Stride Gaming is a leading online gaming operator providing bingo, casino, slots and social gaming in the UK.
We’re proud to be able to bring you industry leading offers, bonuses and games from our companies.
Daub Alderney is an interactive gaming company who operate our flagship software to bring you unique online entertainment experiences.
8Ball Games specialises in multi-platform online bingo and casino brands to offer bespoke gaming experiences and unrivalled choice.
Aspers online is a joint venture between Stride Gaming and Aspers Group to bring the luxury experience of Aspers Casino to you on the go.
Group Service Companies
Stride Together Limited |Think Beyond Media Limited |Spacebar Media Limited |SRG Services Limited |Netboost Media Limited
- The Stride Group
- The types of personal data that we collect
- The reasons why we collect personal data
- Consent and the withdrawal of consent
- The use we make of personal data
- Data sharing
- International data transfers
- Information technology and data security
- Public forums
- Child safety
- Retention of personal data
- Your rights in relation to your personal data
- Exemptions to your rights in relation to your personal data
- Cookies and pixels
- How to contact us
1. ABOUT THE STRIDE GROUP
The Stride Group is made up of Stride Gaming Plc (“Stride”) which is a market leading online gaming operator and its subsidiaries which include: Daub Alderney Limited (“Daub”) (Bailiwick of Guernsey), Stride Together Limited (UK), Think Beyond Media Limited (UK), 8Ball Games Limited (UK), Stride Investment Limited (UK), Spacebar Media Limited (UK), STR Financials (Israel), Aspers Online Limited (UK), SRG Services Limited (Mauritius), Baldo Line s.r.l (Italy), Passion Gaming Private Limited (India), Shifttech (PTY) Limited (South Africa), NetBoost Media Limited (Israel) and Infiapps Limited (Israel).
In order to provide our products and services to our customers we need to process personal data about them. The processing activities that we may carry out in relation to your personal data include requesting it, collecting it, storing it, analysing it and sharing it. Each subsidiary in the Stride Group is a data controller and, in accordance with the General Data Protection Regulation (“GDPR”), each is registered with the national supervisory authority for data protection in its home jurisdiction.
The Stride Group provides services through various applications and/or platforms and which include:
- mobile applications;
- downloadable applications;
- non-downloadable applications; and
- social media networks.
These applications are operated by Daub which is a company registered in Alderney (registration number 1726) and licensed by the Alderney Gambling Control Commission (AGCC) (licence number 71.C1) and by the UK Gambling Commission (UKGC) (reference 39022) in order for the Stride Group to provide its online gaming products and services to its customers. Daub is a data controller and is registered with the Office of the Data Protection Commissioner in the Bailiwick of Guernsey.
2. COLLECTION OF PERSONAL DATA
Personal data is information about you and that identifies you or may reasonably identify you (in conjunction with any other information that we hold about you) for example, your name, e-mail address, address or telephone number, IP address, copies of ID, proof of address, etc.
The personal data that we may collect and process includes information within the following categories:
Personal data collected directly from data subjects:
- Registration details:we will collect personal data from you when you register with us, for example, first and last name, email address, gender, birth data (date and place of birth), physical address, country of residence, city of residence, email address, phone number ;
- Payment information:for billing arrangements payment information may be collected from you, such as your currency, bank account details, e-wallet details, PayPal account, Pay by Mobile etc.;
- Identity and verification information: due diligence documentation including passport, identity card, bank statement, driving licence, utility bill, photograph, occupation, source of funds and wealth data etc.; and
- Communications: communications you have with us by telephone, via email or on chat features, in games, competitions, promotions or surveys, when submitting queries, and when you report any user problems etc.. This will include information which you provide to us on a voluntary basis.
Personal data collected from your use of our websites:
We will automatically collect information from you each time you visit or otherwise use our websites. This includes:
- Technical and device information: connection details and information with regard to your device, software or hardware that may identify you such as unique identifiers, IP address, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, screen resolution, flash version, webpages browsed on Stride websites and geo-location data;
- Gaming and account transactions: transactions, wins, wagers, deposits, withdrawals, bonuses, balances, bets etc.. We also collect information from your patterns of transacting across our platforms and use this information, as required by applicable gambling/gaming legislation, in order that we may identify gambling problems or addictions and to ensure that we maintain a responsible gaming environment; and
- Social networks: registrations made through social network accounts (such as your Facebook account), will give us access to basic information from your social network account, such as name, date of birth, profile picture and friends list, as well as information that you make publicly available on such an
Personal data collected from other sources:
Occasionally, we may be provided with or request the provision of personal data by or from a third party or alternative source which is not the data subject. Examples include:
- Verification data: information in order to verify the identity of a data subject in order to prevent fraudulent or illegal activity;
- Service providers: personal data about a data subject from other sources including third party service providers of risk intelligence and other platform providers;
- Credit agencies: information about a data subject’s credit history from credit agencies (but never full credit card information) and other financial information; and
- Open-source: open source and publicly available sources such as the internet and social networks.
3. LEGAL REASONS FOR COLLECTING PERSONAL DATA
The Stride Group processes personal data for a number of legal reasons or grounds which may include:
- for the performance of our contract with you: for example, to set-up and register, manage and operate your account, to verify your identity and process payments;
- the exercise of rights or obligations conferred on us, or the performance of or compliance with duties imposed on us, by applicable laws and regulations (for example, where we must assist the relevant authorities with the prevention, detection and investigation of crime, and where we are obliged to do so by the terms of our regulatory licences;
- compliance with due process in connection with legal proceedings, the taking of legal advice or otherwise in connection with legal rights; and
- for the furtherance of our legitimate interests in delivering customer focused and personalised content to our players and generally improving the content and delivery of our products and services.
Where the processing of personal data about you is necessary for the furtherance of our legitimate interests, that processing is conditional upon those legitimate interests not being overridden by your interests or by your fundamental rights and freedoms. You are entitled to request information from us concerning the decisions that we may have made to process your personal data for the purposes of our legitimate interests.
4. CONSENT AND THE WITHDRAWAL OF CONSENT
There are cases where in order to process your personal data, we need your consent to do so. However, we are under legal and regulatory obligations to obtain certain personal data from you before we can provide our products and services to you. Accordingly, while you may not be obliged to provide us with your personal data, if you do not do so, we may be unable to provide you with products and services.
Where the legal basis for processing personal data about you is your consent (for example, to send you marketing materials), then you may at any time withdraw your consent by contacting the website support centre for the application(s) concerned, by changing the settings in your account or changing the settings of your cookies. Where you withdraw your consent for us to process personal data about you, we may not be able to provide you, or continue to provide you, with certain products and services.
Where you have not provided consent and/or have withdrawn your consent to certain processing activities (for example, marketing activities) we may need to continue to process your personal data for other legal reasons which may include: other aspects of performance in relation to the contract between us, for a legitimate interest, or in connection with legal or regulatory obligations to which we are subject.
5. USE OF INFORMATION COLLECTED
We use personal data for the following purposes:
- to register user accounts;
- to update user accounts and perform business and administrative activities that support the maintenance of those accounts;
- to provide users with access to the games and services available on our platforms;
- to identify and authenticate user access to certain features for example, restricted access products and services on the platforms;
- to communicate with our users and keep them informed of our latest services, updates and special offers;
- to determine your VIP status;
- to enhance user experience of our products and services and to continually improve those products and services;
- to provide a responsible gaming environment to our users including monitoring to detect patterns of behaviour (for example, play, deposits and other variables) that may be an indication of problem gambling;
- to collect monies, to allow you to place deposits and wagers, to enable withdrawal of funds;
- to send you notifications about operational requirements, technical service issues, security issues, account balance information and promotional information;
- to respond to queries, requests, complaints and provide customer support services;
- for marketing analysis and to market our service including to provide you with promotional update communications by email, post, telephone, direct messaging, direct mail and other digital channels (pop ups, push notification, banner advertising, etc.) about our products and services, promotional materials, as well as products, services, websites and applications which relate to products and services from companies within the Stride Group which we believe may interest you;
- to understand customer needs and preferences in order to provide bespoke offers to our customers;
- to process any requests for information;
- to investigate and resolve disputes concerning our services;
- to comply with the conditions of our regulatory licences and with other regulatory and/or legal requirements;
- to conduct credit searches;
- to improve user experience through data collected through analytics;
- to carry out customer due diligence;
- for monitoring user activity on the platforms in order to help us develop the platforms and the services offered on them;
- to detect and prevent fraudulent, otherwise illegal or anti-social activities;
- to investigate violations of our policies and user agreements;
- to prevent money laundering and to prevent the financing of terrorism; and
- where otherwise required to do so by law, regulation or other binding authority.
Subject to customer consent, we share personal data with carefully selected third parties engaged in the business of providing marketing and promotional services. We do this in order to improve customer experience of our products and services, to make additional and promotional products and services, to develop new and improved services, and to offer promotions and rewards.
Where you have provided your consent to further marketing activities you may receive advertisements and other promotional materials about the products and/or services of third parties which may be of interest to you. In order to ensure that we offer our users carefully selected additional products and services we use data analysis techniques, including profiling, in order to analyse your age, location, playing patterns and behaviour, preferences and interests. The conclusions that we make, having undertaken such customer analysis, enables us to ensure that you receive marketing, promotional and other additional material which is uniquely tailored to you.
7. DATA SHARING
The sharing of personal data about our customers between entities within the Stride Group is governed by a binding corporate agreement pursuant to which all members of the Stride Group have agreed to adhere to the standards of GDPR.
- organisations providing website and data hosting services, storage and hosting providers, cloud provision services, fulfilment services, communications distribution services, marketing lists and support services, feedback services, IT support services, marketing and promotional services, including events services, promotional and advertising etc.;
- credit reference agencies for the purpose of assessing credit scores where this is a condition of us entering into a contract with a customer, user verification and authentication services providers, and fraud prevention service providers and chargeback investigation providers;
- payment processing providers who provide us with secure payment processing services and related banking services;
- research, data analysists, technical and diagnostic services;
- services concerned with maintaining responsible gaming practices;
- accountants, auditors, lawyers, other experts and other professional service providers; and
- licensing authorities, governmental and regulatory bodies if required to do so by law or regulation in connection with the licences under which we conduct our gaming business.
We may also be required to disclose personal data in certain circumstances which may include:
- where we are required to do so by a court of law in connection with legal proceedings;
- where we are required to do so by regulatory and/or supervisory authority in connection with any aspect of the regulated environment in which we conduct our online gaming services (such as law enforcement agencies, government agencies, the controllers of public registers, other regulators and supervisory bodies);
- where we are required to so protect our legal rights and/or enforce our legal obligations for example, to our customers, employees and to members of the public;
- in the event of an insolvent situation; and
- in connection with a sale of or investment in one or more of the companies within the Stride Group, or a restructuring, refinancing, consolidation, dissolution or other corporate procedure concerning all or part of the Stride Group.
8. INTERNATIONAL DATA TRANSFERS
The Stride Group operates globally. The sharing of personal data about our customers between entities within the Stride Group is governed by a binding corporate agreement pursuant to which all members of the Stride Group, regardless of their geographic location, have agreed to adhere to the standards of GDPR. We need to transfer personal data within and between the Stride Group in order to provide and support the products and services that we provide to our customers.
It is the case that some countries outside of the European Economic Area (“EEA”) may not protect personal data to standards equivalent to those applicable under GDPR. Where we need to transfer personal data outside of the EEA, we will take all appropriate steps to ensure that personal data is transferred only where subject to appropriate safeguards which are designed to ensure the protection of personal data and the enforceability of personal data rights. We will, for example, seek to rely on a recognised legal adequacy mechanism, on a binding and enforceable instrument or to transfer only on the basis of standard data protection clauses.
9. INFORMATION TECHNOLOGY AND DATA SECURITY
All personal data held by the Stride Group is stored on secure servers. We use strict procedures and security features to maintain the security of our systems and the personal data and other information stored in them. We take cyber-security very seriously and implement multiple different layers of physical and technological controls to prevent unauthorised access and to ensure data security, integrity and privacy. Systems and controls include, but are not limited to:
- firewalls, network segmentation, anti-malware scanning, intrusion detection and prevention systems;
- penetration testing and vulnerability management and remediation;
- security events and incident management program through a 24/7 security operations centre;
- encryption for sensitive data in transit and at rest;
- strict access controls and authentication procedures;
- regular cyber-security audits;
- TLS encryption for payment transactions; and
- use of ISO27001:2013 accredited hosting and co-location facilities.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our applications you are responsible for keeping your password(s) confidential. We will never ask you to disclose your password to us and we would ask you not to share your password with anyone.
10. PUBLIC FORUMS
The websites contain places that are public such as chat rooms, message boards, news groups and/or other forums. Any information that you disclose in these areas becomes public information. You should therefore exercise caution when using these public areas and avoid posting any personal data on them. Any information that you communicate in these public places may be viewed and utilised by third parties, for example to send you messages, to send you advertising or for any other purposes. We are unable to control the activities and behaviours of third parties in public areas. Accordingly, if you disclose personal data in public spaces, you do so at your own risk. We recommend that you review the privacy policies of any relevant third parties before disclosing your personal data on their websites or platforms.
11. CHILD SAFETY
12. RETENTION OF PERSONAL DATA
We retain personal data for as long as necessary for the purpose(s) for which the personal data was collected. For example:
- for as long as you have an account with us, we need to retain your personal data in order to meet our contractual obligations to you;
- to comply with our licence conditions and any other regulatory and legal requirements;
- for a period after termination of a customer relationship with us in order to comply with ongoing legal and regulatory provisions (such as employment law and tax law); and
- where there are compelling legitimate grounds to do so.
We may retain aggregate information for longer periods in order to conduct market research and to help us to continue to develop and improve our services. You cannot be identified from aggregate information retained or used for these purposes.
Periodically we review the personal data that we hold on all of our customers in order to ensure that we are not retaining it for any longer than is necessary.
13. YOUR RIGHTS
GDPR provides data subjects with a number of rights. The Stride Group is significantly invested in protecting data subject rights and upholding the protections of GDPR. A data subject about whom we hold personal data may approach us at any time to request to review the personal data that we hold in relation to them, ask us to amend it, request that we erase it, ask us to cease using it, or request that it be transferred to another party. In summary, your rights in relation to your personal data include the following rights:
- to receive confirmation as to whether we are processing personal data about you;
- to access the personal data about you held by us;
- to be informed of the legal bases for the processing of your personal data by us;
- to withdraw your consent to any processing of your personal data based solely on your consent;
- to be informed of the recipients of any personal data that we have shared outside of the Stride Group;
- to be advised of any retention periods applicable to the storage, by us, of your personal data;
- to request the rectification of inaccurate personal data, to have incomplete personal data about you completed, or the erasure of your personal data if it is no longer required by us;
- to restrict our processing activities in relation to your personal data;
- to be advised of the source of personal data that we hold on you, where you are not the direct source of that personal data;
- to have your personal data transferred to another controller, where technically possible, by automated means;
- to object to the continued processing by us of your personal data;
- the right to object to the processing of personal data which is based on the legitimate interests of the Stride Group; and
- information on any profiling or automated decision making undertaken by us in relation to your personal data.
We will deal with your request within one month of receiving it, save that in certain circumstances we have the right to seek an extension to this period, and free of charge (unless your requests are for some reason repetitive, unfounded or otherwise excessive).
Where a data subject has reason to make a complaint in relation to the Stride Group’s processing of their personal data or the protection of their data protection rights, they may make a complaint, in writing, to the Office of the Data Protection Commissioner Office of the Data Protection Commissioner, St Martin’s House, Le Bordage, St. Peter Port, Guernsey, GY1 1BR
GDPR provides for a data subject who has reason to complain about the handling of their complaint by a data protection authority to appeal to court where specified grounds exist.
14. EXEMPTIONS TO DATA SUBJECT RIGHTS
There are circumstances where certain data rights may not be applicable. These circumstances may include cases where to apply a data subject right may conflict with other legal obligations. For example, your right to erasure of personal data may not be applicable where we are under an obligation to retain the personal data concerned in order to comply with applicable legislation or regulation, to comply with a legal or a licensing requirement or in connection with legal proceedings. Further, we may be able to demonstrate compelling legitimate grounds for the processing of your personal data which override your personal data rights.
15. COOKIES AND PIXELS
16. COOKIES POLICY
We use the following types of cookies:
- Strictly necessary cookies: these are cookies that are required for the operation of our websites and under our terms with you. They include, for example, cookies that enable you to log into secure areas of our websites, use a shopping cart or make use of e-billing services;
- Analytical/performance cookies: these are cookies that allow us to monitor traffic on our websites, to recognise and count the number of visitors and to see how visitors move around our websites when they are using them. These cookies help us to continually improve the way our websites work, for example, by ensuring that users are finding what they are looking for easily;
- Functionality cookies: these cookies are recognise you when you return to a website and enable us, subject to your choices and preferences, to personalise your content, greet you by name and remember your preferences (for example, your choice of language or region); and
Targeting/advertising cookies: these cookies record your visit to our websites, the pages you have visited and the links you have followed. We will use this information subject to your choices and preferences, to make our websites and the advertising displayed on then more relevant and personal to your interests. Subject to your consent, we may share this information with third parties for this same purpose. We may also work with advertising networks that gather information about the content on those of our websites that you visit and on information on other websites and services you visit. This may result in you seeing advertisements on/or through our websites or our advertisements when you visit other websites and services of third parties which we believe may be of interest to you. For more information about how to turn this feature off see below or visit youronlinechoices.com/uk/.
You may refuse to accept cookies by activating a setting on your browser which allows you to refuse the setting of cookies. The effect of disabling cookies depends on which cookies you disable but, in general, the websites may not operate properly if all cookies are switched off. If you only disable third party cookies, you will not be prevented from transacting on our platforms. However, If you disable all cookies, you will be unable to transact on our platforms.
You can learn more about cookies by visiting allaboutcookies.org which provides useful information on cookies and how to block cookies using different types of browser or mobile device. Please note, however, that by blocking or deleting cookies used on the platforms, you may not be able to take full advantage of the products and services that are on offer.
For Microsoft Internet Explorer:
- Choose the menu “tools” then “Internet Options”
- Click on the “privacy” tab
- Select the setting the appropriate setting
For Google Chrome:
- Choose Settings> Advanced
- Under “Privacy and security,” click “Content settings”.
- Click “Cookies”
- Choose Preferences > Privacy
- Click on “Remove all Website Data”
For Mozilla Firefox:
- Choose the menu “tools” then “Options”
- Click on the icon “privacy”
- Find the menu “cookie” and select the relevant options
For Opera 6.0 and further:
- Choose the menu Files”> “Preferences”
Identifies a customer on Our system
To display the username on some pages and make the experience more personal
Identifies customer VIP level
Used to validate the customer activity in Our system
Identifies the user’s country
Display customer’s currency on the table
Identifies user’s device so it can have a better user experience
Identifies from which affiliate campaign the user came from
Affiliate link ID
Identifies from which affiliate the user came from
Affiliate tracking ID
Tracks the affiliate ID during the first visit of the user
Affiliate history tracking
Keeps all affiliate life time data from user
Tracks dynamic information set on the affiliate campaign used by the user
Identifies the previous page from which a link to the currently requested page was followed
Identifies the player’s navigation across the website
Used to identify when the user navigates to the website from the bingo client
Promo code used by user
Used to link user side and server-side communication which allows our system to know how and what to display to customers.
We use pixel based tracking to track a visit or event on the platforms and to track advertisement.
18. HOW TO CONTACT US
If you would like to contact us with any queries or comments concerning data protection, our contact details are as follows:
Data Protection Officer
Daub Alderney Limited
St Peter Port
Telephone: 0845 565 2059