BACKGROUND
Star Jar (IOM) Limited (“the Company”) referred to as “We” “Our” or “Us” is committed to protecting the privacy and security of your personal data. We have developed this privacy notice to inform you of the data we collect, what we do with your data, what we do to keep it secure as well as the Rights you have over your personal data.
Throughout this notice we refer to data protection legislation which includes the Isle of Man Data Protection Act 2018, the EU General Data Protection Regulation 2016 (“GDPR”) and other laws mandating data protection including (but not limited to) the e-Privacy Directive. This also includes any replacement legislation which may come into effect from time to time.
Star Jar operates the website Bodog.io in reliance to an Isle of Man licence with the Isle of Man Gambling Supervision Commission (“IOMGSC”) to provide remote Casino and gambling to end users. For the purposes of data protection, the Company is the Data Controller with regards to customer data as we have determined the purposes of why personal data should be collected and processed.
You can contact our head office using the following details:
Second Floor
14 Athol Street
Douglas
Isle of Man
IM1 1JA
Email address: support@starjargroup.com
We have also appointed an external data protection officer (DPO) and their details are as follows:
Evalian Limited
West Lodge
Leylands Business Park
Colden Common
Hampshire
SO21 1TH
United Kingdom
Email: dpo@starjargroup.com
Phone: +44 (0)333 050 0111
Website: www.evalian.com
DATA WE COLLECT FROM OR ABOUT YOU
- - Registration details: When you open an account and register to use our website you will be asked to provide us certain details about yourself, such as: full name, email address, date of birth, physical address, username, password, telephone number etc.
- - Payment information: In order for you to enjoy all of the functions of our services (e.g. place bets, make withdrawals, etc.), payment information will be collected from you by third party payment service providers. We do not collect or store this information ourselves. For further information you can contact us using our details as mentioned above. Payment methods are only available in the form of cryptocurrency on our website.
- - Government–issued ID: In certain instances, you will be required to provide a copy of a government-issued ID, in order for us to verify your identity. Please note that this information may be required in order for you to use or continue using our services.
- Public information: In certain instances, such as customer due diligence verification, we may need to search publicly available sources of information to confirm your identity or source of funds (for example, electoral rolls or databases regarding property values).
- - Voluntary information: We also collect information which you provide us voluntarily. For example, when you respond to communications from us, communicate with us via email, live chat or otherwise, or share additional information about yourself through your use of our services. We also collect details of any deposit, spend or loss limits that you have set.
- - Information we collect from third parties: We collect data about you from third party service providers, such as confirmation of your age and address and other financial information which is relevant and required for the provision of our services, as well as information which is gathered in order to verify your identity and prevent fraudulent or illegal activity.
- Device information: We collect specific types of connection details and information with regard to your device, software or hardware that may identify you, such as: your device’s unique identifiers and geolocation data. We may also gather information with regard to other software which is running simultaneously with our website in order to detect if you are using software which is associated with fraudulent activity (e.g. bots, malw- Device information: We collect specific types of connection details and information with regard to your device, software or hardware that may identify you, such as: your device’s unique identifiers and geolocation data. We may also gather information with regard to other software which is running simultaneously with our website in order to detect if you are using software which is associated with fraudulent activity (e.g. bots, malware) or checking if the connection you are using is via a VPN or proxy. are) or checking if the connection you are using is via a VPN or proxy.
- - Gaming information: in order for us to provide our services, we automatically record different information related to your use of our services, including with respect to your transactions, deposits, balances, bets, withdrawals, bonuses and winnings etc.
- - Technical information: In order to enhance the functionality of our website and to provide you with a better user experience, we collect technical information transmitted by your device, including certain software and hardware information (e.g. your language preference, the type of browser and operating system your device uses, access time, the domain name of the website from which you linked to our services; etc.).
- - Analytics information: We collect information using Webtrekk about your use of our services such as website usage, log files, user activity (e.g. pages viewed, the amount of time spent on particular pages, online browsing, clicks, actions, etc.), time stamps, alerts, etc. This information is collected for a number of reasons including troubleshooting errors and bugs as well as for research, profiling and analytics purposes about your use of our services, and to provide you with tailored marketing and personalized products and services.
You are under no obligation to provide personal information to us. However, certain personal information is essential for the provision and quality of the services that we offer (for example, enabling you to place bets on the website or conducting verification as mandated by the law) and you might not be able to obtain certain services if you choose to withhold information we have requested that is required for those services. For example, we ask you to share your precise geolocation to ensure that we are authorised to provide gambling services to you in your location.
HOW WE USE YOUR DATA
In accordance with data protection laws, we will only process your data where we have a lawful basis for doing so. There are four relevant lawful bases for processing personal data that may be relevant when we process data about you (depending on the type of processing being conducted):
1. Consent: you have given us consent.
2. 2. Contract: the processing is necessary to perform a contract we have entered into with you, or because you have asked us to take specific steps before entering into a contract.
3. 3. Legal obligation: the processing is necessary for us to comply with laws or regulations that apply to us (not including contractual obligations).
4. 4. Legitimate interests: where it is in our legitimate interests to process your personal information, provided that our legitimate interests are not overridden by your own rights, freedoms and interests.
The table below sets out:
- The purposes for which we process your data
- The lawful basis(es) which justify our processing activities
1. Purpose – To register, administer and manage your account (including processing deposits and withdrawals) Lawful Basis(es) – Contract
2. Purpose – To provide you with gambling services Lawful Basis(es) - Contract
3. Purpose – To send you service-related updates Lawful Basis(es) - Contract and Legitimate interests
4. Purpose – To receive and respond to your communications and requests Lawful Basis(es) – Contract and Legitimate interests
5. Purpose – To ensure that we are able to fulfil our regulatory obligations regarding your use of our services, including by verifying the accuracy of any information you provide us and by verifying your age and location Lawful Basis(es) - Legal obligation and Contract
6. Purpose – To prevent you from using our website and services if you have requested that we do so (i.e. where you self-exclude) Lawful Basis(es) - Legal obligation and Contract
7. Purpose – To comply with any deposit, spend or loss limits that you have set Lawful Basis(es) - Legal obligation and Contract
8. Purpose - To comply with our obligations under applicable laws (including regulatory and licensing requirements related to our gambling licences) Lawful Basis(es) - Legal obligation
9. Purpose – To monitor gambling patterns and to identify possible responsible gambling concerns Lawful Basis(es) - Legal obligation
10. Purpose – To identify and disclose any suspected unlawful, fraudulent, or other improper activity connected with our website and services (including money laundering) Lawful Basis(es) - Legal obligation
11. Purpose – To prevent or detect unlawful acts or protecting members of the public against dishonesty, malpractice or other seriously improper conduct Lawful Basis(es) - Legal obligation
12. Purpose – To detect if you are using software which is associated with fraudulent activity (e.g. robots, malware) or to check if the connection you are using is via a VPN or proxy. Lawful Basis(es) – Legal Obligation, Contract and Legitimate interests
13. Purpose – To analyse how you and other players use our website and respond to promotions and adverts so that we can improve our products and services and provide tailored offers and recommendations Lawful Basis(es) - Legitimate interests
14. Purpose – To personalize our service to you Lawful Basis(es) - Legitimate interests
15. Purpose – To build up your personal profile in order to gain a better understanding of your interests in our products and services and to make recommendations that are relevant to you Lawful Basis(es) - Legitimate interests
16. Purpose – To provide you with ads on social media sites, except where you have requested not to receive such ads via your social media account Lawful Basis(es) - Legitimate interests
17. Purpose – To send you offers and promotions relating to our services Lawful Basis(es) - Consent
18. Purpose – To use your name, image, username or location in publicity and marketing Lawful Basis(es) - Consent
If you do not wish for us to use your personal information in order to provide the personalised betting service to you, you can withdraw your consent by contacting us at any time or by the profile settings on our website.
WHO WE SHARE YOUR INFORMATION WITH
- We share your personal data with the IOMGSC and other gaming regulators with whom we are licensed.
- We use third party payment service providers to process payments to and from your account. These third party providers will have access to or process your cryptocurrency payment information for the purpose of providing these services to us but we do not collect or store the payment information.
- We use third party providers in order to manage aspects of your account; including antifraud and anti-money laundering checks, credit risk checks. These third party providers may have access to or process your personal information for the purpose of providing these services to us.
- We use third party service providers in order to advertise and market to you, if you have given us express consent to do so. Such consent can be withdrawn by you at any point.
- We use Customer Relationship Management (CRM) tools in order to manage our advertising activities. Your personal data may be shared with these third parties for this purpose. You will only receive advertising material from us or our partners if you have opted to receive marketing materials.
- We may share some or all of your personal information in connection with or during negotiation of any potential sale or investment in any of the companies in the Group or in the event of a corporate transaction (e.g. a sale of a substantial part of our respective businesses, a merger, financing, restructuring, consolidation, acquisition, corporate divestiture, dissolution transaction, or other proceeding involving the sale, transfer, divestiture or disclosure of all or a portion of our business or assets). In the event of an insolvency, bankruptcy, or receivership, your personal information may also be transferred as a business asset. In the case that the new designated data controller wishes to process any personal data transferred as a business asset, consent must be obtained from the data subject(s) prior to any processing of the personal data in question.
- In some cases we may disclose your personal information and any other information and/or records relating to you, if we are under a duty to disclose or share these details in order to comply with any legal obligation, or when ordered to do so by any governmental or administrative authority. We may also share such information if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms and Conditions, or as otherwise required by law.
- The above list is representative and not exhaustive.
As a gambling operator, we are subject to strict legal and regulatory obligations to ensure you can use our website. Because of this, we may share your personal information with certain third party service providers (such as verification agencies, fraud prevention agencies, payment service providers and similar third parties) that are also “data controllers” in respect of the personal information about you that is held by them.
Upon request we can provide a full list of suppliers and third parties we use to process personal data. To request this please contact us using our details above.
Where we use data processors we always ensure that this is undertaken pursuant to a written contract that includes the necessary data processor clauses as set down under data protection legislation.
HOW LONG WE KEEP YOUR INFORMATION
We will retain your personal information for as long as it is reasonably necessary for our legal and business purposes. Please note that we may be required in certain circumstances to retain your information indefinitely (for example, in order to comply with our policies and procedures in connection with responsible gambling and self-exclusion). As required by our regulators at the IOMGSC (as applicable), we will also keep your personal data and all the details of your financial transactions for a minimum period of five years after the closure of your account with us. We will take all necessary steps to ensure that the privacy of your information is maintained for the period of retention. Once any mandatory retention period has elapsed, we will delete or anonymize any personal information no longer required to be held by us.
CHILDRENS PRIVACY
The Company does not knowingly collect information from children under the age of 18 years old. If we become aware of anyone under the age of 18 using our services we will delete their personal data, permanently close the account and block them from accessing our services.
YOUR DATA PROTECTION RIGHTS
The right of access
- You have the right to access your personal information.
- You can ask us to provide you with all the personal information we hold and/or process about you.
- The right to access is free of charge, unless this a repeat request or manifestly unfounded or excessive. In such cases we can charge a reasonable fee for the administrative costs of complying with the request. We will provide the requested data within 1 month of the request (or within 3 months where the request is complex). If responding to your request will take us more than 1 month, we will write to you prior to the expiration of the 1 month period to advise you that this is the case. In any event we have to provide a full response to you within 3 months.
The right to rectification
- You have the right to request that we rectify and correct any personal information that we are processing about you which is incorrect, whether that is an accidental error (such as a typo), because something has changed (address/email) or otherwise.
- We want the information we keep about you to be as accurate as possible. You can amend your personal information in the ‘My Account’ section of the website, or contact us and ask us to correct and/or erase incorrect and/or inappropriate data.
The right to erasure
- You have the right to request that we erase your personal information where there is no compelling reason for us to continue processing it (“right to be forgotten”).
- We will respond to requests to exercise the right to be forgotten within 1 month of the request. However, this right is not absolute and only applies in certain circumstances.
- If the request relates to marketing that you had previously opted into, we will assist you in opting out of this.
- If we cannot comply with your request, we will let you know why this is and the reason for retaining your data.
The right to restrict processing
- You have the right in certain circumstances to request that we suspend our processing of your personal information.
- If you think the data we hold is inaccurate or has been unlawfully processed then you can contact us to request that the data you provided is restricted from processing.
- Where we agree to suspend our processing of your personal information we will still be permitted to store your personal information, but any other processing of this information will require your consent, subject to certain exemptions.
The right to data portability
- You have the right to be provided with personal information that you have provided to us with your consent or which was necessary for us to provide you with our products and services in a structured, machine readable and commonly used format and you may also have the right to request that we transfer the personal information directly to another data controller without hindrance, if it is technically feasible for us to do so.
The right to object
- You have the right to object to our use of your personal information which is processed on the basis of our legitimate interests.
- However, we may continue to process your personal information, despite your objection, where there are compelling legitimate grounds to do so or we need to process your personal information in connection with any legal claims.
The right to be informed about automated individual decision-making, including profiling
- If automated decision-making is necessary for the performance of the contract we have with you or based on your consent, you have the right to obtain human intervention, to express your point of view and to contest the decision.
The right to withdraw consent
- Where we have relied upon your consent to process your personal information, you have the right to withdraw that consent.
To exercise any of your rights regarding your personal data please contact us. Some changes can be made directly by you on our website from “Profile > My Account > Account details”.
Please note that not all of your rights are absolute, and we may be entitled to extend the period for dealing with your request if it is complex. We also have the right to take suitable steps to confirm your identity before responding to a request.
We may also rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion, in accordance with our internal policies.
The right to complain
- You have a right to raise concerns with, or complain to, us by sending an e-mail or letter using the contact details provided at the top of this Privacy Notice.
You can also report any concerns or complaints to the Isle of Man Information Commissioners Office at https://www.inforights.im/
WHERE WE STORE, PROCESS AND/OR TRANSFER YOUR INFORMATION
All information you provide to us is stored on secure servers maintained by us or suitable third parties. All payment transactions are encrypted using Transport Layer Security (TLS) technology and our payment processors are PCI DSS accredited thus ensuring the protection of your payment details.
The personal information we hold about you is primarily stored and processed within the Isle of Man. However, when your information is transferred to our 3rd party suppliers, then your data may be processed outside of the Isle of Man.
Where we transfer personal information from the Isle of Man to other countries in which applicable laws do not offer the same level of data privacy protection as in your home country, we take steps to ensure that your data is treated securely and in accordance with this privacy notice. For example, we use approved contractual clauses, intragroup agreements and other measures designed to ensure that the recipients of your personal information protect it.
HOW WE SECURE YOUR INFORMATION
We employ various technical and organisation security measures to protect your personal data. We maintain technical safeguards relating to secure system configuration, access control, data encryption and monitoring which are designed to protect against unauthorized access, disclosure, modification or loss of information. We maintain a principle of least privilege to ensure access to your information is restricted only to those employees who have a legitimate 'need to know' within the remit of their role. You also have an important role in protecting your personal information; account credentials should be unique, with complex passwords and should never be shared or re-used across other services.
If we become aware of any loss, misuse, alteration of personal data we will work closely with our IT team, DPO and other parties as necessary to investigate the incident at hand. We have put into place the relevant procedure and policies in place to investigate, mitigate and report (when needed to relevant parties) such instances.
COOKIES, TAGS AND OTHER IDENTIFIERS
A cookie is a small file that we store on your browser and/or your mobile. Cookies record information about you and can be used to customise your experience on the App. You can find out more about cookies at https://www.allaboutcookies.org/
We may use the following types of cookies:
- Essential Tracking Cookies – which are essential to enable you to log in and use the services (because they keep a record of who you are as you navigate our services)
- Functional Tracking Cookies – which are used to remember choices you make, and to personalise our service
- Performance Tracking Cookies – which analyse your use of our service (for example, the amount of time you spend using different aspects of our services; these are used for analytics and personalisation)
- Marketing or Advertising Cookies – these are used to deliver tailored advertisements to you, and to measure the effectiveness of our advertising campaigns
- Social Media Tracking Cookies – these track your use of social media features such as ‘shares’ or ‘likes’ – your use of social media is governed by the privacy notice of the relevant social media company.
We use cookies for the following purposes:
- To identify your preferred language, so it can be automatically selected when you return to the App;
- To ensure the bets you place are associated with your betting coupon and your Account - For analysis of the App traffic, so that we can make suitable improvements.
- To enable us to personalise the App and provide you with tailored services and marketing
Please be aware that it is not possible to use the App without cookies. You can turn off cookies by disabling them in the settings for your browser; but note that certain functions of the App may not work if you do this. If you require additional information about how we use cookies, please contact us.
THIRD PARTY WEBSITES
The App may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy notices and that we are not responsible for and have no control over information that is submitted to, or collected by, these sites.
WEB APP COOKIE POLICY
We use cookies and by agreeing to our Terms & Conditions, you consent to our use of cookies in accordance with the terms of this policy, which is incorporated into our Terms & Conditions.
About cookies
‘Cookies’ are small files stored in your web browser that contain an identifier (a string of letters and numbers) that enable us to recognise your computer and track the navigation of different pages of our site.
Cookies are used to make things quicker, easier and more personal to you. They are also essential in keeping certain parts of our websites functioning correctly and securely. Cookies do not contain any information that personally identifies you.
Cookies may be either “persistent” or “session” cookies. A persistent cookie will be stored by a web browser and will remain valid until its set expiry date (unless deleted by you before the expiry date). A session cookie, on the other hand, will expire at the end of your session, when the web browser is closed.
Cookies used on the site
There are two types of cookies:
- First-party cookies are created by us when you visit our site.
- Third-party cookies are created by other sites. These sites own some of the content, like ads or images that you see on the webpage you visit.
We only uses first-party cookies presently, although we do reserve the right to use third-party cookies.
The cookies we use are Strictly Necessary cookies, this means that without these cookies parts of our site will not work at all.
We use the information we obtain from your use of our cookies for the following purposes:
- To enable you to contact our customer support teams directly from your App by use of LiveChat.
Blocking and deleting cookies
How to block cookies in iOS 7 Safari:
a) Launch the Settings app from the Home screen of your iPhone or iPad running iOS 7. b) Scroll down and tap on Safari.
c) Under Privacy & Security, tap on Block Cookies.
d) Choose between Always, From Third parties and advertisers, and Never.
How to block cookies on Android
a) On your Android phone or tablet, open the Chrome app
b) To the right of the address bar, tap More Settings.
c) Tap Site settings Cookies.
d) Turn Cookies off.
Clearing cookies
How to clear cookies on iOS:
a) From the home screen, tap the Settings button. (+)
b) On the Settings screen, scroll down and tap the Safari button. (+)
c) Under the ‘Privacy’ section of the Safari screen, tap the button labelled Clear Cookies and Data. (+)
d) On the confirmation screen, tap Clear Cookies and Data. (+)
How to clear cookies on Android:
If you remove cookies, you’ll be signed out of our site and any saved preferences may be deleted.
a) On your Android phone or tablet, open the Chrome app.
b) To the right of the address bar, tap More Settings.
c) Tap Privacy Clear browsing data.
d) Choose a time range, like Last hour or All time.
e) Check “Cookies, media licenses and site data.” Uncheck all the other item. f) Tap Clear data.
Review and Updates
We will review this notice and make changes to it from time to time. We recommend that you check this notice to see where changes have been made and to ensure you are able to review updated information at all times.
Last reviewed: February 16th, 2023