CaptainFreeSpins PRIVACY STATEMENT
INTRODUCTION
This statement sets out how your data is used and processed through your use of this website and service. We respect and value all user privacy and only collect data in ways which are consistent with our obligations and your rights under the law.
This website is owned by EPIC Intent, a company registered in England under company number 13162704 whose registered office is at 2 Manor Farm Court, Old Wolverton Road, Old Wolverton, Milton Keynes, Buckinghamshire, MK12 5NN. EPIC Intent is a wholly-owned subsidiary of SB Media Group Limited.
WHAT DATA DO WE PROCESS
We collect some or all of the following data for processing:
Identity Data This includes your first and last name, social media profile, username, email address and telephone numbers
Transaction Data This includes the details of offers you have signed up to or subscribed to via the third-party links provided on this website
Technical Data This includes your device ID or information, cookie data, browser type and version, device time, operating system, IP address and location and other technology on the devices you use to access the website
Usage Data This includes information about how you use our website, products and services
Non-Personal Data This includes aggregated data such as statistical or demographic data which does not directly or indirectly reveal your identity. This is to analyse and assess website usage
WHY DO WE COLLECT THIS INFORMATION
Under the General Data Protection Regulation (GDPR) we are required to have a lawful basis in the use of the above data. In using our website, we have a legitimate interest and (in some cases) consent, which means your data may be used for one or more of the following purposes:
· To perform our obligations under the contract between us
· To ensure that content from our site and any publications are presented in the most effective manner possible
· To regularly review and update the services on our website in order to provide consumers with the best possible experience
· For internal operations; including troubleshooting, data analysis, testing, research, statistical and survey purposes
· To comply with our contractual or legal obligations to share data by law or governmental order
· To create retargeting strategies
We do not generally rely on consent as a legal basis for processing your data. HOWEVER, in the event that you subscribe to receive offers or other marketing communications from us via email or SMS, we will ensure we have your consent to do so. You have the right to withdraw said consent to marketing at any time by contacting us.
We may use certain personal information to engage in retargeting exercises (i.e. creating custom or lookalike audiences) on social media platforms. This helps us to show relevant promotional material to people who are most likely to be interested in our services.
When we do this, your information is converted into a secure code before being shared with any social media platform – meaning it cannot be used to directly identify you. These secure codes are then used to find people with similar interests.
We do not see any individual social media profiles and social media platforms do not disclose their identity to us.
If you do not want us to use your data for this purpose, please email us at [email protected] and your data will no longer be included in any new audience uploads (please note existing audience lists may take a short time to refresh or be deleted.
HOW DO WE COLLECT THIS INFORMATION
We can use different methods to collect data from and about you including:
Direct Interactions You may give use your identity, contact and financial data by filling in forms or by corresponding with us by post, phone, email or otherwise. This also includes personal data when you:
· Complete our offers form
· Subscribe to marketing communications and/or choose your preferences for email or SMS
· Entry into our prize draws
· Email our support team
· Raise a complaint; or
· Request information be sent to you
Indirect Interactions We may collect other types of data as highlighted above when you interact with our website. This is collected through cookies, server logs and other similar technologies. We can also receive this data if you visit other websites which use our cookies or tracking technologies.
WHO DO WE DISCLOSE YOUR DATA TO?
All parties who process your data are subject to stringent obligations to respect and maintain security and confidentiality and to treat your personal data in accordance with the law. We do not allow our third-party service providers, partners, agents, subsidiaries or employees to use your personal data for their own purpose and only permit them to process personal data for specific purposes and in accordance with our instructions
There are times we may share your personal data with other companies in our group in order to deliver one or more of the reasons for which we collect the personal data (as highlighted above)
Separately to this, we may sometimes need to share your personal data with contracted third parties who assist us in delivering our services. The information we share is restricted only to the personal data that is required for them to fulfil their services to us. These companies can include:
· IT companies who support our website and business systems
· Marketing companies, which enables us to manage our electronic communications
· Contracted partners and affiliates who provide marketing communications containing deals, discounts, free-to-enter competitions as well as; lifestyle, sports and gambling offers
· Customer service providers who manage and coordinate all customer queries, complaints and enquiries on our behalf
· Professional advisers, i.e. auditors, bankers, lawyers and insurers who provide tailored services to us in order to assist with the operation of our business
There are also limited circumstances where we may be legally required to share personal data which could include yours if we are involved in or complying with legal obligations, a court order or the instructions of a government body.
Where your personal data is transferred outside the EEA, we will take further additional technical and organisational steps to ensure your personal data is treated just as safely and securely by those we contract with, as it would be in the UK or EU.
EPIC Intent and SB7 Mobile Ltd are part of the same corporate group. We maintain internal data-sharing arrangements to ensure that prize promotions are properly administered and paid out. These arrangements comply with UK-GDPR and ensure that only the minimum data required is shared for the stated purpose
Third-Party Offers – our website contains contests, special offers or other event links to third-party websites. If you provide your personal data by subscribing to or interacting with that third party’s link, you give them your permission to use it for the purposes of that promotion. CaptainFreeSpins does not control the use of any personal data you have submitted to a third party and accepts no liability or responsibility in your provision of such personal data.
PRIZE DRAW ADMINISTRATION
If you enter one of our prize draws, we will process your personal information to administer the promotion, verify eligibility and contact you if you win. This is to ensure that we can perform our obligations under contract and ensure a fair promotion.
Our prize draw is insured and paid for by SB7 Mobile Ltd. If you win, we will share limited personal data (such as your name, contact details and bank information) with SB7 Mobile so it can verify and pay the prize won under its own cover. SB7 Mobile acts as an independent data controller for this purpose and will process your information in accordance with its own privacy notice which can be found here https://www.sb7mobile.com/privacy.php
SB7 Mobile will not use your data for marketing purposes unless you have separately consented to receive marketing directly from it.
We retain prize-draw entrant data for up to 12 months after the draw closes (to handle winner verification and audit requirements) unless you remain subscribed to our marketing communications
HOW LONG DO WE KEEP YOUR DATA FOR?
Your personal data will never be held for any longer than is necessary to fulfil the purposes that we collected it for. We will always follow the relevant statutory retention limits for personal information where applicable. Where the retention period ends and your data is no longer needed or has been requested to be deleted; your data will be completely deleted or anonymised.
In some instances, we may anonymise your data to ensure that it can no longer be used to associate with you, but can be used in a non-identifiable way for statistical analysis and business planning.
HOW CAN YOU ACCESS YOUR DATA – YOUR DATA SUBJECT RIGHTS
In order to know what personal data we have about you, you can submit a ‘Data Subject Access Request’ which is a formal request for details of that personal data and for a copy of it.
All requests must be made in writing by email or by completing the DSAR form on our website. These can be sent to our Data Protection Lead at [email protected]
We will respond to your request within one month of receiving it and usually aim to provide a complete response, however, in cases where the request is complex, more time (up to three months) from the date we receive your request.
In the event you are not satisfied with our response or believe we are not processing your personal data in accordance with the law, you may make a complaint to the Information Commissioner’s Office (ICO) through their website https://ico.org.uk/make-a-complaint/.
HOW DO WE PROTECT YOUR PERSONAL DATA?
We implement several security measures to ensure the safeguarding of your personal data and use appropriate technical and organisational measures to maintain such protection. This includes, but is not limited to:
· Data encryption between services within our system and provided by third parties
· Firewalls restricting inbound and outbound network traffic
· File encryption on all database servers with restricted file access
Please note that no transmission of information through the Internet or wireless network can be guaranteed to be 100% secure. You, therefore, acknowledge that there are limitations to security and privacy which are beyond our control and cannot be guaranteed.
We have robust and stringent procedures in place to deal with any suspected personal data breach. In the event of a breach, we will notify you and the relevant regulatory where we are legally required to do so.
COOKIES AND SIMILAR TECHNOLOGIES
We use cookies on our website to provide you with the best experience when you browse our website and to improve our site and its contents. In continuing to browse the site, you agree to our use of cookies.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer. Other storage technologies can include web beacons; an often-transparent graphic image that is placed on our website to monitor the behaviour of users visiting our sites or receiving our emails, or pixels; a code placed on our website that triggers a cookie and calls an application on a media-buying platform to download a cookie on your browser if your settings allow it.
You can find out more about cookies and protecting your privacy by visiting www.aboutcookies.org.
In delivering our website, we use the following cookies:
Strictly Necessary Cookies This is required for the operation of our website, i.e to allow users to subscribe to receive offers. These are necessary for the website to function and cannot be switched off in our systems. You may be able to set your browser to block or alert you about these cookies, however, doing so will mean some parts of the website will not work.
Performance Cookies This allows us to recognise and count the number of visitors, how they move around the website and which areas are more popular than others. This helps to improve the way the website works. The information these cookies collect is aggregated and anonymous – without it we do not know when you have visited our website and cannot monitor its performance
Targeting Cookies This records your visit to our website and the links you have interacted with. We use this information to make our website and advertising more tailored to your interests. They do not store personal information but are based on uniquely identifying your browser and internet device
Please note, third parties may also use cookies over which we have no control, i.e. Google Analytics. These are likely to be performance or targeting cookies.
You may avoid the use of cookies by configuring your web browser to either delete or block them, this, however, may affect the quality of your use of the website.
CHANGES TO THIS POLICY
We may update this Privacy Statement from time to time in line with any updates made to our service which expands the sharing or use of your personal data in ways that have not been disclosed to you already. In the event of an update, all changes will be made available via our website.
HOW TO CONTACT US