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GAMBLEWISE APP PRIVACY POLICY

ABOUT GAMBLEWISE
Gamblewise Limited (“Gamblewise”, “we”, “us” or “our”) is committed to protecting and respecting the privacy of the users (“user”, “you” or “your”) of the app that encourages users to gamble responsibly; raises awareness of users’ gambling activities; and allows users to exercise controls over their gambling (“Gamblewise App”). This privacy policy (“Privacy Policy”) provides information on how we collect and use your personal data. Please read this Privacy Policy carefully to understand how we will use your personal data. We are a company registered in England and Wales, with company number: 10475959 and with a registered office located at 232 Cranmer Court Whiteheads Grove, London, England, SW3 3HD. Our ICO registration number is ZA317754 (the Information Commissioner’s Office (“ICO”) is the UK’s data protection regulator) and you can access its ICO notification here. For the purposes of data protection legislation in the UK, we are the controller of personal data.

ABOUT THIS PRIVACY POLICY
This Privacy Policy (together with our Terms of Use for the Gamblewise Mobile App available at Play Store Apple Store and any other documents referred to in it (“Gamblewise App Terms of Use”)) sets out the information that we collect, the reasons for which we collect that information, and how we may use and share that information with third parties. By using our Gamblewise App, you acknowledge the practices described in this Privacy Policy.

PURPOSE OF THE GAMBLEWISE APP
The purpose of the Gamblewise App is to encourage responsible gambling of users by: raising awareness of a user’s gambling activities through their use of the Gamblewise App; enabling the user to exercise controls over its gambling activities in the Gamblewise App by setting Gambling Limits (as defined below in “Gambling Data”), using the Time Tracker (as defined below in “Gambling Data”); and enabling a gambling venue operator (“Operator”) to provide support to users while gambling in the Operator’s gambling venue (for example, by reminding the Operator of a user’s Gambling Limits).

WHAT PERSONAL DATA DO WE COLLECT AND PROCESS?
When you interact with us, whether by using the Gamblewise App or communicating with us, you may provide us with your personal data, and we may collect and process your personal data as a result of your use of the Gamblewise App or your communication with us. We process the following personal data when you use the Gamblewise App: User Account Data: a unique ID assigned to you, your name, email address, phone number and profile picture. Location Data: your device’s Bluetooth signal and your location when entering a gambling venue. Gambling Data: the gambling venues you have visited (including the date, time you entered and exited the gambling venue, and the time spent in the gambling venue). You may set limits within the Gamblewise App and this includes the limits on your visits per week or the time you may spend per visit, days in the month that you do not wish to gamble on and/or days of the week that you do not wish to gamble on (“Gambling Limits”). You may set a timer within the app to record the time you spend in a gambling venue (“Time Tracker”). User Conversation Data: conversations that you may have with an Operator Employee.

WHAT DO WE USE YOUR PERSONAL DATA FOR?
In order for us to provide the Gamblewise App to you, we may process your personal data for one or more of the following purposes, which will include sharing your personal data with the Operators and other third parties (please refer to Section 6 below for further details): To provide you with access to the features of the Gamblewise App: in order for you to use the Gamblewise App, you need to register an account by providing User Account Data. We will need to 2 process your User Account Data to set up your account and communicate with you should we need to. We process your User Account Data to send an email to you to confirm that you wish to register your account with Gamblewise. You will have access to the features of Gamblewise App once you have confirmed your account. We rely on your consent to process your User Account Data in order to set up your account and provide you with access to the features of the Gamblewise App. To administer your account and allow you to use the features of the Gamblewise App: to enable you to continue using the Gamblewise App we continue to process your User Account Data; we rely on your consent to do this. You may also set Gambling Limits and use the Time Tracker feature Maintaining records of users in respect of their Gambling Limits (including reminders of and breaches of your Gambling Limits) and Time Tracker: if you choose to set Gambling Limits or use the Time Tracker feature in the Gamblewise App, we will process your Gambling Limits and Time Tracker data within our database. We will maintain records of your Gambling Data along with your User Account Data for the purposes of identifying the Gambling Limits and Time Tracker data that you have set or that is associated with your use of the Gamblewise App. To notify you if you have entered a gambling venue: if you choose to turn on the location notification feature, we will process your User Account Data and Location Data in order to be able to notify you, by SMS message or from the Gamblewise App, that you have entered a gambling venue. We process your User Account Data and Location Data for the performance of the contract we have with you to provide you with the services in the Gamblewise App. To notify an Operator that you have entered a gambling venue: we process your User Account Data and Location Data in order to be able to notify the Operator that you have entered its gambling venue and to allow the Operator to recognise you when you are in its gambling venue (by name and by sight). We rely on your consent to process your User Account Data and Location Data to enable the Operator to oversee those engaging in gambling activities in its gambling venue. To provide notifications to you in respect of your Gambling Limits (including reminders of and breaches of your Gambling Limits): you may set Gambling Limits in the Gamblewise App. If you do, we will process your User Account Data and Gambling Data for the purposes of monitoring if you are in breach of your Gambling Limits. In the event that you breach your Gambling Limits we will process your User Account Data and Gambling Data in order to provide a notification to you. The notification to you will be in the form of an SMS message or in-app notification. We process your User Account Data and Gambling Data for the performance of the contract we have with you to provide you with notifications in respect of your Gambling Limits. To enable an Operator to monitor interactions with individuals in its venue: an Operator’s Employee may approach you to discuss your Gambling Limits while you are in a gambling venue. If this happens, the Operator Employee will record notes of the conversations he or she has with you. These notes will be entered into the Operator’s app, and stored by Gamblewise, which requires us to process your User Account Data and User Conversation Data for the purposes of recording such conversations in our database and making such conversations available to the Operator. We rely on your consent to process your User Account Data and User Conversation Data. To fulfil our legal and regulatory obligations: if required we may be required to process your personal data for the purposes of complying with a legal or regulatory request. If we do, we will do so in accordance with Section 6 (Who do we share your personal data with?). To prepare and share statistical reports about the use of the Gamblewise App: we may aggregate and anonymise your personal data with personal data of other users of the Gamblewise App, creating a dataset of information about the usage of the Gamblewise App, and other general, grouped information about users of the Gamblewise App (for example, average breach limits and numbers of users that stay within their limits), for the purposes of understanding user behaviour to be able to identify trends in user gambling activity. We may use such statistical reports for our internal purposes and share such statistical reports with Operators. When your personal data is aggregated or anonymised, you cannot be identified and it is no longer personal data. If this changes, and you can be identified from an aggregated or anonymised dataset, we will process your personal data in accordance with this Privacy Policy. We do not sell your personal data to any third party without your consent or agreement. WHO DO WE SHARE YOUR PERSONAL DATA WITH? If you use the Gamblewise App, we may share your personal data with third parties in limited circumstances and for one or more of the following purposes: Third parties supporting the Gamblewise App: we rely on a limited number of third parties to support the Gamblewise App, including our database storage provider and cloud hosting provider. We also rely on your SMS mobile operator in order to be able to provide SMS message notifications should you 3 choose to turn these on within the Gamblewise App. Without these third parties, we could not provide the Gamblewise App to you. Third party messaging services: we rely on third party messaging services in order to be able to send in-app notifications to you and/or SMS messages (as we have described in Section 5 above). We may also send other supportive messages and messages of encouragement to users who stay within their limits. Operators where you choose to gamble: we share your personal data with those Operators that own and/or run the gambling venues that you have entered. The purposes that we share your personal data with these Operators are set out above in Section 5 (What do we use your personal data for?). We do not share your personal data with Operators of gambling venues that you have not entered. To comply with legal or regulatory requests: on occasion we may be required to liaise with various regulators and law enforcement agencies, whether as a result of law, a court order, or another legal process. Although we dispute requests if it is appropriate to do so, in some cases we may have to share your personal data with regulators or law enforcement agencies. Where we consider it appropriate, and provided we are not prohibited from doing so by law or court order, we will attempt to notify you of these legal or regulatory demands. TRANSFERS OF YOUR PERSONAL DATA We will not transfer your personal data outside of the EU. If there are circumstances which would require us to transfer your personal data outside of the EU, we will seek your consent to transfer your personal data outside of the EU. In the event of such a transfer, where applicable, we will put appropriate safeguards in place to cover transfers of your personal data including, for example, signing standard contractual clauses/data protection clauses adopted by the European Commission, or where applicable, relying on a Privacy Shield certification where the transfer contains a US entity. Please click here for a link to the standard contractual/data protection clauses and click here for more information about the Privacy Shield for US companies. If you would like further information, please contact us at [email protected] DATA RETENTION We will only retain your personal data for as long as is necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal or regulatory requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. We retain your personal data as follows: You will receive an email confirming your request to register an account on the Gamblewise App. If you do not consent to us processing your personal as described in this email, we will no longer continue to process your personal data and your personal data will be deleted from our database within 7 days of your receipt of this email. If you request us to delete your account, we will delete your personal data when we review account deletions on a monthly rolling basis (which includes your User Account Data, Location Data and User Conversation Data). If your account remains inactive for a period of [X months/years], we will delete your personal data when we review account deletions on a monthly rolling basis (which includes your User Account Data, Location Data and User Conversation Data). We retain your Gambling Data (in a form that can identify you) for a year after we have deleted your account. After this time, we anonymise and/or aggregate your Gambling Data with other users Gambling Data and retain this anonymised and/or aggregate data set for [indefinitely period of time] for future use by us for the purposes of improving the Gamblewise App as discussed in more detail above. You may request deletion of the personal data we hold about you by contacting us via email at [email protected] ACCESSING YOUR INFORMATION AND YOUR RIGHTS As a result of us collecting and processing your personal data, you have the following legal rights: to access personal data held about you; 4 to request us to make any changes to your personal data if it is inaccurate or incomplete; to request your personal data is erased where we do not have a compelling reason to continue to process such data in certain circumstances; to receive your personal data provided to us as a data controller in a structured, commonly used and machine- readable format where our processing of the data is based on: (i) your consent; (ii) our necessity for performance of a contract to which you are a party to; or (iii) steps taken at your request prior to entering into a contract with us and the processing is carried out by automated means; to object to, or restrict, our processing of your personal data in certain circumstances; if we use your personal data for direct marketing, you can ask us to stop and we will comply with your request; if we use your personal data on the basis of having a legitimate interest, you can object to our use of it for those purposes, giving an explanation of your particular situation, and we will consider your objection; to object to, and not be subject to a decision which is based solely on, automated processing (including profiling), which produces legal effects or could significantly affect you; and to lodge a complaint with a data protection supervisory body, which in the UK is the ICO. To exercise any of your rights set out above, including to withdraw your consent where we have stated we are processing your personal data based on your consent, please contact us at [email protected] and: let us have enough information to identify you [(e.g. name and email address)]; let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and let us know the information to which your request relates. If you would like to unsubscribe from any marketing communication you can also click on the ‘unsubscribe’ button at the bottom of the marketing communication. It may take up to 7 days before you are removed from our marketing database. CONTACT US If you have any questions or concerns about this Privacy Policy or our processing of your personal data, please email us at [email protected] UPDATES TO THIS POLICY This Privacy Policy was last updated on 24.05.2018 . If you require a copy of a previous version of this Privacy Policy please contact us. Any changes we may make to this Privacy Policy in the future will be posted on this page and, where required or appropriate, notified to you by email. Please check back regularly to keep informed of updates or changes to this Privacy Policy.Double Click to Edit