We appreciate that by law and subject to certain conditions, you have a number of rights concerning the personal information we hold about you. If you wish to exercise these rights, you should contact our Data Protection Officer using the details set out above in Section 3. These rights include the right to access, amend and erase the personal information we hold about you, the right to object to the processing of your data, the right to withdraw consent, and the right to data portability. You also have the right to complain to your data protection authority if you are concerned with how we process your information. In addition, you have certain rights relating to automated decision-making and ‘profiling’. Further information and advice about your rights can be obtained from our lead data protection authority, IDPC or from your country’s data protection regulator.
Right to access and rectify the information we hold about you
You have a right to request a copy of the personal information we hold about you, known as a data subject access request. You also have the right to request that information we hold about you which may be incorrect, or which has been changed since you first told us, is updated or removed. These requests are free of charge and can be sent by email to our Data Protection Officer at [email protected]
or by contacting Customer Services (see Section 3).
Right to delete your data
In some circumstances, you can ask us to erase personal information we hold about you (‘the right to be forgotten’). This includes when:
- the information is no longer necessary in relation to the purpose for which it was collected (as explained in our privacy notice);
- if you previously gave consent to the use of your information, but decide to withdraw it and we cannot justify another legal ground for using it under data protection law;
- we process your information based on our legitimate interests and we cannot demonstrate overriding legitimate grounds to continue processing the information;
- we don’t have a lawful ground under data protection law to process your information;
- the data has to be erased to comply with a legal requirement;
This right is subject to mandatory retention periods under EU/local laws.
Right to restrict processing
You have the right to ask us to restrict (‘block’ or ‘suppress’) the processing of your personal information. When processing is restricted, we can still store your information, but will not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in the future. This right is available to you when:
Right to Data Portability
- you dispute the accuracy of the personal information (while we verify matters);
- the processing is unlawful, and you object to the erasure of the information and request that we restrict processing instead;
- we no longer need the data, but you require it to establish, exercise or defend a legal claim; and
- we process your information for our legitimate business interests but you object and while we verify the grounds for continued processing.
You have the right to receive personal information you provide to us, in a ‘commonly used machine-readable format’. This allows you to obtain and reuse your information for your own purposes across different services. For example, if you decide to switch to a different provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability. This is not a general right however, and only arises when the processing of your information is:
Right to object
- based on your consent or where it is necessary for the performance of a contract, and
- when the information is processed by solely by automated means
Based on your particular situation, you can object to the processing of your personal information, that is:
- based on our legitimate business interests (including profiling); or
- done for research and statistical purposes
You also have the right to object to the use of your personal information for direct marketing purposes (including profiling), such as when you receive emails from us notifying you about other Kindred Group services which we think will be of interest to you.
Right to withdraw consent
When we rely on your consent as the basis to process your personal information – such as for sales and marketing communications (see section 5D) – you have the right to withdraw your consent at any time. We’ll always strive to make it easy for you to withdraw consent by choosing an “unsubscribe” option in every communication you receive from us. If you find this isn’t the case, then just get in touch with our Data Protection Officer in the ways outlined above in Section 3, and we’ll try to fix things ASAP.
Rights related to automated decision making, including profiling
We sometimes use systems to make automated decisions based on your personal information. This helps us to make sure our decisions are quick, fair, efficient and correct, based on what we know. These automated decisions can affect the products, services or features we may offer you now or in the future, or the ability to use our services.
We may use automate decisions making in the following situations:
- tailoring products and services – we may pace you in groups with similar customers (segments) to study and learn about preferences and your needs, and offer more tailored experience for you;
- detecting fraud - we use your personal information to help decide and detect if your account may be being used for fraud or money-laundering. If we think there is a risk of fraud, we may block or suspend the account;
- opening account - when you open an account with us, we check that the product or service is relevant for you, based on what we know. We also check that you meet the conditions needed to open the account. This may include checking age, residency, nationality or financial position;
- risk assessment connected to your bet, as more particularly explained in section 5A.
Data protection law seeks to safeguard individuals against harm that may arise from decision-making - including profiling - that takes place without human intervention. You have the right not to be subject
to a decision - including profiling - when it is based on the automated processing of your personal information and it has a legal effect or a similarly significant effect on you.
Please note that the right does not apply
when the processing is:
- necessary for entering into or for the performance of a contract with you; or
- when it is authorised by law; or
- when it is based on your explicit consent.