Privacy and Cookie Policy

IMPORTANT NOTICE: below is the full privacy policy for DipStakes Limited. Some elements of the privacy policy will only become relevant after DipStakes Limited obtains an operator licence from the UK Gambling Commission. If you have any uncertainty about which sections apply to you today, stop using our website until you have contacted DipStakes using the details at the bottom of this page and received clarification about your query (or queries).

DipStakes Limited Privacy Policy

Version: 1.1

Document summary

The policy provides information and guidance to users of DipStakes about the personal data we collect from you (or personal data that you provide to DipStakes) and how it will be processed by us.

Is it important that as a user of DipStakes, you clearly understand our use of your personal data. By visiting our website, you are accepting and consenting to the practices described within this policy. DipStakes Limited (DipStakes) is a data controller for the information that is gathered about/from you through the DipStakes website. As a note, throughout this document there may be reference to the “company”, “we”, “us” and/or “our” – each of these refers to DipStakes.

We have a designated data protection officer (aka DPO). As such, any questions you have about this privacy policy should be directed to our DPO. They can be contacted by post using the address at the bottom of this page.

Information we collect about you

Data about you that we will collect and process is as follows:

Information that you give us. This is the data about you, that you provide DipStakes, by way of filling in our forms and/or corresponding with us by phone, email, or any other method. For example, the information provided when you register to use our site, make deposits, place stakes (i.e. bets) or make withdrawals. Accepting promotions and other use of our website are further examples of where you will likely provide DipStakes with information about yourself. Key to DipStakes meeting its social and regularly requirements is making sure we know our customers properly. Knowing our customers often requires due diligence documentation to be submitted (for example, filling out a source of wealth questionnaire). We will collect and process this data. Reporting a problem and/or complaint will also create data about you that is collected and processed. The information commonly shared throughout all of these examples may include your name, date of birth, address, identification number(s), financial information, username, personal description, proof of identification, proof of funds, proof of address and photograph(s). In instances where you make deposits through the DipStakes website using electronic identification methods, you are also providing us with the personal information contained within such an electronic identification system (for the purpose of carrying out account functionality).
Information we collect about you. This is in respect of each of your visits to our site – the following information will automatically be collected:
- Technical information. This includes the IP (internet protocol) address you used to connect your device (computer, smartphone etc), your browser type and version, login information, time zone, operating systems, platform and browser plug-in types.
- Information specific to your visit. This includes pages your visiting and/or events you placed stakes on, full URL (uniform resource locators) and information about how you interacted with pages of our website.
- Information received from cookies. Specific information about cookies will be provided as per the Cookie Notice upon visiting our site. The cookie notice provides further information on the types of cookies we use.
- Information received during the course of delivering services to you. We work with a number of third party data processes, an example being business partners and delivery partners related to payment/payment processing and marketing (such as email marketing providers and direct mail distributors). These examples of partners are not exhaustive, further patterns could include due diligence companies, search information providers and credit reference agencies. This category of data also includes information we receive from our Publishers, Advertisers and other Partners that we work with to help us deliver personalised content and advertisements to you and to also recognise you across devices (and browsers). This may include pseudonymous advertiser identifiers that some advertisers or other third party ad platforms choose to share with us. Data processors process personal data according to our written instructions and their activities will be limited to those that are needed from them to assist us deliver the service to you.

There are times, dictated by law or under the terms of the agreement DipStakes has with you, where DipStakes must collect personal data about you. In such instance, if you are unwilling and/or unable to provide the data requested, it is possible that DipStakes will be unable to complete the contract we have (or are making attempt to have with you). One such example is when creating an account with DipStakes. If you are not able to verify your identity, DipStakes cannot allow an account to be made. In such an instances, there is the possibility that DipStakes will have to decline or close your account.

Information we hold about you

Personal information (or personal data) means any and all information about an individual from which a person can be identified. This means data where identity has been removed, i.e. anonymous data, is not included in this definition.

Personal information that is collected and processed about you can be categorised in the following way:

Marketing and communications data. This includes your preferences related to your communication preferences. Additionally this data relates to what marketing you would like to receive from DipStakes and our third parties.
Identity data. This can be name information, such as first name, last name, maiden name, username and/or similar identified. It also includes, martial status, title, date of birth, gender, employment status, occupation, passport number/document, identification number/document, and/or, drivers licence number/document.
Financial data. This can be details about your wealth, salary, payment card, payment account, bank account and/or source of funds (used to make a deposit with DipStakes). It can also include information such as bank statements, payslips and other equivalent/related documentation collected for know your customer purposes.
Technical data. This includes information such as your login data, browser type (and version), location, time zone, internet protocol address (aka IP address), browser plug-ins (and versions), operating system and other technology on the devices in which you access the DipStakes website.
Contact data. This includes telephone numbers (landline and/or mobile), residential address and email address.
Transaction data. This includes data about your bets and details of the events/markets you have entered through DipStakes. It also includes data about your deposits and withdrawals.
Usage data. This includes information about how you use/interact with our products/services and also the DipStakes website. It also includes your username and password (encrypted), events entered, login/logout times, duration of time spent on the website, responsible gaming and anti-money laundering classification and also any bonuses and promotions claimed.

To meet our legal obligations as an operator of a UK gambling licence (if/when an operating licence is issued), we are required to collect certain special categories of your personal data. This includes data relating to any governmental or political positions you may hold, any problem gambling admissions (or behaviour) and also any offences and/or criminal convictions.

Our purpose of collecting and holding your data

Of the information you give us, we will use the information to:

Fulfil our obligations. These are obligations arising from the terms and conditions agreed between you and DipStakes, and to provide you with gambling products/services you ask from from DipStakes. Providing you with gambling products/services includes accepting deposits from you, handling withdrawals, completing fraud check/management processes, answering questions from you, handling complaints you may have and also related situations related to the core services DipStakes provides you.
Marketing and promotions. Marketing and promotional activities that are aligned for our interested (that are reasonably valid given the agreement you and DipStakes enter into). This considers and/or includes:

- Customised advertising (including push notifications) based on the data gathered as described in this policy.
- Customised and general information about DipStakes promotions, bonuses and our services. This includes past, present and future offerings by DipStakes.
- As a DipStakes customer, we will contact you about promotions, services and/or products by electronic means, direct mail and/or by phone. Electronic means corresponds to SMS and emails.
- The above points are dependent on the preferences you have communicated to DipStakes - including the methods by which you will be contacted.
- It is important to note that DipStakes uses a number of third party providers to deliver its services to customers. As such, you should be aware that any data gathered and held by DipStakes may be shared with a third party supplier. The data shared will only be data necessary for the correct function of the product and/or service provided by the third party.
- Your personal data will be used for marketing/promotional reasons throughout the time you have a relationship with us. That is, unless you have informed DipStakes of a preference not to be contacted. We may also contact you for a sensible time following the ending of our relationship – again, unless you have communicated a wish not to be contacted. Post-relationship contact would be to notify you of promotions, offers, products and services which DipStakes believes could be of interest to you.

Notification of changes. This relates to changes to DipStakes services.
Content presentation. This relates to making sure that content from the DipStakes website is shown in the most effective manner based on your device and your preferences.
Regulatory and legal obligations. This relates to DipStakes meeting its obligations as per anti-money laundering legislation, and the associated rules/regulations. It also relates to all other laws DipStakes may be required to meet.
Personalisation. This relates to DipStakes personalising the information and content you see on our website (as per your preferences).
Internal activities: administration. This relates to data admin, research, troubleshooting, testing and surveys. Normally the information required for these areas will be gathered by way of Cookies.
Internal actives: fraud and risk management. This relates to allocating you a risk profile and/or a risk status for your account.
Internal activities: behaviour monitoring. This relates to evaluating your patterns and behaviour through using our site. This information will contribute to creating a detailed customer profile about you. Your customer profile will include (but is not limited to) the following areas:

- Transaction history, in order to make sure we are supporting responsible gambling. This is to ensure that your gambling with DipStakes remains fun and does not develop into a problem/become a danger to you. Your account might have a score assigned to it which reflects how responsible your gambling is. As a result of this, there is the possibility you will be categories as a high risk of gambling addiction or a problem gambler.
- Bonus abuse, in order to maintain a database of customers who have abused bonuses. Customers on this list may not be eligible for future offers/bonuses/promotions, and in severe cases, customers may be excluded from using DipStakes services entirely.
- Anti-money laundering (AML) and counter terrorist financing (CTF). Your personal data may be analysed and compared to third party data sources in order for DipStakes to create an AML and CTF profile about you. An associated risk score for your account may be assigned. DipStakes will keep a database of customers with a high risk score relating to AML and CTF.

Website improvements. This relates to making sure that the information and content shown on our website is shown in the most appropriate way based on your preferences and device (e.g. smartphone or computer).
Interactive features. This relates to collecting of data so you can utilise interactive parts of our services. This part can directly support our efforts to keep our site safe and secure.
Advertising performance. This relates to DipStakes evaluating the efficiency of the advertising we show our users.
Product information. This relates to providing you with suggestions/recommendations about DipStakes products/services.
Aggregated data. This relates to DipStakes gathering and sharing aggregated data. Examples of which are demographic information. While aggregated data could be derived from your personal data, it is not considered personal data as per the laws of the UK. The reason for this is that the data does not identify you (either directly or indirectly). If there are instances where we bring together or connect aggregated data with personal data about you, the personal data will be handled as per this privacy policy.
Other data sources. This relates to information we received from other sources that is combined with data provided by you to us, and also that we collect about you. This information (and any resulting combination) will be used as per the purposes detailed in this section. Other data sources can include third party service providers of identity verification, address verification, age verification, databases of problem gamblers, PEP (politically exposed person)/sanction searches, regulators and/or related providers with whom DipStakes may work on occasion.

Your user account

All of the information that DipStakes holds relating to you (regardless of whether it is provided by yourself or a third party) will be gathered under one user profile.

Lawful justification for personal data processing

The table below shows a description of the different ways DipStakes intends to use your personal information. For each activity, there is also the legal justification for why such data processing is required and information relating to the category of data the information pertains to.

Privacy policy information summary table part 1

Privacy policy information summary table part 2

Disclosure of your information

You consent that DipStakes has the right to share your personal data/information with:

Any member of DipStakes that needs access to your personal information in order to provide the services requested by you.
Third parties, who are under a data processing agreement with DipStakes in order to ensure your personal data is safeguarded. These third parties include:
- Gambling software suppliers who may deliver gambling software on our website and who require such information to permit you to participate in events/markets.
- To advertisers/advertising networks that need data to choose and share relevant adverts with you (including promotional emails, SMS, calls and direct mail). This does not apply if you have unsubscribed to such contact in your preferences.
- Search engine providers, business intelligence providers/partners and analytics partners that help DipStakes in the optimisation and improvement of our website.
- Credit reference agencies. These are used for the purpose of assessing your credit score. Assessing your credit score may be required as a condition of DipStakes entering into a contract with you.
- Suppliers that verify your age and identity. This also extends to other suppliers that can verify known client information.
- Our banks and/or payment service providers (including payment gateways). This is in order to be able to complete payment instructions to you.
- Our consultants, lawyers and advisors. These may be engaged at any time to provide advice on any matter which may require these third parties to gain access to personal data/information.
- Any regulatory authority, governmental body, non-governmental organisation, company and/or person that keeps and updates a register of problem gamblers (or any other purpose to support responsible gambling).
- Any regulatory authority, governmental body, non-governmental organisation, company and/or person that keeps and updates a database and/or register that has the goal of preventing money laundering, preventing terrorist financing, preventing crime and preventing proliferation financing.
- Should DipStakes accept to transfer our business relating to some or all of our operations, your personal information will be disclosed to a prospective buyer or their legal representatives, financial advisers, consultants and/or their employees as part of the due diligence process and also as part of the transfer process.
Under commitment to provide your personal information to comply with any legal obligation. Or, to enforce/apply our terms and conditions and other agreements. Or, to preserve our safety, rights and/or property. This extends to the exchange of information/data with other organisations and companies with the aim of credit risk reduction and fraud protection.

Where we store your personal data

Primarily, the data we collect from you will be stored on servers in the UK. It should be noted, that the information/data we gather from you, will be transferred to third parties as covered in this policy. This data, will, as a consequence, be stored by them. Some of the third parties that DipStakes shares information with, may locate their servers outside of the UK and outside of the European Economic Area (EEA). It is reasonable to expect that the data will be processed by companies (and their staff) that operate outside of the EAA, who either work for DipStakes or one of our suppliers. This includes but is not limited to staff who are involved in the delivery of your order, i.e. processing of your payment information. By way of providing your personal information, you consent to this transfer, processing and/or storing of data. DipStakes will take appropriate steps to make sure your data is treated securely and in line with this privacy policy, and, that the party we are sharing information with, use similar measures as DipStakes relating to personal information. If personal information is to be transferred outside of the EEA, DipStakes will look to take further measures – for example, entering into an EU compliant data transfer agreement with the data importer (where necessary).
The information you provide DipStakes will be stored on secure servers.
Payment transactions will be encrypted using SSL (secure sockets layer) technology.
It should be noted that the transmission of information via the internet can never be considered completely secure. DipStakes will do its best to protect your personal data, but we cannot guarantee the security of your data transmitted to our site. As such, any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Your rights

The data protection laws in the UK provide you with rights (under certain circumstances). These rights are:

The right to access personal information held about you. By logging into your DipStakes account you will be able to see some of the data held about you. You can access additional information by contacting DipStakes using the details at the bottom of this page. DipStakes will meet any just access request. Should your request require a disproportionate level of work, we reserve the right (while adhering to UK law) to charge a fee to you for the work required to complete your request.
The right to request your personal data is corrected. This right means you are able to ensure incomplete and/or inaccurate information about you can be updated and corrected. As a note, corrected information may require verification that you are providing accurate data.
The right to request your personal data is erased. This means you can ask DipStakes to delete any data/information that we hold about you. Importantly, data which is relevant to the purpose in which we collect it, may not be deleted following your request. This right ensures you can request the removal/deletion of personal data we may hold for which there is no good reason for DipStakes continuing to process it. You are also able to request the deletion of all of your personal data, which may lead to DipStakes asking you to close your account. As a licensed gambling operator, and a UK business, there are legal obligations which may prevent us from deleting some (or all) of the data we hold about you at the time of your request. An example of relevant obligations is anti-money laundering. Regardless, DipStakes will handle your request as soon as practicably possible whenever any data retention period elapses.
The right to object to the processing of your personal data. This gives you the right to object to the processing (by DipStakes) of personal information, where we are following a legitimate interest, or those of a third party, and there is something related to your situation which means you would like to object to processing (based on the above logic) as you feel that it has consequence on your fundamental freedoms and rights. Additionally, you have the right to object in instances DipStakes is processing your personal data for direct marketing purposes (based on legitimate interest). Furthermore, you can object to DipStakes showing you targeted adverts on our website. In this instance, the number of adverts won’t be reduced but the relevance to you will be decreased. There may be instances where we demonstrate that we have compelling legitimate grounds to processes your information which override your rights and freedoms.
The right to request restriction of processing your personal data. This means you can ask DipStakes to halt the processing of your personal information in these scenarios:
- You have objected to DipStakes’ use of your information but we need to confirm if there is overriding legitimate grounds to use the data, or
- You want us to confirm the accuracy of the data, or
- You challenge whether DipStakes’ use of your personal data is lawful.
The right to request the transfer of your personal information i.e. a data portability request. This right means you can ask for your personal information. As a result, we will issue you your personal information in a machine-readable format. This right applies only to the data which you initially provided consent for DipStakes to use, or, where DipStakes used the information to meet the obligations of a contract with you.
The right to unsubscribe from direct marketing. This means you have the right (at any time) to change your mind in relation to DipStakes being able to contact you via direct marketing. A simple way to exercise this right is by logging into your DipStakes account and updating your preferences. It is also possible to change your presences by using the “unsubscribe” link included in the direct marketing. We aim to complete communication requests as soon as possible, however please allow up to two working days (48 hours) for requests to be fully processed. Also note, that opting out of marketing emails does not mean you won’t receive any emails from DipStakes, as we may still contact you with important service information relevant to your account.
The right to withdraw your consent. This means you have the right to take back your consent (at any time) in instances where we rely on your consent for the processing of personal information.
As a note, DipStakes will keep copies of any communication that is sent by you, to us, so that we can keep accurate records of information received from you. This includes emails.
Any and all communications with DipStakes must be made using the email address associated with your account. For data related matters (including you exercising your rights) you may contact DipStakes at any time using the contact details at the bottom of this page. If required, DipStakes will verify your identity prior to responding to any request.

How long it takes for DipStakes to respond to data requests

Our aim is to respond to all valid requests within one month (30 days). There may be instances where it takes us longer – for example if you have multiple requests pending or your request is very complicated.

Security of data

DipStakes has put into place a number of appropriate security measures to mitigate the risk of your personal information being subject to unauthorised access, use, alteration or disclosure, and also to mitigate against accidental loss. Further more, DipStakes restricts access to your personal information to employees, contractors, agents and other third parties who have a need to know based on the business being carried out. In all instances, the people/organisations who process your personal information will only do so on our instruction and subject to maintaining confidentiality. There is a process for dealing with suspected personal information breaches, and as part of this, any affected customer and any applicable regulatory body will be notified where we are legally required to do so.

Retention of data

As per UK law, we are required to maintain core information about you. This includes identity, contact, financial, transaction and KYC (know your customer) data. The information will be kept for 5 years after you close your DipStakes account, or a longer period of time if required by law of the UK.

In cases where you exercise your right to request your personal data is erased, we will erase all data possible, excluding the information in which DipStakes is required to maintain as part of our legal and regulatory obligations.

There may be instances where we anonymise your personal information. Meaning, the information can no longer for associated with you. Anonymised data for research and/or statistical purposes maybe be held and used indefinitely without further notice to yourself.

The DipStakes website uses cookies. A cookie is defined as a small file of numbers and letters that we put on your computer/device. By doing so, we are able to recognise you from other users of the DipStakes website. By doing so, we are better able to provide you with a positive experience of our website, and also, we are better able to improve our website. For more information on cookies, please see the cookie notice at the end of this policy.

Advertising on our website

There may be instances where we feature on-site advertising based on the information you have made available to DipStakes during your use of our content, site and/or services. On-site adverts, commonly called targeted or personalised adverts, are chosen based on the information gathered through cookies.

As detailed in this policy (the section covering your rights) it is possible to opt out of receiving personalised adverts. You can modify your preferences by logging into your account and adjusting the relevant settings. Additionally, it is possible to modify the settings on many of the main internet browsers to make you aware of cookies and disable cookies.

Advertisements on third party sites

We may use third parties that collect data about visitors to their websites and/or applications through their own use of cookies, web beacons and other technology related to your online pursuits. The intention of this is to gain better comprehension of your interests and to provide advertisements that are more suited to your interests. Furthermore, DipStakes may purchase advertising space on third party websites and as such, our adverts may show when the third party deems that our advert is aligned with your interested (as per the data they collected).

DipStakes does not issue personal data to advertisers or third party sites that showcase our personalised adverts, however, such entities could have obtained personal data about you via the use of data analytics (e.g. Google Analytics) and/or their own site (e.g. articles read), and as such, these third parties my customise advertising material published on their site based on your interests.

Third party advertisers (or advertising companies working on their behalf) may, on occasion, utilise technology to serve our advertisements. These may automatically receive your IP address when this happens. Cookies can also be used to track the impact of their advertisements and to personalise the advertising content you see.

DipStakes does not have control and/or access to the features (such as cookies) that advertisers and/or third party sites use – and the information policy/practices of these advertisers and third party websites are not covered by this Policy. Contact should be made directly with these entities about their policies, procedures and practices.

Updates and alterations to our privacy policy

From time to time, DipStakes may seek to update/alter our privacy policy. Any changes will be reflected in the policy available on our website and our customers will be notified by email as to changes. We encourage all our customers to check our policies frequently to keep up to date with any changes. If you do not agree with the changes made to our privacy policy, please contact our customer support team via the contact us part of the DipStakes website. Alternatively, you may choose to close your account.

Our cookie notice

How to control cookies

It is possible to manage cookie settings through your internet browser settings. For difficulties, please consult the “help” section of your preferred browser, as this will provide you with the best chance of sourcing correct information about settings. For devices such as smartphones and tables, reading of the device’s user guides/help may be the most effective way to manage cookies. Some providers of browsers issue useful cookie guides. Additionally, the website “www.allaboutcookies.org" is a useful resource for cookie information.

Cookie Classification

There are four types of cookies used by DipStakes. These are as follows:

Functionality cookies. These cookies are used to remember the choices you make on our website. For example, language, user name and the region you are located. What this means is that you can be delivered a more personalised website experience. Functionality cookies can also recall modifications you make to fonts, text size and other items on the website (that can be customised). Functional cookies can also be used for services you have requested – including posting comments and watching videos. Functional cookie information can also be anonymised. As a final note, functional cookies aren’t able to track you browsing activity on other sites.
Performance cookies. These cookies are used to gather information about how a customer uses our website. This can include if the user gets an error message and how a user utilises the website. Performance cookies do not gather data that can identify a visitor – as all the information these cookies generate is aggregated and as a result, anonymous.
Strictly necessary cookies. These cookies are a vital requirement for facilitating your journey around the DipStakes website and use the site’s features. For example, gaining access to secure parts of the site. As such, by preventing these cookies it may make some content and/or functionality of the website unavailable.
Targeting (advertising) cookies. These cookies are used to record the events you have entered, the pages you have visited, your habits on the website and the financial transactions you make. As a result, these cookies are used to bring advertisements that are more aligned to your interests and behaviour. Such cookies can also be used to limit number of instances you see an advertisement, in addition to helping assess the effectiveness of an advertising campaign. DipStakes may also share this data with third parties for this cause (and hence assist DipStakes with analytics).

Third party cookies

Third party cookies include (but are not limited to) suppliers of external services such as website traffic analysis and advertising networks. It is important to note that third parties can use cookies, of which DipStakes has zero control. Such cookies are expected to be performance cookies and/or targeting cookies.

An example of a third party website that may use cookies on our website is a platform that auctions a car that DipStakes features. As such, is it possible you will receive a cookie from such a third party if you were to visit their website to gather more information about the vehicle being sold.

Another example of a third party website that may use cookies are those linked to the “Share” features, in that you share DipStakes content beyond our site, for example, via social media. These sites may issue you cookies.

DipStakes does not have any control over these cookies, so we urge you to familiarise yourself with privacy and cookie information for the relevant third party site.

Cookies called “session” and “persistent” are commonly used to understand the behaviour of website users. Session cookies are temporary as they are relevant to the session you are having on a website. Once you exit the site and/or close the browser, the session cookie is no more. In contrast persistent cookies remain on a device and becomes reactivated when that user returns to the website which generated the cookie in the first instance. Persistent cookies can be removed manually and/or will expire after a set time period (as per the cookie file). DipStakes uses both session and persistent cookies.

Contact

If you have have any queries, comments or questions relating to this policy, you can contact DipStakes using the information at the bottom of the this page.

Alternatively, you can send a letter to:

Popeshead Court Offices,

Peter Lane,

York,

North Yorkshire,

YO1 8SU