GVC Privacy Notice
GVC takes your privacy seriously where we deal with your personal information. This means information that may be used to identify you, including, but not limited to, first and last name, date of birth, home or other physical address, email address, phone number, photograph or other contact information or data that can be linked with such information in order to identify you directly or indirectly (“information”).
This Privacy notice (the “Notice”) sets out the basis on which any of your information will be collected, stored and used by us and reflects our commitment to maintain the confidentiality of your information and to provide all our customers with the best possible service.
References to “GVC“, “us“, “we“, “our” in this Notice mean GVC Holdings PLC with registered address at 32 Athol Street, Douglas, Isle of Man IM1 1JB.
You have the right to object to us using, sharing or carrying out any activity with your personal information (in certain circumstances) including using your personal information for direct marketing (i.e. receiving emails from us notifying you about other products which we think will be of interest to you or being contacted with varying potential opportunities). Contact us at any time with the details provided in the contact section below for more details and to exercise this right where applicable.
1. WHAT INFORMATION DOES GVC COLLECT?
Information you give us directly
- You give us information about you when you contact us or otherwise interact with us, including via e-mail, letter, phone or chat function.
- You give us information about you when you register for our investor alert service. Information including your name and contact details.
- You give us information about you when you like, post, apply for a job or otherwise interact with our social media pages such as Facebook, Twitter, LinkedIn, Glassdoor and Kununu. This is generally the contents of your public profile and any messages or comments posted or sent to us by you.
- You give us information about you when you register and apply for vacancies on the careers section of our website. Information including your full name, username, password, contact details, current and preferred salary, correspondence preferences, resume, place of residence, eligibility to work, cover letter, references, transcripts and other academic related information.
Information we collect from other parties
- We may collect information about you from our other group companies for internal reasons, primarily for business and operational purposes. We only use this information in line with the privacy notice and privacy commitments of the relevant group company we have collected your information from.
- We collect information on you from individuals who you provide as references when you make an application on our careers page. This is generally a description of the relationship between you and the referee along with any merits (or demerits) in relation to you as concerns your job application.
Where you provide us information about another person, you confirm that you have informed them of our identity and the purposes for which their information will be processed and that you have obtained their consent to such processing.
Information we collect automatically
- When you interact with our services, our servers keep an activity log unique to you that collects certain administrative and traffic information including source IP address, time of access, date of access, web page(s) visited, language use, software crash reports and type of browser used.
2. HOW DOES GVC USE MY INFORMATION?
We may use your information for the following purposes:
To provide a requested service or carry out a contract with you
- To carry out our obligations arising from any contracts we enter into with you.
- To provide you with the information, products and services that you request from us.
- To provide you with recruitment and career services, where you register and make applications for a job on our career page. This includes matching your skills, experience and education with the roles we have on offer and communicating to you the progress on your applications.
- To provide you with service messages, including messages requesting your feedback on our services and notifying you about changes to our website, services or changes to our terms, conditions and policies.
Where we have your consent
- To contact you, including by email, SMS and telephone to provide you with direct marketing communications, including press releases, financial results, other key shareholder messages and job alerts. We will only do this in line with your preferences and you can opt-out of receiving such communications at any time.
- To share your contact details, including name, email address, contact telephone number and account status with selected media partners and affiliates for the purposes of them being able to offer their own marketing services to you. We only do this where we have your consent and in line with your marketing preferences. You can opt-out of this at any time.
Where we have a legitimate Interest
- To provide you with information about goods or services we feel may interest you, where these goods and services are similar to those which were the subject of a previous sale or negotiations of a sale with you. We will only contact you by electronic means (e-mail or SMS). You are able to object to receiving such communications at any time.
- To provide support services to you.
- To investigate and address enquiries, questions and complaints and respond to any feedback.
- To develop and improve our website to enhance your experience.
- To improve the quality of the services we provide.
- To ensure effective operational management and internal administration of our business, document retention, compliance with regulatory guidance and exercise or defence of legal claims.
- To have our product services team contact you were you have indicated an interest in our products.
- To monitor, record, store and use any telephone, email or other communication with you in order to check any instructions given to us, for training purposes, for crime prevention and to improve the quality of our customer service. We will clearly notify you prior to any such recording.
Where we have a legal obligation
- To protect, investigate and deter against fraudulent, unauthorised or illegal activity. Including undertaking necessary security and identifying verification checks.
Where we rely on legitimate interest as a ground for processing your information, we carry out a ‘balancing test’ to ensure that our processing is necessary and that your fundamental rights of privacy are not outweighed by our legitimate interests, before we go ahead with such processing. We keep a record of these balancing tests. You have a right to the information contained in these balancing tests on request, and can find out more by contacting us using the details below.
3. DOES GVC SHARE MY INFORMATION?
We share your information in the following circumstances:
- We share your information with our other group companies for internal reasons, primarily for business and operational purposes in line with this Notice.
- We share your information where we engage the services of trusted third-party suppliers to provide technical support, and to maintain your account with us, such as analytics and search engine providers that assist us in the improvement and optimisation of our site. We share your information with trusted third-party suppliers of information verification services (including credit reference agencies) for the purposes of validating the information you provide to us in the course of interacting with us or entering into a contract with us.
- We share your information with trusted third-party suppliers of email distribution services (which includes MailChimp) for the purposes of sending you investor alerts in accordance with your preferences.
- As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or merges with us your information will be disclosed to such entity. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information may be considered an asset of ours and as such it is possible they will be transferred to third parties.
We take steps to ensure that our arrangements with third-party suppliers (including online vendors) protect your privacy. We do not sell, rent or exchange your information with any third party for commercial reasons.
4. HOW LONG DOES GVC KEEP MY INFORMATION?
When determining the relevant retention periods for your information, we will take into account factors including:
- our contractual obligations and rights in relation to the information involved;
- legal obligation(s) under applicable law to retain data for a certain period of time;
- our legitimate interests where we have carried out balancing tests (see section on ‘How does GVC use my information above);
- statute of limitations under applicable law(s);
- (potential) disputes; and
- guidelines issued by relevant data protection authorities.
Otherwise, we securely erase your information once this is no longer needed.
5. INTERNATIONAL TRANSFERS
As with any multinational organisation, we are often required to transfer data internationally. Accordingly, data about you may be transferred globally (if your data is collected within the European Economic Area, this means that your data may be transferred outside of it).
Where your personal information is transferred to a country or territory outside the European Economic Area, and where this is to a country that is not subject to an adequacy decision approved by the EU Commission, We will take steps with the aim of ensuring that the privacy of your information continue to be protected. For example, by using third party’s Processor Binding Corporate Rules, Intra-group privacy agreements, EU Commission approved standard contractual clauses or verifying that third parties are certified under an approved certification mechanism according to international privacy rules.
We only use Analytical/performance Cookies on our website. These Cookies help us understand how you interact with our website, by providing information about the areas visited, the time spent on the website, and any issues encountered, such as error messages. This helps us improve the performance of our website.
You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but, if you prefer, you can usually modify your browser setting to decline cookies. The Help menu on the menu bar of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie and how to disable cookies altogether. If you choose to decline cookies, you may not be able to experience all of the interactive features on Our Site.
To configure Our cookies and those of third parties, users can go to:
- Google Chrome: Tools → Settings → Show advanced settings → Content settings → Cookies → Block third-party cookies and site data.
- Mozilla Firefox: Tools → Options → Privacy → History→ Use custom settings for history (uncheck all boxes).
- Internet Explorer: Tools → Internet Options → Privacy → Settings for the Internet Zone (move the navigation bar up to “Block al l cookies”).
- Safari: Settings → Preferences → Privacy → Block cookies (select “always”)
- Safari (IOS): Settings → Safari → Block cookies
7. HOW DOES GVC KEEP MY INFORMATION SECURE?
- Secure Firewalled Datacentres;
- Certified Encrypted Webpages; and
- ISO27001:2013 certified business practices.
8. WHAT ARE MY PRIVACY RIGHTS?
- The right to object to processing. You have the right to object to certain types of processing, including processing for direct marketing (i.e. receiving emails from us notifying you about other products or job openings which we think will be of interest to you or being contacted with varying potential opportunities).
- The right to be informed. You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Notice.
- The right of access. You have the right to obtain access to your information (if we’re processing it), and certain other information (similar to that provided in this Notice). This is so you’re aware and can check that we’re using your information in accordance with data protection law.
- The right to rectification. You are entitled to have your information corrected if it is inaccurate or incomplete. You can request that we rectify any errors in information that we hold.
- The right to erasure. This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there is no compelling reason for us to keep using it. This is not a general right to erasure, there are exceptions.
- The right to restrict processing. You have rights to ‘block’ or supress further use of your information. When processing is restricted, we can still store your information, but will not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in the future.
- The right to data portability. You have rights to obtain and reuse your information for your own purposes across different services. This is not a general right however and there are exceptions.
- The right to lodge a complaint. You have the right to lodge a complaint about the way we handle or process your information with your national data protection regulator. See contact us section below.
- The right to withdraw consent. If you have given your consent to anything we do with your information, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your information with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your information for marketing purposes.
9. PROTECTION OF CHILDREN
10. CHANGES TO OUR PRIVACY NOTICE
11. CONTACT US
If you have any questions, or wish to exercise any of your rights, please contact us by one of the following means:
By email: email@example.com
By post: GVC Holdings PLC, 32 Athol Street, Douglas, Isle of Man IM1 1JB
Group Data Protection Officer
Name: Nicola Mckilligan-Regan
By post: Data protection Officer, 32 Athol Street, Douglas, Isle of Man IM1 1JB
By email: firstname.lastname@example.org
If you are not satisfied with our response to a complaint you have made, or think we are not complying with data protection law, you can make a complaint to the Isle of Man Information Commissioner:
Address: First Floor, Prospect House, Prospect Hill, Douglas, Isle of Man, IM1 1ET