Hippodrome Casino Rewards App: Privacy Notice

Introduction

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 within the Hippodrome Casino Rewards App, 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:

1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have informed you about.
6. Kept securely.
7. We are accountable as a Controller for the principles and individual rights with respect to the processing we undertake.

How Your Personal Information Is Collected & The Type Of Data Accessed

The Hippodrome Rewards App collects personal information about you from the internal systems within Hippodrome Casino, and our external partners who administer payment transactions as part of the cashless wallet.

The app retrieves data from our internal systems based on the demands of the user, such as full name, address, photographic image, membership details, internal ID and voucher information.

The cashless wallet is purely a number assigned to you in our customer database and transactional records are retained by the business, but not shared with any third parties.

We partner with Paypal, Octo and Trust Payments for the purpose of administering funds to your account and data is received from these partners via an API. No data is shared by Hippodrome to these third parties. The Rewards App notifies the appropriate partner if you wish to top-up or withdraw funds and the supporting partner administers this request.

If you use Google Pay or Apple Pay, the last 4 digits of your registered card number will be shared with Hippodrome.

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:

1. To operate the Hippodrome Casino Rewards Program.
2. To administer the flow of funds to and from the cashless wallet.
3. To inform you of news, events and promotions we feel may be of interest – based on the marketing preferences we hold on you.
4. To carry out our Gambling Commission and wider licencing obligations as a Casino.
5. To perform background checks for any reason in relation to our legal obligations to prevent debt (affordability) and fraud.
6. To confirm the source of funds, which may include verifying this data with other casinos and gambling establishments.
7. To cash cheques and process financial transactions, whether in the form of debt recovery, or the payment of winnings.

Hippodrome Casino will not sell or rent your personal data to any third parties. We will only share your personal data where we are required to as part of our Licencing Conditions.

Situations In Which We Will Use Your Personal Data

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).

Data Retention

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.

Your Rights:

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.

Contact Us

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 “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

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