Privacy Policy

<tr>
  <td class="px-6 py-4 border-r border-gray-500 align-top">
    <p>Fraud prevention / Anti-money laundering</p>
  </td>
  <td class="px-6 py-4">
    <p>
      When you use our services we may need to process and verify your
      personal data to comply with fraud prevention and anti-money
      laundering requirements, regulators’ requirements (including the UK
      Gambling Commission and other industry standards. In some instances,
      we may share your personal information with third parties to conduct
      identification or verification checks and/or to enable financial
      transactions to be processed.
    </p>
    <p>
      <em>Specific examples are:</em>
    </p>
    <ul>
      <li>
        <em>
          Sharing and validating your data with credit reference agencies,
          fraud prevention agencies or for age verification purposes.
        </em>
      </li>
      <li>
        <em>
          Sharing and validating your data against databases or with
          commercial organisations which identify potential illegal activity
          or related indicators of the same.
        </em>
      </li>
      <li>
        <em> Sharing your data with law enforcement agencies. </em>
      </li>
      <li>
        <em>
          In order to ensure that illegal activity, including fraud and
          anti-money laundering, is prevented and detected, we may have
          cause to work with and share your data with other gambling
          operators. We will ensure that any data we share or receive for
          this purpose is shared or received lawfully and in line with
          industry guidelines.
        </em>
      </li>
      <li>
        <em>
          Monitoring your interactions with us for crime prevention
          purposes, for example cheating at gambling.
        </em>
      </li>
      <li>
        <em>
         Using public sources to verify information you have provided to us on affordability, source of funds and CCD / ECDD due diligence, including social media pages, the electoral roll, HM Land Registry, Companies House and insolvency registers.
        </em>
      </li>
    </ul>
    <p><em>Sharing and validating your data (to the minimum extent necessary)
          with other gambling operators, service providers, banks, financial
          institutions and payment service providers / gateways, the
          National Casino Forum, the International Association for Casino
          Surveillance and similar bodies or associations in the interests
          of security, good practice or safety, for the purposes of the
          prevention and detection of crime, cheating, counter-fraud
          measures and investigations, money laundering, other impropriety,
          and in order to uphold gaming integrity.</em></p><br />
    <p>
      <em>
        If you would like to know more about gambling regulation and the
        obligations we are placed under as a licensed gambling operator,
        please visit the UK Gambling Commission’s website
      </em>
      (<a href="http://www.GamblingCommission.gov.uk">
        <em>www.GamblingCommission.gov.uk</em>
      </a>)
      
    </p>
    <p>
      <strong>
        In our view, our processing of your personal data under this
        category is essential to our ability to comply with legal and
        regulatory requirements, and to protect our business and customers.
        Should you object to our use of your data for these purposes your
        only option may be to terminate your membership and/or not use our
        services. Even if you do so we may retain some data for a period of
        time due to legal and/or regulatory obligations.
      </strong>
    </p>
  </td>
</tr>
<tr>
  <td class="px-6 py-4 border-r border-gray-500 align-top">
    <p>Compliance with legal and regulatory obligations</p>
  </td>
  <td class="px-6 py-4">
    <p>
      We are subject to a number of laws and regulations and we are
      required to process and provide personal data requested by regulatory
      bodies, law enforcement agencies and the courts.
    </p>
    <p>
      Some of the legal and regulatory obligations we are placed under
      require us to use personal data collected for certain purposes and/or
      to retain it for a specified time period.
    </p>
    <p>
      We may also be required to share information with industry bodies.
    </p>
    <p>
      We have in place a number of safeguards and mitigations to ensure
      that your personal data is processed proportionately and safely when
      processed for these purposes.
    </p>
    <p>
      <em>Specific examples are:</em>
    </p>
    <ul>
      <li>
        <em>
          Carrying out checks during the course of your relationship with us
          to ensure that you are gambling legally. These checks may include
          the securing of a copy of identification, for example a copy of
          your passport or asking you to evidence the source of your funds.
        </em>
      </li>
      <li>
        <em>
          Carrying out checks, monitoring your play, and segmenting or
          profiling the data we hold about you and your gambling with us to
          ensure that you are gambling responsibly and to enable us to
          identify and intervene when we think you may be at risk of problem
          gambling;
        </em>
      </li>
      <li>
        <em>
          In some instances we may ask third parties to assist us with this
          segmentation or profiling. Such parties may also include other
          companies within the wider Genting group of companies.
        </em>
      </li>
      <li>
        <em>
          Conducting checks against the SENSE national self-exclusion scheme
          or any other national self-exclusions schemes in any country to
          which we might subscribe from time to time so that we can apply
          your chosen restrictions to services we provide to you.
        </em>
      </li>
      <li>
        <em>
        Using Live Facial Recognition Technology to help identify individuals who suspended / barred for responsible gambling reasons. 
           </em>
      </li>
      <li>
        <em>
          Compliance with requests for disclosures by law enforcement
          agencies, regulatory bodies (such as the UK Gambling Commission or
          the courts.
        </em>
      </li>
      <li>
        <em>
          Using records held for other audit, insurance, legal and
          regulatory compliance purposes.
        </em>
      </li>
    </ul>
    <p>
      <em>
        If you would like to know more about gambling regulation and the
        obligations it places Genting under, please visit the Gambling
        Commission’s website
      (<a href="http://www.GamblingCommission.gov.uk">
        www.GamblingCommission.gov.uk
      </a>)
      </em>
    </p>
    <ul>
      <li>
        <strong>
          On occasion you may indirectly provide us with sensitive
          information, such as your ethnicity (for example if you provide us
          with identification documentation). We will only use this
          information for the specific purpose for which it is provided.
        </strong>
      </li>
    </ul>
    <p>
      <strong> </strong>
    </p>
    <ul>
      <li>
        <strong>
          You may also provide us with sensitive information about your
          psychological or physical health, in particular if you were to
          talk to us about problems with gambling. We understand the
          sensitivities surrounding such disclosures and will only ever use
          this information to provide you with support or to ensure we
          comply with legal or regulatory obligations.
        </strong>
      </li>
    </ul>
    <p>
      <strong>
        In our view, our processing of your personal data under this
        category is essential to our ability to comply with legal and
        regulatory requirements, and to protect our business and customers.
        Should you object to our use of your data for these purposes your
        only option may be to close your account and/or not use our
        services. Even if you do so we may retain some data for a period of
        time due to legal and/or regulatory obligations.
      </strong>
    </p>
  </td>
</tr>
<tr>
  <td class="px-6 py-4 border-r border-gray-500 align-top">
    General commercial operations
  </td>
  <td class="px-6 py-4">
    <p>
      We use personal data to manage the day-to-day operation of our
      business and to enable us to provide you with our products and
      services. This includes management of customer preferences, suppliers,
      and other relationships, sharing information within the Genting group,
      implementing safety procedures and allocating resources.
    </p>
    <p>
      <em>Specific examples are:</em>
    </p>
    <ul>
      <li>
        <em>
          Facilitating the creation of your membership or account, or our
          provision of services to you.
        </em>
      </li>
      <li>
        <em>
          Responding to queries we receive from you (for example by email,
          text, social media etc)
        </em>
      </li>
      <li>
        <em>
          Administering your participation in our rewards / loyalty schemes
          including ‘My Genting’
        </em>
      </li>
      <li>
        <em>
          Using technical information about your device, such as browser
          version, operating system, IP address and location data to ensure
          our websites or mobile Apps are functioning correctly and that you
          are presented with the correct version.
        </em>
      </li>
      <li>
        <em>
          Contacting you about important service matters (non-marketing).
        </em>
      </li>
      <li>
        <em>
          To maintain our records, including transactional, financial and
          player records.
        </em>
      </li>
      <li>
        <em> To monitor and analyse activity in our casinos </em>
      </li>
      <li>
        <em>
          To conduct internal analysis of our customers to enable us to
          understand why and how you use our services and what we can do to
          improve them. For example, for our land-based services we may
          monitor the busiest times in our premises so that we can ensure we
          have the requisite number of staff available or we may consider
          the broad demographic groups who use our services at different
          times and in different locations so that we can offer appropriate
          facilities and services to those sites.
        </em>
      </li>
      <li>
        <em>
          To share information with other companies within the wider Genting
          group of companies.
        </em>
      </li>
      <li>
        <em> Administering your responsible gambling controls. </em>
      </li>
      <li>
        <em>Reporting management information.</em>
      </li>
      <li>
        <em>
          Monitoring physical access to offices, visitors, conducting CCTV
          operations and audio recordings, surveillance reports of game play for gaming integrity monitoring.
        </em>
      </li>
      <li>
        <em>
          To monitor your use of our products and services for business
          intelligence purposes. For example we may monitor your use of our
          services to ensure that you act in line with our terms and
          conditions so that we can identify activity that may be
          prejudicial to our commercial interests (for example fraudulent
          activity) and take requisite action such as by restricting the
          services we provide to you.
        </em>
      </li>
      <li>
        <em>Managing third party relationships.</em>
      </li>
      <li> 
        <em>Conducting market research.</em>
      </li>
    </ul>
    <p>
      <em>
        Processing identifiable personal data by
        anonymising/de-identifying/re-identifying/pseudonymising.
      </em>
    </p>
    <ul>
      <li>
        <em>
          To enable you to participate in interactive features of our
          services when you choose to do so, including administering your
          voluntary participation in any promotional events, engagement
          surveys, market research activities, competitions or prize draws
          from time to time. In relation to competitions and tournaments, this may include, but is not limited to, displaying your name, county of residence and performance stats on a competition leader board or similar display in our casinos .You can opt-out of appearing on our leader boards by notifying our staff at any time.
        </em>
      </li>
      <li>
        <em>
          To keep our services, websites and mobile Apps safe and secure.
        </em>
      </li>
      <li>
        <em>
          To improve our products and services through troubleshooting,
          testing, analysis, and research activities.
        </em>
      </li>
      <li>
        <em>
          Conducting research in connection with our obligations as a
          socially responsible gambling operator – for example, making
          samples of anonymised or pseudonymised player data available to
          our third party research partners for the purpose of developing
          our responsible gambling safeguarding / problem gambling detection
          measures.
        </em>
      </li>
      <li>
        <em>
          For information, system, cyber and network security. For example
          we will use personal data you provide to us to monitor, detect and
          protect our business, its infrastructure, networks, computer
          systems, information, intellectual property and other rights from
          unwanted security intrusion, access, disclosure of and acquisition
          of information, data and software breaches, hacking, industrial
          espionage and cyberattacks.
        </em>
      </li>
    </ul>
    <p>
      We may use cookies to facilitate our ability to personalise some of
      the services we refer to in this section. You can control this through our interactive consent tools on our website or via 
      your browser settings. Please see the <u>Cookies Policy</u> for more
      information on our use of Cookies and how to manage their settings.
    </p>
    <p>
      <strong>
        In our view, our processing of your personal data under this
        category is essential to our ability to ensure that we protect our
        commercial interests. Should you object to our use of your data for
        these purposes you have the option to close your account and/or not
        use our services. Even in these instances we may retain some data
        for a period of time due to legal and/or regulatory obligations.
      </strong>
    </p>
  </td>
</tr>
<tr>
  <td class="px-6 py-4 border-r border-gray-500 align-top">
    Marketing
  </td>
  <td class="px-6 py-4">
    <p>
      We will process certain personal data to gather market intelligence,
      promote products and services, communicate offers to individual
      customers and monitor the use and take up of our loyalty and reward
      cards and points and promotions (for example, so that we will have an
      understanding of your interests so that we can send you offers more
      relevant to you).
    </p>
    <p>
      We may also provide aggregated and pseudonymised or anonymised data
      to third parties – where we do this we will ensure that these third
      parties take appropriate measures to secure any personal data that is
      provided, however we would look to anonymise / pseudonymise where
      possible.
      <strong>
        We will never pass your contact information to third parties for
        them to use for their own marketing purposes unless we have your
        consent.
      </strong>
      <strong>
        Where you have opted-in to receive direct marketing communications
        from us (or have not chosen to opt-out as the case may be) we may
        from time to time engage third party service providers to carry out
        direct marketing activities on our behalf. In such cases, our third
        party service providers are not permitted to use your details for
        their own direct marketing activities or to pass your data on to any
        other third parties for these purposes. Such arrangements are
        subject to contractual protections to ensure the safeguarding and
        integrity of your data in accordance with the relevant data
        protection laws.
      </strong>
    </p>
    <p>
      <em> Specific examples of the marketing we will undertake are: </em>
    </p>
    <ul>
      <li>
        <em>
          Direct marketing by email, SMS, telephone, push notification,
          Whatsapp.
        </em>
      </li>
      <li>
        <em>Targeted advertising on social media.</em>
      </li>
      <li>
        <em>Marketing by post.</em>
      </li>
      <li>
        <strong>
          When you become a registered member of our Casinos, we will
          contact you by email and/or SMS for the purposes of direct
          marketing about similar products and services automatically. This
          is known as the “soft opt-in” rule under current e-privacy
          regulations. In these circumstances we will provide you with a
          simple means of refusing our use of your personal data for these
          purposes both at the time we collect your details and in each
          subsequent communication we send to you.
        </strong>
      </li>
    </ul>
    <ul>
      <li>
        <strong>
          In addition, you can opt-out of marketing at the time that you
          become a member or initially transact with us, at any point by
          accessing our <u>Preference Centre</u>, by clicking on the link
          included in our marketing communications, by contacting our
          customer support services, or by asking at any of our reception
          desks.
        </strong>
      </li>
    </ul>
    <p>
      <u> </u>
    </p>
    <h4>Preference Centre</h4>

    <p>
      We have created a Preference Centre within which you will be able to
      control how and why we contact you for the purposes of direct
      marketing. We will include a link to our Preference Centre in all of
      the communications that we send to you.
    </p>
    <p>
      We will only ever contact you in accordance with your contact
      preferences.
    </p>
    <ul>
      <li>
        <em>
          Our main means of contact will be by post, email, SMS, telephone,
          Whatsapp and push notification. From time to time we may contact
          you by other means (for example via social media).
        </em>
      </li>
      <li>
        <em>
          Matters we may contact you about include existing or future
          services, products, promotional offers, loyalty and rewards
          incentives, service changes and other of our activities and those
          of our group companies which we think may be of interest to you.
        </em>
      </li>
    </ul>
    <p>
      <strong>
        You can update your contact preferences or opt-out from the receipt
        of direct marketing in our Preference Centre, at reception, or by
        following the instructions in any marketing communications we send
        you.
      </strong>
    </p>
    <h4> In App Data Collection / Use and Website Marketing </h4>
    <p>
      If you are a user of any of our mobile Apps or our Website, we may
      send you push notifications. You can disable these notifications
      independently through your devices settings and by following the
      prompts issued on download of mobile Apps..
    </p>
    <p>
      We use services to review in-App events as part of your use of our
      mobile gaming Apps. These technologies collect information regarding
      in-App player activity such as new-user registrations, login and
      session times, device and IP data. Our third party partners do not
      process this data for their own purposes and provide only hosting and
      reporting solutions for Genting’s internal business activities. Data
      collected via these technologies allows us to analyse and improve our
      services, to offer you gaming experiences and marketing more tailored
      to your preferences and to measure the effectiveness of our
      advertising campaigns. You can manage data collection and Ads
      preferences via your device's privacy settings (e.g.
      <a href="https://support.apple.com/en-gb/HT202074">
        Apple iOS Limit Ad Tracking
      </a>
      ,
      <a href="https://support.google.com/ads/answer/2662922?hl=en-GB">
        Opt-out of seeing personalised Ad on Android device/Google
      </a>
      ).
    </p>
  </td>
</tr>
<tr>
  <td class="px-6 py-4 border-r border-gray-500 align-top">
    Profiling or segmentation
  </td>
  <td class="px-6 py-4">
    <h4>Marketing</h4>
    <p>
      We would like to be able to contact you about specific offers and
      promotions that we believe will appeal to you.
    </p>
    <p>
      In order for us to be able to approach our marketing in a socially
      responsible and non-invasive manner we need to fully understand your
      use of our services by carefully analysing your preferred products and
      average spend alongside the records that we hold about our other
      customers.
    </p>
    <p>
      We analyse your data by placing it into pre-determined segments
      based on the specific offer or promotion we are operating.
    </p>
    <ul>
      <li>
        <em> Our segments are identified using information such as: </em>
      </li>
      <li>
        <em>
          Product (to ensure that we only contact you about your preferred
          products);
        </em>
      </li>
      <li>
        <em>
          Spend (to ensure that we only bring offers to your attention that
          correlate with your preferred spend and that we act in a socially
          responsible manner);
        </em>
      </li>
      <li>
        <em>
          Location (to ensure that we only contact you about offers that are
          realistically accessible by you from a geographical perspective)
        </em>
      </li>
      <li>
        <strong>
          We will never use any special category personal data that we hold
          about you for marketing profiling purposes unless we have your
          explicit consent to do so.
        </strong>
      </li>
    </ul>
    <h4>
      Social Responsibility / Anti-money laundering / Business records
    </h4>
    <p>
      We may also profile or segment your personal data to ensure that we
      act in socially responsible and lawful manner, and to enable us to
      produce anonymised transactional business reports.
    </p>
    <p>
      We will only share the results of this information externally if we
      are required to do so by law.
    </p>
    <h4>Important Information</h4>
    <ul>
      <li>
        <strong>
          We strongly believe that our customers would rather receive
          marketing information that is relevant to their preferences. Our
          ability to segment or profile the information that we hold is
          essential if we wish to ensure this occurs. All of our marketing
          is tailored in this way.
        </strong>
      </li>
    </ul>
    <p>
      <strong>
        IF YOU DO NOT WANT US TO SEGMENT OR PROFILE YOUR INFORMATION FOR
        MARKETING PURPOSES, YOU WILL NEED TO OPT-OUT OF THE RECEIPT OF ALL
        MARKETING FROM US.
      </strong>
    </p>
    <ul>
      <li>
        <strong>
          You can opt-out of marketing at the time that you become a member
          of our land-based casinos at any point by accessing our Preference
          Centre, by clicking on the link included in our marketing
          communications or by asking at any of our reception desks.
        </strong>
      </li>
      <li>
        <strong>
          If you have opted-out of the receipt of marketing we may still
          segment your data for the sole purpose of ensuring you do not
          receive marketing information from us. We will continue to
          personalise our online services. Please see
          <a href="/cookies-policy/">our Cookies Policy</a> for more information about this and how
          to control our use of cookies.
        </strong>
      </li>
    </ul>
  </td>
</tr>
<tr>
  <td  class="px-6 py-4 border-r border-gray-500 align-top">
    Sharing with, or processing by, third parties
  </td>
  <td class="px-6 py-4">
    <p>
      We may need to provide your personal data to third parties in order
      to deliver certain aspects of our services to you and to generally run
      our day to day business operations. The majority of these third
      parties are our service providers or other companies within the wider
      Genting group of companies. Where we do this we will ensure that these
      third parties take appropriate measures to secure your data.
    </p>
    <p>
      <em>Specific examples are:</em>
    </p>
    <ul>
      <li>
        <em>
          Sharing data with other Genting branded services such as Genting
          Casino online (operated by our third-party partner Skill On Net
          Limited). We may use land-based customer data to determine where our UK
          casino customers are also customers of Genting Casino online. We
          may use this data to offer and suggest other Genting branded
          products and services that you may be interested in.
        </em>
      </li>
      <li>
        <em>
          Providing personal data to other gambling operators, service
          providers, banks, financial institutions, the National Casino
          Forum, the International Association for Casino Surveillance and
          similar bodies or associations in the interests of security, good
          practice or safety (for example, our participation in the Casino
          Operators Information Network “COIN”, for the purposes of the
          prevention and detection of crime), cheating, bonus abuse and
          other service mis-use, counter-fraud measures and investigations
          (including the verification and investigation of “chargeback”
          claims relating to your transactions with Genting), money
          laundering, other impropriety, and in order to uphold gaming
          integrity.
        </em>
      </li>
      <li>
        <em>
          Processing your payment transaction data in conjunction with our
          third party payment service providers and payment gateways, banks
          or financial institutions acting as ‘Acquiring Banks’ and
          Alternative Payment Method Providers (APMPs) in each case to
          enable us to receive payments from you and to credit payments to
          you (e.g. the payment of gaming winnings or the withdrawal of
          funds back to your card). In such circumstances, third party
          payment service providers and gateways, Acquiring Banks and APMPs
          may act as Data Controllers in their own right in respect of
          certain processing activities associated with receiving and making
          payments online. **We use the ‘Worldpay’ group as a payment services provider – Worldpay also act as an independent Controller of the personal data that you provide as part of a payment transaction. You can find more information about how they process your personal on Worldpay’s corporate website.** 
        </em>
      </li>
      <li>
        <em>
          Providing your personal information to our service providers,
          software suppliers and game suppliers who help us to provide you
          with services (for example, a software service used to supply
          gaming services to you, a cloud services provided for data storage
          / hosting or services used to process bookings or payments or to
          provide customer service support.
        </em>
      </li>
      <li>
        <em>
          Providing your personal data to other Genting Group Companies (for
          example Genting Malaysia Berhad and the group of Genting companies
          identified at the beginning of this Privacy Notice) (acting as
          controller or processor) in relation to services they provide,
          offer, or consider providing to you and for any other purpose
          which would be permitted under this policy if we undertook the
          same processing of your data. Such processing is also necessary
          for us to carry out our day to day business operations in the
          context of a multi-brand group of companies.
        </em>
      </li>
      <li>
        <em>
          Providing your personal data (typically basic information such as
          your name and contact information) to social media operators
          including (but not limited to) Facebook and Twitter to facilitate
          our marketing to you via the social media channels that you
          participate in. Use by those social media operators for that
          purpose will also be subject to the privacy policies that such
          operators provide to you, and where applicable, to the contact
          preferences, consent and privacy settings that you have given
          those operators in relation to their use of your personal data.
          Please note that your Preference Centre settings will not be
          reflected in our marketing via these third parties; they only
          apply to marketing sent directly by us.
        </em>
      </li>
      <li>
        <em>
          Sharing your device, content and log Information with our service
          and analytics providers in order to enable them to analyse website
          and mobile App performance, improve our services, or tailor web
          and landing pages to any identified preferences – please also see
          the Genting Casino Cookies Policy for further information.
        </em>
      </li>
      <li>
        <em>
          Sharing your data with market research agencies for research and
          analysis purposes.
        </em>
      </li>
      <li>
        <em> Sharing your data with credit reference agencies. </em>
      </li>
      <li>
        <em>
          Sharing your data with prospective and actual buyers (and our
          professional advisors) in the event of the proposed sale or
          restructuring of any part of our business. Such disclosures shall
          be subject to adequate contractual obligations of confidentiality
          to ensure the safeguarding of your personal data.
        </em>
      </li>
      <li>
        <em>
          Sharing your data (to the minimum extent necessary) with our
          third-party professional advisers for the purposes of obtaining
          legal, regulatory, accounting, tax, insurance or other
          professional advice where required.
        </em>
      </li>
      <li>
        <em>
          Sharing your data (to the minimum extent necessary) with our
          third-party insurers for the purposes of administering insurance
          related claims and commencing / defending legal claims.
        </em>
      </li>
      <li>
        <em>
          Sharing your data (to the minimum extent necessary) with our third
          party service providers in order to administer and give effect to
          Data Subject Rights – e.g. sharing CCTV images with our third
          party visual / audio redaction specialists in order to redact
          third party personal data / images in connection with a Data
          Subject Access Request.
        </em>
      </li>
    </ul>
    <p>
      We may in some instances have to share your data with third parties
      who provide services to us that are based in countries
      outside of the UK, or permit these third parties to access our systems.
      Whenever we disclose your personal data to these third parties, we will ensure that Chapter V of the UK GDPR is complied with by checking that an adequacy regulation is in place for the destination country, or requiring the third party to enter into appropriate safeguards to support the transfer, such as ICO’s International Data Transfer Agreement / UK Addendum and or conduct a Transfer Risk Assessment. We will also 
      require the third party to have appropriate technical and
      organisational measures to safeguard your personal data.
    </p>
  </td>

</tr></tbody>