Privacy Statement
This privacy statement details
how we use your personal data. Last Updated 17th July 2023.
In This Article:
1. OVERVIEW
2. PERSONAL DATA TYPES WE USE
3. HOW AND WHY WE USE YOUR
PERSONAL DATA
4. GENERAL PROCESSING
INFORMATION
1. OVERVIEW
Welcome to the etec Global Ltd Ltd privacy
statement.
This privacy statement
(“Statement”) is designed for you to easily access the information you need,
when you need it.
This Statement applies to our
registration website, (our "Service").
We trust that you find this
Statement helpful but if you have any concerns or questions
please feel free to share feedback via the contact methods listed in the
Contact details.
1.1. Introduction to etec Global
Ltd
1.1.1. Controller details
References in this document to
"us", "our", "we", “etec Global” or “SBG” are
references to the following data controllers:
etec Global Limited, is a
company registered in England and Wales (14204390 with registered offices
located at: 28 Dudley Street, Grimsby, N e Lincolnshire, DN31 2AB United
Kingdom.
etec Global Limited is the
exclusive representative of New Wave Interactive Ltd, a corporation duly
organised and existing under and by virtue of the laws of the Territory of the
British Virgin Islands with office at Morgan & Morgan Building, Pasea estate, Road Town, Tortola, British Virgin Islands
for the purposes of extending the reach of the licence and licensed network in
Europe.
Etec Global is the data
controller of personal data processed in relation to the Service.
1.1.2. Contact details, including
DPO
If you have any concerns about
how etec Global handles your personal data, you can contact our Data Protection
Officer (DPO) and Data Protection Team at: info@etec.world.
1.2. Privacy and Data Protection
at etec
Data protection is all about
keeping your personal data safe and secure, and ensuring that your legal rights
in relation to your data are respected. Privacy is a fundamental right, and you
are entitled to have your personal data protected, used in a fair and legal
way, and made available to you when you ask for a copy.
1.2.1. Our commitment
At etec, we take the protection
of our customers’ personal data and privacy very seriously, and we never lose
sight of the fact that your personal data is YOUR personal data.
We believe in using your
personal data to make things simpler and better for you, and we will always
keep your personal data safe using the highest standards of security. We’ll be
clear and open with you about why we collect your personal data and how we use
it, and where you have choices or rights, we’ll explain them to you and respect
your wishes.
1.2.2. Our key privacy and data
protection principles
To meet these commitments, we
employ the following 3 principles at etec. These principles are at the heart of
everything we do and ensure that your rights are considered at every step.
1. Keeping your data secure: We are committed
to employing best-in-class security measures to protect your information and
our technological security solutions are governed by a mature framework.
2. Transparency: Transparency is a key
principle of data protection. Our Privacy Statement provides you with
everything you need to know about how your information will be used by etec.
3. Giving you the choice: We believe that
respecting your privacy begins with giving you a say in how it is used.
1.3. How to navigate and read
this document
We have designed this Statement
so that you can easily access the information you need. It is split into three
parts as follows:
PERSONAL DATA TYPES WE USE
explains the different types of personal data that you provide to us when you
use our Services, that is generated when you use our Services and that we
collect from other sources.
HOW AND WHY
WE USE YOUR PERSONAL DATA explains what we use your personal data for. It
contains different sections for each type of personal data usage, with each
section providing information on the purposes and legal basis for using the
data, as well as on any sharing of the data that may occur.
GENERAL PROCESSING INFORMATION
contains information about our personal data processing that is relevant to all
individuals who engage with our Service.
For information on cookies,
please see our our Cookies Policy further in this
document.
1.4. Changes to the Statement
It is important to check back
often for updates to this Statement. If we make material and important changes,
we will let you know by placing a notice and/or contacting you using other
methods such as email.
2. PERSONAL DATA TYPES WE USE
We gather and use different
types of personal data that you provide to us, that is generated through your
use of our Service or is which we have collected from other sources. This data
includes your registration information, verification and know your customer
documentation, your interactions with our customer operations teams, payment
information, financial information, safer gambling information, device,
tracking and other online information, profiling and analytical information, as
well as information from other sources including public sources and trusted
third parties.
2.1. Data provided by you
When using our Services, we
collect the following types of information provided by you:
Registration Information
When you register an application
with us, you are required to provide us with details including your name, date
of birth, postal
address, e-mail address, phone number, any other details as might be requested
from you for the purpose of registration and/or continued use of our Service.
As a condition to using our
Service, we will ask you to share your precise geolocation so we can ensure
that we are authorised to provide the Services to you in your location.
Verification and Know Your
Customer (‘KYC’) Documentation
In order to verify your
identity, you may be required to provide documents such as a copy of your
passport or driver’s licence, documentation establishing your address such as
utility bills, or any other information we deem necessary to confirm your age
and/or identity.
Interactions with Customer
Operations
When you interact with our
customer operations via live email we will retain a record of your
conversations with our staff, as well as notes relating to these interactions
and their outcomes.
Financial Information
Payslips or other documents
proving your source of wealth including but not limited to proof of earnings,
bank statements and evidence of business ownership.
2.2. Data created by using our
Services
Some of the personal data we
process relating to you is generated by your use of the Service.
Device Information
Details relating to your device
and communication data, including IP address, browser type, unique device
identifier, IDFA, hardware model, operating system and version, software,
preferred language, serial numbers, device motion information, mobile network
information and location data.
Server Logs and Traffic
Information
Information such as dates and
times of access, the app features or pages you view, app crashes and other
system activity, and the third-party site or service you were using immediately
before visiting our site.
Cookie and Tracking Information
When you access or use our
Service, we may collect information from your devices through the use of
'cookies' and similar technologies.
These technologies can collect a
wide variety of information about how you interact with our Service, such as
your language preferences, pages visited and content viewed, links and buttons
clicked, and URLs visited before and after you use our Services.
For further detail on cookies, please refer to our Cookies Policy. To
manage your cookie preferences, please go to our onsite Cookie Management
centre (located at the bottom of our websites).
2.3. Data from other sources
Not all the personal data we
hold about you will always come directly from you or from your use of our
Services. As detailed below, we may also collect information from third parties
such as our partners, service providers and publicly available websites (i.e. social media platforms), to comply with our legal and
regulatory obligations, offer Services we think may be of interest, to help us
maintain data accuracy and to provide and enhance the Service.
Credit Reference Agencies
Data provided by trusted credit
reference agencies who may perform a soft check for verification and
affordability purposes which do not affect your credit score. A record of the
outcome of these checks is provided back to us.
3. HOW AND WHY WE USE YOUR
PERSONAL DATA
We only use your personal data
where necessary and where it is lawful to do so. Our use of your personal data
is needed to enable us to deliver the Service to you, to meet our legal or
regulatory obligations, to meet or protect yours, ours, the wider public’s or
other third parties’ interests, and sometimes for other reasons only where we
have your explicit consent to do so.
Below, we explain how and why we
need to use your personal data, providing you with information on our different
uses of your personal data. This includes detailed information on the reasons
for using your data, the types of personal data we use and also information on
the legal basis for using your data, which may include using your personal
data:
To enter into or perform a
contract with you (‘Performance of a contract’), such as delivering our Service
in accordance with the terms and conditions;
To meet our legal or regulatory
obligations (‘Legal and regulatory obligations’), such as our taxation, company
or data protection law or our licencing obligations;
To meet our own legitimate
interests or those of a third party (‘Legitimate interests’), such as where we
use data to protect our business assets or information, to improve our Services
or to keep you safe while you use our Services;
To perform tasks in the
interests of the general public (‘Public interests’), such as safeguarding the
public from gambling related harms; or
3.1. Analysing the use of our
site by website visitors
3.1.1. Who the section applies to
All visitors to the service.
3.1.2. Overview
We use your personal data to
provide you with the Service and ensure that our sites and apps are functioning
correctly.
We use technical information
about your device, operating system and browser version to present you with the
correct version of our website or app and to keep it functioning securely. This
information is also used to diagnose system problems, improve and test the
features and functions of our Services, and carry out testing.
In order to abide by our legal
and regulatory requirements, we will also check your location to ensure users
are using our Services in licensed countries, and that the correct version of
the site is presented to them.
We also perform analysis of the
performance and usage of our website to help improve your user experience. For
further information on cookies, please refer to our Cookies Policy
3.1.3. Who we share your personal
data with
We use a number of tools to
assist in performing analytics on our site, such as Adobe.
3.2. Registering & verifying
your account
3.2.1. Who the section applies to
All customers that register and submit
an application.
3.2.2. Overview
When you register an account
with us, you are required to provide us with certain information in order to register
your application and verify your identity. This allows us to ensure that you
are who you claim to be and that you are old enough to use the Services. As
part of this process, we rely on trusted third parties to assist us in confirming
the details you have provided.
In certain circumstances, you will be required
to provide us with a copy of your photographic identification, such as passport
or driver’s licence. We may also ask you to provide us with proof of address,
such as a copy of a recent utility bill.
Once you provide your
identification documentation, we will perform automatic system matching against
information entered when opening an account and if the match is confirmed,
verification is successful. Where we have been unable to successfully match a
customer’s details the application for the service may be temporarily suspended.
The process is overseen by our Customer Operations teams. If you have any
queries or concerns about the verification process or an account suspension,
please get in touch and one of our advisors will be able to assist.
3.2.4. Who we share your personal
data with
Document checking – We may use
third parties to help in confirming the legitimacy of the documents you have
submitted, including Jumio.
Electronic verification – We may
use third parties to verify that the details you have submitted are legitimate.
Credit checking – We may use
credit reference agencies to verify your details and the amount that you can
spend on our Services.
3.3. Processing your payments
& delivering the Service.
3.3.1. Who the section applies to
All applicants who successfully
register an application for the service.
3.3.2. Overview
In order to process your payment we may use information in relation to your chosen
payment methods. These details are used where possible, to prevent fraudulent
use of your payment methods, and to monitor trends and performance in relation
to our payment Services.
If you have concerns in relation
to a payment that you have made, we will investigate your query promptly and
may use further information in relation to your account to support this investigation.
You may be asked to provide further information, and in certain circumstances,
we may contact your bank or payment provider to resolve the issue.
In certain circumstances, where
we have concerns over payments being made on customer accounts, we may perform
additional due diligence to confirm that funds are being sent and received from
the true owner of the account. We may
examine details in relation to your location, IP address or device to confirm
where payments are being made from. We may also require you to submit
additional verification documentation to confirm your ownership of the payment
method in question.
3.3.4. Who we share your personal
data with
Payment providers - Sharing details in
order to process your transactions with your registered bank.
Fraud prevention service
providers, such as Iovation;
3.4. Contacting Customer
Operations
3.4.1. Who the section applies to
This section applies to any
person that contacts Customer Operations via email.
3.4.2. Overview
From time to time, you may
experience issues with the Service, or may have queries about the markets or
products we offer.
When you contact our Customer
Operations teams via the contact methods we offer, we will use information
relating to your account and activity, as well as the information you provide
to our staff, to investigate your query and work towards a resolution.
In order to process your query,
you may be asked for additional information in relation to the issue you are
facing. Any information you provide may be shared internally with other
relevant operational teams.
Please note that all
interactions you have with our Customer Operations functions are recorded and
retained. We use a number of third-party software tools to help deliver our
support functions, and information you share with will be processed and/or
stored on these tools.
3.5 Anti-Money Laundering and
Counter-Terrorist Financing
3.5.1. Who the section applies to
All applicants to the Service.
3.5.2. Overview
As a licensing related company we have certain legal obligations we need to abide
by. One set of such obligations requires that we do everything we can to
prevent money laundering. At etec, and in accordance with the terms and
conditions of our Services, we will use your personal data to ensure the
proceeds of crime are not being used by individuals using our Service, and to
identify and tackle such behaviours.
As outlined in the Registering
& verifying your account section above, where you initially register an
account with us, we are required to gather certain information about you in
order to verify your identity, as part of our EDD requirements. For this purpose you
may be required to submit documentation establishing your identity and address,
and where required, any other information as may be deemed necessary to confirm
your identity.
etec adopts a risk-based
approach to compliance with its Anti-Money Laundering obligations, and,
depending on your personal characteristics and activity levels, we may be
required to gather further information on you, in order to meet requirements
under applicable legislation. As part of this EDD process, we may collect and
store financial information in relation to you, as well as information gathered
from publicly available sources such as the land registry, the register of
companies and social media.
In certain circumstances, we may
require you to provide additional documents proving your source of wealth including
but not limited to proof of earnings, bank statements, payslips and evidence of
business ownership. Such processing will always be conducted with due regard to
your privacy.
As part of our obligations, we
also regularly screen our customer base against databases of publicly available
information. This ensures that we are not offering our Services to individuals
who have been the subject of sanctions, and allows us to identify individuals
who have been the subject of adverse media report, and ‘Politically Exposed
Persons’. For this purpose, we may use Finscan, a
trusted provider of such databases.
Where suspicious activities,
behaviours or characteristics are identified, further investigation will be
conducted, and where necessary, actions may be taken in relation to your
account. This may result in your account being suspended until such time as
further information is provided by you, or your account being permanently
closed. We may also be required to inform local law enforcement authorities or
government agencies, as mandated by law.
3.5.3. Who we share your personal
data with
Providers of databases for
screening purposes such as Finscan;
Third-parties who assist with
verification and Due Diligence, such as GB Group and Iovation;
3.6. Onsite or In-App
Personalisation
3.6.1. Who the section applies to
All users of the service or
other assets covered by this Statement.
3.6.2. Overview
We use personal data to deliver
and suggest tailored content to personalise your experience with our Services.
This is processing which is necessary for the purpose of our legitimate
interests in delivering or presenting relevant content to our customers.
Whichever Service you use,
wherever and however you interact with us, we want to give you the same great
level of service and make it personal to you. We will tailor your experience,
personalising the layout and content of our sites according to what we know
about you.
3.7. Other Purposes
3.7.1. Who the section applies to
All individuals who engage with
SBG or use its Services.
3.7.2. Overview
In addition to the purposes we described above, there are other circumstances
in which we are required to process your personal data, as described below:
Information/Disclosure Requests
and Regulatory Submissions
Apart from the functions set out
in this Statement, we do not share your personal data with third parties except
where we are compelled or permitted by law to do so. These circumstances are
rare but may require us to share information in response to requests from
courts, law enforcement agencies, regulatory agencies, and other public and
government authorities, which may include such authorities outside your country
of residence.
Whenever we share personal data,
and whatever the circumstances, we will always do so legally and with due
regard to your privacy. If we receive a request from law enforcement or other
statutory bodies, we do not disclose personal data without a warrant, court
order or other legally valid proof of authority.
Restructuring
If ownership of all or part of
our business changes or we undergo a reorganisation or restructure, we will
transfer your personal data to the new owner or successor company so we or they
can continue to provide the Services you have requested.
Financial Reporting and Analysis
In accordance with our
obligations under company law and other similar regulations we are required to
keep a record of your transactions in order to maintain proper financial
records to meet and to ensure all transactions are being performed in
accordance with the Terms and Conditions of our Services.
4. GENERAL PROCESSING
INFORMATION
This section provides you with
some other important information you need to be aware of in relation to how we
use your personal data, including information on international transfers of
your personal data, how we keep your personal data secure and how long we need
to keep your personal data for.
4.1. International transfers
Some of the third-party
providers we may use are based in, or carry out their activities in, countries
outside the European Economic Area (‘EEA’) and/or outside the UK.
Countries outside the EEA and UK
do not always have strong data protection laws. This means that, unless your
personal data is being transferred to a country where the European Commission
or UK has determined there to be an adequate level of protection, we have to
put in place additional protections to ensure that your personal data is protected
to the same level as it is within Europe or the UK.
We put these additional
protections in place by using standardised contractual clauses that have been
approved by the European Commission (for transfers outside the EEA) and the
Information Commissioner’s Office (for transfers outside the UK). Where
necessary, we also put in place any additional contractual measures required by
local law in any of the countries in which we operate. As and when required, we
will also put additional technical or organisational measures in place to
ensure that your data is kept safe.
4.2. Keeping your personal data
secure
We recognise that online
security and data protection is an area of vital importance for all our
customers, so it is important to us that you have confidence in the security of
your personal details before you register for the Service. We are committed to
employing security measures to protect your information from access by
unauthorised persons and to prevent accidental or unlawful processing, disclosure,
destruction, loss, alteration and damage. Our technological security solutions
are very advanced and are governed by a mature framework. Our approach is
focused on preventing risks. In order to help us in this regard, we employ
pseudonymisation and encryption whenever possible to reduce the impact of any
potential incidents. As the security of some communications via the internet is
not completely secure, we cannot guarantee the security of any information that
you disclose using your internet connection. You accept the inherent security
implications of using the internet and the Group will accept no liability for
any direct, consequential, incidental, indirect, or punitive losses or damages
arising out of such an occurrence.
4.3. How long we keep your personal
data for
A key principle of data
protection is ‘storage limitation’, which means that organisations should only
hold onto your personal data for as long as is needed.
At etec, we have taken steps to
ensure that we hold your personal data only as long as we have a valid legal
basis or reason to do so, which includes providing you with the Service you
have requested, meeting our legal and regulatory obligations, resolving
disputes and enforcing our agreements.
The length of time for which we
keep different types of personal data can vary, depending on why we originally
obtained them, the reason we process them and the legal requirements that apply
to them. When setting our data retention and deletion timescales we take into
account a range of factors including applicable regulations and standards
relating to gambling and gaming, anti-money laundering, taxation, payment
processing and complaint handling, the need to prevent or detect crime or other
misuses of our Services, and audit requirements.
To fulfil our requirements, some
of your personal data will need to be retained for a period of time after you
cease to be a licensee. When we no longer need it to fulfil the purposes and
legal bases set out in this Statement, we delete it securely. Subject to us not having a legal or
regulatory requirement or a risk management reason for retaining your
information for a longer period, your information will not be kept for longer
than 7 years from your last login or expiry of a self-exclusion. This allows us
to meet our record-keeping obligations in applicable legislation, as well as
allowing us to defend ourselves against potential legal claims.
We will take all necessary steps
to ensure that the privacy of information is maintained for the period of
retention.