Privacy Statement

Who are we?

The Greyhound Stadium is run by Ladbrokes Betting & Gaming Ltd. which is a member of GVC Group of companies. This Policy explains how we collect your personal data and what it will be used for.  

Where we use the term “we” or “us”, this includes the entity and Brands (https://gvc-plc.com/about/business-overview/our-brands/) and other companies within the GVC group.

We are committed to protecting your personal data when you use our services through our website and mobile application and take the security of your information very seriously.  We have strict security measures in place to protect your personal data which includes robust security procedures which are regularly tested and reviewed.   If you have any concerns about the way in which we process or protect your personal data or would like to contact us about any aspect of this policy, please get in touch through the contact details at the bottom of this statement.

This privacy policy should be read in conjunction with our cookies policy, any notices or terms located within the stores and our site terms of use/terms and conditions.

The Information we collect about you

We will collect personal data about you from the following sources:

• When you contact us to book tickets or make a reservation

• When you visit us at the Stadium
• When you register as an owner or as a Trainer (and we publish your information on our website)
• When you visit our website
• When you sign up to receive information about our activities or promotions
• When you communicate with us (by email, mail, phone, in-store or through chat or social media)

• From cookies and tracking devices on your devices where you have permitted their use.

DIGITAL

What We Use Your Personal Data for

What we use your Personal Data for	Typical Personal Data	Further information	Legal basis
Provision of tickets	Your name, home or email address, telephone number or online identity or other contact information you provide to us. Card details when you pay	To meet our obligations arising from any agreements entered into between you and us	Performance of contract Legal obligations
Customer Service matters	Name, online identity, Player ID Contact Information Account notes and communications	To provide you with customer services, answer your questions or address your complaints or concerns.	Performance of contract Legitimate interests in customer satisfaction and protecting our business
Meeting our legal and regulatory obligations	Facial images, CCTV images, a physical description or profile of you where your personal details are unknown to us Health Information Biometric data (for example facial recognition)	To discharge our legal and regulatory obligations and duties which include (but are not limited to) Gambling Act and Responsible Gambling obligations, Anti-money Laundering, Anti-fraud & Anti-terrorism laws, Health & Safety matters.   This may include electronic methods of identifying you, such as through the use of biometric facial recognition procedures	Legal obligation Protect the vital interests of data subjects and others Performance of a task carried out in the public interest Legitimate interests in protecting our business, staff and customers
Responsible Gambling and Self-Exclusion Identity Checks and Age Verification	Facial images, CCTV images A physical description or profile of you where your personal details are unknown to us	To meet our Responsible Gambling obligations (such as recording self-excluders and where we believe a customer has a gambling problem).   To check or validate your identity, age and protect your information This may include electronic methods of identifying you, such as through the use of biometric facial recognition procedures	Consent Performance of contract Legal obligation Protect the vital interests of data subjects and others Performance of a task carried out in the public interest
Lifestyle and demographic Insight and Profiling	Name and contact details Contact preference Interests	Your preferences and your interests are recorded and where you have asked us to we will use this information to keep you informed about our services and products. You can opt-out of receiving this information at any time.	Consent Legitimate interests
Prevention and Detection of Crime, Prevention of loss Protection of staff and customers Ensuring the integrity of the sport	Names and contact information Facial images, CCTV images, a physical description or profile of you where your personal details are unknown to us History of interaction with you	To prevent or detect fraud, theft or loss to our business and our customers and prevent the use of unfair practices (for example in potential breach of our General Terms and Conditions or of applicable law). To protect our staff and other individuals from harm or loss This may include CCTV, electronic methods of identifying you, such as through the use of biometric facial recognition in our shops	Performance of a task carried out in the public interest Legitimate interests to protect our customers, business and workers.
Registering entrants into races (owners and trainers)	Name, date of birth and contact details Kennel details Relevant experience Entrants registered	To fulfil our obligations to you and yours to us when you register entrants into our races and manage the administration of such events	Performance of a contract between us
Business sale, acquisition and rights	CCTV images,	To exercise or defend legal claims or acquiring or selling a business	Legitimate interests to protect and defend our business

Much of the information we collect about you is required to meet our legal and regulatory obligations, such as Gambling Act and Money Laundering, however, where we ask for your consent to process your personal data, you are not required to provide it, however, if you do not do so, you may not be able to take advantage of our services.

We may also store more sensitive personal data about you (often referred to as “special categories of personal data”) which may come directly from you, from other sources as described above or from decisions we have made about you to meet our responsible gambling obligations.

Some of these decisions or actions we may take in managing your account or meeting our legal obligations may involve fully automated decisions. We will however always provide you with contact details where you can ask for a review of the decision or get further information from us.

Who we may pass your data on to:

We may need to share personal information with other organisations to ensure that we meet our legal obligations or where we need support in meeting your needs or our contractual obligations.  We may also share information with other organisations where we consider it to be in the public interest or in the legitimate interest of ourselves or these other parties. These other parties are typically:

• business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
• members of the GVC Group and third party suppliers and service providers for the purposes identified above;
• third party suppliers and service providers to the extent they assist the GVC Group with its legal/regulatory obligations e.g. providers of services in respect of anti-money laundering, fraud, verification etc.;

• analytics and search engine providers that assist us in the improvement and optimization of our site and other selected third parties;
• other gambling operators, banks, credit card companies, Sports Governing Bodies and appropriate agencies for the purpose of investigating and safeguarding against underage, fraudulent, criminal or suspicious activity (or other activities we are bound by law, regulation or guidance to investigate and safeguard against) or if we have reason to believe that you have undertaken such activity; and
• our regulators, law enforcement or fraud prevention agencies, as well as our legal advisers, courts, applicable independent adjudication services, sports' governing bodies and betting integrity organisations and any other authorised bodies, for the purposes of investigating any actual or suspected criminal activity, maintaining standards of behaviour in sport or other regulatory or legal matters

We may share your personal information with other members of the GVC Group for marketing purposes.  We will not share it with other 3rd party organisations however unless you have expressly opted-in/consented to the disclosure of your personal data for these purposes. If you are based within the UK, when we check your identity when you first become a customer, or check your financial status as required by our License Conditions, we share information with a Credit Reference Agency and this will leave a “soft” footprint on your credit file. Further information about how this agency holds and uses your information can be found here: https://www.callcredit.co.uk/legal-information/bureau-privacy-notice.

We may also disclose your personal information to third parties in the following circumstances:

• in the event that we consider selling or buying any business or assets, in which case we will disclose your personal data to any prospective sellers or buyers of such business or assets;
• in the event of any insolvency situation (e.g. the administration or liquidation) of GVC Group plc, or a data controller or any of its group entities;
• if we, or substantially all of our assets, are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;
• in order to enforce or apply our terms of use;
• to protect the rights, property, or safety of us, our staff, our customers, or others.  This includes exchanging information with other companies and organisations (including without limitation, other gambling operators and the local police or other local law enforcement agencies) for the purposes of staff and customer safety, crime prevention, fraud protection and credit risk reduction;

• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or regulatory requirements, or otherwise for the prevention or detection of fraud or crime; and
• Where you have self-excluded yourself from gambling, we may share this information with our regulators or other companies in our field where we believe it is important to support your exclusion

If you are a Trainer, we will publish your details on our website in order to support your legitimate business interest. If, however you wish this information to be removed, please contact us to make the necessary changes.

Meeting our Responsible Gambling Obligations

We have an obligation to identify those at harm from gambling as early as we can and help them stop gambling by suspending accounts or stopping them entering our shops. 

In order to meet these obligations, we continuously analyse customer’s transactions and evaluate behaviour. 

We are also constantly looking at innovative ways to help spot players who may be on a path to difficulties or identify them in our shops.  This means that we may use systems that identify customers (such as facial recognition in our shops or cookies on player’s devices).  We may also share player data with specialist organisations who help evaluate risks by looking at how you may interact with other gambling operators or help individuals directly. 

In all these cases, please be assured that we take our obligations - both in helping customers gamble responsibly and of protecting personal information- very seriously and we will always ensure that we take the most appropriate measures and controls to protect your data,

How long we retain your personal data

Type of Data	Typical Retention Time	Information
Marketing consents	24 months	Unless consent is refreshed
CCTV	Up to 36 months	Extended retention may be applied on a case by case basis
Customer or Trainer Data	A seven-year retention period which starts to run from the last interaction date with you	We will only continue to hold personal data relating to you as permitted under data protection legislation (i) where we are under a legal requirement under gambling or tax legislation to retain your data; and (ii) to exercise or defend our legal rights If you register under the self-exclusion scheme, whilst the self-exclusion itself may have a shorter duration, a record of this will be retained as part of your customer profile in line with this retention policy.

The above retention times may be extended for example where it is needed to meet a specific regulatory obligation, investigate a crime, handle a claim or resolve a complaint

Locations that we may transfer your personal data

From time to time, service providers, members of the GVC Group and organisations with whom we work with, may be located outside the UK or European Economic Area in countries that do not have the same standards of protection for personal data as the UK or EEA Countries. We will, however, always use every reasonable effort to ensure sufficient protections are in place to safeguard your personal data. We will also ensure that our service providers enter into compliant processing agreements with us to ensure that your personal data is processed in accordance with applicable data protection legislation. Further information about the mechanisms we will apply can be found here but please contact us at the “data protection” email address below if you have any specific questions regarding international transfers: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_en

Security

We implement technical and organisational measures which take into account the harm that may be suffered, to protect your personal data.  All information you provide to us is stored on our secure servers.

Cookies

We use cookies for various purposes including making your experience of our website better. For more information on our use of cookies, please see our policy below.

Marketing Communications and your choices

When we first collect your personal data we’ll ask you to tell us how you would like to hear from us in future about our other products and services. It’ will normally be via tick boxes on forms and you can opt-out at any time.

What is 'Opting Out'?

The term opt-out refers to several methods by which individuals can avoid receiving unsolicited product or service information. This ability is usually associated with direct marketing campaigns such as telemarketing, e-mail marketing, or direct mail.

*Please consider that 'opting out' will not prevent any essential customer correspondence e.g. bet or account correspondence.

How can I opt-out of marketing correspondence?

If you do not wish to receive any offers, promotions, information on events and tailored communications based on your account activity, you can request to be made un-contactable by:

• Using the “unsubscribe” option provided in any electronic marketing communication you receive
• contacting us at [add contact details].

What details do you require from me?

Your rights

	DESCRIPTION OF RIGHT
Right 1 The right of access	You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights.
Right 2 The right to be informed	A right to access personal data held by us about you.
Right 3 The right to rectification	A right to require us to rectify any inaccurate personal data held by us about you.
Right 4 The right to erasure	A right to require us to erase personal data held by us about you.  This right will only apply where (for example): we no longer need to use the personal data to achieve the purpose we collected it for; or where you withdraw your consent if we are using your personal data based on your consent; or where you object to the way we process your data (in line with Right 6 below). This right is not absolute and will not apply when legitimate and overriding reasons apply.
Right 5 The right to object to processing	In certain circumstances, a right to restrict our processing of personal data held by us about you.  This right will only apply where (for example): you dispute the accuracy of the personal data held by us; or where you would have the right to require us to erase the personal data but would prefer that our processing is restricted instead; or where we no longer need to use the personal data to achieve the purpose we collected it for, but you require the data for the purposes of dealing with legal claims.
Right 6 The right to data portability	In certain circumstances, a right to receive personal data, which you have provided to us, in a structured, commonly used and machine-readable format.  You also have the right to require us to transfer this personal data to another organisation, at your request.
Right 7 The right to object processing	A right to object to our processing of personal data held by us about you where the processing of such data is necessary for the purposes of our legitimate interests unless we are able to demonstrate, on balance, legitimate grounds for continuing to process personal data which override your rights or which are for the establishment, exercise or defence of legal claims.
Right 8 The right not to be subject to automated decisions including profiling	A right for you not to be subject to a decision based solely on an automated process, including profiling, which produces legal effects concerning you or similarly significantly affects you.
Right 9 The right to withdraw consent	A right to withdraw your consent, where we are relying on it to use your personal data (for example, to provide you with marketing information about our services or products).
Right 10 The right to lodge a complaint	You have the right to complain to the relevant Data Protection Supervisory Authority.  In the UK, this is the Information Commissioner’s Office and in Gibraltar, the Gibraltar Regulatory Authority (GRA)

Contact Us or Our Data Protection Officer

If you have any questions about this notice or would like further information about your rights, please contact one of the following means:

By email: dataprotection@gvcgroup.com.

By Post: GVC Holdings Plc, 32 Athol Street, Douglas, Isle of Man. IM1 1JB

Our Data Protection Officer is also be contacted at the above address or by emailing dataprotection@gvcgroup.com.

Questions, comments and requests regarding this privacy policy are welcomed.

Changes to this Privacy Policy

Any changes to this privacy policy in the future will be posted on this page, and where appropriate, notified to you by email. Please check back frequently to see any updates or changes to this privacy policy.

This policy was last reviewed and updated: March 2020