1. DATA PROTECTION
a. Personal data, or personal information, means any information about a person from which that person can be identified (“Personal Data”). It does not include data where the identity has been removed (anonymous data).
b. You may contact the data controller for any questions in relation to the manner in which we use your Personal Data at https://www.superlenny.com/en/about-us.
2. WHAT AND HOW PERSONAL INFORMATION IS COLLECTED
We will collect and process data about you depending under which of the following category/ies you belong:
a. Browsing through the Site
With regard to each of your visits to our Site, whether you have a User Account (as defined below) or not, we might automatically collect the following information:
• Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, your internet service provider (ISP), your device, your location, your operating system and platform and other online identifiers. While this information is non-personal, we do treat it with the same level of security and afford it the protection we afford to your Personal Data. It is only used for internal analysis of user trends, so that we can best optimise the Site to offer a superior online experience.
• If you use our Site on your mobile device, we may collect your mobile carrier information and the unique device id number.
• Information about your visit to the Site, including the full Uniform Resource Locators (URL) and page interaction information.
• Information received from cookies.
b. Opting to receive our Newsletter or Opting into any promotion
When you choose to join our email newsletter or opt into any promotion, we will also record your name and email address and we will contact you via email.
You may opt out of receiving newsletter and promotional emails from the Site by following the instructions in those emails. If you opt out, we may still send you non-promotional emails, such as emails about your Account.
c. Creating a User Account
i. When you create a free online user account on the Site (“User Account”), apart from the information referred in Clause 2(a) above, we will also record the following information about you: name, date of birth, email address, username, country and IP address, favourite game.
ii. If you choose to ‘Register with Facebook’, the information you choose to share with us may include the basic information available in your Facebook profile (including your email address, status updates and a list of your contacts). We will only receive registration information from Facebook and no other information. Facebook will be able to tell you more about how they use and process your data whenever you connect with us through them.
d. Contacting us
When you contact our support team for assistance with regards to any information on the Site we may also record all the information you provide to us.
3. HOW YOUR PERSONAL INFORMATION IS USED
a. Your personal information is used by the Site to:
i. Deliver Marketing Communications – to keep you up to date with new information, announcements, relevant updates and other events deemed to be of value to you. You will receive any such information through email and other forms of electronic communications only if you have opted to receive any such information prior to signing up, or through modifying your settings in your User Account to allow for receipt of such information. You may choose at any time to opt out of receiving communication by accessing your User Account and modifying the settings or by following the relevant unsubscribe link.
ii. When you enter any competitions, giveaways or sweepstakes offered by the Site we will use your personal information to administer such programs.
b. We will also use your personal information to verify your account information should the need to verify such information arises.
4. CATEGORIES OF DATA HELD ABOUT YOU
The personal data collected and processed on you can be grouped into the following categories:
• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, employment status and occupation.
• Contact Data includes residential address, email address and telephone numbers.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data includes your username and password (encrypted), login and logout times.
• Usage Data includes information about how you use the Site.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
5. LAWFUL BASIS FOR PROCESSING PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
|PURPOSE/ACTIVITY||CATEGORY OF DATA|| |
LAWFUL BASIS FOR PROCESSING
INCLUDING BASIS OF LEGITIMATE INTEREST
|To register you as a new user||(a) Identity|
(c) Profile Data
| a. Necessary for our legitimate interests|
(to keep our records updated)
|To manage our relationship with you which will include:|
(b) Maintain a User Account with us.
(d)Marketing and Communications
|(a) Performance of a contract with you|
(c) Necessary for our legitimate interests
(to keep our records updated)
|To send you promotional information and newsletters||(a) Identity|
(e)Marketing and Communications
|a. Consent (if we contact you by means of|
|To administer and protect our business and the Site|
(including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
|Technical||(a) Necessary for our legitimate interests|
(for running our business, provision of
administration and IT services, network
security, and in the context of a business reorganisation or group restructuring exercise)
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity|
(e)Marketing and Communications
|Necessary for our legitimate interests|
(to define types of users, to keep our Site updated and relevant and to develop our business)
|To use data analytics to improve our website, products, marketing, customer relationships and experiences||(a) Technical|
|a. Necessary for our legitimate interests|
(to grow our business) if suggestions are delivered via the Site.
b. Consent (if we contact you by means of direct marketing).
|To make suggestions and recommendations to you about products that may be of interest to you||(a) Identity|
(f)Marketing and Communications Data
|a. Necessary for our legitimate interests (to grow our business) if suggestions are delivered via the Site.|
b. Consent (if we contact you by means of direct marketing).
6. COOKIES & ANALYTICS
For more information on Cookies, please see our Cookie Notice.
The site also uses Analytics. Whether you have a User Account or not, we may use Google Analytics and Matomo Analytics, as well as any other analytics providers that we may use from time to time, to advertise on the Site and/or on third-party Sites to you after you visit our Site. We and third-parties like Google and Matomo, use first party cookies and third party cookies to inform, optimise and serve ads based on your past visits to our Site:
i. Google Analytics
1. Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Site. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
2. We use Google Analytics’ 3rd-party audience data such as age, gender and interests to understand the behaviour of our customers. We also work with companies that collect information about your online activities to provide advertising targeted to suit your interests and preferences. This means that you may from time to time see several advertisements on the Site or other sites you browse because we contract with Google and other companies to target our advertisements based on data we or they have collected, including data collected through cookies. These companies may also be able to collect information when you click on advertisements on the Site, which helps track and manage the effectiveness of our marketing efforts.
3. You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page (https://adssettings.google.com/authenticated). Google also recommends installing the Google Analytics Opt-out Browser Add-on for your browser (https://tools.google.com/dlpage/gaoptout). Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
7. PERSONAL INFORMATION DISCLOSURE TO THIRD PARTIES
b. We do seek to partner with companies who provide services, solutions and promotions we feel will be of value to our customers, and in such instances we will provide you with any such services, solutions and promotions of such other companies.
c. The Site also reserves the right to provide statistics about your use of the Site, sales, traffic, and other statistical information relating to the Site to third parties, without however, identifying your identity.
d. The Site may provide your personal data to its affiliates or related companies for legitimate business purposes.
f. We may release your information should we be required to do so by law in order to comply with any legal processes.
g. We do not provide any warranty against the use of your information by third party sites linked to, and from, the Site.
8. YOUR RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
a. Request access to your personal data. You have the right to access information held about you. We shall comply with any reasonable access request. In the events that the access request involves a disproportionate amount of work, we reserve the right, in line with applicable law, to charge a fee covering the work involved.
b. Request correction of your personal data. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
c. Request erasure of your personal data. You have the right to ask us to delete any information we hold about you which is not relevant to purpose for which we collect it. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You may also request for us to delete all your personal data, in which case we ask you to close your account. There may be legal obligations which may prohibit us from deleting all or any information held about you immediately at the time of the request (such as Anti-Money Laundering legislation), however we will process your request at the earliest opportunity whenever any applicable data retention period expires.
d. Object to processing of your personal data. You have a right to object to our processing of personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes, in which case we ask you to untick the relevant tick-box for direct marketing, prior to creating a User Account, or to modify the settings of your User Account, which grants us the consent to process your data for marketing communications. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
e. Request restriction of processing your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
f. Request transfer of your personal data (data portability request). This enables you to request your personal data. We will provide to you, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
g. Right to withdraw consent for direct marketing. You have the right at any time to change your mind in relation to us being able to contact you with direct marketing. You can exercise your right to stop receiving direct marketing by accessing your account and unticking the consent boxes related to direct marketing or by contacting customer support. Any withdrawal of consent for the processing of personal data for marketing purposes will apply for the Site only.
h. We will retain copies of any communications that you send to us (including copies of any emails) in order to maintain accurate records of the information that we have received from you.
i. You can also exercise your rights at any time by contacting us at https://www.superlenny.com/en/about-us.
9. PROTECTION OF CHILDREN
a. The Site is an online gambling information portal and as such none of its marketing content, products, services or promotions are appropriate for, or targeted at, children and visitors under the age of 18 years of age (or equivalent minimum age in the relevant jurisdiction).
b. The Site does not knowingly solicit or collect personal data from children below the age of 18. If the Site discovers that it has accidentally collected personal data from a child below 18, it will remove that child’s personal data from its records as soon as reasonably possible.
c. The Site bears no responsibility for the actions taken by children or visitors under the age of 18 (or equivalent minimum age in the relevant jurisdiction) based on the content found on the Site, or any of its sub-domains and pages, nor our outbound marketing campaigns (including but not limited to our email newsletter).
10. GENERAL ACCOUNT REGISTRATION POLICY
a. You can register a free account with the Site. Please note it is not obligatory to do so in order to continue using the Site and participating in the promotions on offer, unless stated otherwise.
c. Once you have registered an account you can at any time request for the account to be de-activated, or deleted. Please note we will retain the registered information in our secure archive for statistical and analysis purposes, as explained better in Clause 11 below (Data Retention).
11. DATA RETENTION
a. You can ask us to delete your data by closing your User Account. In that case, we will immediately delete all information aside from that which we may from time to time be required to retain by law.
b. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
12. CUSTOMER ACCOUNT CONFIDENTIALITY
a. Your personal information will only be exposed to staff members of the Site who require access to certain data in order to perform the functions associated with their position in the company.
b. Your personal information is password protected in a secure digital encryption environment.
c. We abide by all regulations for the protection of personal information.
13. GENERAL DATA SECURITY
The Site has implemented the necessary and digital and infrastructure security measures at the physical IT and data storage facilities to protect against the loss, misuse and alteration of your information.
14. CONTENT CONDITIONS
a. Due to the realities of maintaining the Site and other digital content we cannot guarantee that all content will be accurate at all times.
b. For this and other reason the Site reserves the right to adjust and make amendments to the information contained within the Site without notice.
c. It is worth noting that some services and promotions are subject to regulatory and jurisdictional restrictions, and are therefore not available in all markets.
The responsibility lies with you to ensure that any information you respond to is currently valid before committing to the required action.
16. OTHER SITES