The privacy and security of your personal data is of the utmost importance to Carlton Clubs and we invest heavily in measures that help to protect your data protection rights.
This policy describes how and why we collect, store, process and manage the personal data we hold from our members. The term ‘Personal Data’ refers to any information relating to an identifiable individual or his or her personal identity.
This policy outlines how your data will be processed lawfully, fairly and in a transparent manner. Carlton Clubs does not sell or rent your personal data to third parties for marketing purposes whatsoever.
We will ensure that the personal data we process is accurate, adequate, relevant and not excessive, given the purpose for which it was obtained. We will not process personal data obtained for one particular purpose for any unconnected purpose unless the person has agreed to this or would otherwise reasonably expect this.
Carlton Clubs collects your personal data in order to manage your membership of our clubs. We also collect your data so that we can send you marketing information regarding our products, promotions and services for which you have provided your consent by specifying your choice of medium for receiving the communication.
You have the right to see the data we hold on you, rectify that data and also to request us to delete that data at any time.
1.1
Carlton Clubs is defined as the
data controller with regard to all of the information contained within this document.
1.2
This Privacy Policy sets out the
way in which Carlton Clubs (“we”, “us” or “Carlton Clubs”), collects and
processes Personal Information of our club members. Carlton Clubs Ltd is
registered for the purposes of data protection with the Information
Commissioner’s Office in the UK (Registration Reference: Z547305X).
1.3
By using our Services and
registering for membership, you acknowledge that you have read, and agree to
the terms of this Privacy Policy in relation to processing under legitimate interests.
1.4
This Privacy Policy is incorporated
into, and forms part of our terms & conditions of membership.
2.1
As part of maintaining your
membership, we collect your Personal Information. “Personal Information” means
any information from which you, as a ‘data subject’, can be personally
identified, including (for example) your name, email address, home address,
telephone number, debit/credit card data or date of birth.
2.2
We collect
your Personal Information when you register for membership, through the use of
online forms and when you email us your details. We also collect information about the transactions you undertake
whilst at our clubs.
2.3
In addition, we may collect
Personal Information through surveys which we undertake. Such surveys are
voluntary and are anonymous where possible.
3.1
Under data protection law you
retain the following rights over your personal data outlined in paragraph 3.2.
3.2
The right to access the data we hold about you
The right to rectification of any data that is inaccurate or incomplete.
The right to erasure of your data (also known as ‘the right to be forgotten’) The right to restrict processing of your data
The right to data portability
The right to object to the processing of your data
Rights in relation to automated decision making and profiling.
3.3
If you exercise your right to be
forgotten, this would result in a termination of your membership to Carlton
Clubs. This means you would no longer be able to visit or play at our clubs
unless you were to re-join as a member.
4.1
For the purpose of managing a
regulated business within the Gambling Industry it is important for us to
maintain a membership database. This database allows us to achieve our
regulatory compliance responsibilities and safeguard the security of our members.
4.2
It is a requirement of our Terms
and Conditions that any person who wishes to attend or partake in the services
offered at our premises must register as a member.
4.3
Information collected and processed
for the purposes of becoming and remaining a member is on basis of a legitimate
interest. The justification for this is outlined in 4.1 above.
4.4
In order to keep you up to date
with our news and promotional events we create and send regular marketing
information via direct marketing, SMS and email channels. In order to send you
this information we will gain your consent. This is usually obtained at the
point of registration.
4.5
This consent can be withdrawn at
any time by speaking to your local Club Manager
5.1
Your Personal Information is
processed by us to provide you with the products and services relating to our
business. In particular, we collect your Personal Information in order to
enable us to:
·
Set-up, administer and manage your
membership, associated accounts and records;
·
Receive and respond to your communications and requests;
·
Notify you about promotional offers and general marketing;
·
Ensure that we are able to fulfil
our regulatory obligations regarding your account, including by verifying the
accuracy of any information you give us;
·
Comply with our obligations under
applicable laws (including, but not limited to the Gambling Act 2005);
·
Investigate, and assist with the
investigation of, suspected unlawful, fraudulent or other improper activity
connected with the services (including, where appropriate, dealing with
requests from regulatory bodies for the sharing of information);
·
Carry out market research campaigns;
·
In the event that we sell or buy
any business, assets or shares in part or whole we may disclose your personal
details to such relevant third parties involved.
6.1
We may
disclose your Personal Information to any of the following recipients:
·
Any company within our Group
(including to its employees and sub- contractors) which assists us in providing
the services or which otherwise has a need to know such information.
·
Any contractors or other advisers
auditing any of our business processes or who have the need to access such
information for the purpose of advising us.
·
Any data processor which enables us
to manage systems or processes as part of any service or promotion offered to
our members.
·
Any law enforcement or regulatory
body which may have any reasonable requirement to access your Personal Information.
·
In the event that we sell or buy
any business, assets or shares in part or whole we may disclose your personal
details to such relevant third parties involved.
7.1
We will
not send you unsolicited information regarding any third party’s products or services.
7.2
As part of the account registration
process, you will have the opportunity to choose whether or not to receive
information on our offers and promotions. This consent is subject to the data
retention periods defined within this policy.
7.3
Existing members who registered
prior to 1st May
2018 and have not provided explicit consent to receive marketing information
will not receive marketing materials after 25th May 2018. (25th May is the
date on which the provisions of GDPR come into force in the UK)
7.4
We will
send you promotional marketing information and updates until such time that you
inform us that you do not wish to continue to receive them or do not refresh
your consent upon our request at the end of 5 years from the date of your consent.
You may update your marketing preferences at any time by contacting your local
club or through the contact form on our website: www.carltonbingo.com
8.1 You may update your Personal Information at any time by contacting your local Club Manager.
8.2
You may obtain a copy of your
Personal Information held by us by contacting your local Club Manager in
writing. We require up to one month in
order to respond to such requests.
8.3
Requests for access to your personal data are free
of charge.
9.1 We retain your data for no longer than is necessary. This length of time is different for each type of personal data that we hold. These retention periods are subject to change only where deemed necessary where there is a defined vital interest under data protection law.
|
Membership information |
This is the information we
collect at the point of registration |
Data retained for 5 years after data subjects’ most recent visit. |
|
Marketing Preferences |
These are the marketing channels you give consent
for us to contact you by |
Data retained for 5 years
from consent being given. |
|
Information
required by legislation |
This includes data which
relates to social responsibility or anti- money laundering policy |
Data retained for 10 years after data subjects’ most recent visit. |
|
Data relating to spend
information |
This includes information on cash or card
transactions which take place on or around our premises in exchange for
products or services provided by Carlton Bingo |
Data retained for 5 years after data subjects’ most recent visit. |
Figure 1.1 data retention
periods
10.1
We may
collect anonymous information about your use of our website (the website’ refers specifically to www.carltonbingo.com, if
appropriate using “cookies”, pixel tags and similar functionality. We use cookies for the operation of the
website. We also use cookies for our
own analytical purposes so that we can improve our customers’ experience.
10.2
If you object to cookies or want to
delete any cookies that are already stored on your computer, you should follow
the instructions for deleting existing cookies and disabling future cookies on
your web browser or equivalent software. Further information is available at www.aboutcookies.org.
10.3
As part of the website’s operation,
and for our own statistical analysis of site traffic, our website automatically
logs internet IP addresses.
11.1
We use
a number of methods to ensure that all customer information remains
confidential. We have developed a
comprehensive policy for data
protection management which is reviewed and updated as necessary.
Carlton Clubs takes the responsibility of holding personal data very seriously and is happy to receive any queries or concerns you may have. If you believe that we have not adhered to this policy or that your data has been handled in a way which you feel is not in accordance with your wishes then you may complain using the following contact details:
Carlton Bingo Ltd PO Box 21
23/25 Huntly Street Inverness
IV1 1LA
SARrequests@carltonclubs.com 01463 237611
Alternatively you may contact the Information Commissioners Officer (ICO) directly who are the body responsible for managing data protection compliance in the UK.
You can contact the ICO at the following address: Information Commissioner's Office
Wycliffe House Water Lane Wilmslow Cheshire
SK9 5AF
casework@ico.org.uk 0303 123 1113
Please contact us via the contact form on our website or in writing to: Carlton Bingo Ltd
PO Box 21
23/25 Huntly Street Inverness
IV1 1LA
SARrequests@carltonclubs.com 01463 237611