Privacy Policy

In this policy, all references to “we”, “us” and “our” are to Gamban LTD. Our company registration number is 10601657 and our registered office is located at Enterprise House, Ocean Village Marina, Southampton, Hampshire, SO14 3XB.

We are registered at the Information Commissioner's Office as a data controller and our registration number is ZA275059.

You can request further information about how we use your personal information by writing to our registered office or by emailing our general enquiries line: info@gamban.com. You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

We keep our privacy policy under regular review. This version was last updated on 14/10/2024.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Whilst there are age restrictions in the UK around access to gambling services, we appreciate that in some instances individuals under the age of 18 may benefit from access to the Services. Notwithstanding this, the Services are not intended for use by children under the age of 13.

We take privacy of your information very seriously. It is important to us that you can be confident your personal information will be handled securely and protected at all times.

This policy explains how and why we process the personal information you provide to us. It explains in what circumstances we will pass your personal information to third parties and gives a summary of your rights.

In order to provide you with the Services, we may need the following information from you:

• Identity data: includes your name;
• Contact data: includes your email address, your phone number;
• Device data: includes information about the various devices that our blocking licence covers.
• Marketing data: your preferences with regards to receiving our newsletter.
• Profile data: includes gambling addiction status which includes level of gambling, time of last gambling session, your username
• Technical Data: includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Transaction data: includes details about payments to and from you and other details of Services that you have purchased;
• Usage Data: includes information about how you use our website, and our products

We will only collect and process the personal information that you give to us directly.

We do not seek or collect personal information about you from publicly available sources or third party databases.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our Services in order to better understand how Gamban is used.

Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

• Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience.
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

We need your information for the following reasons:

To register you as a new user of our Services, including setting up an account. Lawful basis: Performance of a contract.

To provide the Services to you, including carrying out your order, taking payment and collecting and recovering any money owed. Lawful basis: Performance of a contract.

To keep you updated and manage our relationship with you, including:

• Providing you with important information regarding the operation of the Services and to deliver any helpdesk functions to you Lawful basis: Performance of a contract,.and legitimate interests;
• Providing you with notifications, to advise you that your subscription is due to come to an end. Our systems will generate automated messages to you to flag when your subscription with us is ending so that you can determine whether or not you wish to renew your subscription. If you do not renew your subscription with us, the Services will cease to operate within your operating system and access to gambling websites will return. Lawful basis: Performance of a contract,.and legitimate interests;

To administer and protect our business and website, including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data. Lawful basis: legitimate interests and performance of a legal obligation.

To use data analytics, for example to improve our website, the Services, our customer relationships and experiences and to measure the effectiveness of our communications. Lawful basis: legitimate interests.

Keeping internal records: in order to manage our account with our customers we will need to keep internal records of the persons who have access to Gamban. This is also needed to ensure we comply with our legal obligations; Lawful basis: legal obligation.

We will only share your personal information with the following third parties in the specific circumstances outlined below:

• organisations that have specific functions stipulated by law (such as a regulatory body, a statutory body, the police or a competent authority). We will share your personal information with these bodies where we're obligated by law or regulation to disclose information to them;
• a company to whom our business is to be sold or transferred (in whole or in part). Our company may, from time to time, change ownership or control. In this case we may need to share your personal information with the new company so that they can continue to supply you with the Services or in order to complete discussions with that company about the potential sale or transfer;
• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• our trusted business partner and service providers: for example, we share limited information (user id, email, name, phone number (where provided)) with Zendesk in order to be able to provide our support representatives with accurate information about the user that is contacting them so that we can deal with the issue or query, we also use a trusted third party payment provider Braintree to process payments.

In sharing your personal information with these third parties we will, put safeguards in place to protect the security of your personal information.

Within our website you may see links to other websites owned and operated by third parties (Third Party Websites). These Third Party Websites will have their own privacy notices governing use of that site and any collection of personal data through it. If you click on any link on our website that takes you to a Third Party Website, please ensure that you read the privacy policy for that Third Party Website before continuing to use the site.

If you choose to download Gamban and a payment is required, payment will be collected by our payment provider Braintree Payments. Your use of Braintree Payments will be governed by their terms and conditions and privacy policy which can be found at:

https://www.braintreepayments.com/en-gb/legal

If you download the Gamban App, you are offered additional payment options and you can pay using Google Pay or Apple Pay, depending on the operating system you are using.

We may contact you with ‘service messages’ including:

• if you fail to complete the online registration process or download to see if we can offer you any help with this;
• to confirm you have successfully set up your account with us;
• to confirm you have successfully downloaded Gamban;
• to discuss installation if Gamban has not installed properly;
• to notify you of the expiry of a licence to use Gamban;
• to notify you of the end date of your subscription and how our automatic renewal process operates;
• to notify you of an update to the software that we have made;
• to notify you about changes to your account; and
• to remind you your subscription is ending or that it will be auto renewed.

This contact will be by email to the address you have provided.

We will not contact you to market to you any product or service save where you have consented to receiving our regular newsletters. You can withdraw this consent by clicking on the unsubscribe link, or by emailing us at info@gamban.com (from within the Account Management function).

It is sometimes necessary for us to transfer your personal data to countries outside the UK. In those cases we will comply with applicable UK laws designed to ensure the privacy of your personal data.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; or
• Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Please contact us: info@gamban.com if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We also use two-factor authentication and advanced access control to ensure your data remains secure.

If you download our Services we will retain your personal information for the duration of your subscription and for a period of one calendar year after your subscription has ended.

We have carefully selected this retention period to reflect the length of time we deem necessary to conduct the activities outlined in this policy and to comply with our legal obligations. You can change this position as outlined in section 12 below but please note this may impact upon our ability to provide you with the Services.

We retain information collected using cookies for the periods set out in section 7.

In visiting our website we collect information from you such as your IP address and other online identifiers. This is your personal information. We collect this so that we can see how you use our website and monitor traffic. To assist us in improving our website we would like to understand the behaviour of users who visit.

Transmission of data over the internet is never entirely secure. Data may be intercepted, accessed and used by third parties who are not the intended recipient of that data. Unfortunately, this interaction is outside of our control; however data security is of great importance to us and we have deployed appropriate physical and electronic security measures to safeguard your personal information.