Protecting your privacy

Return to Player (“We“) are committed to protecting and respecting your privacy.

This policy (together with our terms of use and any other documents referred to on it) sets out the basis on which any Personal Data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting https://www.returntoplayer.com you are accepting and consenting to the practices described in this policy.

“Subscriber” means any person or entity that is registered on Website or our mailing list.

“Personal Data” means any information that identifies or can be used to identify a Subscriber or Visitor, directly or indirectly. Examples of Personal Information include, but are not limited to, first and last name, date of birth, email address, gender, occupation, or other demographic information.

“Website” means any website we own and operate (such as www.returntoplayer.com) or any web pages, interactive features, applications, widgets, blogs, social networks, social network “tabs,” or other online, mobile, or wireless offerings that post a link to this privacy policy.

“Visitor” means any person who visits our Website.

Information we may collect from you

We may collect and process the following data about you:

  1. Information you give us: You may give us information about you by filling in forms on our site https://www.returntoplayer.com (our site) or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our site or subscribe to our service, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, and all other similar activities, and when you report a problem with our site. The information you give us may include your name, address, e-mail address, phone number, social media account information and gaming preferences and interests.
  2. Information we collect about you: With regard to each of your visits to our site we may automatically collect the below information. We may collect this information as a part of log files as well as through the use of cookies or other tracking technologies. Our use of cookies and other tracking technologies is discussed more below.
    • technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
    • information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; 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.
  3. Information we receive from other sources: We may also obtain information from third party social accounts such as Google, Facebook, Twitter and such information will be treated in accordance with this policy. Such examples being:
    • Social media platforms and applets. Our Website includes social media features, such as the Facebook Like button. These features may collect information about your IP address and which page you are visiting on our Website, and they may set a cookie to make sure the feature functions properly.
    • Comment threads/Forums/Guest Blogs. From time to time we have such features on our Website. Any information you include on these features may be read, collected, and used by anyone. If your Personal Data appears in such a way that you want it removed, contact us (please use the Contact Form). If we are unable to remove your information, we will tell you why.
    • Contests and sweepstakes. We may, from time to time, offer surveys, contests, sweepstakes, or other promotions on our Websites or through social media.
    • Links to third-party websites. Our Website includes links to other websites, whose privacy practices may be different from ours. If you submit Personal Information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.

Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie policy.

Uses made of Personal Data

We use information held about you in the following ways:

  • To provide, operate, optimize, and maintain our Website;
  • To send you information for marketing purposes, in accordance with your marketing preferences;
  • For recruitment purposes, if you have applied for a role with Return to Player;
  • To respond to your online inquiries and requests, and to provide you with information and access to resources or services that you have requested from us;
  • To manage our Websites and system administration and security;
  • To improve the navigation and content of our Website;
  • To identify any server problems or other IT or network issues;
  • To set up online accounts where such functionality is made available;
  • To compile aggregated statistics about our Website usage and to better understand the preferences of our Visitors;
  • To carry out research and development to improve our products and services;
  • To customize content and layout of the Website; or
  • To carry out other legitimate business purposes, as well as other lawful purposes.

In addition, we may combine Personal Data with other information we collect or obtain about you (such as information we source from our third-party partners) to serve you specifically, such as to deliver a product or service according to your preferences or restrictions, or for advertising or targeting purposes in accordance with this privacy policy. When we combine Personal Data with other information in this way, we treat it as, and apply all of the safeguards in this privacy policy applicable to, Personal Data.

Disclosure of your information

We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, or our business partners, as defined in section 1159 of the UK Companies Act 2006.

We may disclose your personal information to third parties:

  • In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
  • If Return to Player or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
  • To our third-party service providers, who help us provide and support our services and other business-related functions.
  • Where Return to Player partners with third-party advertising networks and exchanges to display advertising on our Website.
  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of Return to Player, our customers, or others, or where we believe disclosure is necessary as a matter of applicable law or regulation. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Where we store your personal data

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA“). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Legal basis for processing

If you are from the EEA, our legal basis for collecting and using your Personal Data will depend on the Personal Data concerned and the specific context in which we collect it.

However, we will normally collect and use Personal Data from you where the processing is in our legitimate interests and not overridden by your data-protection interests or fundamental rights and freedoms. Typically, our legitimate interests include improving, maintaining, providing, and enhancing our technology, products, and services; ensuring the security of the services and our Website; and for our marketing activities.

If you are a Subscriber, we may need the Personal Data to perform a contract with you. In some limited cases, we may also have a legal obligation to collect Personal Data from you, for instance, if we (as a gaming lead generation Website) are required to obtain gaming licences in order to provide our services.

If we ask you to provide Personal Data to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Data is mandatory or not, as well as of the possible consequences if you do not provide your Personal Data.

Where required by law, we will collect Personal Data only where we have your consent to do so.

If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us (please use the Contact Form).

Your rights

Generally speaking you have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us (please use the Contact Form).

You have the following data protection rights:

  • To access, correct, update, or request deletion of your Personal Data. We take reasonable steps to ensure that the data we collect is reliable for its intended use, accurate, complete, and up to date. You may contact us directly at any time about accessing, correcting, updating, or deleting your Personal Information, or altering your data or marketing preferences by contacting us (please use the Contact Form) or updating your subscription settings on the Website. We will consider your request in accordance with applicable laws.
  • If you are a resident of the EEA, you can object to processing of your Personal Data, ask us to restrict processing of your Personal Data or request portability of your Personal Information. Again, you can exercise these rights by contacting us (please use the Contact Form).
  • Similarly, if we have collected and processed your Personal Data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.
  • You have the right to complain to a data protection authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We may ask you to verify your identity in order to help us respond effectively to your request.

Access to information and retention

You can request access to the information held about you at any time by contacting us (please use the Contact Form) or by email using ‘privacy (at) returntoplayer.com’.

We retain Personal Data where we have an ongoing legitimate business or legal need to do so, and the retention periods vary. In general, terms, because Subscribers have controls to administer their Personal Data we would retain the data until they remove/alter it, retract consent to the processing and use, or until they close their Website account. For other aspects of Personal Data, particularly Visitor Data and Personal Data not directly provided we would consider:

  • Whether we have a legal or contractual need to retain the data.
  • Whether the data is necessary to provide any services on our Website.

When we have no ongoing legitimate business need to process your Personal Data, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Data has been stored in backup archives), then we will securely store your Personal Data and isolate it from any further processing until deletion is possible.

Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be sent via our Contact Form.

Last update: 24 May 2018.