options within its privacy settings to allow you to opt out.
Research: To determine the effectiveness of promotional campaigns and advertising and to develop our products, services, systems and relationships with you.
You can tell us whether or not you wish to be contacted for marketing purposes and, if so, how we can contact you. We will obtain this information from you when we first collect your Data and we will ask you what kind of communication you would like to receive from us.
You can opt-out from receiving marketing communications from us at any time by following the instructions below:
* Email marketing: to opt-out from emails, use the unsubscribe link provided within any email you receive or manage your preferences through the “Account Details” section of the Site or App.
* SMS Marketing: to opt-out from SMS, you can use the STOP code provided in any SMS you receive or manage your preferences through the “Account Details” section of the Site or App.
* Call Marketing: to opt-out from being contacted by telephone for marketing purposes, you can manage your preferences through the “Account Details” section of the Site or App.
* Post Marketing: to opt-out from receiving marketing by post, you can manage your preferences through the “Account Details” section of the Site or App.
Push notifications: to opt-out from receiving push notifications, you can disable push notifications on your device or browser settings.
Please be aware it may take up to 28 days for your request to take effect. Please note you will still receive other important information about our product and services.
11. Your rights
Under Data Protection Legislation, you have a number of rights in relation to your Data. We have listed these below, but please note that some only apply in certain specific circumstances (detailed in the Data Protection Legislation):
| Your rights | How to exercise your rights |
|---|---|
| Right to access and receive a copy of the Data we hold about you. | It is generally free for you to request access to your Data by completing our Webform. If your request is repetitive or excessive, we may refuse to comply or we may charge you a fee. More information can be found here |
| Right to correct any inaccurate Data we hold about you. | You can amend, correct, delete or edit your Data in the “Account” section of the Website. If you wish to correct other Data, please contact our customer support team. Please see our contact details here. |
| Right to require us to erase your Data if (for example): (i) we no longer need the Data for the purpose we originally collected it for; (ii) we only collected it with your consent, and you now withdraw your consent; or (iii) you object to how we are Processing your Data. | You can request erasure of your Data by contacting our customer support team. Please see our contact details here. Or be completing our WebForm here This process is not reversible. |
| Right to request that we restrict the Processing of your Data if (for example): (i) you believe that the Data we hold on you is inaccurate; (ii) you have the right to request that we erase your Data but would prefer us to restrict our Processing instead; or (iii) we no longer need the Data for the purpose we originally collected it for but you require the Data for legal actions. | You can request the restriction of Processing of your Data by contacting our customer support team. Please see our contact details here. Once you have requested this you can change your mind at any time by contacting us again. Your account will not be accessible while the restriction is in place. |
| Right to request a copy of the Data we hold on you in a structured, commonly used and machine readable format. You can also request that we transfer this to a third party on your request. Please note that this right may not apply to all of your Data. | In some circumstances, you can request the transfer of your Data to a third party by email to dpo@virginbet.com. The request must include which Data you would like to be transferred, to whom it should be transferred and by which method. |
| Right to object to our Processing of your Data, including for marketing purposes. Please note that in some cases, we may demonstrate that we have legitimate grounds to Process your information which overrides this right. | You can object to Processing of your Data by contacting our customer support team. Please see our contact details here. Once you have objected you can change your mind at any time by contacting us again. Your account will not be accessible while the restriction is in place. |
| Right to not be subject to a decision based solely on an automated process, such as profiling, which results in you being significantly affected or produces legal effects concerning you. | You can exercise this right by contacting our customer support team. Please see our contact details details here. |
| Right to withdraw your consent where we only Process your Data based on your consent. You can withdraw your consent to receive marketing communications from us at any time and for free. | To exercise your right to withdraw your consent to receive marketing communications please see section 10 above. |
12. Privacy policies of other websites
Our Site or Apps may contain links to other websites. This Policy only applies to our Site and Apps. If you click on a link to another website, you should read their privacy and cookie policies to understand how they Process your information.
13. Changes to this Privacy Policy
We may, from time to time, change or update this Privacy Policy in line with legal requirements or if our business changes. All changes to this Privacy Notice will be published on this page of the Site or in the relevant section of the App. Each change will become effective on publication. We recommend that you revisit and read this Privacy Policy regularly to ensure that you are up-to-date with the current terms.
This policy was last reviewed and updated in February 2023.
14. Questions?
If you have any questions or comments about this Policy, want to know more about how we use your Data, or want more information on your rights, please contact our Data Protection Officer by emailing: dpo@virginbet.com.
15. Complaints
If you have a complaint about how we Process your Data, please contact us at dpo@virginbet.com and will try to resolve this. However, if you feel that we haven’t addressed your concern in a satisfactory manner, you have the right to complain to the Information Commission (“ICO”) (www.ico.org.uk) or the Gibraltar Regulatory Authority (www.gra.gi).
Glossary
| Term | What this means |
|---|---|
| Data | Information relating to an identifiable person, who can be directly or indirectly identified in particular by reference to an identifier, or which is otherwise defined as ‘Personal Data’ under Data Protection Legislation. |
| Data Protection Legislation | Data Protection Act 2018, EU General Data Protection Regulation 2018 (GDPR), the Privacy and Electronic Communications (EC Directive) Regulations 2003, and any other applicable laws relating to the protection of Data. |
| Process, Processing or Processed | Accessing, collecting, obtaining, recording, holding, disclosing, using, altering, deleting, erasing or destroying Data, or carrying out any operation(s) on the Data or as otherwise defined under applicable Data Protection Legislation. |