Privacy and Cookies Policy

Our Promise

Jackpot Happy is committed to protecting and respecting your personal data and your privacy. This Policy explains when and why we collect & use your personal information, how we use it, the conditions under which we may disclose it to others and how we keep it secure. It also explains your rights as a data subject.

We reserve the right to update and amend this policy at any time, however when we do we shall notify you on our website via pop ups and where possible by email.

Who We Are

We are Bear Group Ltd, a UK and Alderney licenced gambling company based in Guernsey. Bear Group is a wholly owned subsidiary of Gaming Realms PLC (“Gaming Realms”), a UK company listed on the London Stock Exchange. Gaming Realms and Bear Group are independent data controllers in respect to your personal data, and any referral to ‘we’ throughout this policy refers to Gaming Realms and Bear Group.

The brand “Jackpot Happy” is owned by Jackpotjoy Operations Ltd (the "Brand Owner"), and they are also independent data controllers in respect of your personal data. The Brand Owner is part of a group of companies headed by Jackpotjoy plc (registered in England and Wales under company number 10303804), which we will refer to as the "JPJ Group". The JPJ Group owns and/or operates a number of gambling websites (the "JPJ Websites").

Information We Collect About You

We collect and store your personal information when you create an account and use our service. We collect this via the various methods set out below.

Information you provide to us

We collect personal information that you provide directly to us, for example on registration or updating your account details, via customer support, when you report a problem, via chat or when you agree to receive our marketing communications. We also observe and collect information as you use our service; for example, when you are playing our games, making a deposit or interacting with our site.

We will also store information such as dates and times of your play, logs of errors and crashes and other system activity as you use our services.

From time to time, we may also collect information from you via customer satisfaction surveys or feedback on social media and emails.

Please remember that you are under no obligation to provide your personal information to us. However, you might not be able to access and/or use some or part of our website or services if you choose to withhold personal information that is required for those services.

Information we get from your device

We collect information directly from the device you use to access our service, for example the following: your IP address, device ID, operating system, browser information and location data. We may also collect logs of crash data (observed when using our service) direct from your device. With regard to your visits to this website and all associated Gaming Realms websites we automatically collect the following information:

  • technical information, including the Internet Protocol (IP) address used to connect your computer to the internet, browser type and version, time zone setting, browser plug-in types and operating system;
  • information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

Information provided by cookies

We collect information from cookies and use them frequently around the site for personalisation, marketing and troubleshooting. Please read our Cookies section further down to find out all about how we use cookies.

Information From external sources

To comply with our legal and regulatory obligations, we sometimes need to collect information from other sources.

We will do this when we need to verify information you have given us and to confirm you are over 18 years of age and will do so by using services such as GB Group Plc and Experian. In some cases we may need to verify further information as you continue with us as a customer, to do this we use other organisations and companies who collate information to help with the prevention of crime and fraud.

We will also consult publicly available information such as council registers, post office data, Companies House and social media to confirm information we may need.

To comply with our obligations in relation to responsible gambling we will receive information about you if you’ve registered with the GAMSTOP National Self-Exclusion Scheme.

How We Use Your Personal Information

In order to provide a service

We require your personal information in order to provide you with an account, deal with queries and allow you to access games and our content. Technical information that we gather is used to provide correct versions of software and to help troubleshoot any issues you may have. We may use your information to:

  • ensure that content from our websites are presented in the most effective manner for you and for your computer;
  • administer our websites and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • allow you to participate in interactive features of our products and services (where applicable), when you choose to do so;
  • keep our websites safe and secure; send you communications which you have requested and that may be of interest;
  • complete certain transactions with you.

If you object to your data being used for this reason, you might not be able to access and/or us some or part of our website or services.

To comply with legal and regulatory obligations

The Bear Group is regulated by both the UK Gambling Commission and the Alderney Gambling Control Commission, and is obliged to ensure that all of our customers play legally and responsibly. This is done via regular checks on customers, audits and regulatory reporting.

We are committed to responsible gambling, and as such we monitor customers’ gambling behaviour and use various sets of information such as age, gender, location and deposit patterns in order to identify common issues. It’s vital that we’re able to do this work, which allows us to detect problem gamblers at an earlier stage and help them with support.

As an industry, we are highly aware of the risks of fraud, money laundering and other crimes. As such we carry out verification at various stages of the customer journey, validating information you’ve provided against various other databases and information from fraud prevention agencies. Where we detect any potential fraudulent activity and suspicious transactions, we may share data with applicable regulators. Where necessary we may also pass information onto law enforcement agencies and other official organisations.

If you object to your data being used for this reason, your option is to not use our service and request your account to be closed.

To improve the quality of our service to all customers

We use personal information to help personalise and improve our services, and it’s within our legitimate interests to do so. This includes providing suggestions of games you would like to play, customising offers that might be appropriate to you and tracking which parts of the service players use most. It is a core part of our business to ensure that our service is constantly improved and is ran effectively and efficiently, and we may use your data in order to do so.

The Brand Owner also uses your personal information, on the basis that it has legitimate interests in doing so, to personalise and improve its gambling websites, other products/services, customer relationships and experiences.

If you use other websites that are owned by other companies in the JPJ Group, the Brand Owner has determined that it has legitimate interests in matching your account details across those websites in order to build up your personal profile and gain a better understanding of your interests in the JPJ Sites, to provide you with tailored recommendations, to improve the JPJ Sites, and to prevent abuse across those sites.

Direct Marketing

To keep you up to date with all our site offers and new games, we love getting in touch with all our customers via email, text, phone or post. You have a choice about whether or not you wish to hear from us. You will need to opt-in to all marketing preferences and if you decide you don’t want to hear from us you can select not to receive this communication either at registration or at any time from your Contact Preferences within your Manage Account section. You can also opt out directly from an email campaign by clicking ‘unsubscribe’ or replying to an SMS with the correct STOP message detailed inside. Alternatively you can contact us via customer support, who can update your preferences for you at any time. We will not contact you for marketing purposes unless you have given us your express prior consent to do so.

Please note that we may still need to send you important information regarding your account via these methods, even if you have opted out of receiving marketing.

Social Media

Both we and the Brand Owner often use Social Media such as Facebook and Twitter to advertise our services. If you no longer want to receive personalised and targeted advertisements from us on Social Media, you can manage your advertising preferences and decide what you want or do not want to see by using the settings in your social media account.

Push notifications

If you use our services via one of our apps, we may send push notifications from time to time. You can change whether or not you wish to see these when you first install the app, or at any time afterwards through your device settings.

Cookies

Cookies are small text files that are stored in your browser when you visit websites. They are essential to keep certain parts of our site running correctly and securely. They are also used to personalise your online experience to make it more relevant to you and also to provide usage data back to us. They can also be used to present you with more tailored advertising content. For cookies to work as required, personal information may be collected from you. You can choose whether to accept or reject some or all types of cookies and control this through your device’s browser settings. However, please note that if you reject some cookies, the website may not function as it should do, and we've indicated this where relevant below.

The types of cookies we use are outlined below:

Necessary and Functionality Cookies

These cookies are essential for you to navigate the site correctly and log in to the secure areas. They also enable us to deliver content specific to your device.These cookies allow our websites to remember choices you have made, such as your username or region. They help us keep you logged into your account as you navigate around our website. We also use them to personalise your experience by, for example, showing more relevant onsite content. Without these cookies you may not be able to access your account or play games.

Analytical cookies

These cookies collect information about visitor activity on the website so that we can monitor performance. For example how many people visit certain pages, the number of people who see specific content. They also ensure we can pay our marketing partners correctly for users they refer to us. Without these cookies you will still be able to login and play on the site without an effect on your online experience.

Targeting Cookies

These cookies are used to deliver adverts and content that are more relevant to you as well as to limit the number of times you see a particular advertisement and to measure the effectiveness of advertising campaigns. These cookies remember that you have visited a website, and we share this information with other organisations for advertising purposes. We also use them to test and improve our products and services by, for example, testing out different product experiences with different groups of customers to see which is most popular. Without these cookies you will still be able to login and play on the site but may not receive the most relevant content.

Tracking Cookies

We use cookies placed by third parties to collect personal information about your browsing activity, which they then group with data about what other people with similar interests in similar demographic groups are looking at. The resulting information is used to show you online adverts based on those interests (this is known as ‘online behavioural advertising’).Without these cookies you will still be able to login and play on the site without any effect on your experience.

Controlling my cookies

All modern browsers allow you to see what cookies you have, and to clear them individually or in their entirety by changing your cookie settings. Cookie settings are typically found in the 'options' or 'preferences' menu of your browser, otherwise you should use the 'Help' option in your browser for more details. You may also find the links below helpful:

How We Might Share Your Information

The Brand Owner and the JPJ Group

We will be sharing your personal information with Brand Owner on a regular basis. This is because the Brand Owner owns this website, and we operate it on their behalf.

In the event that the Brand Owner appoints someone else to operate this website (whether another service provider, or another member of the JPJ Group) then we would share your personal information with the new operator of this website and they would assume our rights and obligations under this Policy.

Third Party Service Providers

The categories of third parties with whom we and/or the Brand Owner may share your data include:

  • Providers of marketing tools (to send emails, texts and print marketing)
  • Subsidiaries of Gaming Realms (for support, marketing functions, customer insights)
  • Companies in the JPJ Group
  • Online advertising tools
  • Payment service providers
  • Game suppliers (for both gameplay and tournaments/competitions)
  • Identity verifications service providers and fraud prevention service providers
  • Web hosting & data storage services
  • Data analytics companies
  • Customer feedback and market researchers
  • Regulatory bodies & law enforcement agencies
  • IT service providers
  • Accountants, auditors, other professional service providers

Regulatory bodies and law enforcement agencies

The Bear Group may share some or all of your personal information with the UK Gambling Commission, the Alderney Gambling Control Commission and any other gaming authorities with whom the Bear Group is licensed, in order to comply with regulatory requirements.

Both we and the Brand Owner may need to share your personal information with other regulatory bodies or law enforcement agencies if we or the Brand Owner believes in good faith that such disclosure is necessary (a) to comply with relevant laws or to respond to subpoenas or warrants; (b) in connection with any legal investigation; (c) to protect or defend the rights or property of our group of companies, the JPJ Group, or users of our websites and/or (d) to investigate or assist in preventing any violation or potential violation of law, this Policy, or our terms and conditions.

Sending information outside of the EU

While transferring data to and from our group companies or to third parties, both we and the Brand Owner may transfer your data outside of the EU. However, we will only do this when we are satisfied that the company we are transferring to will meet the same data protection standards as those in based the EU. For example, we use approved contractual clauses, intragroup agreements and other measures designed to ensure that the recipients of your personal information protect it.

Publicity

We will not use your personal information for any publicity without your consent. If we wish to publicise a large win and you don’t wish to take part, we will only use details that cannot be used to identify you personally, such as gender and city location.

With other players

If you play multiplayer games such as Slingo Boom or multiplayer poker, your username will be public and shared to other players in the room. This is also true if you take part in leaderboard tournaments.

In other circumstances

Both we and the Brand Owner may share some or all of your personal information in connection with or during negotiation of any potential sale or investment in any of the companies in our group or the JPJ Group or in the event of a corporate transaction (e.g. a sale of a substantial part of our respective businesses, merger, financing, restructuring, consolidation, acquisition, corporate divestiture, dissolution transaction, or other proceeding involving the sale, transfer, divestiture or disclosure of all or a portion of our business or assets). In the event of an insolvency, bankruptcy, or receivership, your personal information may also be transferred as a business asset.

In the case of an ownership change or part or all of our business, we would transfer your data to the new owner to ensure a smooth transition of the service. We will ensure that your privacy rights are protected during this time, and any movement of data is done securely.

If either we or the Brand Owner need to share your data for any another reason than mentioned above on an ongoing basis, we will update this privacy policy to reflect that.

How Long We Store Your Information

Both we and the Brand Owner store your data only as long as necessary to provide a service to you, and to comply with our legal, regulatory and business obligations after our relationship with you has ended. Once you have stopped using the service, the Bear Group is required to hold onto your data for a period of time in order to satisfy various requirements, including but not limited to: anti-money laundering, audit requirements, complaint handling, licence requirements and protection of problem gamblers. Gaming Realms and the Brand Owner may also retain your personal information after you have closed your account, in order to comply with internal policies and for risk management purposes.

As soon as your data is not covered by any of these requirements and there is no valid reason to hold onto it, it will be deleted or anonymised.

Your Privacy Rights – how you can access and update your information

You have certain rights when it comes to what we and the Brand Owner do or provide with your data. For all privacy requests that you cannot do from your account, please send through your query to customer support with as much detail as possible.

Please note that these rights are not absolute and requests are subject to any applicable legal requirements, including gambling regulations and other legal and ethical reporting or document retention obligations. We will advise you in our response to your request if we are relying on any such exemptions.

Right of access

You have the right to access your personal information. This includes (a) identification of and access to any or all of your personal information under our and the Brand Owner's custody or control; (b) an explanation of how that personal information is or has been collected, used or disclosed; and (c) the names of any individuals and organisations to which your personal information has been disclosed.

Right to rectification

You have the right to request correction to your personal information in the event it is inaccurate, incomplete or out of date.

Right to erasure

You can request that we and/or the Brand Owner erase your personal information where there is no compelling reason for us to continue processing it.

Right to data portability

This right allows you to obtain the personal information that you have provided to us with your consent or which was necessary for us to provide you with our services in a format which enables you to transfer that personal information to another organisation. You may have the right to have your personal information transferred directly to the other organisation, if it is technically feasible.

Right to object

You have the right to object to us and/or the Brand Owner processing your data on the basis of our respective legitimate interests. However, we each may continue to process your personal information, despite your objection, where there are compelling legitimate grounds to do so or where either we or the Brand Owner needs to process your personal information in connection with any legal claims.

Restriction of processing:

You have the right in certain circumstances to request that we and/or the Brand Owner suspend processing of your personal information. Where this right applies and we and/or the Brand Owner suspend our processing of your Personal Information, then we will each still be permitted to store your personal information, but any other processing of this information will require your consent, subject to certain exemptions.

Withdrawal of consent

Where either we or the Brand Owner rely upon your consent to process your personal information, you have the right to withdraw that consent.

Links To/From Other Websites

We may provide links from our websites to other organisations or companies from time to time. This Policy applies only to this website. Please note that other organisations will have their own privacy policies, which we advise you read and understand before providing any personal information to them. We are not responsible for the policies of any third party links, and you should direct any queries regarding their policies or use of data to the site’s owner.

In addition, if you linked to our website from another third party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party site and recommend that you read their privacy policies.

How We Keep Your Data Secure

When you provide us with personal information, we take steps to ensure that it’s treated securely. Both we and the Brand Owner put in place policies, procedures and security features to try to prevent unauthorised data breaches.

We have implemented secure technology and policies to safeguard your privacy from unauthorised access and improper use, and continuously evaluate our procedures. We abide by ISO27001 principles, are PCI compliant.

In addition, the Bear Group undergoes regular security standards audits as part of its UK licence obligations.

What You Can Do To Keep Your Data Safe

If you use our services while on a shared device, remember to log out securely and if on a public computer we advise that you clear cookies from the web browser used. Never let anyone else share your account and keep your password safe - NB not even our customer support agents will ask you for your password at any time. You are responsible for keeping the password confidential and we ask you not to share your password with anyone. When you set your password, remember to choose something complex and never use the same passwords on multiple websites.

How To Contact Us

In order to exercise any of your rights described above or for general queries please contact customer support.

For all queries relating to this Policy or if you wish for further technical detail around our data protection principles, please contact us via one of the methods set out below:

Email: [email protected]

Post:
Data Protection
Gaming Realms Plc
One Valentine Place
London, SE18QH

If you have any queries about the information that the Brand Owner collects about you and how it is used, you can also contact the Brand Owner directly via email at [email protected] or by sending a letter to:

Jackpotjoy Operations Ltd
Attn: Data Protection Officer
Albany Financial Center, Suite 304
South Ocean Boulevard
New Providence, The Bahamas

Complaints

You have the right to lodge a complaint with the Information Commissioner’s Office in the UK or (if not the ICO) your local national data supervisory authority.

You can find a link to the Information Commissioner’s website here: www.ico.org.uk

REVIEW OF THIS POLICY

We keep this Policy under regular review. This Policy was last updated on: 25th May 2018


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