Privacy Policy
Membership Privacy Policy
The privacy and security of your personal data is of the utmost importance to Cosmo Bingo and we invest heavily in measures that help to protect your data protection rights.
This policy describes how and why we collect, store, process and manage the personal data we hold from our members. The term ‘Personal Data’ refers to any information relating to an identifiable individual or his or her personal identity.
This policy outlines how your data will be processed lawfully, fairly and in a transparent manner. Cosmo Bingo does not sell or rent your personal data to third parties for marketing purposes whatsoever.
We will ensure that the personal data we process is accurate, adequate, relevant and not excessive, given the purpose for which it was obtained. We will not process personal data obtained for one particular purpose for any unconnected purpose unless the person has agreed to this or would otherwise reasonably expect this.
Cosmo Bingo collects your personal data in order to manage your membership of our clubs. We also collect your data so that we can send you marketing information regarding our products, promotions and services for which you have provided your consent by specifying your choice of medium for receiving the communication.
Cosmo Bingo has appointed a Data Protection Officer (DPO) who is responsible for ensuring that personal data is managed responsibly throughout the company. You can contact the DPO using the details listed at the end of this document.
You have the right to see the data we hold on you, rectify that data and also to request us to delete that data at any time.
1.Introduction
1.1 Cosmo Bingo is the data controller of the personal data you provide to it.
1.2 This Privacy Policy sets out the way Cosmo Bingo Halls Manchester Limited trading as Cosmo Bingo (“we”, “us” or “Cosmo Bingo”), collects and processes Personal Information of our club members. Cosmo Bingo is registered for the purposes of data protection with the Information Commissioner’s Office in the UK (Registration Reference ICO: ZB502084).
1.3 By using our Services and registering for membership, you acknowledge that you have read, and agree to the terms of this Privacy Policy.
1.4 This Privacy Policy is incorporated into, and forms part of our terms & conditions of membership.
2.The information we collect
2.1 As part of maintaining your membership, we collect your Personal Information. “Personal Information” means any information from which you, as a ‘data subject’, can be personally identified, including (for example) your name, email address, home address, telephone number or date of birth.
2.2 We collect your Personal Information when you register for membership, through the use of online forms and when you email us your details. We also collect information about the transactions you undertake whilst at our clubs.
2.3 In addition, we may collect Personal Information through surveys which we undertake. Such surveys are voluntary and are anonymous where possible.
3.Your rights as a ‘data subject’
3.1 Under data protection law you retain the following rights over your personal data outlined in paragraph 3.2.
3.2 Your Data Protection Rights:
- The right to access the data we hold about you
- The right to rectification of any data that is inaccurate or incomplete.
- The right to erasure of your data (also known as ‘the right to be forgotten’)
- The right to restrict processing of your data
- The right to data portability
- The right to object to the processing of your data
3.3 If you exercise your right to be forgotten and Cosmo Bingo was no longer obliged to retain the data as per section 9 below, this would result in a termination of your membership to Cosmo Bingo. This means you would no longer be able to visit or play at our clubs unless you were to re-join as a member.
4.Our basis for processing personal data
4.1 For the purpose of managing a regulated business within the Gambling Industry it is important for us to maintain a membership database. This database allows us to achieve our regulatory compliance responsibilities and safeguard the security of our members.
4.2 It is a requirement of our Terms and Conditions that any person who wishes to attend or partake in the services offered at our premises must register as a member.
4.3 Information collected and processed for the purposes of becoming and remaining a member is on basis of our legitimate interests and compliance with our legal obligations. The justification for this is outlined in 4.1 above.
4.4 In order to keep you up to date with our news and promotional events we create and send regular marketing information via direct marketing, SMS, post and email channels. In order to send you this information we will gain your consent. This is usually obtained at the point of registration.
4.5 This consent can be withdrawn at any time by speaking to your local club or by contacting the Data Protection Officer using the details at the end of this policy.
5.How we use your Personal Information
5.1 Your Personal Information is processed by us to provide you with the products and services relating to our business. In particular, we collect your Personal Information in order to enable us to:
- Set-up, administer and manage your membership, associated accounts and records;
- Receive and respond to your communications and requests;
- Notify you about promotional offers and general marketing;
- Ensure that we are able to fulfil our regulatory obligations regarding your account, including by verifying the accuracy of any information you give us;
- Comply with our obligations under applicable laws (including, but not limited to the Gambling Act 2005);
- Investigate, and assist with the investigation of, suspected unlawful, fraudulent or other improper activity connected with the services (including, where appropriate, dealing with requests from regulatory bodies for the sharing of information);
- Carry out market research campaigns;
- In the event that we sell or buy any business, assets or shares in part or whole we may disclose your personal details to such relevant third parties involved.
6.1 We may disclose your Personal Information to any of the following recipients:
- Any company within our Group (including to its employees and sub-contractors) which assists us in providing the services or which otherwise has a need to know such information.
- Any contractors or other advisers auditing any of our business processes or who have the need to access such information for the purpose of advising us.
- Any data processor which enables us to manage systems or processes as part of any service or promotion offered to our members.
- Any law enforcement or regulatory body which may have any reasonable requirement to access your Personal Information.
- In the event that we sell or buy any business, assets or shares in part or whole we may disclose your personal details to such relevant third parties involved.
7.1 We will not send you unsolicited information regarding any third party’s products or services.
7.2 As part of the account registration process, you will have the opportunity to choose whether or not to receive information on our offers and promotions.
7.3 If you have consented to receiving marketing from us, we will send you promotional marketing information and updates until such time that you inform us that you do not wish to continue to receive them. You may update your marketing preferences at any time by contacting your local club or through the contact form on our website: www.cosmobingoonline.com
8.Accessing and Updating your Personal Information
8.1 You may update your Personal Information at any time by contacting your local club or the company data protection officer using the details below.
8.2 You may obtain a copy of your Personal Information held by us by contacting our Customer Services team or by writing to us at: The Data Protection Officer, Cosmo Bingo Halls Manchester Limited, 62 Market Street, Stalybridge, SK15 2AB. We require up to one month in order to respond to such requests.
8.3 Requests for access to your personal data are free of charge.
9.How long do we keep your data for?9.1 We retain personal information for as long as we reasonably require it for legal, accounting or business purposes. Subject to us not having a legal or regulatory requirement or a risk management reason for retaining your information for a longer period, your information will not be kept for longer than 5 years after you have closed your account. Please note that we may be required in certain circumstances to retain your information indefinitely (for example under our procedures on responsible gambling and self-exclusion). We will take all necessary steps to ensure that the privacy of information is maintained for the period of retention.
9.2 Data retention periods:
|
Membership information |
This is the information we collect at the point of registration |
Data retained for 5 years after the business relationship has ended. |
|
Marketing Preferences |
These are the marketing channels you give consent for us to contact you by |
Where explicit marketing consent has been given, we will send you promotional marketing information and updates until such time that you inform us that you do not wish to continue to receive them. This data is retained indefinitely to ensure we continue to abide by your wishes. |
|
Information required by legislation |
This includes data which relates to social responsibility or anti-money laundering policy and includes self-exclusion information |
Most data retained for 10 years after data subjects’ most recent visit. Self-exclusion data is retained for 5 years after the end of the last period of self-exclusion. |
|
Data relating to spend information |
This includes information on cash or card transactions which take place on or around our premises in exchange for products or services provided by Cosmo Bingo |
Data retained for 5 years after the business relationship has ended. |
Figure 1.1 data retention periods
10.Advertising and use of Cookies10.1 We may collect anonymous information about your use of our website (the website’ refers specifically to https://www.cosmobingoonline.com), if appropriate using “cookies”, pixel tags and similar functionality. We use cookies for the operation of the website. We also use cookies for our own analytical purposes so that we can improve our customers’ experience.
10.2 If you object to cookies or want to delete any cookies that are already stored on your computer, you should follow the instructions for deleting existing cookies and disabling future cookies on your web browser or equivalent software. Further information is available at www.aboutcookies.org.
10.3 As part of the website’s operation, and for our own statistical analysis of site traffic, our website automatically logs internet IP addresses.
11.Security11.1 We use a number of methods to ensure that all customer information remains confidential and secure.
11.2 We may send your personal information to countries that are within the European Economic Area (EEA), and which are subject to the EU General Data Protection Regulation, which provides effectively identical data protection as the UK General Data Protection Regulation.
11.3 We do not usually transfer your personal information to countries that are outside of the EEA. However, we may sometimes send such data to a recipient in a country outside the EEA which has been designated by the Information Commissioner’s Office as providing adequate data protection. If we need to send the data to a country outside the EEA that has not been so designated, we will have appropriate contract clauses agreed with the recipient in place to protect the data.
12. ComplaintsCosmo Bingo takes the responsibility of holding personal data very seriously and is happy to receive any queries or concerns you may have. If you believe that we have not adhered to this policy or that your data has been handled in a way which you feel is not in accordance with your wishes then you may complain to the Data Protection Officer using the contact details below.
The Data Protection Officer,
Cosmo Bingo Halls Manchester Limited
62 Market Street
Stalybridge
SK15 2AB
Alternatively, you may contact the Information Commissioner’s Office (ICO) directly who are the body responsible for managing data protection compliance in the UK.
You can contact the ICO at the following address:
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow Cheshire SK9 5AF
casework@ico.org.uk Tel: 0303 123 1113
13.Contact information
Please contact us via the contact form on our website or in writing to:
The Data Protection Officer,
Cosmo Bingo Halls Manchester Limited
62 Market Street
Stalybridge
SK15 2AB
