The Company (as defined in the User Agreement applicable to you) offers gambling services (the “Services”) via its in-house brands (each an "In-House Brand") and via third parties' brands as part of so called "white labels". The white label owner and its corporate affiliates shall hereinafter be referred to as the "White Label Brand".
The Group (as defined below), and the White Label Brand (if applicable) (collectively "we", "our" or "us"), know that how we collect, use and protect your information is important to you (“you” or the “user”), and we value your trust. That is why protecting your information and being transparent about what we do with it is a vital part of our relationship with you.
- The Group
- The types of information we collect
- How we use the information we collect and for what purposes
- Cookies and pixels
- Data sharing
- User choice and retention
- Keeping your information secure
- Accessing, updating and correcting your information
- How to contact us
About the Group
The 888 group of companies (the “Group”) is headquartered in Gibraltar and the Company (as applicable) forms part of the Group. The Group provides the Services through the following applications and platforms (collectively the “Platforms”):
- Internet websites;
- Downloadable applications and software ("Software"), such as native applications which are distributed through mobile application stores and PC and Mac desktop software which can be downloaded to your computer;
- Non-downloadable online applications (e.g. flash applications, HTML5 applications, etc.);
- Facebook applications; and
- White Label Brands.
Information We Collect
We may collect the following types of information from or about you:
- Personal Information
- What is “Personal Information”?
Personal Information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual. We gather the information, either independently or through the help of third party service providers, as detailed below.
- Types of Personal Information we collect from or about you
- Registration details: When you open an account and register to use the Services, you will be asked to provide us certain details about yourself, such as: first and last name, email address, full name and gender, birth data, physical address, ID number, phone number, etc.
- Payment information: In order for you to enjoy all of the functions of the Services (e.g. place bets, perform purchases, play in tournaments, etc.), payment information may be collected from you, such as your credit card number and bank account details.
- 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 or share additional information about yourself through your use of the Services, such as on the chat feature and in games.
- 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 (e.g. UDID, MAC address), browser fingerprinting, IP address and geo-location data.
- Information we collect from third parties: We may collect Personal Information from third party service providers, such as information about your credit history from credit agencies and other financial information which is relevant to the provision of the Services, as well as information which is gathered in order to verify your identity and prevent fraudulent or illegal activity.
- What is “Personal Information”?
- Non-personal Information
- What is “Non-personal Information”?
Non-personal Information is non-identifiable information that, when taken alone, cannot be used to identify or contact you. 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 the Services, preventing fraud and performing web analytics. We may gather such information, either independently or through the help of our third party service providers and the White Label Brand (if applicable).
- Types of Non-personal Information we collect from or about you:
- Technical information: In order to enhance the functionality of the Services 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. the type of browser and operating system your device uses, language preference, access time and the domain name of the website from which you linked to the Services; etc.).
- Gameplay information: We record game play information including, amongst other things, your deposits, bets, bonuses, game session duration and your high scores. We may also share and publish such information through any of our Platforms.
- Device and connection information: If you download the Software to your device, we may collect information from the particular device you are using, for security and fraud detection and prevention purposes. For example, we may gather information with regard to other software which is running simultaneously with the Software for detecting if you are using software which is associated with fraudulent activity (e.g. robots, malware, etc.) or checking if the connection you are using is via a VPN or proxy.
- Analytics information: We collect information about your use of the Services, such as applications' 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 and analytics purposes about your use of the Services.
- Data combination: If we combine Personal Information with Non-personal Information or anonymous information, the combined information will be treated as Personal Information for as long as it remains combined.
- What is “Non-personal Information”?
Cookies and Pixels
A "cookie" is a small piece of information that a website assigns to your device while you are viewing the website. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages of the website efficiently, enable automatic activation of certain features, remembering your preferences and making the interaction between you and the Services quicker and easier. Cookies are also used to help ensure that the advertisements you see are relevant to you and your interests and to compile statistical data on your use of the Services.
Cookies cannot harm your device as they are non-executable and cannot be used to install malware. They’re more like a personal file with basic information about you that is checked and updated every time you visit the website.
We may use the following types of cookies:
- 'Session cookies' which are stored temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed;
- 'Persistent cookies' which are saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, to store your preferences for the next log-in and to improve our users’ experience of the Services and website as well as present different marketing messages and advertisements for existing users; and
- 'Third party cookies' which are set by other websites or services that run content and advertisements on the page you are viewing, such as by third party analytic companies or advertisers who monitor and analyze your web access.
- 'Flash cookies' which are saved during game play to allow quicker and better gaming experience.
We also use pixel based tracking to track a visit or event on the Platform and to track advertisements' impressions. This information is also used by us for remarketing purposes and for tracking conversions that are used to optimize our marketing activities. We may share such information (which is Non-personal Information) with our advertising and marketing partners. Please see below specific information with regard to our advertising and marketing practices.
You may remove the cookies by following the instructions of your device preferences; however, if you choose to disable cookies, some features of the Service may not operate properly and your online experience may be limited. Additionally, for legitimate security reasons, we may refuse access to specific website content unless you accept the use of a cookie or similar device.
How We Use the Information Collected
- To set up and update your account;
- To provide the Services to you via any of the Platforms;
- To communicate with you and to keep you informed of our latest updates and special offers;
- To market our websites, products and services . (see below, under "Marketing");
- To serve you advertisements;
- To conduct analytics in order to improve and customize the Services to your needs and interests;
- To support and troubleshoot the Services and to respond to your queries;
- To provide you with a responsible gaming environment;
- To notify you about updates to our software and/or Services;
- To process any of your requests for information;
- To identify and authenticate your access to certain features of the Services;
- To detect and prevent fraudulent and illegal activity or any other type of activity that may jeopardize or negatively affect the integrity of the Services;
- To investigate violations of our policies and User Agreement as well as enforce our policies and the User Agreement;
- To investigate and resolve disputes in connection with your use of the Services; and
- As required by law, regulation or other governmental authority or to comply with a subpoena or similar legal process or respond to a government request.
We may share Personal Information with any of the following recipients:
- The White Label Brand;
- Any replacement service provider that the White Label Brand may engage to operate the “white label” website or any application (if applicable);
- Companies within the Group and other affiliated companies;
- Subcontractors and third party service providers as well as their subcontractors which by way of example includes but is not limited to payment processors and data verifiers;
- To any third parties who provide services in relation to the operation or promotion of the applicable In House Brand or the “white label” website and application (if applicable)
- To any third parties who organize offline events or tournaments on behalf of or in conjunction with any companies within the Group;
- Auditors, contractors or advisers of any of the Group's business processes;
- To any third parties who investigate, detect or prevent fraudulent or illegal activity (e.g. governmental authorities, police, banks and other investigatory organizations); and
- Potential purchasers or investors in any of the companies within the Group or While Label Brand (if applicable) or the “white label” (if applicable).
- Storing such information on our behalf, for example by using cloud computing service providers;
- Processing such information to assist us with our business operations (e.g. to process payments and your deposits; authenticate your access; auditing our operations; detect and prevent fraudulent or illegal activity; etc.);
- Performing research, technical diagnostics or analytics; and
- Communicating promotional and informational materials, in accordance with our marketing policy (see below, under "Marketing").
We may or also share your information with third parties whenever we believe in good faith that disclosure is necessary to protect our rights or legal claims, protect your safety or the safety of others, as well as to investigate or prevent any fraud, for security reasons or to help us with any other related technical issue.
We may also share Non-personal Information or anonymized information with other third parties for advertising purposes (see below specific information with regard to our advertising and marketing practices, under "Advertisements").
Third Party Collection of Information
You are knowingly and voluntarily assuming all risks of using any third-party websites, services or applications. You agree that we shall have no liability whatsoever with respect to such third party sites and your usage of them.
User Choice and Retention
You may, at any time, request to change and update your Personal Information by emailing us at email@example.com. You may also request that we will correct errors with regard to your Personal Information (except in cases where the information is required to be kept in its original format under any applicable laws and regulations).
Any request to obtain a copy of your Personal Information, is subject to us receiving an administrative fee of £10 as well as any documentation and/or information we may require to confirm your identity and assist us with your enquiry. Following our receipt of such fee and all of the documentation and information required, we will provide you with a copy of your Personal Information within 28 days.
We may also rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.
We take great care in implementing and maintaining the security of the Services and your information. We have put in place appropriate physical and technological safeguards to help prevent unauthorized access, to maintain data security, and to use correctly the information we collect online. These safeguards vary based on the sensitivity of the information that we collect and store.
We employ industry standard procedures and controls to ensure the safety of our users’ information, such as:
- Secure network topology, which includes intrusion prevention and Firewall systems;
- Encrypted communication;
- Authentication and Access Control;
- External and Internal audit tests; etc.
Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse the Services, and we make no warranty, express, implied or otherwise, that we will prevent such access.
Since we operate globally, it may be necessary to transfer your Personal 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 − in these instances we will take steps to ensure that a similar level of protection is given to your Personal Information. You hereby consent to transfer of your Personal Information to countries outside the European Union.
If you feel that your privacy was treated not in accordance with our policy, or if any person attempted to abuse the Services or acted in an inappropriate manner, please contact us directly at firstname.lastname@example.org.
We use a third-party advertising technology to serve advertisements when you visit the Platforms and use the Services. This technology uses Non-personal Information with regards to your use of the Services to serve advertisements to you (e.g. by placing third-party cookies on your web browser). We may also use our third parties and share with them Non-personal Information to assist us in evaluating the success of our advertising campaigns and help us retargeting our users.
You may opt-out of many third-party ad networks, including those operated by members of the Network Advertising Initiative (“NAI”) and the Digital Advertising Alliance (“DAA”). For more information regarding this practice by NAI members and DAA members, and your choices regarding having this information used by these companies, including how to opt-out of third-party ad networks operated by NAI and DAA members, please visit their respective websites: http://www.networkadvertising.org/optout_nonppii.asp and http://www.aboutads.info/choices.
We, both the Group and the White Label Brand may use your Personal 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 the Services as well as products, services, websites and applications which relate to: (i) other companies within the Group; (ii) White Label Brand; or (iii) Group's business partners and affiliates (collectively: “Marketing Affiliates”), which we believe may interest you.
We may also share and disclose Personal 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 Personal Information for different marketing techniques, such as direct email, post, SMS and telephone marketing purposes.
You may at any time decline receiving further marketing offers from us or from our business partners and marketing affiliates by contacting us at to email@example.com. Please note that even if you unsubscribe from our marketing mailing list, we may continue to send you service-related updates and notifications.
You hereby acknowledge and agree that by downloading, installing or accessing the Services, we may share your Personal Information with our business partners and marketing affiliates for the purpose of marketing.
We may share Information, including Personal Information, in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, reorganization, bankruptcy, consolidation or asset sale of an asset or transfer in the operation thereof) in relation to any company within the Group or in the event of a corporate transaction in relation to the White Label Brand (if applicable) or the “white label”.
The Services are not designed or directed to persons under the age of 18 or persons under the age of legal consent with respect to the use of the Services of any jurisdiction, whichever is higher (“Legally of Age”). If you are not Legally of Age, you should not download or use the Services nor provide any Personal Information to us.
We reserve the right to access and verify any Personal Information collected from you. In the event that we become aware that a user who is not Legally of Age has shared any information, we may discard such information. If you have any reason to believe that a minor has shared any information with us, please contact us at firstname.lastname@example.org.
How to Contact Us
If you have any general questions about the Services or the information that we collect about you and how we use it, please contact us via email at email@example.com or by sending a letter to Suite 601-701, Europort Avenue, Gibraltar.
Information about Us
The Group includes the following companies all of which have an address at 601-701 Europort, Gibraltar:
- Cassava Enterprises (Gibraltar) Limited;
- 888 UK Limited;
- Virtual Digital Services Limited; and
- 888 Ireland Limited.
Last updated on 11th of may, 2017