Let’s talk about Privacy
Our Policy explains how Sky Betting and Gaming uses your personal data, whether you’re just visiting one of our websites, placing a bet or playing one of our games. There is a lot of information, and we know you won’t want to read it all at once, but where you see the ‘!’ symbol, it indicates something that we particularly need you to be aware of as it has an impact on your privacy. This includes information you may not already know about your data privacy rights, circumstances in which we share and obtain information about you, and how we use it to personalise the marketing you receive. Please take time to read those sections carefully.
Our Privacy Promise:
We never lose sight of the fact that your personal information is your personal information. Your privacy is important both to you and to us and we make the following promise to you:
Sky Betting and Gaming is committed to protecting your privacy. We believe in using your personal information to make things simpler and better for you. We will always keep your personal information safe. We’ll be clear and open with you about why we collect your personal information and how we use it. Where you have choices or rights, we’ll explain them to you and respect your wishes.
Who’s in control of your information?
In the UK, to comply with local data protection law, Hestview Limited, Bonne Terre Limited, Cyan Blue Odds Limited & Core Gaming Limited are registered as ‘Data Controllers’ with the Information Commissioner’s Office (ICO) and details are published on a public register on the ICO website at http://ico.org.uk. In Germany, the ‘Data Controller’ is Cyan Blue International Limited.
In Italy, to comply with local data protection requirements, our employees are officially appointed as ‘Incaricati Del Trattamento’ (‘persons in charge of handling of personal data’) on behalf of the company. They, like all our employees in any of our locations, undertake regular data privacy training and are required to comply with internal policies and procedures whenever they handle personal information.
Our Data Protection Officer
If you have any concerns about how SBG handles your personal information, you can contact our Data Protection Officer at: firstname.lastname@example.org
If you wish to submit a subject access request or a request to exercise any of your rights here, please click here for details of how to do so.
Collecting information about you
Information we get from you
Sky Betting and Gaming collects personal information about you whenever you use our services. Some of it is information you give us directly when, for example, you register for an account, deposit funds, place a bet or play one of our games. Other information is collected as you interact with us, such as the bets you place or online chats with our customer services team. We also collect information about the way you access, view, share, contribute to and communicate with and through our services, for example when you post comments via our social media channels or chat functionalities (such as via Sky Poker).
Information we get from your device
We collect information from the devices you use to receive Sky Betting and Gaming content, products and services. This includes, but is not limited to the following: your IP address (a number that identifies a specific device on the internet and is required for your device to communicate with websites), hardware model, operating system and version, software, preferred language, serial numbers, device motion information, mobile network information and location data.
We also collect server logs, which include information such as dates and times of access, the app features or pages you view, app crashes and other system activity, and the third party site or service you were using immediately before visiting our site.
Information we get via Cookies
'Cookies' are small text files stored in your web browser that enable us to recognise your computer when you visit one of our websites. Cookies are essential to keep certain parts of our websites functioning correctly and securely. We also use them to make things quicker, easier and more personal to you, and to help us understand how our websites are used. They can also be used to present you with more tailored advertising content.
The cookies we use fall into the following categories:
Strictly Necessary cookies: Making our websites work:
These Cookies are essential so that you can move around the sites and log in to the secure areas. They also enable us to deliver content in a way that works for your device.
Without these cookies you would be unable to place bets, play games or access your account so if you opt out of receiving these cookies, parts of our site will not work correctly and may not work at all.
A few examples of the ways in which we use strictly necessary cookies:
- Allowing you to navigate smoothly through our websites;
- Showing content in the best format for your device or browser and positioning it for your screen;
- keeping you logged in during your visit so that you don’t have to log in on every one of our websites each time you visit;
- Enabling you to stream content without having to repeatedly adjust volume and viewing settings.
Cookies for Fraud and money laundering prevention and identifying unfair use of our services:
As a betting and gaming company we have certain legal obligations we need to abide by. One of those rules is that we must do everything we can to prevent fraud and money laundering. These Cookies help us to protect our customers and our business by ensuring that customers are genuine, haven’t registered more than once, and are not fraudulently trying to access accounts that don’t belong to them. They also help us to recognise behaviour that may indicate fraud, money laundering, other illegal activities or breaches of our terms and conditions. We use the ‘iesnare’ cookie for these purposes.
Without these cookies you will be unable to use our websites. If you do not wish to accept this type of cookie, your option will be to close your account and not use our services.
Functionality cookies: Enabling the features of the website:
These Cookies allow our websites to remember choices you have made, such as your user name, your region or the selections you have placed on your bet slip. They help us keep you logged into your account as you navigate around our websites, and enable you to use certain features such as resetting your PIN or user ID. We also use them to personalise your experience by, for example, showing more relevant price boosts based on your previous activity, giving you access to information provided by social media websites such as Twitter, or to show you ‘related article’ links relevant to information you’re looking at.
Without these cookies you will still be able to use the site but may experience difficulty using certain features, and will need to keep logging in as you navigate around our sites. You will not see content (including price boosts) that is relevant to you.
Analytical cookies - Monitoring the performance of our websites:
These Cookies collect information about how people use our websites and how the sites are performing, e.g. how many people visit, which pages are most popular and whether and where people see error messages. They also ensure we can pay our marketing partners correctly for users they refer to us. A few examples of the ways in which we use Analytical cookies:
- to identify trends about how people use our website;
- to help us keep our content relevant and up to date;
- to count the number of times a page or email has been viewed and allow us to measure the effectiveness of our content and communication; and
- to improve the functioning of our applications and websites.
Without these cookies you will still be able to use and enjoy all the online features of our websites
Targeting Cookies - Marketing & advertising:
These cookies are used to deliver adverts and content that are more relevant to you as well as to limit the number of times you see a particular advertisement and to measure the effectiveness of advertising campaigns. The Cookies remember that you have visited a website, and we share this information with other organisations for advertising purposes. We also use them to test and improve our products and services by, for example, testing out different product experiences with different groups of customers to see which is most popular
Without these cookies: You will be able to use and enjoy all the features of our websites but the adverts you see will not be tailored to your interests
Tracking Cookies: Online Behavioural Advertising
We use a cookie placed by a company called Lotame to collect non-personal data that is used for online behavioural advertising. To opt out of the collection and use of data by Lotame in your browser (including a mobile browser if you have enabled third-party cookies), you can click here and follow the instructions provided. Your opt-out choice is applied only to the browser from which you make the choice, so if you use different browsers you will need to opt out in each one. This opt-out is cookie based, so if you delete your cookies, you will no longer be opted out and will need to opt out again.
In Germany, our Skybet.de website uses third party cookies from a company called Exactag, from which you can opt out here, and Google Analytics, from which you can opt out here Again, these two opt outs are cookie-based. Skybet.de also uses the following third party tracking cookies, all of which you can control through your browser settings: Silverpop (now IBM Digital Marketing), Fabric Engine, DoubleClick, Google Tag Manager, Income Access and Urban Airship.
Without these cookies: you will still be able to use and enjoy the features of our websites and you will still be presented with advertising but it is unlikely to be relevant to you.
If you would like to find out more information about Online Behavioural Advertising and the choices you have, the following websites are helpful:
- Your Online Choices – Provides information and allows you to choose not to receive behavioural advertising from the majority of the advertising networks.
- Network Advertising Initiative (NAI) – Please see the “opt-out” page. This allows you to opt-out of behavioural advertising from each of the ad networks represented by the NAI.
- European Digital Advertising Alliance – Please see the Online Behavioural Advertising Choices page.
Controlling my cookies
All modern browsers allow you to see what cookies you have, and to clear them individually or in their entirety by changing your cookie settings. Cookie settings are typically found in the 'options' or 'preferences' menu of your browser, otherwise you should use the 'Help' option in your browser for more details. You may also find the links below helpful:
- aboutcookies.org (contains information about cookies on a wide variety of desktop browsers.)
- Cookie settings in Internet Explorer
- Cookie settings in Firefox
- Cookie settings in Chrome
- Cookie settings in Safari
- Cookie settings in Edge
Information we get from external companies
To help us comply with our legal and regulatory obligations, when you open your account we obtain information (in the UK and Germany) from a Credit Reference Agency called CallCredit and, in the UK, from GB Group plc. This does not involve data about your credit standing or ‘credit score’. If you are SkyBet Italia customer, we check your details through a portal provided by the ADM (Agenzia delle Dogane e dei Monopoli).
Sometimes we need to undertake additional checks to verify information or, once an account is active, to investigate activity that could indicate a risk. To do this we use organisations and databases (such as Iovation Ltd) which collate information and make it commercially available for use in crime prevention and detection, the promotion of responsible gambling and ensuring the fair use of services. We also look at publicly available information to verify things like occupation status or property ownership, and at social media.
Where a UK customer self-excludes through the ‘Gamstop’ national self-exclusion scheme, we will receive a notification of this, which we will use to apply their chosen restriction across our sites and apps. To help us in our commitment to responsible gambling, we aim to understand the factors that can lead people to self-exclude or indicate the early stages of problem gambling. We look at information about customers who have self-excluded (such as age group, location and past betting behaviour) to identify common factors and this helps us to provide better and earlier support for customers who may be at risk of problem gambling. We may in future subscribe to similar national self-exclusion schemes in any of the countries in which we operate, and we will update this policy to let you know.
Like many companies, from time to time we may supplement the information we hold about you with data from companies such as Experian or in the UK, the Royal Mail, that collate and update address and household information from a range of sources and make it commercially available. This helps us keep our records up to date, fill gaps in our data and learn more about our customers so we can continue to improve our products and services. We will only work with reputable organisations that obtain their data legally in accordance with data protection law.
Occasionally, we obtain lists of potential customers from companies that collate these details and make them commercially available for marketing purposes. We only deal with reputable companies that take privacy as seriously as we do and have obtained your consent to share this data with us or companies in our sector for marketing, and you will always be able to opt out of receiving further marketing from us.
Publicly available information
As a betting and gaming company we must comply with legal obligations to promote responsible gambling, consider our customers’ financial ability to gamble, and prevent our products and services being misused or used for illegal purposes. If we observe account activity that could present a risk, or believe you have given false information, we will look at publically available information about you such as your Facebook or other social media pages, property ownership details, the electoral roll, company annual returns for places you have worked, industry bodies of which you may be a member, and insolvency registers. Although this information is public, we remain mindful of your privacy and use it only as and where necessary for carrying out these checks.
If you would like to know more about gambling regulation and the obligations it places on companies like SB&G, you can find out more on the Gambling Commission website for the UK, the Malta Gaming Authority for Germany or the AAMS for Italy
Information we get from social media
If you raise a query or a complaint through the Sky Betting and Gaming Facebook or Twitter pages, we will of course have a record of your user name and will use this to talk to you to resolve the matter you’ve raised and keep accurate records of how it was resolved.
We look at information on your Facebook or other public social media pages when carrying out checks to comply with our legal and regulatory obligations. This helps us to verify information you have given us and ensure our products are being used legally and responsibly.
We use information posted publicly on social media sites to help us understand how our customers interact with us. For example, we might look at which groups of customers are more likely to contact us via social media or to use social media to talk about our products and services. We do this in a way that does not identify individual customers.
How and why we use your personal information
We use the information we hold about you in a range of different ways, which fall into these broad categories:
- Things we need to do in order to provide you with the products or services you’ve requested
- Things we need to do to meet legal or regulatory obligations
- Things that enable us to run our business effectively and efficiently, and
- Things we do with your consent for marketing purposes
We’re telling you this because data protection law gives you rights over your personal data, which differ according to which of these categories it falls into. This section explains more about each category, the rights it gives you, how to exercise them and what that means in practice.
Providing our products and services
There are certain things we have to do in order to be able to provide you with our products and services. As you would expect, we use your personal information to enable you to use our sites, to set up your account respond to queries, contact you about bets you have placed or games played and provide you with the best possible level of customer service. We use technical information about your device, such as operating system, browser version and location to present you with the correct version of our website or app and keep it functioning securely and correctly.
Like most organisations, to provide our products and services we share your information with external organisations working on our behalf. You can find out more about this here
Privacy Rights: Can I opt out of having any of my data used in this way?
This category covers everything that is essential in order for us to provide you with the service(s) you use or sign up for. If you don’t want your data used in this way your option is to not use our services and close your account.
Meeting our Obligations
Legal and Regulatory Requirements
We need to comply with a range of legal and regulatory requirements, some of which involve the use of personal information and/or set out timescales for which we need to keep that information. As a provider of betting and gaming services, we are regulated by the UK Gambling Commission and, outside Great Britain, by the Alderney Gambling Control Commission. In Germany, operate with a Maltese License issued by the Maltese Gaming Authority and we comply with German regulations where applicable, and in Italy we are regulated by the AAMS. To comply with their requirements, we carry out checks during account opening and throughout the life of account to ensure our customers bet and play responsibly and legally. Free-to-play games on SkyGames are not regulated in this way, although we do carry out age verification checks to ensure players are over 18.
We take our social responsibility and our commitment to responsible gambling very seriously and we actively look for behaviour that may indicate that someone is at risk of problem gambling so that we can intervene at an early stage to provide them with support and direct them to sources of help.
Where a UK customer self-excludes through the ‘Gamstop’ national self-exclusion scheme, we will receive a notification of this, which we will use to apply their chosen restriction across our sites and apps.
To help us understand the factors that can indicate the early stages of problem gambling, we look at information about customers who have self-excluded (either directly or through Gamstop), such as age, location and past betting behaviour, to identify common factors. This helps us intervene earlier in cases where customers may be at risk of problem gambling, and provide them with better support.
We are also subject to laws and regulations relating to other aspects of our business, such as payment processing or complaint handling and some of these too involve the use of, or set timescales for holding, your personal information.
Fraud, Money Laundering and Other Illegal Activity
When you set up an account with us, place bets or play our games (other than free-to-play games on Sky Games), we carry out identity verification, fraud prevention and anti-money laundering checks, validating the information you give against third party crime prevention databases and, where necessary, information from publicly-available sources. We share your personal data with organisations that verify details and transactions and identify potential indicators of illegal activity, which they make available to other organisations using their services. Where necessary, we share your data with Credit Reference Agencies or fraud prevention agencies, which keep a record of that information and make it available to other organisations for use in credit decisions, identification checks and fraud detection and prevention. Where appropriate, we pass information to the police and other law enforcement agencies, debt recovery companies and other similar bodies.
It is important that Betting and Gaming operators work together to prevent illegal activity and promote responsible gaming. In the UK, our industry is working with the Gambling Anti-Money Laundering Group, the Gambling Commission and the UK Information Commissioner’s Office to establish a framework for sharing information between providers for this purpose. Where we believe it appropriate and necessary to do so to prevent money laundering and fraud, we will share information with, and receive information from, other betting and gaming providers. We will always do this in legally and in line with any industry guidelines.
If you are a Sky Games customer, we carry out age verification checks using publicly available information but we don’t carry out full identity, fraud prevention and anti-money laundering checks unless you later upgrade your account to use our pay-to-play products.
Privacy Rights: Can I object to having my personal information used in this way?
This category covers activities we are obliged to do in order to provide our products and services legally, responsibly, and in line with the requirements of our regulators, and ultimately to protect our customers and our business. We cannot provide you with our products and services without carrying out these activities, and if you don’t want your data used in this way your option is to not use our services and close your account
Running our business effectively and efficiently
There are some things we do to help us operate as a commercial organisation. We have a legitimate interest in carrying out these activities, and where they involve using your personal information we are careful to carry them out in a way that minimises any impact on your privacy. Data protection law gives you the ‘right of objection’ to the activities in this category if your right to privacy outweighs our legitimate business interest in doing them. You always have the option to exercise this right but, as we explain in more detail below, the activities involved are central to our business, so if you wish to do so it will usually mean you need to close your account.
Please read this section carefully and ensure you are happy with it before providing us with your personal information.
We carry out basic analytics to help us understand, how, when, where and why our customers use our services, and how our business is performing. This helps us monitor and plan everything from the effectiveness of our advertising through to ensuring we have enough staff available to handle queries at peak times. It also gives us a much clearer picture of our customers generally, the broad demographic groups they fit into (e.g. age group, gender, location, etc.) and the products and services they use, which in turn helps us to develop better and more relevant features, products and services. We do this analysis in a way that does not identify individual customers, so there is no impact on the privacy of any one person.
Privacy Rights: Can I object to having my personal information used in this way?
Like any business, we need to keep a close eye on how our business is performing and whether we’re meeting the needs of our customers. As we do this in a way that does not identify you as an individual, there is no impact on your privacy. If you don’t want your data used in this way your option is to not use our services and close your account.
Giving you a more personal experience
Whichever SBG products or services you use, wherever and however you interact with us, we want to give you the same great level of service and make it personal to you. We will tailor your experience, personalising the layout and content of our sites according to what we know about you, your preferences and the way you like to play or bet. For example, we will present you with features we know you have used or think you are likely to use, show you the type of score card or bet slip that best suits your style of betting, remind you to deposit funds when your account is running low and personalise search results to show more relevant results first.
We also look at aggregated (non-identifiable) data showing how our customers use our products and features and which games they tend to enjoy. We use this information to suggest games we think you’ll enjoy because they are popular with others who play the same games as you
Privacy Rights: Can I object to having my personal information used in this way?
We believe this personalised experience makes betting and gaming better and we want to give you the best customer experience we can. Using your personal data in this way enables us to do that in a way that we believe does not have an impact on your privacy. If you don’t want your data used in this way your option is to not use our services and to close your account
Please note that some aspects of your customer experience are provided via cookies. If you have enabled cookies in your browser, we will personalise certain aspects of our site, such as remembering your user name and location, and you can control this via your browser settings. You can learn more about how to control this here
Protecting our commercial interests
Most people use our products and services fairly, but we carry out monitoring of how our customers bet, play and interact with our products and services, to identify behaviour that is not in line with our Terms and Conditions or that could be prejudicial to our commercial interests. To help us do this, we receive information from tools and databases which collate information about customer behaviour across the industry and share it with betting and gaming operators for this purpose. We use services provided by Iovation Ltd., and may also use others including (in the UK) CIFAS. Although we obtain information from these sources, we do not allow the information we provide to them to be used by other operators for this purpose.
Privacy Rights: Can I object to having my personal information used in this way?
As a business, we have a legitimate interest in protecting our commercial interests against deliberate misuse, and we are confident that we do it in a way that is proportionate to the risks we face and has minimal impact on your privacy. If you don’t want your data used in this way your option is to not use our services and to close your account
We will occasionally invite you to give feedback on SB&G services you have used or to take part in customer surveys, questionnaires or focus groups. We will contact you online or via email, directly or through a third party organisation acting on our behalf. Taking part in research is always voluntary, and where we use a third party we do not pass over any details (other than your contact details so they can send you the initial request or invitation) unless and until we have your consent to do so.
Privacy Rights: Can I object to having my personal information used in this way?
It’s really important for any business to find out what its customers think. As we are careful to limit the number and frequency of feedback/research requests we send to any one person, and you can always decline to take part, there is no adverse impact on your privacy and you cannot opt out of receiving these very occasional requests.
Things we do with your consent: Marketing
We will send you offers and information only if you have given your consent for us to do so, in which case we will contact you via email, post, SMS or online about any of our group products and services. We never share your data with companies outside our group for them to use for their own marketing. From time to time, we may team up with a third party to bring you details of a product or service we think might interest you, but where we do this the contact will come from us - we will never pass your details to the third party without your prior consent.
Please be assured that we do not use any sensitive information we hold about you (for example, information about self-exclusion, health or ethnicity) for marketing-related purposes.
Keeping it Relevant
At SBG we want to make betting and gaming better for you, so we want to be able to tell you about products, services and features that you will find exciting and relevant, and we tailor the offers and information we send to suit you. To do this, we look at what we know about you - such as your age, location and gender, your browsing, betting and gaming history and patterns, your social media usage and how you interact with us - and we use it to build up a picture of you that helps us decide what you’re most likely to want to hear about. (This is sometimes known as ‘Profiling’). We also combine this with information we’ve obtained from publicly or commercially available sources about the things people with similar characteristics to you (in terms of age, gender, location etc.) tend to be interested in so we can fine-tune the offers we present to you.
Putting you in Control
We firmly believe our customers prefer offers and information that are relevant to them and their interests over general adverts, so we tailor all our marketing using this picture we’ve built up of you. We think this makes our marketing better both for you and for us. However, data protection law gives you the right to opt out of having your personal data used to build up this type of picture and predict what you might be interested in, so you can opt out at any time. As we explain above, all our marketing is tailored to you in this way, so to opt out of this type of personalisation you will need to opt out of receiving all direct marketing from us. You can do this when you sign up, by not ticking the box to opt in to marketing, or at any later point via your online account, and SkyBet customers in Italy and Germany can also do this via their online preference centre. We won’t then send you offers and information by post, email or SMS but we will continue to personalise your online experience based on the picture we’ve built up of you. This means you’ll continue to benefit from a more personalised look and feel on our websites and apps, and will still see the following:
- Targeted pop-ups telling you about products, services and offers we think you’ll like
- Bespoke offers relevant to you, communicated through pop-ups or other on-site content
- On-site (including in-game) recommendations for games you have played or might enjoy
- Targeted messages on social media platforms such as Facebook or Twitter (which you can control easily through your privacy settings on each individual platform) and in other places on the internet that support targeted advertising.
We think this strikes the best balance: it lets you opt out of receiving marketing through offline channels (post, email and SMS) while still enjoying the best online and in-game experience and without having to miss out on boosts, bonuses and other benefits. However, if you prefer not to receive any personalised messages or offers online you can opt out by out by editing your account details via your online account. If you do opt out you will experience a less personal look and feel on our sites and apps and won’t get to hear about bespoke offers and bonuses, but don’t worry – we will continue to personalise those aspects of your online experience that are not marketing-related so, for example, you will still see games you recently played. Please also note the following:
- We will still make onsite recommendations for games you might enjoy. We base these on how our customers as a whole tend to use our sites and features, not on information about you as in individual.
- Some personalised banner adverts on our sites are controlled separately through cookies, so you will also need to adjust your browser’s cookie settings or you will continue to see them.
- You may still see our adverts on other websites or social media platforms you visit, but these will not be specifically targeted at you.
Marketing: Keeping it relevant and putting you in control - At a Glance:
All our marketing is tailored to be more relevant and interesting to you, so if you’re:
- Happy to receive personalised offers and information by email, post, SMS and online – Make sure you opt in to direct marketing
- Happy to see personalised offers and information when you’re online but don’t want to receive them by email, post or SMS – you need to opt out of direct marketing
- Not happy to see personalised offers and information online or by e-mail, post or SMS – be sure to opt out of personalised marketing and adjust your cookie settings to avoid receiving banner adverts
Remember, you can change your mind at any time by updating your preferences in your account.
Upgrading from Free to Play: marketing preferences
If you are a Free to Play member and you upgrade your account, your existing marketing preferences will continue to apply unless you change them. You can do this easily at any time via your online account.
Online banner adverts: cookies
If you have enabled cookies in your browser you may receive banner adverts on our homepage, as these are cookie-based and not tailored using other information we hold about you. As they are cookie-based you will receive them even after you have opted out of personalised marketing, but you can control them easily via your browser settings
Advertising on Social Media
If you have given your consent to marketing, we will work with social media companies such as Facebook and Twitter to provide you with information about our products and services via their platforms. If you do not wish to see these adverts, you can control this easily by disabling preference-based marketing in the privacy and ad settings on each individual platform.
Even if you have withdrawn your consent to personalised marketing by SBG, you might still see general adverts for SBG products and services on your social media feeds. These will not be specifically targeted to you, and again, you can control this via the privacy and ad settings on each platform.
Online Behavioural Advertising
Marketing on our apps: Push Messages
When using our apps, you will receive push messages. These can be easily disabled through your phone or device’s settings.
Privacy Rights: Can I opt out of marketing?
Yes, you have the right to opt out of having your information used for direct marketing and the right to opt out of having it used to build up a picture of you so we can personalise our marketing to suit you. Please read the sections headed ‘Keeping it relevant and keeping you in control’, which explain how we use your personal data in our marketing, and how to control the marketing you see, and remember you can change your mind about receiving marketing material at any time via your online Sky Betting and Gaming account or, if you are a SkyBet Italia customer, through your online preference centre.
If you wish to opt out of e-mail marketing only, you can also do this by clicking on the link at the bottom of any email we have sent you. To opt out of receiving SMS messages you can reply “STOP” to 57785, and you can disable our push notifications via your phone’s settings.
As our marketing campaigns are prepared well in advance, you are likely to continue to receive material for a short period of time after updating your preferences.
More sensitive matters: how we use sensitive data
As a responsible provider of betting and gaming services, we do our best to ensure that our customers bet responsibly, and encourage you to make use of the range of tools available to help you with this. This means that on occasion you may provide us, directly or indirectly with information about your physical, psychological or emotional health or situation and talk to us about problems with gambling. We appreciate the sensitivity of this information and use it only to provide you with the support you have asked for and to signpost you to the appropriate sources of help.
To help us in our commitment to responsible gambling, it’s important that we understand the factors that can lead people to self-exclude or may indicate the early stages of problem gambling. Where a customer self-excludes, either directly or (in the UK) through the national Gamstop scheme, we look at demographic information about them (such as age group and location) and their past betting behaviour and transactions to help us identify common factors. This in turn helps us to provide earlier and better support to customers who may be at risk of problem gambling. As well as ensuring we do all we can to fulfil our regulatory obligations, it helps us to help our customers gamble responsibly.
On occasion, you may provide us, usually indirectly, with other sensitive information about yourself, such as your ethnicity or nationality (for example, identity verification documentation or checks can reveal this information). It is rare for us to ask you for this type of information directly, and we will only do so if we have a specific and valid legal reason, which we will explain clearly at the time. Where we do need to hold this type of sensitive information because it is shown in an identification document for example, we will do so only to comply with our legal or regulatory requirements and will not use or make it available for any other purpose.
Where you provide us with details of, or a copy of, your passport, driving licence, national identity card, code fiscal (in Italy), or other national identification documentation, we use it only for identification and verification purposes required to fulfil our legal and regulatory requirements.
Sharing Your Information
Companies that provide services on our behalf
We share your personal information with external organisations that carry out a range of services on behalf of SB&G. We carry out checks to ensure that the companies we work with will give your information the same level of care and protection as we do. Both we and they are obliged to handle your information in accordance with data protection law, and we are also required to put in place contractual measures reinforcing those obligations.
The main functions that are or may be carried out, fully or in part, by third parties are listed below:
- Account set-up and registration
- Management and execution of marketing campaigns
- Customer services
- Payment processing and verification
- Anti-fraud and -money laundering checks and ID verification
- Checks to detect unfair use of our products and services
- Web hosting, online content services and data storage
- Management of competitions, contests and offers
- Data analytics and data cleansing
- Market research and collecting or analysing customer feedback
- IT services and support
- Audit-, Legal- & Compliance- related services
In Germany, Skybet uses a gaming platform and technical services provided by SBTech Malta an (d other significant third party providers include Amazon Web Services, which provides data warehousing, and SafeCharge, which provides payment processing.
Sharing information with Credit and Fraud-Prevention Agencies
For ID verification and the prevention of fraud, money laundering and other illegal use of our pay-to-play services, we use commercially-available tools or services provided by Credit Reference and Fraud Prevention Agencies and services: Iovation Ltd (in the UK, Germany and Itay), CallCredit (in the UK and Germany), and GB Group (in the UK). These agencies/services keep a record of the information we and other companies provide and make it available for use by other organisations carrying out identification checks and fraud prevention. In order to provide this essential service, these agencies/services are ‘data controllers’ for the purposes of data protection law, which means they own and control the information we and their other subscribers provide to them. As ‘data controllers’, they are obliged to comply with data protection law and can use the information shared with them only to provide these checks. We cannot provide our products and services without carrying out these essential checks by sharing your data in this way, so it is important that we make you aware of it from the outset, and for this reason we bring it to your attention in ‘Fraud, Money Laundering and Other Illegal Activity’ above. If you are not happy for us to pass your information to credit and fraud prevention agencies, you will not be able to open an account and use our pay-to-play products and services.
Sending Personal Information outside Europe
Some of the third party providers we use are based in, or carry out their activities in, countries outside the European Economic Area (EEA), which is made up of the EU Member states plus certain countries considered to offer a standard of data protection equivalent to that of Europe. Where this means personal information is transferred outside the EEA, we have to put in place additional legal protections on top of our standard checks and measures, to ensure it receives the same level of protection as it would within Europe. We do this by using standardised contractual clauses (sometimes called ‘the EU Model Clauses’) approved by the European Commission and European privacy regulators, although there are alternative approved legal mechanisms which we can decide to use instead. Where necessary, we also put in place any additional contractual measures required by local law in any of the countries in which we operate, except where they conflict with the General European Data Protection Regulation.
If you would like to know more about the EU ‘Model Clauses’ or the other measures organisations like SB&G can use when transferring personal data overseas, you can find information here
Other circumstances in which we share your personal data
Apart from the functions set out above, we do not share your personal information with third parties except where we are compelled or permitted by law to do so. These circumstances are rare, but may require us to share information with the police or other law enforcement agencies, the courts, statutory authorities (e.g. in connection with tax matters) and sporting bodies (in connection with sporting integrity issues) in any of the countries in which we operate.
Where necessary to protect or defend our rights and interests, resolve disputes or enforce our agreements, we will share personal data with our regulators, external legal advisors and debt recovery and tracing agencies, although again these circumstances are rare.
As we’re a group we may sometimes need to share your information within our group for any of the purposes outlined in this policy, but we only do this if it’s strictly necessary for one of those purposes and where the law permits us to do so.
If ownership of all or part of our business changes or we undergo a reorganisation or restructure, we will transfer your personal information to the new owner or successor company so we or they can continue to provide the services you have requested.
Whenever we share personal information, and whatever the reason or circumstances, we will always do so legally and with due regard to your privacy. If we receive a request from law enforcement or other statutory bodies, we do not disclose personal information without a warrant, court order or other legally valid proof of authority.
How long do we keep your information?
We hold your personal information only as long as we have a valid legal reason to do so, which includes providing you with the services you have requested, meeting our legal and regulatory obligations, resolving disputes and enforcing our agreements.
The length of time for which we keep different types of personal information can vary, depending on why we originally obtained them, the reason we process them and the legal requirements that apply to them. When setting our data retention and deletion timescales we take into account a range of factors including applicable regulations and standards relating to gambling and gaming , anti-money laundering, taxation, payment processing and complaint handling, the need to prevent or detect crime or other misuse of our services, and audit requirements. To fulfil our requirements, some of your personal data will need to be retained for a period of time after you cease to be a customer. When we no longer need it to fulfil the above requirements, we delete it securely. Where we wish to retain any information for analysis purposes, we first anonymise it to the standards approved by the UK Information Commissioner’s Office, (which, as we are based in the UK, is our lead regulator on matters relating to Data protection) so that it can no longer be linked back to an individual. Please note that if you opt out of receiving marketing from us, we will still need to keep your contact details in order to suppress them from future marketing activity.
Privacy Rights: How do I exercise my ‘right to be forgotten?’
Staying in control of your Personal information: Your Privacy rights
We respect the fact that your personal information is your information so we want to be clear about what those rights mean in practice and how you can exercise them. Please see ‘how and why we use your data’ for more information about the purposes for which we process your information and the rights this gives you.
The right to opt out of having your information used for marketing
We firmly believe that our customers prefer to receive offers and information that are relevant to them so we tailor all of our marketing to make it more interesting to our customers. Please read the section ‘Keeping it relevant and putting you in control’ for more details.
The right to have any inaccuracies in your personal information corrected
You can update your personal details at any time via your online Sky Betting and Gaming account, but please be aware that if you have an account with Oddschecker you will need to update your personal details with them directly.
Please help us to help you by keeping your contact details up to date and letting us know if you spot any errors in the information we hold about you. If it is something you cannot correct yourself online, you should contact us at email@example.com if you are in the UK, firstname.lastname@example.org if you are a SkyBet Italia customer and email@example.com if you are in Germany. We’ll update inaccuracies promptly, and within a month if you are requesting a more complex change. If we take the decision not to make a change you have requested, we will explain why and make a note on your account to show that you requested the change. If you disagree with our decision, you have the right to complain to the privacy regulator
Your ‘right of objection’ to certain activities
Data protection law gives you the right to express an objection to activities detailed in the section entitled ‘Running our business effectively and efficiently’ if you believe your privacy rights outweigh the legitimate interest we have as a business in doing those things. Please read that section carefully before getting in touch with us and note that exercising your right of objection will usually mean you need to close your account and stop using our services. If you disagree with our decision on this, you have the right to complain to the privacy regulator.
Your Right to Erasure
People sometimes refer to this as the ‘right to be forgotten’. Under data protection law, you have the right to request erasure of your personal data in the following circumstances:
- Where the courts or our regulators have found us to be processing it unlawfully;
- Where our original purpose for collecting the data has been completed and we have no other valid legal grounds for continuing to hold it;
- Where you have withdrawn your consent to marketing and personalised marketing and asked us to delete the information we previously used for those purposes, in which case we will either delete it from our marketing systems or fully anonymise it, but note that we will retain your contact details in order to prevent further marketing;
- Where you have successfully exercised your ‘right to object’ to one of the activities in the section entitled ‘running our business effectively and efficiently’ and asked us to delete the information we used for that purpose. As we explain in that section, exercising your right to object will usually mean closing your account, and note that in most cases we will need to retain your information for a period of time after your account is closed. We will not delete information as long as we still have a valid legal or regulatory reason to hold it, unless the courts or our regulators order us to do so.
How do I exercise this right?
Please read the sections entitled ‘How long do we keep information’ and ‘’your right to erasure’ carefully before contacting us. If you still wish to exercise your right, you should contact us at firstname.lastname@example.org and we will respond to your request within a month. If we uphold your request and erase your data we will also notify any third parties to which the data has been passed, where we are able to do so, and tell you who they are. If we do not uphold your request, we will tell you why. If you disagree, you have the right to complain to the privacy regulator
The right to access the data we hold about you
If you would like a copy of the personal information we hold about you, you should request it here. We will ask you to complete and return a form, which is not compulsory but helps us to help you by providing the information you are looking for. Before we respond to your request, we will ask you for valid proof of identity and once we’ve received it we will provide our response within one month. If your request is unusually complex and likely to take longer than a month, we will let you know as soon as we can and tell you how long we think it will take.
If you are also a customer of SportingLife or Oddschecker and require any information we hold about you there, please let us know this when you make your request.
We will fulfil requests wherever possible, but there are occasional situations in which local or European data protection law requires or permits us to withhold some information (such as where it would involve disclosing information about another person or information which is commercially sensitive), or permits us to make a small charge. If either of these applies, we will explain this to you.
Your Right to ‘Data Portability’
The right to ‘data portability’ aims to enable consumers to re-use some of their personal information online by making it available in a commonly-used, machine-readable format that can be passed to and used by other organisations. This is a new initiative and it is not yet possible to ‘port’ data directly between providers in the betting and gaming industry. However, if you wish to exercise this right, you should submit your request here, and we will provide you with the following information as a CSV file:
- the personal and contact details held in your online account
- your betting and gaming history
- A list of payments made and funds withdrawn
Before responding to your request, we will ask you to provide valid proof of identity, and we will provide our response within one month of receiving it.
In future, it may become possible to transfer (or ‘port’) data directly between organisations. In the meanwhile, if you would like to take your SBG data to another provider you should first check that your chosen provider is able to upload data from a CSV file before making your request as above and passing the file to the provider yourself. If you would like to ‘port’ your data into SBG from another provider, you should first contact SAR@skybettingandgaming.com to see whether we can accommodate your request. It is unlikely that we will be able to do so at the present time, but we will try to accommodate requests where we can.
Your Right to Complain to the Regulator
If you believe your privacy rights have been infringed, or you disagree with a decision we have made about your privacy rights, you have the right to complain to the privacy regulator. As we are based in the UK, our principal data protection regulator is the UK’s ICO, but if you are in Germany, Italy or any other country in which we operate, you may prefer to initiate contact through the regulator in your country of residence:
- In the UK, ICO https://ico.org.uk/
- In Ireland, Data Protection Commissioner https://www.dataprotection.ie/docs/Home/4.htm
- In Germany: https://www.bfdi.bund.de/DE/Home/home_node.html
- In Italy: http://www.garanteprivacy.it/home_en
- In the Isle of Man: email@example.com
- In Jersey and Guernsey: firstname.lastname@example.org
- In Gibraltar: email@example.com
Links to Third Party Sites
Keeping your data secure
SB&G Security Accreditations
At SB&G we adhere to ISO27001 principles, we are Cyber Essentials Plus accredited and PCI compliant.
Your privacy and shared computers
If you log in to one of our websites from a shared computer, cookies may cause your e-mail address or user name to display in the login field to anyone who uses the site on that computer after you. You can avoid this by clearing the Cookies stored by the web browser. The option to do this is normally in the ‘Tools’ dropdown menu at the top of the browser window. If you have opted to stay logged in, remember that another person using the same device could access your account unless you log out.
Passwords and PINs
Remember to keep your passwords and PINS secret, choose complex passwords, change them periodically and never use the same password or PIN on multiple websites.