Ladbrokes Coral and its group companies are committed to protecting and respecting your privacy.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
Information we may collect from you
We will collect and process the following data about you either from your use of our site, or when you come into our stores:
Information you give us. This is information about you that you give us by filling in forms on our site / in person or by corresponding with us by phone, face-to-face, e-mail or otherwise and includes information you provide when you register to use our site or sign up to use our services in-store, subscribe to any of our services, use the services provided by our site or certain third party services, when you provide us with information requested by us for the verification of your identity, information submitted as part of any promotions, competitions, betting opportunities, games or contests in which you participate, when you report a problem with our site or submit an in-store complaint. You may also give us information in the course of business, where you are a sole trader or a company representative. The information you give us may include your name, address, date of birth, gender, e-mail address, user name and password, phone number, details of any comments you provide to us and financial and credit card information. Other information you give us may include feedback regarding our services, our stores or our sites and responses to surveys and/or market research (although you do not have to respond to such surveys or requests). The information you give us may also include information relevant to a job application (including contact details, references, CV's, application forms, criminal background checks and diversity data. We may also collect and process records of any correspondence and communications with us and telephone calls may also be recorded.
Information we receive from other sources. To comply with our regulatory obligations we will complete our own due diligence or use third party providers to assist us with background / identity or financial verification checks and may also receive information from our regulators (or third parties operating in our sector) in respect of barred / self-excluded customer lists. Personal information may also be provided to us from online vendors, service providers who refer you to our sites or services, from customer lists lawfully acquired from third party vendors and from other third parties who work with us in connection with our sites or services. Personal information may also be provided to us by third party sources in the context of job applications (including criminal record checks and references). Third-party service providers may, without limitation, be appointed to provide technical support, process your transactions and maintain your accounts or to run promotions or marketing campaigns. We may have access to any personal information provided to such vendors, service providers and third party e-commerce services.
HOW WE USE YOUR INFORMATION
We use information held about you in the following ways:
Please note we will not use any financial or credit card information for any purpose other than to discharge our legal / regulatory duties and to process payments by you for our products and services or due to you by agreement.
USING YOUR INFORMATION IN ACCORDANCE WITH DATA PROTECTION LAWS
Compliance with legal obligations: As a regulated entity, each data controller (as set out above) is obliged to comply with applicable guidance provided by any relevant regulatory body and has obligations under applicable legislation, including gambling, betting and gaming law and anti-money laundering/ fraud legislation. In particular, we will need to process your personal information to verify your identity, establish your age and your source of funds for the purposes of combatting money laundering, fraud, terrorist financing, bribery, corruption, tax evasion, the provision of financial or other services to persons who may be subject to economic or trade sanctions and to establish whether you have self-excluded or have been barred from any of our shops or from using our services (or those of other gambling operators). Failure to provide the requisite personal information on sign-up / as you use our site or services, will unfortunately mean we cannot provide our services to you, as to allow you to use our service would mean we would be in breach of our legal obligations. You will not be able to object to processing or ask for the deletion of your personal information insofar as it falls under this category.
Necessary for the entry into / performance of a contract: When you enter into a transaction with us, a contract between you and us will have been entered into. In order for us to fulfil our obligations under such contract (e.g. to allow you to place a bet and pay out winnings), we will need to collect and process your personal information. Failure to provide the requisite personal information on sign-up and financial information on entering into the transaction or objecting to this type of processing / exercising your deletion rights will unfortunately mean we cannot provide our services to you. This will also be the case where you (as a sole trader) or the business you work for has entered into a contract with us and we need to process your information in order to manage and administer such contract.
Consent: We may send you marketing messages across our platforms such as email, text messages, telephone, direct mail, inbox messaging, push notifications about us and our site, stores, services and offers where you have not unsubscribed or managed through the preference centre, and where you have placed a bet or purchased other services from us. We provide easy ways to stop our marketing, and you can opt out at any time.
If you are not a customer of ours but have provided us with consent to use your details for marketing purposes, then we may also contact you about our site, stores, services and offers.
If you have confirmed that you would like to hear from us about other party’s goods and services then we will use your details to contact you with marketing information about such party's goods and services.
If you have confirmed that you would like to hear directly from a third party (including other members of our Group) about such party’s goods and services then we will share your details with such third party so they can contact you about their goods and services.
In each of the situations above, you have the right to withdraw your consent at any time and can object to processing of this nature. Where you consent to us sending you marketing information, we will treat this as lasting for 24 months unless we tell you otherwise at the time.
We may also use consent as a basis for processing some of your personal information in respect of job applications, for example in carrying out criminal records checks. In some cases, we may do this without your consent if it is necessary for a particular role.
HOW LONG WE KEEP YOUR INFORMATION FOR
When your data is no longer required for the purposes listed above, we will delete it within the periods set out below:
Marketing consents will be refreshed/deleted after 24 months;
Call recordings will typically be deleted after 19 months;
CCTV will typically be deleted after 90 days;
Unsuccessful job applications will typically be deleted after 6 months;
Business contact details will typically be deleted once our relationship (i.e. our contract) has come to an end.
Successful job applications will be kept as part of the employee file, which is held for the duration of the employment plus 6 years.
Any other information will typically be deleted within 10 years from the data of our last positive interaction with you. We may keep your personal information for up to 10 years, to enable us to retain the information we may require for legal and regulatory purposes.
If you are not a customer and we have collected information about you, this will be deleted within 3 months (provided we do not need to keep it for regulatory purposes e.g. barred / fraudulent customers).
Disclosure of your information
We may disclose your personal information to any member of the Ladbrokes Coral Group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 ("Ladbrokes Coral Group").
We will only share your personal information with other members of the Ladbrokes Coral Group for marketing purposes where you have expressly opted-in/consented to the disclosure of your personal data for these purposes.
We will only disclose your information to:
business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
our affiliates and selected third parties, where you have expressly opted-out of receiving marketing from us / third parties, have been barred or self-excluded, in which case we may share suppression lists with our affiliates and selected third parties, to ensure you do not receive unsolicited marketing;
members of the Ladbrokes Coral Group and third party suppliers and service providers for the purposes listed under HOW WE USE YOUR INFORMATION above;
third party suppliers and service providers to the extent they assist the Ladbrokes Coral Group with its legal / regulatory obligations e.g. providers of services in respect of anti-money laundering, fraud, verification etc.;
selected third parties so that they can contact you with details of the services that they provide, where you have expressly opted-in/consented to the disclosure of your personal data for these purposes;
analytics and search engine providers that assist us in the improvement and optimisation of our site and other selected third parties;
other gambling operators, banks, credit card companies, ESP's (defined below) and appropriate agencies for the purpose of investigating and safeguarding against underage, fraudulent, criminal or suspicious activity (or other activities we are bound by law, regulation or guidance to investigate and safeguard against) or if we have reason to believe that you have undertaken such activity; and
our regulators, law enforcement or fraud prevention agencies, as well as our legal advisers, courts, applicable independent adjudication services, sports' governing bodies and betting integrity organisations and any other authorised bodies, for the purposes of investigating any actual or suspected criminal activity or other regulatory or legal matters etc.
We will disclose your personal information to third parties:
in the event that we consider selling or buying any business or assets, in which case we will disclose your personal data to any prospective sellers or buyers of such business or assets;
in the event of any insolvency situation (e.g. the administration or liquidation) of Ladbrokes Coral Group plc, or a data controller or any of its group entities;
if we, or substantially all of our assets, are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;
to protect the rights, property, or safety of us, our staff, our customers, or others. This includes exchanging information with other companies and organisations (including without limitation, other gambling operators and the local police or other local law enforcement agencies) for the purposes of staff and customer safety, crime prevention, fraud protection and credit risk reduction; and
if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or regulatory requirements, or otherwise for the prevention or detection of fraud or crime.
THE USE OF IESNARE TECHNOLOGY
We use iesnare cookies which collect your IP address along with certain device information. For more information on the use of iesnare cookies and cookies generally, please see our cookies policy [cookies policy to be hyperlinked].
Where we store your personal data
In order to ensure fair and transparent processing, we will, taking into account our processing activities, adopt appropriate procedures for the processing of personal data, which shall include implementing technical and organisational measures which take into account the harm that may be suffered, and correct inaccuracies identified in personal data processed, so that risk of errors are minimised and your personal data is processed in a fair and secure manner.
All information you provide to us is stored on our secure servers. 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.
From time to time, service providers, members of the Ladbrokes Coral Group and organisations with whom we work, may be located outside the European Economic Area in countries that do not have the same standards of protection for personal data as the UK. We will, however, always use every reasonable effort to ensure sufficient protections are in place to safeguard your personal data. We will also ensure that our service providers enter into compliant processing agreements with us to ensure that your personal data is processed in accordance with applicable data protection legislation.
You have a number of rights under data protection law in relation to the way we process your personal data. These are set out below. You may contact us using the details on our site (or by contacting our DPO directly – details below) to exercise any of these rights, and we will respond to any request received from you within one month from the date of the request.
DESCRIPTION OF RIGHTS
Right 1: A right to access personal data held by us about you.
Right 2: A right to require us to rectify any inaccurate personal data held by us about you.
Right 3: A right to require us to erase personal data held by us about you. This right will only apply where (for example): we no longer need to use the personal data to achieve the purpose we collected it for; or where you withdraw your consent if we are using your personal data based on your consent; or where you object to the way we process your data (in line with Right 6 below).
Right 4: In certain circumstances, a right to restrict our processing of personal data held by us about you. This right will only apply where (for example): you dispute the accuracy of the personal data held by us; or where you would have the right to require us to erase the personal data but would prefer that our processing is restricted instead; or where we no longer need to use the personal data to achieve the purpose we collected it for, but you require the data for the purposes of dealing with legal claims.
Right 5: In certain circumstances, a right to receive personal data, which you have provided to us, in a structured, commonly used and machine readable format. You also have the right to require us to transfer this personal data to another organisation, at your request.
Right 6: A right to object to our processing of personal data held by us about you where the processing of such data is necessary for the purposes of our legitimate interests, unless we are able to demonstrate, on balance, legitimate grounds for continuing to process personal data which override your rights or which are for the establishment, exercise or defence of legal claims.
Right 7: A right for you not to be subject to a decision based solely on an automated process, including profiling, which produces legal effects concerning you or similarly significantly affect you.
Right 8: A right to withdraw your consent, where we are relying on it to use your personal data (for example, to provide you with marketing information about our services or products).
If you have any concerns regarding our processing of your personal data, or are not satisfied with our handling of any request by you in relation to your rights, you also have the right to make a complaint to our lead supervisory authority, which is the UK's Information Commissioner's Office. Their address is:
First Contact Team
Information Commissioner's Office
If you are based in a jurisdiction outside of the UK you may also choose to contact your local supervisory authority. Details of supervisory authorities located in the main countries in which we operate are set out below:
Jurisdiction: Gibraltar Supervisory authority: Gibraltar Regulatory Authority,
1 Europort Road,
Jurisdiction:Belgium Supervisory authority:Data Protection Authority ,
(“Gegevensbeschermingsautoriteit” / “Autorité de protection des données”,
Drukpersstraat 35 Rue de la Presse,
Jurisdiction: Republic of Ireland Supervisory authority:Data Protection Commissioner,
Jurisdiction: Germany Supervisory authority:
Jurisdiction: Jersey Supervisory authority: Office of the Information Commissioner,
Jurisdiction: Guernsey / Alderney Supervisory authority:Office of the Data Protection Commissioner,
Guernsey Information Centre,
St. Peter Port,
Jurisdiction: Italy Supervisory authority:
Garante per la protezione dei dati personali,
Piazza di Monte Citorio, 121,
00186 Roma RM
Jurisdiction:Spain Supervisory authority: Spanish Data Protection Agency,
C/ Jorge Juan, 6,
ARE YOU A SOLE TRADER/PARTNERSHIP OR AN INDIVIDUAL COMMUNICATING WITH US FROM A BUSINESS?
This policy was last reviewed and updated: 27 April 2018