Privacy Notice - Horizons Casino : Horizons Casino

Introduction to Mayfair

This privacy notice describes how the Mayfair Group (we, us, our) processes your personal data when you receive our services. It provides land-based gambling services and the services that you receive will determine how your personal data is processed and which member of the group will be responsible for ensuring your personal data is processed lawfully and fairly. This privacy notice will describe how the different services are provided and what this will mean for your personal data. Of course, if you have any questions, you can reach us at: [email protected].

The Mayfair Group consists of the following entities, each of which may be a controller of your personal data:

Horizons Leisure Limited which operates the Horizons casino (Horizons)
Clermont Leisure (UK) Limited which operates the Clermont casino (Clermont)

Horizons and Clermont each operate and run casinos in the UK. If you enter these casinos or register to become a member of one of these casinos, the relevant entity will be a controller of your personal data for the purpose of providing you with these services. In addition, each entity will owe obligations to certain gambling regulators, such as the Gambling Commission, and therefore when it becomes a controller it will also process your personal data to ensure that it complies with gambling regulation – such as ensuring you are over 18 years old and to make sure that you are gambling responsibly.

‘Controller’ is a legal term and essentially means the entity that will be responsible for determining how your personal data is used and that there are lawful grounds for such uses. Personal data means any information relating to you through which you may be identified or identifiable. Mayfair Group is committed to protecting your personal data and ensuring that your personal data is processed fairly, lawfully, and transparently. The above is an overview of how Mayfair Group uses your personal data, but please read this privacy notice in full to understand more about our processing of your personal data and your rights.

Mayfair Casino Limited

Mayfair Casino Limited is the holding company for each member of the Mayfair Group. If your personal data is collected by any member of the Mayfair Group, it will be held and stored by Mayfair Casino Limited. Mayfair Casino Limited will also make decisions regarding the operation of the Mayfair Group as well as the appointment of processors. Therefore, when any Mayfair Group collects your personal data, Mayfair Casino Limited will also be a controller of your personal data. A contact is in place between the Mayfair Group and Mayfair Casino Limited to ensure that personal data is processed in accordance with this privacy notice.

How we collect your personal data

In order to open an account with any member of the Mayfair Group you will need to submit certain personal data such as your name, age, address, occupation and email. This is required in order for us to provide you with our gaming services; Horizons and Clermont each use CCTV in their casinos which means that footage of you will be captured when you enter one of these casinos.

We also collect information about the transactions you make, including your gambling activity. We may collect personal data through surveys which we, or companies engaged by us for such purpose, undertake. In addition, we collect information about your use of our casinos and services. We will also collect other information necessary for us to process your personal data for the purposes set out in this privacy notice.

We will also process any personal data you provide in communications you make with any member of the Mayfair Group.

We may also collect personal data from third party service providers, such as Experian and fraud prevention companies.

How will we use your personal data?

In accordance with data protection laws, we will only process your personal data when we have a lawful basis for doing so. In respect of your personal data. We process your personal data if: (i) it is necessary to provide services to you under the performance of the contract we have with you; (ii) we are required to do so in accordance with legal or regulatory obligations; (iii) you have given your consent; and, (iv) it is in our legitimate interests to process your personal data, provided that none of these prejudice your own rights, freedoms and interests.

With the exception of limited circumstances, we do not process special categories of personal data about you (such as personal data relating to your health, ethnicity, religion, political persuasion, trade union membership or sexuality) or personal data relating to criminal offences or convictions. For the limited circumstances in which we process special categories of personal data, we have set out the additional lawful basis required in italics below.

The following is a list of the purposes for which each member of the Mayfair Group processes your personal data, and the lawful basis on which it carries out such processing:

Purpose	Lawful Basis
Mayfair Group
To set-up, administer and manage your account	Necessary for the performance of a contract
To provide you with our services (including to allow you to play our games)	Necessary for the performance of a contract
To receive and respond to your communications and requests	Necessary for the performance of a contract if the communication relates specifically to our services, otherwise consent
To notify you with important updates to our websites, casinos, and services	Necessary for the performance of a contract
To ensure that we are able to fulfil our regulatory obligations regarding your use of our services, including by verifying the accuracy of any information you provide us (which may involve us disclosing your personal data to third parties or supplementing your personal data with information received from third parties (such as credit reference agencies))	Necessary to comply with a legal or regulatory obligation
To ensure that we are able to fulfil our regulatory obligations of understanding your affordability to gamble, your source of funds, and your source of wealth (which may involve us disclosing your personal data to third parties or supplementing your personal data with information received from third parties (such as credit reference agencies))	Necessary to comply with a legal or regulatory obligation
To comply with our obligations under applicable laws (including gambling legislation, and regulatory and licensing requirements related to our gambling licences)	Necessary to comply with a legal or regulatory obligation
To identify and disclose any suspected unlawful, fraudulent, or other improper activity connected with our casinos and services (including money laundering)	Necessary to comply with a legal or regulatory obligation Substantial Public Interest: Preventing or detecting unlawful acts / protecting the public against dishonesty / regulatory requirements relating to unlawful acts and dishonest / preventing fraud/suspicion of terrorist financing or money laundering
To monitor gambling patterns and to identify possible responsible gambling concerns.	Necessary to comply with a legal or regulatory obligation. Substantial Public Interest: Safeguarding of individuals at risk / safeguarding of economic well-being of certain individuals.
To prevent you from using our casinos and services if you have requested that we do so.	Necessary to comply with a legal or regulatory obligation Substantial Public Interest: Safeguarding of individuals at risk/safeguarding of economic well-being of certain individuals
To comply with any deposit, spend or loss limits that you have set, or which have been applied to you.	Consent
To support any other purpose necessary for the performance of our contractual obligations or specifically stated at the time at which you provided your personal data.	Necessary for the performance of a contract
To carry out market research campaigns	Legitimate interests of better understanding the products and services that our customers most enjoy.
To prepare statistics relating to the use of our casinos and services by you and other customers	Legitimate interests of understanding the use of, and therefore improving, our products and services
To send you offers and promotions relating to our services that you may be interested in if you have opted-in and not opted out.	Legitimate interests in order to recommend similar and identical goods and services to those that have signed up to our services.
To record telephone calls to and from, and live chats with, our customer services representatives for training	Legitimate interests of improving our customer services
To record telephone calls to and from, and live chats with, our customer services for security and regulatory purposes	Necessary for a legal or regulatory obligation
To use your name, image, username or location in publicity and marketing, but only when you have provided your express and informed	Consent
Sharing: To share your personal data with other members of the Mayfair Group who assist in providing the services to you	Legitimate interests to allow us to provide services
Sharing: To share your personal data with social media services to provide you and others like you with ads on social media sites, unless you have requested not to receive such ads via your social media account.	Legitimate interest of better advertising our products and services
Sharing: To share your personal data with third parties for identity verification.	Necessary to comply with a legal or regulatory obligation
Sharing: To share your personal data with third parties for fraud and AML detection purposes.	Necessary to comply with a legal or regulatory obligation. Substantial Public Interest: Preventing or detecting unlawful acts / protecting the public against dishonesty / regulatory requirements relating to unlawful acts and dishonest / preventing fraud / suspicion of terrorist financing or money laundering.
Sharing: To share your personal data with law enforcement agencies for the prevention and detection of crime.	Legitimate interests of helping to protect our service and our community. Substantial Public Interest: Preventing or detecting unlawful acts / protecting the public against dishonesty / regulatory requirements relating to unlawful acts and dishonest / preventing fraud / suspicion of terrorist financing or money laundering.
Sharing: To share your personal data with national self-exclusion databases if you have self-excluded, such as SENSE and GamStop	Necessary to comply with a legal or regulatory obligation. Substantial Public Interest: Safeguarding of individuals at risk / safeguarding of economic well-being of certain individuals.
Clermont and Horizons
To capture CCTV footage (including audio) to ensure the security of our casinos, the security of those attending our casinos, to detect and prevent crime and to detect and prevent prohibited activities at our casinos (including cheating and harassing staff or other customers)	Legitimate interests of ensuring the security and enjoyment of our casinos
Use of facial recognition to identify individuals who may be dealing with problem gambling or to identify those that are suspected or known to have committed crimes or fraudulent activity.	Necessary to comply with a legal or regulatory obligation. Substantial Public Interest: Safeguarding of individuals at risk / safeguarding of economic well-being of certain individuals. Substantial Public Interest: Preventing or detecting unlawful acts / protecting the public against dishonesty / regulatory requirements relating to unlawful acts and dishonest / preventing fraud / suspicion of terrorist financing or money laundering.
To process payments made by card.	Necessary for the performance of a contract
Recording transactional data on table iPad and at Cash Desk manually	Necessary to comply with a legal or regulatory obligation.
Sharing: To share your personal data with third party service providers that assess whether you are able to lose the amounts set by us as the maximum amounts for you	Necessary to comply with a legal or regulatory obligation.
Sharing: To share your personal data with intelligence networks to prevent access to casinos to those that have committed criminal acts.	Legitimate interests of helping to protect our service and our community. Substantial Public Interest: Preventing or detecting unlawful acts / protecting the public against dishonesty / regulatory requirements relating to unlawful acts and dishonest / preventing fraud / suspicion of terrorist financing or money laundering.

In addition to the purposes set out above, we may also process your personal data for other purposes that we deem compatible with those listed above. We will update this privacy notice accordingly when we do this.

Disclosing your personal data

In addition to the purposes involving the sharing of your personal data listed above, we will also disclose your personal data to processors we engage. We will have a contract in place with each such processor to ensure your personal data is kept secure.

We may also disclose your personal data in the following circumstances:

when required by applicable law or regulation (disclosure to a governmental, regulatory or enforcement authority);
in order to defend ourselves legally and/or in relation to legal proceedings; and
whilst negotiating a takeover, purchase or merger, and pursuant to the same.

Transferring your personal data outside of the EEA

We do not transfer your personal data outside the UK or the European Economic Area (EEA), except for when investigating source of wealth and source of funds. The recipient will vary depending on the nationality of the data subject in question but will put in place adequate safeguards to ensure your personal data is protected in line with the same data protection standards that are in place in the UK and EEA – these measures may include entering into standard contractual clauses or using US companies that are certified under Privacy Shield.

Security

We will take appropriate security, technical and organisational measures to ensure that your personal data is kept secure and to prevent the theft, loss or unauthorised access to your personal data. It is important to understand however that security can never be guaranteed, and you will not hold us liable save where your security is compromised due to our negligence.

Marketing

We may engage third party service providers and other members of the Mayfair Group to provide you with certain direct marketing services. We take steps to ensure that arrangements with these parties protect your privacy by obtaining adequate assurances from these parties that they will comply with our instructions when they are processing your personal data.

If you have signed up to services offered by the Mayfair Group, we may send you direct marketing in relation to other services offered by the Mayfair Group provided that such services are identical to or similar to those that you have signed up for.

At any time, you can choose to opt-in to receive direct marketing communications from us by contacting us directly.

If you wish to unsubscribe from direct marketing for which you have signed up to you can do this by clicking ‘unsubscribe’ in the link included in any electronic direct marketing communication. Please be aware that when you unsubscribe from direct marketing it may take up to 28 days for this to take effect.

Affordability

We are committed to making sure our customers understand the risks related to gambling and have the tools to help keep them safe. As part of that commitment, we may undertake checks to ensure that you are comfortable with the amount of time and money you may be spending with us, and also for us to understand your level of affordability.

To help us understand your affordability, we may use credit reference agencies to perform an assessment of your data, which will return as applicable information including your public derogatory data, CCJs, bankruptcies, insolvencies, credit searches by debt collection agents, which will be used to assess your affordability.

However, you may opt out of us using this service by emailing us at: [email protected]

Cookies

In this privacy notice, we use the expression ‘cookie’ to refer to cookies and similar technologies we use to store information (such as web beacons). A cookie is a simple text file that is stored on your computer or mobile (or other) device by a website’s server, and only that server will be able to retrieve or read the contents of that cookie. Each cookie is unique to your web browser. It will contain some anonymous information, such as a unique identifier and the website name and some digits and numbers.

Almost all websites and applications you visit, including our website, will use cookies in order to improve your user experience by enabling that website and/or application to ‘remember’ you, either for the duration of your visit (using a ‘session cookie’) or for repeat visits (using a ‘persistent cookie’).

Cookies are used to improve your use of a website or application, for example through letting you navigate between pages efficiently and storing your preferences. Cookies make the interaction between you and the website faster and easier. If a website or application doesn’t use cookies, it will think you are a new visitor every time you move to a new page on the website. Cookies can also be used to enable targeted advertising and analysing your browsing of a website.

You can learn more about our use of cookies via our Cookie Note here.

You can learn more about cookies generally and how to disable them on your browser here.

You can learn more about what advertising cookies exist on your device and you can disable them directly by clicking here.

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 your last contact with us. We may delete your personal data sooner, if it is no longer necessary for us to process it.

If you self-exclude from any of our services, we will retain this information for a minimum of seven years.

Updating your personal data

You can update your personal data at any time by coming into or contacting one of our casinos. We request that when your personal data changes you update your account as soon as possible.

Your rights

You have the following rights in relation to your personal data:

a right to access your personal data held by us (also known as a subject access request);
a right to receive certain personal data in machine-readable format;
a right to have inaccurate or out-of-date personal data rectified;
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; and
a right to have certain personal data erased where it is no longer necessary for us to process it, if you have withdrawn your consent pursuant to the paragraph above, where you have objected pursuant to the paragraph below, where your personal data has been unlawfully processed, or where erasing your personal data is required in accordance with a legal obligation;
a right to object to the processing if the lawful basis is that it is in our legitimate interests to process your personal data, but please note that we may still process your personal data if there are other relevant lawful bases or if we have compelling grounds to continue processing your personal data in our interests which are not overridden by your rights, interests or freedoms;
a right to request an explanation of the logic involved if we make decisions about you solely through automated means;
a right to object to direct marketing, which can be done by opting out of direct marketing either by speaking to a manager at the casino, 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.

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.

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.

When 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.

Supervisory authorities

If you have any complaints, you have the right to contact your own national data protection supervisory authority (for example, in the UK this will be the Information Commissioner’s Office) however we do ask that you contact us in the first instance to allow us the opportunity to address your concerns.

The national supervisory authorities that govern us are as follows:

Information Commissioner’s Office in respect of Horizons and Clermont.
Information Commissioner’s Office in respect of Mayfair Casino Limited.

Contact us.

If you have any questions regarding our use of your personal data, or you would like to exercise ay of your rights, please contact our Data Protection Officer at [email protected].