Privacy and Cookie Policy 

This policy applies to the website (www.gamban.com) and to our use of any personal data you provide to us when using the Gamban product. Please read this policy carefully as it contains important information about how we use your personal information.

1. Who are we?

In this policy, all references to “we”, “us” and “our” are to Beanstalk HPS Ltd. Our company registration number is10601657 and our registered office is located at Enterprise House, Ocean Village Marina, Southampton, Hampshire, SO14 3XB.

We are registered at the Information Commissioners Office as a data controller and our registration number isZA275059.

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

2. Your data privacy

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.

3. The information we will collect from you

In order to provide you with our Gamban product, we may need the following information from you:

• your name;
• your email address;
• your mobile phone number, if you are a business user;
• financial details, such as debit or credit card details to process your payment, where a payment is required;
• the type of computer you are using and on which Gamban will be downloaded. This is known as your operating system;
• information about your use of our website such as your IP address. This is a unique number which identifies your device and internet connection.

We will only collect and process the personal information that:

• you give to us directly; or
• is given to us by a third party you have authorised to give us information, such as an employer.

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

We do not collect or process any sensitive personal data about you. Sensitive personal data is data which relates to your racial or ethnic origin, political opinions, religious or philosophical beliefs and genetic data.

4. Why do we need this information? What will we do with this information?

We need your information for the following reasons:

To provide you with the Gamban product:To set up an account with us so we can deliver the product to you and take payment. This account also allows you to manage your user settings and provide us with updates to your personal information when circumstances change.

To keep you updated:To provide you with:

• important information regarding the product during your subscription that is relevant to the operation of the Gamban product and to deliver any helpdesk functions to you;
• 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 Gamban product will cease to operate within your operating system and access to gambling websites will return.

Without the information listed in section 3 of this policy we will not be able to provide you with the Gamban product.

We may also have a justifiable reason to hold the personal data you provide to us. For example:

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.

Conducting analysis in order to develop the Gamban product:we may conduct statistical analysis in order to better understand how Gamban is used. It is important to us that we can, where possible, improve the products and services we offer. This includes using information like the country that you are based in to offer product developments specific to your region. We also analyse whether you signed up for Gamban using a promo-code or voucher. When we undertake analysis in this way, any data is aggregated and anonymised to ensure that we cannot and do not identify individual users.

Recording calls:if we need to speak with you to resolve a problem, we may record the call for training and monitoring purposes. This helps us improve the quality of the service we provide to you.

5. Will we share your personal information with third parties?

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 Gamban product or in order to complete discussions with that company about the potential sale or transfer;
• third parties where you have expressly agreed we can share your personal information with them;and
• our trusted business partner and service providers: for example, we share limited information (user id, email, name, phone number (where provided) withZendesk 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.

In sharing your personal information with these third parties we will, as far as it is within our control, put safeguards in place to protect the security of your personal information.

6. Third party websites

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 Paymentswill 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.

7. Our use of cookies and analytics

We use cookies and other similar technologies on our website. A cookie is a small text file which is sent from our server to whatever device you use to view our site (desktop, laptop, smartphone etc.). The cookie is stored by your device and allows us to recognise it so that we can make our site easier to use. We only use these cookies where we have obtained your consent or where they are strictly necessary for the functioning of our website.

What cookies do we use?

We use Google Analytics in order for us to analyse visitor information such as browser usage and new visitor numbers. Any data collected by us is aggregated and anonymised unless we specifically have your consent for another use. You can read more about how Google Analytics workshere. For _ga_cookies specifically, you can opt-out by using an add-on, available from Googlehere.

To be clear, we always ask you for your consent to use any type of cookie other than strictly necessary cookies. You can block all cookies by activating the setting on your browser (including necessary cookies) but you may not be able to access all or parts of our site.

8. How will we communicate with you?

We may contact you:

• 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.

We may also contact you to confirm your financial details, if the details have not already been provided by you, or the details lapse or stop working. If this occurs, you will have 15 days to confirm your financial details. If you do not confirm your financial details within 15 days, your ability to use the Gamban product will come to an end.

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 unless you have expressly consented to this.

You can ask us to stop contacting you from within the Account Management function, by emailing us atinfo@gamban.com or writing to us at our registered office address detailed in section 1 of this policy.

9. Will we transfer your personal information overseas?

We do not transfer your personal information outside of the European Economic Area. We do operate a cloud based storage system (this being a remote server network hosted on the internet to process and store information) but access is restricted to within the European Economic Area and the data held on this system is at all times held behind firewalls. We also use two-factor authenticationand advanced access control to ensure your data remains secure.

10. How long will be retain your personal information?

If you download our Gamban product 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 Gamban product.

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

11. Use of our website

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.

12. Your privacy rights

We recognise that the personal information we hold about you belongs to you and it is right that you have control over that personal information. We have detailed below a summary of your legal rights.

You can:

• ask us to have access to, and for a copy of, the personal information we hold about you;
• request that we amend or delete your personal information;
• ask us to stop processing your personal data altogether or in a certain way;
• change your mind about how you have agreed we can use your personal information. If you have given us express permission to use your personal information in a specific way you can withdraw it. This means that we will stop processing your personal data in the way you have objected to from the date that your permission is withdrawn;
• issue a complaint to the appropriate authority – seewww.ico.org.uk for more information;
• request that we transfer your personal information to another provider (this is known as data portability);
• object to any automatic processing we conduct, such as automatic renewal of your subscription.

If you would like to exercise any of these rights please contact us using the contact information given in this policy.

We need to make you aware that even where you exercise a right detailed above, we may not be able to comply with that request if an exception in law applies. Where this is the case we will notify you and explain why we’re unable to meet your request.

13. Children's Privacy

We understand the importance of taking extra precautions to protect the privacy and safety of children using our product. Children under the age of 13 are not permitted to use Gamban.

We do not knowingly collect personal information from children under the age of 13. If we become aware that we have collected personal information from a child under age 13 without verification of parental consent, we will take steps to remove that information from our servers as soon as possible.