Privacy Policy

Introduction

As a “data controller” (meaning we are responsible for deciding what personal information we collect about you and what reasons we use it for) tombola (International) plc is committed to protecting and respecting your privacy.

Please read the following policy to understand how we collect and use information about users of our websites, tombola bingo tombola.co.uk and tombola arcade www.tombolaarcade.co.uk including versions of our websites viewed on mobile phones, tablets or other electronic devices (in all cases referred to as the ‘websites’).

The Privacy Policy should be read in conjunction with the tombola Terms and Conditions and any additional applicable terms posted to the websites.

If you have any requests concerning your personal information or any queries with regard to these practices, please contact us at [email protected] 

Information Collected

We collect information from you when you visit our website, use our app, deposit funds with us, play our games, contact us by telephone or email or receive a communication from us. The provision of information to us is voluntary; however, if you do not provide us with Transaction information or Preference information, we may not be able to provide our service or parts of it to you or provide you with updates

 

Category of personal data

 

Examples of your personal data

Contact information

Name, Address, Email Address, Telephone Number

Transaction information

Contact information, together with your username, online account details, deposits made and withdrawn, stakes placed, payment details, any communications we have about your purchases, games played

Legal information

Your date of birth, fraud checks or flags raised about your transactions, payment card refusals, complaints

Preference information

Your marketing preferences, your account settings including any default preferences, any preferences we have observed, such as the types of offers that interest you, or the areas of our website that you visit.

Communications with us

Communications we may have with you, whether relating to a transaction or not. Please note that calls to our customer services team may be recorded

Voluntary information

Any voluntary information you provide us with, such as your gender, responses to surveys or competition entries, your favourite types of online game.

Observed information

Details of your online browsing activities on our website, such as the pages, products or areas of our website that you visit, or which link has brought you to our website from our email communications or other websites.

 

This information may be identifiable to you because you are logged in to your account, or because we have collected details of your IP address or the device that you have used to access the website. This will also collected the geographic region which your device reports to us that you are located in.

 

Customer specific: When logged into your account we collect information about your device (make and model) and from your web browser such as browser type and version, your IP address (to validate location) and Browser User Agent (to enhance your experience on the site) and we generate a unique device identifier for you on tombola or use the actual device identifier generated by iOS and Android when using the app. We use global and session tracking cookies for fraud and user journey tracking to maximise user experience and flow through our websites and we use request cookies to help us diagnose if users are having any problems on the websites. For more information on cookies, please see our cookies policy.

 

Website users = Google analytics anonymous data collection about spend times on website, customer journey on website and which sites users are coming from and going to without tying it to specific users

  


We hold this information on our servers securely in Ireland. Players can use the tombola bingo and arcade websites with the same login details.

Purposes

We use the personal data we collect about you for various purposes. To do this we must rely on a specific “lawful bases” for processing that personal data. The tables below sets out under which basis we process different information about you, an explanation of the purpose of that processing and the specific rights in relation to your personal data, which may depend on the basis we process it for. 

Lawful basis and purpose

What personal data do we use?

Consent:

to send you direct marketing in accordance with the preferences you select when you sign up to receive updates, play games, or via our preferences centre.

 

To collect certain personal data about you via cookies or other similar technologies, as more fully described in our Cookies Policy.

 

 

Contact information

 

 

Observed information

Performance of our contract with you: to take payment for our services and to provide our services to you, to deal with any customer support queries and provide customer service or any after sales services

Transaction information

Complying with legal obligations: To confirm your identity and your age, to keep records required by law or to evidence our compliance with laws, including tax laws, consumer protection laws, our regulatory requirements, and data protection laws. To provide information to law enforcement agencies or other authorities where we are required to do so

Legal information, Transaction information, Communications (where relevant), Preference information in the case of marketing and cookie preferences only

Our legitimate interests: For our internal business administration, to manage Player accounts, including keeping general records of customers, sales, customer care and other interactions, and to monitor, investigate and protect genuine customers and our business from fraud to minimise the risk of false details being used, and abuse of card details by fraudsters. This is necessary in order for us to operate efficiently, deal with any issues which may arise and to protect ourselves against any future legal claims and ourselves and others against fraudulent transactions.

To manage any competitions or other promotions that you have chosen to participate in.

 

To publish your username if you are a winner on our website and on our social media channels.

 

To target our direct marketing to you (where you have consented to receive it): This means that we use the information you provide us with and that we observe from your interactions with us to build a better picture of the type of offers and products/services we can provide which you might be interested in, so that the communications you receive are more relevant to you. Without using this information, we could only send generic communications to you, and we’d rather not be cluttering up your inbox! We believe this is justified as you are in control over whether you receive our direct

Transaction information, Legal information, Communications, Preference information

 

 

 

 

 

 

 Contact information, Preference information, Communications, Voluntary information

 

Contact information

 

 

Transaction information, Preference information Communications, Preference information, Voluntary information, Observed information 

Requesting your rights

You have certain legal rights, which are briefly summarised below, in relation to any personal data about you which we hold.

Where our processing of your personal data is based on your consent, you have the right to withdraw your consent at any time. If you do decide to withdraw your consent we will stop processing your personal data for that purpose, unless there is another lawful basis we can rely on – in which case, we will let you know. Your withdrawal of your consent won’t impact any of our processing up to that point.

Where our processing of your personal data is necessary for our legitimate interests, you can object to this processing at any time. If you do this, we will need to show either a compelling reason why our processing should continue, which overrides your interests, rights and freedoms or that the processing is necessary for us to establish, exercise or defend a legal claim. 

Your right

What does it mean?

Limitations and conditions of your right

Right of access

Subject to certain conditions, you are entitled to have access to your personal data (this is more commonly known as submitting a “data subject access request”).

If possible, you should specify the type of information you would like to see to ensure that our disclosure is meeting your expectations.

We must be able to verify your identity. Your request may not impact the rights and freedoms of other people, eg privacy and confidentiality rights of other individuals.

Right to data portability

Subject to certain conditions, you are entitled to receive the personal data which you have provided to us and which is processed by us by automated means, in a structured, commonly-used machine readable format.

 

If you exercise this right, you should specify the type of information you would like to receive (and where we should send it) where possible to ensure that our disclosure is meeting your expectations.

This right only applies if the processing is based on your consent or on our contract with you and when the processing is carried out by automated means (ie not for paper records). It covers only the personal data that has been provided to us by you.

Rights in relation to inaccurate personal or incomplete data

You may challenge the accuracy or completeness of your personal data and have it corrected or completed, as applicable.

 

We encourage you to notify us of any changes regarding your personal data as soon as they occur, including changes to your contact details, telephone number.

This right only applies to your own personal data. When exercising this right, please be as specific as possible.

Right to object to or restrict our data processing

Subject to certain conditions, you have the right to object to or ask us to restrict the processing of your personal data.

As stated above, this right applies where our processing of your personal data is necessary for our legitimate interests. You can also object to our processing of your personal data for direct marketing purposes.

Right to erasure

Subject to certain conditions, you are entitled to have your personal data erased (also known as the “right to be forgotten”), eg where your personal data is no longer needed for the purposes it was collected for, or where the relevant processing is unlawful.

We may not be in a position to erase your personal data, if for example, we need it to (i) comply with a legal obligation, or (ii) exercise or defend legal claims.

Right to withdrawal of consent

As stated above, where our processing of your personal data is based on your consent you have the right to withdraw your consent at any time.

 

If you withdraw your consent, this will only take effect for future processing.

If you have a question or concern about your privacy and rights on tombola, please do not hesitate to contact Us.

Telephone number: 0800 298 873

E-mail: [email protected]

If you wish to exercise any of your rights please contact the:

Data Compliance Officer: [email protected]

 

You also have the right to lodge a complaint with your local supervisory authority. In the UK this is the Information Commissioner’s Office and more information can be found at https://ico.org.uk/.

Who do we share personal information with and where are they?

Your personal data may be processed by us and/or our business partners, suppliers, sub-processing certain services on our behalf for the purposes specified above. For example, we share information with security verification companies, for the purpose of card/payment processing, identity and security checking (the Customer’s credit rating will be unaffected) or investigations on Tombola’s behalf. 

Such third parties have access to personal data solely for the purposes of performing the services specified in the applicable engagement, or to comply with applicable laws and not for any other purpose.

We will have in place an agreement with our service providers which will restrict how they are able to process your personal information and require them to keep it secure.

We may also use service providers in less direct ways, such as in the provision of our payment and finance systems, fraud verification. We may exchange information with other companies and organisations for the purposes of age verification, data cleansing, fraud protection, credit checks and/or risk reduction.

If you have been found to have defrauded or cheated the company or any service including game manipulation or payment fraud, including stolen credit cards, or fraudulent activity (including chargeback or other reversal of a payment) or money laundering, we reserve the right to share this information, including your identity with other online gaming websites, banks, credit companies and agencies.

Data privacy laws across the countries in the European Union, Norway, Iceland and Liechtenstein, (the European Economic Area) are the same or very similar.  We have called this area ‘Europe’ for ease. If it is necessary for us to transfer your personal information outside Europe we will only make that transfer if we use a method approved as privacy-safe by the data privacy regulators in Europe: 

- the country to which the personal information is to be transferred has been approved by them;

- the recipient of the personal information is in the USA and has certified they will comply with the Privacy Shield rules to protect personal information, approved by them

- the recipient of the personal information is legally bound to protect your personal information under binding corporate rules approved by them

- we have made sure that there is a contract to protect your personal data with the recipient, using a template approved by them;

- the transfer is needed for another reason approved by them, such as to make an international delivery of a prize at your request; or

- where you explicitly consent to the transfer.

If any service provider is based outside of the European Economic Area, we will ensure that the provider is either a current subscriber to the EU/US Privacy Shield, or we have an appropriate contract for the international transfer of personal information with them. 

We may share any of your personal data with a prospective purchaser or purchaser of any part of our business, on the basis of our legitimate interests and the interests of our purchaser, so that they can appropriately value the business and assess any risks and continue doing business with you after the acquisition. 

In addition we may be required by law or by a court to disclose certain information about you or any engagement we may have with you to relevant regulatory, law enforcement and/or other competent authorities. We may also need to share your information in order to enforce or apply our legal rights under any agreed terms of business.

How long do we keep your information for?

If you are our customer we will keep your personal data during the period your account remains active and then, after your account becomes inactive, for as long as is necessary in connection with both our and your legal rights and obligations. This may mean that we keep some types of personal data for longer than others.

We will only retain your personal data for a limited period of time. This will depend on a number of factors, including:

- any laws or regulations that we are required to follow, especially regulatory requirements related to our online gambling licenses;

- whether we are in a legal or other type of dispute with each other or any third party;

- the type of information that we hold about you; and

- whether we are asked by you or a regulatory authority to keep your personal data for a valid reason.

Any personal data contained in any work related correspondence or records may be retained for longer, dependant on the retention period of the file that your personal data is held on.

Your account

Access to your personal account information is restricted to you by your unique username and password. All details are stored under the strictest supervision. We want to ensure complete trust with our Players and to make playing tombola an enjoyable experience.

Security 

We have implemented suitable security policies and rules and fully understand the importance of information security and the need to store it correctly. We store all personal information within a secure network meaning data, passed back and forth between your computer and our systems is secured using a public key cryptography. Your computer exchanges key information with our servers to create a private conversation that only your computer and our servers can understand.

Our links with our payment gateways use technology to transmit any payment information securely. They in turn have secure encrypted links between themselves and all of the major banks to allow the payment to be processed. Tombola employees do NOT have access to your full credit/debit card details.

Protection of Children

The services on tombola are not intended for or directed to persons under the age of 18. Any person who provides their information to us through our Websites represent that they are over 18. We reserve the right to access and verify any information submitted to us by you. If we become aware that a minor has attempted to or has submitted personal information via the Websites, we will take action to remove such information from our records.

Marketing contact

You may opt out of receiving communications offering commercial goods or services at any time by adjusting your contact preferences within the “My Account” area of the websites, or by sending a request to [email protected] in accordance with our Privacy Policy. 

After 48 hours you will no longer receive any marketing via direct mail/email/SMS text. However, we may still need to correspond with you regarding account details, prize fulfilment and other operational matters and you consent to continue to receive these account communications even after you have opted-out of commercial offerings solicitations.

Changes to our Policy

We reserve the right to update this privacy policy at any time but do not want to bother you about minor changes, so we will only provide you with a new privacy policy when we make any updates with a significant impact on your privacy which you should know about. The latest privacy policy with any other updates will always be available on our websites for you to check. We may also notify you in other ways from time to time about our use of your personal information.

Contact Information

Telphone: 0800 298 873

E-mail: [email protected]

Last updated on: 23 May 2018