Privacy Policy
Last modified: November 25, 2024
When you use our Services, you trust us with your Personal Data. We are committed to keeping that trust. That starts with helping you understand how we process your Personal Data.
This Privacy Notice (the “Privacy Notice” or “Notice”) applies to all Users of our website (https://doctor-bet.com), including any mobile or device-specific versions of the website and any related applications, products or Services (together the “Website”).
1. WHO WE ARE
The Data Controller responsible for the Personal Data is Rednines Gaming LTD (reg no. 11622562) that is licensed and regulated in Great Britain by the Gambling Commission under account number 56377. Our ICO registration number is ZA777246.
All references in this Notice to “we”, “us” or “our” are considered to be references to Rednines Gaming LTD.
You can contact us by mail: 22 Beckenham Grove, Flat 7, Bromley, England, BR2 0XB, or by email: support@doctor-bet.
2. HOW TO CONTACT OUR DATA PROTECTION OFFICER WITH QUESTIONS
If you have any questions or concerns about our privacy practices, please contact our data protection officer at any time by mail: 22 Beckenham Grove, Flat 7, Bromley, England, BR2 0XB, or by email: [email protected].
3. WHAT KIND OF PERSONAL DATA DO WE COLLECT?
To provide our Services, we must process personal information about you. You are not obliged to provide us with Personal Data. However, some kinds of information are partly:
- required by relevant law (e.g., anti-fraud and anti-money laundering regulation, financial record-keeping obligations);
- necessary to conclude and perform a contract with you (for example, information on the counterparty).
The non-provision of the Personal Data required by law or contract would have the consequence that the contract with you could not be concluded and you could not use our Services.
We currently collect and process the following information about you:
3.1. Personal Data you provide directly
| Registration Data | When you create an account, you provide us with the Personal Data that includes name, username, date of birth, password and your contact details (permanent address (country, city, address, zip code), email address, phone number), a unique user ID |
| Identification and Verification Data | To meet our regulatory requirements, we will ask you to provide us with certain documents such as identity documentation (e.g., ID card, passport, driver’s license), financial documentation (bank statements, tax invoices, etc.) and proof of address (for example, utility bills). |
| Communication Data | If you communicate with us, it means that we collect some data regarding calls, texts, or other communications, including date and time of communications, the content of communications, and your responses to our communication. We record incoming and outgoing phone calls and retain communications to and from our customer support team in order to:
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3.2. Data created during use of the Website
| Transaction Data | This information includes deposits, withdrawals, date, time and amount of transactions, account balances, bonuses and payment methods used. |
| Payment Data | When you conduct a transaction, we may obtain certain information about you (e.g., payment account details, your currency, amount, unique user ID, etc.) from third parties. |
| Gaming Data | When you play games, we collect information about your gaming activities (for instance, games you play, tournaments and spins). |
| Log in Data | We collect information about the interaction of your devices with the Website. This includes device IP address, date and time of your logins, duration of logins, browser type and settings, operating system, time zone, device information, including the unique device identifier. |
| Usage Data | Information about how you use the Website, including pages visited, content viewed and links clicked . |
| Profile Data | Information based on your activity on the Website (e.g., your preferences, intentions, interests and other notes to your account). |
| Marketing Data | We collect information about how you interact with our marketing activities (for example, information about when you click on our advertisements or open our email communications). |
3.3. Personal Data from third parties
| Identification and anti-money laundering service providers | To comply with the legal requirements of the Gambling Commission, we may obtain personal information about you for identification, anti-fraud and anti-money laundering purposes (for example, confirmation whether the document uploaded by you is modified). |
| Payment service providers | When you conduct a transaction, we may obtain certain information about you (e.g., payment account details, your currency, amount, unique user ID, etc.) from third parties. |
| Analytics providers | We use third-party providers for analytics to understand how our Website is used. |
| Marketing service providers | We obtain Personal Data from our marketing partners who may provide us with information about potential Users of our Services and our users behaviour. |
| Gamstop | We obtain certain information about Users who registered with the Gamstop (UK’s national online self-exclusion scheme). Gamstop is a way to help you restrict your online gambling activities. Please refer here for more information about Gamstop. |
3.4. Special Categories of Personal Data and information about criminal convictions and offences
Our processing of Personal Data may also involve Special Categories of Personal Data (such as information about your health) and information about criminal convictions and offences (for example, information about offences committed by you).
In order to protect our business and Users from fraud and any illegal activities, we may process information about criminal convictions and offences. However, such data will only be used to review specific incidents that have occurred, and will not be routinely used.
We process Special Categories of Personal Data for the following purposes:
- to prevent fraud, money laundering and other illegal activities;
- to comply with regulatory requirements;
- to comply with our responsible gaming obligations;
- to ensure that self-excluded Users do not have access to the Services.
We process Special Categories of Personal Data and information about criminal convictions and offences on the following legal basis:
- for compliance with our legal obligations;
- to protect the public interests;
- to prevent or detect unlawful acts;
- to protect our Users against dishonesty, malpractice or other seriously improper conduct.
- to protect the economic well-being of our Users;
- to establish, exercise or defend against legal claims.
3.5. Personal Data from publicly available sources
To comply with our legal obligations under anti-fraud and anti-money laundering regulations and to protect our business from illegal activities, we may occasionally collect information about you from publicly available sources (for example, public databases, social networking services, search engines, etc.).
3.6. Personal Data we obtain through cookies
We and our service providers may collect browser and cookie information. “Cookies” are small text files that are delivered by the Website on your device. They help us to maintain security whilst you are logged in to your account. Sometimes they may collect information about your preferences while navigating the Website, to help you access your preferred Services easier.
4. HOW DO WE USE THIS PERSONAL DATA?
We use the information collected for the following purposes:
| To create and update User’s accounts | Contract with you | Registration Data Log in Data |
| To provide our Services, like access to games and any ancillary services | Contract with you Legitimate interests (account functionality, access to gambling, payment processing, etc.) | Registration Data Log in Data Transaction Data Payment Data Gaming Data Communication Data |
| To provide you with access to tournaments, competitions, loyalty programs | Contract with you Legitimate interests (account functionality, access to gambling, payment processing, etc.) | Registration Data Transaction Data Gaming Data Profile Data |
| To manage payments | Contract with you | Registration Data Transaction Data Gaming Data |
| To verify (KYC) and protect Users | Compliance with a legal obligation Legitimate interests (e.g., verify whether Users are reached the gambling age) | Registration Data Identification and Verification Data Log in Data Transaction Data Payment Data Gaming Data Communication Data Usage Data Profile Data |
| To prevent any suspicious behaviour in order to protect business and Users from fraud and any illegal activities | Compliance with a legal obligation Legitimate interests (for instance, to prevent money-laundering on the Website) | Registration Data Identification and Verification Data Log in Data Transaction Data Payment Data Gaming Data Communication Data Usage Data Profile Data |
| To comply with responsible gaming obligations | Compliance with a legal obligation Legitimate interests (e.g., minimising gambling-related harm) | Registration Data Identification and Verification Data Log in Data Transaction Data Gaming Data Communication Data Usage Data Profile Data |
| To ensure that self-excluded Users do not have access to Services | Compliance with a legal obligation Legitimate interests (for example, protecting Users from irresponsible gambling) | Registration Data Log in Data Communication Data Usage Data Profile Data |
| To provide User support | Legitimate interests (e.g., solving issues and any problems) | Registration Data Communication Data Profile Data |
| To provide marketing communication | Consent-based | Registration Data Communication Data |
| To personalise marketing communications, assess the effectiveness of our marketing campaigns | Legitimate interests (e.g., to tailor our marketing activities) | Registration Data Transaction Data Gaming Data Usage Data Profile Data Marketing Data |
| To maintain the safety, security, and integrity of our Website and Services | Compliance with a legal obligation Legitimate interests (for instance, ensuring information security) | Registration Data Log in Data Transaction Data Gaming Data Usage Data |
| To use data analytics to maintain and improve our Website, Services and User experience | Legitimate interests (e.g., improve the quality of our Services, measure and understand our audience, provide customized experience for the users) | Registration Data Transaction Data Gaming Data Usage Data Profile Data Marketing Data |
5. HOW WE SECURE YOUR PERSONAL DATA
We work hard to protect your Data from unauthorized access, alteration, disclosure, or destruction, including:
- encryption to keep your Data private;
- antispam and firewalls to protect our data storage facilities;
- review our information collection, storage, and processing practices, including physical security measures, to prevent unauthorized access to our systems;
- restrict access to Personal Data to our employees, contractors, and agents who need that information to process it and who are bound by an obligation of confidentiality, etc.
6. HOW IS YOUR PERSONAL DATA SHARED?
Your information is shared with others in the following ways:
6.1. For external processing
We provide your Personal Data to our service providers to process it according to this Privacy Notice and conditions of data processing agreements.
| Payment service providers | To process payment transactions on the Website |
| Identity verification (KYC), anti-fraud and anti-money laundering service providers | To verify your identity, monitor anti-money laundering (AML) risks, and prevent fraud and other illegal activities on the Website |
| Hosting providers | To store and transfer our content and data |
| Marketing partners, including vendors that enable communication with you | To send service and marketing emails, SMS, push notifications and to make phone calls |
| Data analytics providers | To measure performance and effectiveness of the Website and marketing campaigns |
| Providers of virtual slot machines | To provide you with access to high quality virtual slot machines |
| Sportsbook providers | To enable you to wager on various sports events |
| User support service providers | To answer your questions and resolve any other problems |
| Vendors that assist us to enhance the safety and security of the information systems | To protect the Website and our technical infrastructure |
| Consultants, lawyers, accountants and other professional service providers | To receive professional advice |
Please be aware that, to verify your identity and monitor anti-money laundering (AML) risks, we will send Identification and Verification Data to a third-party verification and fraud prevention provider, for example, HooYu Ltd. They provide services to validate this information in order to assist us in verifying identity or preventing or detecting fraud, and they will record and store details of the search as necessary to show that the search has been performed.
6.2. With other Controllers
We are subject to strict know-your-customer (KYC) and anti-money laundering (AML) legislation. To comply with our legal obligations, we engage specific anti-fraud and anti-money laundering service providers. Some of them act as Controllers of Personal Data contained in their databases. These databases may contain certain information about you. We conclude appropriate agreements with those third parties in order to ensure that the level of protection of your Personal Data guaranteed by the data protection legislation is not undermined.
6.3. For legal reasons or in the event of a dispute
We will share Personal Data if we have a good-faith belief that such access, use, or disclosure is reasonably necessary to:
- meet any applicable law, regulation, legal process, court orders or enforceable governmental requests, including requests from the gambling regulator;
- enforce our Terms and Conditions , including for the establishment, exercise or defence of legal claims;
- detect, prevent, or otherwise address fraud, security, or technical issues;
- protect against harm to our or Users’ rights, property or safety, or to the public as required or permitted by law.
6.4. In the case of merger, acquisition, or sale of assets
If we are involved in a merger, acquisition, or sale of assets, or if the owner or operator of the Website changes, we may transfer your Personal Data to a third party which will assume the rights and obligations guaranteed by this Notice.
6.5. With your consent
We will share personal Personal Data outside when we have your consent. We will ask for your consent before the sharing of your Personal Data for a purpose that is not covered in this Notice.
7. AUTOMATED PROCESSING AND PROFILING
We use automated processing and may carry out profiling based on your Transaction Data and Gaming Data for the following purposes:
- to comply with the licence requirements and our legal obligations under anti-fraud and anti-money laundering legislation (for example, we monitor our Users to detect potentially suspicious activities). Final decisions regarding suspicious activities are not taken solely by automated means and require human intervention;
- for direct marketing purposes (for instance, we analyse your Gaming Data and may propose special offers and bonuses). These decisions are not taken solely by automated means and require human intervention;
- for User clustering when carrying out our loyalty program, offering tailored services and games (e.g., we may propose you a “VIP” status). The decisions are not taken solely by automated means and require human intervention;
- to assess the risk of betting activities (such actions are performed by our sportsbook providers). A final decision concerning the user is confirmed or amended by a natural person.
8. WHEN DO WE TRANSFER YOUR PERSONAL DATA?
Some of your Personal Data is accessed and processed by service providers outside the United Kingdom and/or European Economic Area. To secure an adequate level of protection of your personal information, we:
- only transfer Personal Data to third countries where such transfer is based on adequacy decision of the * relevant regulator(s);
- enter into agreements with service providers based on the standard data protection clauses adopted by the relevant regulator(s), so they are bound to preserve at least the same level of personal data protection as it is granted by the law applicable to us;
- when none of the other transfer mechanisms are available, we may rely upon certain derogations to the prohibition on transfers outside the United Kingdom and/or European Economic Area such as your explicit consent, the performance of a contract involving the Data Subject, important public interest, legal claims or defenses.
Please contact us if you want further information on the specific mechanism used by us to protect your Personal Data when they are transferred to third countries outside the United Kingdom and/or European Economic Area.
9. HOW LONG DO WE STORE YOUR PERSONAL DATA?
We retain your Personal Data for the period reasonably required for our legitimate business and legal purposes, such as security, fraud and abuse prevention, financial record-keeping, or compliance with legal and regulatory requirements.
For example, according to legal requirements, records of your financial and wagering transactions must be stored for up to 7 years following the closure of your account.
We will take all necessary steps to ensure that the privacy of information is maintained for the period of retention.
10. HOW CAN YOU EXERCISE YOUR RIGHTS?
If you make a request to exercise your rights, we have one month to respond to you. This time frame can be extended by two further months for cases of specific situations and/or especially complex requests.
While exercising your rights, we must confirm your identity before any actions are taken. For security reasons, we would need to request additional details regarding your identity. Once we receive the relevant information, we will handle your request within the legal timeframe.
You are not required to pay any charge for exercising your rights.
10.1. Your rights
You can exercise the following rights:
| Your right to withdraw consent – You have the right to withdraw consent where we rely upon your consent for processing Personal Data. | To withdraw your consent, please contact our support team by chat, email or phone (you can find contact details at the bottom of this page), use the marketing preferences tool available on the “My account” page, or follow “opt-out” instructions included in the marketing communication you receive from us. |
| Your right of access – You have the right to ask us for copies of your Personal Data | Please contact our support team by chat, email or phone (you can find contact details at the bottom of this page) or email us at [email protected]. |
| Your right to rectification – You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. | You can rectify and correct some of your Data on the “My account” page using the tools we developed. You can also request us to rectify and correct any Data about you by contacting our support team via chat, email or phone (you can find contact details at the bottom of this page) or email us at [email protected]. |
| Your right to erasure – You have the right to ask us to erase your Personal Data in certain circumstances. Please note that this right is not absolute and may be restricted in cases laid down in the applicable legislation. We are obliged to store some information about you to comply with our legal obligations. Please see Section 9 “How long do we store your Data?” for more information. | Please contact our support team by chat, email or phone (you can find contact details at the bottom of this page) or email us at [email protected]. |
| Your right to restriction of processing – You have the right to ask us to restrict the processing of your Personal Data in certain circumstances. Even where the processing of your Personal Data is restricted, we are entitled to continue storing your Personal Data for a limited period of time. | Please contact our support team by chat, email or phone (you can find contact details at the bottom of this page) or email us at [email protected]. |
| Your right to lodge a complaint – You can lodge a complaint if you are unhappy with how we use your Data. | You can lodge a complaint to the Information Commissioner’s Office (competent authority in the United Kingdom) or your local data protection authority. |
10.2. How can you object to the processing?
You have the right to object to the processing of your Data which is based on our legitimate interests or when processing is necessary for the performance of tasks carried out in the public interest. You have the right to object to processing for direct marketing at any time.
To object to the processing of your Data, contact our support team by chat, email or phone (you can find contact details at the bottom of this page) or email us at [email protected].
To object to any processing for direct marketing, please use your marketing preferences tool available on the “My account” page, contact our support team by chat, email or phone (you can find contact details at the bottom of this page), or follow “opt-out” instructions included in the marketing communication you may receive from us.
11. MARKETING
We may contact you with promotions, products or Services that you may be interested in from time to time by email, telephone, text messaging, online, or otherwise, but only where you have consented to receive such marketing communications. You will receive push notifications only when you enable that type of communication in your device settings.
You can update your marketing preferences through the “My Account” page when you log in to your account, by contacting our support team via chat, email or phone (you can find contact details at the bottom of this page), or by following instructions in the relevant communication.
To unsubscribe from receiving SMS, you can also send a single-word message “STOP” which triggers the block.
You can disable push notifications via your device settings.
We endeavour to process your requests as soon as possible. Please note, when you choose to opt-out from email, SMS or phone marketing, you will stop receiving marketing communications within 48 hours.
Sometimes, we may deliver relevant marketing content to you on certain third-party social media platforms (for example, Facebook). We collect information about you if you chose to interact with our content and pages available on social media platforms. You can control the delivery of certain advertising campaigns through the settings offered by the respective third-party platforms since we do not control the way these platforms operate and process your Data. We highly recommend you to read their privacy notices to understand how they process Personal Data.
12. HOW WILL WE NOTIFY YOU OF CHANGES TO THIS NOTICE?
We reserve the right to modify this Privacy Notice from time to time. All modifications to the Notice will be published on this page of the Website. We encourage you to review this Privacy Notice regularly for the latest information on our privacy practices. We shall also archive and store previous versions of the Privacy Notice for your review upon request.
13. DEFINITIONS AND LEGAL REFERENCES
Here you can find the vocabulary of the definitions we use in this Notice.
| Personal Data (or Data) | Any information that directly, indirectly, or in connection with other information allows for the identification of a natural person. |
| Special Categories of Personal Data | Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic data, biometric data, data concerning health or data concerning sex life or sexual orientation. |
| User | The individual using this Website who, unless otherwise specified, coincides with the Data Subject. |
| Data Subject | The natural person to whom the Personal Data refers. |
| Data Controller (or Controller) | The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data |
| Services | Services provided by the Website as described in the relative Terms and Conditions on the Website. |
| European Union (or EU) | Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union. |
| European Economic Area | Consists of the member states of the European Union and three additional countries, namely Iceland, Liechtenstein, and Norway. |
