GDC Media Limited, a subsidiary of Gambling.com Group Limited (Nasdaq: GAMB) (“GAMB”<\/strong>), is the owner of the websites operated by and on behalf of GDC. <\/p>\n The terms “GDC<\/strong>“, “we<\/strong>“, “us<\/strong>“, or “our<\/strong>” refer collectively to GAMB, and its current and future subsidiaries (“Group Members<\/strong>“). <\/p>\n GDC Media Limited has licensed the operation of certain GDC’s websites in certain geographic locations to other Group Members, including: <\/p>\n (a)\t all GDC websites operating in the United States to GDC America Inc.; <\/p>\n (b)\tcertain GDC websites operating in the area of the United States to Roto Sports, Inc., a GAMB subsidiary, under a sub-license from GDC America; and <\/p>\n (c)\tcertain GDC websites operating worldwide (excluding the United States), to NDC Media Limited. <\/p>\n This Privacy and Cookies Policy (“Policy”) describes the practices of GDC Media Limited and the Group Members involved in the operation of the GDC’s websites in different geographic locations and the rights and choices available to individuals regarding personal data. <\/p>\n GDC respects your privacy and is committed to protecting your personal data. Personal data means any information that relates to an identifiable individual. It does not include data where the ability to identify an individual has been removed (anonymous data).<\/p>\n This Policy describes your rights and choices regarding your personal data. It is important that you read the Policy carefully. If you have any questions about this Policy, including any requests to exercise your legal rights, please contact us as set out below.<\/p>\n We may alter this Policy at any time and from time to time as needed for certain services of GDC and to abide by local laws or regulations around the world, including by providing supplemental information to users in certain jurisdictions. This Policy does not apply to GDC’s processing of the personal data of its personnel, such as employees and contractors.<\/p>\n We also provide important additional information here that is solely applicable to individuals located (i) within the Member States of the European Union, countries in the European Economic Area, the United Kingdom, and Switzerland (collectively, “Europe” or “European”), (ii) in Brazil, and (iii) in California, Colorado, Connecticut, Nevada, Utah, and Virginia in the United States,: <\/p>\n Our websites 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, use or otherwise handle data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave any of our websites, we encourage you to read the privacy policy of every website you visit.<\/p>\n We collect personal data about individuals from various sources described below. Where applicable, we will let you know how we intend to use your data before collecting it, so that you can decide whether or not you wish to provide that information. We may collect, use, store and transfer different kinds of personal data about you (“Personal Data<\/strong>“) which we have grouped as follows:<\/p>\n “Personal Information<\/strong>” includes any information from which you can be personally identified, including your name, surname, email address, telephone number or mobile number. <\/p>\n “Profile Data<\/strong>” includes a username, password and a profile image that an individual may establish and upload on one of our websites or mobile applications, along with any other information that an individual enters into their account profile;<\/p>\n “Financial account data<\/strong>” includes payment card details or bank account details;<\/p>\n “Recruitment Process Data<\/strong>” includes the CV and any covering letter of a job applicant and notes taken for the duration of your recruitment process relating to a job application and interview of a job applicant, and other information supplied by a job applicant, such as professional credentials and skills, educational and work history, and other information of the type included on a CV or covering letter;<\/p>\n “Technical Data<\/strong>” includes internet protocol (IP) address, browser type and version, time zone setting and location, operating system and platform, and other technology on the devices you use to access our websites;<\/p>\n “Usage Data<\/strong>” includes information about how you use our websites.<\/p>\n We also may collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.<\/p>\n We may retain recordings of any telephone voice messages that you have left for our customer support teams.<\/p>\n We automatically collect Technical Data and Usage Data. If you are using a mobile device, we collect data that identifies your mobile device, device-specific settings and characteristics, app crashes and other system activity. <\/p>\n We do not collect any information about your race, ethnicity, religious or philosophical beliefs, gender or sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data. However, if you are applying for a job with us, we will collect information about criminal convictions and offences.<\/p>\n We may use different methods to collect data from and about you including the following:<\/p>\n Generally, our websites can be accessed and used without registration and without having to provide us any Personal Data (Personal Information, Profile Data, and\/or Recruitment Process Data). You may opt in to receive information about promotions, bonuses, bets, tips and strategy by subscribing to one or more of our mailing lists by providing your email address. You may any time opt out from receiving such communications by writing to us or clicking the “unsubscribe” button in any of our emails to you. In case you contact us, whether by email, through contact forms, or in other writings, we may keep a copy of that correspondence. We will not share your Personal Data with third parties for marketing purposes unless you have provided us with your express consent to do so and\/or, with respect to our Media Partners, you have consented to receive marketing communications from those Media Partners. You may withdraw your consent by contacting those Media Partners directly. You may not withdraw your consent given to our Media Partners by contacting the Group.<\/p>\n We may use your Personal Data for the purposes of:<\/p>\n Providing our services, which may include:<\/strong><\/p>\n For research and development<\/strong><\/p>\n We use the information we collect for our own research and development purposes, which include:<\/p>\n Marketing<\/strong><\/p>\n We may use your Personal Data to form a view on what services we think you may want or need or what may be of interest to you.<\/p>\n We may contact you with marketing communications using the Personal Data you have provided to us if you have actively expressed your interest in availing of our services or have availed of our services and, in any case, you have not opted out of receiving that marketing, to the extent permitted by applicable law. <\/p>\n You can ask us to stop sending you marketing messages at any time by contacting us using the details below or clicking on the opt-out link included in each marketing message. <\/p>\n Should you choose to opt out of receiving our marketing messages, we will continue to conduct our other relevant activities using your Personal Data, including sending non-marketing messages.<\/p>\n Managing our recruiting and processing employment applications<\/strong><\/p>\n We process Personal Data, such as information submitted to us in a job application, to facilitate our recruitment activities and process employment applications, such as by evaluating a job candidate for an employment activity, and monitoring recruitment statistics.<\/p>\n Complying with law <\/strong><\/p>\n We use your Personal Data as we believe necessary and appropriate to comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.<\/p>\n Compliance, fraud prevention and safety<\/strong><\/p>\n We use your Personal Data as we believe necessary or appropriate to (a) enforce the terms and conditions that govern our services; (b) protect our rights, privacy, safety or property, and\/or that of you or others; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.<\/p>\n With your consent<\/strong><\/p>\n In some jurisdictions, applicable law may require us to request your consent to use your Personal Data in certain contexts, such as when we would like to send you certain marketing messages. If we request your consent to use your Personal Data, you have the right to withdraw your consent any time in the manner indicated when we requested the consent or by contacting us. If you have consented to receive marketing communications from our third-party partners, including our Media Partners, you may withdraw your consent by contacting those partners directly (and not by contacting us).<\/p>\n To create anonymous data<\/strong><\/p>\n We may create anonymous data from your Personal Data and other individuals whose Personal Data we collect. We make Personal Data into anonymous data by excluding information that makes the data personally identifiable to you and use that anonymous data for our lawful business purposes. <\/p>\n We may have to share your data to the following parties: <\/p>\n Group Members<\/strong><\/p>\n We may disclose your Personal Data to other Group Members for purposes consistent with this Policy. <\/p>\n Service providers<\/strong><\/p>\n We may employ third parties to administer and provide services on our behalf (such as third parties that provide customer support, that we engage to host, manage, maintain, and develop our websites, mobile applications, and IT systems, and that help us process payments). These third parties may use your information only as directed by us and in a manner consistent with this Policy. These third parties are prohibited from using or disclosing your information for any other purpose.<\/p>\n Participants in the transaction processing chain<\/strong><\/p>\n We may share your Personal Data with companies in the transaction processing chain in connection with processing a payment transaction, such as merchants, banks or other card issuers, card associations, debit network operators and their members.<\/p>\n Professional advisors<\/strong><\/p>\n We may disclose your Personal Data to professional advisors, such as lawyers, bankers, auditors and insurers, in the course of the professional services that they render to us.<\/p>\n Transfers to third parties<\/strong><\/p>\n We may disclose your Personal Data to third parties, such as our Media Partners and other third-party business partners, in order to provide our services. When we carry out any sharing with third parties, we always ensure that there is an appropriate contract in place, that the information being shared is transferred in a secure way, and that we only share the minimal amount of your information necessary. We will never sell your information to any other third parties.<\/p>\n Where the third party is a data controller, they have the same obligations under data protection law to protect your data, as we do.<\/p>\n Where the third party is a data processor, we require that these third parties provide a sufficient guarantee that the necessary safeguards and controls have been implemented to ensure there is no impact on your data rights and freedoms.<\/p>\n Compliance with Laws and Law Enforcement; Protection and Safety<\/strong><\/p>\n GDC may disclose information about you to government or law enforcement officials or private parties as required by law, and disclose and use such information as we believe necessary or appropriate to (a) comply with applicable laws and lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; (b) enforce the terms and conditions that govern our services; (c) protect our rights, privacy, safety or property, and\/or that of you or others; and (d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.<\/p>\n GAMB is incorporated in the Channel Island of Jersey and GDC operates globally, with primary offices in United States and Ireland. The mailing address of our principal executive offices is 22 Greenville St., St. Helier, Channel Island of Jersey JE4 8PX. Your personal data may be transferred to other locations outside of your state, province, country or other governmental jurisdiction where we, our third-party partners, including our Media Partners, or our service providers maintain offices and where privacy laws may not be as protective as those in your jurisdiction. If we make such a transfer, we will require that the recipients of your personal data provide data security and protection in accordance with applicable law.<\/p>\n European users should read the important information provided below in Section 9 about transfer of personal data outside of your region \/ country.<\/p>\n We have put in place appropriate security measures which we believe reasonably prevents 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, subsidiaries, affiliates 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. We have put in place commercially reasonable 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.<\/p>\n We will process and store the relevant Personal Data for as long as it is necessary or required in order to fulfil our legal, contractual, or statutory obligations and\/or for the establishment, exercise or defence of legal claims.<\/p>\n In this section, we describe the rights and choices available to all users. Users who are located in Europe may read additional information about their rights in paragraph 9 below.<\/p>\n Marketing communications<\/strong><\/p>\n You can ask us to stop sending you marketing messages at any time by contacting us or clicking on the opt-out link included in each marketing message. You may continue to receive service-related and other non-marketing messages.<\/p>\n Choosing not to provide your Personal Data<\/strong><\/p>\n Where we request Personal Data directly from you, you do not have to provide it to us. If you decide not to provide the requested information, in some circumstances we may be unable to provide services to you. For example, we may be unable to process your transaction.<\/p>\n Accessing, modifying or deleting your information<\/strong> <\/p>\n In some jurisdictions, applicable law may provide a right for individuals to access, modify, or delete their Personal Data in some. You may contact GDC directly to request access to, modify or delete your information. We may not be able to provide access to, modify, or delete your information in all circumstances.<\/p>\n Complaints<\/strong><\/p>\n If you have a complaint about our handling of your Personal Data, you may contact our data protection officer using the contact information below. A complaint must be made in writing. Please provide details about your concern or complaint so that we can investigate it. We will determine whether to take action in response to your complaint, which, if we do so, may include conducting internal discussions with relevant business representatives. We may contact you for additional details or clarification about your concern or complaint. We will contact you to inform you of our response to your complaint. You also may have a right to file a complaint with a national or local regulatory agency.<\/p>\n Data Controller <\/strong><\/p>\n GDC is the data controller for the purpose of the General Data Protection Regulation (“GDPR<\/strong>“), and other applicable data protection laws. This means that GDC is principally responsible for looking after your Personal Data and this Policy determines the means and purposes of processing of Personal Data. <\/p>\n Legal bases for processing<\/strong>PURPOSE OF THIS POLICY<\/h2>\n
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THE PERSONAL DATA WE COLLECT <\/h2>\n
COLLECTION OF PERSONAL DATA<\/h2>\n
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USE OF PERSONAL DATA<\/h2>\n
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TO WHOM DO WE PROVIDE PERSONAL DATA<\/h2>\n
INTERNATIONAL TRANSFERS OF DATA<\/h2>\n
DATA SECURITY AND DATA RETENTION<\/h2>\n
YOUR RIGHTS AND CHOICES<\/h2>\n
ADDITIONAL INFORMATION FOR EUROPEAN USERS<\/h2>\n
\nWe are required to inform you of the legal bases of our processing of your Personal Data, which are described in the table below. If you have questions about the legal basis of how we process your Personal Data, please contact us at dataprotection@gdcgroup.com. <\/p>\n