REF: ZZDFGDPR, Issue: 3
Issue Date: 01 July 2020
- All data subjects ("You") whose personal data or personal information ("Information") is collected on any of Our products provided by Dragonfish, in line with the requirements of the GDPR.
- Zenzero Limited ("Zenzero", "We", "Us") is responsible for ensuring that this notice is made available to You prior to collecting/processing Your personal data.
- Privacy Notice
Who are We?
Zenzero is the marketing company who owns the branding of the product operated by Our service providing partner, Dragonfish ("Operator"). We manage the retention and acquisition marketing including but not limited to; ad serving; electronic mail; text messaging; direct postal mail; and on-site communications. We also operation bespoke promotional campaigns which are managed by Our promotions team.
We are a registered Data Controller in the Isle of Man. "Controller" is a legal term under data protection law. We are responsible for the justification and appropriate processing of Your personal Information.
We have an agreement with the service providing Operator. Our brands are used to style, market, and promote the gambling services provided to You by the Operator. The Operator collects Your Information when You use any of Our sites, and shares it with Us. We use Your personal Information for a variety of purposes, as described below, such as marketing Our website, and monitoring the website's business performance.
Our Data Protection Officer (DPO) and data protection representatives can be contacted directly here:
- ATTN: Data Protection Officer, 13 Tower House, Castle Street, Douglas, IM1 2EZ
How we collect Your Information
The Operator will ask for Your personal Information, such as Your name, surname, username, password, security question, date of birth, home address, email address, phone number, mobile number, for the purposes of opening an account, and providing the gambling service to You. The Operator also collects information about the transactions You make, including with respect to Your transactions, deposits, balances, bets, withdraws, bonuses and winnings and Your general gaming activities.
The Operator regularly shares some aspects of the personal Information they have collected about You with Us. This includes Information which We reasonably need in order to market Our sites. The Operator may provide Us with all of the personal Information they hold on You – for example, if We arrange for someone else to operate a website instead of the current Operator, then the Information held by the Operator would be transferred to a new operator.
Similarly, if We arrange a sale of one of Our websites, We may need to reasonably transfer Your Information to the new brand owner and Operator's marketing partner.
The Information We would like to collect from and process from You:
Information Type Source Full Name Operating partner after registration on the service. Postal Address Operating partner after registration on the platform. Alternatively, given directly by You during participation of campaign via online form or email. Date of Birth Operating partner after registration on the platform. Email Address Operating partner after registration on the platform. Alternatively, given directly by You during participation of campaign via online form or email. Cell Phone Number Operating partner after registration on the platform. Alternatively, given directly by You during participation of campaign via online form or email. Username/User ID Gameplay History Operating partner after registration on the platform and continually thereafter resulting from gameplay. Transaction History Operating partner after registration on the platform and continually thereafter resulting from transactions. IP Address Automatically passed to Us by Your ISP.
The Information We collect will be used for the following purposes:
- To segment and profile Your account to provide targeted and relevant promotions to You, for example, if You are a new player We use Your Information to send You new player promotions. Similarly, if You are a regular player, You may be invited to join Our reward or VIP schemes based on the processed Information.
- To get in contact with You to keep You up to date with promotions and offers which are relevant to You. We do this by email, text, and postal flyers, depending which contact methods You have asked Us to use.
- To send You news and promotions that are relevant to You from Our other brands ("Sister Sites"), or from close partners operating similar products. We never sell Your Informaition to other companies, except in the instance of the whole product being transferred to a new Data Controller, and a new marketing partner of the Operator. Any emails, texts, or postal flyers sent with offers from Our Sister Sites or close partners are sent from Us, on their behalf, and only using methods You have asked Us to.
- To operate the web-server systems that provide the visual elements of Our product and secure communications between Your computer and Our servers.
- To provide a rich and engaging website experience Your account's username may be made publicly visible on the webpages of our website; our Sister Sites; and our related social media pages in relation to promotions and offers, including using your Username to detail any promotional offer win or prize you have been awarded or acheived. Further, your Username may be made public when you interact with dynamic sections of the website, for example, by taking part in polls, or making comments and/or ratings by using interactive parts of the website. This list of interactive dynamic engaging content is not exhaustive. By participating in these promotions or offers, you agree to have Your username published to the website's community and publicly in this way.
Our legal basis for processing for the personal data:
- Our Operating partner is contractually obliged to provide Us access to Your Information as part of operating the product and promotions. They are required to collect the data to comply with industry regulations.
- To provide the services and promotions offered to You on Our product, We need to process Your Information as detailed above, in particular, to send You news and updates on promotions and offers which are relevant to You by email, text, and post, We must process Your contact details to ensure accurate delivery.
Any legitimate interests pursued by Us, or third parties We use, are as follows:
- We believe it is in Your interest to receive segmented and profiled content based on Your history with Us. This provides You with the most relevant and up-to-date news and promotions, which You can then choose whether to participate in.
- We believe it in Your interest to hear from Our sister-sites and close partners as their promotions and services are very similar to ours, and We believe those offers will be of interest and value to You. We never sell or transfer Your personal data to third parties for marketing purposes, which means the control of Your data is not at risk and always under Your control with Us.
The special categories of personal data concerned are:
- We do not collect special category information as it is not relevant to Our service.
By opening an account You are consenting to this Privacy Notice, and You are giving Us permission to process Your personal data specifically for the purposes identified.
You may withdraw consent at any time by any of the below methods:
- Contacting Our Operating partner to withdraw or modify consent
- Contacting Us directly by email mailboxes operated by Our product
- Contacting Us directly to Our data protection officer firstname.lastname@example.org
- Clicking or tapping the data-protection link sent with all Our texts and emails
- Visiting the data-protection URL printed on all Our postal flyers
- Visiting the product and updating Your preferences on Your settings page
- Writing to Us at "ATTN: Data Protection Officer, 13 Tower House, Castle Street, Douglas, IM1 2EZ"
Zenzero Limited will pass on Your Information to third parties in order to operate the services under the legitimate interests listed above. The following third parties will receive Your Information for the following purpose(s) as part of the processing activities:
Zenzero will process personal data for the duration of the time You are active with any of Our products, only within the remit of the membership or promotion You elected to take part in, and will store the personal data for no longer than 6 years after activity ceases, in line with industry standards.
In instances of unsubscription, Your data associated with Your contact method will be stored indefinitely or until You re-subscribe, in order to keep communications suppressed.
Your Rights as a Data Subject
At any point while We are in possession of or processing Your Information, You, the data subject, have the following rights:
- Right of access - You have the right to request a copy of the information that We hold about You.
- Right of rectification - You have a right to correct data that We hold about You that is inaccurate or incomplete.
- Right to be forgotten - in certain circumstances You can ask for the data We hold about You to be erased from Our records.
- Right to restriction of processing - where certain conditions apply to have a right to restrict the processing.
- Right of portability - You have the right to have the data We hold about You transferred to another organisation.
- Right to object - You have the right to object to certain types of processing such as direct marketing.
- Right to object to automated processing, including profiling - You also have the right to be subject to the legal effects of automated processing or profiling.
- Right to judicial review: in the event that Organisation Name refuses Your request under rights of access, We will provide You with a reason as to why. You have the right to complain as outlined in clause 3.6 below.
All of the above requests will be forwarded on should there be a third party involved (as stated in 3.4 above) in the processing of Your personal data.
In the event that You wish to make a complaint about how Your Information is being processed by Zenzero Limited (or third parties as described in 3.4 above), or how Your complaint has been handled, You have the right to lodge a complaint directly with the supervisory authority and Zenzero's data protection representatives.
The details for each of these contacts are:
Supervisory authority contact details Zenzero's Data Protection Officer Contact Name: Isle of Man Information Commissions Complaints Data Protection Officer Address line 1: First Floor Prospect House Zenzero Limited, ATTN: PDO Address line 2: Prospect Hill 13 Tower House Address line 3: Douglas Castle Street Douglas Address line 4: Isle of Man Isle of Man Address line 5: IM1 1ET IM1 2EZ Email: Online Form email@example.com Telephone: See Contact Area See Contact Area
Read more about how and why We use Your data by visiting any of Our products and clicking on Data Protection Guidebook at the bottom of the page.
Personal Data Under the EU's General Data Protection Regulation (GDPR) personal data is defined as:
"any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person".
How We use Your information This privacy notice tells You how We, Zenzero, will collect and use Your personal data for operating Our services and products, and activities We believe are in Your personal interest for example tracking cookies, profiling and segmenting, complaints, and operating communication subscriptions.
Why does Zenzero need to collect and store personal data? In order for Us to provide You with Our products and services We need to collect personal data for correspondence and promotion operation. In any event, We are committed to ensuring that the information We collect and use is appropriate for this purpose, and does not constitute an invasion of Your privacy. We are committed to collecting as little information and personal details about You as possible.
In terms of being contacted for marketing purposes Zenzero believe it is in Your legitimate interest to hear from Us regarding the service You have registered for, and from other products We operate, and from close partners of ours due to the close similarity of services offered. All marketing We send You includes clear and easy avenues for updating Your settings if You with to revoke permission to contact You or cease processing Your data.
Will Zenzero share my personal data with anyone else? We may pass Your personal data on to third-party service providers contracted to Zenzero in the course of supplying the product/service to registered for, to You. Any third parties that We may share Your data with are obliged to keep Your details securely, and to use them only to fulfil the service they provide You on Our behalf such as carrying mail or analysing data. When they no longer need Your data to fulfil this service, they will dispose of the details in line with Zenzero's procedures. If We wish to pass Your sensitive personal data onto a third party other than detailed in this Policy, We will only do so once We have obtained Your consent, unless We are legally required to do otherwise. We do not sell personal data to third-parties.
How will Zenzero use the personal data it collects about me? Zenzero will process (collect, store and use) the information You provide in a manner compatible with the EU's General Data Protection Regulation (GDPR). We will endeavour to keep Your information accurate and up to date, and not keep it for longer than is necessary. Zenzero is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.
Under what circumstances will Zenzero contact me? Our aim is not to be intrusive, and We undertake not to ask irrelevant or unnecessary questions. Moreover, the information You provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.
Can I find out the personal data that the organisation holds about me? Zenzero, at Your request, can confirm what information We hold about You and how it is processed. If Zenzero does hold personal data about You, You can request the following information:
- Identity and the contact details of the person or organisation that has determined how and why to process Your data. In some cases, this will be a representative in the EU.
- Contact details of the data protection officer, where applicable.
- The purpose of the processing as well as the legal basis for processing.
- If the processing is based on the legitimate interests of Zenzero or a third party, information about those interests.
- The categories of personal data collected, stored and processed.
- Recipient(s) or categories of recipients that the data is/will be disclosed to.
- If We intend to transfer the personal data to a third country or international organisation, information about how We ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, We will ensure there are specific measures in place to secure Your information.
- How long the data will be stored.
- Details of Your rights to correct, erase, restrict or object to such processing.
- Information about Your right to withdraw consent at any time.
- How to lodge a complaint with the supervisory authority.
- Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether You are obliged to provide the personal data and the possible consequences of failing to provide such data.
- The source of personal data if it wasn't collected directly from You.
- Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
What forms of ID will I need to provide in order to access this? Zenzero accepts the following forms of ID when information on Your personal data is requested. One of the following: Passport, Driving Licence, or Government-Issued ID PLUS one of the following: Birth Certificate, Utility Bill from the last 3 months.
Contact details of the Data Protection Officer (DPO):
Data Protection Officer (DPO) contact details Contact Name: Data Protection Officer Address line 1: Zenzero Limited, ATTN: DPO Address line 2: 13 Tower House Address line 3: Castle Street Douglas Address line 4: Isle of Man Address line 5: IM1 2EZ Email: firstname.lastname@example.org
Issue 3: Addition of Sailor Bingo to our Dragonfish brands list.
Approved by: Zenzero Data Protection Officer [CMC].
Date of issue: 01 July 2020.
Issue 2: Addition of Fortune Fiesta, Fruity Vegas, Bingorella, Giant Spins, Winzino, and Spinzilla to our Dragonfish brands list. Addition of TextMarketer as a third party processor.
Approved by: Zenzero Data Protection Officer [CMC].
Date of issue: 09 November 2018.
Issue 1: Initial issue.
Approved by: Zenzero Data Protection Officer [CMC].
Date of issue: 01 June 2018.
We may need to use alternative or additional service providers. If a new service provider is added and intended to perform services on Our behalf on a permanent basis We will add them to this Privacy Notice. You agree to regularly review the partners We use to process Your Inforamtion by visiting this Privacy Notice. If a broad change in processing partners is made, We will notify you using methods you have asked us to.