Introduction

This Policy applies to our products and services such as Dial-a-bet and any business conducted within our shops.

This purpose of this privacy policy is to give you a better understanding of:

• what information we collect;
• how we use that information;
• how this information is shared;
• how this is stored;
• your rights; and
• other useful privacy and security related matters.

Please take the time to read this policy and check this regularly for updates. If we make changes we consider to be important, we will let you know by placing a notice on the relevant Service and/or contact you using other methods such as email.

Who is the Data Controller?

The Toals Bookmakers data controller is Toals Bookmakers Limited of 15a Pottingers Court, Belfast, Co Antrim, BT1 4DU

And, what about the Data Protection Officer/ Controller?

Our Data Controllers can be reached at dp@toalsbookmakers.com, our Customer Service team will be your initial point of contact if you wish to exercise your rights. Please see the 'Your Rights' section below.

Information we collect

When you use our Services, we collect the following types of information:

Information you provide us:

We collect information about you during the account registration process for Dial-a-bet. This information may include, but is not limited to your name, postal address, e-mail address, phone number, credit/debit card details and any other details as might be requested from you for the purpose of registration and/or continued use of our Services.

We may also collect information from you if you request information or customer support.

Additional Information collected:

We may also collect the following information:

1. name, contact information and message if you contact us or participate in a survey, contest or promotion;
2. your betting, gaming, deposits, payments, payment method and other account transactions - these are routinely analysed to assist us in improving the Services we provide to you;
3. your telephone or Live Chat conversations – either to place a bet or a customer service call;
4. your response to marketing campaigns from us or through our third parties i.e. open/click on such emails/ SMS messages;
5. your social media profile details (name, profile photo and other information you make available to us) when you connect with or contact us through a social media account;
6. information derived based on profiling activity (see below); and
7. information from third party databases to comply with our legal and regulatory obligations.

Third Party and Publicly Available Sources

Not all the personal information we hold about you will always come directly from you. We may also collect information from third parties such as service providers and publicly available websites (i.e. social media platforms), to comply with our legal and regulatory obligations, offer Services we think may be of interest, to help us maintain data accuracy and provide and enhance the Services.

If you log into one of our products through Facebook, Facebook provides us with some of your Facebook user details. We may use these details for the purposes of our registration process and to market our products and Services to you on Facebook.

How do we use this information?

We process personal information for these Services- and business-related purposes:

• Account setup, verification and management: We use personal information such as your name, email address, phone number, and information about your device to set up and administer your account, provide technical and customer support and training, verify your identity, process payment information and send important account and Service information.

  As a condition to using our Services, we may ask you to share your precise geolocation so we can ensure that we are authorised to provide the Services to you in your location. The above processing is required in order for us to provide the Services to you pursuant to our terms and conditions.

  To verify your age and accuracy of your registration details, including disclosure of such information to third parties e.g. financial institutions and third party reference agencies. This is required for the purpose of our complying with our legal obligations.

  We may also use personal information to enforce our terms and conditions.

• Personalisation: We use personal information to deliver and suggest tailored content to personalise your experience with our Services. This is processing which is necessary for the purpose of our legitimate interests in delivering or presenting relevant content to our customers.
• Marketing and events: Subject to any preferences you have expressed (where applicable), we use personal information to deliver marketing and event communications to you across various platforms, such as email, telephone, text messaging, direct mail, online, push notification or otherwise. We will do this during the period of your relationship with us and, unless specifically instructed otherwise by you, for a reasonable period of time after the relationship has ended in order to inform you about products, services, promotions and special offers which we think may be of interest to you.

  If we send you a marketing email or SMS, it will include instructions on how to opt out of receiving these marketing communications in the future. Please remember that even if you opt out of receiving marketing emails, we may still send you important Service information related to your accounts and subscriptions.

  We will, from time to time, send you marketing material which may of particular interest to you based upon your behaviours i.e. your betting and gameplay activity, trends and interests. These marketing messages will provide you with information about the products, services, active promotions or offers available to you.

  Except where we use your personal data for marketing purposes on the basis of your prior written consent and subject to any opt out preferences you notify to us in respect of electronic direct marketing communications, we process personal data for marketing purposes as necessary for the purpose of our legitimate interests in promoting our products and services.

  We may publish players’ aliases and/or chat names, along with any winnings and prizes received, on our websites, we may also publish large winning bets from our shops in accordance with our legitimate interests.

• Risk Management: In order to provide the Services to you and for our legitimate purposes, we process personal data to evaluate and manage risks to our business.
• Surveys and polls: If you choose to participate in a survey or poll, any personal information you provide may be used for marketing or market research purposes in accordance with our legitimate interests.
• Legal and regulatory obligations: We may be required to use and retain personal information for legal and compliance reasons, such as the prevention, detection, or investigation of a crime; or fraud. We may also use personal information to meet our internal and external audit requirements, information security purposes, and as we otherwise believe to be necessary or appropriate: (a) under applicable law, which may include laws outside your country of residence; and (b) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include such authorities outside your country of residence.
• Profiling: In accordance with our legitimate interests detailed below or to comply with our legal obligations, we carry out profiling and analysis based upon your location data, age, betting and gameplay activity, interests and behaviours for the following purposes:
  • to offer you tailored products and services, and more relevant marketing;
  • Risk and trading analysis; and
  • Licensing and legal obligations i.e. Responsible Gambling, Anti Money Laundering, Age Verification, prevention of fraud and to ensure the integrity of sporting events.
• Other purposes: We may be required to use and retain personal information for; loss prevention; and to protect our rights, privacy, safety, or property, or those of other persons in accordance with our legitimate interests.

How is the information shared?

Within the Company

Includes any member of Toals Bookmakers Limited may use and share, within the company and with its advisors, the information you provide and other information it holds about you for the following purposes:

• Account set up, verification and management;
• Marketing and events
• Risk management; and
• Legal and regulatory obligations.

Toals Bookmakers may retain trusted third parties to process your information to provide us with services, including for customer support, information technology, payments, sales, marketing, data analysis, research and surveys. As part our agreements with our partners, we may be required to share your information for the purposes of calculating fees and benefits owed.

Third parties for legal reasons:

We will share personal information when we believe it is required, such as:

• To comply with legal obligations and respond to requests from government agencies, including law enforcement and other public authorities, which may include such authorities outside your country of residence;
• In the event of a merger, sale, restructure, acquisition, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings); and
• To protect our rights, users, systems, and Services

Regulatory or Sporting body

Your personal information including, but not limited to, your registration details, betting records, records of payments, device information etc., may also be disclosed to any regulatory or sporting body in connection with policing the integrity or enforcing the rules of a sport or game and/or prevention and detection of crime and where we consider that there are reasonable grounds to suspect that you may be involved in a breach of such rules or the law, have knowledge of a breach of such rules or the law or otherwise pose a threat to the integrity of the relevant sport or game based upon our assessment of your betting behaviours or it may be based on information provided to us by a regulatory or sporting body. Those bodies may then use your personal information to investigate and act on any such breaches in accordance with their procedures.

How we store your information?

We protect your information with security measures under the laws that apply and we meet international standards. We keep our computers, files and buildings secure.

When you contact us to ask about your information, we may ask you to identify yourself. This is to help protect your information.

Your rights

Under the General Data Protection Regulation, you, as a data subject have a number of rights which are detailed below. Some of these only apply in specific circumstances and are qualified in several respects by exemptions in data protection legislation. We will advise you in our response to your request if we are relying on any such exemptions.

• Access to personal data: You have a right to request a copy of the personal information that we hold about you. Should you wish to make such a request, please see above on how to contact us

  You should include adequate information to identify yourself and such other relevant information that will reasonably assist us in fulfilling your request. Your request will be dealt with as soon as possible and within one month of submission.

• Correction of personal data: You can request us to rectify and correct any personal data that we are processing about you which is incorrect. We provide you with account settings and tools to access the information associated with your account.
• Right to withdraw consent:Where we have relied upon your consent to process your personal data, you have the right to withdraw that consent.

  To opt out of marketing, you can use the unsubscribe link found in the SMS marketing communication you receive from us or you can request to opt out from a member of our customer services team

• Right of erasure: You can request us to erase your personal data where there is no compelling reason to continue processing. This right only applies in certain circumstances, it is not a guaranteed or absolute right.
• Right to data portability: This right allows you to obtain your personal data that you have provided to us with your consent or which was necessary for us to provide you with our products and services in a format which enables you to transfer that personal data to another organisation. You may have the right to have your personal data transferred by us directly to the other organisation, if this is technically feasible.
• Right to restrict processing of personal data: You have the right in certain circumstances to request that we suspend our processing of your personal data. Where we suspend our processing of your personal data we will still be permitted to store your personal data, but any other processing of this information will require your consent, subject to certain exemptions.
• Right to object to processing of personal data: You have the right to object to our use of your personal data which is processed on the basis of our legitimate interests. However, we may continue to process your personal data, despite your objection, where there are compelling legitimate grounds to do so or we need to process your personal data in connection with any legal claims.
• Rights relating to automated decision making and profiling: You have the right not to be subject to a decision which is based solely on automated processing (without human involvement) where that decision produces a legal effect or otherwise significantly affects you. This right means you can request that we involve one of our employees or representatives in the decision-making process. We are satisfied that we do not make automated decisions of this nature.

How to contact us

For any requests related to your personal information or any of your rights referenced above, please feel free to contact us in one of the following ways:

Email : dp@toals.com

Post:Customer Services, Toals Bookmakers, 15a Pottingers Court, Belfast, Co Antrim, BT1 4SU

Filing a complaint

If you are not satisfied with how we manage your personal data, you have a right to make a complaint to your local Data Protection Authority.

If you have a complain about the use of your personal information, please let a member of staff in your branch or in the dial-a-bet team know, giving them the opportunity to put things right as quickly as possible. If your wish to make a complaint you may do so in person, by telephone, in writing and by email. Please be assured that all complaints received will be fully investigated. When making a complaint, we ask you to supply as much information as possible to help our staff resolve your complaint quickly.

You can also contact the Information Commissioner’s Office at www.ico.org.uk

Other useful privacy & data security related matters

Retention

We retain personal information for as long as we reasonably require it for legal or business purposes, your information will not be kept for longer than is needed post account closure. Please note that we may be required in certain circumstances to retain your information indefinitely (for example under our procedures on responsible gambling and self-exclusion). We will take all necessary steps to ensure that the privacy of information is maintained for the period of retention.

Security

We recognise that online security and data protection is an area of vital importance for all our customers, so it is important to us that you have confidence in the security of your personal details before you register an account.

Updates to this notice

We will make changes to this notice from time to time, particularly when we change how we use your information, and change our technology and products

You can always find an up-to-date version of this in all our branches and on our website:

www.abet.com