Fitzwilliam Private Members Club & Golden Horseshoe Limited

 

Data Privacy Notice

 

This is your guide to how personal data is managed by the Fitzwilliam Private Members Club.

Please read it carefully.

Data privacy is taken very seriously at the Fitzwilliam Private Members Club. It is important that you know exactly what we do with the personal information you and others provide to us, why we gather it and what it means to you. This document outlines our approach to Data Privacy to fulfil our obligations under the General Data Protection Regulation (2018). We also welcome it as an opportunity to reassure you of the importance we place on keeping your personal data secure, and of the strict guidelines we apply to its use. We want you to be clear on:

  1. Who we are
  2. The information we collect about you
  3. When and how we collect information about you
  4. How we use your information*
  5. How we use automated processing or “analytics”
  6. Who we share your information with
  7. How long we hold your information
  8. Implications of not providing information
  9. The legal basis for using your information
  10. Processing your information outside the EEA
  11. How to exercise your information rights (including the right to object)
  12. How to contact us and/or our Data Protection Officer
  13. Changes to this notice

 

*This notice applies to all our services.

If you have any questions about how your information is gathered, stored, shared or used, please contact dataprotection@fitzwilliamcardclub.com. You have a number of rights in relation to your information, including the right to object to processing of your personal information for direct marketing or where the legal basis for our use of your data is our legitimate business interests or performance of a task in the public interest.

 

  1. Who we are

Throughout this document, “we”, “us”, “our” and “ours” refer to the Fitzwilliam Private Members Club and the Golden Horseshoe Limited.

“Fitzwilliam Private Members Card Club” means:

  • “The Fitzwilliam Casino and Card Club” an unincorporated partnership in Ireland, and the Golden Horseshoe Limited incorporated in Ireland with Limited Liability
  • Club premises:                                 Clifton Hall, Lower Fitzwilliam Street, Dublin 2.
  • Registered Office: 13 Fitzwilliam Square East, Dublin 2.
  • Registered Number: 338384

 

  1. The information we collect about you

There are a number of reasons for gathering information about you. For instance, we need to know how to get in touch with you, we need to be certain of your identity and we need to have some knowledge of your financial circumstances, so we can offer you services and give you the best possible customer experience. The information we collect falls into various categories.

 

  • Identity & contact information

Name, date of birth, copies of ID, contact details, security details to protect identity, nationality, address, email address, and personal phone numbers.

 

  • Financial details/circumstances

Source of income, occupation/employment status, transaction details, information relating to power of attorney arrangements.

 

  • Information you provide us about others or others provide us about you

If you give us information about someone else (for example, information about their financial circumstances), or someone gives us information about you, we may add it to any personal information we already hold and we will use it in the ways described in this Data Privacy Notice.

Before you disclose information to us about another person, you should be sure that you have their agreement to do so. You should also show them this Data Privacy Notice. You need to ensure they confirm that they know you are sharing their personal information with us for the purposes described in this Data Privacy Notice.

 

  • Sensitive categories of data

We may hold information about you which includes sensitive personal data, such as health or criminal conviction information. We will only hold this data when we need to for the purposes of the services we provide to you or where we have a legal obligation to do so. Examples of when we use this type of data include:

  • Medical information, for example, any history of addiction, any reports from a concerned friend or family member regarding your health or state of mind, requests for self-exclusion, requests to revoke a previous self-exclusion request, behaviour that could indicate a potential gambling problem.
  • If you have criminal convictions, we may process this information in the context of compliance with our anti-money laundering obligations.

 

  • Information about you provided by others

If you give us information about someone else, or someone gives us information about you, (for example, where another person provides information about you to us during the course of visiting the Club), we may add it to any personal information we already hold and use it in the ways described in this Data Privacy Notice.

  • Information which you have consented to us using
  • Your agreement to allow us contact you through certain channels to offer you relevant services.
  • Information from online activities.
  • We may collect information about your internet activity using technology known as cookies, which can often be controlled through internet browsers. For detailed information on the cookies we use and the purposes for which we use them, see our Cookie Policy, which is available on our website.
  • We may collect information about your internet browser settings or otherwise Internet Protocol (IP) and other relevant information to help us identify your geographic location when providing you with our services.
  • Other personal information
  • Telephone and image recordings.
  • CCTV images at our Club premises, offices and ATM (but only for security reasons, to assist with any internal investigations into breaches of policies and procedures, and to help prevent fraud or crime).
  • Information in relation to data access, correction, restriction, deletion, porting requests and complaints.
  • Sometimes we may collect and use your information even though you are not a customer of ours

For example, you may be a friend or concerned family member of a club member, a beneficiary, or representative of one of our customers, or you may be in the process of making an application to join the Fitzwilliam Private Members Club. If so, we will apply the principles outlined in this Data Privacy Notice when dealing with your information.

 

  1. When and how we collect information about you

As you use our services, make enquiries and engage with us, information is gathered about you. We may also collect information about you from other people and other parties, for example, when you are named in a media article, regulatory authorities, and from sources where you have chosen to make your information publicly available, such as social media sites.

 

When we collect information about you:

  • When you ask us to provide you with certain services. For example, a self-exclusion facility, may require us to collect relevant health information from you.
  • When you use our website and online services provided by us (including mobile applications) and visit our premises.
  • When you or others give us information verbally or in writing. This information may be on application forms, in records of your transactions with us or if you make a complaint.
  • When you use our services, including making transactions on your deposit account, we gather details about who you get money from, who you pay money to, how much the payments are for and when the payments are made.
  • From information publicly available about you – for example in trade directories, online forums, websites, Facebook, Twitter, YouTube or other social media. When you make information about yourself publicly available on your social media accounts or where you choose to make information available to us through your social media account, and where it is appropriate for us to use it, this information can help enable us to do things like (1) improve our service (for example, identifying common service issues), (2) personalise your experience with us, including through games, videos or apps, (3) contact you through the social media services, and (4) enable you to share your experience and content via social media services. For a description on how social media services and other third party platforms, plug-ins, integrations or applications use your information, please refer to their respective privacy policies and terms of use, which may permit you to modify your privacy settings.
  • From your online activities with third parties where you have given us your consent (for example, by consenting to our use of certain cookies or other location tracking technologies).
  • From credit reference agencies, credit registration agencies, fraud prevention agencies or public agencies such as property registration authorities, the Companies Registration Office or judgement registries.

 

Please note: you should only give personal information about someone else (for example, employment type, addiction issues) with their permission.

 

 

 

 

  1. How we use your information

Whether we’re using it to confirm your identity, to help in the processing of an application for a service or to improve your experiences with us, your information is always handled with care and the principles outlined in this Data Privacy Notice are always applied.

To provide our services to you, we use your information to:

  • Establish your eligibility for our services.
  • Manage and administer our services to you. For example, if you have a member’s deposit account we must retain records of your transactions.
  • Process your application for membership of the Club or retention of membership.
  • Carry out background checks. Where we make these searches, agencies may keep a record of the search.
  • Process payments that are paid to you or by you. For example, if you open a player’s deposit account we will keep a record of all transactions by you.
  • Run loyalty and reward programmes you have signed up to.
  • Contact you by post, phone, text message, email, social media, fax, or other means, but not in a way contrary to your instructions to us or contrary to law.
  • Monitor and record our conversations when we speak on the telephone or in person (for example, to check your instructions to us, to analyse, to assess and improve customer service and for training and quality purposes).
  • Manage and respond to a complaint or appeal.

 

To manage our business for our legitimate interests

To manage our business we may use your information to:

  • Provide service information, to improve our service quality and for training purposes

We may gather information about your interactions with us – for example, the games you play, CCTV of your activities in the Club.

 

  • Conduct marketing activities

For example, running competitions, promotions and direct marketing (provided that you have not objected to us using your details in this way), and research, including customer surveys, analytics and related activities.

  • To run our business on a day to day basis including to:
  • Carry out strategic planning and business management.
  • Compile and process your information for audit, statistical or research purposes (including, in some instances, making your data anonymous) in order to help us understand trends in our customer behaviour and to understand our risks better, including for providing management information, operational and data risk management.
  • Protect our business, reputation, resources and equipment, manage network and information security (for example, developing, testing and auditing our websites and other systems, dealing with accidental events or unlawful or malicious actions that compromise the availability, authenticity, integrity and confidentiality of stored or transmitted personal data, and the security of the related services) and prevent and detect fraud, dishonesty and other crimes (for example, to prevent someone trying to steal your identity), including using CCTV at our premises.
  • Manage and administer our legal and compliance affairs, including complying with our obligations to credit card providers, compliance with regulatory guidance and voluntary codes of practice to which we have committed.
  • Enable us to share or access your information for internal administrative purposes, audit, prudential, statistical or research purposes (including making your data anonymous) to help us understand trends in customer behaviour, for helping us to understand our risks better and for the purposes set out in this Data Privacy Notice (but not for the purposes of direct marketing where you have objected to this).

 

To comply with our legal and regulatory obligations

We need to use your information to comply with legal and regulatory obligations including:

  • Complying with your information rights.
  • Providing you with statutory and regulatory information and statements.
  • Establishing your identity and residence in order to comply with law and regulation concerning taxation and the prevention of money laundering, fraud and terrorist financing
  • We are required by law to screen applications that are made to us to ensure we are complying with the international fight against terrorism and other criminal activities. As a result, we may need to disclose information to government and other statutory bodies.
  • Preparing returns to regulators and relevant authorities including preparing income tax, capital gains tax, capital acquisition tax and other revenue returns.
  • Reporting to and, where relevant, conducting searches on industry registers.
  • Complying with binding requests from regulatory bodies, including the Revenue Commissioners, the Gardaí, and the Dept. of Justice.
  • Complying with binding production orders or search warrants, and orders relating to requests for mutual legal assistance in criminal matters received from foreign law enforcement agencies/prosecutors.
  • For other reasons where a statutory reason exists we do so.
  • Complying with court orders arising in civil or criminal proceedings.
  • Performing a task carried out in the public interest, for example engaging with a concerned friend or family member about a loved ones gambling habits.

 

Where you have given us permission (which you may withdraw at any time)

Where you have given us permission (which you can withdraw at any time) we may:

  • Send electronic messages to you about product and service offers from us or our selected and trusted partners.
  • Share your data with third parties so that they may send you electronic messaging about their products and offers.
  • Use transaction history/account information from your cash desk transactions, gaming table transactions, transactions on player’s deposit accounts or credit card to identify your spending habits in order to personalise offers that are exclusive and individual to you, based on your account transactions.
  • Use cookies in accordance with our Cookie Policy.
  • Use special categories of data, or sensitive data.
  • Use information you have made public and combine with this with the activities outlined above.

When we ask for your consent, we will provide you with more information on how we will use your data in reliance on that consent, including in relation to third parties we would like your consent to share your data with.

 

  1. How we use automated processing or “analytics” & our legal basis

We use automated statistical analysis of the information we collect about you as part of our business

  • Analysis of your information helps us to make automated promotional decisions
  • To decide the type of financial service suitable for you.
  • Approval for increased threshold limits generally takes account of information from three sources: (1) information you provide during your application, (2) information provided by other reference agencies, and (3) information that may already be held about you. Our credit scoring system will consider information from these sources to make an overall assessment of your application.

Where we make solely automated decisions that affect you in a legal or a significant way, you have the right to provide your point of view and have those decisions reviewed by a member of our team.

 

  • Automated analysis of our customer information (including your information) as a whole helps us to manage our business for our legitimate interests. It enables us to:
  • Make more informed business decisions, including improving the quality of services we can offer (including for the purposes of direct marketing, unless you have objected to us using your details in this way).
  • Test and maintain the stability and performance of our systems.
  • Carry out long-term statistical modelling, provided that such modelling does not affect any decision we make about you.
  • Automated analysis of your information also enables us to improve our services and helps us to form a single view of your relationship with the Fitzwilliam Club. This is intended to help us to manage and build our relationship with you and is an important part of managing our business in our legitimate interests.
  • Automated analysis of your information assists us to comply with our legal obligations.
  • For example, in connection with our money laundering, fraud and terrorist financing prevention obligations, we may use automated processing to screen for suspicious transactions, or to identify payments which may be subject to international sanctions.
  • There are certain automated analyses of your information that we will only carry out where you have given us your consent (which you can withdraw at any time).
  • We will only automatically process your information to enable us to undertake the following activities where we have your consent:
  • Send electronic messages to you about service offers from our Group and/or our selected trusted partners.
  • Share your data with third parties so that they may send you electronic messaging about their services and offers.
  • Use your transaction history/account information to identify your spending habits, in order to personalise offers that are exclusive and individual to you, based on your transactions. We will provide you with more information on this when we seek your consent.
  • Use your location data to send you information regarding special offers from us or our partners close to your location.
  • Use sensitive categories of data, as set out in data protection legislation.
  • Use information you have made public and combine this with the activities outlined above.

 

  1. Who we share your information with

We only share your information with a select number of individuals and companies, and only as necessary. Sharing can occur in the following circumstances and/or with the following persons:

  • Your authorised representatives:
  • These may include a family member,/attorney (under a Power of Attorney) and any other party authorised by you to receive your personal data.
  • Third parties we need to share your information with in order to facilitate payments you have requested (for example, BIC, IBAN, credit card issuers and merchant banks) and those you ask us to share your information with. However we do not obtain or store credit card or bank account details on any of our business systems other than receipts for transactions performed at your request.
  • Companies that provide support services for the purposes of protecting our legitimate interests.
  • Your personal information remains protected when our service providers use it. We only permit service providers to use your information in accordance with our instructions, and we ensure that they have appropriate measures in place to protect your information.
  • Our service providers include marketing and market research companies, analytics companies, investment companies, IT and telecommunication service providers, software development contractors, data processors, debit/credit card producers, computer maintenance contractors, printing companies, property contractors, document storage and destruction companies, custodians and providers of administration services, archiving services suppliers, debt collection agencies, budgeting and advice agencies, tracing agencies, receivers, liquidators, examiners, official Assignee for Bankruptcy and equivalent in other jurisdictions, auditors, ATM administrators and consultants, including legal advisors.
  • We may also share information with the following third parties to help us manage our business for our legitimate interests:
  • Trade associations and professional bodies, non-statutory bodies and members of trade associations such as the Gaming and Leisure Association of Ireland.
  • Persons making an enquiry or complaint.
  • Healthcare professionals and medical consultants.
  • Business partners and joint ventures. In such cases, we, our business partners or those involved in the joint venture will let you know that your information is being shared and who it is being shared with.
  • Statutory and regulatory bodies (including central and local government) and law enforcement authorities.
  • These include the courts and those appointed by the courts, government departments, statutory and regulatory bodies in all jurisdictions where the Bank of Ireland Group operates including: the Central Bank of Ireland, the European Central Bank, the Data Protection Commission, Financial Services Ombudsman, Credit Review Office, An Garda Síochána/police authorities/enforcement agencies, Revenue Commissioners, Criminal Assets Bureau, US, EU and other designated authorities in connection with combating financial and other serious crime, NAMA and its agents or other parties designated by or agreed with NAMA or designated under the relevant legislation, police forces and security organisations, ombudsmen and regulatory authorities, as well as fraud prevention agencies.

 

  1. How long we hold your information

The length of time we hold your data depends on a number of factors, such as regulatory rules and the type of service we have provided to you.

  • Those factors include:
  • The regulatory rules contained in laws and regulations or set by authorities like the Department of Justice.
  • Whether you and us are in a legal or some other type of dispute with another person or each other.
  • The type of data we hold about you.
  • Whether you or a regulatory authority asks us to keep it for a valid reason.
  • Whether we use your data for long-term statistical modelling, provided that such modelling does not affect any decision we make about you.
  • As a general rule, we keep your information for a specified period after the date on which a transaction has completed or you cease to be a customer. In most cases this period is Seven (7) Years.

 

  1. Implications of not providing information

Sharing information with us is in both your interest and ours.

  • We need your information in order to:
  • Provide our services to you.
  • Manage our business for our legitimate interests.
  • Comply with our legal obligations.
  • Of course, you can choose not to share information, but doing so may limit the services we are able to provide to you.
  • We may not be able to provide you with certain services that you request. We may not be able to continue to provide you with or renew existing services.
  • We may not be able to assess your suitability for our service, or, where relevant, give you a recommendation regarding taking a break from gambling or self-exclusion.
  • When we request information, we will tell you if providing it is a contractual requirement or not, and whether or not we need it to comply with our legal obligations.

 

  1. The legal basis for using your information

We will use your data and share that data where:

  • Its use is necessary in relation to the delivery of our service or because you have asked for something to be done so you can secure or retain membership of the Club.
  • Its use is in accordance with our legitimate interests outlined in this notice.
  • Its use is necessary because of a legal obligation that applies to us (except an obligation imposed by a contract). An example of this would be us sharing your information with the AML Inspectors in the course of an audit of the Club.
  • You have consented or explicitly consented to the using of your data (including special categories of data) in a specific way.
  • Its use is necessary to protect your “vital interests”.
  • In exceptional circumstances we may use and/or disclose information (including special categories of data) we hold about you to identify, locate or protect you, for example, if it comes to our attention that you are in imminent physical danger and this information is requested by An Garda Síochána or your relative.
  • Where you have made clearly sensitive categories of data about yourself public.
  • Where the processing of special categories of data is necessary for the establishment, exercise or defence of legal claims.
  • Where authorised by law or regulation, we may undertake processing of special categories of data for a substantial public interest.
  • Where the processing of criminal conviction data is authorised by EU or local law.

 

  1. Processing your information outside the EEA

Your information is stored on secure systems within the Club premises and with providers of secure information storage.

We may transfer or allow the transfer of information about you and your products and services with us to our service providers and other organisations outside the European Economic Area (EEA), but only if they agree to act solely on our instructions and protect your information to the same standard that applies in the EEA.

Using companies to process your information outside the EEA.

Some of our service providers, for example IT, telecommunication, credit reference agencies, payment processors, custodians and providers of administration services, tracing agents and contractors may be  based outside of the EEA. Where we authorise the processing/ transfer of your personal information outside of the EEA, we require your personal information to be protected to at least Irish standards and include the following data protection transfer mechanisms:

  • Confirmation from our service providers to ensure that any personal data leaving the EEA will be transferred in compliance with EU data-protection law.
  • Adherence to the EU/US Privacy Shield. You can find more information on the EU/US Privacy Shield at www.privacyshield.gov including a list of all organisations that have signed up to the EU/US Privacy Shield framework.

 

  1. How to exercise your information rights (including the right to object)

Providing and holding personal information comes with significant rights on your part and significant obligations on ours. You have several rights in relation to how we use your information. If you make your request electronically, we will, where possible, provide the relevant information electronically unless you ask us otherwise:

You have the right to:

  • Find out if we use your information, to access your information and to receive copies of the information we have about you.
  • Request that inaccurate information is corrected and incomplete information updated.
  • Object to particular uses of your personal data where the legal basis for our use of your data is our legitimate business interests (for example, profiling we carry out for our legitimate business interests) or the performance of a task in the public interest. However, doing so may have an impact on the services and products we can / are willing to provide.
  • Object to use of your personal data for direct marketing purposes. If you object to this use, we will stop using your data for direct marketing purposes.
  • Have your data deleted or its use restricted – you have a right to this under certain circumstances. For example, where you withdraw consent you gave us previously and there is no other legal basis for us to retain it, or where you object to our use of your personal information for particular legitimate business interests.
  • Obtain a transferable copy of certain data which can be transferred to another provider, known as “the right to data portability”.
  • This right applies where personal information is being processed based on consent or for performance of a contract and the processing is carried out by automated means. You are not able to obtain through the data portability right all of the personal information that you can obtain through the right of access. The right also permits the transfer of data directly to another provider where technically feasible. Therefore, depending on the technology involved, we may not be able to receive personal data transferred to us and we will not be responsible for the accuracy of same.
  • Withdraw consent at any time, where any processing is based on consent. If you withdraw your consent, it will not affect the lawfulness of processing based on your consent before its withdrawal.

We are obliged to respond without undue delay. In most instances, we will respond within one calendar month. If we are unable to deal with your request fully within a calendar month (due to the complexity or number of requests), we may extend this period by a further two calendar months. Should this be necessary, we will explain the reasons why. If you make your request electronically, we will, where possible, provide the relevant information electronically unless you ask us otherwise.

 

You have the right to complain to the Data Protection Commission or another supervisory authority. You can contact the Office of the Data Protection Commissioner at

https://www.dataprotection.ie/docs/Contact-us/b/11.html

 

Telephone:         +353 (0)761 104 800 or Lo Call Number 1890 252 231

Fax:                        +353 57 868 4757

E-mail:                  info@dataprotection.ie

Postal Address:                 Data Protection Commission, Canal House, Station Road, Portarlington, R32 AP23, Co. Laois.

  1. How to contact us and/or our Data Protection Officer

If you have any questions about how your personal data is gathered, stored, shared or used, or if you wish to exercise any of your data rights, please contact us at

 

Online: www.fitzwilliamcardclub.com

Telephone:         +353 (0)1 611 4677

E-mail:  dataprotection@fitzwilliamcardclub.com

Postal Address:                  Fitzwilliam Card Club, Clifton Hall, Lower Fitzwilliam St, Dublin 2

 

  1. Changes to this notice

We will update this Data Privacy Notice from time to time. Any changes will be communicated to you and made available on this page and, where appropriate, notified to you by SMS, e-mail or when you visit the Club.

 

 

 

 

Dated: 12.05.2018

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