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Privacy Policy

Introduction

Flutter Group (Flutter, we) are partners with Casino Davos. Casino Davos is the license holder and will provide you with gambling services (and as such will be a controller of your personal data). TSG Interactive Gaming Europe Ltd, part of the Flutter Group, operates the online poker platform which is provided to you by Casino Davos (under Casino Davos’s license) and in respect of your use of the poker platform only we will be your data controller. This Privacy Policy only relates to your use of the poker platform and how we will process your personal data when using the poker platform. Please be sure to also read Casino Davos’s privacy policy here.

And, what about the Data Protection Officer, or is it DPO?

Yes, Flutter Group has appointed a Data Protection Officer (DPO) who can in principle be reached at dataprotection@flutterint.com. However, according to Swiss gaming laws and in line with Swiss data protection laws, all queries should be sent to Casino Davos through.

What is meant by “Flutter Group”?

Reference to Flutter Group within this Privacy Policy means Flutter Entertainment plc and all or any of its direct or indirect subsidiary undertakings, joint venture partners, and their related companies wherever located in the world as may exist from time to time. 

How Flutter Group collects your personal data?

Flutter Group receives your personal data from Casino Davos and through your use of the poker platform.

How will we use your personal data?

In accordance with data protection laws, Flutter Group will only process your personal data when we have a lawful basis for doing so in respect of your personal data. We process your personal data if: (i) it is necessary to provide our services to our partner Casino Davos; (ii) we are required to do so in accordance with legal or regulatory obligations; (iii) you have given your consent; or, (iv) it is in our legitimate interests to process your personal data, provided that none of these interests prejudice your own rights, freedoms and interests.  

The following is a list of the purposes for which Flutter Group processes your personal data, and the lawful basis on which it carries out such processing: 

PurposeLawful Basis
To operate the poker service Necessary for the performance of our services to Casino Davos
To assist Casino Davos with any communications you send to them that relate to your use of the poker platform Necessary for the performance of the services if the communication relates specifically to our services to Casino Davos, otherwise legitimate interests
To ensure that you are playing poker in Switzerland, reside in or have habitual stay in Switzerland Necessary to comply with a legal or regulatory obligation
To comply with our obligations under applicable laws (including gambling legislation, and regulatory and licensing requirements related to our gambling licenses) Necessary to comply with a legal or regulatory obligation
To identify and disclose to Casino Davos any breaches of T&Cs, suspected unlawful, fraudulent, or other improper activity connected with the poker platform Necessary to comply with a legal or regulatory obligation
To monitor gambling patterns and to identify possible responsible gambling concerns Necessary to comply with a legal or regulatory obligation 
To prevent you from playing poker if you have notified Casino Davos of your self-exclusion  Necessary to comply with a legal or regulatory obligation
To comply with any limits that you have set or which have been applied to you, such as spend limits Consent
To prepare statistics relating to the use of our services by you and our other customers Legitimate interests of understanding the use of, and therefore improving, our products and services
Sharing: As Casino Davos is the license holder and operates the Customer Support, we may share information with them about players on the poker platform which relate to the use of poker on the service Necessary for the performance of the services to Casino Davos
Sharing: As Casino Davos is the license holder we may share information with them about players where we suspect there has been any fraudulent or illegal activity or any misconduct on the poker platform Necessary for a legal or regulatory requirement
Sharing: To share your personal data with our professional advisors, such as lawyers and consultants Legitimate interests to allow us to seek advice
Sharing: To share personal data with other members of the Group where we are required to ensure that responsible gambling measures can be applied Necessary for a legal or regulatory obligation
Sharing: To share your personal information with third parties for fraud and anti-money laundering detection purposes Necessary to comply with a legal or regulatory obligation
Sharing: To share your personal data with law enforcement agencies for the prevention and detection of crime Legitimate interests of helping to protect our service and our community

In addition to the purposes set out above, we may also process your personal data for other purposes that we deem compatible with those listed above. We will update this Privacy Policy accordingly, when we do this. 

Disclosing your personal data

In addition to the purposes involving the sharing of your personal data listed above, we will also disclose your personal data to processors we engage. We will have a contract in place with each such processor to ensure your personal data is kept secure. 

We may also disclose your personal data in the following circumstances:

  • when required by applicable law or regulation (disclosure to a governmental, regulatory or enforcement authority);
  • in order to defend ourselves legally and/or in relation to legal proceedings; and
  • whilst negotiating a takeover, purchase or merger, and pursuant to the same.

Transferring your personal data outside of the EEA

We store your personal data in the Isle of Man, a territory that has received an Adequacy Decision from the European Commission regarding its suitable data protection laws. The Federal Data Protection and Information Commissioner (‘FDPIC’) has also determined that the Isle of Man guarantees adequate data protection. Your personal data may also be accessed by members of the Group who are located outside of Switzerland, the European Union, and the European Economic Area and in such cases we have implemented standard contractual clauses to ensure adequate protection of your personal data. 

We may also share your personal data with third parties outside of Switzerland, the European Union, and the European Economic Area and we will ensure that an Adequacy Decision or alternatively a standard contractual clause are in place to protect your personal data. In the case of a standard contractual clause, the Federal Data Protection and Information Commissioner will be informed (‘FDPIC’).

Security

We will take appropriate security, technical and organizational measures to ensure that your personal data is kept secure and to prevent the theft, loss or unauthorized access to your personal data. It is important to understand however that security can never be guaranteed and you will not hold us liable save where the security of your personal data is compromised due to gross negligence on our behalf.

Marketing

If you have signed up to receive marketing in relation to poker then we may work with Casino Davos to arrange for them to send you such marketing.   

At any time you can manage your marketing consents via your user account. You can also unsubscribe by using the tools in any marketing communication you receive. Please note that if you unsubscribe from marketing it may take up to 28 days for this to take effect. 

Social Media Marketing

We may also use information you provide to us to show you relevant advertising and personalized content about Flutter Group’s services on certain third party social media platforms (Social Media Sites) made available to us through relevant service providers (e.g. Facebook, Twitter). If you do not wish to see these advertisements you can change your settings on the Social Media Sites. If you do not want us to share this information with Social Media Sites please let us know by contacting our partner Casino Davos.

Cookies

In this Privacy Policy, we use the expression ‘cookie’ to refer to cookies and similar technologies we use to store information (such as web beacons). A cookie is a simple text file that is stored on your computer or mobile (or other) device by a website’s server, and only that server will be able to retrieve or read the contents of that cookie. Each cookie is unique to your web browser. It will contain some anonymous information, such as a unique identifier and the website name and some digits and characters.

Almost all websites and applications you visit, including our website, will use cookies in order to improve your user experience by enabling that website and/or application to ‘remember’ you, either for the duration of your visit (using a ‘session cookie’) or for repeat visits (using a ‘persistent cookie’).

Cookies are used to improve your use of a website or application, for example through letting you navigate between pages efficiently and storing your preferences. Cookies make the interaction between you and the website faster and easier. If a website or application doesn’t use cookies, it will think you are a new visitor every time you move to a new page on the website. Cookies can also be used to enable targeted advertising and analyzing your browsing of a website. 

You can learn more about cookies generally and how to disable them on your browser here.

You can learn more about what advertising cookies exist on your device and you can disable them directly by clicking here.

Retention of your personal data

We retain your personal data for 10 years. 10 years is calculated from the closure of your user account or where your user account has been dormant for this period. There are some exceptions to this retention period, namely:

  • If you self-exclude from any of our services, we will retain this information indefinitely.
  • If you are under investigation or we have identified possible fraud, money-laundering, criminal activity we may also retain your personal data. Personal data collected in connection with filings to the Money Laundering Reporting Office of Switzerland (MROS) will be deleted 5 years after the filing.  
  • If there is a legal dispute, we will retain your personal data for the duration of the dispute and for 10 years thereafter.

Your rights

You have the following rights in relation to your personal data:

  • a right to access your personal data held by us and to receive information on the source of the data (also known as a subject access request);
  • a right to receive certain personal data in machine-readable format;
  • a right to have inaccurate or out-of-date personal data rectified;
  • where we have specifically requested your consent to process your personal data and have no other lawful conditions to rely on, you have the right to withdraw this consent;
  • a right to have certain personal data erased where it is no longer necessary for us to process it, if you have withdrawn your consent pursuant to the paragraph above, where you have objected pursuant to the paragraph below, where your personal data has been unlawfully processed, or where erasing your personal data is required in accordance with a legal obligation; 
  • a right to object to the processing if the lawful basis is that it is in our legitimate interests to process your personal data, but please note that we may still process your personal data if there are other relevant lawful bases or if we have compelling grounds to continue processing your personal data in our interests which are not overridden by your rights, interests or freedoms;
  • a right to request an explanation of the logic involved if we make decisions about you solely through automated means; and
  • a right to object to direct marketing, which can be done by opting-out of direct marketing either through your user account or by opting out via the communication itself. You also have a right to object to any profiling to the extent that it relates to direct marketing only.

To exercise your rights you should contact Casino Davos, and this will be handled by them or shared with us if your request relates to our role as a controller in respect of the poker platform. 

Please be aware that your rights are not absolute rights. This means that Casino Davos or us may have to refuse your request or may only be able to comply with it in part. 

When you make a request in respect of your rights, proof of identification may be required. 

Supervisory authorities

If you have any complaints you have the right to contact your own national data protection supervisory authority however we do ask that you contact Casino Davos in the first instance.

Contact us

If you have any questions regarding Casino Davos or our use of your personal data, or you would like to exercise any of your rights, please contact Casino Davos in the first instance. Where appropriate, our partner Casino Davos will forward your request to our Data Protection Officer at dataprotection@flutterint.com.

Privacy Policy last revised: October 18, 2022