Privacy Policy & Fair Processing Notice
1.IMPORTANT INFORMATION
BY REGISTERING AS A MEMBER (“MEMBER” WITH LES AMBASSADEURS CLUB, BY PROVIDING YOUR PERSONAL INFORMATION, USING LES A PREMISES AND / OR BY USING THE WEBSITE, YOU EXPLICITLY CONSENT TO LES A PROCESSING AND DISCLOSING YOUR PERSONAL INFORMATION FOR THE PURPOSES SET OUT BELOW WITHIN THIS NOTICE, OR AS OTHERWISE PROVIDED IN ACCORDANCE WITH LES A CLUB RULES.
IF YOU WISH TO QUALIFY, VARY, MODIFY OR LIMIT YOUR CONSENT IN RELATION TO MARKETING COMMUNICATIONS OR IN CIRCUMSTANCES WHERE ANY PROCESSING OF YOUR DATA IS LIKELY TO CAUSE DAMAGE OR DISTRESS OR SUCH OTHER CIRCUMSTANCES AS THE LAW ALLOWS THEN YOU MAY DO SO BY NOTIFYING US.
IF YOU DO NOT AGREE WITH THESE TERMS, YOU SHOULD NOT PATRONISE LES A OR USE ITS WEBSITE.
INTRODUCTION
The Proprietor and Owner of Les Ambassadeurs Club (“Les A”) is Les Ambassadeurs Club Limited.
Registration No. 02708889.
The name of the Company Les A is “Les Ambassadeurs Club” (“Les A” or “we”) and its address is 5 Hamilton Place, London W1J 7ED.
Les A is regulated and licensed by the UK Gambling Commission and holds an Operating Licence.
Les A is a Data Controller registered with the Information Commissioner’s Office, Registration No. Z5542615.
We want our Members, their guests and website users (“you”) to know that we are just as concerned as you are about the privacy of any personal information that you may choose to provide to us (“Personal Information”).
Personal Information is any information relating to you from which you can be identified and may include your name and address, date of birth, nationality, family, lifestyle and social circumstances, goods and services, financial details including payment card details, employment and education details, copies of passports and other ID, credit history, gaming history, SENSE / voluntary self-exclusion information, details of winnings and account transfers and any other information you may wish to provide, as well as sensitive information such as physical or mental health details, ethnicity, offences and alleged offences, and criminal or civil proceedings, outcomes and /
or sentences. It is impossible to foresee precisely what types of Personal Information might be obtained about each individual Member, and some of these types of Personal Information may not be obtained at all for particular Members.
Les A’s business practices that involve the collection, processing, storage, use or disclosure of Personal Information are compliant with the Data Protection Act 2018 and the General Data Protection Regulation (GDPR).
In this Privacy Policy & Fair Processing Notice (the “Notice”), we want not only to advise you of your rights, but also explain how we respect them.
Any Personal information you provide to us is subject to the terms of this notice and the terms and conditions contained in the Club Rules (the “Rules”).
By applying for and accepting membership of Les A (“Membership”), visiting Les A and /or using this website (“Website”) you permit the collection, processing, use and disclosure of your Personal Information as outlined below and you agree to this “Notice”.
We are not generally obliged to keep records of such data, save as required by law or regulations.
2. INFORMATION WE MAY COLLECT FROM YOU
We may collect and process Personal Information about you for the purposes of promoting our goods and services, to maintain our accounts and records, and to support and manage our staff, including for the purposes of administration, customer services, marketing and /or carrying out appropriate compliance, security and /or financial checks.
We may collect and process Personal Information about you in circumstances including, but not limited to, the following:
• You provide Personal Information (such as your name, date of birth, nationality, copies of passport and other IDs, address, and email address) when applying for Club Membership, entering Les A, using its facilities, and /or providing up to date personal details or ID.
• Personal Information may be collected about you when we verify your identity and personal details, and conduct credit, security and /or compliance checks.
• Personal Information may also be collected when you contact us for any reason, communicate with us on our Website and / or request or receive services or information.
• We may also ask you for information if you complain or report any problems and /or are in dispute with us.
• Les A may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
Details of your visits to our Club and /or our website, and the resources that you access online and the facilities that you use when at Les A, may be recorded, including, but not limited to:
• communication data, gaming data, transaction data and due diligence data, whether this is required for our own billing, compliance, security, financial or marketing purposes or otherwise.
• To ensure a good quality of service we may monitor and record any communication you have with us in writing, by phone or by electronic mail.
• You should note that email is not encrypted to / from Les A. Any information which you transmit to us is transmitted at your own risk.
• We may also collect Personal Information about you from third parties, such as credit references agencies, authorised service providers, debt collection and tracing agencies, and other authorised agents / subcontractors, the Gambling Commission or other regulatory / government authorities, complaints adjudicators / alternative dispute resolution bodies, law enforcement or other business for the purpose of prevention or detection of crime, apprehension or prosecution of offenders, other casinos for the purpose of credit risk reduction, prevention or detection of crime and /or apprehension or prosecution of offenders, and or any affiliate or related company or any subsidiary or parent undertaking as defined by section 1162 of the UK Companies Act 2006.
3. CONSENT
By providing your Personal Information, using Les A premises or facilities, using the Website and /or registering with us as a Member or guest, you consent to Les A collecting, processing and /or disclosing your Personal Information as set out in this “Notice” and, in the case of Members, in accordance with the “Rules”.
If you wish to qualify, vary or withdraw your consent in relation to marketing communications or, in circumstances where any processing of your data is likely to cause damage, or distress, or such other circumstances as the law allows, then you may do so by providing us reasonable notice in writing by email to enquiries@lesaclub.com, to Les Ambassadeurs Club Membership committee by email to lesamembershipcommittee@lesaclub.com, or by mail to Les A’s address, 5 Hamilton Place, London W1J 7ED.
Certain data collection, processing and sharing of Personal Information is necessary for Les A to provide you with services and for the Purposes set out below including to ensure compliance with applicable laws and regulations.
If you qualify, vary or withdraw your consent to the collection, processing and /or sharing of such necessary information, in many cases Les A may be unable to provide you with services and /or your Membership may be terminated.
4. CCTV, FACIAL RECOGNITION AND AUDIO RECORDING
The Club employs the use of CCTV, Facial Recognition as well as audio recording software. This is used upon entry to the Club, throughout the casino premises and surrounding areas, specifically the Club`s perimeter to enable the effective monitoring and traceability of individuals thus ensuring the security of the premises is maintained, to prevent and investigate crime, cheating and regulatory breaches.
It may also be used to monitor staff when carrying out work duties.
The Personal Information collected and processed about you may therefore include audio footage, visual images, personal appearance and behaviour.
5. NON-MEMBER, VISITOR MANAGEMENT SYSTEMS
The information that you supply via our non-member visitor management system form will be entered into a digital filing system and will only be accessed by authorised persons of Les A. The information will be retained by Les A and will only be used for the purpose of: (a) the identification of those entering the premises; (b) summary information for statistical and audit purposes; and (c) to ensure compliance with any regulatory requirements.
By supplying such information, you consent to Les A storing the information for the stated purposes.
Further information regarding how your personal information is stored and processed on our non-member visitor management system may be found at the following address; https://www.sine.co/privacy
HOW YOUR PERSONAL INFORMATION WILL BE USED
We take the security of your Personal Information very seriously and will only use it in accordance with this “Notice” and, if applicable, the “Rules”.
Les A will process your Personal Information in order to allow you access and make use of our Club and Les A’s website, to allow you to participate in the services offered, to promote our goods and services, to administer your account, to maintain our accounts and records, to support and manage our staff, to monitor usage and levels and the quality of the service we provide, to carry out all necessary enquiries and /or investigations, including but not limited to appropriate identity, credit, compliance, security and /or financial checks, to verify information provided by
you or about you, to inform you, from time to time, about products and services that we consider may interest you and for related purposes, to take or defend actual or potential legal or regulatory proceedings, and to respond to complaints (the “Purposes”).
Explicit consent to marketing use; by providing consent for purposes of marketing, you have given Les A explicit consent to use your personal information for this purpose or permit marketing use; your personal information may be used for marketing purposes.
You do not have to agree to this.
If you object to the use of your personal data for this purpose, you can immediately not “opt in” at the point of registration thus “opting out”.
You may also “opt out” or withdraw your consent for us to process your information for this purpose thereafter, by informing the Duty Manager and /or a member of the Reception Team at any time. Alternatively, you may contact Les A by any of the means provided within the Privacy Policy & Fair Processing Notice.
Authorised service providers may use such data, to provide you with information about related services which may be of interest to you and we or they may contact you about these.
Upon receiving your decision to “opt out” or your “withdrawal of consent”, Les A will, as soon as reasonably practicable after receiving your request, remove your contact details from its marketing database.
If you have already provided your details to a third party, or we have done so with your consent, you may have to
contact the third party directly to ensure your contact details are removed from their database, as we do not control third party databases.
Les A will also retain such information and may analyse it in order to investigate any actual or suspected fraudulent or other criminal activity.
All rights in the manner of recording your Personal Information held by Les A, including copyright and database rights, shall remain its property.
Telephone calls relating to users may be recorded and may be actively monitored for the purposes of compliance, security and / or customer service.
All users hereby consent to such monitoring.
Where necessary or required, your Personal Information may be shared as described overleaf.
6. WHERE YOUR PERSONAL INFORMATION MAY BE STORED
The Personal Information we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”).
We will take all steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this “Notice”.
Personal Information will not be retained for longer than necessary for the Purposes for which it was collected or as required by law.
DISCLOSURE OF YOUR INFORMATION
Where necessary or required, we may share your Personal Information with:
• credit reference agencies
• authorised service providers
• debt collection and tracing agencies, and other authorised agents / subcontractors
• the Gambling Commission, the Information Commissioner’s Office or other regulatory / governmental authorities
• complaints adjudicators / alternative dispute resolution bodies
• law enforcement or other businesses for the purpose of prevention or detection of crime, apprehension or prosecution of offenders
• other casinos for the purpose of affordability risk reduction, prevention or detection of crime and /or apprehension or prosecution of offenders
• any affiliate or related company or any subsidiary or parent undertaking as defined by section 1162 of the UK Companies Act 2006 in the event that Les A sells or buys any business or assets, the prospective seller or buyer, of such business or assets.
In the event that Les A or substantially all of its assets are acquired by a third party, Personal Information held by Les A may be one of the transferred assets.
Your Personal Information may also be disclosed or shared in order to comply with any legal or regulatory obligation (including a statutory duty or court order of any court of competent jurisdiction), in order to enforce or apply our “Rules” and / or any other agreement or obligation owed to us, and / or in order to protect the rights, property and / or safety and security of Les A, our members, guests, users or others.
7. LIABILITY
You agree not to hold Les A liable for information released to third parties or used by Les A in accordance with this “Notice” and, where applicable, the “Rules”.
8. ACCESS TO YOUR PERSONAL INFORMATION
You may at any time request a copy of your Personal Information held by Les A in accordance with subject access rules in the General Data Protection Regulation (GDPR).
The GDPR gives you the right to access information held about you, under the “Right of Access”, Article 15, subject to certain statutory exceptions and limitations.
In compliance with the GDPR, we will provide the information requested, to which you are entitled, promptly and no later than one month of the receipt of the request.
However, the period of compliance may be extended by a further two months.
This is in cases where the requests are complex or multiple.
In such an instance, you will be informed within one month of the receipt of the request and an explanation as to why the extension is necessary.
Any access request is free, although in some cases a reasonable fee may be charged.
This is when a request is unfounded or if it is made excessively or repetitively.
A fee may also be charged when more copies are required for the same information.
The fee will be based purely on the administrative cost associated with providing the information.
The Right of Erasure, to Withdraw Consent, to Rectification and the Right to lodge a complaint in accordance with your Freedoms and Rights, shall be processed in accordance with your rights unless there are legal grounds / exceptions replied upon as granted to the UK under GDPR Derogations.
These rights may be exercised at any time by contacting the Data Protection Officer (DPO) in writing by email to DPO@Lesaclub.com or by mail, for the attention of the DPO, to Les A’s address. DPO@Lesaclub.com
9. CHANGES TO THIS “NOTICE”
Les A reserves the right to update, change or supplement this “Notice” at any time including by altering the types of Personal Information that may be collected, processed or shared and / or the purposes for which Les A may do so.
In the event that Les A considers it appropriate to make any such change, you will be informed of those changes by Les A’s updates to the “Notice” which will be posted on our Website and within internal Literature made available to you on entry to and within Les A via notices and leaflets. Your continued use of the Website and / or your Membership will constitute acceptance of those changes.
10. CONTACT US
Questions, complaints, comments and requests regarding this “Notice” are welcomed and should be made:
• via the corporate website: www.lesaclub.com
• by post to: The Data Protection Officer (DPO), Les Ambassadeurs Club, 5 Hamilton Place, London, W1J 7ED.
• by email to: The Data Protection Officer (DPO) at DPO@Lesaclub.com
• by email to: Les Ambassadeurs Club at enquiries@lesaclub.com
• the Membership Committee at lesamembershipcommittee@lesaclub.com
To further query your rights regarding your personal information, to lodge a complaint, raise a concern about how your complaint has been handled and / or appeal against any decision made following your complaint, in accordance with your rights, you may contact the supervisory authority directly.
The supervisory authority is the Information Commissioner’s Office (ICO): https://ico.org.uk/
11. GOVERNING LAW AND JURISDICTION
This “Notice” and any dispute arising out of or in connection with it and/or Les A’s collection, processing, use and/or disclosure of Personal Information shall be governed by and construed in accordance with English law.
You agree that you irrevocably submit to the jurisdiction of the Courts of England and Wales in respect of any such dispute.
You agree that you may not bring proceedings in respect of any such dispute against Les A in any jurisdiction other than England and Wales.
At its election, Les A may bring proceedings against you in respect of any such dispute in the Courts of England and Wales and/or any other court with jurisdiction.
To the extent permitted by law, Les A may take concurrent proceedings in any number of jurisdictions.
Issued February 2019