Privacy Policy - Help Bwin Zambia

Customer Privacy Notice

Who are we?
The information we collect about you
How we use your personal data
Who we may pass your data onto
Location that we may transfer your personal data to
Your rights
How to contact us / Our Data Protection Officer
Changes to this Policy

Who are we

Wave Digital Zambia Limited is a member of Entain Group of companies and this Notice explains what your personal data will be used for.

We are committed to protecting your personal data when you use our services through our website and mobile application and take the security of your information very seriously. We have strict security measures in place to protect your personal data which includes robust security procedures which are regularly tested and reviewed. If you have any concerns about the way in which we process or protect your personal data or would like to contact us about any aspect of this policy, please get in touch through the contact details at the bottom of this statement.

This privacy notice should be read in conjunction with our cookies notice, any notices or terms located within the stores and our site terms of use / terms and conditions.

What you are consenting to when you agree to our Privacy Policy

When we ask you to confirm your acceptance of our Privacy Policy, you are providing your consent for us to:

Process your personal data for the purposes we have indicated above under the section “what we use your personal data for”
Disclose your data to our suppliers, business partners and other entities that we have indicated above under the section “Who we share your data with”

Transfer your personal data and special category data to locations outside of Zambia, as indicated above in the section “Locations that we may transfer your personal data”.

The Information we collect about you

We will collect personal data about you from the following sources:

When you register for an account with us
When you visit our website or our social media sites
Through surveys you complete
When you communicate with us (by email, mail, phone, in store or through chat, including chat rooms or social media)
When we undertake analysis of your interaction with us
From our other group companies for internal reasons, primarily for business and operational purposes
From public sources of information such as public records or social media postings
From cookies and tracking devices on your devices where you have permitted their use
From third parties’ databases to comply with our legal and regulatory obligations
From vendors and service providers s and from customer lists lawfully acquired from third-party vendors

What you are consenting to when you accept our terms and conditions and our Privacy Statement

The processing of your personal data for the purposes set out below
The disclosure of your personal data to our suppliers and sub-suppliers and to the organisations and reasons set out in the section on “who we share your data with”
The transfer of your data outside of Zambia to other locations within the Entain Group or where our suppliers are located outside of Zambia

What We Use your Personal Data for

Typical Personal Data	Further information	Legal basis in addition to Consent
Provision of products or services	Your name, telephone number or online identity or other contact information you provide to us. Log in information Game Transactional information and payment methods	To meet our obligations arising from any agreements entered into between you and us and provide you with the information, products and services that you request from us, including information about changes to our website, services or our terms, conditions and policies.	Performance of contract Legal obligations
Customer Service matters	Name, online identity, Account notes and communications, call recordings Game Transactional information and payment methods IP Address, MAC address, Device type, apps, location	To provide you with customer services, answer your questions or address your complaints or concerns.	Performance of contract Legitimate interests in player satisfaction, protecting our business and our customers in relation to responsible gambling
Meeting our legal and regulatory obligations	Name, Online Identity, Player ID, Contact Information Games played, bets, winnings and losses, deposits and withdrawals, payment methods Online images of play and screenshots IP Address, MAC address, Device type, apps, location.	To discharge our legal and regulatory obligations and duties which include (but are not limited to) Gambling License obligations, Anti-money Laundering, Anti-fraud & Anti-terrorism laws. This may include electronic methods of identifying you, such as through the use of cookies and images on online play.	Legal obligation Protect the vital interests of data subjects and others Performance of a task carried out in the public interest Legitimate interests in protecting our business, staff and customers
Identity Checks and Age Verification	Name, Online Identity, Contact Information, date of birth and gender Log in details, websites and webpages visited Game Transactional information and payment methods IP Address, MAC address, Device type, apps, location Historic communications and account notes, Call Recordings	To meet our Gambling License obligations To check your or validate your identity, age and protect your information This may include electronic methods of identifying you, such as through the use of cookies	Performance of contract Legal obligation Protect the vital interests of data subjects and others Performance of a task carried out in the public interest
Undertake Surveys competitions and promotions	Name or online identity Contact details, phone number Contact preferences Responses to surveys, click through on marketing, preferred products, feedback you provide	To invite you to take part in competitions, to provide us with feedback on your experiences, take up promotions or to keep you informed about products of services which may be of interest to you. To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you. You may opt out of receiving direct marketing communications at any time.	Legitimate interests to understand our customer’s views and encourage greater interaction with our customers
Prevention and Detection of Crime, Prevention of loss Protection of staff and customers	Name, Online Identity, Contact Information Log in details, websites and webpages visited Games played, bets, winnings and losses, credits and withdrawals, payment methods Online images of play and screenshots IP Address, MAC address, Device type, apps, location Risk scores, profile classifications Historic communications and account notes List of active software applications and active processes while using our website, including access to files and site-related program folders	To prevent or detect crime, fraud, theft or loss to our business and our customers and prevent the use of unfair practices in our websites or potential breach of our General Terms and Conditions and of applicable law. To protect our staff and other individuals from harm or loss. This may include monitoring online activity, electronic methods of identifying you, such as through the use of cookies, your online transactions and payments.	Performance of a task carried out in the public interest Legitimate interests to protect our customers, business and workers.
Business sale, acquisition and rights	Name, Online Identity, Player ID, Contact Information Log in details, websites and webpages visited Games played, bets, winnings and losses, credits and withdrawals, payment methods IP Address, MAC address, Device type, apps, location Risk scores, profile classifications Historic communications and account notes	To exercise or defend legal claims or acquiring or selling a business	Legitimate interests to protect and defend our business

Much of the information we collect about you is required to meet our legal and regulatory obligations, such as Gambling License requirements and Global Money Laundering laws, however, where we ask for your consent to process your personal data, you are not required to provide it, however, if you do not do so, you may not be able to take advantage of our services.

We may also store more sensitive personal data about you (often referred to as “special categories of personal data”) which may come directly from you, from other sources as described above or from decisions we have made about you.

Some of these decisions or actions we may take in managing your account or meeting our legal obligations may involve fully automated decisions. We will however always provide you with contact details where you can ask for a review of the decision or get further information from us.

Who we share your data with

We may need to share personal information with other organisations to ensure that we meet our legal obligations or where we need support in meeting your needs or our contractual obligations. We may also share information with other organisations where we consider it to be in the public interest or in the legitimate interest of ourselves or these other parties. These other parties are typically:

business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
our affiliates and selected third parties, where you have expressly opted-out of receiving marketing from us / third parties, have been barred or self-excluded, in which case we may share suppression lists with our affiliates and selected third parties, to ensure you do not receive unsolicited marketing;
members of the Entain Group and third party suppliers and service providers for any of the purposes identified in the table above; third party suppliers and service providers to the extent they assist the Entain Group with its legal / regulatory obligations e.g. providers of services in respect of anti-money laundering, fraud, verification etc.;
selected third parties so that they can contact you with details of the services that they provide, where you have expressly opted-in/consented to the disclosure of your personal data for these purposes;
analytics and search engine providers that assist us in the improvement and optimization of our site and other selected third parties;
other 3^rd party organisations who ask, encourage or collate feedback and any online views of your experiences with us to help us improve and optimize our services;
banks, credit card companies and relevant agencies and payment providers who may share with third parties for the purpose of investigating and safeguarding against underage, fraudulent, criminal or suspicious activity or safer gambling (or other activities we are bound by law, regulation or guidance to investigate and safeguard against) or if we have reason to believe that you have undertaken such activity; and
our regulators, law enforcement or fraud prevention agencies, as well as our legal advisers, courts, applicable independent adjudication services and betting integrity organisations and any other authorised bodies, for the purposes of investigating any actual or suspected criminal activity, maintaining standards of behaviour in gaming or other regulatory or legal matters.

We may share your personal information with other members of the Entain Group for marketing purposes. We will not share it with other 3^rd party organisations however unless you have expressly opted-in/consented to the disclosure of your personal data for these purposes.

We may also disclose your personal information to third parties in the following circumstances:

in the event that we consider selling or buying any business or assets, in which case we will disclose your personal data to any prospective sellers or buyers of such business or assets;
in the event of any insolvency situation (e.g. the administration or liquidation) of Entain Group plc, or a data controller or any of its group entities;
if we, or substantially all of our assets, are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;
in order to enforce or apply our website terms of use;
if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or regulatory requirements, or otherwise for the prevention or detection of fraud or crime;

How long we retain your personal data

Type of Data	Typical Retention Time	Information
Customer Call recordings	3 years	An extended retention may be applied on a case by case basis
CCTV	30 days	An extended retention may be applied on a case by case basis
Customer Data	A 7-year retention period which starts to run from the date your account is closed	We will only continue to hold personal data relating to your account (i) where we are under a legal requirement under gambling or tax legislation to retain your data; and (ii) to exercise or defend our legal rights.

The above retention times may be extended for example where it is needed to meet a specific regulatory obligation, investigate a crime, handle a claim or resolve a complaint.

Locations that we may transfer your personal data

From time to time, service providers, members of the Entain Group and organisations with whom we work with, may be located in other countries. We will, however, always use every reasonable effort to ensure sufficient protections are in place to safeguard your personal data. We will also ensure that our service providers enter into compliant processing agreements with us to ensure that your personal data is processed in a lawful manner.

Security

We take compliance with security regulations, standards, guidelines and privacy laws very seriously and promote security measures that will maintain the confidentiality, integrity and availability of personal data. We use reasonable organisational, technical and administrative measures to protect customer personal data from unauthorised access, alteration, disclosure or destruction of personal data that we hold.

As a business, we have secure firewalled datacentres, certified encrypted webpages and we are ISO27001:2013 certified. We also take steps to ensure our subsidiaries, agents, affiliates and suppliers employ adequate levels of security across the business.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to prevent unauthorised access attempts.

Marketing Communications and your choices

When we first collect your personal data, we’ll ask you to tell us how you would like to hear from us in future about our other products and services. It’ will normally be via a tick boxes on forms or web page and you can opt-out at any time.

What is ‘Opting Out’?

The term opt out refers to several methods by which individuals can avoid receiving unsolicited product or service information. This ability is usually associated with direct marketing campaigns such as telemarketing, e-mail marketing, or direct mail.

*Please consider that ‘opting out’ will not prevent any essential customer correspondence e.g. bet or account correspondence.

How can I opt out of marketing correspondence?

If you do not wish to receive any offers, promotions, information on events and tailored communications based on your account activity, you can request to be made un-contactable by:

Using the “unsubscribe” option provided in any marketing communication you receive
changing your preferences on your account settings
contacting our Customer Support department.

What details do you require from me?

We would need as much of the following as possible, to ensure that you are not sent any further unwanted correspondence:

Your full name
How we contacted you, i.e. email, SMS, or post
The mobile number or email/postal address we contacted you on
The mobile number or email address that the message came from
The date(s) and time(s) you were contacted
A copy of the message you were sent (e.g. a screenshot or a forwarded email sent to our customer care team)

Your rights

	Description of Right
Right 1 The right of access	You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights.
Right 2 The right to be informed	A right to access personal data held by us about you.
Right 3 The right to rectification	A right to require us to rectify any inaccurate personal data held by us about you.
Right 4 The right to erasure	A right to require us to erase personal data held by us about you. This right will only apply where (for example): we no longer need to use the personal data to achieve the purpose we collected it for; or where you withdraw your consent if we are using your personal data based on your consent; or where you object to the way we process your data (in line with Right 6 below). This right is not absolute and will not apply when legitimate and overriding reasons apply.
Right 5 The right to restrict processing	In certain circumstances, a right to restrict our processing of personal data held by us about you. This right will only apply where (for example): you dispute the accuracy of the personal data held by us; or where you would have the right to require us to erase the personal data but would prefer that our processing is restricted instead; or where we no longer need to use the personal data to achieve the purpose we collected it for, but you require the data for the purposes of dealing with legal claims.
Right 6 The right to data portability	In certain circumstances, a right to receive personal data, which you have provided to us, in a structured, commonly used and machine-readable format. You also have the right to require us to transfer this personal data to another organisation, at your request.
Right 7 The right to object to processing	A right to object to our processing of personal data held by us about you where the processing of such data is necessary for the purposes of our legitimate interests, unless we are able to demonstrate, on balance, legitimate grounds for continuing to process personal data which override your rights or which are for the establishment, exercise or defence of legal claims.
Right 8 The right not to be subject to automated decisions including profiling	A right for you not to be subject to a decision based solely on an automated process, including profiling, which produces legal effects concerning you or similarly significantly affect you.
Right 9 The right to withdraw consent	A right to withdraw your consent, where we are relying on it to use your personal data (for example, to provide you with marketing information about our services or products).
Right 9 The right to lodge a complaint	You have the right to complain to the relevant Data Protection Authority. In Zambia, this is the Data Protection Commissioner’s Office

Contact Us or Our Data Protection Officer

If you have any questions about this notice or would like further information about your rights, please contact by one of the following means:

By email: [email protected].

Our Data Protection Officer be also be contacted at the above address or by emailing [email protected].

Questions, comments and requests regarding this privacy policy are welcomed.

Changes to this Privacy Policy

Any changes to this privacy policy in the future will be posted on this page, and where appropriate, notified to you by email. Please check back frequently to see any updates or changes to this privacy policy.
This policy was last reviewed and updated: 05.07.2022

Customer Privacy Notice

What is ‘Opting Out’?

How can I opt out of marketing correspondence?

What details do you require from me?

CONTACT US