Privacy Policy

Our Terms / Privacy Policy

Privacy Policy

This privacy policy is effective from 25th May 2018. All previous privacy policies are cancelled and
replaced with this privacy policy.

This privacy policy applies to the entire contents of this website and other websites including applications operated
by In Touch Games Limited, including without limitation www.mFortune.co.uk ,
www.PocketWin.co.uk , www.MrSpin.co.uk and www.DrSlot.co.uk .

In Touch Games Limited respects your privacy and is committed to protecting your personal data. This privacy policy
will inform you as to how we look after your personal data when you visit our website or any of our game apps
including the app launcher (regardless of where you visit it from) and tell you about your privacy rights and how
the law protects you.

IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY POLICY

This privacy policy aims to give you information on how In Touch Games Limited collects and processes your personal
data through your use of this website, including any data you may provide through this website when you register an
account, make a deposit, play any of our games or take part in a competition or promotion.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we
may provide on specific occasions when we are collecting or processing personal data about you so that you are fully
aware of how and why we are using your data. This privacy policy supplements the other policies and is not intended
to override them.

CONTROLLER

In Touch Games Limited is the controller and responsible for your personal data (collectively referred to as “ITG”,
“we”, “us” or “our” in this privacy policy).

Our Legal Department is responsible for overseeing questions in relation to this privacy policy. If you have any
questions about this privacy policy, including any requests to exercise your legal rights, please contact the Legal
Department in writing using the details set out below.

CONTACT DETAILS

Our full details are: c/o Legal Department, In Touch Games Limited, Fountain House, Great Cornbow, Halesowen, B63
3BL.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK
supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal
with your concerns before you
approach the ICO so please contact us in the first instance.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your
personal data changes during your relationship with us.

THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or
enabling those connections may allow third parties to collect or share data about you. We do not control these
third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage
you to read the privacy policy of every website you visit.

THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be
identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together
follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier,
    marital status, title, date of birth and gender;
  • Contact Data includes billing address, delivery address, email address and telephone numbers;
  • Financial Data includes bank account, payment card details Mobile billing and PayPal and Skrill
    transactions;
  • Transaction Data includes details about payments to and from you.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and
    version, time zone setting and location, browser plug-in types and versions, operating system and platform and
    other technology on the devices you use to access this website;
  • Profile Data includes your username and password, deposit methods made by you, your interests,
    preferences, feedback and survey responses;
  • Usage Data includes information about how you use our website and games.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and
    our third parties and your communication preferences.

We also collect and use Aggregated Data such as statistical or demographic data for any purpose.
Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does
not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to
calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated
Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as
personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about
your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade
union membership, information about your health and genetic and biometric data). Due to our regulatory requirements
we will collect information about criminal convictions and offences as part of our PEP and sanction procedures,
however this information will not be passed to third parties unless required by law.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to
provide that data when requested, we may not be able to perform the contract we have or are trying to enter into
with you (for example, to provide you with gambling services). In this case, we may have to close your account you
have with us but we will notify you if this is the case at the time.

HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your identity, contact and financial data by logging in to
    your account, filling in forms or by corresponding with us by post, phone, email, live chat or otherwise. This
    includes personal data you provide when you:
  • Register an account;
  • Contact us by telephone, email or live support facility;
  • Request marketing to be sent to you;
  • Enter a competition, promotion or survey; or
  • Give us some feedback.
  • Automated technologies or interactions. As you interact with our website, we may automatically
    collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by
    using cookies, server logs and other similar technologies.
  • Third parties or publicly available sources. We may receive personal data about you from
    various third parties and public sources as set out below:

(a)analytics providers such as Google based outside the EU;

(b)search information providers based inside the EU such as:

  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Fonix
    based inside the EU.
  • Identity and Contact Data from data brokers or aggregators such as GB Group based inside the EU.
  • Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register
    based inside the EU.

HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the
following circumstances:

  • Enable us to set up your account so that you can make full use of all of the features of the services, including
    crediting your account with funds, and playing games;
  • Comply with relevant regulations regarding your registration for example completing age verification checks; and
  • (provided that you do not opt out of receiving marketing materials), to keep you informed of future events,
    offers and promotions from us (and any other company in our group);
  • Setting up, operating and managing your account;
  • Proving any of the services which are requested of us, and for any proper purpose connected with such provision;
  • Verifying the accuracy of your information, including disclosure of such information to third parties (including
    financial institutions, age verification and credit reporting agencies);
  • Preparing statistics, providing analytical reports and analysis relating to the use of the services by you and
    other customers;
  • Analysing and recording your use of services and websites in order to improve our products and the way we
    deliver the services;
  • Preparing and displaying appropriate individualised marketing material and content;
  • Conforming to regulatory and legal requirements or complying with legal processes;
  • The investigation of suspected unlawful, fraudulent or other improper activity connected with the services;
  • The reporting of a crime or suspected crime, including money laundering, proceeds of crime or any fraud; and
  • Any other purpose which is necessary for the performance of our contractual obligations to you or our legal and
    regulatory obligations;

You have the right to withdraw consent to marketing at any time by:

  • telephone live chat, via the Support Button on the Website;
  • using the unsubscribe feature in the marketing material: or
  • amending your settings in the marketing preferences section of my account.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which
of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for
which we are using your data. Please contact us if you need details about the specific legal ground we are relying
on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer and choose whether to give explicit consent or not to receiving free
bonuses and exclusive offer news from ITG.
(a) Identity

(b) Contact

(c) Marketing and Communications

Performance of a contract with you;

Processing and disclosure of your Personal Information for the purposes of sending relevant marketing
material, promotions and prizes to you.

To process and deliver your transactions including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use
our services)

To enable you to partake in a prize draw, promotion, competition or complete a survey (a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our services, to develop them and
grow our business)

To administer and protect our business and this website (including troubleshooting, data analysis,
testing, system maintenance, support, reporting and hosting of data)
(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT
services, network security, to prevent fraud and in the context of a business reorganisation or group
restructuring exercise)(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness
of the advertising we serve to you
(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow
our business and to inform our marketing strategy)
To use data analytics to improve our website, services, marketing, customer relationships and experiences
and Responsible Gambling requirements
(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Technical

(f) Usage

Necessary for our legitimate interests (to define types of customers for our services, to keep our
website updated and relevant, to develop our business and to inform our marketing strategy and to ensure
we have comply with our Social and Responsibility Requirements)
To make suggestions and recommendations to you about our new games, promotions and depositing methods
that may be of interest to you
(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

Necessary for our legitimate interests (to develop our services and grow our business)

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and
advertising. We have established the following personal data control mechanisms:

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or
need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we
call this marketing).

You will receive marketing communications from us if you have requested information from us or if you provided us
with your details when you entered a competition or registered for a promotion and, in each case, you have not
agreed to receive that marketing.

Where you have agreed to receive such communications, ITG may use contact you for marketing purposes by SMS, email or
phone. These marketing messages will provide you with various information about our new games, promotions and other
services.

We may also send push notifications to your mobile device in order to provide game updates, account communications,
promotions or other relevant messages.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any company outside the ITG group of
companies for marketing purposes.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any
marketing message sent to you or by Contacting us at any time.

COOKIES

A “cookie” is a small text file that is downloaded onto your access device when you visit a Website and
that enables the website to obtain certain information from your browser which include your preferences. All
Websites and game apps including the game launcher which are operated by In Touch Games use cookies and similar
technologies to manage login sessions, provide personalized web pages to tailor advertising and other content to
reflect your specific needs and interests. A cookie does not harm your access device nor does it contain any viruses
or other malware.

Your browser also generates other information, including which language the website is displayed in, and your
Internet Protocol address (“IP address”). An IP address is a set of numbers which is assigned to your
computer during a browsing session whenever you log on to the internet via your internet service provider or your
network (if you access the internet from, for example a computer at work). Your IP address is automatically logged
by our servers and used to collect traffic data about visitors to our website. We also use your IP address to help
diagnose problems with our server, and to administer our website.

We also use cookies that obtain information about your device, these include Your IP address, device type,
geo-location data and browser information. This information is used to help us identify you for fraud prevention and
to detect prohibited practices that might affect your customer experience. Please note we only receive data from
your access device when you are logged into your account.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies.
If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not
function properly.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we
need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an
explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis
which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above
rules, where this is required or permitted by law.

DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in
paragraph 4 above.

Where required by law, your personal information may also be disclosed to an applicable governmental, regulatory or
enforcement authority. Additionally, in circumstances where we deem it appropriate, your personal information may be
disclosed to any regulatory authority which has issued any company within the Group with a gambling operator
license.

We require all third parties to respect the security of your personal data and to treat it in accordance with the
law. We do not allow our third-party service providers to use your personal data for their own purposes and only
permit them to process your personal data for specified purposes and in accordance with our instructions.

INTERNATIONAL TRANSFERS

We share your personal data within the ITG Group. This may involve transferring some of your data outside the
European Economic Area (EEA).

Some of our external third parties are based outside the European Economic Area (EEA) so their
processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we will ensure personal data has a similar degree of
protection that it would have in Europe.

DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used
or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to
those employees, agents, contractors and other third parties who have a business need to know. They will only
process your personal data on our instructions and they are subject to a duty of confidentiality.

All data on our secure websites is encrypted using Secure Sockets Layer (“SSL”) technology. Where we have
given you (or where you have chosen) a password which enables you to access your account, you are responsible for
keeping this password confidential.

Any data which contains personal information which identifies you will be encrypted at all times whilst in transit
over the internet. SSL is a special protocol that automatically encrypts any information sent by you on our secure
pages. Our server then reads the information using a private key. This means that your information, be it debit or
credit card information or any other personal details, is turned into code that can only be decoded with the private
key or password.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any
applicable regulator of a breach where we are legally required to do so.

DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including
for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of
the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the
purposes for which we process your personal data and whether we can achieve those purposes through other means, and
the applicable legal requirements.

By law to maintain our compliance with AML regulations we are required to keep basic information about our customers
(including Contact, Identity, Financial and Transaction Data) for a period of at least five years after the
relationship with the customer has ended. The date the relationship with the customer ends is the last date on which
they visit or use our services.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”).
This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully
processing it.

Request correction of the personal data that we hold about you. This enables you to have any
incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data
you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data
where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove
your personal data where you have successfully exercised your right to object to processing (see below), where we
may have processed your information unlawfully or where we are required to erase your personal data to comply with
local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal
reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those
of a third party) and there is something about your particular situation which makes you want to object to
processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to
object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate
that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the
processing of your personal data in the following scenarios: (a) if you want us to establish the data’s
accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to
hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d)
you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use
it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a
third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that
this right only applies to automated information which you initially provided consent for us to use or where we used
the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However,
this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw
your consent, we may not be able to provide certain products or services to you. We will advise you if this is the
case at the time you withdraw your consent.

Should you wish to make a Subject Access Request you should contact us in writing at:

Subject Access Request c/o Legal Department, In Touch Games Limited, Fountain House, Great Cornbow, Halesowen, B63
3BL with a cheque payment for £10.00 made payable to In Touch Games Limited.

You should include adequate information to identify yourself and such other relevant information that will reasonably
assist us in fulfilling your request. Your request will be dealt with as soon as possible. Under the GDPR, we charge
an administration fee for processing such requests. This administration fee is to cover the cost and time involved
with gathering the relevant data and administration services such as photocopying and postage.

We may reject requests for disclosure or deletion of your information that are unreasonable or extremely impractical
such as it requires a disproportionate human or technical effort or require significant changes to our processes and
technology and impact our ability to provide the services.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access
your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal
data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further
information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if
your request is particularly complex or you have made a number of requests. In this case, we will notify you and
keep you updated.

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