Last Updated 03 October 2011
Ladbrokes is committed to preserving the privacy of all visitors to its Websites. We are committed to ensuring that all services and activities made available via our Websites are provided in a safe and secure online environment.
Information we may collect from you
Use of your information
Monitoring of transactions
Cookies and tracking
Security and privacy
Retention and disposal
Changes to our policy
Accuracy and access to Information
1. Information we may collect from you
We may collect and process the following Information about you:
- Information that you provide by filling in forms on our Websites. This includes Information provided at the time of registering to use our Websites, subscribing to any of our services, posting material or requesting further services. We may also ask you for Information when you enter a competition or promotion, make a customer services enquiry or complaint or when you report a problem with our Websites;
- records of correspondence, if you contact us;
- your responses to any surveys we conduct for research purposes, although you do not have to respond to such surveys;
- details of bets, gaming, payments and other transactions that you conduct on our Websites and details of the fulfilment of your orders;
- details of your visits to our Websites including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise, and the web pages and resources that you access; and
- information and communication on forums on the Websites, for example, chat rooms and message boards (where applicable).
You acknowledge that the information provided by you may amount to personal or sensitive data under the Data Protection Act 1998 and you give your consent to your data being processed as set out in this policy.
2. Use of your information
2.1 We may collect and process Information, including sharing the Information with our third party data processors who process your Information on our behalf, including for the purposes of:
- setting up, re-activating, operating and managing your Ladbrokes account, including providing the services that you request from us;
- building up personal profiles of our customers;
- providing you with information about promotional offers. If you do not wish to receive information about promotional offers and future events organised by us, please make sure that you click on the appropriate "opt out option" box on the account registration form. All our marketing and promotional activities will be in compliance with relevant law, including the Communications (Personal Data & Privacy) Regulations 2006 and the Privacy and Electronic Communications Regulations 2003;
- verifying the accuracy of the Information collected from you, including disclosing your Information to third parties (such as financial institutions, credit reporting agencies and age verification agencies) in connection with such verification;
- complying with our legal and regulatory duties and responsibilities to the relevant licensing and regulatory authorities as well as all duties and responsibilities owed under any other applicable legislation and to any other applicable regulators in other jurisdictions;
- processing card and on-line payments in connection with our services (including our Affiliate Program);
- conducting data cleansing, verification and enhancement exercises, (for example, verifying your Information against third party databases relating to 'movers', 'goneaways' and recent deaths);
- any other purpose which is necessary for the performance of our contractual obligations to you; and
- undertaking research, conducting surveys, research analyses and obtaining feedback from customers.
2.2 Using the internet to collect and process Information necessarily involves the transmission of Information on an international basis. Some third party processors we engage to process Information on our behalf may be based outside the European Economic Area ("EEA"). Therefore, by browsing our Websites and communicating electronically with us, you acknowledge and agree to the transmission and processing of your Information outside the EEA in this way. Countries outside the EEA do not always have strong data protection laws. However, we will always take all steps reasonably necessary to ensure that your Information is used by third party processors securely and in accordance with this policy.
2.3 Except where we engage third parties to process your Information on our behalf for the purposes listed in paragraph 2.1 above, we will not disclose or sell your Information outside Ladbrokes' corporate group, except in connection with a joint venture or the proposed or actual sale of the whole or part of Ladbrokes' business. Unless required to do so by law, we will not otherwise share, sell or distribute any of the Information you provide to us without your consent.
3. Monitoring of transactions
All bets, gaming and account transactions are recorded on our computer system. We also carry out routine monitoring of all transactions as they take place to assist us in improving the service that we provide to you.
4. Telephone calls
Your telephone conversations – either to place a bet or a customer service call - may be recorded both to assist us in training and in quality management, and to allow for the speedy resolution of queries.
5.1 A 'cookie' is a small text file containing small amounts of information which is downloaded to your device when you visit a website or use applications. The cookie enables the server to collect information from the browser.
5.2 We use the cookies on our Websites for a number of purposes, including:
- to authenticate and identify you on our Websites and applications so we can provide you with the services you request;
- to allow you to login to the Websites and to check that your computer is still logged in to the same session while you browse from page to page. While placing bets, Information will be temporarily stored in a cookie until the transaction has been completed. This enables you to get the most out of our products and services. Further, various other settings, such as the language and odds display that you have selected, are stored in cookies for a longer duration so that when you return to the Websites as many of these settings as possible remain the same;
- to automatically collect Information about bets and account transactions carried out on our Websites;
- to deliver adverts and information more relevant to you and your interests and also to help measure the effectiveness of Ladbrokes’ advertising campaigns; and
- to compile reports on Website activity and providing other services relating to Website activity and internet usage. We may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Ladbrokes’ behalf.
5.3 We use flash, session and persistent cookies on our Websites and applications. Flash cookies are small pieces of information stored and accessed by Adobe Flash, the browser plug-in used by sites. Session cookies are used by the server to store information about user page activities so users can easily pick up where they left off on the server's pages. Persistent cookies enable a website to remember you on subsequent visits, speeding up or enhancing your experience of services or functions required.
6. Security and privacy
6.1 We employ security measures to protect your Information from access by unauthorised persons and to prevent unlawful processing, accidental loss, destruction and damage. Protection of your Information, including your registration details and any debit or credit card information you provide to us, is a priority for us. Data on our secure pages is encrypted using Secure Sockets Layer ("SSL") technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Websites, you are responsible for keeping this password confidential.
6.2 Any personal information which identifies you will be encrypted at all times whilst in transit over the internet. SSL is special protocol that automatically encrypts any information sent by you on our secure pages. Our server then reads the information using a private key. This means that your Information, be it debit or credit card information or any other personal details, is turned into a code that can only be decoded with the private key or password. If your browser is suitably configured, you will receive a warning message when you first access any secure page on the Website. This is simply information to advise you that the Website is protecting your Information.
6.3 Unfortunately, the transmission of Information via the internet is not completely secure. Although Ladbrokes will do its best to protect your Information as described in paragraph 6.2 above, it cannot guarantee the security of any Information that you disclose online. You accept the inherent security implications of using the internet and will not hold us responsible for any breach of security unless we have been negligent. For your own privacy protection, we encourage you not to include sensitive Information (such as credit/debit card numbers) in any emails you may send to us.
7. Retention and disposal
It is our policy to retain and make available financial information for a period of 7 years. Other Information will be retained for the period necessary to fulfil the purposes set out in paragraph 2.1 unless a longer retention period is required or permitted by applicable law. We will take all reasonable steps to ensure that the privacy of Information is maintained on disposal.
8. Changes to our policy
We may modify this policy from time to time. Any changes to our policy will become effective upon posting of the revised policy on the Websites.
9. Accuracy and access to Information
9.1 We will take all reasonable steps to ensure that any Information that we collect from you is accurate and has been verified.
9.2 You are entitled to see the Information held about you and you may ask us to make any necessary changes to ensure that it is accurate and kept up to date. We are entitled by law to make a small administrative charge for providing such Information.
9.3 All comments, queries and requests relating to our use of your Information are welcome and should be made in writing or by telephone via the Contact Us section on the Websites
Issue Date: 30 October 2009