Privacy & Cookies
• what information we collect; • how we use that information; • how this information is shared; • your rights; and • other useful privacy and security related matters.
We hope you take the time to read this policy. It is important to check back often for updates to this policy. If we make changes, we consider to be important, we will let you know by placing a notice on the relevant Service and/or contact you using other methods such as email.
Who is the Data Controller? The low6 data controller is low6 Limited.
And, what about the Data Protection Officer? Yes, our DPO can be reached at firstname.lastname@example.org, our Customer Service team will be your initial point of contact if you wish to exercise your rights. Please see the ‘Your Rights’ section below.
Information we collect when you use our Services:
Information you provide us: We collect information about you during the account registration process for any of our Services. This information may include, but is not limited to your name, postal address, e-mail address, phone number, debit card details and any other details as might be requested from you for the purpose of registration and/or continued use of our Services. We may also collect information from you if you request information or customer support.
Additional Information collected: We may also collect the following information:
Third Party and Publicly Available Sources Not all the personal information we hold about you will always come directly from you. We may also collect information from third parties such as our partners, service providers and publicly available websites (i.e. social media platforms), to comply with our legal and regulatory obligations, offer services we think may be of interest, to help us maintain data accuracy and provide and enhance the Services.
We ensure that all personal information that you supply is securely stored by us in accordance with the requirements set out in The General Data Protection Regulation (GDPR) (EU) 2016/679). All personal information stored by us is stored in secure and controlled facilities with protected access to this information restricted to only persons who require access to it.
How do we use this information? We process personal information for these Services- and business-related purposes:
Account setup, verification and management: We use personal information such as your name, email address, phone number, and information about your device to set up and administer your account, provide technical and customer support and training, verify your identity, process payment information and send important account and Service information.
As a condition to using our Services, we will ask you to share your precise geolocation, so we can ensure that we are authorised to provide the Services to you in your location. The above processing is required in order for us to provide the Services to you via our website in accordance to our Terms & Conditions.
To verify your age and accuracy of your registration details, including disclosure of such information to third parties e.g. financial institutions and third-party reference agencies. This is required for the purpose of our complying with our legal obligations.
We may also use personal information to enforce our terms and conditions. Personalisation: We use personal information to deliver and suggest tailored content to personalise your experience with our Services. This is processing which is necessary for the purpose of our legitimate interests in delivering or presenting relevant content to our customers.
Marketing and events: Subject to any preferences you have expressed (where applicable), we use personal information to deliver marketing and event communications to you across various platforms, such as email, telephone, text messaging, direct mail, online, push notification or otherwise. We will do this during the period of your relationship with us and, unless specifically instructed otherwise by you, for a reasonable period of time after the relationship has ended in order to inform you about products, services, promotions and special offers which we think may be of interest to you.
If we send you a marketing email or SMS, it will include instructions on how to opt out of receiving these marketing communications in the future. You can also manage your information and update your marketing preferences through the “My Account” tab when you login to your account. Please allow up to 48 hours for any changes you make to your marketing preferences to be fully processed. Please remember that even if you opt out of receiving marketing emails, we may still send you important Service information related to your accounts and subscriptions.
Legal and regulatory obligations: We may be required to use and retain personal information for legal and compliance reasons, such as the prevention, detection, or investigation of a crime; or fraud. We may also use personal information to meet our internal and external audit requirements, information security purposes, and as we otherwise believe to be necessary or appropriate: (a) under applicable law, which may include laws outside your country of residence; and (b) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include such authorities outside your country of residence.
Profiling: In accordance with our legitimate interests detailed below or to comply with our legal obligations, we carry out profiling and analysis based upon your location data, age, betting and gameplay activity, interests and behaviours for the following purposes:
Customer segmentation to offer you tailored products and services, and more relevant marketing. For example, if the majority of your bets are placed on horse racing, we will aim to primarily send you marketing material related to horse racing;
Risk and trading analysis; and Licensing and legal obligations i.e. Responsible Gambling, Anti Money Laundering, Age Verification, prevention of fraud and to ensure the integrity of sporting events.
Other purposes: We may be required to use and retain personal information for; loss prevention; and to protect our rights, privacy, safety, or property, or those of other persons in accordance with our legitimate interests.
Any information you provide and other information we hold about you will be for the following purposes:
• Account set up, verification and management; • Marketing and events • Risk management; and • Legal and regulatory obligations.
Third parties for legal reasons: We will share personal information when we believe it is required, such as:
• To comply with legal obligations and respond to requests from government agencies, including law enforcement and other public authorities, which may include such authorities outside your country of residence; • In the event of a merger, sale, restructure, acquisition, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings); and • To protect our rights, users, systems, and Services
Regulatory or Sporting body Your personal information including, but not limited to, your registration details, betting records, records of payments, device information etc., may also be disclosed to any regulatory or sporting body (with whom the Group has agreements (Memoranda of Understanding or “MOUs”) for the sharing of such data) in connection with policing the integrity or enforcing the rules of a sport or game and/or prevention and detection of crime and where the Group considers that there are reasonable grounds to suspect that you may be involved in a breach of such rules or the law, have knowledge of a breach of such rules or the law or otherwise pose a threat to the integrity of the relevant sport or game based upon our assessment of your betting behaviours or it may be based on information provided to us by a regulatory or sporting body. Those bodies may then use your personal information to investigate and act on any such breaches in accordance with their procedures.
Your rights Under the General Data Protection Regulation, you, as a data subject have a number of rights which are detailed below. Some of these only apply in specific circumstances and are qualified in several respects by exemptions in data protection legislation. We will advise you in our response to your request if we are relying on any such exemptions.
• Access to personal data: You have a right to request a copy of the personal information that we hold about you. Should you wish to make such a request, please see the Contact Us section for information on how to contact us. You should include adequate information to identify yourself and such other relevant information that will reasonably assist us in fulfilling your request. Your request will be dealt with as soon as possible. • Correction of personal data: You can request us to rectify and correct any personal data that we are processing about you which is incorrect. We provide you with account settings and tools to access the information associated with your account. • Right to withdraw consent: Where we have relied upon your consent to process your personal data, you have the right to withdraw that consent. To opt out of marketing, you can use the unsubscribe link found in the marketing communication you receive from us. For other marketing preferences, you can visit the My Account tab when you log into your account or the contact us option within the relevant Service. • Right of erasure: You can request us to erase your personal data where there is no compelling reason to continue processing. This right only applies in certain circumstances, it is not a guaranteed or absolute right. • Right to data portability: This right allows you to obtain your personal data that you have provided to us with your consent or which was necessary for us to provide you with our products and services in a format which enables you to transfer that personal data to another organisation. You may have the right to have your personal data transferred by us directly to the other organisation, if this is technically feasible. • Right to restrict processing of personal data: You have the right in certain circumstances to request that we suspend our processing of your personal data. Where we suspend our processing of your personal data, we will still be permitted to store your personal data, but any other processing of this information will require your consent, subject to certain exemptions. • Right to object to processing of personal data: You have the right to object to our use of your personal data which is processed on the basis of our legitimate interests. However, we may continue to process your personal data, despite your objection, where there are compelling legitimate grounds to do so or we need to process your personal data in connection with any legal claims.
How to contact us For any requests related to your personal information or any of your rights referenced above, please feel free to contact us in one of the following ways:
Email: info@Low6.co.uk Phone: 0121 295 1235 Post: Low 6 Limited, 2 Shottery Brook Office Park, Timothy’s Bridge Road, Stratford-upon-Avon, Warwickshire, CV37 9NR.
Last updated 27th February 2020