PRIVACY POLICY

eCOGRA Limited (“eCOGRA”, “we”, “us”, or “our”) is committed to protecting and respecting your privacy. This Privacy Policy explains when and why we collect personal data from individuals, how we use it, the conditions under which we may disclose it to others, how we keep it secure and provides information regarding the rights of individuals.

Personal data is defined as any information relating to an identified or identifiable living/ natural person (“data subject”) that is not already in the public domain. eCOGRA will process any personal data provided to us whether obtained via the eCOGRA self-regulatory services, newsletter subscription, testing agency services or any other means, or otherwise held by us relating to you in the manner set out in this Privacy Policy or as otherwise stated at the point of collection.

Personal Data We Collect

When collecting and using personal data, our policy is to be transparent about why and how we process personal data. eCOGRA will only process personal data to the extent that at least one of the following applies:

• the data subject has given consent to the processing of his or her personal data for one or more specific purposes;
• processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
• processing is necessary for compliance with a legal obligation to which eCOGRA is subject;
• processing is necessary in order to protect the vital interests of the data subject or of another natural person;
• processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in eCOGRA; and
• processing is necessary for the purposes of the legitimate interests pursued by eCOGRA or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

Through your interaction with eCOGRA lines of business, eCOGRA may collect personal data that identifies an individual or relates to an identifiable individual.

• Dispute Resolution Services

• By submitting a dispute to eCOGRA we collect and process personal data. This may or may not include a player’s name, surname, address, contact number, email address, identification document, utility bills and other information that is necessary for adequately investigating the dispute.

• eCOGRA Newsletters

• Through subscribing to eCOGRA news, we obtain a subscriber’s name, email address and role in the industry.

• Testing Agency and Self-Regulatory Services

• In performing our testing services, we may review or process personal data such as an individual’s name, surname, email address, identification number, phone number and other information that is necessary for adequately performing our testing services.

• Prospective Employees

• When individuals apply to work for us, we may collect and process personal data in terms of our Human Resources policies and procedures. Personal data may include an individual’s name, surname, address, contact number, email address, identification document, utility bills, references and other information that is necessary to perform the recruitment process and define the contractual obligations with the prospective employee.

Purpose for Collection

eCOGRA will only use your personal data for the purpose for which it was collected, unless we obtain your specific consent to other uses, or unless otherwise required or permitted by law or professional standards:

• Dispute Resolution Services

• eCOGRA obtains personal data of players through the various dispute forms on the eCOGRA Website to enable us to handle any disputes you may have with a Great Britain Gambling Commission licence holder or eCOGRA approved seal holder.

• eCOGRA Newsletter

• eCOGRA may send you press releases and other marketing information relating to new eCOGRA clients, new eGAP seal holders, updates to self-regulatory requirements, eCOGRA’s achievements, the achievements of our client’s where eCOGRA has been involved, new executive level staff, and new services offered by eCOGRA.
• While eCOGRA has performed an exercise to obtain informed consent from our stakeholders for sending email press releases and other marketing information, each correspondence will contain an easy means to opt out of further communication. Opting out of receiving marketing communication does not opt the individual out of further correspondence with an eCOGRA representative based on the services we offer to the client organisation.

• Testing Agency and Self- Regulatory Services

• In order to fulfil our contractual and legal obligations as a provider of self-regulation services and Testing Agency we may review or process personal data in order to effectively perform our testing.

• Prospective Employees

• We only obtain and process personal data of prospective employees in accordance with our Human Resources policies and procedures and to fulfil staffing requirements.

Sharing of Personal Data

eCOGRA will not sell, rent or share your personal data with third parties. However, eCOGRA may disclose your personal data to meet legal obligations, regulations, or valid governmental requests.

Personal Data Security

The security of your personal data is very important to eCOGRA. We use industry-standard methods and mechanisms, such as firewalls, encryption, intrusion monitoring, and passwords to protect electronic information. Multiple physical security methods, such as locking devices and 24-hour premise monitoring, are also employed. Access to personal data is limited and on a need-to-know basis.

Retention and Storage of Personal Data

We review our retention periods for personal data on a regular basis. We are legally required to hold certain types of information to fulfil our statutory obligations (for example licensing conditions). We will hold your personal data on our systems for as long as is necessary for the relevant activity, or as long as is set out in any relevant contract you hold with us.

Personal data is stored on servers located in South Africa and is processed and secured as per the South African Protection of Personal Information Act (POPI). Personal data is also backed up to servers in Dublin and the Netherlands.

Your rights as a Data Subject

At any point whilst eCOGRA is in possession of or processing your personal data, all data subjects have the following rights:

• Right of access – you have the right to request a copy of the information that we hold about you;
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete;
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records. Where there are valid grounds to do so, you have the right to withdraw consent by emailing info@ecogra.org;
• Right to restriction of processing – where certain conditions apply you have a right to restrict the processing of the data we hold about you;
• Right of portability – you have the right to have the data we hold about you transferred to another organisation;
• Right to object – you have the right to object to certain types of processing such as direct marketing; and
• Right to object to automated processing, including profiling – you have the right not to be subject to the legal effects of automated processing or profiling.

In the event that eCOGRA refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge.

eCOGRA, at your request, can confirm what information it holds about you and how it is processed.

Protection of Personal Information Act

Our Privacy Policy governs the way we, eCOGRA treat your personal information in accordance with The Protection of Personal Information Act, 2013 (POPIA Act) and in terms of The Promotion of Access to Information Act, 2000, which aims to promote and protect the information processed by our organisation. We process your personal information with respect and integrity with utmost confidentiality.  The Privacy Policy explains how we use, collect and share your personal information. eCOGRA is a group of entities, some of which operate in the United Kingdom, therefore report to the Information Commissioner's Office (“ICO”) (the United Kingdom’s data protection regulator). Our PAIA Manual is accessible here.

You can request the following information from eCOGRA:

• eCOGRA's contact details;
• Contact details of eCOGRA's data protection officer;
• The purpose of the processing as well as the legal basis for processing;
• If the processing is based on the legitimate interests of eCOGRA or a third party such as one of its clients, information about those interests;
• The categories of personal data collected, stored and processed;
• Recipient(s) or categories of recipients that the data is/will be disclosed to;
• How long the data will be stored;
• Details of your rights to correct, erase, restrict or object to such processing;
• Information about your right to withdraw consent at any time;
• How to lodge a complaint with the Information Commissioner's Office ("ICO") (the United Kingdom's data protection regulator);
• Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data;
• The source of personal data if it wasn’t collected directly from you; and
• Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

Complaints

If you wish to complain about our use of personal data, please send an email with the details of your complaint to info@ecogra.org. We will assess and respond to any complaints we receive within a timely manner.

You also have the right to lodge a complaint with the Information Commissioner's Office (“ICO”) (the United Kingdom’s data protection regulator). For further information on your rights and how to complain to the ICO, please refer to the ICO Website.

Changes to our Policy

eCOGRA’s Privacy Policy was last updated 29/06/2021.

We may update this Privacy Policy at any time by publishing an updated version here. So you know when we make changes to this Privacy Policy, we will amend the last updated date. The new modified or amended Privacy Policy will apply from that revision date. Therefore, we encourage you to review this Privacy Policy periodically to be informed about how we are protecting your information.

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