PRIVACY POLICY - JACKPOTJOY SLOTS

Table of contents

Introduction

  1. Get to know us!
  2. Our Data Protection Officer
  3. What Personal Data do we collect about you?
  4. How we use your Personal Data
  5. Our marketing services
  6. How we share your Personal Data
  7. Keeping your Personal Data safe
  8. Where we process, store and transfer your Personal Data
  9. Data Retention
  10. Your rights
  11. What happens when you consult other websites and/or applications?
  12. Contacting us about this Privacy Policy
  13. Changes to this Privacy Policy

 

Introduction

Welcome to the Privacy Policy of Jackpotjoy Slots!

This Privacy Policy is dated 30th October 2018.

Jackpotjoy Slots respects your privacy and is committed to protecting your Personal Data when you use our application (the “App”) and any related applications of the App (our “Services”). The App is available at the following locations:

This App and the Services are not intended for children and we do not knowingly collect information relating to children.

The law requires us to clearly explain to you who collects your Personal Data, why your Personal Data is being collected, how long your Personal Data will be collected for, how we protect it, how we share it and what your legal rights are in relation to information we hold about you.

We have prepared this Privacy Policy to inform you about how we look after your Personal Data when you access our Services (regardless of where you access them from), and tell you about your privacy rights and how the law protects you.

We know no one likes to read a lengthy document, so we have done the following to make your life easier, helping you to clearly understand how we look after your Personal Data:

We have tried our best to make this Privacy Policy helpful to you but if you have any questions or concerns in relation to its content, please feel free to contact our Data Protection Officer.

 

  1. Get to know us!

Information about our App

This App is operated by joint controllers, Bagelcode Inc. ("Bagelcode") and Circuscode Ltd. ("Circuscode"). Together these constitute the group ("the Bagelcode Group").

Who is the data controller?  

Bagelcode Inc. and Circuscode Ltd. are joint controllers with respect to your Personal Data.

  • Circuscode Ltd. is registered in England and Wales under registration number 11199607. The registered address is 10 Piccadilly, London, W1JODD, England.
  • Bagelcode Inc. is registered in South Korea under registration number 107-87-84490. The registered address is 8F Sewoong Tower, 12 Seolleung-ro 94-gil, Gangnam-gu, 06162, Seoul.
  •  

    1. Our Data Protection Officer

    The Bagelcode Group has appointed a Data Protection Officer (“DPO”) who is responsible for handling questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy and want to know more about how we handle your Personal Data when you use our Services, please contact our DPO as per the following details:

    By mail to:

    The Data Protection Officer

    Circuscode Limited

    10 Piccadilly,

    London, W1J 0DD (UK)

    By email to: dpo@thesecondrow.com

    If you want to know how to exercise your legal rights with respect to the information we hold about you, please see section 10 “Your Rights” below.

     

    1. What Personal Data do we collect about you

    This Privacy Policy aims to give you information about how we collect and process your Personal Data through your use of the Services, including any data you may provide, for example, through our App when you register an account with us, sign up to receive marketing communications from us, or take part in a competition.

    Information that may be used to identify you or relates to you as an individual is Personal Data.

    Personal Data means any information from an individual from which that person can be identified. It does not include information where the identity has been removed, which is Anonymous Data.

    Information you directly provide to us

    You are under no obligation to provide Personal Data. However, certain Personal Data is essential for the provision and quality of the Services offered to you and you might not be able to obtain certain Services if you choose to withhold requested information required for those Services. If you refuse to provide your Personal Data where the law requires us to collect it from you to fulfil our legal obligations, we will not provide you access to our App or Services.

    We collect, use, store and transfer different types of information about you, which we have grouped together below:

    Account:

    If you choose to log in to Facebook to access our Services (upon registration or at a later date), we collect your Facebook ID to form your player ID. We also collect the following information if you grant us permission through Facebook: first name, email address, gender and birth date. If you choose to register for an email account, we collect your email address which is used to form your player ID. If you do not log in to Facebook or register for an email account (and use our services as a Guest), we track your usage of the Services as a Guest using the device ID of the device you access the Services from. We also collect your cellphone number if you provide it to us via a feature in the App, and your address if you provide it to us for competition purposes.

    Transaction data:

    If you use our Services, we collect information about your transactions on our App including: spins, purchases, comps and advertisement views.

    Chat conversations:

    We collect information about your communications on our Services including chat messaging.

    Telephone conversations:

    We collect information about your telephone conversations when you call our Customer Support team to discuss information about your account or your use of our Services. We may record telephone conversations for training and monitoring purposes.

    Email communications:

    We collect and store all copies of emails you send to us when you communicate with us, until retention is considered no longer necessary.

    Social Media Profile:

    We collect your social media profile details including your name, profile photo and other information you choose to make available to us when you connect with or contact us through your social media account, or use our Services through your social media account.

    Aggregated Data:

    We collect, use and share Aggregated Data such as statistical or demographic data for any purpose.

    Connection Data:

    When you connect to our App on Facebook, we collect the following information about your device: operating system, IP address, entry point, browser and software crash reports. When you connect to our App on a mobile platform, we collect the following information about your device: device unique identifier (device ID), device push notification token and/or advertising identifier (if permissions are granted), hardware, operating system, IP address, entry point, browser, software crash reports and remaining memory. We also collect your date/time of access and use of the App on all platforms.

    Information we collect from third parties

    We collect information about you from the following categories of third party service providers:

    Advertising Services:

    We collect information about you from our network of advertisers’ service providers who advertise on and about our App

    Hosting providers:

    We collect information about your use of the Services from our hosting service providers which host our App and Services.

    Analytical providers:

    We collect information about you from our network of analytical providers which provide us tools to understand our audience and improve our App.

    We will use Personal Data obtained via such means in accordance with this Privacy Policy.

    Information we collect from social media services

    We collect information about you when you contact us through your account on social media services such as Facebook, Twitter, etc for various purposes (for example, when you enter a competition, raise a complaint, contact us for information, etc.).

    We also collect information about you if you choose to use our Services on Facebook Inc. When you choose to log into Facebook to use our Services, Facebook provides us with your details (such as account information) for which you have granted permission. You should read Facebook Inc. Privacy Policy and Terms of Service to understand how you share your information when using their services.

     

    1. How we use your Personal Data

    Legal basis

    We will only use your Personal Data when required, by laws applicable to us. Most commonly, we (including our employees) will use your Personal Data in the following circumstances:

    See the table below to find out more about the types of lawful basis we rely on to process your Personal Information.

    Purposes for which we use your Personal Data

    We have set out below, in a table format, a description of all the ways we use your Personal Data, and which of the lawful bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

    Please note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your information. Please contact our DPO as per the instructions in section 2 above if you need details about the specific legal ground we are relying on to process your Personal Information, where more than one ground has been set out below.

    Purpose

    Type of Data

    Lawful basis for processing

    To register you as a new user on our App

    Identity and contact details (User Account)

    Entering into and performing a contract with you

    To manage our relationship with you as a user of the App, including notifying you about changes to our App Terms and Conditions or Privacy Policy

    Identity and contact details

    Usage

    Profile

    Entering into and performing a contract with you

    To comply with our legal obligations

    As necessary for our legitimate interest (to keep our records updated and to study how customers use our App and Services)

    For you to provide, and us to receive, feedback and reviews of our games and services

    Identity and contact details

    Profile

    and opinions provided by you in connection with feedback and surveys

    Entering into and performing a contract with you

    As necessary for our legitimate interests (to study how customers use our App and Services and to understand the improvements that can be made to our App and Services). Your participation in this is entirely voluntary.

    To enable you to partake in competitions and promotions

    Identity and contact details

    Profile

    Entering into and performing a contract with you

    To provide various supporting customer services to you (such as where you contact us with a question in connection with the App and/or request certain information from us)

    Identity and contact details

    Profile

    As necessary for our legitimate interests (to deal with customer service requests and respond to communications)

    If you do not provide us with the Personal Information we request from you for customer services purposes, we may not be able to fully answer your queries

    To administer and protect our business and the App (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

    Identity and contact details

    Usage

    Aggregated Data

    Connection Data

    As necessary for our legitimate interests (to run our business, administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

    As necessary to comply with a legal obligation

    To improve our App, products/services, customer relationships and experiences. 

    Aggregated Data

    Connection Data Usage

    As necessary for our legitimate interests (to define types of customers for our games and services,  to keep our App updated and relevant, to develop our business and to inform on our marketing strategy)

    To send you marketing communications (including gifting)

    Identity and contact details

    As necessary for our legitimate interests (to provide you with a personalised experience and improve our App and Services)

    When you give consent to us.

    To manage purchases and credit your account

    Identity and contact details

    Purchase history

    Entering into and performing a contract with you

    To comply with our legal obligations

    To deliver relevant App content and advertisements to you and measure the effectiveness of the content and advertising we serve to you.

    Identity and contact details

    Profile

    Usage

    Marketing and Communications Data

    Aggregated Data

    Connection Data

    As necessary for our legitimate interests (to study how players use our Services, to grow our business and to inform on our marketing strategy)

    To use data analytics to improve our App and Services, marketing, customer relationships and experiences.

    Aggregated Data

    Connection Data

    As necessary for our legitimate interests (to define categories of users for our App and Services, to keep our App updated and relevant, to develop our business and to inform our marketing strategy).

    To make suggestions and recommendations to you about our products on our App and Services that may be of interest to you

    Identity

    Contact details

    Aggregated Data

    Connection Data

    Profile

    Social Media Profile

    As necessary for our legitimate interests (to develop our Services and grow our business).

    To protect our business from fraud and other illegal activities

    Identity

    Contact details

    Aggregated Data

    Connection Data

    Profile

    Social Media Profile

    As necessary for our legitimate interests (to protect our business from any illegal use of our Services).

    To comply with our legal obligations

     

    1. Our marketing services

    Marketing communications for the App

    As a user of our App, you can tell us whether or not you wish to be contacted for marketing purposes and, if so, how we can contact you.

    We may use your Personal Information to offer you personalised experiences on our App.

    Marketing communications may contain details about:

    You can choose to opt-in to receive marketing communications about the App from Jackpotjoy Slots via the following channels:

    You can opt-out from receiving marketing communications about the App from Jackpotjoy Slots at any time, by following the instructions below:

    When you choose to opt-out from email, SMS or phone marketing channels for the App, you will stop receiving marketing communications within 72 hours.

    When you decide to opt-out from receiving post marketing for the App, please be aware it may take up to 28 days for your request to take effect.

     

    1. How we share your Personal Data

    Sharing your Personal Data within the Bagelcode Group

    Your Personal Data will be disclosed to companies in the Bagelcode Group in accordance with the terms of this Privacy Policy. All employees of the Bagelcode Group (including contractors, staff or consultants, which are subject to similar obligations of confidentiality as those imposed on employees of the Bagelcode Group) may share your Personal Data within our group of companies, and with its advisors (for audit, legal and compliance purposes), for the following reasons:

    Sharing your Personal Data with our services providers

    We use service providers for the operation of our App and Services to ensure we deliver the best possible services. We enter into contracts with our service providers, ensuring they deliver the same high level of service as us, and protect any of your Personal Data shared for the required purpose. We are committed to protecting your Personal Data and we obligate our service providers to handle your Personal Data in accordance with applicable data protection laws and with the terms of this Privacy Policy.

    We engage with our service providers for the following services (whether carried out on a full or part time basis):

    Sharing your Personal Data with statutory authorities

    We will share your Personal Data when it is required by applicable law in the following cases:

    Sharing your Personal Data in other circumstances

    The Bagelcode Group may transfer your Personal Information to another company if it restructures its business. The Bagelcode Group may transfer your Personal Information to a third party if the operator of the App changes, or if there is a sale of all or any part of its business or its assets. In the event of any of these transfers occurring, the party who acquires the data will assume the rights and obligations described in this Privacy Policy.

     

    1. Keeping your Personal Data safe

    What we do to keep your Personal Data safe

    We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We follow security standards and requirements of applicable law. Where possible, we employ encryption, pseudonymisation and anonymisation solutions to reduce the impact of any security incident to your Personal Data.  In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.

    Managing a security incident to Personal Data

    We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

    If you have any reason to believe that your account information may no longer be secure, please contact our DPO as per the instructions in section 2.

    Keeping your user account safe

    When you create an account with us and choose to log in to your Facebook account, your Facebook credentials will always be required to ensure your account is secure and can only be accessed by you. If you register for an email account, we ask you to choose a password to retrieve access to your account. We have deployed security measures with the use of password protection to ensure your user account is secured at all times and can only be accessed by you. You must keep your username and password details private and confidential at all times. If you do not connect to Facebook or register for an email account (and use our Services as a guest), your account can only be accessed from the device you registered on.

    Transmission and storage of your Personal Data

    Unfortunately, the transmission of information via the internet is not completely secured. Although we have deployed security measures to protect the transmission of your Personal Data when you use our Services, according to applicable security standards and practices, we cannot guarantee the security of your Personal Data as it is transmitted and stored.

     

    1. Where we process, store and transfer your Personal Data

    We primarily process your User Account data within the EU/EEA, and we use data storage servers located in the EU/EEA and the USA. We transfer your Personal Data outside the EU/EEA when:

    Where we transfer your Personal Data outside of the EEA, if such transfer is made to a country with less stringent data protection laws, we will ensure an adequate protection of your Personal Data.

    Third party service providers

    For our Services, we rely on certain external third party service providers which are based outside the EEA, so their processing of your Personal Information will involve a transfer of data outside the EEA. We always ensure your Personal Data is protected by ensuring our third-party service providers follow the same rules as us when processing your Personal Data.

    Whenever we transfer your Personal Information out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

    For further details on this safeguard, see European Commission: Adequacy of the protection of Personal Information in non-EU countries

    For further details on this safeguard, see European Commission: Model contracts for the transfer of Personal Information to third countries

    For further details on this safeguard, see European Commission: EU-US Privacy Shield

    If you want further information on the specific mechanism used by us when transferring your Personal Information out of the EEA, please contact our DPO as per the instructions provided in section 2 of this Privacy Policy.

     

    1. Data Retention

    We will not keep your Personal Data for longer than required. We will only retain your Personal Data in the following situations:

    1. If required by law;
    2. If necessary to allow us to fulfil the reasons we collected it for;
    3. Until we no longer have a valid reason for keeping it;
    4. As necessary for us to comply with any legal, accounting or reporting requirements our organisation may be subject to;
    5. Until you request us to stop using it when you exercise your legal rights as described in section 10

    We retain your account records of all gameplay and transactions, together with any identification provided, for as long as is necessary for the relevant service, and for no longer than 7 years following lapse of play or closure of your account.

    The duration for which we keep your Personal Data when you have a live user account with us can vary and depends on various reasons. To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data, whether we can achieve those purposes through other means, and what the law requires us to do.

    When we no longer need to keep your Personal Data, we either delete it securely, or fully anonymise it for analytics purposes. These processes are carried out in accordance with applicable security standards and cannot be reversed, so the data can never be linked back to an individual.

    Please note that if you decide to opt-out from receiving marketing communications from us (as per the instructions provided in section 5 above), we will need to retain a copy of your contact details so we can add them to a marketing suppression list. If you choose to exercise your rights (as per instructions provided in section 10 below), we will retain minimal identity and contact details for audit purposes.

    Details of retention periods for different aspects of your Personal Data are available in our data retention policy which you can request from us by contacting the DPO as per the instructions provided in section 2 above.

     

    1. Your Rights

    The law gives you legal rights in respect of the information we hold about you, and we will respect your legal rights in relation to your Personal Data. You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights), unless your request is unfounded, repetitive or excessive, where we may charge a reasonable fee. Alternatively, we may refuse to comply with your request in these circumstances. We may need to request specific information from you from time to time to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one month of receipt. Occasionally it may take us longer than one month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

    Below is a summary table of the legal rights you have under law and what we do to protect them:

    Your legal rights

    What we do to protect your legal rights

    How to exercise your legal rights

    Your right to be informed:

    The Bagelcode Group is publishing this Privacy Policy to keep you informed as to what we do with your Personal Data. We strive to be transparent about how we use your Personal Data.

    You can access this Privacy Policy on our App and contact our DPO as per the instructions in section 2 above if you have any questions or concerns about how we handle your Personal Data.

    Your right to access your Personal Data:

    You have the right to access your information. This right enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.

    You can request access to your Personal Data by email to datarequest@thesecondrow.com, with subject ‘Access’. To speed up your request please include the name of the game, your Player Id (found in your game settings) and a brief summary of what you would like to access. If you are unsure, just let us know and we will provide details of the Personal Data we hold about you. Note that occasionally our responses may be filtered to your junk or spam folders.

    Your right to correct your Personal Data:

    You have the right to request rectification of the personal information we hold about you. This right enables you to request rectification of any Personal Data you believe to be inaccurate or incorrect. Note that certain Personal Data is required for the operation of the App. If you request rectification of Personal Data required for the operation of the App, we will notify you that your request will require an account deletion. Your original data may remain in our logs and/or backups for up to 60 days following the completion of your request, though this data is for operational purposes only and will not be processed.

    You can request rectification of your Personal Data by email to datarequest@thesecondrow.com, with subject ‘Amend’. To speed up your request please include the name of the game, your Player Id (found in your game settings) and a brief summary of what you would like to rectify. If you are unsure, just let us know and we will provide details of the Personal Data we hold about you. Note that occasionally our responses may be filtered to your junk or spam folders.

    Your right to erase your Personal Data:

    You have the right to request erasure of your Personal Data. This is also known as the right to be forgotten. This enables you to request deletion of your Personal Data where there is no good reason for us continuing to process it. You also have the right to request deletion of your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your Personal Data to comply with local law. Note however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. Also note that certain Personal Data is required for the operation of the App. If you request erasure of Personal Data required for the operation of the App, we will notify you that your request will require an account deletion. The erasure process will require a temporary ban to be placed on your account, during which access to the App will not be possible. Your Personal Data may remain in our logs and/or backups for up to 60 days following the completion of your request, though this data is for operational purposes only and will not be processed.

    You can request erasure of your Personal Data by email to datarequest@thesecondrow.com, with subject ‘Erase’. To speed up your request please include the name of the game, your Player Id (found in your game settings) and a brief summary of what you would like to erase. If you are unsure, just let us know and we will provide details of the Personal Data we hold about you. Note that occasionally our responses may be filtered to your junk or spam folders.

    Your right to object to the processing your Personal Data:

    You have the right to object to the processing of your Personal Data. You have a right to object where we are relying on a legitimate interest (or those of a third party) and you feel this processing impacts your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

    You can exercise your right to object to the processing of your Personal Data by email to datarequest@thesecondrow.com, with subject ‘Object’. To speed up your request please include the name of the game and your Player Id (found in your game settings). Note that occasionally our responses may be filtered to your junk or spam folders.

    Your right to request restriction of the processing of your Personal Data:

    You have the right to request restriction of the processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

    You can exercise your right to request the restriction of processing of your Personal Data by email to datarequest@thesecondrow.com, with subject ‘Restrict’. To speed up your request please include the name of the game, your Player Id (found in your game settings) and a brief summary of what you would like us to restrict processing. If you are unsure, just let us know and we will provide details of the Personal Data we hold about you. Note that occasionally our responses may be filtered to your junk or spam folders.

    Your right to request the transfer of your Personal Data to you or to a third party:

    You have the right to request the transfer of your Personal Data to you or to a third party. This is known as the right to data portability. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use, or where we used the information to perform a contract with you.

    You can request the transfer of your Personal Data by email to datarequest@thesecondrow.com, with subject ‘Transfer’. To speed up your request please include the name of the game, your Player Id (found in your game settings) and a brief summary of what you would like to transfer. If you are unsure, just let us know and we will provide details of the Personal Data we hold about you. Note that occasionally our responses may be filtered to your junk or spam folders.

    Your right to complain to the regulator:

    If you are unhappy with our response to your query, you have the right to contact the Information Commissioner (the data protection authority for the UK).

    To exercise your right to complain to the regulator please use the following contact details:

    1.     Website: www.ico.org.uk

    2.     Telephone: 0303 123 1113

    3.     Postal address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

    Your right to withdraw consent:

    You can decide to withdraw your consent at any time and for free.

    To exercise your right to withdraw your consent, you need to update your preferences in your App settings, Device settings or Facebook settings, as explained in section 5.

     

    1. What happens when you consult other websites and/or applications?

    The App may contain links to other websites and/or applications, where information practices may be different to ours. Visitors should consult the other websites’ and/or applications’ privacy notices, as we are not responsible for, and have no control over information that is submitted to, or collected by, these websites and/or applications.

    We may use a reputable third party to present or serve the advertisements that you may see on the App. This Privacy Policy does not cover use of information that a third-party ad server may have collected from you.

     

    1. Contacting us about this Privacy Policy

    If you have any questions or comments about this Privacy Policy, or want to know more about how we use your Personal Data (e.g. information about how we apply our legitimate interests), please contact the DPO as per the instructions provided in section 2 of this Privacy Policy.

    If you want to exercise your right to access your Personal Data, please email us at datarequest@thesecondrow.com as per the instructions in section 10 above.

     

    1. Changes to this Privacy Policy

    We may, from time to time, change or update this Privacy Policy. All changes to this Privacy Policy will be published on this page of the App. Each change will become effective on publication. We recommend that you revisit and read this Privacy Policy regularly to ensure that you are up-to-date with the current terms.