PRIVACY POLICY
Welcome to our privacy policy!
This privacy policy is dated 9th October 2024. To navigate through our privacy policy just click on the links below.
Virgin Games respects your privacy and is committed to protecting your Personal Data when you use our website (www.virgingames.com) including any mobile or device specific version of the website and any related applications (or “apps”) (together the “Website”). We are committed to processing your Personal Data responsibly and in compliance with applicable data protection laws where we operate our Website. In this respect, we have invested into our practices and have been awarded the ISO 27001 (Information Security Management System) certification. This certifications is an internationally recognised standard which provides a framework to allow us to demonstrate our compliance with data protection laws (including the General Data Protection Regulation) and security standards when processing your personal data.
This privacy policy sets out how we collect, use and look after your Personal Data when you access our Website and tells you about your privacy rights.
We know no one likes to read a lengthy document, so we have tried to make your life easier by structuring our privacy policy with different sections, which give you an overview of the entire policy and let you choose the sections you want to read in more detail. We have also added a Glossary at the end of this document to give you more information about the specific terms we use in it.
We have tried our best to make this Privacy Policy as clear as possible but if you have any questions, please feel free to contact our data protection officer.
Information about our Website
Our Website is operated by Gamesys Operations Limited (“GOL”) which is a Controller in respect of your Personal Data as it relates to your use of the Website.
This Privacy Policy explains how GOL handles your Personal Data and references in this document to “we”, “us” or “our” are references to GOL only.
Controller contact details:
Gamesys Operations Limited:
Gamesys Operations Limited is registered as a controller in Gibraltar under number DP009734 and its registered address is:
Gamesys Operations Limited
Suite 2 Floor 4 Waterport Place
Gibraltar
Gamesys Operations Limited is part of a group of companies (the “Gamesys Group”) owned by Gamesys Group Limited. The Gamesys Group has appointed a data protection officer (“DPO”). If you have any questions about this privacy policy and want to know more about how we handle your Personal Data when you use our Website, please contact the Gamesys Group DPO:
By mail to:
The Data Protection Officer
Gamesys
70 Berners Street,
London,
W1T 3NL (UK)
By email to:
If you want to know how to contact us to exercise your legal rights in respect of the information we hold about you, please see section 11 “Your Rights” below.
When you use our Website, we may collect Personal Data about you. We have set out below what data we collect and how we collect it.
You are under no obligation to provide Personal Data to us. However, certain Personal Data is essential for the provision of and the quality of the products and services we offer (for example, enabling you to set up your Member Account or to play the games on our Website) and you might not be able to obtain certain services if you do not provide the information required for those services. In addition, we need certain Personal Data to fulfil our legal and regulatory obligations (including anti-money laundering requirements, responsible gaming requirements and the requirements of the Gambling Commission in the UK and the Gibraltar Gambling Commissioner to which we are subject as a gambling operator). We are subject to the terms of the Licence Conditions and Codes of Practice (“LCCP”) both in the UK and the Remote Technical and Operating Standards (“RTOS”) for the Gambling Commission in Gibraltar which require us to carry out age and identity verification before you can access our Website to play our games (including free-to-play games). If you refuse to provide your Personal Data where law or regulation requires us to collect it from you, we cannot allow you to access our Website.
When you use our Website, we collect the following kinds of information from you:
Member Account: | We collect the following information from you when you use our Website and register your Member Account: your name, surname, username, password, security question, date of birth, home address, email address, phone number, mobile number, credit/debit card, payment method information and we will allocate you a unique member ID. |
Payment Data: | Once you register your Member Account and use our Website, we collect information about your transactions, including your deposits, your withdrawals and your payment methods used. |
Gaming Data: | When you use our Website, we collect information about your gaming activities. |
Identity, anti Money Laundering and Affordability Checks: | We sometimes ask for additional information direct from you for the purposes of identity, anti-money laundering and affordability or credit reference checks. This may include evidence of ability to pay. More information about Department of Trust can be found here. You have the option to use TransUnion’s open banking service to make it easier to provide us with information from your bank account. You can choose alternative options if preferred. More information about TransUnion and its privacy policy can be found here. |
Chat conversations: | We collect information about your communications via our Website, including in our chat, video chat and messaging facilities (including the content of any messages you send or post). |
Telephone conversations: | We collect information about your telephone conversations with our customer and operational support staff. We record all telephone conversations (e.g. customer support calls, responsible gaming calls, fraud monitoring calls and regulatory anti-money laundering and verification calls, etc.) for training and monitoring purposes. |
Email communications: | We collect and store all copies of emails you send to us and our replies to your emails. |
Social Media Profile: | We collect your social media profile details including your name, profile photo and other information you choose to make available to us when you connect with or contact us through your social media account or use our products and services through your social media account. |
Profile Data: | We collect information about you based on our profiling activity which may include any Personal Data we hold about you. Profile Data enables us to comply with our legal and regulatory obligations, risk analysis and to offer tailored products and services. |
Usage Data: | We collect information about how you use the Website, pages visited, and content viewed, links and buttons clicked. |
Marketing Data: | We collect information in relation to your responses to marketing activities (e.g. marketing campaigns, competitions, offers, etc.) (e.g. information about when you open our email communications). |
Social Events (we host): | Videos and photos of you, health data (e.g. food allergies, physical disabilities), photo ID, attendance sheets and contact details. |
We use these terms throughout this document where we describe how these types of data are used.
We collect the following information from your device when you connect to our Website: information about your device’s hardware and software, use of the Website, traffic information, IP address, time of access, date of access, web page(s) visited, language(s) used, software crash reports, device information including the unique device identifier.
We collect information using cookies to protect our Website, offer you a personalised experience with us, tailor our marketing services and improve our Website. For more information about the cookies we use and how to manage your cookie preferences please see our Cookie Policy.
In order to operate our Website, we collect information about you from third party service providers for various reasons such as making sure our Website is safe, to offer a good level of service and also to comply with our legal and regulatory obligations as per the requirements of the Gambling Commission in the UK and the Gibraltar Gambling Commissioner. We collect information about you from the following categories of third party service providers:
Identity Verification Service Providers: | We collect information about you from third party service providers to verify your personal identification details and other information about you when you use our Website in order to comply with our legal and regulatory obligations. |
Gamstop | We receive information about you when you decide to register with “Gamstop”, the national online self-exclusion scheme in the UK. More information about Gamstop can be found here. |
Advertising Services Providers | We collect information about you from our network of advertising service providers who advertise our Website to understand our audience’s behaviour. |
Hosting providers | We collect information about you from our hosting service providers which host our Website. |
Analytical providers | We collect information about you from our network of analytical providers who provide us tools to understand our audience and improve our Website. |
Fraud and anti- Money Laundering | We collect information about you from third party service providers to ensure compliance with the requirements of the Gambling Commission in the UK and the Gibraltar Gambling Commissioner in relation to combatting fraud and money laundering on our Website which includes services such as transaction screening with payment processors, banks and access of third parties’ crime prevention databases and safe payment processing. This includes an option for you to use TransUnion’s open banking service to make it easier to provide us with information from your bank account. You can choose alternative options if preferred. More information about TransUnion and its privacy policy can be found here. |
Credit reference | We collect credit reference data about you from our third-party credit reference agency, Department of Trust, to ensure compliance with our licensing condition and related legal obligations in relation to conducting affordability assessments on you with the aim to minimise the risk of you experiencing harms associated with gambling. Such processing may impact credit limits applied to your account. More information about Department of Trust can be found here. You have the option to use TransUnion’s open banking service to make it easier to provide us with information from your bank account. You can choose alternative options if preferred. More information about TransUnion and its privacy policy can be found here. Credit reference data may include information about your financial status and insolvency related information (hereinafter ‘Credit Reference Data’). |
We will use Personal Data obtained from these third parties in accordance with this Privacy Policy.
In order to comply with our legal and regulatory obligations (including in respect of anti-money laundering and responsible gaming) and to protect our Website from abuse and fraud, we may look at other information from publicly available resources. Our searches may include collecting information about you from the following sources: social media platforms (e.g. Facebook, LinkedIn), the electoral roll, public databases (e.g. telephone directories), internet search engines (e.g. Zoopla, Google, PayScale) the insolvency registry, companies house register and the UK land registry.
These checks allow us to gather information to make an informed decision and understand if the money transacted through our Website is legitimate to comply with our legal and regulatory obligations and to protect our Website from fraud and abuse.
We collect information about you when you contact us through your account on a social media platform such as Facebook, Twitter, etc for various purposes (such as to enter a competition, contact us for information).
We also collect information about you if you chose to interact with our content and pages available on a social media platform. When you do this, the provider of the social media platform may provide us with your details such as your account information. You should read the relevant social media platform’s privacy policy and terms and conditions to understand how you share your information when using their services.
We collect Special Categories of Personal Data and information about criminal convictions and offences in specific circumstances to comply with our legal and regulatory obligations (including anti-money laundering requirements, responsible gaming requirements and the requirements of the Gambling Commission in the UK and the Gibraltar Gambling Commissioner Licence Conditions and Codes of Practice to which we are subject as a gambling operator):
- To verify your identity and satisfy our legal and regulatory obligations;
- To understand your gaming behaviour to ensure you gamble responsibly as per our Responsible Gaming Policy;
- To provide you with the most appropriate tools to enable you to self-exclude from our Website if you need to;
- To understand patterns and behaviours to ensure we can detect any unusual activities in connection with your use of our Website; and
- If you attend our social events or receive gifts from us we may collect special category data you provide us. Examples of special category data we may collect include any relevant:
• Dietary requirements
• Health or medical conditions (including allergies).
We will collect Special Categories of Personal Data as required by the Licence Conditions and Codes of Practice, the Gibraltar Gambling Commissioner Licence Conditions, the Anti-Money Laundering Regulations and the Proceeds of Crime Act and otherwise to fulfil our legal and regulatory obligations as a gambling operator, or for the establishment, exercise or defence of legal claims or where we have your explicit consent.
We will only use your Personal Data as permitted by law. Most commonly, we will use your Personal Data in the following circumstances:
- To perform the contract we are about to enter into or have entered into with you.
- For our legitimate interests (or those of a third party), provided that your interests and fundamental rights do not override those legitimate interests.
- Where we need to comply with a legal or regulatory obligation.
- Where you have consented to our use of your Personal Data.
Click here to find out more about the types of lawful basis that we will rely on to process your Personal Data.
We have set out below, a description of all the ways we may use your Personal Data, and which legal basis we rely on to do so. We have also identified what our legitimate interests are where appropriate.
We may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your information. Please contact our DPO (see section 2) if you need details about the specific legal ground we are relying on to process your Personal Information.
Purpose | Type of Data | Lawful basis for processing |
To register you as a new user on our Website. | Identity and contact details (Member Account details) | Entering into and performing a contract with you. |
To manage our relationship with you as a user of the Website which includes notifying you about changes to our Website and the products and services we offer, terms and conditions or privacy policy. For this purpose, you will receive service communications. | Identity and contact details Member account details |
Entering into and performing a contract with you. To comply with our legal obligations. As necessary for our legitimate interest (to keep our records updated and to study how customers use our products and services). |
For you to provide, and us to receive, feedback and reviews of our products and services. | Identity and contact details Profile Data Information and opinions provided by you in connection with feedback and surveys |
Entering into and performing a contract with you. As necessary for our legitimate interests (to study how customers use our products and services and to understand the improvements that can be made to our products and services). Your participation in this is entirely voluntary. |
To enable you to participate in competitions and promotions and provide you rewards, such as prizes, gifts and invitations to events. To run our Loyalty and Plus schemes including player relationships, prizes, offers and enhanced Support services. |
Identity and contact details Profile Data Device Data Gaming Data |
Entering into and performing a contract with you. As necessary for our Legitimate Interests (to provide you with a personalised experience and improve our Website). When you give consent to us. |
To provide various supporting customer services to you (such as where you contact us with a question in connection with our Website and/or request certain information from us). | Identity and contact details Profile Data
|
As necessary for our legitimate interests (to deal with customer service requests and respond to communications). If you do not provide us with the Personal Data we request from you for customer services purposes, we may not be able to fully answer your queries. |
To administer and protect our business and our Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). | Identity and contact details Usage Data Device Data Gaming Data Payment Data |
As necessary for our legitimate interests (to run our business, administration and IT services, network security, to prevent fraud or abuse and in the context of a business reorganisation or corporate restructuring exercise). As necessary to comply with a legal obligation. |
To improve our Website, products/services, performance, customer relationships and experiences. | Usage Data Profile Data Device Data Gaming Data Payment Data |
As necessary for our legitimate interests (to define categories of customers for our games and services, to keep our Website updated and relevant, to develop our business and to inform our marketing strategy) and for the legitimate interest of third parties providing games and services to us. |
To comply with our legal and regulatory obligations as a gambling operator (e.g. verifying our Members’ identity and age to ensure they can use our Website, spotting bonus abuses and conducting affordability assessments where we are required to do so) and to protect our Members (e.g. spotting responsible gaming problems). | Identity and contact details Device Data Profile Data Special Categories of Personal Data (e.g. health data) Gaming Data Payment Data Usage Data Credit Reference Data |
As necessary for our legitimate interests (to run our business, to prevent fraud and illegal activities on our Website). As necessary to comply with our legal obligations and licencing conditions. To protect public interest. |
To send you marketing communications. | Identity and contact details Member Account details Device Data Payment Data Gaming Data Profile Data |
As necessary for our legitimate interests (to provide you with personalised experience and improve our Website). When you give consent to us. |
To process your gaming on our Website, including managing payment, deposits and withdrawals into your Member Account. | Identity and contact details Payment data Gaming Data |
Entering into and performing a contract with you. To comply with our legal obligations. |
To deliver relevant content and advertisements to you and measure/understand the effectiveness of the advertising we serve to you. | Identity and contact details Marketing and communications data Usage Data Profile Data Payment Data Device Data |
As necessary for our legitimate interests (to study how Members use our Website and to grow our business and to inform our marketing strategy). |
To use data analytics to improve our Website, marketing, customer relationships and experiences. | Member Account Gaming Data Usage Data Profile Data Marketing Data Device Data |
As necessary for our legitimate interests (to define categories of members for our products and services, to keep our Website updated and relevant, to develop our business and to inform our marketing strategy). |
To make suggestions and recommendations to you about our products and services that may be of interest to you. | Identity and contact details Usage Data Social Media Profile Profile Data Gaming Data Payment Data |
As necessary for our legitimate interests (to develop our Website and grow our business). |
To protect our business from fraud, money laundering and other illegal activities. | Identity and contact details Usage Data Social Media Profile Profile Data Device Data Gaming Data Payment Data Criminal Data |
As necessary for our legitimate interests (to protect our business from any illegal or abusive use of our Website). To comply with our legal obligations. The establishment, exercise or defence of a legal claim (including in connection with an investigation or enquiry by a competent regulatory authority). To protect public interest. |
To protect our Members from irresponsible gambling and comply with our responsible gaming policies. | Identity and contact details Usage Data Social Media Profile Profile Data Device Data Special Categories of Personal Data (e.g. health data) Gaming Data Payment Data |
As necessary for our legitimate interests (to protect our Members from irresponsible gambling). To comply with our legal obligations. The establishment, exercise or defence of a legal claim (including in connection with an investigation or enquiry by a competent regulatory authority). To protect public interests (such as to prevent irresponsible gambling). |
To enable our Members to self-exclude from our Website. | Identity and contact details Usage Data Social Media Profile Profile Data Device Data Special Categories of Personal Data (e.g. health data) |
Entering into and performing a contract with you. To comply with our legal obligations. The establishment, exercise or defence of a legal claim (including in connection with an investigation or enquiry by a competent regulatory authority). To protect public interests (such as to prevent irresponsible gambling). |
To ensure we meet your dietary and health requirements when you attend our social events. To offer you gifts. |
Special Categories of Personal Data (e.g. Dietary requirements - this could include religious dietary requirements) Health or medical conditions (including allergies and physical disabilities). |
When you give us explicit consent. |
This section of our privacy policy explains how you will be contacted for marketing purposes.
How to manage the marketing messages you receive:
You can tell us whether or not you wish to be contacted for marketing purposes and, if so, how we can contact you.
Marketing communications may contain details about:
- New games, jackpots, promotions, competitions and offers available to you on the Website;
- The loyalty programme (e.g. Plus), your rewards and promotional pay-outs on the Website;
- Other promotional information about the Website; and
- Marketing information about other great gambling brands of the Gamesys Group.
You can choose to opt-in to receive marketing communications from us about the Website via the following channels:
- Email marketing: when you opt-in to receive marketing communications by email;
- SMS marketing: when you opt-in to receive marketing communications by SMS;
- Call Marketing: when you opt-in to receive marketing communications by telephone; and
- Push notifications: when you have installed the app on your device and enable push notifications in your device settings.
Additionally, you may receive marketing communications by post from us about the Website when you provide your contact details and have not opted-out from receiving marketing communications by post.
You can opt-out from receiving marketing communications from us at any time by following the instructions below:
- Email marketing: to opt-out from emails, use the unsubscribe link provided within any email you receive or manage your preferences in My Account;
- SMS Marketing: to opt-out from SMS, you can use the STOP code provided in any SMS you receive or manage your preferences in My Account;
- Call Marketing: to opt-out from being contacted by telephone for marketing purposes, you can manage your preferences in My Account;
- Post Marketing: to opt-out from receiving marketing by post, you can manage your preferences in My Account; and
- Push notifications: to opt-out from receiving push notifications, you can disable push notifications in your device settings.
If you choose to opt-out from email, SMS or phone marketing, you will stop receiving marketing communications within 96 hours. Please note that you will only be opted out of marketing communication, however you will still receive service messages.
When you choose to opt-out from receiving post marketing, please be aware it may take up to 28 days for your request to take effect.
Marketing communications about the other great gaming websites of the Gamesys Group.
Virgin Games is a brand owned by GOL, part of a group of companies headed by Gamesys Group that also owns other fantastic brands. If you don’t want to miss out on great offers, prizes and news about other current and future brands, you can manage your permissions in My Account to receive marketing communications about our other brands. To the extent any companies within the Gamesys Group are engaged by GOL to process your Personal Data on GOL’s behalf, GOL will ensure that this company complies strictly with GOL’s instructions regarding such processing.
If GOL ceases to operate Virgin Games, you will receive great offers, prizes and news about other brands operated by GOL. Unless you register directly with these other gaming websites, they will not be able to send you marketing messages directly, and GOL will remain in control of whether marketing messages are sent to you.
You can always change your contact preferences later in My Account.
Social Media Marketing: We may also use information you provide to us to show you relevant advertising and personalised content about us on certain third party social media platforms made available to us through those services (e.g. Facebook, Twitter). We do not control the way these platforms operate and collect your information and you should read their respective privacy policies online to understand how they use your personal information.
About Facebook Ads: If you are a Facebook user, we may periodically use the Facebook Ads services (including Custom Audiences and Facebook Pixels, click here for more information) to provide you with personalised content about us. When you are logged into your Facebook account, we may provide you with personalised content. To provide this personalised content, Facebook may be sharing information with us that you have chosen to make available pursuant to your Facebook settings, such as your profile information and information collected through the “like button”). You can read more information about how Facebook uses your information in their privacy policy. We may also show you personalised and targeted advertisements on the news feed of your Facebook account. If you no longer want to receive personalised and targeted advertisements from us on Facebook, you can manage your advertising preferences and decide what you want or do not want to see by using the settings in your Facebook account. You can read more details about how to manage your ad preferences on Facebook here.
Alternatively, you can also opt-out from receiving personalised advertisements on social media platforms in My Account.
Marketing communications from Third Parties: You will only receive marketing communications from Third Parties if you have agreed to this and if you have opted-in. On our Website, you may be invited to opt-in to receive marketing communications about products, competitions, prizes and offers from our selected partners and third-party services (“Third Parties”). If you decide to opt-in, your information will be passed to these Third Parties and treated in accordance with their own privacy policies as available on their sites from time to time. We do not control the use of your personal information by these Third Parties and you should contact them directly if you want to opt-out from receiving their marketing communications.
We may share your information with the following categories of third parties, who may be Controllers or Processors in respect of your Personal Data, for the purposes explained in section 5.
Your Personal Data will be disclosed to companies within the Gamesys Group in accordance with applicable Data Protection Laws and the terms of this privacy policy, for the purposes set out in section 5 above (e.g. to set up your Member Account, to provide you with customer support services, to manage any risks to our Website and to our business, to comply with any applicable legal and regulatory obligations, to send you marketing communications, and to prevent irresponsible gaming).
We use service providers in connection with the operation of our Website to ensure we deliver the best possible services. We enter into contracts with our service providers and ensure they take good care of your Personal Data we share with them for that purpose. We are committed to protecting your Personal Data and we oblige our service providers to handle your Personal Data in accordance with applicable Data Protection Laws and the terms of this Privacy Policy.
We engage service providers for the following services:
- Hosting our Website: we use hosting providers such as Gibtelecom (Republic of Ireland), Interxion (UK) and BMIT (Malta);
- Marketing services such as segmentation, analytics, email messaging services and SMS marketing service providers: we use providers such as Adobe and Braze;
- IT services and security services: we use services such as Neustar, Akamai and Digicert
- Customer support software service providers: we use providers such as Zendesk;
- Data storage services: we use providers such as Google Cloud Platform and Amazon Web Services;
- Payment service providers: we use service providers such as Worldpay;
- KYC, Anti-fraud, credit reference and money laundering services: we use service providers to verify details about our Members ;
- Click fraud detection and protection service providers: we use certain providers to protect our business from any illegal or abusive use of our Website.
- Data matching services: we use certain service providers offering data matching services to ensure the accuracy of information we receive about you when you decide to register with Gamstop (as described in section 3 above);
- Games providers: we use certain third parties to provide games content and services for our operations.
- Data analytics services to measure and understand our audience, tailor our marketing services, improve your website experience and data cleansing services to suppress our marketing lists; and
- Audit, legal and compliance services.
As a gambling operator, we are subject to strict legal and regulatory obligations to ensure you can use our Website. Because of this, we will share your Personal Data with third party service providers (such as credit reference agencies, fraud prevention agencies, payment service providers, banks, financial institutions and similar third parties) for checking your identity, monitoring your behaviour on our Website, combatting money laundering, protecting our Website against any illegal use, for conducting affordability checks (where we are required to do so) and any other activity we consider necessary to meet our obligations.
Two of such third party identity verification, credit reference and fraud-prevention agencies are TransUnion and Department of Trust. This credit reference agency, in conjunction with the relevant data protection regulators and the financial industry services, have developed a common form of notice called the TransUnion Bureau Privacy Notice. You can read about how TransUnion process your personal data by visiting their Privacy Centre and reading their Privacy Notice, as well as read more about Department of Trust here.
From time to time, we also use another third-party identity verification and fraud-prevention agency called GB Group. You can read how GB Group process your personal data here.
We enter into contracts with these service providers to comply with our legal and regulatory duties. In addition, these specific kinds of service providers are also “controllers” under data protection laws as they own their own databases that may include personal information about you. Because of that, when we share your details with them, your Personal Data and privacy rights are protected as these service providers are also subject to data protection laws.
When you set up your Member Account with us, we will proceed to verify your identity and age as required by the Licence Conditions and Codes of Practice to which we are subject as a gambling operator. If we are unable to verify these details, we may proceed to manual verifications to comply with our obligations. In that case, we may contact you and ask you to supply further proof of your identity and we cannot give you access to our Website until you prove your identity to us.
We will share your Personal Data (including Special Categories of Personal Data) when it is required by applicable law in the following cases:
- To comply with a request for information from a governmental body such as law enforcement (police) or other public authorities (e.g., Insolvency Service);
- To comply with a court order to disclose your Personal Data; and/or
- To comply with a regulatory investigation from a relevant gambling authority (e.g. the Gambling Commission in the UK or the Gibraltar Gambling Commission or a relevant data protection authority (e.g. the Information Commissioner’s Office in the UK).
- The establishment, exercise or defence of a legal claim (including in connection with an investigation or enquiry by a competent regulatory authority).
The Gamesys Group may transfer all your Personal Information to a third party if the operator of the Website changes, or if there is a sale of all or any part of its business or its assets. In the event of any of these transfers occurring, the party who acquires the data will assume the rights and obligations described in this Privacy Policy.
Until 26th September 2019, Virgin Bet Limited formed part of the Gamesys Group. Virgin Bet Limited is the operator of the virginbet.com website (“VirginBet”). If you registered on a Gamesys website or on VirginBet before this date, certain elements of your Personal Data (which may include Special Categories of Personal Data) are shared between the Gamesys Group and Virgin Bet Limited. The Gamesys Group may share your Personal Data (which may include Special Categories of Personal Data as listed in section 4) with Virgin Bet Limited for the following purposes:
- To comply with its policies and procedures for anti-money laundering.
- To comply with its procedures to prevent irresponsible gambling and/or to protect social responsibility (including to continue to comply with the terms of any self-exclusion agreement you may have entered into with the Gamesys Group).
- To comply with applicable laws and regulatory requirements.
- For the establishment, exercise or defence of a legal claim (including as part of a regulatory investigation or enquiry).
- To protect public interests.
Where we receive information about you from VirginBet Limited in connection with the purposes listed above, the Gamesys Group will act as a Controller and will handle your Personal Data in accordance with applicable Data Protection Laws and the terms of its privacy policy. Where the Gamesys Group shares information about you with VirginBet Limited in connection with the purposes listed above, VirginBet Limited will act as a Controller and will handle your Personal Data in accordance with applicable Data Protection Laws and the terms of its privacy policy.
We may further provide Anonymised Data to gambling addiction prevention organisations such as GAMSTOP, third party organisation working with GAMSTOP or academic institutions to allow them to conduct research into problem gambling and inform our business practices and better protect vulnerable people.
What we do to keep your Personal Data safe:
We have appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Where appropriate, we employ encryption, pseudonymisation (for example, by using your member ID rather than full name where appropriate) and anonymisation solutions to reduce the impact of any security incident to Personal Data. Although, the nature of the internet means that transmission of information may not be totally secured, we have deployed end to end encryption security measures to protect the transmission of your Personal Data when you use our Website.
In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.
Managing security incidents relating to Personal Data:
We have procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
If you have any reason to believe that your Member Account information may no longer be safe, please contact our customer support staff here.
Keeping your member account safe:
When you create an account with us, we ask you to choose a password and personal question to retrieve access to your member account. We use password protection to ensure your member account is safe at all times and can only be accessed by you. You must keep your username, password and personal question details private and confidential at all times. Please choose a password that is strong and not easy to guess. Please do not share your password with anyone and please change it on a regular basis. If you suspect your password has been disclosed to anyone, please change it immediately to ensure your Member Account remains safe.
We primarily store and process our Member Account data within the UK and European Economic Area (“EEA”).
However, in the following cases we can transfer your Personal Data outside the UK and/or EEA or between the UK and EEA:
- If we have a legal or regulatory reason to do so;
- If we use third parties service providers located outside of the UK and/or EEA; or
- If you have consented to this transfer.
Third parties service providers
To operate our Website, we may use third party service providers which are based outside the UK and/or EEA, so their processing of your Personal Data will involve a transfer of data outside the UK and/or EEA.
Whenever we transfer your Personal Data to a service provider outside of the UK and/or EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your Personal Data to countries where this is permitted by an adequacy ruling by the relevant regulator(s).
- We may contract with the service provider on terms that are approved by the relevant regulator(s) to aim to give Personal Data the same protection it has in Europe as relevant.
If you want further information on the specific mechanism used by us when transferring your Personal Data outside of the UK and/or EEA, please contact our DPO (see section 2 of this Privacy Policy).
We will not keep your Personal Data for longer than required. The precise duration for which we keep your Personal Data when you have a live member account with us or for a period after you cease to be a member with us, can vary and depends on various reasons. 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 what the law requires us to do. For example, we retain a copy of your Member Account’s records of all financial and wagering transactions together with any identification provided for as long as is necessary for the relevant service and for no longer than 7 years after you have closed your Member Account.
When we no longer need to keep your Personal Data, we anonymise it securely and this process cannot be reversed. In certain cases, we need to securely retain certain Personal Data to fulfil our legal and regulatory obligations (including anti-money laundering requirements, responsible gaming requirements and the requirements of the Gambling Commission in the UK and the Gibraltar Gambling Commission to which we are subject as a gambling operator.
Additionally, where we decide to retain your information for analytics purposes, we will fully anonymise it in accordance with applicable security standards, so it can never be linked back to an individual.
Please note that if you decide to opt-out from receiving marketing communications from us (see section 6 above), we will need to retain a copy of your contact details, so we can add them to our suppression list and make sure you do not receive any information about our future marketing activities.
Please contact the DPO (see section 2 above) if you need any further information.
The law gives you legal rights in respect of the Personal Data we hold about you. You can exercise your legal rights for free except where this Privacy Policy states otherwise. We may need to request specific Personal Data from you from time to time to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that your Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month of receipt. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Below is a summary of the legal rights you have, what we do to protect them and how you can exercise them:
Your rights | What we do to protect your rights | How to exercise your rights |
Your right to access your Personal Data | You have the right to access and receive a copy of your Personal Data. | You can request access to your Personal Data by email to sar@virgingames.com. You will not have to pay a fee to access your Personal Data unless your request is unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. You can read more information about how to access your Personal Data here. |
Your right to correct your Personal Data | You have the right to request correction of the Personal Data we hold about you. | You can amend, correct, delete or edit your Personal Data in your Member Account. If you wish to correct other Personal Data, please contact our customer support team. Please see our contact details here. |
Your right to erase your Personal Data | You have the right to request erasure of your Personal Data. Please note, that we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. | You can request erasure of your Personal Data by contacting our customer support team. Please see our contact details here. This process is not reversible. |
Your right to object to processing your Personal Data | You have the right to object to processing of your Personal Data, including for marketing purposes. Please note that in some cases, we may demonstrate that we have legitimate grounds to process your information which override your rights and freedoms. | You can object to processing of your Personal Data by contacting our customer support team. Please see our contact details here. Your objection may take up to 96 hours to take effect. Once you have objected you can change your mind at any time by contacting us again. Your account will not be accessible while the restriction is in place. |
Your right to request a restriction to the processing of your Personal Data | You have the right to request a restriction of processing of your Personal Data. but in certain cases, we need to verify whether we have overriding legitimate grounds to use it. | You can request the restriction of processing of your Personal Data by contacting our customer support team. Please see our contact details here. Once you have requested this you can change your mind at any time by contacting us again. Your account will not be accessible while the restriction is in place. |
Your right to request the transfer of your Personal Data to you or to a third party | You have the right to request the transfer of your Personal Data to you or to a third party. We will provide to you your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. | You can request the transfer of your Personal Data to a third party by email to sar@virgingames.com. The request must include which data you would like to be transferred, to whom it should be transferred and by which method. |
Your right to complain to the regulator | If you are unhappy with our response to your query, you have the right to contact your applicable data protection regulator to raise a complaint. | To exercise your right to complain to the regulator please contact your national data protection regulator. |
Your right to withdraw consent | You can decide to withdraw your consent to receive marketing communications at any time and for free. | To exercise your right to withdraw your consent to receive marketing communications please see section 6 above. |
Our Website may contain links to websites where information practices may be different to ours. You should read the other websites' privacy notices, as we are not responsible for and have no control over information that is submitted to, or collected by, these websites when you visit them.
If you have any questions or comments about this privacy policy or want to know more about how we use your Personal Data, please contact our DPO (see section 2).
If you want to exercise your right to access your Personal Data, please email us at sar@virgingames.com as set out in section 11 above.
We may, from time to time, change or update this privacy policy. All changes to this privacy policy will be published on this page of the Website. Each change will become effective on publication. We recommend that you revisit and read this privacy policy regularly to ensure that you are up-to-date with the current terms.
Term | What this means |
Anonymous Data | Data sets that cannot identify an individual. |
Controller | A natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are or are to be processed. |
Data Protection Laws | UK’s General Data Protection Regulation (GDPR), UK Data Protection Act 2018 and the EU GDPR 2018 , and any other applicable laws relating to the protection of Personal Data. |
Data Processor | A natural or legal person which processes personal data on behalf of the data controller. |
Gambling Commission | The Gambling Commission in the UK and the Gibraltar Gambling Commission. |
Legitimate Interest | Processing Personal Data for our business interest, activities and needs including providing you with the best service and experience we can offer. We will balance our interests against any possible impact on you (both positive and negative), your rights or freedom. Where our business interest and needs are overridden by your interests, rights or freedom, we will not process your Personal Data (unless you have provided us with your consent or required by law). |
Member | Registered individuals on the Website with a live or closed account. |
Member Account | The Member’s user account with the Website. |
Personal Data | Information relating to an identifiable person, who can be directly or indirectly identified in particular by reference to an identifier. |
Special Category of Personal Data | Personal Data revealing details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. |