Effective: 24th January 2018
1. ABOUT THIS POLICY
This Privacy and Cookies Policy (Policy) is for clients and affiliates of The Global Tote Pty Limited (Global Tote, we, us, our). Global Tote is a company registered in in Alderney under company number 1944 which holds a B2B eGambling licence granted by The Alderney Gambling Control Commission. Global Tote owns and operates the website, www.globaltote.com (the Website).
Global Tote is bound in Great Britain by the Data Protection Act 1998. You can contact our Privacy Officer to discuss any privacy related queries you may have – Email: [email protected]
This Policy explains how we collect, use and disclose information about you and explains how we manage your personal information, including:
- the kinds of personal information we collect and hold;
- how we collect and hold your personal information;
- our reasons for collecting, holding, using and disclosing personal information;
- how you may access your personal information held by us and have it corrected;
- how you may complain about the way we deal with your personal information, and how we will deal with your complaint; and
- whether we will disclose your personal information to overseas recipients, and if so the likely location(s) of those recipients.
By accessing and/or using our Website, our products or services or by otherwise providing us with your personal information, you confirm that you have read and agree to this Policy and consent to the management of your personal information as described in this Policy.
3. KINDS OF INFORMATION WE COLLECT AND HOLD
The kind of personal information we may collect and hold depends on your dealings with us, and the requirements of the laws, regulations, licence conditions and betting rules which apply to us from time to time.
3.1 Opening accounts
To open a Global Tote account, we will collect the following personal information from you:
- residential and email addresses;
- date of birth; and
- telephone number.To comply with our obligations under legislation, we may also require copies of documents which confirm your identity, such as:
- driver’s licence;
- birth certificate; and/or
- utility bills.We may ask for other details from you, such as:
- your credit card and/or bank account details (in order to allow you to withdraw funds from, or deposit funds into, your account); and
- some lifestyle or betting frequency information for the purposes of monitoring your betting activity or improving the services provided to you by us or our affiliates.
3.2 Claiming prizes and website enquiries
If you win a prize, or apply for an unclaimed prize or dispute a decision we make, we will collect your personal information including your name, email address, residential address and contact phone number.
3.3 Information from other Global Tote related companies
Our related bodies corporate may provide us with information about you such as:
- contact details;
- date of birth;
- copies of identification documents;
- lifestyle or betting frequency information; and
- recordings of telephone calls you have made to the call centre(s) of any of our related bodies corporate.
3.5 Online behaviour
We may collect information regarding your online behaviour, including:
- your responses to promotions, giveaways and competitions;
- the time, date and URL of each request for a page from our web server (including the times that you login to any accounts to ensure the security of your account and to verify that the person operating the account is you); and
- information from your computer or device (e.g. IP address) allowing us to: analyse trends, administer our Websites, track your web navigation, and gather broad demographic information for aggregated use.
3.6 Use of aggregated data
We also may use the information we collect about you in an aggregate form. Aggregate data is information (which may have been originally personally identifiable or non-personally identifiable) that subsequently is aggregated with information from other sources and is used in aggregate form.
Although aggregate data may be based in part on personally identifiable information about you, it does not identify you personally. We may use aggregate data we collect in order to conduct analysis or research, such as research about customer demographics, internet use, and interests and behaviour. We may share this type of aggregate data with a variety of third parties, including our affiliates, advertisers and other current and prospective business partners. As this form of data does not identify particular users, these third parties will not be able to contact you based solely on this data.
Aggregate data may also be used for Website administration, advertising, and promotional purposes, and we may share this information with various affiliated and unaffiliated entities. We may also enter into agreements with outside companies that possess the technology that allows us to customise the advertising and marketing messages you receive while accessing our Websites. Your non-personally identifiable information and clickstream data about your activities may be shared with these companies so that this customisation can be accomplished. Our agreement with these companies restricts them from sharing your information with third parties or using it for any other purpose. Clickstream and demographic information may also be shared with our advertisers and business partners.
We may provide targeted advertisements based on information about you, such as your interests. We do not provide any personally identifiable information to the advertiser when you interact with or view a targeted ad, although advertisers (including ad serving companies) may assume that people who interact with, view, or click targeted ads meet the targeting criteria.
4. HOW WE COLLECT AND HOLD PERSONAL INFORMATION
4.1. How we collect your personal information
We usually collect your personal information directly from you by telephone, in person or online through our Website. However, we may collect information from a third party if it isn’t reasonable or practicable to collect it from you. For example, we may collect information from:
- third parties assist us in verifying your identity or which help us to assess your risk to our business;
- other companies related to Global Tote, including TopBetta Holdings Limited, TopBetta Pty Ltd, 12Follow Pty Ltd, Mad Bookie Pty Ltd and/or TopTippa Pty Ltd.
We may collect your personal information in a variety of ways, for example, when you visit or use our Websites and/or services, when you register for and log into an account on our Website, when you sign up to join a mailing list or to receive newsletters, through social networking sites, when you enter to participate in competitions or surveys or when you
5. HOW DO WE SECURE YOUR PERSONAL INFORMATION?
We will take reasonable steps to ensure your information is dealt with in a manner consistent with the Data Protection Act 1998. In particular, Global Tote takes reasonable precautions in the circumstances to protect the personal information it holds from:
- misuse, interference and loss; and
- unauthorised access, modification or disclosure.
These include protection of passwords using industry standard encryption; measures to preserve system security and prevent unauthorised access; and back-up systems to prevent accidental or malicious loss of data. Any paper copies are stored in locked cabinets or restricted access archive rooms. We may use third party data storage providers to store personal information electronically. We take reasonable steps to ensure this information is held as securely as information stored on our own equipment and in accordance with the Data Protection Act 1998.
Documents verifying your identity and any credit card information you send us will be stored in a secure database.
Unfortunately, there is always risk involved in sending information through any channel over the Internet and while we aim to use our best efforts to secure and protect your personal information, we cannot guarantee the “perfect security” of any information you transmit or provide to us. You send information over the Internet entirely at your own risk.
6. THE PURPOSES FOR WHICH WE COLLECT, HOLD, USE AND DISCLOSE YOUR PERSONAL INFORMATION
6.1 Our main purposes for collecting your personal information
Our primary purposes for collecting, holding and using your personal information include:
- To identify you and verify your age and identity;
- To provide you with our services and products;
- To manage, administer and control the quality of the products and services we provide to you and otherwise conduct our business, for example, to enforce our terms of service or process payment fees and transactions;
- To register you for an account on our Website and to assist in the management of your account (for example, sending password reminders);
- To market our products and services to you, such as to send you email newsletters;
- To enable our related bodies corporate and selected third party partners to send you product and service information that we believe may be of interest to you;
- To conduct analysis on our Website’s usage, for example to monitor Website use and traffic;
- To contact you or respond to your queries, comments and feedback;
- To comply with our legal, regulatory and licensing obligations, including:
- to the racing controlling bodies (including thoroughbred, harness and greyhound) under race rields approvals and legislation and our permits with various bodies;
- to authorised sports controlling bodies (domestic and international) in accordance with integrity agreements and other arrangements with these bodies.
- To operate self-exclusion, pre-commitment limit, deposit limits and minimum bet exemption programs;
- For any other purpose for which you provided the information; and
- For any other secondary purpose related to the above reasons.
6.2 Our other reasons for collecting, holding, using and disclosing your personal information
We may also collect, hold, use or disclose personal information about you for the following reasons:
- To notify you if you have won a competition, promotion or prize;
- To monitor, develop and improve our services;
- To monitor, develop and improve our products;
- To ensure the optimum level of security surrounding any account you may hold with Global Tote;
- To assist you with your complaints and enquiries;
- To assess whether you pose a risk to our business or the businesses of our wider corporate group; or
- To protect the rights and property of any other Global Tote customer.
6.3 Public Relations
If you win a major prize, we may disclose your details to external publicity businesses for reasonable promotional activities. By entering into a promotion with one our Global Tote related companies, you will be consenting to this use and disclosure of your personal information for this purpose.
6.4 Service providers
We may disclose personal information to third party service providers, contractors, suppliers, vendors, credit-reporting bodies, fraud-checking agencies, credit providers or organisations that assist us in the management and operation of our business and the provision of services to you, in order to:
- electronically verify your identity and age (including online) for example, disclosure to regulated third party ID verification service providers;
- provide, manage and administer our products and services and business systems (including mailing houses, printers, advertising agencies, postal services, call centres, providers of customer relationship management (CRM) services, providers of fraud detection services and IT technicians);
- operate, maintain and manage our Website and customer database (including, website hosting services and information storage services);
- develop and market our products and services (including market research analysts);
- assess risks and comply with any reporting obligations;
- comply with payment card industry standards, and securely manage processing of your credit card payments and storage of your credit card details;
- to evaluate credit related matters such as credit-worthiness, credit rating, credit provision and financing for; and
- analyse trends and aggregated demographic information, and target your interests.
6.5 Government bodies/regulators/industry bodies/venues
We may be required to disclose your personal information to (without limitation):
- government or regulatory bodies and agencies, gambling regulators, law enforcement agencies (such as the police) or courts of law, if required or authorised to do so by law, for example, in response to a subpoena or legal order, to investigate, prevent or take action regarding suspected illegal activities, fraud or potential threats or to exercise legal rights or defend against claims;
- respond to an enquiry from a government agency under relevant laws;
- gambling regulators, for example, The Alderney Racing Commission or the Great Britain Racing Commission, to comply with our notification, regulatory, integrity and compliance obligations under our gambling licences;
- the racing controlling bodies (including thoroughbred, harness and greyhound) under the terms and conditions specified in approvals and permits granted to Global Tote, or agreements entered into with Global Tote, by these racing controlling bodies, for example, in response to an integrity request;
- authorised sports controlling bodies (domestic and international) under the terms and conditions of a sports product fee and integrity agreement;
- other organisations that coordinate a sport or racing code or are responsible for the integrity of a sport or racing code; and
- owners/managers/operators of retail agencies and venues from which you have excluded yourself.
6.6 Related corporations
We may disclose personal information to our related bodies corporate, including (but not limited to):
- TopBetta Holdings Limited;
- TopBetta Pty Ltd;
- 12Follow Pty Ltd;
- Operis Momentus Pty Ltd; and
- Any other related bodies corporate as required from time to time, so they can:
- comply with their obligations under laws, regulations, licence conditions and betting rules; and
- send you marketing information directly (see section 6.7).
Subject to the Data Protection Act 1998, we may occasionally use and disclose your personal information to our related bodies corporate, partners, affiliates or suppliers for the purpose of:
- identifying your betting behaviour, habits and preferences;
- letting you know about upcoming events, promotions and new products/ services or other opportunities, via direct mail, email, SMS, MMS and/or phone calls;
- sending you product and service information on behalf of third parties; and
- enabling our related bodies corporate and selected third party affiliates and business partners to send directly to you product and service information which may be of interest to you. From time to time, our affiliates and business partners may disclose your personal information to other third party advertising clients to provide you with further product and service information which may be of interest to you (unless you have indicated to us that you wish to opt out of receiving these communications).
By agreeing to the terms and conditions of your Global Tote account(s), you consent to receiving marketing material from us and from third party partners and affiliates, but you may withdraw that consent at any time by emailing: [email protected] and informing us that you wish to opt out.
Each time you are sent a marketing communication, you will be able to opt-out from future marketing communications. You can also opt-out from future marketing communications at any time (email: [email protected]). We will promptly action any opt-out request.
6.8 Replacement providers
- transfer responsibility for providing a Global Tote product or service to another business; or
- stop providing a Global Tote product or service (or limit it), and another business continues to offer a similar product/service,
we may disclose personal information to the other business so the product or service can continue to be provided to you. By agreeing to the terms and conditions for your Global Tote account(s), you consent to this disclosure, but you may withdraw that consent at any time by emailing: [email protected]
6.9 Monitoring of betting accounts, including emails
In accordance with our obligations under our gambling licence and gambling legislation generally, we may monitor and maintain records of the transactions on your Global Tote account(s), including any emails you send to us.
You acknowledge and agree that we may use and disclose information collated during monitoring to third parties, including by releasing your personal information to law enforcement agencies, government authorities or any other regulatory authorities, as authorised or required by law or to comply with our obligations under our gambling licence and gambling legislation. We will not tell you when we monitor your transactions or if we disclose any personal information obtained.
6.10 Monitoring and recording phone calls
You acknowledge and consent to such recordings being made and agree that relevant recordings and details of your calls may be disclosed to law enforcement agencies, regulatory authorities and other authorities in the event of a dispute or as otherwise required or permitted in order to comply with our legal and regulatory obligations, for example, our obligations under gambling legislation. We will not notify you of those disclosures if legally permitted to do so. If you do not wish for your telephone call with Global Tote to be recorded, please notify the Global Tote telephone operator immediately, at the beginning of the telephone call.
6.11 Company sale or restructure
We may disclose your personal information to a buyer in the event of a merger, divestiture, restructuring, reorganisation, dissolution or any other form of sale or restructure of some or all of Global Tote’s assets or those of its holding companies in the circumstances where the personal information is held by Global Tote about its customers forms part of the assets transferred.
6.12 Overseas disclosure of personal information
We may disclose your personal information to overseas recipients such as affiliates or third parties who assist us in the management and conduct of our business or provide us with services. These overseas recipients may assist us in the processing, storage or analysis of your information, processing of credit card payments or provide technical or website support to us.
Where Global Tote discloses your personal information to overseas recipients, these recipients are most likely to be located in Australia, the United Kingdom and the United States of America. This list of countries is not exhaustive and may change from time to time.
Important Notice: In the event that the processing of your personal information involves the disclosure of any information outside Alderney or the United Kingdom, you acknowledge that, by providing us with your personal information, you consent to such overseas disclosure. By consenting to such disclosure, you acknowledge that:
- Global Tote will not be accountable under any privacy legislation for any breach of your privacy by the overseas recipient; and
- you will not be able to seek redress under any privacy legislation against Global Tote (or any related body corporate of Global Tote) for any breach of your privacy by an overseas recipient.
Note: Countries outside of the United Kingdom or Australia may not always have the same or similar privacy and data protection laws and in some cases, foreign law may require us to disclose your personal information overseas, for example to an overseas law enforcement authority. Please be aware that you may not be able to seek redress for a breach of privacy in a country outside of the United Kingdom or Australia. However, where we do provide your personal information to third parties, Global Tote will take such steps as are reasonable to ensure your information is used in accordance with this policy.
7. HOW CAN I ACCESS AND CORRECT MY PERSONAL INFORMATION?
You have a right to access the personal information we hold about you. To make a request for access, please contact:
Privacy Officer Address: Inchalla, Le Val, Alderney GY9 3UL
Email: [email protected]
Your personal information will usually be available within 30 days of your request. If there is a fee for accessing your personal information, we will confirm the amount before providing the information.
We may not be able to grant you access to your personal information if the release of your personal information would have an unreasonable impact on the privacy of others or is otherwise unlawful. Please see the APPs for further information. If one of these circumstances applies, we will provide you with a written explanation of the reasons for the refusal, unless it would be unreasonable or unlawful to do so.
You have a right to ask us to correct the personal information we hold about you. To make a request for the correction of your personal information, please contact the Privacy Officer at:
Global Tote Address: Inchalla, Le Val, Alderney GY9 3UL
Email: [email protected]
Once we receive your request for correction, we will endeavour to respond to that request within 30 days of receiving your request. It is not always possible to remove or modify information in our databases, but we will take reasonable steps to correct your personal information to ensure that it is accurate, up-to-date, complete, relevant and not misleading. If we decline to make your requested correction, you may request us to attach to your personal information a statement that it is inaccurate, out-of-date, incomplete, irrelevant or misleading.
If we disclose the information to a third party before correcting it, you may request us to notify the third party of the correction we’ve made. We will not charge you to request a correction, for making a correction or for associating a statement with a record.
8. THIRD PARTY LINKS
9. HOW LONG CAN GLOBAL TOTE KEEP MY PERSONAL INFORMATION?
If Global Tote:
- no longer needs to use or disclose your personal information for any purpose that is authorised under the Alderney, United Kingdom and Australian privacy laws; and
- is not otherwise legally required to retain that information,
then it will take reasonable steps to destroy the personal information or ensure it is de-identified.
At this point in time Global Tote does not use any cookies on this website.