kwiff privacy notice
This privacy notice provides information about:
- Who we are and what we do
- The data we collect from or about you
- How we use your data
- Who we share your information with
- How long we keep your information
- Your rights
- Where we store, process and/or transfer your information
- Cookies, tags and other identifiers
- Third party websites
- How to contact us
Who We Are and What We Do
The kwiff App is operated by kwiff Ltd (“kwiff”), a company registered in Malta with Company Registration No. C77623, and having its registered office and business address at 32 Sovereign Building, Zaghfran Road, Attard, ATD9012, Malta.
kwiff is a wholly-owned subsidiary of Eaton Gate Gaming Ltd (“EGG”), a company registered in England and Wales with Company Registration No. 9526212 and having its registered office at Imperial House, 15 Kingsway, London WC2B 6UN, UK. EGG, together with its wholly-owned subsidiaries, is referred to in these terms as the “EGG Group”.
References in this privacy notice to “we“, “us“, or “our” are references to kwiff and Eaton Gate Gaming Group, who are data controllers in respect of your personal data.
We are registered with UK Gambling Commission (“UKGC“). Our licence number is 044448-R-323408.
The Data We Collect From or About You
- Registration details: When you open an account and register to use our App, you will be asked to provide us certain details about yourself, such as: full name, email address, date of birth, physical address, username, password, telephone number etc.
- Payment information: In order for you to enjoy all of the functions of our services (e.g. place bets, make withdrawals, etc.), payment information will be collected from you, such as your credit card number and bank account details. This information is collected by third party payment service providers, and we do not collect or store this information ourselves.
- Government–issued ID: In certain instances, you will be required to provide a copy of a government-issued ID, in order for us to verify your identity. Please note that this information may be required in order for you to use or continue using our services.
- Public information: In certain instances we may need to search publicly available sources of information to confirm your identity or source of funds (for example, electoral rolls or databases regarding property values).
- Voluntary information: We also collect information which you provide us voluntarily. For example, when you respond to communications from us, communicate with us via email, live chat or otherwise, or share additional information about yourself through your use of our services. We also collect details of any deposit, spend or loss limits that you have set.
- Information we collect from third parties: We collect data about you from third party service providers, such as confirmation of your age and address and other financial information which is relevant to the provision of our services, as well as information which is gathered in order to verify your identity and prevent fraudulent or illegal activity.
- Device information: We collect specific types of connection details and information with regard to your device, software or hardware that may identify you, such as: your device’s unique identifiers. and geo-location data. We may also gather information with regard to other software which is running simultaneously with our App for detecting if you are using software which is associated with fraudulent activity (e.g. bots, malware) or checking if the connection you are using is via a VPN or proxy.
- Gaming information: in order for us to provide our services, we automatically record different information related to your use of our services, including with respect to your transactions, deposits, balances, bets, withdraws, bonuses and winnings etc.
- Technical information: In order to enhance the functionality of our App and to provide you with a better user experience, we collect technical information transmitted by your device, including certain software and hardware information (e.g. your language preference, the type of browser and operating system your device uses, access time, the domain name of the website from which you linked to our services; etc.).
- Analytics information: We collect information about your use of our services, such as app usage, log files, user activity (e.g. pages viewed, the amount of time spent on particular pages, online browsing, clicks, actions, etc.), time stamps, alerts, etc. This information is collected for amongst other things troubleshooting errors and bugs as well as for research, profiling and analytics purposes about your use of our services, and providing you with tailored marketing and personalized products and services.
You are under no obligation to provide personal information to us. However, certain personal information is essential for the provision and quality of the services that we offer (for example, enabling you to place bets on the App) and you might not be able to obtain certain services if you choose to withhold information we have requested that is required for those services. For example, we ask you to share your precise geolocation to ensure that we are authorised to provide gambling services to you in your location.
How We Use Your Data
In accordance with data protection laws, we will only process your data where we have a lawful basis for doing so.
There are five relevant lawful bases for processing personal data that may be relevant when we process data about you (depending on the type of processing being conducted):
- Consent: you have given us consent.
- Contract: the processing is necessary to perform a contract we have entered into with you, or because you have asked us to take specific steps before entering into a contract.
- Legal obligation: the processing is necessary for us to comply with laws or regulations that apply to us (not including contractual obligations).
- Public task: the processing is necessary for us to perform a task in the public interest, and the task or function has a clear basis in law.
- Legitimate interests: where it is in our legitimate interests to process your personal information, provided that our legitimate interests are not overridden by your own rights, freedoms and interests.
The table below sets out:
- The purposes for which we process your data
- The lawful basis(es) which justify our processing activities
|To register, administer and manage your account (including processing deposits and withdrawals)||Contract|
|To provide you with gambling services||Contract|
|To send you service related updates||Contract Legitimate interests|
|To receive and respond to your communications and requests||Contract Legitimate interests|
|To ensure that we are able to fulfil our regulatory obligations regarding your use of our services, including by verifying the accuracy of any information you provide us and by verifying your age and location||Legal obligation|
|To prevent you from using our websites, mobile applications and services if you have requested that we do so (i.e. where you self-exclude)||Legal obligation|
|To comply with any deposit, spend or loss limits that you have set||Legal obligation|
|To comply with our obligations under applicable laws (including regulatory and licensing requirements related to our gambling licences)||Legal obligation|
|To monitor gambling patterns and to identify possible responsible gambling concerns||Legal obligation|
|To identify and disclose any suspected unlawful, fraudulent, or other improper activity connected with our websites, mobile applications and services (including money laundering)||Legal obligation|
|To prevent or detect unlawful acts or protecting members of the public against dishonesty, malpractice or other seriously improper conduct||Legal obligation Public interest|
|To detect if you are using software which is associated with fraudulent activity (e.g. robots, malware) or to check if the connection you are using is via a VPN or proxy.||Legitimate interests|
|To analyse how you and other players use our App and respond to promotions and adverts so that we can improve our products and services and provide tailored offers and recommendations||Legitimate interests|
|To personalize our service to you||Legitimate interests|
|To build up your personal profile in order to gain a better understanding of your interests in our products and services and to make recommendations that are relevant to you||Legitimate interests|
|To provide you with ads on social media sites, except where you have requested not to receive such ads via your social media account||Legitimate interests|
|To send you offers and promotions relating to our services||Consent|
|To use your name, image, username or location in publicity and marketing||Consent|
If you do not wish for us to use your personal information in order to provide the personalised betting service to you, you can withdraw your consent by contacting us at any time by contacting us at email@example.com.
Who we share your information with
- We share your personal information with other companies in the EGG Group.
- We share your personal data with the UKGC and other gaming regulators with whom we are licensed.
- We use third party payment service providers to process payments to and from your account. These third party providers will have access to or process your payment card information for the purpose of providing these services to us but kwiff does not collect or store the payment card information.
- We use third party providers in order to manage aspects of your account; including anti-fraud and anti-money laundering checks, credit risk checks. These third party providers may have access to or process your personal information for the purpose of providing these services to us.
- We use third party service providers in order to advertise and market to you, if you have given us consent to do so.
- We use Customer Relationship Management (CRM) tools in order to manage our advertising activities. Your personal data may be shared with these third parties for this purpose. You will only receive advertising material from kwiff or its partners if you have opted to receive marketing materials.
- We may share some or all of your personal information in connection with or during negotiation of any potential sale or investment in any of the companies in the EGG Group or in the event of a corporate transaction (e.g. a sale of a substantial part of our respective businesses, a merger, financing, restructuring, consolidation, acquisition, corporate divestiture, dissolution transaction, or other proceeding involving the sale, transfer, divestiture or disclosure of all or a portion of our business or assets). In the event of an insolvency, bankruptcy, or receivership, your personal information may also be transferred as a business asset.
- In some cases we may disclose your personal information and any other information and/or records relating to you, if we are under a duty to disclose or share these details in order to comply with any legal obligation, or when ordered to do so by any governmental or administrative authority. We may also share such information if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms and Conditions, or as otherwise required by law.
As a gambling operator, we are subject to strict legal and regulatory obligations to ensure you can use our App. Because of this, we may share your personal information with certain third party service providers (such as verification agencies, fraud prevention agencies, payment service providers and similar third parties) that are also “data controllers” in respect of the personal information about you that is held by them.
Upon request we can provide a full list of suppliers and third parties we use to process personal data. To request this please contact us at firstname.lastname@example.org.
How long we keep your information
We will retain your personal information for as long as it is reasonably necessary for our legal and business purposes. Please note that either kwiff or EGG may be required in certain circumstances to retain your information indefinitely (for example, in order to comply with our policies and procedures in connection with responsible gambling and self-exclusion). As required by our regulator the UK Gambling Commission, we will also keep your personal data and all the details of your financial transaction for a minimum period of five years after the closure of your kwiff account. We will take all necessary steps to ensure that the privacy of your information is maintained for the period of retention. Once any mandatory retention period has elapsed, we will delete or anonymize any personal information no longer required to be held by us.
The right of access
- You have the right to access your personal information.
- You can ask us to provide you with all the personal information we hold and/or process about you.
- The right to access is free of charge, unless this a repeat request or a frivolous/excessive request. We will provide the requested data within 1 month of the request (or within 3 months where the request is complex).
The right to rectification
- You have the right to request that we rectify and correct any personal information that we are processing about you which is incorrect, whether that is an accidental error (such as a typo), because something has changed (address/email) or otherwise.
- We want the information we keep about you to be as accurate as possible. You can amend your personal information in the My Account section of the App, or contact us and ask us to correct and/or erase incorrect and/or inappropriate data.
The right to erasure
- You have the right to request that we erase your personal information where there is no compelling reason for us to continue processing it (“right to be forgotten”).
- We will respond to requests to exercise the right to be forgotten within 1 month of the request. However this right is not absolute and only applies in certain circumstances.
- If the request relates to marketing that you had previously opted into, we will assist you in opting out of this.
- If we cannot comply with your request, we will let you know why this is and the reason for retaining your data.
The right to restrict processing
- You have the right in certain circumstances to request that we suspend our processing of your personal information.
- If you think the data we hold is inaccurate or has been unlawfully processed then you can contact us to request that the data you provided is restricted form processing.
- Where we agree to suspend our processing of your personal information we will still be permitted to store your personal information, but any other processing of this information will require your consent, subject to certain exemptions.
The right to data portability
- You have the right to be provided with personal information that you have provided to us with your consent or which was necessary for us to provide you with our products and services in a structured, machine readable and commonly used format and you may also have the right to request that we transfer the personal information directly to another data controller without hindrance, if it is technically feasible for us to do so.
The right to object
- You have the right to object to our use of your personal information which is processed on the basis of our legitimate interests.
- However, we may continue to process your personal information, despite your objection, where there are compelling legitimate grounds to do so or we need to process your personal information in connection with any legal claims.
The right to withdraw consent
- Where we have relied upon your consent to process your personal information, you have the right to withdraw that consent.
The right to complain
- You have a right to raise concerns with, or complain to, us.
- You can also report any concerns or complaints to the ICO (www.ico.org.uk/concerns/) or (if not the ICO) your local national data supervisory authority.
To exercise any of your rights regarding your personal data please contact us at email@example.com. Some changes can be made directly by you within the App from “Profile > My Account > Account details”.
Please note that not all of your rights are absolute, and we may be entitled to extend the period for dealing with your request if it is complex. We also have the right to take suitable steps to confirm your identity before responding to a request.
We may also rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion, in accordance with our internal policies.
Where we store, process and/or transfer your information
All information you provide to us is stored on secure servers maintained by us or suitable third parties. All payment transactions are encrypted using SSL technology and our payment processors are PCI DSS accredited thus ensuring the protection of your payment details.
The personal information we hold about you is primarily stored and processed within the EEA (European Economic Area). However when your information is transferred to our 3rd party suppliers, then your data may be processed outside of the EEA.
Where we transfer Personal Information from the EEA to other countries in which applicable laws do not offer the same level of data privacy protection as in your home country, we take steps to ensure that your data is treated securely and in accordance with this privacy notice. For example, we use approved contractual clauses, intragroup agreements and other measures designed to ensure that the recipients of your personal information protect it. We may transfer your data to entities in the US if they are part of what is known as the “Privacy Shield”, or if other appropriate steps are taken to safeguard your rights as an EU data subject.
Please contact us if you have any questions regarding the security measures that we have in place with regard to personal information.
Cookies, tags and other identifiers:
A cookie is a small file that kwiff stores on your browser and/or your mobile. Cookies record information about you and can be used to customise your experience on the App. You can find out more about cookies at http://www.allaboutcookies.org/.
We may use the following types of cookies:
- Essential Tracking Cookies – which are essential to enable you to log in and use the services (because they keep a record of who you are as you navigate our services)
- Functional Tracking Cookies – which are used to remember choices you make, and to personalise our services
- Performance Tracking Cookies – which analyse your use of our service (for example, the amount of time you spend using different aspects of our services; these are used for analytics and personalisation)
- Marketing or Advertising Cookies – these are used to deliver tailored advertisements to you, and to measure the effectiveness of our advertising campaigns
- Social Media Tracking Cookies – these are track your use of social media features such as ‘shares’ or ‘likes’ – your use of social media is governed by the privacy notice of the relevant social media company,
- To identify your preferred language, so it can be automatically selected when you return to the App;
- To ensure the bets you place are associated with your betting coupon and kwiff Account
- For analysis of the App traffic, so that we can make suitable improvements.
- To enable us to personalise the App and provide you with tailored services and marketing
Third party websites:
The App may, from time to time, contain links to and from the websites of kwiff’s partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy notices and that we are not responsible for and have no control over information that is submitted to, or collected by, these sites.
How to contact us:
If you have any general questions about the App or the personal data that we collect about you and how we use it, in the first instance, please email us at firstname.lastname@example.org
Revisions to this privacy notice:
We may revise this privacy notice from time to time, in our sole discretion, and the most current version will always be uploaded to the App. We encourage you to review this privacy notice regularly for any changes.
Privacy Notice Version [●001]
Published on [25 May 2018]