- Introduction
This Privacy Policy explains how personal data relating to customers, website visitors and other individuals interacting with Napoleons Casino Bradford is collected, used, retained, shared and protected. It applies to all personal data processed in connection with casino and betting services provided by the company.
Personal data is handled in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. This document sets out the obligations of the company as a data controller and the rights of individuals as data subjects.
By using the services of Napoleons Casino Bradford or by providing personal information, you acknowledge that you have read and understood this Privacy Policy.
- Who the Data Controller Is
Napoleons Casino Bradford is the data controller responsible for personal data collected through its premises and any associated digital services.
Questions about the handling of personal data, or requests to exercise data protection rights, should be addressed using the contact details in Section 9 of this document.
Where a Data Protection Officer (DPO) is required to be appointed, the DPO can be contacted using the same details.
- Personal Data Collected
The following categories of personal data are collected and processed, depending on the nature of the interaction with the company:
- Identity data: full name, date of birth, photographic identification
- Contact data: postal address, email address, telephone number
- Financial data: payment information, transaction records
- Account and gaming data: account registration details, gaming history, session records
- Verification and compliance data: documents and information submitted for Know Your Customer (KYC) and Anti-Money Laundering (AML) checks
- Responsible gambling data: self-exclusion records, affordability assessments, deposit limits, time-out requests
- Technical data: IP address, browser type, device identifiers, access logs where applicable
- Communications data: records of correspondence with customer support
Personal data relating to individuals under the age of 18 is not knowingly collected. If such collection is identified, appropriate steps are taken to delete the data without undue delay.
- Purposes and Legal Bases for Processing
Personal data is processed only where a lawful basis under UK GDPR applies. The main purposes and corresponding legal bases are as follows:
Account registration and management
- Legal basis: performance of a contract
Identity verification and KYC checks
- Legal basis: legal obligation
Anti-money laundering compliance
- Legal basis: legal obligation
Responsible gambling monitoring and intervention
- Legal basis: legal obligation; legitimate interests
Fraud prevention and security
- Legal basis: legitimate interests
Customer support and dispute resolution
- Legal basis: performance of a contract; legitimate interests
Direct marketing (where applicable)
- Legal basis: consent
Regulatory reporting to the Gambling Commission
- Legal basis: legal obligation
Analytics and service improvement
- Legal basis: legitimate interests
Where processing is based on consent, that consent can be withdrawn at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before consent was withdrawn.
- Data Retention
Personal data is retained only for as long as necessary to fulfil the purposes for which it was collected, or for as long as required by applicable law and regulatory requirements.
- Account, KYC and transaction records are retained for a minimum of five years following account closure or the end of the business relationship, in line with AML regulatory requirements.
- Customer service records and records relating to disputes are retained for up to five years following resolution.
- Technical logs and security data are typically retained for between six and twenty-four months.
- Marketing and preference data is retained while you remain subscribed and for up to three years following the last interaction with the company, unless consent is withdrawn earlier.
At the end of the relevant retention period, personal data is securely deleted or anonymised so that it no longer identifies an individual.
- Sharing of Personal Data
Personal data is not sold to third parties. Personal data may be shared in the following circumstances:
- With regulatory authorities, including the Gambling Commission, where there is a legal requirement to do so.
- With third-party service providers processing data on behalf of the company, such as identity verification providers, payment processors and IT service providers. Such providers operate under data processing agreements and are not permitted to use personal data for their own purposes.
- With law enforcement agencies or other public authorities where required by law, regulation or court order.
- With other entities within the same corporate group where necessary for operational, compliance or administrative purposes.
Where personal data is transferred outside the United Kingdom, appropriate safeguards are implemented in accordance with UK GDPR requirements.
- Your Rights
Under UK GDPR, individuals have the following rights in relation to their personal data:
- Right to be informed: to receive clear information about how personal data is used, as set out in this policy.
- Right of access: to request a copy of the personal data held about you.
- Right to rectification: to request correction of inaccurate or incomplete personal data.
- Right to erasure: to request deletion of personal data in certain circumstances.
- Right to restriction of processing: to request that the use of personal data is limited in certain circumstances.
- Right to data portability: to receive personal data in a structured, commonly used and machine-readable format and to transmit that data to another controller in certain circumstances.
- Right to object: to object to processing based on legitimate interests, and to object to direct marketing at any time.
- Rights related to automated decision-making: to request human review of any automated decisions that produce legal effects or similarly significant effects.
Requests to exercise these rights should be submitted using the contact details set out in Section 9. A response will be provided within one calendar month of receipt of a valid request. Identity verification may be required before a request can be processed.
If you are not satisfied with the response to a data protection request or with the handling of personal data, a complaint can be lodged with the Information Commissioner’s Office (ICO), the supervisory authority for data protection in the United Kingdom. Further information is available at www.ico.org.uk.
- Responsible Gambling and Data Processing
Napoleons Casino Bradford operates as a licensed gambling operator regulated under the laws of Great Britain. In this context, customer activity is monitored to identify and respond to indicators of gambling-related harm. This includes the processing of behavioural and account data to:
- assess the risk of gambling-related harm
- apply responsible gambling tools and interventions
- comply with obligations set out in the Gambling Commission’s Licence Conditions and Codes of Practice
Personal data processed for responsible gambling purposes, including self-exclusion records and affordability information, is treated with particular care and is not used for marketing purposes.
- Contact Details
Questions about this Privacy Policy, requests to exercise data protection rights, or concerns about the handling of personal data should be directed to:
Napoleons Casino Bradford
Data Protection Enquiries
Bradford, United Kingdom
All privacy-related requests should be submitted in writing. Please include your full name and the email address associated with your account to enable verification of identity and efficient processing of the request.
- Changes to This Policy
This Privacy Policy may be updated from time to time to reflect changes in legislation, regulatory guidance or internal data processing practices. Where material changes are made, appropriate notification measures will be used.
The current version of this Privacy Policy is available on request and is accessible at the premises of Napoleons Casino Bradford.