Version 1.0 valid from 9 August 2021
Black Cat Holdings Limited (BCH) respects your privacy and is committed to protecting your personal data and processing it in compliance with applicable laws – notably:
The Isle of Man Data Protection Act 2018;
The Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation) – the ‘GDPR’.
Changes to the Privacy Notice
Controller Black Cat Holdings Limited (BCH), an Isle of Man incorporated company is the controller and responsible for the personal data being processed. This policy is applicable to us and any of our affiliates.
Our full details are:
• General email address: firstname.lastname@example.org
• DPO email address: email@example.com
• Postal address: Black Cat Holdings Limited, a company founded under the law of Isle of Man. Registered with the Companies Registry in the Isle of Man under registration number 019249V and has its registered office at Millennium House 1st Floor, Victoria Road, Douglas, Isle of Man. IM2 4RW.
What information do we collect and why?
We mainly collect your information to offer you our online casino services. We also have certain legal requirements to collect information about you, such as documents for verifying your identity in connections to withdrawals or deposits. With this, we also need to save certain information about you for a number of years due to legal requirements, as for example bookkeeping. In addition, we process some of your information to send you promotions and offers in relation to our casino services that we think you are interested in, but you can of course choose to opt out of such marketing whenever you want to.
Information that you provide
This is information that you provide us when filling out forms on our websites or otherwise providing us your personal data, for example:
- When you create an account: Name, gender, address, email, telephone number, date of birth, and information about your preferred currency.
- When you are contacting us: Communications with customer support and service requests.
- When you are making deposits or withdrawals: Payment methods (such as credit/debit cards), ”Know your Customer“ information (such as driver's license, bank account details, etc.)
If you fail to provide Personal Data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with Our Services).
Information that we collect about you
This is information that we collect about you without you yourself providing it to us, as
Activity on our websites (as what games you play, what transactions you have made, if you participate in competitions, what marketing you have seen etc.)
Information from third parties for being able to fulfil our legal requirements (such as detecting fraud or money-laundering or in aid of responsible gambling measures).
Why and how long we process your information
For us to be able to offer you our services, or later being able to follow up on customer support requests, we need to process your personal data. Below is described the overall purposes, on which basis we process your personal data and how long we store such data.
|Purpose of processing||Legal basis for processing|
|Customize your experience||Consent|
|Your account on our website||Necessary for performance of contract|
|Marketing and advertising||Legitimate Interest (with soft opt-in)|
|Verifying your identity and performing security checks||Legal obligation|
|Perform and manage service issues||Necessary for performance of contract|
|For troubleshooting, data analysis, statistics and to counter abuse||Legitimate interest|
|Fraud detection, anti-money laundering or other criminal activity||Legal obligation|
|Bookkeeping of transactions||Legal obligation|
How long do we store your info?
The criteria We use to determine what is ‘necessary’ depends on the nature of the particular personal data in question. Our normal practice is to determine whether there is/are any specific law(s) applicable to Us (for example license requirement, tax or corporate laws) permitting or even obliging Us to keep certain personal data for a certain period of time (in which case We will keep the personal data for the maximum period indicated by any such law) and if not, whether there are any laws and/or contractual provisions that may be invoked against Us by You and/or third parties and if so, what the prescriptive periods for such actions are.
Where Your personal data is no longer required by Us, We will either securely delete or anonymise the personal data in question.
We will generally retain your personal data for a maximum period of ten years from the closure of your account. There are some exceptions to this retention period, namely:
If you are permanently self-excluded from any of our services, we will retain this information indefinitely.
If you are under investigation or we have identified possible fraudulent or even criminal activity, we may retain your personal data for longer and as required to cooperate with the relevant authorities.
If there is a legal dispute, we will retain your personal data at least for the duration of the dispute and as may be required to defend our rights in any subsequent claim or proceeding arising from the same.
Marketing and advertising
We may share information with advertising partners to send promotional messages to you or to show you customized content. We do this to be able to show you offers based on an evaluation of your interests and profile; and to understand how you interact with advertising. Please refer to the section on how we process information on our web site below, for information about cookies and other technologies that we and third parties use on our web site.
Profiling for direct marketing
When you visit our website, we use your activity on the site and your personal data (as age, gender and country of residence) to improve the selection of the games and offers that you see. We offer many different games and we would like to help you see what we think are the most relevant for you. We use the same principle when marketing though other channels, such as Facebook or the use of advertising banners. You have the right to object to this profiling and we must obtain your consent to use these technologies (which you can withdraw at any time), but we will still advertise on third party platforms like Facebook and Google, so you will still see our advertising, but it will not be customized according to what we think is the most interesting for you.
Who we share your information with:
Service providers and others
We engage third parties to provide us with services (such as mail service providers, marketing providers, different payment providers, as well as professional service providers). We always ensure that they maintain at least as much data protection for your data as we do.
Casino game providers
We use a number of different casino game providers, which are integrated to our websites. When playing these games, the service providers can access and process some of your personal data (such as your first name, last name, username, country, language, currency, IP address, contact details (phone or email) and your gender). You will be able to see the specific game provider when starting a specific game. Marketing service providers
We use a number of different service providers for marketing, Search Engine Optimisation and affiliation.
Fraud detection and anti-money laundering service providers
We also use service providers for making sure that we follow the legal requirements in connection to gambling (such as fraud detection or anti-money laundering).
In addition, we also use open source information such as public sources including government registries, databases and social media sites (including Facebook, LinkedIn etc.) to the extent that this is permitted or required by law.
Customer service and support service providers
Providers used with regard to customer service and support, business development and product management.
Other service providers
- Service providers for email, other company communication channels, cloud hosting and other services (e.g. analytics)
- Front and back end platform operation and system security services)
Transfers to third countries
Some of our suppliers and partners are based outside the Isle of Man, as well as outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data to a territory that does not necessarily afford an equivalent level of data protection.
Whenever we transfer your personal data 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:
• transfer your personal data is performed to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission and are recognized by the Isle of Man. • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe and the Isle of Man. Please Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
Since we process your personal data, it is important that you know what rights you have as a customer. Below you'll find information about what rights you have and how they relate to the information that we process.
Right of access. You are entitled to request a copy of the personal data we have stored about you, and you are entitled to receive it free of charge. You can send a request for access to your information by email to [insert DPO’s email address - TBC]
Right to rectification. If we have incorrect or incomplete information about you then you are entitled to request that we correct it at any time.
Right to erasure. If we process your personal data with your consent, and you choose to withdraw your consent, you have the right to request that that information be deleted.
Right to object. When we process your information on the basis of legitimate interest; or we process your information to create a profile for the purpose of determining your interests; you have the right to object to this processing. If you object to such processing, we must either show compelling legitimate reasons that overrides the reasons you stated or stop the processing of your data.
Right to lodge complaints with the supervisory authority. If you are not satisfied with how we treat your personal data, we hope you tell us so that we can better manage your trust. Regardless, you always have the right to file a complaint at the competent supervisory authority:
Isle of Man Information Commissioner, P.O. Box 69, Douglas, Isle of Man, IM99 1EQ Telephone: +44 1624 693260 Email: firstname.lastname@example.org
Right to Data Portability. You have the right to move your data from BCH to another organization of your choice or to download your data. Please email [insert email address - TBC] if you wish to exercise this right.
Right to withdraw consent (when we process your data on the basis of consent).Any consent to processing can be recalled at any time. Processed data based on consent will be removed unless there is another legal basis requiring us to continue processing such data. Withdrawal of consent is easiest done by changing your preferences in your profile or by contacting us.
Right to Data Restriction.
You have the right to ask Us to restrict (that is, store but not further process) Your personal data but only where:
· The accuracy of Your personal data is contested (see the right to data rectification above), for a period enabling Us to verify the accuracy of the personal data; or
· The processing is unlawful, and You oppose the erasure of Your personal data; or
· We no longer need the personal data for the purposes for which they were: collected but You need the personal data for the establishment, exercise or defence of legal claims; or
· You exercised Your right to object and verification of Our legitimate grounds to override Your objection is pending.
Following Your request for restriction, except for storing Your personal data, We may only process Your personal data:
· Where We have Your consent; or
· For the establishment, exercise or defence of legal claims; or
· For the protection of the rights of another natural or legal person; or
· For reasons of important public interest.
Security of your information
We put your personal integrity in first place, and we are working actively so that your personal data is processed with utmost care. We take the measures that are needed to make sure that your personal data is handled safely and in accordance with this Notice and the General Data Protection Regulation and other applicable laws.
Our services are not directed at any one under 18 years of age. We do not consciously collect personal data from people under the age of 18. If you are a parent of a child and become aware that your child has provided personal information to us, please contact us so that you may request to exercise your right of access, rectification, erasure, and / or objection.
Special Category of Personal Data
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). However, from our experience, we may not exclude that You, at your own discretion, send us such data in communication with Us.
Please note that although ID cards are processed, images contained therein are not specifically technically processed to allow or confirm unique identification. Therefore, such data is not to be considered biometric data (special category of data).
How we process information on our web site