Privacy Policy by Winbox

1. Introduction

1.1. This Privacy Policy sets out the way in which Winbox Plc (“we” or “us”), a company incorporated and registered in the isle of Man, collects and processes Personal Information (as defined in paragraph 2.1 below).  If you have any questions about this Privacy Policy or the processing of your Personal Information, please contact us at [email protected]

1.2. We operate the website under the Winbox Group companies banner. We will share your Personal Information in accordance with this Privacy Policy.

1.3. By using our website, you acknowledge Winbox (and any companies in our Group) will process your Personal Information in accordance with this Privacy Policy, including for the purposes set out in paragraph 5 below. If you do not wish to provide your Personal Information on the basis set out in this Privacy Policy, you should not enter the relevant information on the website forms, or otherwise provide us with any of your Personal Information. However, if you do not provide your Personal Information, we may not be able to provide support regarding your queries.

1.4. Capitalised terms are defined in this Privacy Policy

2. The information we collect

2.1. As part of operating the Website, we collect your Personal Information. “Personal Information” means any information from which you can be personally identified, including your name, email address, home or business address and telephone number. Please see paragraph 5 for exhaustive list of personal data collected.

2.2. We collect Personal Information which you provide to us, including when you register interest and information you provide in communications with us. In addition, we collect information about your use of the website.  We will also collect other information necessary for us to process your Personal Information for the purposes set out in this Privacy Policy.

3. Information we collect through Cookies and similar technologies

3.1 We collect information through “Cookies” and other similar technologies (e.g. pixel tags or links). This helps us to remember you when you visit the Website, and to improve your experience.

3.2 We also use information collected through “Cookies” and other similar technologies to detect any abuse of our Website and Services, and to help verify your age upon entry of site.

3.3 To find out more about “Cookies” and similar technologies please see paragraph 13 of this Privacy Policy.  More information about the purposes of the “Cookies” and what is collected and how we use the data, this can be found in paragraph 13.5.

4. Information collected from third parties and how we use it

We do not use information from any third-party service providers.

5. How we use your Personal Information

5.1. In accordance with data protection laws, we will only process your Personal Information where we have a lawful basis for doing so. In respect of your Personal Information, these bases are:

Via the Player enquiry form, if you have a complaint (account, gameplay issues withdrawal issues) or you wish to self-exclude, we will collect: Full name, full address, contact number, email address.

Via Sales enquiry form: If you wish to initiate a commercial agreement with Winbox, we will collect Full name, country of origin, email address and contact phone number.

Via the Careers page: we will collect your CV (which contains full name, contact number, email address, education, work experience etc.) that you submit for an application for open position with Winbox.

Reporting Security issues (direct email from you): The information you supply our security team, when advising of any technical issues. For example, your email address, your name and contact details Phone number / address if you choose to provide this in the email.

Via Marketing / Merchandise provision (Business Partners only):

Your email address for general correspondence, Marketing news and Service News,

your name, address & Contact number for the provision of merchandise and/or corporate gifts

6. Disclosure of your Personal Information

6.1. We may, for the identified stated purposes, disclose your Personal Information to any of the following recipients:

6.1.1. any company within our Group (including to its employees and sub-contractors) which assists Winbox in fulfilling the stated purposes or which otherwise has a need to know such information;

6.1.2. any third party which assists Winbox in fulfilling the stated purposes, including (but not limited to) providing support through Human Resources, Commercial team, Compliance team or our Information Security team;

6.1.3. any third party which can which assists Winbox in verifying the accuracy of your Personal Information, including financial institutions and credit reference agencies (a record of the search may be retained by such third party), if required with the Self Exclusion request;

6.1.4. any third party which assists Winbox in monitoring use of our website, including the detection and prevention of fraud and collusion,

6.1.5. to Operators when supporting in Self-exclusion requests or complaints;

6.1.6. 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 Winbox;

6.1.7. any law enforcement body which may have any reasonable need to access your Personal Information; 

6.1.8. any regulatory body or authorised entity (e.g. a sporting body or law enforcement agency) which may have any reasonable requirement to access your Personal Information; and

6.1.9. any potential purchaser of our business or any investors in it or in any company within our Group (including in the event of insolvency).

6.2. If at any time you wish us to stop processing your Personal Information for the above Purposes (stated in paragraph 5), you should contact us and we will take the appropriate steps to stop doing so, if there are no regulatory requirements. Please contact [email protected]

7. Marketing Preferences

7.1. Winbox or any company within Winbox Group will not send you unsolicited information regarding any third party’s products or services.

7.2. As part of any account registration process (business partners only), you will have the opportunity to choose whether or not to receive information on Winbox offers and promotions.

7.3 At the time of setting up your account by Winbox (for business partners only), this is on the basis you wish to be kept updated on Winbox promotions and services. You will have the opportunity to inform us that you no longer wish to receive them. You may update your marketing preferences at any time by clicking on the “unsubscribe” link in an email and following the instructions or contact [email protected].

8. Transfer of your Personal Information outside of the EEA

Your Personal Information will be transferred outside of the European Economic Area, both to us and other members of our Group. This includes, but is not limited to, the Ukraine, Isle of Man, Guernsey, Philippines. Please refer to Paragraph 5 for the explicit list of all geographic locations, associated with the purposes. Where we transfer your personal data outside of the EEA, we will put in place adequate measures to ensure that your Personal Information is kept secure (and such adequate measures shall include: (i) transferring to a jurisdiction which the European Commission recognises as providing adequate protection for the rights and freedoms of data subjects in connection with the processing of their personal data; and (ii) transfers pursuant to standard contractual clauses in accordance with European Commission decisions on transferring personal data).

9. Updating your Personal Information

You may request an update or deletion of your Personal Information at any time via the relevant contact page or [email protected].

10. Your rights

10.1. You have the following rights in relation to your Personal Information:

10.1.1. a right to access your Personal Information as held by us (also known as a subject access request);

10.1.2. a right to receive certain Personal Information in machine-readable format;

10.1.3. a right to object to processing where the lawful basis is that it is in our legitimate interests, but please note that we may still process your Personal Information where there are other relevant lawful bases or where we have compelling grounds to continue processing your Personal Information in our interests which are not overridden by your rights, interests or freedoms;

10.1.4. a right to have inaccurate Personal Information rectified;

10.1.5. a right to have certain Personal Information erased where it is no longer necessary for us to process it, where you have withdrawn your consent pursuant to paragraph 10.1.8, where you have objected pursuant to paragraph 10.1.3, where your Personal Information has been unlawfully processed, or where erasing your Personal Information is required in accordance with a legal obligation;

10.1.6. a right to request an explanation of the logic involved where we make decisions about you solely through automated means;

10.1.7. a right to complain to the Information Commissioners Office;  if you have any complaints regarding Data Protection.

10.1.8. where we have specifically requested your consent to process your Personal Information and have no other lawful conditions to rely on, you have the right to withdraw this consent; and

10.1.9. a right to object to direct marketing, which can be done by opting out of direct marketing via the communication itself.  You also have a right to object to any profiling to the extent that it relates to direct marketing only.

10.2. If you are unsure about your rights or are concerned about how your Personal Information may be processed, you should contact your national data protection regulator.

10.3. If you would like to exercise any of your rights, then you can do so by contacting us as described below.  Please be aware that while we will try to accommodate any request you make in respect of your rights; they are not absolute rights.  This means that we may have to refuse your request or may only be able to comply with it in part.

10.4. Where you make a request in respect of your rights, we will require proof of identification.  We may also ask that you clarify your request. We will aim to respond to any request within one month of verifying your identity.  If we receive repeated requests or have reason to believe requests are being made unreasonably, we reserve the right not to respond.

11. Retention of your Personal Information

We will retain your Personal Information for the period necessary for us to provide you with our Services and to comply with our legal and regulatory responsibilities.  Accordingly, please refer to paragraph 5 for the retention periods.  Where it is no longer necessary for us to process your Personal Information, we will delete it sooner as stated in section 5.2.  If you request that you should not be able to access our Services (i.e. self-exclude), we will retain this information for a maximum of 6 years, from request, before deletion.

12. Contacting us

12.1.  If at any time you believe that we have not adhered to this Privacy Policy, please contact our privacy team at [email protected]

13. Our use of Cookies

13.1. We may collect anonymous information about your use of the Website using “cookies”, pixel tags and similar functionality. A “cookie” is a small file of text which is downloaded onto your computer when you access the Website, and it allows us to recognise when you come back to the Website. We use cookies for the operation of this website. For these purposes, Cookies are placed on your device to identify you in the future when you visit our website or connect with any of our applications. 

The cookies used on this Website are either set by us or by our third-party service providers, and fall into the following categories:

1) Strictly Necessary – these cookies are essential in order to enable you to move around the Website and use its features. If you remove or disable these Cookies, we cannot guarantee that you will be able to use our Websites or benefit from all our security features.

Some of these are “session cookies”, which stay in place only for the duration of your visit to our website and are deleted at the end of your browsing session. Others are “persistent cookies”, which remain on your device for a period of time after you have left the Website. See 13.5 for retention periods of each cookie.

13.2. Most browsers have cookies enabled by default, but you are able to change your cookies settings, which are usually found in the ‘options’ or ‘preferences’ menu of your internet browser. You can block any cookies from any website by activating the setting on your browser that allows you to refuse the setting of some or all cookies. However, if you block all cookies you may not be able to access all or part of our Website. You can also use your browser settings to delete cookies. For more information about how to disable cookies in your browser please visit www.allaboutcookies.org.

13.3. As part of the Website’s operation, our Website automatically logs internet IP addresses. We do NOT log any e-mail address of visitors to the Website.

13.4. While the Website may contain links to websites operated by parties other than us, we are not responsible for the privacy practices or content of such websites.