1. Introduction
This Privacy Policy sets out how Grosvenor Casino Dudley collects, uses, stores, shares, and protects personal data in connection with the use of its services. It applies to all individuals who interact with the company, including registered account holders, visitors to the premises, and users of any digital services operated by the company.
Grosvenor Casino Dudley acts as a data controller in respect of the personal data it processes. In this capacity, the company determines the purposes and means of processing personal data and is responsible for ensuring that such processing is carried out lawfully, fairly, and transparently in accordance with applicable law.
This document should be read together with any other privacy notices, terms, or information provided at the point personal data is collected.
2. Legal Framework
Personal data is processed in accordance with the following legislation and regulatory requirements:
- UK General Data Protection Regulation (UK GDPR)
- Data Protection Act 2018
- Licence Conditions and Codes of Practice (LCCP) issued by the UK Gambling Commission
- Consumer Rights Act 2015, insofar as it relates to the fairness and transparency of terms and consumer notices
The operations of Grosvenor Casino Dudley are subject to oversight by the UK Gambling Commission (UKGC) and, in respect of data protection matters, by the Information Commissioner’s Office (ICO).
3. Data Collected
Personal data is collected only to the extent necessary to provide services, meet regulatory obligations, and protect the safety and security of customers. This may include:
- Identity data: full name, date of birth, government-issued identification documents
- Contact data: postal address, email address, telephone number
- Account data: account registration details, transaction history, account activity records
- Financial data: payment information, affordability-related information, financial risk indicators
- Verification data: documentation submitted for identity verification and anti-money laundering checks
- Usage data: records of gambling activity, session data, and interaction logs
- Communications data: records of correspondence with customer support
- Technical data: IP address, device identifiers, browser type, and cookie data where applicable
Personal data is not collected beyond what is required for the purposes described in this Privacy Policy.
4. Purposes and Legal Bases for Processing
Personal data is processed on the following legal bases and for the following purposes:
Account registration and management
- Legal basis: performance of a contract
Identity verification and age checks
- Legal basis: legal obligation
Anti-money laundering and fraud prevention
- Legal basis: legal obligation / legitimate interests
Financial risk checks and affordability assessments
- Legal basis: legal obligation / legitimate interests
Responsible gambling monitoring and harm prevention
- Legal basis: legal obligation / legitimate interests
Compliance with UKGC licence conditions
- Legal basis: legal obligation
Customer support and dispute resolution
- Legal basis: performance of a contract / legitimate interests
Marketing communications (where consent is provided)
- Legal basis: consent
Website analytics and cookie-based tracking
- Legal basis: consent (where required)
Where legitimate interests are relied upon as a legal basis, an assessment is carried out to ensure that such interests are not overridden by the rights and freedoms of individuals, taking into account the nature of the processing and the reasonable expectations of individuals in the context of gambling services.
5. Financial Risk Checks and Data Sharing
As part of obligations under UKGC licence conditions, Grosvenor Casino Dudley may conduct financial risk checks and affordability assessments. These checks may involve sharing relevant personal data with third-party lenders, credit reference agencies, or other gambling operators participating in approved data-sharing schemes.
Data sharing for these purposes is limited to what is necessary for assessing financial risk and preventing gambling-related harm. Personal data shared for this purpose is not used for unrelated marketing, profiling, or any other purpose inconsistent with harm prevention.
Where checks are carried out that may involve significant financial loss thresholds, individuals are informed that such checks may be undertaken, in line with ICO guidance on transparency and proportionality.
6. Data Retention
Personal data is retained for as long as necessary to fulfil the purposes for which it was collected, subject to the following minimum requirements:
- Data relating to regulatory compliance, including identity verification records, transaction logs, and account history, is retained for a minimum of five years following the end of the customer relationship, in accordance with UKGC guidance.
- Data held for anti-money laundering purposes is retained in line with the requirements of the Proceeds of Crime Act 2002 and associated regulations.
- Marketing data is retained only for as long as the individual remains opted in, or until consent is withdrawn, whichever occurs earlier.
At the end of the applicable retention period, personal data is securely deleted or anonymised.
7. Cookies and Online Tracking
Where digital services are operated, cookies and similar tracking technologies may be used. Non-essential cookies are only placed with the explicit consent of the user. A consent mechanism is provided that gives equal prominence to accepting and declining non-essential cookies, with granular options for different categories of tracking where applicable.
Deceptive practices are not used to obtain consent for tracking. Cookie preferences can be withdrawn or amended at any time through the settings made available on the relevant digital services.
All third-party trackers used on the platform are disclosed within the applicable cookie notice. Technologies such as fingerprinting or silent pixels are not used without a valid legal basis and appropriate disclosure.
8. Your Rights
Under UK GDPR, individuals have the following rights in relation to their personal data:
- Right of access: the right to request a copy of the personal data held.
- Right to rectification: the right to request correction of inaccurate or incomplete personal data.
- Right to erasure: the right to request deletion of personal data, subject to legal retention obligations.
- Right to restriction of processing: the right to request that processing is limited in certain circumstances.
- Right to object: the right to object to processing based on legitimate interests or for direct marketing.
- Right to data portability: the right to request personal data in a structured, commonly used, machine-readable format, where processing is based on consent or contract.
- Right to withdraw consent: where processing is based on consent, the right to withdraw consent at any time, without affecting the lawfulness of processing carried out before withdrawal.
To exercise any of these rights, the Data Protection Officer should be contacted using the details provided in Section 10.
9. Data Protection Impact Assessments
Where processing activities present a high risk to the rights and freedoms of individuals, including extensive profiling for responsible gambling purposes or large-scale processing of sensitive financial data, Data Protection Impact Assessments (DPIAs) are carried out in accordance with ICO requirements. DPIAs are reviewed and updated when the nature, scope, context, or purposes of processing change in a material way.
10. Contact and Complaints
Questions about this Privacy Policy, or requests to exercise data protection rights, should be directed to the Data Protection Officer of Grosvenor Casino Dudley.
If a satisfactory response is not received, individuals have the right to lodge a complaint with the Information Commissioner’s Office using the following contact details:
Information Commissioner’s Office
Wycliffe House, Water Lane
Wilmslow, SK9 5AF
Telephone: 0303 123 1113
Website: ico.org.uk
11. Changes to This Policy
This Privacy Policy is reviewed periodically and updated where required by changes in law, regulatory guidance, or the processing activities of Grosvenor Casino Dudley. The current version of this policy is available on request and through the relevant digital services. Where material changes are made and contact details are held, such changes may be communicated directly to affected individuals.