PRIVACY POLICY
1 ABOUT OUR SOFTWARE PRIVACY POLICY
1.1 SRGH is registered with the Registrar of Companies for England and Wales, registration
number: N13070770.
1.2 Our websites http://www.SRGH.tech (including all pages with these domain names) and the
services provided on the White label casino are operated by SRGH TECH LTD, company
registration number 13070770, having its registered office at,
63-66 Hatton garden,
London
England EC1N 8LE
(“we”, “us” “SRGH” and “our”).
The White label casino Terms describe the SRGH Services provided to the public via the White
label casino.
1.3 This policy (together with our Terms and any other documents referred to in it) sets out the
basis on which any personal data we collect from you, or that you provide to us, will be processed
by us. Please read the following carefully to understand our views and practices regarding your
personal data, and how we will process it.
2 HOW WE COLLECT INFORMATION ON WEBSITE
2.1 When registering as a user of the White label casino, opening an Account or during your time
as a user of the White label casino you will be asked to provide information to us. You are required
to complete a registration form in which you must provide us with your details including but not
limited to, your title, gender, forename, and surname, date of birth, email, address, and phone
number. We will inform you at the time of collecting other information from you whether you must
provide the information to use the White label casino or specific Services or whether the provision
of information requested by us is optional.
2.2 You agree that your username and name may be shown to other users of the White label
casino. In all cases we will endeavour to inform you at the time of collecting the information from
you whether the information that you provide to us will be accessible to other users of the White
label casino or by third parties so that you can decide whether to provide the information to us.
2.3 We may collect and process the following data about you:
2.3.1 your title, gender, forename, surname, date of birth, nationality, email, address, phone
number, Account currency, Affiliate Partners reference (if applicable), username, encrypted
password, payment details, bank account details and Card details;
2.3.2 an internationally recognised photo ID (passport, driving licence), a utility bill, proof of
identity, residence and/or age, and/or a bank or credit card statement relating to your payment
details that are registered with us;
2.3.3 if you contact us, we may keep a record of that correspondence;
2.3.4 information that you submit in response to a survey(s) or poll;
2.3.5 details of transactions you carry out through the White label casino and your account number
with us;
2.3.6 details of your visits to the White label casino including, but not limited to Bets and
transaction records, traffic data, location data, weblogs and other communication data, whether
this is required for our own billing purposes or otherwise and the resources that you access; and
2.3.7 when you make a withdrawal from your Account, we may require the following from you to
effect the withdrawal and may carry out a security check:
(1) a photocopy of both sides of your Card clearly showing your signature;
(2) a faxed copy of your passport or driving licence;
(3) a copy of your Card statement header showing your billing address; and
(4) a completed SRGH Customer Authorisation Statement (CAS).
2.4 You acknowledge and agree that the information which you provide to any another company
in the SRGH Group for the purposes of registering for use of a website or service offered by the
other company in the SRGH Group is deemed to have been provided to us once you begin to use
of the White label casino for the purposes of accessing the Services.
2.5 We reserve the right to conduct credit checks with third party credit and financial institutions
in order to confirm any information that you have provided to us or to determine your ability to
perform this Agreement.
3 USES MADE OF THE INFORMATION
3.1 We collect and use information from users of the White label casino for the following purposes:
3.1.1 setting up, operating and managing your Account;
3.1.2 providing the Services requested by you from us using the White label casino and to carry
out our obligations arising from any contracts entered into between you and us;
3.1.3 reviewing and determining your eligibility to use the White label casino or open an account
with us;
3.1.4 to enable us to carry out statistical and other analysis;
3.1.5 verifying the accuracy of your information or the processing of Bets or transactions, including
disclosure of such information to third parties (including financial institutions, software providers,
identity verification, age verification and credit reporting agencies) in connection with such
purposes (a record of the search will be retained and the third party may use the information to
assist other companies for verification purposes);
3.1.6 verifying the payment details that you have provided to us, including the address of your
Card;
3.1.7 confirming the details that you have provided to us in relation to your Account;
3.1.8 verifying your eligibility to win or place a Bet on the White label casino;
3.1.9 contacting you using your contact details to tell you about changes to the White label casino
or Services, technical or security issues, updates and changes to this Policy or our Terms;
3.1.10 complying with our regulatory and legal obligations;
3.1.11 providing customer support services;
3.1.12 ensuring that content from the White label casino and the Services are presented in an
effective manner for you and for your computer;
3.1.13 providing you with information regarding our products or services that you request from us
or which we feel may interest you, where you have consented to be contacted for such purposes;
3.1.14 allowing you to participate in interactive features of our service or White label casino, when
you choose to do so; or,
3.1.15 reporting of crime or suspected crime, including money laundering or fraud.
3.2 In order to validate Account information we also reserve the right to request further information
from you prior to any withdrawals that you request to be made from your Account. You agree that
we can contact you using the contact details that you have provided to us for this purpose.
3.3 Except as set out in this Privacy Policy, we do not sell, rent, share, trade or give away any of
your personal information to third parties. We may give some of your personal information to third
parties who operate payment processors for purposes relating to the White label casino and
Services, to third party Affiliate Partners who/which direct users to the White label casino for the
purposes of confirming commission or other related purposes and to other third parties for the
purposes of verifying information that you provided to us (e.g. provision of information to banks
for verifying credit card payments).
3.4 We may also use your email address or your postal address to send you updates or news
regarding the White label casino or Services, but you may choose not to receive emails of this
type by accessing the “My Account” tab of the White label casino (http://_____.com) and updating
your “My Preferences” settings.
3.5 You agree that we can provide the personal data relating to you to any of the other SRGH
Group companies on your behalf should you decide to use the services of any other SRGH Group
companies’ website or services including, but not limited to, for the purposes of managing the
Account that you have with us and its use with regards to a SRGH Group company’s website or
services.
4 DISCLOSURE OF YOUR INFORMATION TO OTHER PEOPLE
4.1 We will not disclose to any third party personal information that you provide to us unless (i)
we have your permission, (ii) it is required or permitted by law, or (iii) your agreement with us
permits such disclosure.
4.2 If you provide personal information to us, you understand and agree that we may disclose
your personal information for the following purposes to the following third parties:
4.2.1 if you have indicated at registration, or at any time during your time as a user of the White
label casino, that you are happy to receive information or promotions from selected third parties
about goods and services which may be of interest to you, you consent to us sending your
information to such third parties so that they may provide you with such offers or information. You
may opt out of receiving such offers or change your preferences at any time by emailing
support@SRGH.com;
4.2.2 to any member of our group of companies, which means our subsidiaries, our ultimate
holding company and its subsidiaries;
4.2.3 to any prospective seller or buyer of any business or assets related to the White label casino
or all or part of SRGH Isle of Man in respect of the sale or insolvency and the ultimate seller or
buyer;
4.2.4 to a third party if we are under a duty to disclose or share your personal data with that third
party in order to comply with any legal obligation, or in order to enforce or apply our Terms and
other agreements, or to protect the rights, property, reputation, security or safety of SRGH Isle of
Man Limited, our White label casino, our customers or others; this includes (but is not limited to)
exchanging information with or providing information to third parties for the purposes of fraud
protection and credit risk reduction;
4.2.5 to any law enforcement or revenue authorities when requested to do so to the extent
necessary to adequately deal with the requests made or in order to facilitate their investigation of
payment fraud, tax payment or any unlawful or suspected unlawful activity;
4.2.6 to any operator, payment processor, verification service provider, marketing partners
that/who provide services to us in relation to the White label casino or Service, including any
person specifically named in our Terms or in other agreements that form part of our agreement
with you;
4.2.7 to your bank or Card scheme operator in order to verify the Card information or bank
information that you provide to us and/or to recover payments made to you in error, in accordance
with the Terms;
4.2.8 to any payment collection agency that we may decide to use in order to recover monies
owing by you to us;
4.2.9 to Racing UK, TBS and Trinity Mirror PLC or any of their group companies for the purposes
of facilitating those companies exercise their rights granted to them under the Terms or the
exercise of our rights;
4.2.10 to AttheRaces Limited, British Horseracing Board Limited or such other licensor of Race
Data from time to time, for the purposes of facilitating those companies exercise their rights
granted to them under the Terms or the exercise of our rights;
4.2.11 to Independent Betting Adjudication Service for the purposes of investigating a Query
made under the Terms; and/or
4.2.12 to our licensor, the Isle of Man Gambling Supervision Commission, which requires
unrestricted access to all player details and records in order to regulate the online gambling
industry and to ensure that it is conducted honestly and fairly and remains free from criminal
influence, or any other licensing or regulatory authority which we may deal with in relation to the
White label casino.
4.3 We do not disclose personal information about you to third parties (including advertisers or
marketing companies), but we may provide them with aggregate anonymised information about
White label casino users. For example, we may inform them that 500 men aged under 30 have
clicked on their advertisement or have played a particular game or Bet on a particular event on
the White label casino on any given day, or we might inform third parties regarding the number of
unique users who visit White label casino, the demographic breakdown of our community users
of White label casino or the activities that visitors to White label casino engage in while on White
label casino. We may also use such aggregate anonymised information to help advertisers reach
the kind of audience they want to target. We may make use of the personal data we have collected
from you to enable us to comply with our advertisers wishes by displaying their advertisement to
that target audience.
4.4 In connection with the provision of our Services or the proper operation of our White label
casino, we may need to transfer data, including personal information, to other companies not
incorporated in the same jurisdiction. You agree that we may transfer personal information we
hold about you to any country, including countries outside the European Economic Area, in
accordance with this Privacy Policy.
5 SECURITY AND CONTROL OF YOUR PERSONAL DATA
5.1 We will take all steps reasonably necessary to ensure that your data is treated securely and
in accordance with this Privacy Policy.
5.2 Where we have given you (or where you have chosen) a password which enables you to
access certain parts of the White label casino, you are responsible for keeping this password
confidential. We ask you not to share your password with anyone.
5.3 We have no obligation to monitor or moderate any user’s activity or use of the White label
casino, however we retain the right at all times to monitor, retain and disclose any information as
necessary to satisfy any applicable law, regulation, legal process or regulatory authority request,
to ensure that the Services are properly used, that this Agreement is being complied with or to
investigate a suspected breach of this Agreement.
5.4 We recognise that online security is an area of vital importance to you. It is an imperative that
you should be fully satisfied that your personal details are secure before you commence activities
with us. In an effort to increase the security associated with the transmission of information via
the Internet communication (which is an insecure method of communication by its very nature)
we use the SSL (Secure Socket Layer) mechanism that is built into your browser to manage the
communication between you and the White label casino. This means that any text you provide is
‘translated’ into extremely detailed encrypted code. Your data is only retranslated into text once it
is stored on our web server. Information such as personal details, credit or debit card numbers,
passwords and all account details are automatically coded. In addition, we have installed the
latest firewall technology. This process is intended to act as a secure barrier to detect any
unauthorised access to our server immediately. Furthermore, our White label casino utilises anti-
fraud checks throughout all transaction and payment processes. Once we have received your
information, we will use strict procedures and security features to try to prevent unauthorised
access.
5.5 Although we cannot completely guarantee the security of your data transmitted to the White
label casino, we will do our best to protect your personal data. You must understand, however,
that while we will take the steps set out in paragraph 5.4, any transmission of data by you over
the internet is carried out at entirely your own risk. You acknowledge that we are not responsible
for any intercepted information sent via the Internet, and you hereby release us from any and all
claims arising out of or related to the use of intercepted information in any unauthorised manner.
6 LINKS TO THIRD PARTY WEBSITES
6.1 The White label casino and Service may, from time to time, contain links to and from the
websites of our partner networks, advertisers and Affiliate Partners as well as third party websites
to which we have no affiliation. If you follow a link to any of these websites, please note that these
websites have their own privacy policies and that we do not accept any responsibility or liability
for these policies.
7 TELEPHONE SERVICES
Telephone calls to and from any of our telephone numbers may be recorded for training and/or
security purposes.
8 IP ADDRESSES AND COOKIES
8.1 We may collect information about your computer, including (where available) your IP address,
operating system and browser type, for system administration, statistical purposes. This is
statistical data about our users browsing actions and patterns, and does not identify any
individual.
8.2 For the same reason, we may obtain information about your general internet usage by using
a cookie file which is stored on the hard drive of your computer. Cookies contain information that
is transferred to your computer hard drive. On revisiting the White label casino our computer
server will recognise the cookie, giving us information about your last visit. They help us to
improve the White label casino and to deliver a better and more personalised service. They enable
us:
8.2.1 to estimate our user size and usage pattern;
8.2.2 to store information about your preferences, and so allow us to customise the White label
casino according to your individual interests; and
8.2.3 to speed up your searches.
8.3 You may refuse to accept cookies by activating the setting on your browser which allows you
to refuse the setting of cookies. However, if you select this setting you may be unable to access
certain parts of the White label casino. Unless you have adjusted your browser setting so that it
will refuse cookies, our system will issue cookies when you log on to the White label casino.
8.4 For information on how to control your cookies go to www.allaboutcookies.org.
9 ACCESS TO INFORMATION AND UPDATING, VERIFYING AND DELETING PERSONAL
DATA
9.1 At any time, you can make a written request to us to have access to all the personal
information that we hold about you. We reserve the right to charge you a small administrative
charge should you make such a request; the current maximum charge is £10 for responding to a
request.
9.2 You may inform us of any changes in your personal data and in accordance with our
obligations to you by contacting us at support@SRGH.tech; we will update or delete your personal
data accordingly. You can change relevant personal data through the My Account section within
the White label casino. It is your responsibility to tell us when information that you have provided
to us is out of date or needs to be amended.
10 COMPLETE CESSATION OF USE
If in the case you close your White label casino Account, your personal details saved in our system
will, be retained for so long as is reasonably necessary for us to ensure that we may enforce of
legal rights and to comply with the agreements that we have relating to our White label casino
and the Services, including in relation to any need we may have to demonstrate compliance with
law or to prosecute or defend of legal claims or allegations or legal proceedings.
11 CHANGES TO OUR PRIVACY POLICY
Any changes we may make to our Privacy Policy in the future will be posted on this page and,
where appropriate, notified to you by email. You should visit this page periodically to review any
changes to the Privacy Policy.
12 USER FEEDBACK AND COMPLAINTS
Questions, comments and requests regarding this Privacy Policy are welcomed and should be
addressed to support@SRGH.tech.