This privacy statement details how we use your personal data. Last Updated 17th July 2023.
In This Article:
2. PERSONAL DATA TYPES WE USE
3. HOW AND WHY WE USE YOUR PERSONAL DATA
4. GENERAL PROCESSING INFORMATION
Welcome to the etec Global Ltd Ltd privacy statement.
This privacy statement (“Statement”) is designed for you to easily access the information you need, when you need it.
This Statement applies to our registration website, (our "Service").
We trust that you find this Statement helpful but if you have any concerns or questions please feel free to share feedback via the contact methods listed in the Contact details.
1.1. Introduction to etec Global Ltd
1.1.1. Controller details
References in this document to "us", "our", "we", “etec Global” or “SBG” are references to the following data controllers:
etec Global Limited, is a company registered in England and Wales (14204390 with registered offices located at: 28 Dudley Street, Grimsby, N e Lincolnshire, DN31 2AB United Kingdom.
etec Global Limited is the exclusive representative of New Wave Interactive Ltd, a corporation duly organised and existing under and by virtue of the laws of the Territory of the British Virgin Islands with office at Morgan & Morgan Building, Pasea estate, Road Town, Tortola, British Virgin Islands for the purposes of extending the reach of the licence and licensed network in Europe.
Etec Global is the data controller of personal data processed in relation to the Service.
1.1.2. Contact details, including DPO
If you have any concerns about how etec Global handles your personal data, you can contact our Data Protection Officer (DPO) and Data Protection Team at: firstname.lastname@example.org.
1.2. Privacy and Data Protection at etec
Data protection is all about keeping your personal data safe and secure, and ensuring that your legal rights in relation to your data are respected. Privacy is a fundamental right, and you are entitled to have your personal data protected, used in a fair and legal way, and made available to you when you ask for a copy.
1.2.1. Our commitment
At etec, we take the protection of our customers’ personal data and privacy very seriously, and we never lose sight of the fact that your personal data is YOUR personal data.
We believe in using your personal data to make things simpler and better for you, and we will always keep your personal data safe using the highest standards of security. We’ll be clear and open with you about why we collect your personal data and how we use it, and where you have choices or rights, we’ll explain them to you and respect your wishes.
1.2.2. Our key privacy and data protection principles
To meet these commitments, we employ the following 3 principles at etec. These principles are at the heart of everything we do and ensure that your rights are considered at every step.
1. Keeping your data secure: We are committed to employing best-in-class security measures to protect your information and our technological security solutions are governed by a mature framework.
2. Transparency: Transparency is a key principle of data protection. Our Privacy Statement provides you with everything you need to know about how your information will be used by etec.
3. Giving you the choice: We believe that respecting your privacy begins with giving you a say in how it is used.
1.3. How to navigate and read this document
We have designed this Statement so that you can easily access the information you need. It is split into three parts as follows:
PERSONAL DATA TYPES WE USE explains the different types of personal data that you provide to us when you use our Services, that is generated when you use our Services and that we collect from other sources.
HOW AND WHY WE USE YOUR PERSONAL DATA explains what we use your personal data for. It contains different sections for each type of personal data usage, with each section providing information on the purposes and legal basis for using the data, as well as on any sharing of the data that may occur.
GENERAL PROCESSING INFORMATION contains information about our personal data processing that is relevant to all individuals who engage with our Service.
For information on cookies, please see our our Cookies Policy further in this document.
1.4. Changes to the Statement
It is important to check back often for updates to this Statement. If we make material and important changes, we will let you know by placing a notice and/or contacting you using other methods such as email.
2. PERSONAL DATA TYPES WE USE
We gather and use different types of personal data that you provide to us, that is generated through your use of our Service or is which we have collected from other sources. This data includes your registration information, verification and know your customer documentation, your interactions with our customer operations teams, payment information, financial information, safer gambling information, device, tracking and other online information, profiling and analytical information, as well as information from other sources including public sources and trusted third parties.
2.1. Data provided by you
When using our Services, we collect the following types of information provided by you:
When you register an application with us, you are required to provide us with details including your name, date of birth, postal address, e-mail address, phone number, any other details as might be requested from you for the purpose of registration and/or continued use of our Service.
As a condition to using our Service, we will ask you to share your precise geolocation so we can ensure that we are authorised to provide the Services to you in your location.
Verification and Know Your Customer (‘KYC’) Documentation
In order to verify your identity, you may be required to provide documents such as a copy of your passport or driver’s licence, documentation establishing your address such as utility bills, or any other information we deem necessary to confirm your age and/or identity.
Interactions with Customer Operations
When you interact with our customer operations via live email we will retain a record of your conversations with our staff, as well as notes relating to these interactions and their outcomes.
Payslips or other documents proving your source of wealth including but not limited to proof of earnings, bank statements and evidence of business ownership.
2.2. Data created by using our Services
Some of the personal data we process relating to you is generated by your use of the Service.
Details relating to your device and communication data, including IP address, browser type, unique device identifier, IDFA, hardware model, operating system and version, software, preferred language, serial numbers, device motion information, mobile network information and location data.
Server Logs and Traffic Information
Information such as dates and times of access, the app features or pages you view, app crashes and other system activity, and the third-party site or service you were using immediately before visiting our site.
Cookie and Tracking Information
When you access or use our Service, we may collect information from your devices through the use of 'cookies' and similar technologies.
These technologies can collect a wide variety of information about how you interact with our Service, such as your language preferences, pages visited and content viewed, links and buttons clicked, and URLs visited before and after you use our Services.
For further detail on cookies, please refer to our Cookies Policy. To manage your cookie preferences, please go to our onsite Cookie Management centre (located at the bottom of our websites).
2.3. Data from other sources
Not all the personal data we hold about you will always come directly from you or from your use of our Services. As detailed below, we may also collect information from third parties such as our partners, service providers and publicly available websites (i.e. social media platforms), to comply with our legal and regulatory obligations, offer Services we think may be of interest, to help us maintain data accuracy and to provide and enhance the Service.
Credit Reference Agencies
Data provided by trusted credit reference agencies who may perform a soft check for verification and affordability purposes which do not affect your credit score. A record of the outcome of these checks is provided back to us.
3. HOW AND WHY WE USE YOUR PERSONAL DATA
We only use your personal data where necessary and where it is lawful to do so. Our use of your personal data is needed to enable us to deliver the Service to you, to meet our legal or regulatory obligations, to meet or protect yours, ours, the wider public’s or other third parties’ interests, and sometimes for other reasons only where we have your explicit consent to do so.
Below, we explain how and why we need to use your personal data, providing you with information on our different uses of your personal data. This includes detailed information on the reasons for using your data, the types of personal data we use and also information on the legal basis for using your data, which may include using your personal data:
To enter into or perform a contract with you (‘Performance of a contract’), such as delivering our Service in accordance with the terms and conditions;
To meet our legal or regulatory obligations (‘Legal and regulatory obligations’), such as our taxation, company or data protection law or our licencing obligations;
To meet our own legitimate interests or those of a third party (‘Legitimate interests’), such as where we use data to protect our business assets or information, to improve our Services or to keep you safe while you use our Services;
To perform tasks in the interests of the general public (‘Public interests’), such as safeguarding the public from gambling related harms; or
3.1. Analysing the use of our site by website visitors
3.1.1. Who the section applies to
All visitors to the service.
We use your personal data to provide you with the Service and ensure that our sites and apps are functioning correctly.
We use technical information about your device, operating system and browser version to present you with the correct version of our website or app and to keep it functioning securely. This information is also used to diagnose system problems, improve and test the features and functions of our Services, and carry out testing.
In order to abide by our legal and regulatory requirements, we will also check your location to ensure users are using our Services in licensed countries, and that the correct version of the site is presented to them.
We also perform analysis of the performance and usage of our website to help improve your user experience. For further information on cookies, please refer to our Cookies Policy
3.1.3. Who we share your personal data with
We use a number of tools to assist in performing analytics on our site, such as Adobe.
3.2. Registering & verifying your account
3.2.1. Who the section applies to
All customers that register and submit an application.
When you register an account with us, you are required to provide us with certain information in order to register your application and verify your identity. This allows us to ensure that you are who you claim to be and that you are old enough to use the Services. As part of this process, we rely on trusted third parties to assist us in confirming the details you have provided.
In certain circumstances, you will be required to provide us with a copy of your photographic identification, such as passport or driver’s licence. We may also ask you to provide us with proof of address, such as a copy of a recent utility bill.
Once you provide your identification documentation, we will perform automatic system matching against information entered when opening an account and if the match is confirmed, verification is successful. Where we have been unable to successfully match a customer’s details the application for the service may be temporarily suspended. The process is overseen by our Customer Operations teams. If you have any queries or concerns about the verification process or an account suspension, please get in touch and one of our advisors will be able to assist.
3.2.4. Who we share your personal data with
Document checking – We may use third parties to help in confirming the legitimacy of the documents you have submitted, including Jumio.
Electronic verification – We may use third parties to verify that the details you have submitted are legitimate.
Credit checking – We may use credit reference agencies to verify your details and the amount that you can spend on our Services.
3.3. Processing your payments & delivering the Service.
3.3.1. Who the section applies to
All applicants who successfully register an application for the service.
In order to process your payment we may use information in relation to your chosen payment methods. These details are used where possible, to prevent fraudulent use of your payment methods, and to monitor trends and performance in relation to our payment Services.
If you have concerns in relation to a payment that you have made, we will investigate your query promptly and may use further information in relation to your account to support this investigation. You may be asked to provide further information, and in certain circumstances, we may contact your bank or payment provider to resolve the issue.
In certain circumstances, where we have concerns over payments being made on customer accounts, we may perform additional due diligence to confirm that funds are being sent and received from the true owner of the account. We may examine details in relation to your location, IP address or device to confirm where payments are being made from. We may also require you to submit additional verification documentation to confirm your ownership of the payment method in question.
3.3.4. Who we share your personal data with
Payment providers - Sharing details in order to process your transactions with your registered bank.
Fraud prevention service providers, such as Iovation;
3.4. Contacting Customer Operations
3.4.1. Who the section applies to
This section applies to any person that contacts Customer Operations via email.
From time to time, you may experience issues with the Service, or may have queries about the markets or products we offer.
When you contact our Customer Operations teams via the contact methods we offer, we will use information relating to your account and activity, as well as the information you provide to our staff, to investigate your query and work towards a resolution.
In order to process your query, you may be asked for additional information in relation to the issue you are facing. Any information you provide may be shared internally with other relevant operational teams.
Please note that all interactions you have with our Customer Operations functions are recorded and retained. We use a number of third-party software tools to help deliver our support functions, and information you share with will be processed and/or stored on these tools.
3.5 Anti-Money Laundering and Counter-Terrorist Financing
3.5.1. Who the section applies to
All applicants to the Service.
As a licensing related company we have certain legal obligations we need to abide by. One set of such obligations requires that we do everything we can to prevent money laundering. At etec, and in accordance with the terms and conditions of our Services, we will use your personal data to ensure the proceeds of crime are not being used by individuals using our Service, and to identify and tackle such behaviours.
As outlined in the Registering & verifying your account section above, where you initially register an account with us, we are required to gather certain information about you in order to verify your identity, as part of our EDD requirements. For this purpose you may be required to submit documentation establishing your identity and address, and where required, any other information as may be deemed necessary to confirm your identity.
etec adopts a risk-based approach to compliance with its Anti-Money Laundering obligations, and, depending on your personal characteristics and activity levels, we may be required to gather further information on you, in order to meet requirements under applicable legislation. As part of this EDD process, we may collect and store financial information in relation to you, as well as information gathered from publicly available sources such as the land registry, the register of companies and social media.
In certain circumstances, we may require you to provide additional documents proving your source of wealth including but not limited to proof of earnings, bank statements, payslips and evidence of business ownership. Such processing will always be conducted with due regard to your privacy.
As part of our obligations, we also regularly screen our customer base against databases of publicly available information. This ensures that we are not offering our Services to individuals who have been the subject of sanctions, and allows us to identify individuals who have been the subject of adverse media report, and ‘Politically Exposed Persons’. For this purpose, we may use Finscan, a trusted provider of such databases.
Where suspicious activities, behaviours or characteristics are identified, further investigation will be conducted, and where necessary, actions may be taken in relation to your account. This may result in your account being suspended until such time as further information is provided by you, or your account being permanently closed. We may also be required to inform local law enforcement authorities or government agencies, as mandated by law.
3.5.3. Who we share your personal data with
Providers of databases for screening purposes such as Finscan;
Third-parties who assist with verification and Due Diligence, such as GB Group and Iovation;
3.6. Onsite or In-App Personalisation
3.6.1. Who the section applies to
All users of the service or other assets covered by this Statement.
We use personal data to deliver and suggest tailored content to personalise your experience with our Services. This is processing which is necessary for the purpose of our legitimate interests in delivering or presenting relevant content to our customers.
Whichever Service you use, wherever and however you interact with us, we want to give you the same great level of service and make it personal to you. We will tailor your experience, personalising the layout and content of our sites according to what we know about you.
3.7. Other Purposes
3.7.1. Who the section applies to
All individuals who engage with SBG or use its Services.
In addition to the purposes we described above, there are other circumstances in which we are required to process your personal data, as described below:
Information/Disclosure Requests and Regulatory Submissions
Apart from the functions set out in this Statement, we do not share your personal data with third parties except where we are compelled or permitted by law to do so. These circumstances are rare but may require us to share information in response to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include such authorities outside your country of residence.
Whenever we share personal data, and whatever the circumstances, we will always do so legally and with due regard to your privacy. If we receive a request from law enforcement or other statutory bodies, we do not disclose personal data without a warrant, court order or other legally valid proof of authority.
If ownership of all or part of our business changes or we undergo a reorganisation or restructure, we will transfer your personal data to the new owner or successor company so we or they can continue to provide the Services you have requested.
Financial Reporting and Analysis
In accordance with our obligations under company law and other similar regulations we are required to keep a record of your transactions in order to maintain proper financial records to meet and to ensure all transactions are being performed in accordance with the Terms and Conditions of our Services.
4. GENERAL PROCESSING INFORMATION
This section provides you with some other important information you need to be aware of in relation to how we use your personal data, including information on international transfers of your personal data, how we keep your personal data secure and how long we need to keep your personal data for.
4.1. International transfers
Some of the third-party providers we may use are based in, or carry out their activities in, countries outside the European Economic Area (‘EEA’) and/or outside the UK.
Countries outside the EEA and UK do not always have strong data protection laws. This means that, unless your personal data is being transferred to a country where the European Commission or UK has determined there to be an adequate level of protection, we have to put in place additional protections to ensure that your personal data is protected to the same level as it is within Europe or the UK.
We put these additional protections in place by using standardised contractual clauses that have been approved by the European Commission (for transfers outside the EEA) and the Information Commissioner’s Office (for transfers outside the UK). Where necessary, we also put in place any additional contractual measures required by local law in any of the countries in which we operate. As and when required, we will also put additional technical or organisational measures in place to ensure that your data is kept safe.
4.2. Keeping your personal data secure
We recognise that online security and data protection is an area of vital importance for all our customers, so it is important to us that you have confidence in the security of your personal details before you register for the Service. We are committed to employing security measures to protect your information from access by unauthorised persons and to prevent accidental or unlawful processing, disclosure, destruction, loss, alteration and damage. Our technological security solutions are very advanced and are governed by a mature framework. Our approach is focused on preventing risks. In order to help us in this regard, we employ pseudonymisation and encryption whenever possible to reduce the impact of any potential incidents. As the security of some communications via the internet is not completely secure, we cannot guarantee the security of any information that you disclose using your internet connection. You accept the inherent security implications of using the internet and the Group will accept no liability for any direct, consequential, incidental, indirect, or punitive losses or damages arising out of such an occurrence.
4.3. How long we keep your personal data for
A key principle of data protection is ‘storage limitation’, which means that organisations should only hold onto your personal data for as long as is needed.
At etec, we have taken steps to ensure that we hold your personal data only as long as we have a valid legal basis or reason to do so, which includes providing you with the Service you have requested, meeting our legal and regulatory obligations, resolving disputes and enforcing our agreements.
The length of time for which we keep different types of personal data can vary, depending on why we originally obtained them, the reason we process them and the legal requirements that apply to them. When setting our data retention and deletion timescales we take into account a range of factors including applicable regulations and standards relating to gambling and gaming, anti-money laundering, taxation, payment processing and complaint handling, the need to prevent or detect crime or other misuses of our Services, and audit requirements.
To fulfil our requirements, some of your personal data will need to be retained for a period of time after you cease to be a licensee. When we no longer need it to fulfil the purposes and legal bases set out in this Statement, we delete it securely. Subject to us not having a legal or regulatory requirement or a risk management reason for retaining your information for a longer period, your information will not be kept for longer than 7 years from your last login or expiry of a self-exclusion. This allows us to meet our record-keeping obligations in applicable legislation, as well as allowing us to defend ourselves against potential legal claims.
We will take all necessary steps to ensure that the privacy of information is maintained for the period of retention.