Our Commitment to Our Players’ Privacy. We are the owner and operator of the website located at www.starsaffiliateclub.com (the “Site”). We are committed to maintaining the confidentiality of the personal information collected by us, utilising ‘best in class’ information security technology and procedures, all in accordance with European Union standards of data protection and the requirements of the applicable regulatory authority for data protection.
Our Legal Obligations. We will comply with the terms of the Isle of Man’s Data Protection Act 2002 (as may be amended or updated from time to time) (the “Act”) when processing your personal information. Your personal information may be also processed or transferred by us to other members of or our group of companies, our affiliates, our agents and third parties providing services to us, in jurisdictions outside of the Isle of Man and the European Economic Area. In this event, we will comply with the terms of the Act which ensure that personal data is only transferred to such jurisdictions which comply with the various ‘adequacy’ requirements for data protection set out in the Act.
3. Conditions: We will process your personal information for a variety of reasons, each of which is prescribed by relevant data protection laws.
Our processing of your personal information will primarily be necessary for the purpose of carrying out administrative functions using your information as well as to assist with the affiliate services you provide to us. We may ask for your consent to processing personal information in a discreet manner; in this instance, your personal information will be processed in accordance with such consent and you will be able to withdraw this consent in writing at any time. By way of example, your consent will be needed in order to send you marketing and promotional communications.
Fulfilment of a contract, compliance with a legal obligation
It may also be necessary for us to process your personal information where it is necessary for the performance of a contract (such as you entering into the Stars Affiliate Club Program or in order for us to comply with our various legal and/or regulatory responsibilities, including, but not limited to, complying with the conditions of our gambling licences and complying with any anti-money laundering legislation.
Finally, we may also process your personal information where we deem such processing to be in our legitimate interests and provided always that such processing will not prejudice your interests, rights and freedoms. Examples of us processing in accordance with legitimate interests would include: (i) where we disclose your personal information to companies in our Group following a restructure or for internal administrative purposes; (ii) where we identify certain companies that can offer you additional benefits to our services or provide us with valuable information about your use of our Service; (iii) processing for the purposes of ensuring network and information security, including preventing unauthorised access to our electronic communications network; and (iv) adhering to regulatory and statutory requirements.
4. Specific Disclosures. We may disclose your personal information as follows:
5. General Disclosures: In addition to the specific examples of disclosures listed above, we may disclose your personal information to our employees, employees of other companies in our Group, our agents and to third party service providers who use your personal information to provide services to us.
8. What Can You Do? You should also play your part in protecting your personal information. Your login information is confidential and you are obliged to keep your password secret and confidential at all times and to use your best efforts to protect its secrecy and confidentiality.
9. Legally Required Disclosures. Due to the legal, regulatory and security environment in which we operate, we may be required, under certain circumstances, to disclose personally identifiable information about members of the Stars Affiliate Club Program and we may not be permitted to inform you that we have done so. We will use reasonable endeavours to limit such disclosure to the following: (a) where we believe in good faith that we are required to do so in response to a subpoena, warrant or other legal process or obligation upon us; or (b) where reasonably necessary to identify, contact or bring legal action against persons or entities to preserve and/or enforce our rights. Further, we can, and you authorise us to, disclose your, name, date of birth, street address, city, county, post code, country, phone number, email, account activity, transactions and communications, to our third party agents or official government bodies as we, in our sole discretion, believe necessary or appropriate in connection with an investigation of money-laundering, fraud, intellectual property infringement, piracy or other unlawful activity or activity that may expose us to legal liability.
10. Group Marketing. We may use your email address and phone number for the purpose of providing you with news, promotions and other marketing offers from us. If you no longer wish to receive these promotional communications, newsletters and marketing offers, you may opt-out of receiving them either when you register with us initially, or subsequently by following the ‘opt-out’ instructions included in each communication. You are also, in addition, entitled at any time to notify us that you do not wish to receive any promotional communications from us and you may do this by emailing us at here.
11. Third Party Offers of Goods and Services. Where you have provided us with your consent to do so, we may also share your email address and phone number with third parties so that they may send you offers of their goods and services. You may request at any time not to receive such offers by sending a blank message with the word ‘Remove’ in the subject area to Support. If you request not to receive these offers, we will remove your details from our marketing distribution lists and from any future lists we may share with our marketing partners. However, you will need to unsubscribe separately from marketing communications sent by partners who have received your contact details from us prior to your request to be removed from these lists.
12. Right to request information about you. We aim to keep our information about you as accurate as possible. You can contact us at any time to review, change, obtain a copy of your information or have your details altered or corrected in accordance with your rights under the Act. In this event, we may require evidence of and be satisfied as to your identity before we take any requested action. To contact us, so as to exercise any of your rights as set out in this Clause 12, please e-mail Stars Affiliate Club. We may, in certain circumstances, levy a small charge to cover the cost of administration regarding any request made by you in this regard or deal with your query in accordance with the Act.
13. Additional Rights. You have the following rights in relation to your personal data:
If you are unsure about your rights or are concerned about how your personal information may be processed, you should contact the Isle of Man Information Commissioner (details set out in clause 14 below). If you contact us in relation to your rights, we will do our best to accommodate your request or objection. Please note, however, that not all rights are absolute.
14. Cookies are text-only strings of information that are downloaded to your personal desktop, laptop computer or mobile device (each a “Device”) when you visit a website. They are then sent back to the originating website on each subsequent visit, or to another website that recognises those cookies. Please see: www.allaboutcookies.org for information about what cookies are and what they do.
15. We are happy to provide you with further information on how we protect and use your personal information. Please contact Stars Affiliate Club. You can also obtain much useful information on data protection and privacy from the office of the Isle of Man Information Commissioner www.inforights.im .