Who we are
Hippodrome Casino Limited is located at Cranbourn Street, Leicester Square, London, WC2H 7JH.
Company registration no. 05497987. Hippodrome Casino Limited is registered with the ICO Z3078892
This privacy notice describes how we collect, use and store personal information about you during and after your business relationship with us, in accordance with the Data Protection Act 2018 / UK GDPR.
Hippodrome Casino is a “data controller”. This means that we are responsible for deciding how we hold and use and store personal information about you. We are required under the DPA 2018 / UK GDPR to notify you of the information contained in this privacy notice.
It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using your personal information.
DATA PROTECTION PRINCIPLES
We will comply with all relevant data protection law (including the DPA 2018 / UK GDPR). This requires that the personal information we hold about you must be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have informed you about.
- Kept securely.
- We are accountable as a Controller for the principles and individual rights with respect to the processing we undertake.
THE KIND OF INFORMATION WE HOLD ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified, whether directly or indirectly. It does not include data where the identity has been removed (anonymous data).
There are also “special categories” of sensitive personal data which require a higher level of protection.
We will collect, store, and use the following categories of personal information about you:
- Identity data including your full name or other identifier, title, date of birth, gender, occupation details, photographic imagery and audio recordings.
- Contact data including your registered address, country of origin, email address and telephone number.
- Payment card / bank account information when you purchase our products or services, which may be administered by third parties.
- Technical data which includes your IP address, login data and browser types when using our information and communications systems.
- Profile data including your username, password, transaction history, interests, preferences, and feedback.
- Marketing & Communications data including your marketing preferences with us.
We also collect, store and use the following “special categories” of sensitive personal information:
- Information about your race or ethnicity.
- Information about criminal convictions and offences.
- Health information
- Biometric information.
LIVE FACIAL RECOGNITION
We use Live Facial Recognition (LFR) technology in the building to maintain a safe and orderly environment for our guests and to abide by our Gambling Commission obligations.
The LFR cameras are positioned inside the building and are unable to, and do not scan, public areas outside of the building.
Appropriate signage is in place as you enter the building alerting you to the use of LFR technology and there is a dedicated Facial Recognition Policy on the main Hippodrome Casino website;
All visitors to Hippodrome Casino, regardless of their reason for attending the venue, are scanned as they enter any of the building entrances and are matched against the stored images in the LFR database.
How It works
We only store images in the LFR database of those individuals that are subject to reasons of local or national self-exclusion or are subject to a Hippodrome banning order for the building premises.
If you are not subject to these use cases, your image will not be on the database.
When you are scanned on entering, if you are not in the database, your image will not be matched and will not be stored in the system and no further processing activity will occur.
If you are in the database, you will be matched, and will be approached by a member of the security team and/or staff and will be challenged about the entry attempt.
Local VSE exclusion or banning data collected internally is not shared with other casinos or organisations.
Data will be shared by us or to us, if you identify as having a gambling problem and register with SENSE – the national self-enrolment exclusion database operated by the Betting and Gaming Council.
Legal Basis for processing
We rely on several legal bases to process your biometric data. Due to our multi venue offerings, footfall volumes and open-door policy, it is not practical to obtain explicit consent for this biometric processing activity. We rely on legitimate interest for self-excluders and those suspended due to suspected unlawful activity.
HOW YOUR PERSONAL INFORMATION IS COLLECTED
We typically collect personal information about you through our customer registration forms, booking systems, tournament entries, playing activity and cookies via the websites. We may sometimes collect additional information from third parties.
Audio recordings are in operation around gaming tables and at the Main Reception Desk.
HOW WE WILL USE INFORMATION ABOUT YOU
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
- To operate the Hippodrome Casino Rewards Program
- To inform you of news, events and promotions we feel may be of interest – based on the marketing preferences we hold on you.
- To carry out our Gambling Commission and wider licencing obligations as a Casino.
- To perform background checks for any reason in relation to our legal obligations to prevent debt (affordability) and fraud.
- To confirm the source of funds, which may include verifying this data with other casinos and gambling establishments.
- To cash cheques and process financial transactions, whether in the form of dent recovery, or the payment of winnings.
Hippodrome Casino will not sell or rent your personal data to any third parties.
SITUATIONS IN WHICH WE WILL USE YOUR PERSONAL INFORMATION
We need all the categories of information detailed in the list above primarily to allow us to perform our contract with you and to enable us to comply with legal and regulatory obligations. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below.
- Administering the contract we have entered into with you and providing our products and services to you
- Business management and planning, including accounting and auditing.
- Making arrangements for the termination of our contracting relationship.
- Dealing with legal disputes involving you, or any disputes that may arise under the contract that we have with you or the way in which we provide our products and services to you.
- To prevent fraud
- For anti-money laundering purposes
- For purposes that promote responsible gambling.
- To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.
- To conduct data analytics studies to review and better understand customer engagement, retention and attrition rates.
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
IF YOU FAIL TO PROVIDE PERSONAL INFORMATION
If you fail to provide certain personal information when requested by us, we may not be able to perform the contract we have entered into with you (such as providing you with our services or guarantees), or we may be prevented from complying with our legal obligations (such as financial and tax reporting and insurance maintenance).
We will store your personal data for as long as we need to fulfil the purposes outlined in this Privacy Notice. For example, under anti-money laundering (AML) guidelines, we are required by law to retain data on patrons who have gambled for 5 years since the last visit, or attempted visit. In some instances, we can extend this retention period to 10 years.
CCTV and audio recordings are retained for 30 days, then automatically deleted.
If you have any questions in relation to our retention of personal data, please contact the Hippodrome Casino Privacy Office on [email protected]
RIGHTS OF ACCESS, CORRECTION, ERASURE & RESTRICTION OF PROCESSING
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
Subject Access Request – this enables you to receive a copy of the personal information we hold about you. To action this request, please email the Hippodrome Casino Privacy Office: [email protected], or write to: Privacy Office, Hippodrome Casino, Cranbourn Street, Leicester Square, London, WC2H 7JH.
We require a suitable form of identification and under normal circumstances, we will supply this to you within one calendar month of your request and of identification being received. No fee is usually payable; however, we may apply an appropriate fee if the request is deemed to be excessive, or repetitive.
Request Correction – this enables you to have any incomplete or inaccurate information we hold about you corrected.
Request Erasure – this enables you to request us to delete or remove personal information when there is no good reason for us to continue processing it.
Object to Processing – in certain circumstances, you have the right to request we suspend the processing of your data. Please contact us if you require more information on this.
Request the Transfer – you have the right to request the transfer of your personal data to a third party. Please contact us if you require more information on this.
Right to Withdraw Consent – where we rely on consent to process your data, you have the right to withdraw this at any time, without giving reason. To withdraw your consent, please contact the Privacy Office. Once received, we will not process your data for the reasons you have agreed to, unless we have another legal basis for doing so.
We reserve the right to update this privacy notice at any time. If you have any questions about this privacy notice, please contact us on [email protected].
If you are based in the EU/EEA, you can still contact us directly, alternatively feel free to contact us via our GDPR EU/EEA Representative, DataRep, which can be reached at:
- [email protected] – be sure to quote <The Hippodrome Casino> in the subject line, otherwise we will not know what your request relates to and it may take significantly longer to administer your email.
- Online webform at www.datarep.com/datarequest
- At the postal address of your country of origin – the full list of which can be accessed here.
Right to complain – you have the right to complain at any time to the Information Commissioners’ Office (ICO) regarding data protection issues that pertain to processing activities of the Hippodrome Casino – https://ico.org.uk