At First Class Slots (“1CS”, “we”, “us”), we process personal data about our customers and visitors on our websites (“you”). We make efforts to handle your personal data with care, keep it secure and comply with data protection laws.

First Class Slots is engaged in performance marketing and lead generation online, with headquarters in the UK.

How this Policy Works

The purpose of this Policy is to explain when, why and how we process information which may relate to you (“personal data”). It also provides important information on your statutory rights. This Policy is not intended to override the terms of any contract you have with us, nor rights you might have under data protection laws.

Who is responsible for looking after your personal data?

First Class Slots is principally responsible for looking after your personal data (your Data Controller). Data Controller means the company that determines the means and purposes of processing of personal data.

You should be aware that although we are principally responsible for looking after your personal data, information may be held in databases which can be accessed by other companies. When accessing your personal data, all companies will comply with the standards set out in this Policy.

What personal data do we process?

We may process the following personal data about you:

  • Name
  • Date of birth
  • Email address
  • IP address
  • Location data
  • Website usage
  • Personal preferences and opinions

What do we use your personal data for and when do we process your personal data?

First Class Slots will collect information directly from you when you use our services or visit our websites.

We use your personal data to:

  • send out promotional emails relating to products and services. See also Section 6 below on Direct marketing.
  • analyse information in our systems and databases to improve the way we run our business and websites according to user preferences, to provide a better service and user experience.
  • improve and target advertisements that you receive from us.
  • register you for a chat forum or community, if we make available, in which you can provide comments.
  • meet or exercise any of our legal obligations or rights.

We will only process your personal data for the purposes set out in this Section 3 and where we are satisfied that:

  • you have provided your consent to us using the data in that way, or
  • our use of your personal data is necessary to support ‘legitimate interests’ that we have as a business (for example, to improve our products, or to carry out analytics across our datasets), in a way that is proportionate and respects your privacy.

Who do we share your personal data with?

  • Service providers or data processors that handle your personal data on our instructions, for example cloud services.
  • In the event we sell, buy or re-organise any business or assets, or if our assets are acquired by a third party, including prospective sellers or buyers.
  • If we are under a duty to disclose to comply with a legal obligation or protect our interests or security.
  • Regulators and government authorities in connection with our compliance procedures and obligations.

We work with many third parties, to help manage our business and deliver services. These third parties may from time to time need to have access to your personal data:

Non-personal information

Non-personal Information is non-identifiable information cannot be used to identify or contact you when considered alone. This stops us from knowing the identity of the user from which the non-personal information was collected.

We use non-personal information for reasons including advertising, service improvements, detecting and preventing fraudulent behaviour, statistical analysis and web analytics.

Types of Non-personal Information we collect about you

Technical information about the software and hardware you use to visit our site in order to provide you with a better experience when you visit. This can include:

  • Device manufacturer & model
  • Type of browser
  • Operating system
  • Language preferences

Analytics information that we collect about your use of our services including pages viewed, time spent on site, clicks and other related activity. This helps us to troubleshoot common errors, review the user experience and provide better insights for our operator partners.

We also use third-party analytics software, such as Google Analytics, to collect anonymous user data on the website. Our privacy policy does not apply to these third-party services and you should always refer to their own policies directly.

Anonymous information is collected by our services in a way that is not personally identifiable. Our use and disclosure of aggregated or de-identified information is not subject to any restrictions under this Privacy Policy, and we may disclose it to others without limitation and for any purpose, such as for advertising or marketing purposes.

Please note that if we combine personal information with non-personal information or anonymous information, the combined information will be treated as personal information for as long as it remains combined.

Direct Marketing

We will use your personal data to send you direct marketing communications regarding products and services that we and our partners offer regarding for example online casino, sports betting and financial services. This may be in the form of email or targeted online advertisements.

In some cases our processing of your personal data for marketing purposes will be based on our legitimate interests (see Section 3 above). When required by law it will be based on your consent.

You always have a right to say no to further direct marketing, at any time. You can use the opt-out link that you find in all direct marketing communications, or by contacting us (see Section 10).

We take steps to limit direct marketing to a reasonable and proportionate level, and to send you communications that we believe may be of interest or relevance to you, based on the information we have about you.

How long do we keep your personal data?

We will retain your personal data for as long as reasonably necessary for the purposes listed in Section 3 of this Policy.

In some circumstances, we keep your personal data during a certain period to meet for example legal, tax or accounting requirements.

We maintain a data retention policy for personal data in our care. Where your personal data is no longer required we will ensure it is either securely deleted or made anonymous.

What are your rights?

An an EU citizen, you have a number of rights under the General Data Protection Regulation, which came into place on 25th May 2018. Some of these apply at any time, but some may only apply in certain circumstances.

Access

You have a right to request a copy of the personal information that we hold about you.

Rectification

You can ask us to rectify inaccurate personal data. We may seek to verify the accuracy of the data before rectifying it.

Erasure

You can ask us to erase your personal data, but only where:

  • it is no longer needed for the purposes for which it was collected; or
  • you have withdrawn your consent (where processing was based on consent); or
  • following a successful right to object (see ‘Objection’ below); or
  • it has been processed unlawfully; or
  • to comply with a legal obligation.

We are not required to comply with your request to erase your personal data if the processing of your personal data is necessary:

  • for compliance with a legal obligation; or
  • for the establishment, exercise or defence of legal claims;

There are certain other circumstances in which we are not required to comply with your erasure request, although these two are the most likely circumstances in which we would deny that request.

Restriction

You can ask us to restrict (i.e. keep but not use) your personal data, but only where:

  • its accuracy is contested to allow us to verify its accuracy; or
  • the processing is unlawful, but you do not want it erased; or
  • it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or
  • you have exercised the right to object, and verification of overriding grounds is pending.

We can continue to use your personal data following a request for restriction, where:

  • we have your consent; or
  • to establish, exercise or defend legal claims; or
  • to protect the rights of another natural or legal person.

Objection

You can object to any processing of your personal data which has our ‘legitimate interests’ as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests.

We have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.

International Transfers

You can ask to obtain a copy of, or reference to, the safeguards under which your personal data is transferred outside of the European Economic Area.

We may redact data transfer agreements or related documents (i.e. obscure certain information contained within these documents) for reasons of commercial sensitivity.

Supervisory Authority

You have a right to lodge a complaint with the responsible local supervisory authority about our processing of your personal data.

We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.

Contact us

Please feel free to contact us with queries, requests, or comments you may have about our Privacy Policy.

Last update: Feb 2019