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SmartEXCLUSION Privacy Notice

IHL SmartEXCLUSION (National Self-Exclusion Scheme) Privacy Notice

Who we are

We are IHL Tech Ltd, 57 Ashbourne Road, Derby, Derbyshire, DE22 3FS.

Company Registration Number: 09926970

We are registered as a data controller at the UK Information Commissioner’s Office under number ZA175849.

We are responsible for the processing of personal data that we have received in accordance with the UK General Data Protection Regulation (UKGDPR) and the DPA 2018.

What is SmartEXCLUSION?

SmartEXCLUSION is a digital Self-Exclusion solution which allows people to enrol in Self-Exclusion Schemes via land-based gambling premises.

There are 4 types of Self-Exclusion that may be offered to you in venue*, these are:

Standard Self-Exclusion
This is the default exclusion type offered by all venues.
This would exclude you in line with the selections you make when completing your self-exclusion.

National Self-Exclusion*
This would exclude you across all venues that operate SmartEXCLUSION

Company (Brand) Exclusion*
This would exclude you across all venues operated by a single Company

Single Site Exclusion*
This would exclude you from the venue you are completing your self-exclusion from ONLY

*National, Company and Single Site exclusions are not available in all venues

Our Partners

We partner with providers of other National Self-Exclusion Schemes, to ensure Self-Exclusion is supported across multiple Licenced Gambling Premises. These Partners are:

  • BSESL (Bacta Self Exclusion Services Ltd)
    • A provider of an Adult Gaming Centre Scheme
    • BSESL utilise the services of bacta as a Processor to provide BSESL with operational and administrative support
  • The Bingo Association
    • Operator of the Traditional Bingo Self-Exclusion Scheme

Our Customers

We provide SmartEXCLUSION to Operators of Adult Gaming Centres, Licensed Betting Offices and Licenced Bingo premises in Great Britain and Ireland. These are referred to as our Customers.

We refer to our Customers premises as Venues.

Our role in your privacy as a Self-Excluder

If you are providing Personal Data to us, either directly or via our Customers or Partners to enable us to enrol you on our, or our Partner’s National Self-Exclusion Schemes, this Privacy Notice applies to you.

Please Note

  • If you are providing us data for any other service we provide, please refer to our Privacy Notice Menu
  • If you are visiting our website, please refer to our standard Privacy Policy.

If you are a member of staff providing Personal Data to us via SmartHub, please refer to our IHL SmartHub (Staff User) Privacy Notice

Our responsibilities

  • Our responsibilities as a Data Controller (and Joint Controller)
    • Whilst you are completing your Self-Exclusion at a Venue, we act as a ‘Joint Controller’ of your data together with our Customers. This means that we are jointly determining with our Customers how your Personal Data is processed to enable us to provide the Self-Exclusion Service to you.
    • When you have completed the enrolment of your Self-Exclusion on the SmartEXCLUSION Scheme, we act as a ‘Data Controller’ of your data. This means we determine why and how your Personal Data is processed to enable us to provide the ongoing Self-Exclusion Service to you.
    • If your Self-Exclusion requires us to share your exclusion data with Self-Exclusion Schemes operated by our Partners, we act as a ‘Joint Controller’ of your data with those Partners. This means we jointly determine with our Partners the purposes and means of processing your personal data, to enable us to provide the Self-Exclusion Service to you.

Your responsibilities

Please read this Privacy Notice

If you follow any external links to webpages that are not part of SmartEXCLUSION, our National Self-Exclusion Scheme, please read the respective Privacy Pages for the site you are visiting.

This may include other National Self-Exclusion Schemes, Gambling Support Sites or Information Sites that we share with you upon request following enrolling for your Self-Exclusion.

When we collect data

We will collect data from you with your consent so that we can email or text you. In addition:

  • If you Self-Exclude with SmartEXCLUSION via our Customers, they will digitally complete a Self-Exclusion in Venue with your assistance, using a Tablet or a PC
  • If you have Self-Excluded with another National Scheme Provider, they will share your exclusion data with us.

Types of data we may collect when you are registering for Self-Exclusion using SmartEXCLUSION

  • Self-Exclusion Data
    • Required Data
      • Title
      • Gender
      • Name
      • Address
      • Photo
      • Date of Birth
      • Signature
      • Vehicle Registration Number (Motorway Service Areas ONLY)
    • Optional Data
      • Email Address
      • Phone Number
      • ID

Types of data we may collect when you Self-Exclude using other National Scheme Providers

  • Self-Exclusion Data
    • Title
    • Gender
    • Name
    • Address
    • Photo
    • Date of Birth
    • Email Address
    • Phone Number

Types of data we DO NOT collect

  • Any data relating to racial or ethnic origin.

Determination of Special Category Data

To allow us to provide Self-Exclusion to you, we require you to provide us a photo of yourself. We have determined that due to the specialist nature of technical processing of the photo and the categorisation of Self-Exclusion data as health data that this data is to be treated as Special Category Data. We will ensure we have the appropriate technical and organisational measures and processes in place to securely manage this data.

Purposes for which we process your data

We collect your data solely for the purpose of providing and managing your Self-Exclusion request. This includes the sending of emails and texts that may contain information relating to gambling support services and organisations and the managing of your Tuki account.

How and why we use your data

Data protection law requires that we only use your data for certain reasons and where we have a lawful basis to do so. Here are the reasons why we process your data:

  • Providing our Self-Exclusion Scheme to our Customers (as a Controller or Joint Controller)
    • Processing of your Self-Exclusion record at your request, to enable IHL to deliver, support and improve its Self-Exclusion Scheme (SmartEXCLUSION).
    • Sharing of your Self-Exclusion record with our other Customers who participate in our Self-Exclusion scheme enabling them to manage and monitor any visits that would be in breach of your Self-Exclusion
    • To ensure our Customers can meet their legal obligations under the Gambling Regulations to manage and maintain an effective Self Exclusion Scheme, prevent underage gambling and keep adult gaming premises safe from crime and disorder.
    • As part of our continuous improvement plan so that we can increase the effectiveness of the scheme in identifying Self-Excluders who may try to access a restricted venue, we may on occasion process live data of Self-Exclusion records to monitor and enhance the accuracy of our systems. Examples of this would include the testing of new technology, including facial detection and recognition to further improve and support the Self-Exclusion scheme.
    • Ensuring Self-exclusion policies and procedures and Self-Excluders instructions are adhered to.
    • Protecting vulnerable adults from potential harm caused through Gambling.
    • Subject to the terms you have selected within your self-exclusion record, as a joint controller, we will share your personal data with the providers of other approved Self-Exclusion schemes as detailed in the ‘Our Partners’ section of this policy.
    • Our lawful basis for processing your personal data in this context is our legitimate interests and in relation to special category data, the substantial public interest. To support this lawful basis, we have conducted a Legitimate Interest Assessment and specifically a balancing test, to ensure that the rights of the self-excluder are not being overridden.

Here is what each “lawful basis” means:

Legitimate Interests

  • The processing of your personal data is necessary for the purposes of our legitimate interests and that of our Customers and Partners in providing a National Self-Exclusion Scheme to protect vulnerable people from potential harm caused through gambling. We know that you would reasonably expect us to be processing your personal data and that we are doing so to prevent you from harm. We have therefore concluded, in the context of all the different types of Self-Exclusion listed at the beginning of this Privacy Notice, that when balancing your interests with our legitimate interests that the processing of your personal data is proportionate and not intrusive.

Substantial Public Interest

  • The processing of special category data is necessary for the purposes of ensuring the integrity of the data being processed within the National Self-Exclusion Scheme to ensure Customers can accurately recognise those individuals that have self-excluded and protect vulnerable people from potential harm caused through gambling. We believe that the substantial public interest can be applied to all the different types of Self-Exclusion listed at the beginning of this Privacy Notice.

Your privacy choices and rights

Your rights

You can exercise your rights by sending us an email at dpo@ihlhub.com.

  • You have the right to access information we hold about you
    • This includes the right to ask us for supplementary information about:
      • the categories of data we’re processing.
      • the purposes of data processing.
      • the categories of third parties to whom the data may be disclosed.
      • how long the data will be stored (or the criteria used to determine that period).
      • your other rights regarding our use of your data.

We will provide you with the information within one month of your request, unless doing so would adversely affect the rights and freedoms of others (e.g. another person’s confidentiality or intellectual property rights) or conflict with our obligations to maintain the integrity of a National Self-Exclusion Scheme which is governed by the Gambling Commission.

We will tell you if we can’t meet your request for any reason.

  • You have the right to be ‘forgotten’ by us following the expiry of your Self-Exclusion
    • You can do this by asking us to erase any data we hold about you if it is no longer necessary for us to hold the data for purposes of your Self-Exclusion UNLESS we have a legal obligation to retain your data.
  • You have the right to object to the processing of your data.
    • We will provide you with the information within one month of your request, unless doing so would adversely affect the rights and freedoms of others (e.g. another person’s confidentiality or intellectual property rights) or conflict with our obligations to maintain the integrity of a National Self-Exclusion Scheme which is governed by the Gambling Commission.
  • You have the right to lodge a complaint regarding our use of your data
    • Please tell us first, so we have a chance to address your concerns. If we fail in this, you can address any complaint to the UK Information Commissioner’s Office, either by calling their helpline or as directed on their website at ico.org.uk.

How secure is the data we collect?

We have physical, technical and organisational procedures in place to appropriately safeguard and secure the data we collect.

  • All data is stored in a secure ISO 27001 facility by AWS (Ireland).
  • All data traffic is encrypted with SHA-256 RSA Encryption.
  • We have Always-On Network Flow Monitoring.
  • We have DDos protection services provided by AWS, including Automated Mitigation and all APIs are protected using a Throttling middleware.
  • We have IP Attack Prevention in the form of Rack Attack Preventative Implemented.

However, please remember:

  • You provide personal data at your own risk: unfortunately, no data transmission across the internet is guaranteed to be 100% secure.

If you believe your personal data may have been exposed to a data breach, please contact us immediately on dpo@ihlhub.com.

Where do we store the data?

The data we collect is processed in our Data Centre hosted in Ireland, in our offices in Northampton (UK), Nottingham (UK) and Withernsea (UK) and also in data processing facilities operated by the third parties identified below.

By submitting your data, you agree to this transfer, storing or processing by us. If we transfer or store your information outside the EEA in this way, we will take steps to ensure that your rights continue to be protected as outlined in this Privacy Notice.

How long do we store your data?

The duration of your Self-Exclusion Agreement is the period set when submitting your exclusion (Exclusion Period), plus a maximum 6 months (Thinking Period) followed by an additional 24 hours (Cooling Off Period).

We will stop actively using any personal/identifiable data following the end of your Self-Exclusion Agreement plus a further 6 months, after which your personal data will be anonymised.

How can you access your data?

To increase the transparency of the data that we hold on you, when you create a self-exclusion in venue you will be provided details via email or text of how to securely access the details of your data via our Tuki Applications.

Other Third parties who process your data (Non-Partners)

Businesses often use third parties to help them host their application, communicate with customers, power their emails etc. We contract with third parties who we believe are the best in their field at what they do.

When we do this, sometimes it is necessary for us to share your data with them in order to get these services to work well.

Your data is shared only when strictly necessary and according to the safeguards and good practices detailed in this Privacy Notice.

If third party providers (processors) are established outside of the EU/EEA, we shall ensure that we contract only with third-party providers that are located in countries that ensure adequate levels of protection based on the European Commission’s adequacy decision or that IHL Tech Ltd has entered into agreements with corresponding Standard Contractual Clauses (SCCs) and/or International Data Transfer Agreements (IDTAs) that ensure adequate safeguards with respect to the protection of the privacy and fundamental rights and freedoms of individuals.

Here are the details of our main third-party service providers, and what data they collect or we share with them, where they store the data and why they need it:

  • Amazon Web Services, Ireland
    • We host our Self-Exclusion Scheme (SmartEXCLUSION) on AWS Data Centres in Ireland.
  • Google, USA
    • We use a service called Google Vision to detect a face in a Self-Exclusion Image as part of our quality control and validation processes.
    • No image data is stored by Google.

Cookies

We do not use cookies in the collection of Self-Exclusion Data.

We do use cookies on our Tuki Web Application, details of which can be accessed here.

Revision Date 29/08/2023