Customer Privacy Notice (EUROPEAN UNION and EEA)
- Who are we
- The information we collect about you
- What We Use your Personal Data for
- Who we share your data with
- Meeting our Responsible Gambling Obligations
- How long we retain your personal data
- Location that we may transfer your personal data to
- Security
- Cookies
- Marketing Communications and your choices
- Your rights
- How to contact us / Our Data Protection Officer
- Changes to this Policy
ElectraWorks Europe Limited is a member of the Entain Group of companies and this Notice explains what your personal data will be used for.
| Territory | Name of the controller | Details |
| EU territories including Austria, Finland and Malta | Martingale Europe Limited | Unit 6, St Business Centre, 120 The Strand, Gzira, Malta |
Where we use the term “we” or “us”, this includes the entity and Brands (https://entaingroup.com/about/business-overview/our-brands/) and other companies within the Entain Group.
We are committed to protecting your personal data when you use our services through our website and mobile application and take the security of your information very seriously. We have strict security measures in place to protect your personal data which includes robust security procedures which are regularly tested and reviewed. If you have any concerns about the way in which we process or protect your personal data or would like to contact us about any aspect of this policy, please get in touch through the contact details at the bottom of this statement.
This privacy notice should be read in conjunction with our cookies notice, any notices or terms located within the stores and our site terms of use / terms and conditions.
The information we collect about you
We will collect personal data about you from the following sources:
- When you register for an account with us
- When you visit our website or our social media sites
- Through surveys you complete
- When you communicate with us (by email, mail, phone, in store or through chat or social media)
- When we undertake analysis of your interaction with us
- From our other group companies for internal reasons, primarily for business and operational purposes
- From public sources of information such as public records or social media postings
- From cookies and tracking devices on your devices where you have permitted their use.
- From third parties' databases to comply with our legal and regulatory obligations;
- From online vendors and service providers such as financial and shared liquidity services, and from customer lists lawfully acquired from third-party vendors.
What We Use your Personal Data for
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What we use your Personal Data for |
Typical Personal Data |
Further information |
Legal basis |
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Provision of products or services |
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To meet our obligations arising from any agreements entered into between you and us and provide you with the information, products and services that you request from us, including information about changes to our website, services or our terms, conditions and policies. |
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Customer Service matters |
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To provide you with customer services, answer your questions or address your complaints or concerns. |
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Meeting our legal and regulatory obligations |
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To discharge our legal and regulatory obligations and duties which include (but are not limited to) Gambling Act and Responsible Gambling obligations, Anti-money Laundering, Anti-fraud & Anti-terrorism laws. This may include electronic methods of identifying you, such as through the use of cookies and images on online play. |
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Identity Checks, Age Verification and Responsible Gambling |
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To meet our Responsible Gambling obligations (such as recording self-excluders and where we believe a customer has a gambling problem). |
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Undertake Surveys competitions and promotions |
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To invite you to take part in competitions, to provide us with feedback on your experiences, take up promotions or to keep you informed about products of services which may be of interest to you. Some of these interactions may be online or through social media. |
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Lifestyle and demographic Insight and Profiling |
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To build a profile of you, your preferences and your habits to better understand your interests and how you play. We may use these profiles to contact you through social media to promote our business. |
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Improve our services and ensure our systems are secure and up to date |
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To ensure that content from the site is presented in the most effective manner for you and for your computer, maintain and improve our products and services, optimise business processes, ensure the integrity of our systems and manage our Information Technology estate, undertake quality assurance, support efficient management of our staff, analyse performance of webpages or promotions and provide content that is relevant to you. |
Legitimate interests to ensure that our interaction with customers is appropriate, working and efficient. |
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Prevention and Detection of Crime, |
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List of active software applications and active processes while using our website, including access to files and site-related program folders To prevent or detect crime, fraud, theft or loss to our business and our customers and prevent the use of unfair practices in our websites or potential breach of our General Terms and Conditions and of applicable law. In certain circumstances, such as high depositing players and/ or politically exposed persons, we will carry out enhanced due diligence focused on source of funds and background checks. These due diligences could include additional documentation provided by players, based on a case-by-case basis, or information available in the public domain. |
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Business sale, acquisition and rights |
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To exercise or defend legal claims or acquiring or selling a business. |
Legitimate interests to protect and defend our business. |
We may need to share personal information with other organisations to ensure that we meet our legal obligations or where we need support in meeting your needs or our contractual obligations. We may also share information with other organisations where we consider it to be in the public interest or in the legitimate interest of ourselves or these other parties. These other parties are typically:
- business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
- our affiliates and selected third parties, where you have expressly opted-out of receiving marketing from us / third parties, have been barred or self-excluded, in which case we may share suppression lists with our affiliates and selected third parties, to ensure you do not receive unsolicited marketing;
- members of the Entain Group and third party suppliers and service providers for any of the purposes identified in the table above; third party suppliers and service providers to the extent they assist the Entain Group with its legal / regulatory obligations e.g. providers of services in respect of anti-money laundering, fraud, verification etc.;
- selected third parties so that they can contact you with details of the services that they provide, where you have expressly opted-in/consented to the disclosure of your personal data for these purposes;
- Social Media platforms, where for example you chose to log onto your gaming account with us through your Social Media identity. Or when we communicate with you via your Social media account;
- analytics and search engine providers that assist us in the improvement and optimization of our site and other selected third parties;
- other 3rd party organisations who ask, encourage or collate feedback and any online views of your experiences with us to help us improve and optimize our services.
- Banks, credit card companies and relevant agencies who may share with third parties for the purpose of investigating and safeguarding against underage, fraudulent, criminal or suspicious activity or safer gambling and affordability checks (or other activities we are bound by law, regulation or guidance to investigate and safeguard against) or if we have reason to believe that you have undertaken such activity, such as:
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KSV1870 Information GmbH Wagenseilgasse 7, 120 Vienna, Austria
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A credit scoring provider used only for Austrian customers and acting as separate data controller. |
- our regulators, law enforcement or fraud prevention agencies, as well as our legal advisers, courts, applicable independent adjudication services and poker organisations and any other authorised bodies, for the purposes of investigating any actual or suspected criminal activity, maintaining standards of behaviour in poker or other regulatory or legal matters.
We may share your personal information with other members of the Entain Group for marketing purposes. We will not share it with other 3rd party organisations however unless you have expressly opted-in/consented to the disclosure of your personal data for these purposes.
We may also disclose your personal information to third parties in the following circumstances:
- in the event that we consider selling or buying any business or assets, in which case we will disclose your personal data to any prospective sellers or buyers of such business or assets;
- in the event of any insolvency situation (e.g. the administration or liquidation) of Entain Group plc, or a data controller or any of its group entities;
- if we, or substantially all of our assets, are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;
- in order to enforce or apply our website terms of use;
- to protect the rights, property, or safety of us, our staff, our customers, or others. This includes exchanging information with other companies and organisations (including without limitation, other gambling operators and the local police or other local law enforcement agencies) for the purposes of staff and customer safety, crime prevention, fraud protection and credit risk reduction;
- if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or regulatory requirements, or otherwise for the prevention or detection of fraud or crime; and
- Where you have self-excluded yourself from gambling, we may share this information with our regulators or other companies in our field where we believe it is important to support your exclusion.
Meeting our Responsible Gambling Obligations
- We take responsible gambling very seriously at Entain. We may share your information across our brands in the Entain Group, and where required with other organisations to meet our responsible gambling commitments.
- We have an obligation to identify those at harm from gambling as early as we can and help them stop gambling by placing certain limits on accounts; this could include deposit limits, product limits, limiting the ability of an account to gamble certain products / times / periods. In order to meet these obligations, we analyse customer’s transactions and evaluate behaviour or financial status across our products and brands, which may lead us to make decisions on your account(s). Please see the on our website for more information.
- We are also constantly looking at innovative ways to help spot players who may be on a path to difficulties and identify them digitally. This means that we may use systems that identify customers (such as cookies on player’s devices or images sent by you) and internally we have developed systems to understand your play to better communicate any risks concerning your activity. We may also share or receive player data with other organisations who help evaluate risks or assess affordability by looking at how you may interact with other gambling operators or help individuals directly.
In all these cases, please be assured that we take our obligations very seriously, in helping customers gamble responsibly and in protecting your personal information. We will always ensure that we take the most appropriate measures and controls to protect your data.
How long we retain your personal data
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Type of Data |
Typical Retention Time |
Information |
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Customer Call recordings |
3 years |
An extended retention may be applied on a case by case basis |
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Customer Data |
A 5 -year retention period which starts to run from the date your account is closed |
We will only continue to hold personal data relating to your account as permitted under data protection legislation (i) where we are under a legal requirement under gambling or tax legislation to retain your data; and (ii) to exercise or defend our legal rights |
The above retention times may be extended for example where it is needed to meet a specific regulatory obligation, investigate a crime, handle a claim or resolve a complaint
Locations that we may transfer your personal data
From time to time, service providers, members of the Entain Group and organisations with whom we work with, may be located outside the UK or European Economic Area in countries that do not have the same standards of protection for personal data as the UK or EEA Countries. We will, however, always use every reasonable effort to ensure sufficient protections are in place to safeguard your personal data. We will also ensure that our service providers enter into compliant processing agreements with us to ensure that your personal data is processed in accordance with applicable data protection legislation. Further information about the mechanisms we will apply can be found here but please contact us on the email address below if you have any specific questions regarding international transfers: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_en.
We take compliance with security regulations, standards, guidelines and privacy laws very seriously and promote security measures that will maintain the confidentiality, integrity and availability of personal data. We use reasonable organisational, technical and administrative measures to protect customer personal data from unauthorised access, alteration, disclosure or destruction of personal data that we hold.
As a business, we have secure firewalled datacentres, certified encrypted webpages and we are ISO27001:2013 certified. We also take steps to ensure our subsidiaries, agents, affiliates and suppliers employ adequate levels of security across the business.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to prevent unauthorised access attempts.
We use cookies for various purposes including making your experience of our website better. For more information on our use of cookies, please see our Cookies Notice.
Marketing Communications and your choices
We use various forms of communication to interact with you, such as email, text or online.
When we first collect your personal data, we’ll ask you to tell us how you would like to hear from us in future about our other products and services. It will normally be via a tick boxes on forms or web page and you can opt-out at any time.
What is 'Opting Out'?
The term opt out refers to several methods by which individuals can avoid receiving unsolicited product or service information. This ability is usually associated with direct marketing campaigns such as telemarketing, e-mail marketing, or direct mail.
You may also hear from us online, by accepting marketing cookies or through your social media provider if you have agreed to accept marketing messages from them. You should check your Social Media providers own Privacy Notice in this regard.
*Please consider that 'opting out' will not prevent any essential customer correspondence e.g. bet or account correspondence.
How can I opt out of marketing correspondence?
If you do not wish to receive any offers, promotions, information on events and tailored communications based on your account activity, you can request to be made un-contactable by:
- Using the “unsubscribe” option provided in any marketing communication you receive
- changing your preferences on your account settings
- contacting our Customer Support department.
What details do you require from me?
We would need as much of the following as possible, to ensure that you are not sent any further unwanted correspondence:
- Your full name
- Your account number
- How we contacted you, i.e. email, SMS, or post
- The mobile number or email/postal address we contacted you on
- The mobile number or email address that the message came from
- The date(s) and time(s) you were contacted
- A copy of the message you were sent (e.g. a screenshot or a forwarded email sent to our customer care team)
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Description of Right |
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Right 1 |
You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. |
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Right 2 |
A right to access personal data held by us about you. This right is not an absolute right and must not be interpreted in isolation of the other provisions of the GDPR. There are lawful limitations to this right that it may apply, for instance, where other rights such as; confidentiality, the rights of others, legal privilege and/or the right to apply adversarial disclosure rules in the course of a potential claim or the defence or establishment of a claim are in scope and need to be balanced with the right of access. |
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Right 3 |
A right to require us to rectify any inaccurate personal data held by us about you. |
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Right 4 |
A right to require us to erase personal data held by us about you. This right will only apply where (for example): we no longer need to use the personal data to achieve the purpose we collected it for; or where you withdraw your consent if we are using your personal data based on your consent; or where you object to the way we process your data (in line with Right 6 below). This right is not absolute and will not apply when legitimate and overriding reasons apply. |
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Right 5 |
In certain circumstances, a right to restrict our processing of personal data held by us about you. This right will only apply where (for example): you dispute the accuracy of the personal data held by us; or where you would have the right to require us to erase the personal data but would prefer that our processing is restricted instead; or where we no longer need to use the personal data to achieve the purpose we collected it for, but you require the data for the purposes of dealing with legal claims. |
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Right 6 |
In certain circumstances, a right to receive personal data, which you have provided to us, in a structured, commonly used and machine-readable format. You also have the right to require us to transfer this personal data to another organisation, at your request. |
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Right 7 |
A right to object to our processing of personal data held by us about you where the processing of such data is necessary for the purposes of our legitimate interests, unless we are able to demonstrate, on balance, legitimate grounds for continuing to process personal data which override your rights or which are for the establishment, exercise or defence of legal claims. |
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Right 8 |
A right for you not to be subject to a decision based solely on an automated process, including profiling, which produces legal effects concerning you or similarly significantly affect you. |
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Right 9 |
A right to withdraw your consent, where we are relying on it to use your personal data (for example, to provide you with marketing information about our services or products). |
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Right 10 |
You have the right to complain to Information and Data Protection Commissioner (https://idpc.org.mt/). |
Contact Us or Our Data Protection Officer
If you would like to exercise any of your data protection rights, such as the right of access to your information or data deletion, directly by yourself or by a third party on your behalf, please contact privacy@partypoker.com
If you have any questions about this Notice or would like further information about your rights, our Data Protection Officer can be contacted by emailing: dataprotectionofficer@entaingroup.com.
Questions and comments regarding this privacy notice are welcomed.
*Please note that these channels are not monitored for any customer service-related queries.
Changes to this Privacy Policy
Any changes to this privacy policy in the future will be posted on this page, and where appropriate, notified to you by email. Please check back frequently to see any updates or changes to this privacy policy.
This policy was last reviewed and updated: March 2023