This privacy statement demonstrates our commitment to your privacy and security and forms part of the First Class Slots General Terms & Conditions.
The policy contains information about how we use, process and store your data, as well as marketing communications and your legal rights.
We respect the privacy of our visitors and are committed to preserving your online safety by preserving your privacy at anytime you visit or communicate with our site.
Who are we?
First Class Slots is a site operated by Traffic Label Limited.
As the owner of First Class Slots, Traffic Label is principally responsibly for looking after your personal data as both a Data Controller and a Data Processor.
For the remainder of this document the following terminology will apply:
- Traffic Label – Data Controller/Processor (“Traffic Label”, “TL“, us”, “we”, “brand owner”)
- First Class Slots – This particular Traffic Label property (“First Class Slots”, “1CS”, “the site”, “the website”)
- Visitors and customers on our websites (“You”, “visitors”, “members”, “players”)
- Promoted brands and third-parties (“Advertising partners”)
- Services offered by First Class Slots (“Services”, “experience”)
- General Data Protection Regulation (“GDPR”)
- Privacy & Electronic Communications Regulations (“PECR”)
- Information Commissioner’s Office (“ICO”)
- Your use of this website
- How we collect data
- What personal data do we collect and process?
- How and why we process your data
- How and why we share your data
- Non-personal information
- Marketing communications
- International transfers
- How long do we keep your data?
- Data security & storage
- Your rights
- How to contact us
1. Your use of this website
If you don’t want us to use or process your Personal Information in the ways we outline above, you should stop using our sites, products and services and contact us to tell us what you do and do not consent to.
If you want to withdraw your consent to use or process your data in a certain way, your access to our sites, products and services may be affected.
2. How we collect data
Data can be collected and processed during the operations of our website. Below is a list of the current ways in which we may currently collect and store your data for First Class Slots in accordance with GDPR and PECR.
- You register on our website
- You subscribe to our website mailing list
- You are a member at another site in the Traffic Label group network
- You subscribe to the mailing list of another site in the network
- You communicate directly with First Class Slots through a support query
3. What personal data do we collect and process?
We may process the following personal data about you:
- Full name
- Date of birth
- Email address
- IP address
- Website usage
- Partner site usage (selected partners)
- Personal preferences and opinions
Website usage includes sign up date, last login date, marketing campaign interactions, partner link clicks, viewed pages and favourited sites.
Partner site usage includes clicks, registrations, deposits, wagers, wins, losses and net revenue totals.
4. How and why we process your data
We process personal information as necessary by law and for certain legitimate business purposes in a way that is proportionate and respects your privacy, as outlined here:
- Send promotional emails related to our own and third-party products and services (see sections 7 & 8)
- Personalise your members area with relevant content and offers
- Analyse information in our systems and databases to provide a better and more relevant experience
- Providing you with the services described on the site
- Verifying your identity when you sign up to First Class Slots
- Updating you with operational news about the site (changes, service disruptions, security updates)
- Monitoring activity on our site and those of our partners to identify potential fraudulent activity and to ensure compliance with the user terms that apply
- Managing our relationship with you, e.g. by responding to your comments or queries submitted to us on the Sites or asking for your feedback or whether you want to participate in a survey;
- Improving our products and services
- To provide you with a responsible gaming environment
- Providing general administrative and performance functions and activities
- Meet or exercise any of our legal obligations or legal rights
You have the right to object to this processing if you wish and can find more details of how to do this further down the page.
5. How and why we share your data
We occasionally work with third parties to help manage and deliver our services, that may require access to your personal data. Below is a list of the third parties in question and the reasons your data may be shared.
- Our mailing application provider, Dotmailer Limited, based in London Bridge, England. We work with Dotmailer to send you marketing and support emails.
- Service providers or data processors that handle your personal data on our instructions, for example cloud services.
- Other sites in the Traffic Label group including, but not limited to, OnlineBingo(.co.uk), for customer analysis, insights and cross-brand promotions.
- Our advertising partners for marketing campaign analysis and performance reviews. This helps us to show you only the content that interests you most.
- Our analytics service providers (such as Google, PushCrew and Facebook), who process personal data for their own purposes as Data Controllers.
- If we are under a duty to disclose to comply with a legal obligation or protect our interests or security.
- A purchaser or prospective purchaser of all or part of our assets or our business, and their professional advisers, in connection with the purchase.
- Regulators and government authorities in connection with our compliance procedures and obligations.
6. Non-personal information
Non-personal Information is non-identifiable information cannot be used to identify or contact you when considered alone. This stops us from knowing the identity of the user from which the non-personal information was collected.
We use non-personal information for reasons including advertising, service improvements, detecting and preventing fraudulent behaviour, statistical analysis and web analytics.
Types of Non-personal Information we collect about you
Technical information about the software and hardware you use to visit our site in order to provide you with a better experience when you visit. This can include:
- Device manufacturer & model
- Type of browser
- Operating system
- Language preferences
- Network provider
Anonymous gameplay information for non-logged in users to monitor marketing campaign performance and to detect fraudulent activity affecting First Class Slots or one of our operator partners.
Analytics information that we collect about your use of our services including pages viewed, time spent on site, clicks and other related activity. This helps us to troubleshoot common errors, review the user experience and provide better insights for our operator partners.
Please note that if we combine personal information with non-personal information or anonymous information, the combined information will be treated as personal information for as long as it remains combined.
7. Marketing communications
We will use your personal data, such as your email address and telephone number, to send you marketing communications relevant to gambling services, promotions and products.
In most cases, we will use our legitimate interests as the lawful basis for processing your data for direct marketing cases, unless we are legally required to seek your explicit consent.
We will only send you communications that we believe are of most interest and relevance to you, based on the personal information we hold. You have the right to decline the receipt of marketing promotions from us at any time; simply contact email@example.com.
Consent to third party promotions
As outlined above, our marketing communications will often promote the products and services from our third-party advertising partners, where their privacy policies allow for such promotion, see section 4.
In these situations, our communication will retain First Class Slots branding, but the content will focus on the specific offer or service from the third-party(ies) in question.
Where possible, we screen against third-party suppression lists to ensure you only receive promotions from brands you from which you have not withdrawn consent.
Please note that First Class Slots is not responsible for the privacy practices or the content of these third party sites. We advise our users to check individual terms and conditions/privacy policies where appropriate.
Behaviour monitoring & profiling
We use automated decision tools provided by our email service provider (Dotdigital) to segment our database according to certain actions or inaction of our users.
This can include:
- Whether or not you opened a particular email
- Whether or not you clicked a particular email
- Your tendency to interact with emails of a particular theme
8. International transfers
Personal Information collected by us may be stored and processed in any country where our advertising partners, subsidiaries, suppliers or agents are located. We may also need to transfer data (including Personal Information) to other Traffic Label companies for the supply of our services.
If this happens, all information will be managed according to and subject to all relevant national, European and international data protection and privacy laws and regulations, including the UK Data Protection Act and the EU General Data Protection Regulations. You hereby consent to transfer of your Personal Information to countries outside the European Union.
9. How long do we keep your data?
We will retain your personal data for as long as reasonably necessary for the purposes listed in Section 4 of this Policy.
In some circumstances, we keep your personal data during a certain period to meet for example legal, tax or accounting requirements.
We maintain a data retention policy for personal data in our care. Where your personal data is no longer required we will ensure it is either securely deleted or made anonymous.
10. Data security
All of the information that you provide and we collect about you is stored on secure servers, but you should understand that transmission of online data is not always completely secure.
We cannot guarantee full protection and security data, only that we take all reasonable action to protect information sent to us electronically. Transmission of any data by you is at your own risk.
Where applicable you may be given access to sections of our site that require a username and password. You are responsible for the safety, appropriateness and confidentiality of any usernames or passwords created at First Class Slots.
Please remember that any information you share in the form of comments on our news article and site review pages will be publicly available. We advise that you exercise caution when deciding to disclose your personal information in these places.
Any information collected will not have any identifying data. It is statistical data about our visitors and how they have used our site. No personal details will be shared that could identify you.
We may assemble information about your common Internet use with a cookie file. When used, the cookies are downloaded to your computer automatically. The cookie is stored on the hard drive, with transferred information. The data sought by the cookie helps us improve our website and any service offered to you.
Your browser has the ability to decline cookies via your browser’s options. Note: if you do decline the download of cookies, some aspects of our site may not work or allow you access, including our ability to track your cashback.
Our advertisers may download cookies to which we have no control. If used, these cookies are downloaded by clicking on an advertisement found on our website.
12. Your rights
An an EU citizen, you have a number of rights under the General Data Protection Regulation, which came into place on 25th May 2018. Some of these apply at any time, but some may only apply in certain circumstances.
Access to personal data
You have a right to request a copy of the personal information that we hold about you.
Correction of personal data
You can contact us to check and correct any personal data that we are processing about you which you think is incorrect.
Right to withdraw consent
Where we have relied upon your consent to process your personal data, you have the right to withdraw that consent.
Right of erasure
You can ask us to erase your personal data where there is no legal reason or legitimate interest in keeping it.
Right to data portability
You can request a copy of the information you have provided us and the right to ask that your personal data is transferred by us directly to the another organisation. For security reasons, we will only do this if it is technically possible.
Right to restrict processing of personal data
In some circumstances you have the right to request that we suspend our processing of your personal data.
Right to object to processing of personal data
You have the right to object to our use of your personal data which is processed on the basis of our legitimate interests. We will still be allowed to keep your personal data to meet our legitimate interests and regulatory obligations.
Rights relating to automated decision making and profiling
You have the right not to be subject to a decision which is based solely on an automated process. We do not currently make any decisions about any customer in this way, but if this changes, we will write to tell you.
The services offered by First Class Slots are not designed or directed to persons under the age of 18 or persons under the age of legal consent with respect to the use of the Services of any jurisdiction in which the individual resides, whichever is higher (“Legally of Age”). If you are not Legally of Age, you should not download or use the Services nor provide any Personal Information to us.
We reserve the right to access and verify any personal information collected from you. In the event that we become aware that a user who is not Legally of Age has shared any information, we may discard such information. If you have any reason to believe that a minor has shared any information with us, please contact us at firstname.lastname@example.org.
This will be done either by contacting you using the details you’ve given us, or via our sites. At this point, you’ll be required to confirm that you’ve read and accepted the changes before you can continue to use our sites, products or services.
If, for any reason, we don’t or can’t confirm your acceptance of the changes, but you continue to use our sites, products or services, we’re allowed to believe that you have accepted the changes.
All activity undertaken prior to the notification and acceptance of the change will be governed by the terms in place at the time that activity was undertaken.
If you have any concerns or questions about how we use your data, you should stop using our sites, products and services and contact us for more information.
15. Contacting Us
The Brand Owner details are as follow:
Name: Traffic Label
Last updated: June 2020
This privacy statement demonstrates our commitment to your privacy and security and forms part of the First Class Slots General Terms & Conditions.