By using any of the features or services you find on ThePOGG.com you are agreeing to all of the below.
ThePOGG.com Ltd, a company incorporated under the laws of the United Kingdom, (company no SC507011) whose registered office is at PO BOX 2089, Livingston, West Lothian, Scotland, EH54 0GF.
Non-personally identifiable information and traffic analysis
ThePOGG.com Ltd strives to make our website as user friendly as possible, and easy to find on the internet. ThePOGG.com Ltd collects data on how You use the site which does not identify You personally. This includes information such as but not restricted to: the pages you browse through; websites that directed You to Us; keywords You used to find Us in search engines; Your IP address; cookies, and other information. The non-identifiable data is analysed manually by members of the ThePOGG.com Ltd team in order to make the Website as user-friendly and as optimised as possible.
Personally identifiable information
You provide this data to us on a voluntary basis in the process of setting up an account and using our Dispute Mediation service. This information is needed to give You access to certain parts of Our Website and appropriately manage any complaint you submit. This data is collected when You:
– Register a membership account with ThePOGG.com
– Voluntarily provide it when using the Website or our email
– Personally disclose the information in public areas of the Website
– Provide it when You contact our customer support team
The information can include but is not restricted to Your username both for our service and other services, Your name, date of birth, email address, residential address, billing address, Your communications with the operator that are relevant to your complaint issue, phone number, social media account details, government issued identity documents, proof of identity cards, utility bills, bank or payment account statements or other payment information. Where you submit a complaint to this service any personal information provide to this service will be used solely for the management of your complaint and will never be used for marketing purposes. Only the approved team members responsible for the management of complaints have access to any information you submit. This does not apply to your email address if you choose to opt into our mailing list when registering your complaint.
Where you submit a complaint to this service you are providing explicit consent for this service to share any personal information you have provided to us with the operator you are complaining about, any 3rd party companies that we in our sole discretion deem relevant to the complaint management process including but not restricted to platform providers and software providers, any regulatory agencies that are responsible for any of the aforementioned companies and any appropriate law enforcement agencies. You also provide explicit permission for any of these parties to share any personal information they may have relating to you or your account with this service.
Where you submit a complaint you are providing the operator you are complaining about, any 3rd party companies that we in our sole discretion deem relevant to the complaint management process including but not restricted to platform providers and software providers and any applicable regulatory agencies explicit permission to share any personal information related to yourself with this service.
You have the right to revoke this permission at any time by sending an email to [email protected] with the subject line ‘Consent withdrawn’. You should be aware that if you withdraw your permission to discuss your account your complaint will by default be found in favour of the operator.
ThePOGG.com Ltd will provide Your personal data to the relevant or legal authorities if it is required to.
You have the right to request access to Your personal data and/or have the right to correct and/or erase incorrect data.
In the event that ThePOGG.com Ltd is taken over by another company user information will be transferred to the new owners. Prior to this happening, an email will be sent to our email mailing list informing you of the take over and offering you the option to remove your details from our database. Failure to respond to this email will be deemed to be declining this option. If you are not registered with our mailing list you will not receive this communication.
All account information is password protected at both the user end and the administrative end.
ThePOGG.com cannot guarantee the accuracy of the information found on this site and it is considered the obligation of the user to ensure all relevant details are still accurate before they act upon them.
How do we use your information?
The information you provide us during the course of managing your complaint can be used in a variety of ways all of which relate solely to the management of your complaint. The primary uses are detailed below. This list is not exhaustive:
- Your name, casino username and email address – This information is used to help identify your account with the operator. Your email address is also used to communicate to you updates related to the progress of your complaint. Your email address will only be used for marketing purposes if you specifically agree to sign-up to our mailing list at the time of registering a complaint, or if you do so separately using the mailing list registration form found on site. Our mailing list information is kept on a separate database to that used for the complaint management system.
- Your communication with the operator – This is used to establish the specifics of what has been said between the involved parties when. This allows our team to construct a timeline of events to assist with the management of your complaint.
- ID and Proof of Address – We may at various stages request that you send ID or proof of address documents directly to the operator while copying us in on the email. Where we do this we are looking to verify receipt of documents so that we can confirm that there’s no technical reason that the operator should not have received your documents. We may also request that you forward on ID or proof of address documents submitted previously to the operator directly to us. In this circumstance concerns will have been raised about the integrity of the documentation submitted and the information you communication will be use to verify or refute these concerns.
- Payment information and bank or payment account statements – Where a payment is contest (claimed to have been made by one party and the other party contests that they have not been received) we may ask you to provide a bank or payment account statement. This is to allow for the identification of a transaction, conformation that the transaction has been processed to the correct details and subsequent investigation of missing transactions. We may also ask for payment information to ensure the operator has the correct details before a transaction is made.
Given the individual nature of each complaint the above list is NOT complete, but intended to provide a overview of why we would ask for varying types of personal information and how we would use this information when you provide it.
All activities we take in reviewing your complaints are intended to be help you gain an independent opinion on the validity of your claim. We cannot do that without sharing various personal information about you with the operator you are complaining about and, depending on the nature of your complaint, various other 3rd parties including platform providers, software providers, regulatory agencies and law enforcement agencies.
As our service cannot perform our stated function without sharing the personal information you provide to us with 3rd parties the Lawful Basis for the processing of your information is as follows:
6(1)(b) – Contract: Processing is necessary for the performance of a contract with the data subject or to take steps to enter into a contract
Nevertheless, we consider your consent absolutely critical to the performance of this service. As such you will be asked to provide explicit consent to discuss your details with various parties at the relevant stages throughout the complaint process in line with the secondary Lawful Basis for processing your information:(a) Consent: the individual has given clear consent for you to process their personal data for a specific purpose.
6(1)(a) – Consent: the individual has given clear consent for you to process their personal data for a specific purpose.
You will also be given the option to withdraw you consent at any point. If you withdraw your consent this will terminate our involvement in your complaint and result in either a ‘Resolved’ or ‘Found for the Casino’ status for the resulting report depending on the circumstances under which you terminate your permission.
Personal information communicated to us with your complaint submission (your Name, username at the gambling operator and email address at the gambling operator) is retained for a period of 5 years from the date of submission of your complaint. After 5 years your data including any information you may have emailed to us, is automatically deleted. We retain data for easy reference if you experience further issues related to your complaint.
Any other information relating to your claim – for example email communications and other files that make up supporting evidence – will be retained for 5 years and automatically deleted after this point. However, at the request of either party or at our own discretion we may delete these files at any point before the 5 year period is up. To ensure transparency users should be aware that as a standard we will ordinarily delete any information related to a claim that we feel is of a sensitive nature to either party at the same time that the claim in question is closed. This is to ensure that the secure data of all involved parties is protected and not held unnecessarily after it has ceased being of any use to our complaint management process.
We take every effort to ensure your data is both stored securely and managed responsibly. Our current security protocols include:
– Dual layered password protecting on all files stored on our servers related to your complaint. Only team members responsible for the management of complaints have access to these files.
– An encrypted database to ensure any programmers engaged for this site cannot access your data.
– Auto-deletion of both the personal information you submit with your complaint alongside and any emails you send to us during the complaint process after 5 years.
However if you believe your data has been mis-used by this service you should submit a complaint to the ICO.