United Commissions Privacy Policy

 

These online services are provided by Daub Alderney Limited via the United Commissions Website (“the Site”).

It explains how We collect, use, store and delete your personal information as well as the choices that you have about how your information is used. Please read this Privacy Policy carefully.

For the purposes of this Privacy Notice please noted that, “We”, “Us” and “Our” has the same meaning as The Group, which is explained below

 

ABOUT THE GROUP

Daub Alderney Limited (‘Daub’) is part of The Rank Group Plc group of companies (‘Rank Group’) which operates gaming venues in Europe and digital gaming sites, including the Bella Casino, Enracha, Grosvenor Casino, and Mecca Bingo brands and other associated and subsidiary companies. For the purposes of this Privacy Policy, the data controller is Daub Alderney Limited whose address is Inchalla, Le Val, Alderney, GY9 3UL. The Group provides services on the Site through various software and/or platforms: (collectively referred to as ‘Platforms’)

  • Websites
  • Mobile applications
  • Downloadable applications
  • Non- Downloadable applications
  • Social Media Networks

This notice explains how we use your personal information, which will be reviewed from time to time. If we make any minor changes to the way we process your data we will always update this notice so please check back regularly for the latest information.  If we make any major changes to the way we process your information we will let you know either through the Site or by notifying you directly.

We are respectful that your personal information belongs to you and we encourage you to read this notice carefully so that you can make informed choices about how you wish your personal information to be used.   

By engaging with Our Site you acknowledge you have read and understood this Privacy Policy.

What is personal data?

Personal data is information about you or that can be used to identify you.  Some of this information we get from you when you register or use our services, but other information we receive may be less obvious such as information we get from your device or via cookies.

Information given to us by you

  • Registration Information

When you register with us you will be asked to provide information such as first and last name, email address, date of birth, mailing address, phone number.

  • Payment Information

We will ask you for your bank details to enable us to pay your commission.

  • Other Information

When you respond to communications from us, communicate with us via email or share additional information about yourself through your use of the Platforms, such as us information about your site, source of traffic, or via chat, skype, WhatsApp and email.

 

Information We Collect About You from Your Use of Our Site

We will automatically collect information from you each time you visit or otherwise use Our site. This includes:

 

  • Technical and Device Information

We may collect specific types of connection details and information with regard to your device, software or hardware that may identify you, such as device’s unique identifiers, IP address used to connect your device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and geolocation data (to comply with our anti-money laundering policy). We use Google Analytics and comply with the Google Analytics Terms of Service and are subject to the Google Analytics Policies.

 

  • Information We Collect About You From Other Sources

We may collect Personal Information about from other sources (e.g. third-party service providers), which is gathered in order to verify your identity and prevent fraudulent or illegal activity.

 

USE OF INFORMATION COLLECTED

We use and share Personal Information for the following purposes:

To register your account with us;

To update your account;

To operate Our platform

To verify your identity when you sign up and sign in to our platform, such as:

  1. To identify a registered Affiliate user as the valid owner of the web site he/she wants to insert advertising material in, delivered by our platform.
  2. To be able to process the payment of Affiliates' commissions.

To communicate with you and to keep you informed of Our latest updates and special offers;

With your prior consent where required by law, a member of our Group, will use your Personal Information for marketing analysis and to provide you with promotional update communications by email, post, telephone, direct messaging, direct mail and other digital channels  (pop-ups, push notification, banner advertising, etc) about Our or their products/services,  promotional materials,  as well as products, services, websites and applications which relate to products and services from companies (other than Daub) within the Group and our Trusted Partners which We believe may interest you. You may at any time object to further marketing by checking and updating your contact details within your account or selecting the "unsubscribe" link at the end of all Our marketing and promotional update communications to you, or by sending us an email to: [email protected]

To assist you with your queries;

To process any of your requests for information;

To notify you about updates to Our software and/or services;

To investigate and resolve disputes about your use of Our services;

To comply with Our licence conditions with the UK Gambling Commission and the Alderney Gambling Control Commission;

To conduct credit searches;

To improve your user experience through data collected through analytics;

To carry out due diligence;

To detect and prevent fraudulent activities

As required by law, regulation or other governmental authority;

We may also use other types of information for the purposes of monitoring Site usage in order to help us develop Our Site and the services and for these purposes.

 

DATA SHARING

We do not sell or share your Personal Information with third parties except as described in this Privacy Policy. The Personal Information will be disclosed to a third party only to the extent required for the specific purpose, as stipulated in this Privacy Policy

 

Who your information may be shared with:

Your information may be shared with any member of Our Group (as defined in this Privacy Policy), who support Our processing of Personal Information under this Privacy Policy. If any of these parties are using your information for direct marketing purposes, we will only transfer the information to them for that purpose with your prior consent. Our selected third parties may include:

Organisations which process your Personal Information on Our behalf and in accordance with Our instructions and applicable data protection laws. This includes in supporting the services We offer through the Site in particular those providing website and data hosting services, providing fulfilment services, distributing any communications We send, supporting or updating marketing lists, facilitating feedback on Our services and providing IT support services from time to time, to third parties who provide services in relation to the operation or promotion of the Site, organize events on behalf of the Group. These organisations (which may include Our third-party suppliers, agents, sub-contractors, auditors, advisors, investors, potential buyers and/or other companies in Our Group) will only use your Personal Information to the extent necessary to perform their support functions.

Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to Our advertisers, but We will provide them with aggregate information about our users. We may also use such aggregate information to help advertisers reach the kind of audience they want to target.

Business partners who provide services to you and with whom We have entered into agreements in relation to the processing of your Personal Information.

Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.

Payment processing providers who provide secure payment processing services.

We will disclose your personal information to third parties:

In the event that We sell or buy any business or assets, in which case We will disclose your Personal Information to a prospective seller or buyer of such business or assets subject to the terms of this Privacy Policy.

If Daub or a member of the Group substantially all of its assets are acquired by a third party, in which case Personal Information held by it about its customers will be one of the transferred assets.

If we are under a duty to disclose or share your Personal Information in order to comply with any legal obligation, or in order to enforce or apply our terms of supply terms and other agreements with you; or to protect the rights, property, or safety of Our Group, Our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction and to prevent cybercrime.

DATA TRANSFERS

The Group operates globally and the Personal Information that We collect may be transferred to, and stored at, a destination outside the European Economic Area ("EEA") that may not be subject to equivalent Data Protection Law. Where we transfer your data outside of the EEA, we have agreements in place with those parties which include standard data protection clauses to ensure that appropriate safeguards are in place to protect your personal data. 

 

We may transfer your personal information outside the EEA:

 

In order to store it.

In order to enable us to provide goods or services to you and fulfil Our contract with you. This includes order fulfilment, processing of payment details, and the provision of support services.

Where We are legally required to do so

In order to facilitate the operation of Our Group, where it is in Our legitimate interests and We have concluded these are not overridden by your rights. In these instances, We will take all steps reasonably necessary to ensure that your Personal Information is subject to appropriate safeguards, such as relying on a recognised legal adequacy mechanism, and that it is treated securely and in accordance with this Privacy Policy.

DATA SECURITY

All information you provide to us is stored on Our secure servers. Any payment transactions will be encrypted using SSL technology. Where We have given you (or where you have chosen) a password which enables you to access certain parts of Our Site you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

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

We take cyber-security very seriously, not only to protect us, but also our clients and their data. We implement different layers of physical and technological controls to prevent unauthorised access and to ensure data security, integrity and privacy.

Controls include, but are not limited to:

 

Firewalls, Network Segmentation, Intrusion Detection and Prevention Systems

Penetration Testing and Vulnerability Remediation

Encryption protocols for data at rest or in transit

Strict Access control and authentication procedures

Regular Cyber-Security Audits

 Our Site may, from time to time, contain links to external sites. We are not responsible for the privacy policies or the content of such sites.

 

CHILD SAFETY

We do not use the Application to knowingly solicit data from or market to children under the age of 18.  If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at [email protected]

 

We will delete such information from our files within a reasonable time.

 

UPDATES OR AMENDMENTS TO THE PRIVACY POLICY

We may revise this Privacy Policy from time to time, in Our sole discretion, and the most current version will always be posted on this Site and substantive changes will be notified to you by e-mail. Your continued use of Our services, following the notification of such amendments on this Site, constitutes your acknowledgement of such amendments to the Privacy Policy.

This Privacy Policy was last updated on 13 February 2020.

 

HOW TO CONTACT US

We welcome your views about the Site and Our Privacy Policy. If you would like to contact Us with any queries or comments please send an e-mail to [email protected]

 

HOW LONG WE KEEP YOUR INFORMATION

We retain Personal Information for as long as you have an account with us in order to meet Our contractual obligations to you and to comply with Our licence conditions with the UK Gambling Commission and Alderney Gambling Control Commission and 5 years after your business relationship with Us ends. We may also retain aggregate information beyond this time for research purposes and to help us develop and improve Our services. You cannot be identified from aggregate information retained or used for these purposes.

 

YOUR RIGHTS

You can ask us:

To access all the Personal Information about you held by us. On request, We will provide you with a copy of this information. We reserve the right to charge a reasonable fee taking into account the administrative costs of providing the information or taking the action requested;

To correct or erase your Personal Information where appropriate;

To restrict the processing of your Personal Information whilst We investigate your concern;

To object to direct marketing or in certain cases object more generally;

Where your processing is based on your consent, to receive your Personal Information in a commonly used electronic format or ask We move the data in that format to another provider where your request relates to the data that you gave us direct and where technically possible (data portability);

To withdraw your consent at any time when the processing relies upon consent.

You also have the right to make a complaint if you remain unhappy with a response you receive by refering the matter to your data protection supervisory authority. https://ec.europa.eu/info/law/law-topic/data-protection_en)