We are bound by data protection and privacy laws. Under data protection and privacy laws Broadway Gaming Ltd. is a data controller of Your personal data. Data controller is a legal term used in the General Data Protection Regulation to signify the person who controls what to do with any given personal data.
1.2 During the registration process and when You subsequently use Your Broadway Gaming Ltd. Account, You may be asked to submit specific personal data including, but not limited to, Your first and last name, date of birth, gender, credit card or other payment data, home or another physical address, e-mail address, phone/mobile number or other contact data. In addition, You will be asked to create a unique user name and password combination for Your Account. This information is required to be able to access Our Services.
1.3 Once You have created an Account and have become a Broadway Gaming Ltd. Customer, additional information is processed on an on-going basis to ensure that Our Services are offered to You in the best possible manner. You must use Your unique password to access Your Account. It is Your responsibility to ensure the security of Your password and not to reveal this information to others. If You are concerned that a third party is aware of Your user name and password, please contact Our customer support via Live Chat or email firstname.lastname@example.org immediately.
1.4 Much of the personal data We request from You is essential for the provision of the Services to You (for example, enabling You to play the games on Our Website) or is required in order for Us to comply with Our legal obligations. It will be made clear to You when information We request is mandatory. We will not be able to provide You with Our Services or allow You to create an Account with us if You choose to withhold requested information.
1.5 When You are logged into Your Account, Broadway Gaming Ltd. may collect:
1.5.2 a record of all wagers and game play activity;
1.5.3 technical information relating to the device, such as device identifier, and browser You use to access Our Website;
1.5.4 details of transactions You carry out through the site, such as payments, withdrawals and wagers;
1.5.5 communications with us or Our employees, for examples calls, emails, and messages sent through the live chat service;
1.5.6 information regarding Your location, including IP address;
1.5.7 any additional information You submit through Website for example on forums, chat rooms, comment sections or in response to quizzes and questionnaires;
1.5.8 in certain instances, We may also request that You send us additional information to verify Your identity. This may include copies of photographic identification documents, proof of address, and source of funds for Your Account. Your documents are stored and treated in a secure manner at all times.
1.7 To protect both You and Us, We use Services provided by third parties to help us decide whether to accept transactions from You by verifying Your age, identity and address and by assessing Your method of payment, and the devices You use to visit Our Website. These third-party Services check that Your identification documents are legitimate and check whether the device or method of payment has been identified with fraudulent or abusive transactions in the past, such as reported instances of identity theft, Promotion abuse or credit card fraud. These third parties also provide information relating to any self-exclusion You may have undertaken.
2. How We Use Your Information2.1 We use the information We collect to provide, maintain, protect and improve Our Services, to develop new ones and to protect Broadway Gaming Ltd. and You. We also use this information to offer You tailored content such as giving You more relevant Promotional offers.
2.2 We process Your personal data for the purposes of:
2.2.2 providing You with Our Services;
2.2.3 if necessary, contacting You via Your registered contact information in connection with the management and operation of Your Account;
2.2.4 Protecting Your personal information;
2.2.5 processing Your online financial and wagering transactions;
2.2.6 researching Your preferences, to develop new features, functionality, products and Services;
2.2.7 providing You with timely customer support;
2.2.8 ensuring Our Website functions correctly and identifying any technical issues;
2.2.9 complying with all Our legal and regulatory requirements, such as those relating to the identification of individuals under anti-money laundering legislation and ensuring responsible gambling;
2.2.10 complying with legal requirements for geo-restriction of gambling Services;
2.2.11 preventing fraudulent activity or cheating;
2.2.12 development of player profiles and algorithms to improve sales and marketing performance;
2.2.13 determining what Promotions and bonuses to offer You;
2.2.14 analysing Website traffic; and
2.2.15 providing You, unless You have not opted in, or subsequent to that, have opted out, with information by the contact methods You authorise us to use about Our, and selected third party Services, products, competitions, prizes and offers.
2.4 Any commercial analysis performed is solely for Our benefit and is not transmitted to any third party provided; however, that We reserve the right to transmit any personal data to third parties in a manner consistent with legal and regulatory requirements such as for e.g., fraud, anti-money laundering purposes and the like.
3. Who We Share Your Data With3.1 Certain trusted third party companies provide Services essential to Our ability to offer Our gambling products to You, for example those that supply the software and games for Our Website, banking and payment Services, one or more entities in our corporate group, identity verification (such as verification service providers), fraud prevention and risk management. We may be required to share some of Your information with these companies to be able to offer Our Services to You. In these instances, We ensure that the third party has appropriate security and privacy arrangements in place, so that Your data is protected.
3.2 Broadway Gaming Ltd. may also be required to disclose Your information to government authorities, such as the police or Our regulators (including the Malta Gambling Authority and the Gambling Commission of the United Kingdom or to any other government regulator pursuant to a proper request therefrom), to comply with Our legal obligations and the requirements of Our gambling licences, including for anti-money laundering purposes.
3.4 In the event of the completed sale of Our business, or other business event which results in us having to transfer Your personal data to a third party, You will be notified via email, or notice posted on Our Website, to explain the identity of the new data controller and Your options regarding Your personal data.
3.5 Our site may contain links to and from the websites of third party organisations. Please note that these websites may have their own privacy policies and that We do not accept any responsibility whatsoever for these policies. Please check these policies carefully before You submit any personal data via those websites.
4. Our Lawful Bases for Processing Your Personal Data4.1 Our processing of Your personal information will be where:
4.1.2 You have provided Your consent (e.g., for Us to send You marketing);
4.1.3 it is necessary for Us to comply with legal obligations that We are under (e.g., to enable Us to comply with fraud, anti-money laundering and gambling legislation);
4.1.4 for reasons of substantial public interest (which may be relevant if You self-exclude); or
4.1.5 it is in Our (or a third party's) legitimate interests and such interests do not prejudice Your rights or freedoms.
4.2.2 Combating crime (e.g., anti-fraud, anti-money laundering, etc) which could also include Our requirement to comply with legal obligations, for instance, under money laundering regulations and legislation;
4.2.3 Detecting and preventing player game fraud and abuse, bonus abuse, in game abuse;
4.2.4 Financial information (such as credit card or bank Account numbers) in connection with a transaction;
4.2.5 Actions that are part and parcel to provision of Services such Account creation, Account functionality, access to gambling, payment processing and customer services;
4.2.6 Commercial purposes including marketing, personalisation of offers, VIP management, trading decisions, Website optimisation, credit worthiness, Promotions and bonuses, loyalty programmes, value profiling and risk management such as Promotional controls and stake factoring and customer retention;
4.2.7 Social responsibility (i.e., minimisation of gambling related harm);
4.2.8 Our enablement to benefit from the Services and expertise of third party Services providers;
4.2.9 Regulatory and statutory requirements, such as, as above combating crime, plus specific know-your-customer issues such as location, device used, and the like, which might be needed to comply with the Gambling Commission's Licence Conditions and Codes of Practice); and,
4.2.10 Transmission of customer data within Our corporate group for the purposes of internal administration.
5. Marketing, Opting In and Opting Out5.1 Broadway Gaming Ltd. reserves the right to process personal data for marketing purposes and in certain limited circumstances to provide this to Our third-party partners for the purpose of marketing Broadway Gaming Ltd.'s Services to You.
5.2 We request Your consent to market to You when You first create an Account with Us. Thereafter, You can choose not to receive marketing/Promotional material at any time by clicking the unsubscribe link from Promotional material being received, by changing Your preference settings in “My Account” or by contacting Us at email@example.com.
5.3 If You have not opted in, or subsequently thereafter have opted out of marketing from us, We will take all reasonable steps to ensure You no longer receive Promotional material about Butlers Bingo. Please note that this may mean You no longer receive information about Promotional bonuses.
6. Access to Your Information and Your Rights6.1 You have the following rights in relation to Your personal information:
6.1.2 a right to access Your personal information in machine-readable format and to request that We transfer this to a third party data controller;
6.1.3 a right to object to processing that is likely to cause or is causing damage or distress;
6.1.4 a right in certain circumstances to have inaccurate personal data rectified, blocked, erased or destroyed, but this right is not absolute, for example specific gambling and/or licensing regulations may require Us to retain certain personal data about You);
6.1.5 a right to object to decisions being taken by automated means;
6.1.6 a right to claim compensation for damages caused by a breach of data protection legislation;
6.1.7 a right to object to Us using Your personal data for direct marketing purposes, including profiling (for more information about how to unsubscribe from marketing please see section 5 above);
6.1.8 where We make it clear that We are relying on consent to process Your personal data (such as for marketing purposes) You will have the right to withdraw consent at any time. You can exercise this right by emailing Us (or in respect of direct marketing by using the unsubscribe feature described out above). This will not affect or undo any instances where We have already lawfully used or shared Your information prior to You withdrawing Your consent;
6.1.9 a right to lodge a complaint to data protection supervisory authorities (for example in the UK this is the Information Commissioner's Office and in Ireland this is the Data Protection Commissioner); and
6.1.10 a right to object to processing based on legitimate interests if You believe that Your particular situation means that Your rights and freedoms are unduly prejudiced(for further information see section 4.3 above).
6.3 You can help Us to maintain the accuracy of Your information by notifying Us of any change.
6.4 Should You require additional information about how to exercise Your rights please write to firstname.lastname@example.org.
7.2 Cookies perform various different functions. For example, some cookies are session cookies, which are downloaded to Your device temporarily for the period that You browse a particular Website; these cookies will allow You to navigate between pages more efficiently or enable Website to remember the offers are eligible to receive. Other cookies are persistent cookies, which can be used to help Website remember You as a returning visitor or ensure the online adverts You receive are more relevant to Your specific needs and interests.
7.4 Broadway Gaming Ltd. will place cookies on Your device using pseudoanonymized data to make full use of the functionality and Services on Our Website and to allow Your browser to identify You as a user. These cookies enable Our Website to store sufficient data to reduce the number of times You will need to re-enter this information each time You visit a Broadway Gaming Ltd. site. These cookies cannot be used to run programs or deliver viruses to Your computer, and are uniquely assigned to You. These cookies can only be read by the web server(s) that placed the cookies on Your device.
7.5 Cookies are an integral part of providing the Service We deliver to You through Our Website. Should You amend Your browser settings to block some or all cookies from Us We will not be able to provide Services to You and, if it persists, close Your Account. Without cookies from Us, some or all the Website’s functions may not perform as intended and the operation of some games will be negatively impacted and may not work at all.
7.6 Some examples of the types of cookies used by Broadway Gaming Ltd. include, but are not limited to:
7.6.2 Preferences, features and Services: These cookies help to improve Your experience on Our Website. For example, they help to remember preferences You have selected, help to show You the correct version of the Website for Your location, offer You Services such as Live Chat and remember whether You accepted the Terms and Conditions.
7.6.3 Performance and analytics: These cookies help Us see how You are using Our Website, to identify any performance issues, and to improve how Our products work. Examples of these types of cookies are “_ga” and “_gid”. These Google Analytics cookies help Us track what pages players are visiting and which features of the Website are being used.
8. Storage, Security and Retention of Personal Data8.1 The data We collect from You may be transferred to, and stored at, destinations outside the European Economic Area (“EEA”) including South Africa and the United States of America. It may also be processed by staff operating outside the EEA who work for Us or for one of Our suppliers. Such staff may be engaged in, among other things, the fulfilment of Your order, the processing of Your payment details and the provision of support Services. These countries may not have equivalent data protection legislation to Europe. However, when We transfer Your personal data in this way We will ensure that adequate measures are in place to keep Your personal data secure, including via standard contractual clauses and Privacy Shield.
8.3 We are required to keep full records of all financial and wagering transactions together with any identification provided. Subject to clause 8.4, We will hold Your personal data on Our systems for as long as is necessary under Our legal obligations and for the purposes for which it was collected.
8.4 We will hold Your personal data for so long as You have Your Account with Us, We are providing Services to You and for up to six years following the end of the Services We provide to You or Your last contact with Us. We will delete any personal data sooner where it is no longer necessary for the purposes for which it was collected, but please be aware that this retention period may also be extended if any applicable statutory or regulatory obligation requires Us to hold information for a longer period or if there is an active dispute or the possibility of an active dispute between Us that extends past the normal retention period.
Page last updated on 16th May 2018.