1. Introduction
Welcome to gold-party2.co.uk (the "Site"), the official website for the "Golden Empire 2" slot game from TaDa Gaming. Your privacy is paramount to us. We understand that as a user of an online gambling site, you are entrusting us with sensitive personal and financial information. This Privacy Policy is designed to clearly explain how we collect, use, store, and protect your personal data, demonstrating our unwavering commitment to transparency, security, and responsible operation.
We are Gold Party Gaming Ltd. ("we", "us", "our"), a company registered in the United Kingdom, and the data controller for the personal data processed on this Site. Our registered address is 14 King Street, London, EC2V 8EA, United Kingdom.
This policy is written in compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, as well as the stringent requirements set by the UK Gambling Commission (UKGC) and other relevant regulatory bodies. We aim to not only meet but exceed these standards, building a foundation of trust with you, our valued player.
2. The Data Controller
The data controller responsible for your personal data collected via this Site is:
3. What Personal Data We Collect
We collect various types of personal data to operate our Site, provide our services, and meet our legal and regulatory obligations. This data falls into the following categories:
- Identity Data: Your full name, date of birth, gender, nationality.
- Contact Data: Postal address, email address, telephone numbers.
- Financial Data: Payment card details (processed securely by third-party payment providers; we do not store full card numbers), bank account details, transaction history, deposit limits, withdrawal history.
- Account Data: Username, password, login details, account preferences, responsible gambling settings, self-exclusion history.
- Gameplay Data: Information related to your interaction with "Golden Empire 2" and other games, including:
- Betting history (bet amounts, game rounds, win/loss records).
- Game session IDs, timestamps, and duration.
- Game feature usage (e.g., activation of Free Games, Bonus Symbols, Wilds, Cascading Reels).
- Progress within games, if applicable.
- Technical game logs.
- Technical Data: 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 Site.
- Usage Data: Information about how you use our Site, services, and the "Golden Empire 2" game, including page views, navigation paths, clickstreams, and interaction with various features.
- Marketing and Communications Data: Your preferences in receiving marketing from us and our third parties, and your communication preferences.
- Verification Data (KYC/AML): Documents and information required for identity verification, age verification, source of funds checks, and anti-money laundering (AML) compliance, such as copies of passports, utility bills, or bank statements.
Special Categories of Personal Data
We do not knowingly collect any Special Categories of Personal Data (such as race, ethnicity, religious beliefs, sexual orientation, health data) unless explicitly required for specific regulatory purposes (e.g., if a health condition impacts responsible gambling, and you voluntarily provide this information).
4. How We Collect Your Data
We collect data from you through various methods:
- Direct Interactions: When you register for an account, deposit funds, play games, contact customer support, participate in promotions, or set responsible gambling limits.
- Automated Technologies or Interactions: As you interact with our Site, we automatically collect Technical Data and Usage Data using cookies, server logs, and other similar technologies (see Section 10). This includes specific gameplay data as you play "Golden Empire 2".
- Third Parties or Publicly Available Sources: We may receive personal data about you from various third parties, such as:
- Technical, payment, and delivery services providers.
- Identity verification and fraud prevention agencies.
- Gambling addiction support organisations (with your consent or where legally mandated).
- Publicly available sources (e.g., electoral roll, open-source intelligence for AML).
5. How We Use Your Personal Data and Our Legal Bases
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances and for the following purposes, relying on these legal bases under UK GDPR:
- To Register and Manage Your Account (Contractual Necessity):
- Creating and maintaining your player account.
- Verifying your identity and age (minimum 18 years old for gambling in the UK).
- Processing deposits and withdrawals.
- Providing access to "Golden Empire 2" and other games.
- Communicating with you about your account, transactions, and service updates.
- To Operate and Improve Our Services (Legitimate Interests):
- Allowing you to play "Golden Empire 2" and track your gameplay, bets, and winnings.
- Analysing gameplay patterns and user behaviour to enhance game features, site functionality, and user experience.
- Troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data.
- Ensuring the fairness and integrity of our games, including "Golden Empire 2", and detecting fraudulent activity.
- For Security and Fraud Prevention (Legal Obligation & Legitimate Interests):
- Detecting, preventing, and investigating fraud, money laundering, and other criminal activities.
- Protecting the security and integrity of our Site and your account.
- Complying with our anti-money laundering (AML) and Know Your Customer (KYC) obligations.
- For Responsible Gambling (Legal Obligation & Public Interest):
- Monitoring your gambling activity for signs of potential problem gambling.
- Implementing and enforcing responsible gambling tools (e.g., deposit limits, loss limits, self-exclusion).
- Referring you to support organisations if appropriate and with your consent, or as required by law.
- Complying with UKGC requirements regarding player protection.
- For Marketing and Promotions (Consent or Legitimate Interests):
- Sending you promotional offers, bonuses, and updates about "Golden Empire 2" or other games, where you have consented or where we have a legitimate interest and you haven't opted out.
- Personalising content and offers based on your gameplay and preferences.
- To Comply with Legal and Regulatory Obligations (Legal Obligation):
- Responding to requests from law enforcement, regulators (e.g., UKGC), or other government bodies.
- Maintaining records as required by law.
- Complying with tax and accounting requirements.
- For Business Operations (Legitimate Interests):
- Managing our relationship with you.
- Administering and protecting our business and this Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
- In the event of a merger, acquisition, or sale of assets, your data may be transferred to the new entity.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.
6. Data Sharing and Disclosure
We may share your personal data with the following categories of recipients:
- Game Providers: TaDa Gaming (developer of "Golden Empire 2") and other game providers to allow you to play their games, facilitate gameplay, and ensure fair play.
- Payment Processors: Third-party payment service providers to process your deposits and withdrawals securely. We do not store your full payment card details.
- Regulators and Law Enforcement: The UK Gambling Commission (UKGC), other gambling authorities, police, and other regulatory or governmental bodies, where legally required or to assist in investigations.
- Fraud Prevention and Identity Verification Agencies: To verify your identity, age, and prevent fraud and money laundering.
- Responsible Gambling Organisations: With your consent, or where legally mandated, to support responsible gambling initiatives (e.g., GamStop, BeGambleAware).
- IT Service Providers: Companies that provide us with IT infrastructure, software, and technical support.
- Analytics Providers: Providers like Yandex.Metrica (see Section 7) to help us understand how users interact with our Site.
- Affiliate Partners: If you arrived at our site via an affiliate link, we may share non-personally identifiable data (e.g., a unique tracking ID) with the affiliate partner for commission calculation purposes. We do not share your direct personal data for this.
- Professional Advisers: Lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.
- Business Transfers: In the event of a merger, acquisition, or sale of all or a portion of our assets, your data may be transferred to the acquiring entity.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
7. International Data Transfers (including Yandex.Metrica)
Some of our external third parties are based outside the UK and European Economic Area (EEA), so their processing of your personal data will involve a transfer of data outside the UK/EEA.
Important Notice: Yandex.Metrica
Crucially, we use Yandex.Metrica for web analytics, which involves the transfer of data to Yandex, a company based in Russia. Russia is not considered by the UK government to provide an adequate level of protection for personal data.
When we transfer your personal data outside the UK/EEA, 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 by the UK government or the European Commission.
- Where we use certain service providers, we may rely on specific contracts approved by the UK government or the European Commission (e.g., Standard Contractual Clauses) which aim to give personal data the same protection it has in the UK/EEA. For Yandex.Metrica, we rely on these contractual clauses and aim to minimise the personal data transferred, primarily focusing on aggregated and anonymised statistical data. While Yandex.Metrica is designed to collect primarily anonymised usage data, we acknowledge the inherent risks associated with data transfers to non-adequate jurisdictions.
- We continuously monitor the security practices of our data processors and strive to use privacy-enhancing technologies where feasible to protect your data during transfer.
By using our Site and services, you acknowledge and agree to the potential transfer of your data to these non-adequate countries, understanding the associated risks. If you do not wish for your data to be processed in this manner, please adjust your cookie settings (see Section 10) or refrain from using our services.
8. Data Security
We have implemented appropriate technical and organisational security measures to prevent your personal data from being accidentally lost, used, accessed in an unauthorised way, altered, or disclosed. This includes:
SSL/TLS Encryption
Access Controls
Firewall Protection
Regular Audits
Data Minimisation
Anonymisation
- Encryption: Using SSL/TLS encryption for all data transmissions between your browser and our servers.
- Access Controls: Restricting access to personal data to employees, agents, contractors, and other third parties who have a legitimate business need to know. They will only process your personal data on our instructions and are subject to a duty of confidentiality.
- Firewalls and Intrusion Detection Systems: To protect our networks from unauthorised access.
- Regular Security Audits: Conducting periodic reviews and assessments of our security practices.
- Data Minimisation: Collecting only the data necessary for our stated purposes.
- Anonymisation/Pseudonymisation: Where possible, processing data in an anonymised or pseudonymised form.
We have procedures in place 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.
9. Data Retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Specifically, in the gambling industry, we are subject to strict regulatory obligations regarding data retention for player accounts, transaction history, and responsible gambling records. This typically means we retain data for a minimum of five years after account closure or your last interaction, and in some cases longer, to comply with AML, KYC, and UKGC requirements.
10. Cookies and Tracking Technologies
Our Site uses cookies and similar tracking technologies (like web beacons and pixels) to distinguish you from other users, provide you with a good experience, and analyse site usage.
- What are cookies? Cookies are small text files placed on your device by websites that you visit. They are widely used to make websites work, or work more efficiently, as well as to provide information to the owners of the site.
- How we use cookies:
- Strictly Necessary Cookies: Essential for the operation of our Site, enabling core functions like account login, game launching, and secure transactions.
- Analytical/Performance Cookies: Allow us to recognise and count the number of visitors and see how visitors move around our Site. This helps us improve the way our Site works, for example, by ensuring users are finding what they are looking for easily. This includes Yandex.Metrica cookies, which collect anonymised data on site usage.
- Functionality Cookies: Used to recognise you when you return to our Site, enabling us to personalise our content for you, greet you by name, and remember your preferences (e.g., language or region).
- Targeting/Advertising Cookies: Record your visit to our Site, the pages you have visited, and the links you have followed. We will use this information to make our Site and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose, including for affiliate tracking.
You can manage your cookie preferences through your browser settings or via the cookie consent banner on our Site. Please note that disabling strictly necessary cookies may impact the functionality of our Site and your ability to play "Golden Empire 2".
11. Affiliate Links and Commercial Transparency
Our Site may contain links to third-party casino operators as part of affiliate marketing programs. When you click on these links and subsequently register or play at an affiliated casino, we may receive a commission.
We use cookies and other tracking technologies to identify that you were referred from our Site. This tracking typically involves non-personally identifiable identifiers (e.g., a unique ID in the link) and does not involve sharing your personal data directly with the affiliate partner beyond what is necessary to attribute the referral.
We are committed to transparency. Any content on our Site that is sponsored or contains affiliate links will be clearly disclosed in accordance with advertising standards (e.g., ASA guidelines in the UK). Our reviews and information are independent, and our primary goal is to provide accurate and helpful content about "Golden Empire 2" and related gaming experiences.
12. Your Legal Rights (UK GDPR)
Under UK GDPR, you have the following rights concerning your personal data:
Your Data Protection Rights
Right to be Informed
To be informed about how your personal data is collected and used (as per this policy).
Right of Access
To request a copy of the personal data we hold about you.
Right to Rectification
To request that we correct any inaccurate or incomplete personal data.
Right to Erasure
To request that we delete your personal data, under certain conditions. Note that due to legal and regulatory obligations (e.g., AML, responsible gambling), we may not always be able to comply with your request for erasure immediately.
Right to Restrict Processing
To request that we limit the way we use your personal data, under certain conditions.
Right to Data Portability
To receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another controller, under certain conditions.
Right to Object
To object to our processing of your personal data, under certain conditions, especially where we rely on legitimate interests.
Rights in Automated Decision-making
To object to decisions made solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, unless it is necessary for entering into, or performing, a contract, authorised by law, or based on your explicit consent. We use automated processes for fraud detection and responsible gambling monitoring.
If you wish to exercise any of these rights, please contact our Data Protection Officer at [email protected]. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
13. Children's Privacy
Age Restriction
Our services are strictly not intended for individuals under the age of 18 (the legal gambling age in the UK). We do not knowingly collect personal data from children. If we become aware that a minor has attempted to submit personal data or has registered an account, we will take steps to remove such information and terminate the account.
14. Responsible Gambling
We are committed to promoting responsible gambling and protecting our players from the risks associated with problem gambling. This is a core part of our operational culture and compliance with UKGC regulations.
We use your gameplay data and account data to:
- Monitor for patterns of play that may indicate problem gambling behaviour.
- Provide you with tools to set limits on deposits, losses, and session times.
- Facilitate self-exclusion from our Site and other UK-licensed gambling sites via GamStop.
- Direct you to independent support organisations such as BeGambleAware.org or GamCare if we identify potential risks or if you request assistance.
Your data is processed with the utmost care to ensure these measures are effective and supportive, not intrusive. We believe that a robust approach to data protection is integral to a robust approach to responsible gambling.
15. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or regulatory guidance. Any changes will be posted on this page with an updated "Last Updated" date. Where the changes are significant, we will notify you by email or through a prominent notice on our Site. We encourage you to review this policy periodically to stay informed about how we are protecting your information.
16. Contact Us
If you have any questions about this Privacy Policy or our data protection practices, please contact:
Complaints
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority 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.