1. Introduction
This Privacy Policy sets out how Napoleons Casino Doncaster collects, uses, stores, shares and protects personal data relating to individuals who interact with the company, including registered account holders, visitors to the premises and users of any digital services operated by the company. This document is issued in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
By using the services of Napoleons Casino Doncaster or by providing personal information to the company, you acknowledge that your data will be processed as described in this policy. If you do not agree with any part of this policy, you should not use the services of Napoleons Casino Doncaster.
This policy may be updated from time to time to reflect changes in law, regulatory guidance or internal practices. The current version of this policy is the operative version. Periodic review of this document is recommended.
2. Data Controller
Napoleons Casino Doncaster is the data controller responsible for the personal data held about you. As data controller, Napoleons Casino Doncaster determines the purposes and means by which your personal data is processed.
Questions about this policy or requests to exercise data protection rights should be directed to the contact details set out in Section 9.
3. Personal Data Collected
Depending on the nature of interaction with Napoleons Casino Doncaster, the following categories of personal data may be collected and processed:
- Identity data: full name, date of birth, gender and government-issued identification documents required for age verification and Know Your Customer (KYC) compliance.
- Contact data: postal address, email address and telephone number.
- Account data: username, account history, transaction records and account preferences.
- Financial data: payment details and records of deposits and withdrawals, collected and processed for the purpose of completing transactions and meeting anti-money laundering (AML) obligations.
- Technical data: IP address, browser type, device identifiers and session data where applicable to digital services.
- Geolocation data: where relevant to verifying location for regulatory compliance purposes.
- Compliance and due diligence data: information collected as part of legal obligations under gambling regulation, including source of funds documentation and responsible gambling assessments.
- Communications data: records of correspondence between you and the team of Napoleons Casino Doncaster, including support interactions.
Special category data (such as health or biometric data) is not collected unless specifically required by law or with your explicit consent.
4. Lawful Bases and Use of Personal Data
Personal data is processed on the following lawful bases:
- Contractual necessity: to open and manage your account, process transactions and provide the services requested by you.
- Legal obligation: to comply with requirements imposed by the UK Gambling Commission, the Financial Conduct Authority, anti-money laundering legislation and data protection law.
- Legitimate interests: to detect and prevent fraud, conduct internal audits, maintain the security of systems and improve operational processes, provided that these interests are not overridden by your rights.
- Consent: where explicit consent has been given, for example in relation to certain marketing communications. Consent may be withdrawn at any time without affecting the lawfulness of processing carried out before withdrawal.
Personal data is not used for automated decision-making that produces legal or similarly significant effects without human review, except where permitted by law.
5. Anti-Money Laundering and Regulatory Compliance
As a licensed gambling operator, Napoleons Casino Doncaster is subject to obligations under the Proceeds of Crime Act 2002, the Money Laundering Regulations and guidance issued by the UK Gambling Commission. These obligations require verification of identity, monitoring of account activity and, in certain circumstances, the reporting of information to relevant authorities.
Processing for these purposes is carried out under legal obligation and cannot be restricted or erased at your request while those obligations remain in force.
6. Data Sharing and Third Parties
Personal data may be shared with third parties in the following circumstances:
- Regulatory and law enforcement authorities: where required by law or a court order, including the UK Gambling Commission, HMRC and the police.
- Identity verification and fraud prevention services: third-party providers used to carry out KYC checks and screen against sanctions lists.
- Payment processors: to facilitate deposits and withdrawals in accordance with your instructions.
- IT and security service providers: entities that support the operation and security of systems under contractual data processing agreements.
- Professional advisers: including legal, audit and compliance advisers, where necessary.
Personal data is not sold to third parties for commercial purposes.
Where personal data is transferred outside the United Kingdom, appropriate safeguards are applied in accordance with UK GDPR requirements, including adequacy decisions or standard contractual clauses.
7. Data Retention
Personal data is retained only for as long as necessary to fulfil the purposes for which it was collected or as required by law.
Purpose - Retention Period
Account records and transaction history - Minimum 5 years from account closure
AML and KYC documentation - Minimum 5 years from the end of the business relationship
Responsible gambling records - Duration of account plus applicable legal period
Support and communications records - Up to 3 years from the date of interaction
Where a legal dispute arises, relevant data may be retained for longer than the standard periods set out above, until the matter is resolved.
8. Your Data Protection Rights
Under UK GDPR, you have the following rights in relation to your personal data:
- Right of access: to request a copy of the personal data held about you.
- Right to rectification: to request correction of inaccurate or incomplete data.
- Right to erasure: to request deletion of your data where it is no longer necessary for the purposes for which it was collected, subject to legal retention obligations.
- Right to restriction: to request restriction of processing in certain circumstances.
- Right to data portability: to request that your data is provided in a structured, commonly used and machine-readable format where processing is based on consent or contract.
- Right to object: to object to processing based on legitimate interests, including direct marketing.
To exercise any of these rights, contact Napoleons Casino Doncaster using the details in Section 9. A response will be provided within one calendar month of receiving a valid request. Verification of identity may be required before a request is processed.
If you are not satisfied with the response received, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection matters. The ICO can be contacted at ico.org.uk or by telephone on 0303 123 1113.
9. Contact Details
For questions about this Privacy Policy, to exercise data protection rights or to raise a concern about the handling of your data, contact:
Napoleons Casino Doncaster
Data Protection Enquiries
[Contact address and email to be inserted by the operator]
All requests and complaints will be handled in accordance with the internal data subject request procedure and within the timeframes required by UK GDPR.
10. Cookies and Tracking Technologies
Where digital services are operated, cookies and similar tracking technologies may be used to support the functioning of those services, analyse usage patterns and meet security requirements. A separate Cookie Policy, where applicable, provides further detail on the types of cookies used and how to manage preferences.
11. Changes to This Policy
This Privacy Policy may be amended at any time. Where changes are material, reasonable steps will be taken to notify users. Continued use of the services of Napoleons Casino Doncaster following any update constitutes acceptance of the revised policy. The date of the most recent revision will be indicated at the top or bottom of this document.