Version 2.0 Updated on 25th March 2023
Welcome to eCOGRA’s privacy notice.
eCOGRA respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to the laws that protects your privacy rights and how we look after your personal data when you visit our website (regardless of where you visit the website from).
Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
1. IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how eCOGRA collects and processes your personal data through your use of this website, including any data you may provide through this website when you submit a form, and information that eCOGRA collects during the recruitment process.
This website is not intended for children, and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
eCOGRA Limited is made up of different legal entities (“eCOGRA Group”). This privacy notice is issued on behalf of the eCOGRA Group so when we mention “eCOGRA”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the eCOGRA Group responsible for processing your data. We will let you know which entity will be the controller for your data when you purchase a product or service with us, and/or when you apply for a vacant position. eCOGRA Limited is the controller and responsible for this website.
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.
Our full details are:
Full name of legal entity: eCOGRA Limited
Data Privacy Manager
2/F Berkeley Square House,
Berkeley Square, W1J 6BD,
Our Ireland subsidiary acts as our EU Representative. You may contact us at our Irish office address:
Ormond Building, 31-36 Ormond Quay Upper, Dublin 7, Dublin, Dublin, D07 EE37, Republic of Ireland
Our South African entity details are as follows:
BUILDING 9 GROUND FLOOR, CNR ROOS S
FOURWAYS OFFICE PARK, GAUTENG,
South Africa, 2055
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 (https://ico.org.uk/ ). We would, however, appreciate the chance to assist with your concerns before you approach the ICO, please contact us first and we will gladly assist in any way we can.
We 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, Protection of Personal Information Act (POPIA) in South Africa. Our PAIA Manual is accessible here.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
This version was last updated on date stated above.
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.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, last name, username or similar identifier, job, company name, company size, city, country.
- Contact Data includes email address and telephone numbers.
- 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.
- Recruitment Data includes the information you have provided to us in your curriculum vitae and covering letter, the information you have provided on our application form, including name, title, address, telephone number, personal email address, and any other information you provide to us during an interview and the recruitment process, including but not limited to date of birth, gender, employment history, qualifications.
- Profile Data includes your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel your request or service you have with us.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity and Contact by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our products or services;
- Apply for any eCOGRA Group’s vacant position
- subscribe to our service or newsletters;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us some feedback.
Automated technologies or interactions:
As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie banner for further details.
Third parties or publicly available sources:
We may receive personal data about you from various third parties and public sources as set out below:
Technical Data from the following parties:
(a)analytics providers such as Google based outside the UK;
(b)marketing platforms such as LinkedIn, Send in Blue] based outside the UK
(c)Recruitment agencies, your named referees, and data from third parties which is publicly accessible such as Linkedin
4. HOW WE USE YOUR PERSONAL DATA
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:
- Where we need to perform the contract, we are about to enter into or have entered into with you.
- In case of recruitment, to assess your skills, qualifications, and suitability for the role, carry out reference checks, where applicable, communicate with you about the recruitment process, keep records related to our hiring processes.]
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|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 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 or Malta Gaming Authority licence holder or eCOGRA approved seal holder.
|Through subscribing to eCOGRA news, we obtain a subscriber’s name, email address and role in the industry.
|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 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
|In order to fulfil our contractual and legal obligations, to effectively perform our testing as an Inspection and Testing Body provider of Product Conformity Certification and Certifications of Information Security Management Systems and self-regulation services we may review or process personal data .
|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, references and other information that is necessary to perform the recruitment process and define the contractual obligations with the prospective employee.
|We only obtain and process personal data of prospective employees in accordance with our Human Resources policies and procedures and to fulfil staffing requirements.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you downloaded a report, entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside eCOGRA Group of companies for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.
Where you opt-out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.
eCOGRA is an equal opportunity employer. We will not discriminate and will take affirmative actions and measures to ensure against discrimination in employment, recruitment, advertisements for employment, compensation, termination, upgrading, promotions, and other conditions of employment against any employee or job applicant on the bases of race, color, gender, national origin, age, religion, creed, disability, veteran’s status, sexual orientation, gender identity or gender expression.
If you submit a resume or job application online, we will use your personal data for recruitment-related purposes, which may include contacting you via email, telephone or post. In some cases, you may be required to register on our website in order that you may track the progress of your application online. Except where you request otherwise, eCOGRA may keep your personal data on file for an appropriate time in order to consider you for other employment opportunities with eCOGRA in the future. If you are providing personal information about an individual other than yourself (such as a referred candidate), you must obtain the consent of the individual before submitting any of their personal information. It is generally not our intention to seek sensitive information (for example, data relating to race or ethnic origin, religious or other similar beliefs, political opinions, criminal record, physical or mental health or sexual life/orientation) as part of our recruitment process or recruitment related activities. However, we might gather sensitive information about you because you voluntarily provide the information to us, or we are required to collect the information as a result of legal requirements imposed on us. If we do receive any sensitive information about you, we will, where necessary, obtain your explicit consent to collect and use such information in accordance with applicable laws. Should you be hired by an eCOGRA entity, your personal information may be used in connection with the employer-employee relationship as permitted by applicable laws.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
We use the following cookies further details available on the cookie banner:
Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
CHANGE OF PURPOSE
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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
Internal Third Parties as set out in the Glossary.
External Third Parties as set out in the Glossary.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them.
If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
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.
6. INTERNATIONAL TRANSFERS
We share your personal data within the eCOGRA Group. This will involve transferring your data outside the United Kingdom (UK).
Many of our external third parties are based outside the United Kingdom so their processing of your personal data will involve a transfer of data outside the UK.
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 by the ICO. Where we use certain service providers, we may use specific contracts approved by the ICO which give personal data the same protection it has in the UK.
7. DATA SECURITY
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 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.
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.
8. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfil the purpose and intention we collected it for, including for the purpose of satisfying any legal, accounting, contractual 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 purpose for which we process your personal data and whether we can achieve that purpose through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please Contact us.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights) except as per the PAIA manual. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
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. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience.
We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by Contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
INTERNAL THIRD PARTIES
Other companies in the eCOGRA Group acting as joint controllers or processors and who are based outside the UK and provide IT and system administration services and undertake leadership reporting.
EXTERNAL THIRD PARTIES
Service providers acting as processors based inside and outside UK who provide IT and system administration services.
Service providers acting as processors based inside and outside UK who provide HR and marketing services.
YOUR LEGAL RIGHTS
You have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Should you have any further queries or comments about this Policy, kindly contact us on the details provided above.