Who are we?
- OB Lead Limited - Data Controller/Processor (“OB Lead”, “us”, “we”, “brand owner”)
- Casino Top Ten - This particular OB Lead Limited property (“CasinoTopTen”, “Casinotopten.com”, “the site”, “the website”)
- Visitors and customers on our websites - (“You”, “visitors”, “members”, “players”)
- Promoted brands and third-parties - ("Advertising partners")
- Services offered by Casino Top Ten - ("Services", "experience")
- General Data Protection Regulation - ("GDPR")
- Privacy & Electronic Communications Regulations - ("PECR")
- Information Commissioner's Office - ("ICO")
Your use of this website
How we collect data
Data can be collected and processed during the operations of our website. Below is a list of the current ways in which we may currently collect and store your data for Casino Top Ten in accordance with GDPR and PECR.
- You subscribe to our website mailing list
- You are a member at another site in the OB Lead Limited group network
- You subscribe to the mailing list of another site in the network
- You communicate directly with Casino Top Ten through a support query
What personal data do we collect and process?
We may process the following personal data about you:
- Full name
- Date of birth
- Email address
- IP address
- Website usage
- Partner site usage (selected partners)
- Personal preferences and opinions
How and why we process your data
We process personal information as necessary by law and for certain legitimate business purposes in a way that is proportionate and respects your privacy, as outlined here:
- Send promotional emails related to our own and third-party products and services (see sections 7 & 8)
- Analyse information in our systems and databases to provide a better and more relevant experience
- Providing you with the services described on the site Updating you with operational news about the site (changes, service disruptions, security updates)
- Monitoring activity on our site and those of our partners to identify potential fraudulent activity and to ensure compliance with the user terms that apply
- Managing our relationship with you, e.g. by responding to your comments or queries submitted to us on the Sites or asking for your feedback or whether you want to participate in a survey;
- Improving our products and services
- To provide you with a responsible gaming environment
- Providing general administrative and performance functions and activities
- Meet or exercise any of our legal obligations or legal rights
How and why we share your data
We occasionally work with third parties to help manage and deliver our services, which may require access to your personal data. Below is a list of the third parties in question and the reasons your data may be shared.
- Our mailing application provider, Dotmailer Limited, based in London Bridge, England. We work with Dotmailer to send you marketing and support emails.
- Service providers or data processors that handle your personal data on our instructions, for example cloud services. Other sites in the OB Lead Limited group include, but not limited to, OnlineBingo, Casino Guide and Mr Spieler, for customer analysis, insights and cross-brand promotions.
- Our advertising partners for marketing campaign analysis and performance reviews. This helps us to show you only the content that interests you most.
- Our analytics service providers (such as Google, PushCrew and Facebook), who process personal data for their own purposes as Data Controllers.
- If we are under a duty to disclose to comply with a legal obligation or protect our interests or security.
- A purchaser or prospective purchaser of all or part of our assets or our business, and their professional advisers, in connection with the purchase.
- Regulators and government authorities in connection with our compliance procedures and obligations.
Non-personal Information is non-identifiable information that cannot be used to identify or contact you when considered alone. This stops us from knowing the identity of the user from which the non-personal information was collected. We use non-personal information for reasons including advertising, service improvements, detecting and preventing fraudulent behaviour, statistical analysis and web analytics.
Types of Non-personal Information we collect about you
Technical information about the software and hardware you use to visit our site in order to provide you with a better experience when you visit. This can include:
- Device manufacturere & model
- Type of browser
- Operating System
- Language preferences
- Network provider
Analytics information that we collect about your use of our services including pages viewed, time spent on site, clicks and other related activity. This helps us to troubleshoot common errors, review the user experience and provide better insights for our operator partners.
Consent to third party promotions
As outlined above, our marketing communications will often promote the products and services from our third-party advertising partners, where their privacy policies allow for such promotion, see section 4. In these situations, our communication will retain Casino Top Ten branding, but the content will focus on the specific offer or service from the third-party(ies) in question. Where possible, we screen against third-party suppression lists to ensure you only receive promotions from brands which you have not withdrawn consent from. Please note that Casino Top Ten is not responsible for the privacy practices or the content of these third party sites. We advise our users to check individual terms and conditions/privacy policies where appropriate.
Behaviour monitoring & profiling
We use automated decision tools provided by our email service provider (Dotdigital) to segment our database according to certain actions or inaction of our users. This can include:
- Whether or not you opened a particular email
- Whether or not you clicked a particular email
- Your tendency to interact with emails of a particular theme
Personal Information collected by us may be stored and processed in any country where our advertising partners, subsidiaries, suppliers or agents are located. We may also need to transfer data (including Personal Information) to other OB Lead Limited companies for the supply of our services. If this happens, all information will be managed according to and subject to all relevant national, European and international data protection and privacy laws and regulations, including the UK Data Protection Act and the EU General Data Protection Regulations. You hereby consent to the transfer of your Personal Information to countries outside the European Union.
How long do we keep your data?
We will retain your personal data for as long as reasonably necessary for the purposes listed in Section 4 of this Policy. In some circumstances, we keep your personal data during a certain period to meet for example legal, tax or accounting requirements. We maintain a data retention policy for personal data in our care. Where your personal data is no longer required we will ensure it is either securely deleted or made anonymous.
All of the information that you provide and we collect about you is stored on secure servers, but you should understand that transmission of online data is not always completely secure. We cannot guarantee full protection and security data, only that we take all reasonable action to protect information sent to us electronically. Transmission of any data by you is at your own risk. Please remember that any information you share in the form of comments on our news article and site review pages will be publicly available. We advise that you exercise caution when deciding to disclose your personal information in these places.
An an EU citizen, you have a number of rights under the General Data Protection Regulation, which came into place on 25th May 2018. Some of these apply at any time, but some may only apply in certain circumstances.
Access to personal data
You have a right to request a copy of the personal information that we hold about you.
Correction of personal data
You can contact us to check and correct any personal data that we are processing about you which you think is incorrect.
Right to withdraw consent
Where we have relied upon your consent to process your personal data, you have the right to withdraw that consent.
Right of erasure
You can ask us to erase your personal data where there is no legal reason or legitimate interest in keeping it.
Right to data portability
You can request a copy of the information you have provided us and the right to ask that your personal data is transferred by us directly to another organisation. For security reasons, we will only do this if it is technically possible.
Right to restrict processing of personal data
In some circumstances you have the right to request that we suspend our processing of your personal data.
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. We will still be allowed to keep your personal data to meet our legitimate interests and regulatory obligations.
Rights relating to automated decision making and profiling
You have the right not to be subject to a decision which is based solely on an automated process. We do not currently make any decisions about any customer in this way, but if this changes, we will write to tell you.
The services offered by Casino Top Ten are not designed or directed to persons under the age of 18 or persons under the age of legal consent with respect to the use of the Services of any jurisdiction in which the individual resides, whichever is higher ("Legally of Age"). If you are not Legally of Age, you should not download or use the Services nor provide any Personal Information to us. We reserve the right to access and verify any personal information collected from you. In the event that we become aware that a user who is not Legally of Age has shared any information, we may discard such information. If you have any reason to believe that a minor has shared any information with us, please contact us at firstname.lastname@example.org.
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