1. Introduction
We are committed to protecting your privacy and personal data. This Privacy and Cookie Notice (the Notice) will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. We may modify this Notice from time to time. Any changes to our Notice will become effective upon posting of the revised Notice on the Website and we will notify you of any material changes to this Notice. We recommend that you review this Notice from time-to-time.
This Notice should be read together with our general “Terms of Use” (as defined in our Website Terms and Conditions available on our Website and any other documents referred to on it).
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
2. Data Controller
christchurchcasinonz.com is a brand that is owned by christchurchcasinonz.com Limited (CCC) and operated by Two Islands Enterprise Limited (TIEL).
The two companies are joint data controllers in respect of your personal data. TIEL is responsible for the purposes related to the provision of the services; and CCC is responsible for the purposes related to the marketing of the services.
At the termination of the joint provision of services, CCC will become the sole data controller of your personal data.
If you have a concern or any questions about our handling of your personal data, please get in contact with our appointed Data Protection Officer (DPO) first so we can try to resolve your query using the email [email protected].
3. Information we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which includes:
Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes billing address, email address and telephone number as well as any other information provided at the time of registering to use our Website, subscribing to any of our services (including promotions about products), posting material or requesting further services.
Correspondence Data includes information you provide when entering a promotion or competition, making a Customer Support enquiry or complaint or when you report a problem with our Website, any other records of correspondence if you contact us about any matter. Your telephone conversations may be recorded both to assist us in training and in quality management, and to allow for the speedy resolution of queries.
Financial Data includes bank account information and information relating to your financial position.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Profile Data includes your username and password and wagering completed by you.
Usage Data includes information about how you use our website.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences, as can be found in the My Account section.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.
We may also collect certain special categories of personal data about you (such as details about your health) and information about criminal convictions and offences. This information is not collected by us in the ordinary course of business but only in exceptional circumstances and shall only be processed to comply with legal or regulatory obligations and responsibilities or where you have provided this information to us.
4. If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the services via our website). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
5. How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us personal data by filling in forms or by corresponding with us. This includes personal data you provide when you create an account on our website; place bets, or wager funds, on a game, via our website; request marketing to be sent to you; enter a competition, promotion or survey; or give us some feedback.
Automated technologies or interactions. As you interact with our website, we may automatically collect data about your equipment, browsing actions and patterns, which may include personal data. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie section below for more information.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources to supplement personal data we hold about you for the processing purposes of prevention or detection of crime as well as responsible gambling as described in section 6 below.
To simplify the sign-up procedure a separate process, such as Bank ID, Google sign-In, Trustly or similar Pay n Play options, may be used as a source for identification and verification. If such a process is used, once you provide us with the authorisation of access and the necessary information upon sign up, personal data (Registration and Contact Data) will be automatically fed to your profile from the third-party source to facilitate your registration.
6. How we make use of your information
In accordance with data protection laws, we will only process your personal data where we have a lawful basis for doing so. In respect of your personal data, these bases are: (i) where it is necessary to provide services to you under the performance of the contract we have with you; (ii) where we are required to do so in accordance with legal or regulatory obligations; (iii) where you have given your consent; and (iv) where it is in our legitimate interests to process your personal data provided that these interests do not prejudice your own rights, freedoms and interests.
We will process your personal data for the purposes and in accordance with the following bases:
| Purpose | Lawful Basis |
| Setting up, re-activating, operating and managing your account, including providing the services that you request from us (including with our white label licensees) | Necessary for the performance of a contract |
| Processing card and on-line payments relating to our services | Necessary for the performance of a contract |
| Verifying your age and identity, including disclosing your personal data to third parties (such as financial institutions, credit reporting agencies and age verification agencies) regarding such verification | Necessary to comply with a legal or regulatory obligation |
| Understanding your financial position to assist us in providing an effective service and to comply with responsible gambling obligations | Necessary to comply with a legal or regulatory obligation |
| Allowing you to subscribe to our push notifications | Consent (you can unsubscribe at any time via your browser settings) |
| Making available to you online advertisements and branding in relation to our goods, services, promotions and offers which may be of interest to you | Legitimate interests |
| Preventing fraud, cheating and money laundering, ensuring compliance with our Terms of Use, reducing credit risk and protecting games integrity, which may require us to disclose your personal data and betting and gaming history to third parties such as the relevant regulator, gaming bodies, financial institutions, agencies responsible for verifying age, the police and credit reporting agencies | Necessary to comply with a legal or regulatory obligation |
| Monitoring and giving effect to deposit, spend and loss limits that you have set | Consent |
| Improve our service and make your experience as enjoyable as possible by preparing statistics and providing analytical reports and analysis relating to the use of the services by our customers | Legitimate Interests |
| Enforcing or applying our Terms of Use and other agreements, and to protect the rights, property, or safety of our company, our players, or others | Necessary for the performance of a contract and also necessary to comply with a legal or regulatory obligation |
| Undertaking research, conducting surveys, technical diagnostics, research analyses and obtaining feedback from our players (which may include us contacting you directly) in order to better understand and improve our services | Legitimate Interests (and you can opt-out of us contacting you at any time) |
| Training and quality management to improve our services and customer relations (which may include recording telephone calls) | Legitimate interests |
| Monitoring our customers’ gambling and gambling patterns to comply with responsible gambling obligations and to ensure that your use of our services is responsible (which may include recording telephone calls) | Necessary to comply with a legal or regulatory obligation |
| Giving effect to any self-exclusion (or any other responsible gambling tool). This includes sharing your data with national self-exclusion databases if you have self-excluded, such as GamStop. | Necessary to comply with a legal or regulatory obligation |
| Responding to communications you send to us | Consent |
| Providing you with any other services or complying with other legal or regulatory obligation from time-to-time | Necessary to comply with a legal or regulatory obligation and/or necessary for the performance of a contact. |
We may use non-personal information (which is non-identifiable information that, when taken alone, cannot be used to identify or contact you). This could include game play information, technical information and analytics information. As such, we are not aware of the identity of the user from which the non-personal information was collected. We use such information for different purposes, such as advertising, improvement of our services, preventing fraud and performing web analytics. We may gather such information, either independently or through the help of our third-party service providers.
Where we process your personal data as set out above, we may do this directly or appoint members of our group or service providers (known as processors) to do this on our behalf and all of whom adhere to this Notice, and who only process your personal data on our behalf for the purposes set out above.
7. Data transfer
Since we operate globally, it may be necessary to transfer your Information to countries outside the European Union. The data protection and other laws of these countries may not be as comprehensive as those in the European Union.
8. Marketing
We may use your information, such as your name, home address, email address, telephone number etc, ourselves or by using our third party subcontractors for the purpose of providing you with promotional materials, concerning our Website as well as products, services, websites and applications which relate to: (i) other companies within the Group; (ii) our White Label Partner, ChristchurchCasino.com Limited and its group of companies or (iii) Group’s business partners and affiliates (together the ‘Marketing Affiliates’), which we believe may interest you.
We may also share and disclose Information with our Marketing Affiliates for the purpose of providing you different marketing offers, which we, or our Marketing Affiliates, believe are relevant for you. Our Marketing Affiliates may use this information for different marketing techniques, such as direct email, post, SMS and telephone marketing purposes.
We will only send you marketing communications where you have consented to receive such communications. You may at any time decline receiving further marketing offers from us or from our business partners by contacting us or following the links in the relevant communication to unsubscribe. Please note that even if you unsubscribe from our marketing mailing list, we may continue to send you service-related updates and notifications.
We may use Google and Facebook Ads services to receive ad measurement services and to provide you with content about our websites, respectively. To provide this content we may share information with Facebook. You can read more about Facebook Ads here. By using this Website, you consent to Facebook and us using your personal data for personalized advertising. If you no longer wish to receive such advertisements on Facebook, you can manage your preferences on Facebook in the link set out above.
9. Monitoring, profiling and automated decisions
All bets, gaming and account transactions are recorded on our computer systems. We also carry out routine monitoring of all transactions as they take place to assist us in improving the service that we provide to you and to comply with our licensing and regulatory obligations.
9.1. Responsible gaming purposes. Under such licensing and regulatory obligations, we are legally obliged to monitor our players in order to identify people who may be experiencing, or at risk of developing, problems with their gambling, and interact with them to offer help or support. fulfil this obligation, by using historic data describing behaviour of players, in particular certain Responsible Gaming Data, Transaction and Usage Data, and Other Communication Data, we have established rules regarding who is likely to suffer from gambling addiction and then take relevant action.
Decisions are generally not taken automatically without human intervention but there are instances where our system may automatically lock certain users’ accounts or apply certain limits. You can contact us, at any time, at [email protected] to contest any decision and to require direct human review or intervention.
9.2. Anti-money laundering. We are also legally obliged to monitor its players in order to identify potentially suspicious activities in this context. Based on data describing the behaviour of players, in particular Transaction and Usage Data, the algorithm suggests a risk profile.
Decisions on the basis of such predictions are not taken automatically and require human intervention.
10. Security
We employ security measures to protect your personal data from access by unauthorised persons and to prevent unlawful processing, accidental loss, destruction and damage. These safeguards vary based on the sensitivity of the information that we collect and store. Protection of your personal data, including your registration details and any debit card information you provide to us, is a priority for us.
Data on our secure pages is encrypted using TLS v1.2 at a minimum. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Websites, you are responsible for keeping this password confidential.
Any personal data which identifies you will always be encrypted whilst in transit over the internet. SSL is a special protocol that automatically encrypts any information sent by you on our secure pages. Our server then reads the information using a private key. This means that your personal data, be it debit card information or any other personal details, is turned into a code that can only be decoded with the private key or password. If your browser is suitably configured, you will receive a warning message when you first access any secure page on the Website. This is simply information to advise you that the Website is protecting your Information.
Unfortunately, the transmission of Information via the internet is not completely secure. Although we will do our best to protect your Information, we cannot guarantee the security of any personal data that you disclose online. You accept the inherent security implications of using the internet and will not hold us responsible for any breach of security unless we have failed in our obligations under data protection legislation. For your own privacy protection, we encourage you not to include sensitive Information (such as debit card numbers) in any emails you may send to us.
11. Retention
We will hold your personal data for so long as you use our service and for no more than five years after (unless required to be kept longer in accordance with legal and regulatory requirements). We will endeavour to delete any personal data sooner where it is not necessary for us to hold this, but please be aware that we may hold personal data for longer if we are under a legal obligation to do so or where we have a reasonable belief that it is necessary to do so for business or legal reasons.