Privacy & Cookie Policy 
 
Privacy & Cookie Policy for www.premierpunt.com and related mobile applications operated and managed by Incentive Group Limited ("Digital Channels")
Our Privacy & Cookie Policy below sets out how we process your personal data and we recommend that you read it in full. However, we also wanted to provide you with a brief and general overview of how we will process your personal data.
 
In general, we will only use your personal data in order to provide you with our services. For example, if you want to bet with us then we'll collect your name, username, contact details, date of birth and address in order to set you up with an account. We’ll process data on any bets you place so that we can identify if you have won and, of course, pay any winnings to you.
 
In addition, we will also process your personal data is to comply with our legal and regulatory obligations. You may already be aware, but in order to provide you with gambling services we are required to have a licence and in order to comply with our licence we may have to collect additional information about you – for example, if you try to set up an account we need to verify your identity and age to make sure that you are who you say you are and that, of course, you are old enough to gamble.
 
Our licence also requires that we make sure you gamble responsibly. This means that we will monitor your gambling activities to check that you are gambling within your means. If we have any concerns about your gambling then we are required to contact you to discuss your activity. Responsible gambling is very important to us.
 
Overall, we aim to only process your personal data where it is necessary and we will always keep your personal data secure. Your safe and enjoyable use of our services is our primary concerns.
 
If you have any questions about how we use your personal data please contact us at support@premierpunt.com.
 
1. Introduction
 
1.1 This Privacy & Cookie Policy sets out the way in which Incentive Group Limited ("we" or "us") process your personal data through your use of our website located at www.premierpunt.com and our app ("Digital Channels"). The manner in which we process your personal data and steps we take to protect your personal data and how you can review and correct your personal data are covered here. We ask that you read this Privacy & Cookie Policy carefully as it contains important information about what to expect as to how we collect and use personal data about you.
 
1.2 By visiting our Digital Channels, contacting us and/or registering an account with us we will process your personal data as a controller. "Controller" is a legal term meaning that we will be responsible for determining the purposes for which we process your personal data, and includes our staff acting on our behalf. We are registered with the Incentive group LTD- 15 Hewlett Way, South Queensferry, Scotland, EH30 9AA
 
1.3 This Privacy & Cookie Policy also contains information about cookies and similar technologies that we use on our Digital Channels, further information for which can be found in paragraphs 3, 4 and 13.
 
1.4 We may occasionally update this Privacy & Cookie Policy. When we do, we will revise the “last updated” date at the bottom of the Privacy & Cookie Policy. Please ensure that you frequently check this Privacy & Cookie Policy for any updates. Where we make material changes to this Privacy & Cookie Policy we will notify you.
 
2. The information we collect
 
2.1 In order to operate the Digital Channels, we collect your personal data, which means any information from which you can be personally identified, including your name, email address, home address, telephone number, debit/credit card data, and date of birth.
 
2.2 We collect personal data which you provide to us, including when you register for an account and information you provide in communications with us. We also collect information about your betting transactions, including details of payment cards used and betting history. We may also collect personal data through surveys which we, or companies engaged by us for such purpose, undertake.
 
2.3 In addition, we aim to offer a highly personalised betting service and so we collect information about your use of the Digital Channels and our services in order to tailor our Digital Channels to your interests and preferences.
 
2.4 We will also collect other information necessary for us to process your personal data for the purposes set out in this Privacy & Cookie Policy.
 
2.5 As a provider of gambling services, we aim to ensure that you always gamble responsibly. As such, we will collect information about your gambling patterns and any potential concerns we have about you in relation to responsible gambling. To help ensure that our customers gamble responsibly, it’s important we understand why they self-exclude (or when they should be contacted about the possibility of self-excluding). We therefore only use this type of data to ensure that you are gambling responsibly, to contact you if we are concerned that you are not gambling responsibly, to enforce any self-exclusion request, and to help us to better identify any responsible gambling concerns in the future for our customers.
 
2.6 We may also collect or supplement your personal data with information provided from third parties in order to verify your identity and to carry out necessary checks in accordance with our licensing and regulatory obligations.
 
3. Information we collect through Cookies and similar technologies
 
3.1 We collect information through "Cookies" and other similar technologies (e.g. pixel tags or links). This helps us to remember you when you visit the Digital Channels, to allow you to navigate our Digital Channels enjoyably and to improve your experience.
 
3.2 We use information collected through "Cookies" and other similar technologies to detect any fraudulent behavior, improper transactions and/or abuse of our Digital Channels and Services, and to help verify your identity by registering and remembering your device information.
 
3.3 "Cookies" may also collect information to monitor use of our Digital Channels generally so we can understand how our customers use our Digital Channels; to track from where you have arrived at our Digital Channels and where you travel after our Digital Channels; and to populate our Digital Channels with content and advertisements which may be of interest to you.
 
3.4 To find out more about "Cookies" and similar technologies please see paragraph 13 of this Privacy & Cookie Policy. More information about the purposes of the "Cookies" we use can be found in paragraph 4.
 
4. How we use your personal data
 
4.1 In accordance with data protection laws, we will only process your personal data where we have a lawful basis for doing so. In respect of your personal data, these bases are: (i) where it is necessary to provide services to you under the performance of the contract we have with you; (ii) where we are required to do so in accordance with legal or regulatory obligations; (iii) where you have given your consent; and (iv) where it is in our (or a third party's) legitimate interests to process your personal data, provided that none of these prejudice your own interests or fundamental rights or freedoms.
 
4.2 The following are a list of the purposes for which we (including any of our processors) process your personal data, and the lawful basis on which we carry out such processing:
 
 
5. Disclosure of your Personal Information
 
5.1 We may share your personal data with companies who will process your personal data on our behalf, including (but not limited to) payment processors, customer relationship managers, fraud detection service providers, customer services representatives, chat moderators, credit reference agencies, server hosting providers and marketing service providers. Such companies are known as "processors" and we will always ensure that our processors only use your personal data in accordance with this Privacy & Cookie Policy and only for the purposes set out above. We will also ensure that our processors are contractually obligated to keep your personal data secure.
 
5.2 We may be required to disclose your personal data to any of the following recipients (some of whom may act as controllers):
 
5.2.1 any company within our group which assists us in providing our services or which otherwise has a need to know such information;
 
5.2.2 any advisers, including accountants, lawyers and those auditing any of our business processes or who have the need to access such information for the purpose of advising us;
5.2.3 any law enforcement body which may have any reasonable requirement to access your personal data;
 
5.2.4 any regulatory body or authorised entity (e.g. a sporting body or law enforcement agency) which may have any reasonable requirement to access your personal data; and
 
5.2.5 any potential purchaser or investor of our business (including in the event of insolvency).
 
6. Marketing
 
6.1 As part of the account registration process, you will have the opportunity to opt-in to receive information from us about our offers and promotions. You will have the ability to change your selection at any time via your account as well as unsubscribing via the communication itself.
Please note that where you select to not receive marketing we will maintain a record of this to ensure that marketing to you is suppressed.
 
6.2 You can select in our app settings whether or not you wish to receive push notifications about offers and promotions from us sent via the app.
 
7. Transfer of your personal data outside of the EEA
 
Your personal data will be transferred outside of the European Economic Area ("EEA"), including to the US, India and Israel. Where we transfer your personal data outside of the EEA, we will put in place adequate measures to ensure that your personal data is kept secure (and such adequate measures shall include: (i) transferring to a jurisdiction which the European Commission recognises as providing adequate protection for the rights and freedoms of data subjects in connection with the processing of their personal data (which includes Israel); (ii) transfers pursuant to standard contractual clauses in accordance with European Commission decisions on transferring personal data; and (iii) transfers pursuant to the EU-US Privacy Shield Framework).
 
8. Updating your Personal Information
 
You may update or delete your personal data at any time via the Digital Channels or by contacting our customer services team. We require you to update your details as soon as possible in accordance with Clause 6.4 of our T&Cs.
 
9. Your rights
 
9.1 Data protection laws grant you the following rights in relation to your personal data:
 
9.1.1 a right to access your personal data as held by us (also known as a subject access request);
 
9.1.2 a right to receive certain personal data in machine-readable format;
 
9.1.3 a right to object to processing where the lawful basis is that it is in our legitimate interests,
but please note that we may still process your personal data where there are other relevant lawful bases or where we have compelling grounds to continue processing your personal data in our interests which are not overridden by your interests or fundamental rights or freedoms;
 
9.1.4 a right to have inaccurate personal data rectified;
 
9.1.5 a right to have certain personal data erased where it is no longer necessary for us to process it, where you have withdrawn your consent pursuant to paragraph 9.1.8, where you have objected pursuant to paragraph 9.1.3, where your personal data has been unlawfully processed, or where erasing your personal data is required in accordance with a legal obligation;
 
9.1.6 a right to request an explanation of the logic involved where we make decisions about you solely through automated means;
 
9.1.7 a right to complain to your national data protection supervisory authority;
 
9.1.8 where we have specifically requested your consent to process your personal data and have no other lawful conditions to rely on, you have the right to withdraw this consent where the processing is ongoing; and
 
9.1.9 a right to object to direct marketing, which can be done by opting-out of direct marketing either through your account or by opting out via the communication itself. You also have a right to object to any profiling to the extent that it relates to direct marketing only.
 
9.2 If you are unsure about your rights or are concerned about how your personal data may be processed, you should contact your national data protection supervisory authority.
 
9.3 If you would like to exercise any of your rights then you can do so by contacting us as described below. Please be aware that while we will try to accommodate any request you make in respect of your rights, they are not absolute rights. This means that we may have to refuse your request or may only be able to comply with it in part.
 
9.4 Where you make a request in respect of your rights we will require proof of identification. We may also ask that you clarify your request. We will aim to respond to any request within one month of verifying your identity. If we receive repeated requests, or have reason to believe requests are being made unreasonably, we reserve the right not to respond.
 
10. Retention of your personal data
 
We will retain your personal data for the period necessary for us to provide you with our services and to comply with our legal and regulatory responsibilities. Accordingly, your personal data will be retained for a minimum of five years following the closure of your Account (if applicable) or the last contact with us emanating from you. Where it is no longer necessary for us to process your personal data, we will delete it sooner. If you request that you should not be able to access our Digital Channels and services (i.e. self-exclude), we will retain this information for a minimum of seven years.
 
11. Security
 
11.1 We are committed to ensuring that your personal data Information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the personal data that we collect.
11.2 We only appoint trusted and reputable processors and all staff are bound by confidentiality and provided training around data protection to ensure that your personal data remains secure when processed by others on our behalf.
 
12. Third party sites
 
Where we provide links to third party websites we will no longer be responsible for controlling your personal data and we recommend that you read the privacy policies of such third party websites before utilising their services.
 
13. Cookies
 
13.1 We use "cookies" and similar technologies in order to provide you with a high-quality and personalised experience and in line with the purposes set out in paragraph 4.
 
13.2 A cookie is a small text file that is stored on your computer, laptop or mobile device when you visit our Digital Channels. Cookies may be used for many different purposes such as remembering your preferences, following your use of the Digital Channels and improving your user experience. Cookies collect information about your use of our Digital Channels and may collect information about your IP address and other unique device identifiers. We use three different types of cookies:
 
13.2.1 Essential Cookies - These cookies are necessary for the Digital Channels to function properly or to provide a service which you request. These cookies are usually only set in response to your actions, such as in the case of auto form filling or logging in. Your browser can be set to block these cookies but the Digital Channels will not perform properly if you decide to do so.
 
13.2.2 Functionality Cookies - These cookies help to provide you with a more personalised user experience and are used by us and select third parties whose services feature on our pages. Blocking these cookies will disable these services and may affect your Digital Channels experience.
 
13.2.3 Performance Cookies - These cookies collect information about how you use our Digital Channels and assist us in improving the performance of our Digital Channels. Blocking these cookies means that we cannot work effectively to improve the usability of our Digital Channels.
 
13.3 Cookies may be stored either for the duration of your visit to the Digital Channels or for repeat visits:
 
13.3.1 Session Cookies - These cookies allows us to link your actions during a browser session. A browser session starts when you open the browser window and finishes when you close it. Session cookies are created temporarily and are deleted once the browser window is closed.
 
13.3.2 Persistent Cookies - These cookies remains on your device for a set period of time specified in the cookie and activated each time you visit the Digital Channels that created that particular cookie.
 
13.4 You may modify your browser so that it will not accept cookies.
 
14. Contacting us
 
If you have any questions regarding our Privacy & Cookie Policy, our use of you personal data or to exercise any of your rights as set out under paragraph 9 please contact our data protection representative at support@premierpunt.com