Last Updated: 23rd May 2024
Welcome to the official website for Big Bass Reel Repeat (the "Site"), operated by AquaPlay Digital Ltd. (\"we,\" \"us,\" or \"our\"). This Privacy Policy explains how we collect, use, disclose, and protect your personal data when you visit our Site and play the Big Bass Reel Repeat slot game.
Your privacy and trust are paramount to us. As a licensed online gambling operator, we understand the critical importance of protecting your personal and financial information. This Privacy Policy is designed not only to comply with stringent legal and regulatory requirements but also to provide clear, transparent, and reassuring information to you, our user. We are committed to demonstrating our expertise, authoritativeness, and trustworthiness in all aspects of our operations, especially concerning data protection.
1. Who We Are (Data Controller)
The data controller responsible for your personal data collected through this Site is:
AquaPlay Digital Ltd.
Registered Address: 12 Ocean Drive, London, SW1A 0AA, United Kingdom
Company Registration Number: 12345678
Licensed and regulated by the United Kingdom Gambling Commission (UKGC) under account number 12345.
Email: [email protected]
2. Our Commitment to Your Privacy and Trust
We recognise that choosing an online gambling site involves entrusting us with sensitive personal and financial data. We are dedicated to building and maintaining that trust by:
- Transparency: Clearly explaining what data we collect, why we collect it, and how we use it.
- Security: Implementing robust measures to protect your data from unauthorised access, loss, or misuse.
- Compliance: Adhering strictly to UK data protection laws, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, as well as specific requirements from the UK Gambling Commission (UKGC) and anti-money laundering (AML) regulations.
- Responsible Gambling: Using data to identify and support responsible gambling practices, demonstrating our care for your well-being.
- Clarity: Presenting this policy in an accessible and understandable manner, avoiding excessive legal jargon.
3. Key Definitions
- Personal Data: Any information relating to an identified or identifiable living individual.
- Processing: Any operation performed on Personal Data, such as collection, recording, storage, use, disclosure, or deletion.
- Data Controller: The entity that determines the purposes and means of processing Personal Data (that's us, AquaPlay Digital Ltd.).
- Data Processor: An entity that processes Personal Data on behalf of the Data Controller.
- UK GDPR: The General Data Protection Regulation as it forms part of the law of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018.
4. What Personal Data We Collect and How We Collect It
We collect various types of personal data to operate our Site, provide the Big Bass Reel Repeat game, and meet our legal obligations.
4.1. Data You Provide Directly
While the Big Bass Reel Repeat site itself doesn't require direct account registration for playing the demo, if you interact with us (e.g., via contact forms), you might provide:
- Contact Information: Your name, email address, and any other details you provide when contacting our customer support or sending inquiries.
4.2. Data Collected Automatically (During Site Usage & Gameplay)
When you visit our Site and play Big Bass Reel Repeat, we automatically collect certain information:
- Device and Connection Information: IP address, browser type and version, operating system, device type, screen resolution, language settings, and unique device identifiers.
- Usage Data:
- Website Interaction: Pages viewed, links clicked, time spent on pages, referral source (e.g., if you came from an affiliate link).
- Gameplay Data (for Big Bass Reel Repeat):
- Session Information: Start and end times of game sessions.
- Game Progress: Information about your interactions with the game, such as spins initiated, bet amounts (e.g., \"BET MULTIPLIER 10x\", \"TOTAL BET $1.80\"), win/loss outcomes, features triggered (e.g., \"FREE SPINS round,\" \"ANTE BET,\" \"BUY FREE SPINS\"), and choices made within the game (e.g., \"DON'T SHOW NEXT TIME\" checkbox, \"QUICK SPIN,\" \"INTRO SCREEN,\" \"AMBIENT MUSIC,\" \"SOUND FX\" toggles).
- Game Settings: Preferences you set within the game, such as spin speed, sound levels, and intro screen visibility.
- Location Data: General geographical location derived from your IP address (e.g., country, city).
- Cookies and Tracking Technologies: As detailed in Section 8, we use cookies to collect information about your browsing activities and preferences.
4.3. Data from Third Parties
We may receive limited information from third parties:
- Affiliate Partners: If you arrive at our Site via an affiliate link, we may receive information indicating which affiliate referred you. This data is typically anonymised or pseudonymised and used for commission tracking, not for identifying you personally.
- Publicly Available Sources: In some cases, we may use publicly available information to verify your identity or for fraud prevention, but this is rare for a game-specific site unless it's linked to an operator account.
5. How and Why We Use Your Personal Data (Purposes and Legal Bases)
We process your personal data for specific purposes, relying on various legal bases under the UK GDPR:
| Purpose of Processing |
Types of Data Used |
Legal Basis under UK GDPR |
| 1. To Provide and Operate the Site & Game |
Device & Connection Info, Usage Data (Gameplay, Site Interaction), Cookies. |
Legitimate Interest: To ensure the Site functions correctly and provides a seamless gaming experience. |
| 2. To Ensure Game Fairness & Integrity |
Usage Data (Gameplay history, spin outcomes), Device & Connection Info. |
Legal Obligation: To comply with UKGC licensing conditions requiring fair and transparent gaming. Legitimate Interest: To protect our business from fraud and ensure trust in our games. |
| 3. For Site Analytics & Performance Improvement |
Device & Connection Info, Usage Data (Site Interaction, limited Gameplay data), Cookies (Yandex.Metrica). |
Legitimate Interest: To understand how users interact with our Site and game, identify areas for improvement, and optimise user experience. Where consent is required for analytics cookies, we rely on Consent. |
| 4. To Comply with Legal & Regulatory Obligations |
Device & Connection Info, Usage Data (potentially), Contact Information (if provided). This may include reporting to the UKGC or other authorities. |
Legal Obligation: To adhere to laws such as the UK Gambling Act 2005, AML regulations, and data protection laws. |
| 5. For Security & Fraud Prevention |
Device & Connection Info (IP addresses), Usage Data (unusual patterns). |
Legitimate Interest: To protect our systems and users from malicious activity, fraud, and unauthorised access. Legal Obligation: To maintain a secure operating environment as required by regulators. |
| 6. To Respond to Your Inquiries |
Contact Information (name, email), content of your message. |
Legitimate Interest: To provide effective customer support and address user queries. Contract: If your inquiry relates to an existing or prospective contract. |
| 7. For Affiliate Program Tracking |
Limited pseudonymised data (e.g., unique tracking IDs, referral source) from affiliate partners. |
Legitimate Interest: To manage and track our affiliate marketing efforts and ensure accurate commission payments. This processing does not involve direct personal identification by us in this context. |
| 8. To Monitor for Responsible Gambling |
Usage Data (Gameplay: bet amounts, session duration, frequency of play, changes in play patterns), Device & Connection Info. |
Legal Obligation: To comply with UKGC requirements to identify and interact with customers who may be at risk of gambling-related harm. Vital Interest: In extreme cases, to protect the vital interests of an individual. |
| 9. For Internal Auditing & Business Reporting |
Aggregated and anonymised Usage Data, general Site statistics. |
Legitimate Interest: To analyse business performance, conduct internal audits, and improve our overall operations. This typically involves non-personal or highly anonymised data. |
6. How We Share Your Personal Data
We may share your personal data with third parties in the following circumstances:
- Game Providers: We share necessary gameplay data with Reel Kingdom, the developer of Big Bass Reel Repeat, to ensure the game functions correctly, for technical support, and to verify game integrity.
- Service Providers: We engage third-party companies and individuals to facilitate our services (e.g., hosting providers, IT support, security services). These providers only process data on our behalf and are bound by strict contractual obligations to keep your data secure and confidential.
- Analytics Providers: As detailed in Section 7, we share data with Yandex.Metrica for web analytics.
- Regulators and Law Enforcement: We may disclose your data if legally required to do so by the UKGC, other regulatory bodies, law enforcement agencies, or in response to a valid court order or subpoena.
- Fraud Prevention & Security: We may share data with third-party services dedicated to fraud prevention and cybersecurity to protect our Site and users.
- Affiliate Partners: We may share anonymised or pseudonymised data (e.g., conversion tracking IDs) with our affiliate partners to track referrals and manage commissions. This does not involve sharing your directly identifiable personal data.
- Business Transfers: In the event of a merger, acquisition, or sale of all or a portion of our assets, your personal data may be transferred to the acquiring entity. We will ensure appropriate safeguards are in place.
We do not sell your personal data to third parties for their marketing purposes.
7. International Data Transfers (Including Yandex.Metrica)
Your personal data may be transferred to, and stored at, a destination outside the UK or the European Economic Area (EEA). This section specifically addresses the use of Yandex.Metrica.
Yandex.Metrica
- Purpose: We use Yandex.Metrica, a web analytics service provided by Yandex LLC, to analyse user behaviour on our Site, understand traffic sources, and improve the overall user experience and performance of Big Bass Reel Repeat. This helps us make data-driven decisions to enhance the game and the Site.
- Data Transferred: Yandex.Metrica collects information such as your IP address (anonymised), device information, browser type, pages visited, and interactions with the Site.
- Transfer Destination: Yandex LLC is based in Russia.
- UK GDPR Implications: The UK (and EU) currently does not have an adequacy decision with Russia, meaning that Russia is not deemed to provide an equivalent level of data protection to the UK GDPR. This means that data transferred to Russia does not benefit from the same level of legal protection as it would within the UK/EEA.
- Our Safeguards:
- Anonymisation: We configure Yandex.Metrica to anonymise your IP address as much as possible before it is processed.
- Contractual Clauses: We strive to include robust data protection clauses in our agreements with Yandex to ensure they commit to protecting your data.
- Transparency & Choice: We are transparent about this transfer in our Privacy Policy and provide mechanisms for you to manage your consent to analytics cookies (see Section 8).
- Your Awareness: By using our Site and accepting analytics cookies, you acknowledge and accept that your data may be transferred to Russia for web analytics purposes, despite the lack of an adequacy decision. We continuously monitor the legal landscape and available safeguards to ensure the best possible protection for your data.
For more information about Yandex.Metrica's privacy practices, please refer to Yandex's Privacy Policy.
8. Cookies and Other Tracking Technologies
We use cookies and similar tracking technologies to enhance your experience on our Site. Cookies are small text files placed on your device.
- Essential Cookies: These are strictly necessary for the operation of our Site and game (e.g., to remember your game session, ensure security). You cannot opt out of these.
- Analytics Cookies (Yandex.Metrica): These help us understand how you interact with our Site, measure performance, and identify areas for improvement. As explained in Section 7, this involves data transfer to Russia.
- Affiliate/Marketing Cookies: These cookies track if you arrived at our Site via an affiliate link, allowing us to attribute referrals and pay commissions. They do not track your personal activities beyond the referral.
Managing Your Cookies:
When you first visit our Site, you will be presented with a cookie consent banner, allowing you to accept or decline non-essential cookies. You can also manage your cookie preferences at any time through your browser settings. Be aware that disabling certain cookies may affect the functionality of the Site.
9. Data Security
We implement appropriate technical and organisational measures to protect your personal data from unauthorised access, alteration, disclosure, or destruction. These measures include:
- Encryption: Using SSL/TLS encryption for data in transit.
- Access Controls: Restricting access to personal data to authorised personnel only, based on a need-to-know basis.
- Firewalls and Intrusion Detection Systems: To protect our network infrastructure.
- Regular Security Audits and Penetration Testing: To identify and address vulnerabilities.
- Staff Training: Ensuring our employees are trained on data protection best practices.
- Data Minimisation: Collecting only the data strictly necessary for our purposes.
Despite our efforts, no method of transmission over the Internet or method of electronic storage is 100% secure. We cannot guarantee absolute security.
10. Data Retention
We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including for satisfying any legal, accounting, or reporting requirements.
- Legal & Regulatory Obligations: Data related to financial transactions, responsible gambling, and AML compliance may be retained for 5-7 years, or longer if required by specific regulations (e.g., UKGC).
- Website & Gameplay Analytics: Data collected via Yandex.Metrica is typically retained for a maximum of 5 years, often in an aggregated or anonymised form.
- Customer Inquiries: We retain correspondence for a reasonable period to manage ongoing support and improve our services.
Once data is no longer required, we securely delete or anonymise it.
11. Your Data Protection Rights
Under the UK GDPR, you have the following rights regarding your personal data:
- Right to Be Informed: To receive clear, transparent, and easily understandable information about how we use your data and your rights (this Privacy 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 (\"Right to Be Forgotten\"): To request the deletion of your personal data in certain circumstances (e.g., if the data is no longer necessary for the purposes for which it was collected).
- Right to Restrict Processing: To request that we limit the way we use your personal data in certain situations.
- Right to Data Portability: To receive your personal data in a structured, commonly used, and machine-readable format, and to transmit it to another controller.
- Right to Object: To object to the processing of your personal data where we are relying on legitimate interests as our legal basis.
- Rights in Relation to Automated Decision-Making and Profiling: To not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
To exercise any of these rights, please
contact us using the details provided in Section 15. We may need to verify your identity before fulfilling your request.
12. Responsible Gambling and Your Privacy
Responsible Gambling
As a responsible gambling operator, we are committed to protecting players from gambling-related harm. Your privacy data plays a crucial role in this:
- We may analyse gameplay data (e.g., bet patterns, session duration, frequency of play, changes in spending) to identify potential indicators of problem gambling.
- This analysis helps us fulfil our Legal Obligation under UKGC regulations to identify and interact with customers who may be at risk.
- Any such monitoring is conducted with strict confidentiality and solely for the purpose of player protection.
- We will never use this data to exploit vulnerability or for predatory marketing.
If you are concerned about your gambling, or that of someone you know, please seek help from the following organisations:
- GamCare: Free and confidential support for anyone affected by problem gambling.
- Website: www.gamcare.org.uk
- National Gambling Helpline: 0808 8020 133
- GambleAware: Provides information, advice and directs people to relevant support.
- Website: www.gambleaware.org
13. Children's Privacy
Our Site and the Big Bass Reel Repeat game are strictly for individuals aged 18 or over. We do not knowingly collect personal data from anyone under the age of 18. If we become aware that we have collected personal data from a child, we will take steps to delete that information as quickly as possible.
14. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will notify you of any significant changes by posting the new Privacy Policy on this page and updating the \"Last Updated\" date at the top. We encourage you to review this Privacy Policy periodically.
15. Contact Us
16. Complaints
If you are not satisfied with our response to a privacy concern, or if you believe we are processing your personal data unlawfully, you have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK's independent authority for upholding information rights:
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