Customer Privacy Notice (REST of the WORLD)

Who are we
The information we collect about you
What We Use your Personal Data for
Who we share your data with
Meeting our Responsible Gambling Obligations
How long we retain your personal data
Location that we may transfer your personal data to
Security
Cookies
Marketing Communications and your choices
Your rights
How to contact us / Our Data Protection Officer
Changes to this Policy

Who we are

ElectraWorks Limited is a member of the Entain Group of companies and this Notice explains what your personal data will be used for.

Territory	Name of the controller	Details
All territories excluding the United Kingdom and European Union	ElectraWorks Limited	Suite 6, Atlantic Suites, Europort Avenue, Gibraltar, GX11 1AA

Where we use the term “we” or “us”, this includes the entity and Brands (https://entaingroup.com/about/business-overview/our-brands/) and other companies within the Entain Group.

We are committed to protecting your personal data when you use our services through our website and mobile application and take the security of your information very seriously. We have strict security measures in place to protect your personal data which includes robust security procedures which are regularly tested and reviewed. If you have any concerns about the way in which we process or protect your personal data or would like to contact us about any aspect of this policy, please get in touch through the contact details at the bottom of this statement.

This privacy notice should be read in conjunction with our cookies notice, any notices or terms located within the stores and our site terms of use / terms and conditions.

The information we collect about you

We will collect personal data about you from the following sources:

When you register for an account with us
When you visit our website or our social media sites
Through surveys you complete
When you communicate with us (by email, mail, phone, in store or through chat or social media)
When we undertake analysis of your interaction with us
From our other group companies for internal reasons, primarily for business and operational purposes
From public sources of information such as public records or social media postings
From cookies and tracking devices on your devices where you have permitted their use
From third parties' databases to comply with our legal and regulatory obligations
From online vendors and service providers such as financial and shared liquidity services, and from customer lists lawfully acquired from third-party vendors.

What We Use your Personal Data for

What we use your Personal Data for	Typical Personal Data	Further information	Legal basis
Provision of products or services	Your name, home or email address, telephone number or online identity or other contact information you provide to us. Your Date of Birth, Gender. Log in information. Game Transactional information and payment methods.	To meet our obligations arising from any agreements entered into between you and us and provide you with the information, products and services that you request from us, including information about changes to our website, services or our terms, conditions and policies.	Performance of contract. Legal obligations.
Customer Service matters	Name, online identity, Player ID. Contact Information. Account notes and communications, call recordings. Game Transactional information and payment methods. IP Address, MAC address, Device type, apps, location.	To provide you with customer services, answer your questions or address your complaints or concerns.	Performance of contract. Legitimate interests in player satisfaction, protecting our business and our customers in relation to responsible gambling.
Meeting our legal and regulatory obligations	Name, Online Identity, Player ID, Contact Information. Games played, bets, winnings and losses, deposits and withdrawals, payment methods. Online images of play and screenshots. IP Address, MAC address, Device type, apps, location.	To discharge our legal and regulatory obligations and duties which include (but are not limited to) Gambling Act and Responsible Gambling obligations, Anti-money Laundering, Anti-fraud & Anti-terrorism laws. This may include electronic methods of identifying you, such as through the use of cookies and images on online play.	Legal obligation. Protect the vital interests of data subjects and others. Performance of a task carried out in the public interest. Legitimate interests in protecting our business, staff and customers.
Identity Checks, Age Verification and Responsible Gambling	Name, Online Identity, Player ID, Contact Information, date of birth and gender. Log in details, websites and webpages visited. Game Transactional information and payment methods. IP Address, MAC address, Device type, apps, location. Historic communications and account notes, Call Recordings. Information on customer’s wellbeing. Affordability checks which may include obtaining data from other sources such as public domain information or credit history. Images and selfies.	To meet our Responsible Gambling obligations (such as recording self-excluders and where we believe a customer has a gambling problem). To check your or validate your identity, age and protect your information This may include electronic methods of identifying you, such as through the use of cookies.	Consent Performance of contract. Legal obligation. Protect the vital interests of data subjects and others. Performance of a task carried out in the public interest.
Undertake Surveys competitions and promotions	Name or online identity. Contact details, Home address, Email or phone number. Contact preferences. Responses to surveys, click through on marketing, preferred products, feedback you provide.	To invite you to take part in competitions, to provide us with feedback on your experiences, take up promotions or to keep you informed about products of services which may be of interest to you. To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you. You may opt out of receiving direct marketing communications at any time. Some of these interactions may be online or through social media.	Consent. Legitimate interests to understand our customer’s views and encourage greater interaction with our customers.
Lifestyle and demographic Insight and Profiling	Contact preferences. Responses to surveys, click through on marketing, preferred products, feedback you provide. Interests and habits.	To build a profile of you, your preferences and your habits to better understand your interests and how you play. We may use these profiles to contact you through social media to promote our business.	Legal obligation. Performance of a task carried out in the public interest. Legitimate interests.
Improve our services and ensure our systems are secure and up to date	Player ID. Log in details, websites and webpages visited. Games played. IP Address, MAC address, Device type, apps, location. How you use mobile applications and websites.	To ensure that content from the site is presented in the most effective manner for you and for your computer, maintain and improve our products and services, optimise business processes, ensure the integrity of our systems and manage our Information Technology estate, undertake quality assurance, support efficient management of our staff, analyse performance of webpages or promotions and provide content that is relevant to you.	Legitimate interests to ensure that our interaction with customers is appropriate, working and efficient.
Prevention and Detection of Crime, Prevention of loss Protection of staff and customers	Name, Online Identity, Player ID, Contact Information. Log in details, websites and webpages visited. Games played, bets, winnings and losses, credits and withdrawals, payment methods. Online images of play and screenshots. IP Address, MAC address, Device type, apps, location. Risk scores, profile classifications. Historic communications and account notes.	To prevent or detect crime, fraud, theft or loss to our business and our customers and prevent the use of unfair practices in our websites or potential breach of our General Terms and Conditions and of applicable law. To protect our staff and other individuals from harm or loss. This may include monitoring online activity, electronic methods of identifying you, such as through the use of cookies, your online transactions and payments. In certain circumstances, such as high depositing players and/ or politically exposed persons, we will carry out enhanced due diligence focused on source of funds and background checks. These due diligences could include additional documentation provided by players, based on a case-by-case basis, or information available in the public domain.	Performance of a task carried out in the public interest. Legitimate interests to protect our customers, business and workers.
Business sale, acquisition and rights	Name, Online Identity, Player ID, Contact Information. Log in details, websites and webpages visited. Games played, bets, winnings and losses, credits and withdrawals, payment methods. IP Address, MAC address, Device type, apps, location. Risk scores, profile classifications. Historic communications and account notes.	To exercise or defend legal claims or acquiring or selling a business.	Legitimate interests to protect and defend our business.

Who we share your data with

We may need to share personal information with other organisations to ensure that we meet our legal obligations or where we need support in meeting your needs or our contractual obligations. We may also share information with other organisations where we consider it to be in the public interest or in the legitimate interest of ourselves or these other parties. These other parties are typically:

business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
our affiliates and selected third parties, where you have expressly opted-out of receiving marketing from us / third parties, have been barred or self-excluded, in which case we may share suppression lists with our affiliates and selected third parties, to ensure you do not receive unsolicited marketing;
members of the Entain Group and third party suppliers and service providers for any of the purposes identified in the table above; third party suppliers and service providers to the extent they assist the Entain Group with its legal / regulatory obligations e.g. providers of services in respect of anti-money laundering, fraud, verification etc.;
selected third parties so that they can contact you with details of the services that they provide, where you have expressly opted-in/consented to the disclosure of your personal data for these purposes;
Social Media platforms, where for example you chose to log onto your gaming account with us through your Social Media identity. Or when we communicate with you via your Social media account;
analytics and search engine providers that assist us in the improvement and optimization of our site and other selected third parties;
other 3rd party organisations who ask, encourage or collate feedback and any online views of your experiences with us to help us improve and optimize our services.
Banks, credit card companies, and relevant agencies who may share with third parties for the purpose of investigating and safeguarding against underage, fraudulent, criminal or suspicious activity or safer gambling and affordability checks (or other activities we are bound by law, regulation or guidance to investigate and safeguard against) or if we have reason to believe that you have undertaken such activity;

our regulators, law enforcement or fraud prevention agencies, as well as our legal advisers, courts, applicable independent adjudication services, and any other authorised bodies, for the purposes of investigating any actual or suspected criminal activity, maintaining standards of behaviour in gaming or other regulatory or legal matters.

We may share your personal information with other members of the Entain Group for marketing purposes. We will not share it with other 3rd party organisations however unless you have expressly opted-in/consented to the disclosure of your personal data for these purposes.

We may also disclose your personal information to third parties in the following circumstances:

in the event that we consider selling or buying any business or assets, in which case we will disclose your personal data to any prospective sellers or buyers of such business or assets;
in the event of any insolvency situation (e.g. the administration or liquidation) of Entain Group plc, or a data controller or any of its group entities;
if we, or substantially all of our assets, are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;
in order to enforce or apply our website terms of use;
to protect the rights, property, or safety of us, our staff, our customers, or others. This includes exchanging information with other companies and organisations (including without limitation, other gambling operators and the local police or other local law enforcement agencies) for the purposes of staff and customer safety, crime prevention, fraud protection and credit risk reduction;
if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or regulatory requirements, or otherwise for the prevention or detection of fraud or crime; and
Where you have self-excluded yourself from gambling, we may share this information with our regulators or other companies in our field where we believe it is important to support your exclusion.

Meeting our Responsible Gambling Obligations

We take responsible gambling very seriously at Entain. We may share your information across our brands in the Entain Group, and where required with other organisations to meet our responsible gambling commitments.
We have an obligation to identify those at harm from gambling as early as we can and help them stop gambling by placing certain limits on accounts; this could include deposit limits, product limits, limiting the ability of an account to gamble certain products / times / periods. In order to meet these obligations, we analyse customer’s transactions and evaluate behaviour or financial status across our products and brands, which may lead us to make decisions on your account(s). Please see the Affordability section on our website for more information.
We are also constantly looking at innovative ways to help spot players who may be on a path to difficulties and identify them digitally. This means that we may use systems that identify customers (such as cookies on player’s devices or images sent by you) and internally we have developed systems to understand your play to better communicate any risks concerning your activity. We may also share or receive player data with other organisations who help evaluate risks or assess affordability by looking at how you may interact with other gambling operators or help individuals directly.

In all these cases, please be assured that we take our obligations very seriously, in helping customers gamble responsibly and in protecting your personal information. We will always ensure that we take the most appropriate measures and controls to protect your data.

How long we retain your personal data

Type of Data	Typical Retention Time	Information
Customer Call recordings	3 years	An extended retention may be applied on a case by case basis
Customer Data	A 5-year retention period which starts to run from the date your account is closed	We will only continue to hold personal data relating to your account as permitted under data protection legislation (i) where we are under a legal requirement under gambling or tax legislation to retain your data; and (ii) to exercise or defend our legal rights If you register under the self-exclusion scheme, whilst the self-exclusion itself may have a shorter duration, a record of this will be retained longer as part of your customer profile.

The above retention times may be extended for example where it is needed to meet a specific regulatory obligation, investigate a crime, handle a claim or resolve a complaint

Locations that we may transfer your personal data

From time to time, service providers, members of the Entain Group and organisations with whom we work with, may be located outside the UK or European Economic Area in countries that do not have the same standards of protection for personal data as the UK or EEA Countries. We will, however, always use every reasonable effort to ensure sufficient protections are in place to safeguard your personal data. We will also ensure that our service providers enter into compliant processing agreements with us to ensure that your personal data is processed in accordance with applicable data protection legislation. Further information about the mechanisms we will apply can be found here but please contact us on the email address below if you have any specific questions regarding international transfers: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_en.

Security

We take compliance with security regulations, standards, guidelines and privacy laws very seriously and promote security measures that will maintain the confidentiality, integrity and availability of personal data. We use reasonable organisational, technical and administrative measures to protect customer personal data from unauthorised access, alteration, disclosure or destruction of personal data that we hold.

As a business, we have secure firewalled datacentres, certified encrypted webpages and we are ISO27001:2013 certified. We also take steps to ensure our subsidiaries, agents, affiliates and suppliers employ adequate levels of security across the business.

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 prevent unauthorised access attempts.

Cookies

We use cookies for various purposes including making your experience of our website better. For more information on our use of cookies, please see our Cookies Notice.

Marketing Communications and your choices

We use various forms of communication to interact with you, such as email, text or online.

When we first collect your personal data, we’ll ask you to tell us how you would like to hear from us in future about our other products and services. It will normally be via a tick boxes on forms or web page and you can opt-out at any time.

What is 'Opting Out'?

The term opt out refers to several methods by which individuals can avoid receiving unsolicited product or service information. This ability is usually associated with direct marketing campaigns such as telemarketing, e-mail marketing, or direct mail.

You may also hear from us online, by accepting marketing cookies or through your social media provider if you have agreed to accept marketing messages from them. You should check your Social Media providers own Privacy Notice in this regard.

*Please consider that 'opting out' will not prevent any essential customer correspondence e.g. bet or account correspondence.

How can I opt out of marketing correspondence?

If you do not wish to receive any offers, promotions, information on events and tailored communications based on your account activity, you can request to be made un-contactable by:

Using the “unsubscribe” option provided in any marketing communication you receive
changing your preferences on your account settings
contacting our Customer Support department.

What details do you require from me?

We would need as much of the following as possible, to ensure that you are not sent any further unwanted correspondence:

Your full name
Your account number
How we contacted you, i.e. email, SMS, or post
The mobile number or email/postal address we contacted you on
The mobile number or email address that the message came from
The date(s) and time(s) you were contacted
A copy of the message you were sent (e.g. a screenshot or a forwarded email sent to our customer care team)

Your rights

	Description of Right

Right 1 The right to be Informed access	You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights.
Right 2 The right of access	A right to access personal data held by us about you. This right is not an absolute right and must not be interpreted in isolation of the other provisions of the UK/Gibraltar GDPR. There are lawful limitations to this right that it may apply, for instance, where other rights such as; confidentiality, the rights of others, legal privilege and/or the right to apply adversarial disclosure rules in the course of a potential claim or the defence or establishment of a claim are in scope and need to be balanced with the right of access.
Right 3 The right to rectification	A right to require us to rectify any inaccurate personal data held by us about you.
Right 4 The right to erasure	A right to require us to erase personal data held by us about you. This right will only apply where (for example): we no longer need to use the personal data to achieve the purpose we collected it for; or where you withdraw your consent if we are using your personal data based on your consent; or where you object to the way we process your data (in line with Right 6 below). This right is not absolute and will not apply when legitimate and overriding reasons apply.
Right 5 The right to object to processing	In certain circumstances, a right to restrict our processing of personal data held by us about you. This right will only apply where (for example): you dispute the accuracy of the personal data held by us; or where you would have the right to require us to erase the personal data but would prefer that our processing is restricted instead; or where we no longer need to use the personal data to achieve the purpose we collected it for, but you require the data for the purposes of dealing with legal claims.
Right 6 The right to data portability	In certain circumstances, a right to receive personal data, which you have provided to us, in a structured, commonly used and machine-readable format. You also have the right to require us to transfer this personal data to another organisation, at your request.
Right 7 The right to object processing	A right to object to our processing of personal data held by us about you where the processing of such data is necessary for the purposes of our legitimate interests, unless we are able to demonstrate, on balance, legitimate grounds for continuing to process personal data which override your rights or which are for the establishment, exercise or defence of legal claims.
Right 8 The right not to be subject to automated decisions including profiling	A right for you not to be subject to a decision based solely on an automated process, including profiling, which produces legal effects concerning you or similarly significantly affect you.
Right 9 The right to withdraw consent	A right to withdraw your consent, where we are relying on it to use your personal data (for example, to provide you with marketing information about our services or products).
Right 10 The right to lodge a complaint	You have the right to complain to the: Gibraltar Regulatory Authority (https://www.gra.gi/)

Contact Us or Our Data Protection Officer

If you would like to exercise any of your data protection rights, such as the right of access to your information or data deletion, directly by yourself or by a third party on your behalf, please contact privacy@partycasino.com.

If you have any questions about this Notice or would like further information about your rights, our Data Protection Officer can be contacted by emailing: dataprotectionofficer@entaingroup.com .

Questions and comments regarding this privacy notice are welcomed.

*Please note that these channels are not monitored for any customer service-related queries.

Changes to this Privacy Policy

Any changes to this privacy policy in the future will be posted on this page, and where appropriate, notified to you by email. Please check back frequently to see any updates or changes to this privacy policy.

This policy was last reviewed and updated: March 2023