Privacy Policy

How we safeguard your personal information.

INTRODUCTION

We at Celeblotto take your privacy very seriously and are committed to keeping your personal data safe. This Privacy Policy (alongside our Term & Conditions and Legal information) informs you about the way we look after your personal data when you visit our website/app, your rights and how the law looks after you.

PURPOSE OF THIS PRIVACY POLICY

This Privacy Policy gives you all the information you need to know on how we collect, store and process your personal data in you Celeblotto account.

It is important that you read this Privacy Policy together with any other notice on the subject of privacy or fair processing that we may add to actions on the Website/App when we are collecting or processing your personal data.

WHO ARE WE & OUR ROLE AS DATA CONTROLLER

This website is operated by PLAYLOT.TO Limited, trading as Celeblotto, so when we mention “Celeblotto”, “we”, “us” or “our” in this Privacy Policy, we are also referring to PLAYLOT.TO Limited which is the ‘data controller’ (a term used in the data protection legislation) responsible for processing your personal data.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

OUR CONTACT DETAILS

Our full company contact details are:

PLAYLOT.TO LIMITED t/a Celeblotto

3a Cestrian Court, Lightfoot Street, Chester, CH2 3AD, United Kingdom

Our appointed Data Protection Officer can be reached on support@celeblotto.com - it would help if headed any contact Data Protection so that we can ensure it gets to the Data Protection Officer immediately, albeit this is not necessary.

You have the right to make a complaint at any time to the Information Commissioner, the United Kingdom's supervisory authority for data protection issues (www.ico.org.uk). Contact details:

Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Email: casework@ico.org.uk

We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact our DPO using the contact information above in the first instance.

PLEASE HELP US KEEP YOUR DATA UP TO DATE

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. If any of your personal details are incorrect, you can update them in the “Account” section of the Website/App, or you can contact our Customer Care team via email at support@celeblotto.com.

CHANGES TO THE PRIVACY POLICY

We may need to change this Privacy Policy from time to time. If we do change the Privacy Policy, we will post the new version on the Website/App. The new version of the Privacy Policy will take effect immediately upon its publication on the Website/App.

THIRD-PARTY LINKS

This Website/App may include links to third-party websites, plug-ins and applications (for example Facebook, Twitter etc).

Clicking on such links may allow third parties to collect or share data about you (albeit they should require you to authorise this with a cookie control form in the usual way). Once you have left our site, we are no longer in control of the way these third-parties act or collect data and we encourage you to read the Privacy Policy of every website you visit and be cautious about signing up to their data collection policy.

PART 1 - THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about you that can identify you. It does not include data where identity indicators have been removed (anonymized data).

We may collect, use, store and transfer different kinds of personal data about you as follows:

  • Identity Data includes: first name, last name, username or similar identifier, title, date of birth and gender.
  • Contact Data includes: address, email, telephone and social handles.
  • Financial Data includes: bank account and payment card details.
  • Transaction Data includes: details about payments to and from you and other details of bets placed, games played, and products you have purchased.
  • 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 and other technology on the devices you use to access our products and games.
  • Profile Data includes your username and password, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use the Website/App.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  • We also collect, use and share Aggregated Data such as statistical or demographic data. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity - this is the anonymized data we described above.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to provide you with the services we offer on the Website/App.

PART 2 - HOW IS YOUR PERSONAL DATA COLLECTED

We use different methods to collect data from and about you including:

  • Direct interactions. You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise when you:
    • Place a bet with us or play a game;
    • create an account with us;
    • request marketing to be sent to you;
    • enter a competition, promotion or survey; or
    • give us some feedback.
  • Automated technologies or interactions. As you interact with our Website/App, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies (such as Google Analytics).
  • Third parties or publicly available sources. We may also receive personal data about you from various third parties and publicly available sources and utilize this information for identification checks to minimize fraud or money laundering risks that we are duty-bound to undertake.

PART 3 - USING YOUR DATA

GENERAL

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests do not override ours.
  • Where we need to comply with a legal or regulatory obligation.
  • We rely on imputed consent as the legal basis for processing your personal data to undertake the transactions you have requested.

In relation to sending third-party direct marketing communications to you via any media other than messages appearing in the Website/App, we rely on actual consent that you can manage in the Account section. You also have the right to withdraw any consent to marketing at any time by contacting us at support@celeblotto.com

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have provided a non-exhaustive list of descriptions (What) of the ways we use your personal data below showing, what types of data we process when doing so (Which) and why we have a legal basis for doing so (why). We have also identified what our legitimate interests are where appropriate.

  • What we do -  Register you as a new customer or to verify your age and to ensure you are not gambling from a restricted country.
    • Which data - Identity, Contact
      • Why we do it - To start our contract with you.
  • What we do - Process your bets and to enable you to play games including, taking payments from you and paying your winnings as well as collecting and recovering money owed to us including any fees and charges.
    • Which data - Identity, Contact, Financial, Transaction, Marketing & Communications.
      • Why we do it - Performance of a contract with you and necessary for our legitimate interests (such as to recover debts).
  • What we do -  Manage our relationship with you such as telling you about changes to our terms and conditions or privacy policy or enabling you to interact with our Customer Care team via email, phone and live chat.
    • Which data - Identity, Contact, Profile, Marketing & Communications.
      • Why we do it - Performance of our contract with you and comply with legal obligations as well as meeting our legitimate interests (to keep our records updated and to study how customers use our products/services)
  • What we do -  Provide with offers for free competitions or complete a survey or other tool to enhnace your experience with us.
    • Which data - Identity, Contact, Usage, Profile, Marketing & Communications.
      • Why we do it - Performance of our contract with you and for our legitimate interests in finding out how you use our products/services, what you like and develop our relationship with you.
  • What we do -  Administer and protect our business and the security of our website/app (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
    • Which data - Identity, Contact, Technical.
      • Why we do it - For our legitimate interests in running our business, provision of administration and IT services, network security, to prevent fraud and comply with our legal obligations. 
  • What we do -  Deliver relevant website/app content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.
    • Which data - dentity, Contact, Usage, Profile, Marketing & Communications and Technical.
      • Why we do it - for our legitimate interests in studing how you use our products/services etc.
  • What we do -  Use data analytics to improve our website/app, products/services, marketing, customer relationships and experiences
    • Which data - Technical and Usage.
      • Why we do it - for our legitimate interests in defining types of customers for our products and services, to keep our website/app updated and relevant, to develop our business and to inform our marketing strategy.
  • What we do - Making suggestions and recommendations to you about our products and offers or promotions that may be of interest to you and to carry out direct marketing.
    • Which data - Identity, Contact, Usage, Profile, Marketing & Communications and Technical.
      • Why we do it - for our legitimate interests in developing our products/services and our business generally.

 [Note that we may process your personal data for more than one lawful ground at a time.]

MARKETING

We strive to provide you with choices and a personalised online betting experience, so you can receive offers or betting products that are relevant for you, in accordance with your marketing preferences.

You can opt out and unsubscribe and stop receiving personalised offers via email and SMS by clicking the unsubscribe link within each email or SMS that you receive from us, or by changing your marketing preferences in the My Account section of your account.

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. (we call this marketing).

You will receive marketing communications from us if you have opened an account with us or purchased a bet or played a game or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not unsubscribed from receiving such marketing communication.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any company outside Celeblotto for marketing purposes.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.

COOKIES

To enable the working of certain functions during your visit to our website or App, we make use of cookies on various pages. Cookies are small text files that are stored on your device. We make use of certain cookies that are deleted after your browsing session (session cookies). Other cookies remain on your device and allow our business partners and us to read information we have written into the file. The second type of cookies are read by us on your next visit to our website/app (persistent cookies).

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website or App may become inaccessible or not function properly.

DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:

  • Other companies linked directly to PLAYLOT.TO Limited, acting as joint controllers or processors and who provide customer services, IT and system administration services such as our payments processor (Wirecard - see express declaration below).
  • Fraud prevention agencies used to provide customer due diligence including, money laundering, fraud and sanctions checks.
  • External third parties to provide marketing and promotional services on our behalf.
  • Third parties that we sell, transfer or merge parts of our business or our assets with. If such a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.
  • Service providers who provide our IT and system administration services.
  • Professional advisers, including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services to us.
  • Regulators and other authorities who require reporting of processing activities in certain circumstance.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

INTERNATIONAL TRANSFERS

We do not transfer your personal data outside the European Economic Area (EEA).

PAYMENTS

Wirecard processes all credit card payments made on Celeblotto. In this capacity, Wirecard is acting as a ‘controller’ under Article 4 (7) of the General Data Protection Regulation (GDPR). Further details of which can be found at https://www.wirecardbank.com/GDPR.

DATA SECURITY

OUR DATA SECURITY CONTROLS

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for five years after they cease being customers for money laundering purposes.

YOUR LEGAL RIGHTS & ACCESS TO THE DATA WE HOLD

RIGHTS

At any point while we are in possession of or processing your personal data, you have the following rights:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. 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.
  • Request erasure of your personal data. 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 also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your 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 some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. If you still wish to exercise your right to object, we may have to terminate your account or cancel a bet you have placed with us but we will notify you if this is the case at the time.
  • Request restriction of processing of 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.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, 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.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact the DPO.

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

Celeblotto tries to respond to all legitimate requests within one month. Occasionally it may take us longer than this if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.