Jet Management Group Limited – Privacy Policy

Welcome to our privacy policy!

If you are a player of Costa Bingo, Sing Bingo, City Bingo, Costa Games, Slot Crazy, Fantastic Spins or any of our other great branded sites (the “Jet Sites“), then you can find out here how and why we handle your personal data.

Some information about who we are

We are Jet Management Group Limited, and we are committed to protecting the privacy of any personal data that you provide to us or that we collect about you (“Personal Information“). Personal Information is information which identifies you and/or which relates to you, and may include your name, address, date of birth, payment card details, gaming history, account details, and any other information that we hold about you.

We are a controller (also known as a “data controller”) in respect of your Personal Information. “Controller” is a legal term under data protection law, and it means that we are responsible for determining the purposes for which your Personal Information is processed.

The Jet Sites are all operated by a member of the 888 group of companies (“888“) on our behalf. If you are a member of any of the Jet Sites, then 888 is responsible for delivering gambling services to you in accordance with its gambling licences. This means that 888 is an independent data controller in relation to your Personal Information. If you want to learn more information about how and for what reasons 888 handles your Personal Information, please read 888’s privacy policy, which you can find on the on the home page of any Jet Site you are registered with (e.g. https://www.costabingo.com/regulation/privacy-policy )

In this Privacy Policy, we tell you about how we, Jet Management, collect your Personal Information, use your Personal Information, disclose your Personal Information, secure your Personal Information, market to you, use cookies, and retain your Personal Information. We also tell you about your rights in respect of your Personal Information, and how to contact us.

Our Group

We are part of the Jackpotjoy group of companies, which is headed by JPJ Group plc (the “JPJ Group“). The JPJ Group owns and/or operates a number of great gambling brands, such as Jackpotjoy; Starspins; Jackpot Happy; Vera&John; InterCasino; Costa Bingo; Sing Bingo; City Bingo; Costa Games; Slot Crazy; and Fantastic Spins (the “JPJ Sites“). You can find a full list of the JPJ Group’s gambling brands here. The JPJ Group includes companies such as Jackpotjoy Operations Ltd and Jet Management Group Ltd.

How the Jet Sites are operated

We have an agreement with 888, who operate all the Jet Sites. As the operator, 888 are responsible for delivering all Jet Site gambling services to you in accordance with applicable laws and the gambling licences they hold. Our brands are used to brand and promote the gambling services provided to you by 888. 888 collect Personal Information about you when you use any Jet Site, and share it with us. We use that Personal Information for a variety of purposes, as described below, such as marketing the Jet Sites and monitoring the business performance of the Jet Sites.

This means that we and 888 are each independent data controllers in respect of your Personal Information. Details of how and why we process your Personal Information is set out in this Privacy Policy. For details of how and why 888 process your Personal Information, please 888’s privacy policy, which you can find on the on the home page of any Jet Site you are registered with (e.g. https://www.costabingo.com/regulation/privacy-policy )

We may update this Privacy Policy from time to time, and therefore recommend that you review this Privacy Policy regularly. Where we make any material changes to this Privacy Policy, we will notify you that changes have been made.

How we collect your Personal Information

You will be asked to provide 888 with your Personal Information, such as your name, surname, username, password, security question, date of birth, home address, email address, phone number, mobile number, for the purposes of registering and opening an account. 888 also collects information about the transactions you make, including with respect to your transactions, deposits, balances, bets, withdraws, bonuses and winnings and your gaming activities generally.

888 regularly share some aspects of the Personal Information they have collected about you with us – this includes Personal Information which we reasonably need in order to market the Jet Sites. In certain instances, 888 may provide us with all of the Personal Information they hold on you – for example, if we arrange for someone else to run the Jet Sites instead of 888, then the Personal Information held by 888 would be transferred to the new operator.

Both we and 888 also collect information about your use of the Jet Sites and how you respond to advertisements and promotions. We also collect other information necessary for us to process your Personal Information for the purposes set out in this Privacy Policy.

We may also collect Personal Information from third parties, including service providers such as credit check or fraud prevention companies, and (if you have given us permission to do so) from your social media profile.

If you have an account with more than one of the JPJ Sites, then we may match your account, and combine the Personal Information which we hold with the Personal Information held by other members of the JPJ Group. This is explained in further detail below.

Finally, both we and 888 use “cookies” which may collect certain information about you, such as your devices’ IP addresses and information about how you navigate to and from the Jet Sites. You can learn more about the cookies we use in the ‘Cookies’ section below.

How we use your Personal Information

In accordance with data protection laws, we will only process your Personal Information where we have a lawful basis for doing so. In respect of your Personal Information, these bases are: (i) where we are required to do so in accordance with legal or regulatory obligations; (ii) where such processing is in the public interest; (iii) where you have given your consent; and, (iv) where it is in our legitimate interests to process your Personal Information, provided that our legitimate interests are not overridden by your own rights, freedoms and interests.

The following are a list of the purposes for which we process your Personal Information, and the lawful basis on which we carry out such processing:

Purpose	Lawful Basis
To receive and respond to your communications and requests	Consent or legitimate interests
To notify you about updates to the Jet Sites	Legitimate interests
To comply with our obligations under applicable laws	Necessary to comply with a legal or regulatory obligation
To identify and disclose any suspected unlawful, fraudulent, or other improper activity connected with the Jet Sites (including money laundering)	Necessary to comply with a legal or regulatory obligation
To prevent or detect unlawful acts or protecting members of the public against dishonesty, malpractice or other seriously improper conduct	Necessary to comply with a legal or regulatory obligation or necessary for reasons of substantial public interest
To carry out market research campaigns so that we can better understand the products and services that our customers most enjoy	Legitimate interests
To analyse how you and other players use the Jet Sites and respond to promotions and adverts, in order to identify relevant patterns and business insights, so that we can improve our products and services and provide tailored offers and recommendations	Legitimate interests
To build up your personal profile in order to gain a better understanding of your interests in our products and services, to make recommendations for games and other gaming websites owned by the JPJ Group that are relevant to you, and to improve the gaming websites owned by the JPJ Group	Legitimate interests
If you use other websites that are owned by us or by other companies in our group, to match your account details across those websites in order to build up your personal profile and gain a better understanding of your interests in the JPJ Group’s gaming websites and to provide you with tailored recommendations	Legitimate interests
If you use other websites that are owned by us or by other companies in the JPJ Group, to match your account details across those websites in order to carry out checks which may be required for regulatory or public interest purposes, or to prevent abuse of our services	Necessary to comply with a legal or regulatory obligation or necessary for reasons of substantial public interest or legitimate interests
To send you offers and promotions relating to our services or the services of other members of our Group that you may be interested in, provided that you have given your consent (and as more particularly described in the “Marketing” section below)	Consent
To send you offers about our other brands, provided that you have given your consent (and as more particularly described in the “Marketing” section below)	Consent
To provide you with ads on social media sites, except where you have requested not to receive such ads via your social media account	Legitimate interest
To record telephone calls to and from, and live chats with, our customer services representatives for training so that we improve our customer services and also for security and identification purposes	Legitimate interests in respect of training, and necessary for a legal or regulatory obligation in respect of security and identification
To prevent you from receiving marketing communications about the Jet Sites, if you have requested that we do so	Necessary to comply with a legal or regulatory obligation
To use your name, image, username or location in publicity and marketing, but only where you have provided your express and informed consent for us to do so	Consent
Cookies: those that are necessary for the operation of the Jet Sites, including allowing you to interact with the Jet Sites and to recall selections as you move between pages	Legitimate interest
Cookies: those that analyse your use of the Jet Sites and monitor our web audience so we can continue to analyse and improve our websites and services, and those that populate certain content on our websites in line with your usage so we can better tailor our websites to our customers	Consent
Cookies: Those that track your journey to and from the Jet Sites so we can understand how customers come to and from our websites and give effect to any commercial arrangements	Consent
Cookies: those that are necessary for regulatory compliance, including identifying multiple accounts, false logins or potential fraud	Necessary to comply with a legal or regulatory obligation
Cookies: those that are used for third party marketing	Consent

Disclosing your Personal Information

Your Personal Information may, for the purposes described above, be disclosed by us to any companies which are part of the JPJ Group and processed by such companies in accordance with this Privacy Policy. We may also send your Personal Information back to 888, in which case such Personal Information will be processed by 888 in accordance with its privacy policy.

We may also disclose your Personal Information to processors to provide services on our behalf. Such processors will only process your Personal Information in accordance with this Privacy Policy, and we will have a contract in place with each such processor to ensure your Personal Information is kept secure.

We engage service providers for the following services:

marketing services such as segmentation, analytics, email messaging, SMS messaging, telephone marketing, social media marketing and postal marketing service providers, and customer retention specialists, whether such services are provided directly to us or by means of us using third party software-as-a-service solutions;
storage, despatch and fulfilment companies;
IT services and security service providers;
customer support and customer relationship management software service providers;
data storage services: as well as storing data on our own servers, we also use server hosted by third parties, such as Melita [insert full name], and cloud storage service providers such as Amazon Web Services;
data analytics services to measure and understand our audience, tailor our marketing services, improve your website experience and data cleansing services to suppress our marketing lists; and
financial, audit, legal and compliance services.

We may also disclose your Personal Information in the following circumstances:

in the event that we engagement a replacement service provider to operate the Jet Sites, instead of 888, or we start to operate the Jet Sites ourselves;
where required by applicable law or regulation to a governmental, regulatory or enforcement authority;
in order to investigate or assist in preventing any violation or potential violation of law, this privacy notice, or our terms of use;
in order to defend ourselves legally and/or in relation to legal proceedings; and/or
in connection with or during negotiation of any potential sale or investment in any of the companies in the our group, or the 888 group of companies, or in the event of a corporate transaction (e.g. a sale of a substantial part of our respective businesses, merger, financing, restructuring, consolidation, acquisition, corporate divestiture, dissolution transaction, or other proceeding involving the sale, transfer, divestiture or disclosure of all or a portion of our business or assets).

In the event of an insolvency, bankruptcy, or receivership, your Personal Information may also be transferred as a business asset.

Transferring your Personal Information outside of the EEA

We primarily store and process Personal Information within the European Economic Area (“EEA”). However, in the following cases we can transfer your Personal Information outside the EEA:

if we have a legal or regulatory reason to do so;
if we use third parties service providers located outside of the EEA; or
if you have consented to the transfer.

If we do transfer your Personal Information outside the EEA, we will take all reasonable steps to ensure that adequate measures are in place to keep your Personal Information as secure as it is within the EEA, and in accordance with this Privacy Policy.

Security

We have implemented extensive technical and organisational measures to protect your data from loss, manipulation and unauthorised access. Security measures include, but are not limited to, digital and physical perimeter protection, asset management, encrypted communication, pseudonymisation of Personal Information, external and internal audit tests, access control and operational security controls. These safeguards vary based on the sensitivity of the information that we collect and store.

While we will use all reasonable endeavours to keep your Personal Information safe and secure at all times, you should note that security can never be guaranteed, and we may not be responsible for a breach of security in circumstances where we have taken all reasonable steps to prevent it.

Marketing

Subject to any preferences you have notified to us (where applicable) we use Personal Information to communicate with you and to keep you informed of our latest updates and special offers across different channels such as email, telephone, SMS, direct mail and push notifications. We do this in order to market the Jet Sites and, if you have given us permission to do so, other gaming brands owned by the JPJ Group.

We may engage the services of third party service providers and members of our group to provide you with certain marketing services. We take steps to ensure that arrangements with these parties protect your privacy by ensuring that these parties comply strictly with our instructions when they are processing your Personal Information.

Marketing communications about the Jet Sites

As a user of any of the Jet Sites, you can tell us whether or not you wish to be contacted for marketing purposes and, if so, how we can contact you.

We may use your Personal Information to offer you personalised experiences on the Jet Sites. We may deliver from time to time personalised content by using cookies to understand your behaviour and online preferences. To understand how cookies are used, please see the table above and the ‘Cookies’ section below.

Marketing communications about the Jet Sites may contain details about:

new games, jackpots and promotions available to you on the Jet Sites;
our loyalty programme (e.g. VIP), your rewards and promotional pay-outs on the Jet Sites; and
other promotional information about the Jet Sites.

You can choose to opt-in to receive marketing communications from us about the Jet Sites via the following channels:

email marketing: when you opt-in on any of the Jet Sites to receive marketing communications by email;
SMS marketing: when you opt-in on any of the Jet Sites to receive marketing communications by SMS;
phone Marketing: when you opt-in on any of the Jet Sites to receive marketing communications by telephone;
post marketing: when you provide your contact details and have not opted-out from receiving marketing communications by post; and
push notifications: when you have installed our app on your device and enable push notifications in your device settings.

You can opt-out from receiving marketing communications from us about the Jet Sites at any time by following the instructions below:

Email marketing: to opt-out from emails, use the unsubscribe link provided within any email you receive or manage your preferences in your account;
SMS Marketing: to opt-out from SMS, you can use the STOP code provided in any SMS you receive or manage your preferences in your account;
phone Marketing: to opt-out from being contacted by telephone for marketing purposes, you can manage your preferences in your account;
post Marketing: to opt-out from receiving mail marketing, you can manage your preferences in your account; and
push notifications: to opt-out from receiving push notifications, you can disable push notifications in your device settings.

When you choose to opt-out from email, SMS or phone marketing channels about the Jet Sites, you will stop receiving marketing communications within 72 hours.

When you decide to opt-out from receiving post marketing about the Jet Sites, please be aware it may take up to 28 days for your request to take effect.

Marketing communications about the other great gaming websites in our group

You can choose to opt-in to receive marketing communications from us about the other great gaming websites in our group. These include Jackpotjoy Operations Ltd and Dumarca Gaming Limited. Don’t worry, unless you register directly with those other gaming websites, they will not be able to send you marketing messages directly, and we will remain in control of whether marketing messages are sent to you. To the extent any members of our group are engaged by us to process your Personal Information on our behalf, we will ensure that these sister companies comply strictly with our instructions regarding such processing.

You can always change your contact preferences later by following our group opt-out instructions.

Social Media Marketing

We may also use information you provide to us to show you relevant advertising and personalised content about our group’s gaming websites on certain third party social media platforms (“Social Media Sites”) made available to us through those services (e.g. Facebook, Twitter). We do not control the way these Social Media Sites operate and collect your information, and you should read their respective privacy policies to understand how they use your personal information.

If you are a Facebook user, we may periodically use the Facebook Ads services to provide you with personalised content about our gaming websites. When you are logged into your Facebook account, we may provide you with personalised content. To provide this personalised content, Facebook may be sharing information with us that you have chosen to make available pursuant to your Facebook settings. You can read more information about how Facebook uses your information in their privacy policy. We may also show you personalised and targeted advertisements on your Facebook account. If you no longer want to receive personalised and targeted advertisements from us on Facebook, you can manage your advertising preferences and decide what you want or do not want to see by using the settings in your Facebook account. You can read more details about how to manage your ad preferences on Facebook here.

Cookies

About Cookies: In this privacy policy, we use the expression ‘cookie’ to refer to cookies and similar technologies for storing 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 numbers.

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 do lots of different jobs that improve your use of a website or application, like letting you navigate between pages efficiently, storing your preferences, and generally improving your experience of a website. 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.

Some websites, including our Website, will also use cookies to enable them to target their advertising or marketing messages (based, for example, on your location and/or browsing habits).

Cookies may be set by the website you are visiting (“first party cookies”) or they may be set by other websites who run content on the page or application you are viewing (“third party cookies”).

Our Cookies: We use a number of different cookies on our Website to help us to recognise you, track your activity and improve your use and experience of the Website.

In addition, we use a number of third party service providers (including 888), who also set cookies on the Website, in order to deliver the services that they are providing. Such services include, but are not limited to providing the services to you on the Website, helping to improve your use and experience of the Website by tracking your activity on the Website, measuring the effectiveness of the Website and the effectiveness of our marketing campaigns.

We and/or third parties may use cookies to collect or receive information from the Website and use that information to advertise to you on other websites. You can view the cookies used for such purposes on this Website and opt out of the collection and use of your information for such targeted advertising here: www.aboutads.info/choices.

What to do if you don’t want Cookies to be set: Some people find the idea of a website storing information on their computer or mobile (or other) device intrusive, particularly when this information is stored and used by a third party without them knowing. Although this is generally quite harmless, you may not, for example, want to see advertising that has been targeted to your interests. If you prefer, it is possible to block some or all cookies, or even to delete cookies that have already been set but you need to be aware that you might lose some functions of that website. Most online browsers automatically accept cookies. However, if you wish to restrict or block cookies you can modify your browser settings. Information on deleting or controlling cookies is available at www.AboutCookies.org.

Retention of your Personal Information

We will retain your Personal Information for as long as we reasonably require it for our legal or business purposes.

Please note that we may be required in certain circumstances to retain some aspects of your Personal Information indefinitely (for example, in order to prevent us from sending marketing communications to you when you have told us not to (i.e. self-exclusion)). We will take all necessary steps to ensure that the privacy of this information is maintained for the period of retention.

Updating Your Personal Information

You can update your Personal Information at any time via your account. We request that where your Personal Information changes you update your account as soon as possible.

We may also rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.

Your Rights

You have the following rights in relation to your Personal Information:

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

If you are unsure about your rights or are concerned about how your Personal Information may be processed, you should contact your national data protection supervisory authority.

If you would like to exercise any of your rights then you can do so by contacting us as described below. Please be aware that while we will try to accommodate any request you make in respect of your rights, they are not necessarily absolute rights. This means that we may have to refuse your request or may only be able to comply with it in part.

Where you make a request in respect of your rights we will require proof of identification. We may also ask that you clarify your request. We will aim to respond to any request within one month of verifying your identity. If we receive repeated requests, or have reason to believe requests are being made unreasonably, we reserve the right not to respond.

Contact Us

If you have any questions regarding our use of your Personal Information, or you would like to exercise any of your rights, please contact our DPO at DataProtection-Jet@jpj-ops.com.

Alternatively you can write a letter to:

Jet Management Group Limited
Attn: Data Protection Officer
Albany Financial Center, Suite 304
South Ocean Boulevard
New Providence,
The Bahamas

For any queries regarding the Privacy Policy, please contact us at: DataProtection-Jet@jpj-ops.com.

Companies in the group include:

Jackpotjoy Operations Ltd., which owns great brands like Jackpotjoy UK, Starspins, Botemania, Canal Bingo and Jackpot Happy.
Dumarca Gaming Limited, which owns great brands like Vera&John, InterCasino and Finlandia.
Jet Management Group Limited, which owns great brands like Costa Bingo, Sing Bingo, City Bingo, Fancy Bingo, Rio Bingo, Wish Bingo, Angry Bingo, Treasure Bingo, Monkey Bingo, Giant Bingo, Dino Bingo, Sparkly Bingo, Frozen Bingo, Farmyard Bingo, Season Bingo, Costa Games, Slot Crazy, Crocodile Bingo, Fantastic Spins, Deep Sea Bingo, Sweetshop Bingo, Kingdom of Bingo, Rewind Bingo, Sky High Slots, Slots Force, Real Deal Bingo, Bringo Bingo and Lucky Rainbow Bingo.

Jet Management Group Limited – Privacy Policy

Companies in the group include:

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