2. Who are we?
We are Marathon Alderney Limited, a company registered in Alderney under number 1686, with registered offices at 2 Victoria Street, Alderney GY9 3UF, commonly known as Marathonbet or Marathonbet.co.uk.
3. What laws apply to our processing of your personal data?
Marathon Alderney Limited has a legal duty to protect your personal data under data protection laws, including the General Data Protection Regulation 2016 and the Data Protection (Bailiwick of Guernsey) Law, 2017.
We are licensed by the Gambling Commission and the Alderney Gambling Control Commission.
4. What type of information do we collect?
Registration with Marathonbet.co.uk is mandatory if you wish to deposit and bet on the website.
To register for an account on our website, we will ask you for personal information. As a minimum, this will include your name, address (including country of residence), date of birth and contact details, such as your email address and telephone number. We will also ask you for payment details, so that you can deposit money into your account. You do not need to give us your payment details at this stage, but if you do not then you will not be able to make use of certain services, for example you will not be able to place a bet. You can add or amend your payment details at any time.
In addition to the information we collect during registration, we may also collect the following information whilst you are a customer or when you access the website:
- details of transactions you carry out on your account, including information about your bank account and bank card;
- deposits, withdrawals, all real money wagers, products and services used, abandoned bets and free play games;
- details of your journey through the website;
- information you provide to us in any correspondence and a record of any correspondence that has taken place between you and us through any of our communication channels;
- information about any possible fraudulent, criminal or anti-money laundering activity which our systems may detect;
- information about your betting history and patterns;
- details that you may have provided as part of a competition entry;
- information that you may have provided as part of a customer survey;
- technical information associated with the device that you have used with us, including, but not limited to, traffic data, location data and other communication data.
We may also collect personal data about you from publicly available sources, such as social media, internet searches and information you submit in forums on the internet. We may combine personal data you give to us with information we collect about you and use this combined information for the purposes set out below (depending on the types of information we receive).
Before undertaking any activities of this sort, we will evaluate the risk to your rights and take appropriate steps to ensure that your rights are not infringed by such data collection.
5. How do we use information about you?
When processing personal data, we will have made a judgement about the legal basis upon which it is processed. This is a requirement of data protection laws. The legal basis for our processing of personal data depends upon the specific personal data and processing concerned. It includes your consent (for example, for marketing communications), fulfilling contracts (for example, in relation to the processing of bets placed by you), our legitimate interest (for example, fraud prevention) and legal obligations (for example, when one of our regulators legally asks us to provide certain information).
When you accept Marathonbet.co.uk’s terms and conditions, you consent to certain checks being made.
The information that has been collected by us (as described in the sections above) may be used for the following purposes:
- to perform a check of the details provided to us during the registration service and, on an on-going basis thereafter, checks against the GAMSTOP national self-exclusion service;
- to validate the details and personal information supplied by you during registration against appropriate third-party databases to confirm your age and your identity. No credit check is performed, and your credit rating will be unaffected;
- to assist with general account management, including the setup of the account and other operational actions such as the management of customer queries;
- to process any banking or online payment transactions, including with third-party payment service providers if applicable, to and from your Marathonbet.co.uk account;
- to allow you to participate in our betting and gaming services;
- to monitor your gambling patterns and to identify possible responsible gambling concerns;
- to monitor, in accordance with our responsible gambling and social responsibility obligations and for the benefit of our customers, gambling / deposit patterns that may indicate concern in respect of responsible gambling. We may use automated decision-making processes to help us to identify such patterns (for example, our systems may automatically prevent you from depositing beyond limits set by you or set by us, as further detailed in section 16). These decisions enable us to help you gamble responsibly;
- to monitor your (and all our customers') gambling activity and manage our risk and odds;
- to provide you with the most suitable information around promotional offers and events, in line with the marketing preferences you have chosen (see the next section ‘Marketing communications’ for more details);
- to assist third-party advertisers or advertising networks in promoting advertisements that they consider you may find interesting (see the next section ‘Marketing communications’ for more details);
- personal data may be aggregated and anonymised to give trends and themes, and you may receive targeted communications based upon the overall analysis as further detailed in section 17;
- as part of our commitment to provide customers with the best service possible, this information may be used as part of internal assessments around the quality of the services we provide;
- to research customer activity and our products (including customer surveys);
- to detect and prevent fraud, money laundering, cheating or any other unusual or irregular betting activity;
- to ensure we comply with legal and regulatory duties;
- to ensure that content from our website is presented in the most effective manner for you and your device;
- to run our business in a professional and efficient manner.
6. Your status as a customer
Upon registration with Marathonbet, we consider you a customer.
You will cease to be a customer of Marathonbet if you have closed your account, or if you have self-excluded from using our services.
7. Marketing communications
We particularly want to draw your attention to our use of your personal data to send you information about promotional offers (for example, Free Bets), technical updates and new site features. Depending upon your marketing preferences, we may also share some of your personal details with advertisers and advertising networks, to enable them to promote our products and services to you through other media, for example social media sites. We will send you marketing communications whilst you are a customer. We will send you marketing communications via a number of different marketing channels, including e-mail, SMS messages, push notifications and social media sites.
When you first register with the website you will have the opportunity to select your marketing preferences. You can change your preferences at any time. We have explained how to do this and how to opt out of marketing communications in section 9 (How to opt out of marketing communications) below.
8. Customer feedback
We will occasionally use your personal data to invite you to give feedback on our services. We will contact you using one of the marketing channels listed above in section 7 (Marketing communications), either directly or through a third-party organisation acting on our behalf. The frequency will be limited, your participation in the provision of feedback is always voluntary and you have the option to decline to take part. Where we use a third-party organisation to collect this feedback and send the invitations, we will only send them your contact details, so they can contact you with the initial invitation and will not pass over any other personal data (unless we have your consent to do so).
9. How to opt out of marketing communications
If you decide that you no longer wish to receive marketing communications from us, you can unsubscribe at any time. To unsubscribe from any marketing communications sent by any medium, including third-party social networks, you can do so by:
- unchecking the relevant boxes on the My Account/Other Settings page;
- contacting Customer Support;
- selecting the “Click this link to unsubscribe” option at the foot of any of our communications;
- disabling our push notifications via your phone’s settings.
If you notify us that you want to self-exclude from our services, you will automatically opt out of marketing communications and we will no longer contact you.
Please note that, even if you opt out of receiving marketing communications, you will still receive administrative communications, and other important non-marketing related announcements from us.
10. With whom might we share information about you?
We may share information about you with other companies in the Marathonbet group.
We may also share information about you with the following organisations:
- business partners, suppliers and sub-contractors that are necessary for us to provide the services that you have requested;
- organisations that support fraud prevention and credit risk reduction;
- advertisers and advertising networks that require the data to select and serve relevant adverts to you in other contexts, for example through targeted advertisements placed on social media sites;
- advertisers and advertising networks on an aggregated basis, to enable wider analysis to be undertaken about our customers and the type of offers that may be most suitable. In these cases, we do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users. We may also use such aggregate information to help advertisers reach the kind of audience they want to target;
- analytics and search engine providers that assist us in the improvement and optimisation of our site;
- if we sell or buy any business or assets, to the seller or buyer of such business or assets (for example, if Marathon Alderney Limited is sold, personal data held by it about its customers will be one of the transferred assets);
11. International transfer of your personal data
As the internet is a global commodity, its use to collect and process personal data may involve the transmission of this data on an international basis, including to countries outside the European Economic Area. In order to provide you with an efficient service, Marathon Alderney Limited and/or its service providers may need to transfer your personal data from one country to another on a worldwide basis. By registering and using our website, you acknowledge and agree to our processing and potential transfer of your personal data in this way.
If we do transfer personal data outside of the EEA, we will carry out an assessment to satisfy ourselves as to the adequacy of the recipient, put in place appropriate contractual provisions if necessary (including EU standard contractual clause agreements) and make sure that appropriate controls exist, to protect personal data.
13. Keeping your information up to date
It is important that the information we hold about you is accurate so that we can comply with our legal and regulatory obligations and provide you with the best possible service.
Please tell us as soon as possible, if there are any changes to your personal details. You can update your personal information at any time in the My Account/Personal Details section of the website or by telephoning the Customer Support team. Alternatively, you can get in touch with us at [email protected].
14. How long do we keep information about you?
We will process your personal data in accordance with the provisions above whilst you are a customer of Marathonbet. We have explained how we consider you to be a customer and when you cease to be a customer in section 6 (Your status as a customer).
We are obliged to retain some of your personal data for a minimum of five years following you ceasing to be a customer, in order that we can comply with laws that apply to us and in accordance with our licensing requirements. During this time, we will not use your personal data, except as necessary for us to comply with laws and regulations.
15. Your rights under data protection laws
You benefit from a number of rights in respect of the personal data we hold about you. We have summarised your rights below, and more information is available from the Information Commissioner’s Office website (https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/). These rights apply for the period in which we process your data.
- a) Access to your data
You have the right to ask us to confirm that we process your personal data, as well as access to (copies of) your personal data. You can also ask us to provide a range of information, although most of that information corresponds to the information set out in this fair processing notice.
We will provide the information free of charge unless your request is manifestly unfounded, excessive or repetitive, in which case we are entitled to charge a reasonable fee. We may also charge you if you request more than one copy of the same information.
We will provide the information you request as soon as possible and within one month of receiving your request in any event. If we need more information to comply with your request, we’ll let you know.
- b) Rectification of your data
If you believe that personal data we hold about you is inaccurate or incomplete, you can ask us to rectify that information. We will comply with your request within one month of receiving it, unless we don’t feel it’s appropriate, in which case we’ll let you know why. We’ll also let you know if we need more time to comply with your request.
- c) Right to be forgotten
In some circumstances, you have the right to ask us to delete personal data we hold about you. This right is available to you:
- where we no longer need your personal data for the purpose for which we collected it;
- where we have collected your personal data on the grounds of consent and you withdraw that consent;
- where you object to the processing and we don’t have any overriding legitimate interests to continuing processing the data;
- where we have unlawfully processed your personal data (i.e. we have failed to comply with GDPR); and
- where the personal data has to be deleted to comply with a legal obligation.
There are certain scenarios in which we are entitled to refuse to comply with a request. If any of those apply, we’ll let you know.
- d) Right to restrict processing
In some circumstances you are entitled to ask us to suppress the processing of your personal data. This means we will stop actively processing your personal data, but we don’t have to delete it. This right is available to you:
- if you believe that the personal data we hold isn’t accurate—we’ll cease processing it until we can verify its accuracy;
- if you have objected to us processing the data—we’ll cease processing it until we have determined whether our legitimate interests override your objection;
- if the processing is unlawful; or
- if we no longer need the data but you would like us to keep it because you need it to establish, exercise or defend a legal claim.
- e) Data portability
You have the right to ask us to provide your personal data in a structured, commonly used and machine-readable format, so that you are able to transmit the personal data to another data controller. This right only applies to personal data you provide to us:
- where processing is based on your consent or for the performance of a contract (i.e. the right does not apply if we process your personal data on the grounds of legitimate interests); and
- where we carry out the processing by automated means.
We’ll respond to your request as soon as possible and within one month from the date we receive it in any event. If we need more time, we’ll let you know.
- f) Right to object
You are entitled to object to us processing your personal data:
- if the processing is based on legitimate interests or the performance of a task in the public interest or exercise of official authority;
- for direct marketing purposes (including profiling); and/or
- for the purposes of scientific or historical research and statistics.
In order to object, you must have grounds for doing so based on your particular situation. We will stop processing your data unless we can demonstrate that there are compelling legitimate grounds which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
We will handle any exercise of your data subject rights in accordance with the requirements of data protection laws at the time of your request. If you wish to exercise any of your rights, we ask that you submit these in writing to our Data Protection Officer ([email protected]), although you are not always required to do so.
Where you make a request in respect of your rights, we will require proof of identification. We may also ask that you clarify your request. If we receive repeated requests or have reason to believe requests are being made unreasonably, we reserve the right not to respond.
16. Do we do any automated decision making?
Automated decision-making means making a decision solely by automated means without any human involvement. This would include, for example, an automatic refusal of a request for registration by an individual under the age of 18 years old without any human involvement. You can object to automated decision making, however if this means we cannot complete our processes, it may mean that we’re not able to offer you the full range of our services.
We may use automated decision-making processes to help identify patterns that cause concern in respect of responsible gambling. For example, our systems may automatically prevent you from depositing beyond limits set by you or us. We also use automated decision-making processes to assist our Know Your Customer processes and to automatically decline registration for individuals under the age of 18 years old that have attempted to register to become a customer of Marathonbet.
We also automate certain aspects of your journey with us to enhance your experience of our services. This will include sending you automated notifications through one of the marketing channels listed above to notify and remind you about certain aspects of the services we provide.
We want to make your experience better when you use our services. We therefore use your personal data to create a “profile” of you, which allows us to anticipate your needs and personalise your experience (this is sometimes known as “profiling”). To build your “profile”, we look at what we know about you, such as your age, location, gender, browsing activity (including betting and gaming history patterns) and social media usage. Our legal basis for this profiling is legitimate interests.
We may then use your personal data (or your “profile”), with your consent (where required) to show you specific content or promotions that are tailored to your interests and provide you with targeted advertising. You can opt out of the processing of your personal data for this purpose at any time. You can opt out of profiling by unchecking the relevant box for profiling on the My Account/Other Settings page, or if there is no box for profiling, by opting out of marketing communications as a whole. We have explained how you can opt out of marketing communications in section 9 (How to opt out of marketing communications) above.
18. What to do if you want to complain about the processing of information about you
If you have a complaint about how we are processing your personal data, please get in touch with our Data Protection Officer ([email protected]) who will review your complaint with you.
If you are dissatisfied with the way we have handled your personal data and we are unable to resolve the matter for you, you may take your complaint to the Information Commissioner’s Office. Further details can be found via their website at www.ico.org.uk.
Protection of your personal data is of paramount importance to us. This website has been designed to provide the best levels of security to our customers. All critical communications between you and the website are encrypted using 256-bit Secure Socket Layer (SSL) technology.
When you log in, we recognise your IP address. This is then recorded on our system. When you log in again, you can see your last log-in date and the IP address used. This is done to assist you in preventing unauthorised access to your account.
When you first register you will be given a unique login and be able to choose a password. Please keep this information secret as we cannot be responsible if, through no fault of Marathonbet, this information falls into a third party’s hands. If you have forgotten any of this information, please get in touch with our Customer Support team or follow the links on the website for forgotten logins and passwords.
20. Links to other websites
Our web site contains links to other sites. We have no control over other sites’ privacy policies and, as such, have no responsibility for any information you may enter when accessing one of these links.
21. Recording of communications
We record telephone calls and internet communications with customers for training, quality assessment, dispute resolution and security purposes. When a dispute occurs that cannot be resolved by Marathonbet, the relevant recording(s) may be made available to a third-party alternative dispute resolution specialist that will help you and us resolve the dispute.
22. Changes to our policy
Should changes be significant, we will get in touch by email to draw your attention to the relevant changes.
23. Getting in touch with us
|Post:||141 Davigdor Road|
|Phone:||From the UK: Free phone 0800 9757882|
Outside the UK: +44 1273 964705
Last Modified Date: 11/09/2019