Les Ambassadeurs Club Privacy Policy under UK GDPR

1. Introduction

This Privacy Policy explains how personal data is collected, processed, retained and shared in connection with the use of services provided by Les Ambassadeurs Club. The policy applies to all individuals who interact with the company, including registered account holders, visitors to physical premises or digital platforms, and any person who makes contact directly.

For the purposes of applicable data protection law, Les Ambassadeurs Club acts as a data controller in relation to the personal data it handles. As data controller, the company determines the purposes and means of processing personal data and is responsible for ensuring that all processing activities comply with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

This policy should be read in full. By using the services of Les Ambassadeurs Club or by providing personal data to the company, you acknowledge that you have read and understood the contents of this Privacy Policy.

2. Data Collected

Personal data is collected and processed only to the extent necessary for the operation of services and for compliance with legal and regulatory obligations. The categories of personal data that may be collected include:

Full name, date of birth and contact details, including postal address, email address and telephone number.
Identity verification documents, including copies of passport, driving licence and proof of address.
Financial information required for account management and customer due diligence purposes.
Records relating to gaming activity and responsible gambling indicators.
Occupation and source of funds information where required under anti-money laundering obligations.
Communications sent to the company, including correspondence with customer support.
Technical data collected when interacting with digital services, including device identifiers and usage logs.

Personal data is not collected beyond what is necessary for the purposes described in this policy.

3. Lawful Basis for Processing

Personal data is processed only where at least one lawful basis exists under UK GDPR. The lawful bases relied upon are:

Performance of a contract: Processing is necessary to provide services to you and to manage your account.
Compliance with a legal obligation: Processing is required to meet obligations under applicable law, including Gambling Commission licence conditions, the Money Laundering Regulations and anti-fraud requirements.
Legitimate interests: Processing is necessary for the legitimate interests of Les Ambassadeurs Club or a third party, provided those interests are not overridden by your rights and interests. This may include internal operations, risk management, fraud prevention and service improvement.
Consent: Where consent is relied upon as a lawful basis, for example in relation to certain marketing communications, consent may be withdrawn at any time.

Where special category data or data relating to criminal offences is processed, an additional condition under Schedule 1 of the Data Protection Act 2018 is identified, including where processing is necessary for the prevention or detection of unlawful acts or for the protection of the public against dishonest or improper conduct.

4. Use of Personal Data

Personal data collected by Les Ambassadeurs Club is used for the following purposes:

Verifying identity and conducting customer due diligence in accordance with regulatory obligations.
Managing accounts and providing access to services.
Detecting, investigating and preventing fraud, money laundering and other unlawful activity.
Complying with conditions imposed by the Gambling Commission and other applicable regulators.
Monitoring gaming activity for responsible gambling purposes, including identifying potential indicators of harm.
Conducting profiling and segmentation for internal operational and compliance purposes.
Communicating in relation to accounts, including service notifications.
Sending marketing communications where consent has been provided or where a legitimate interest exists, subject to the right to object.

5. Retention of Personal Data

Personal data is retained for as long as necessary to fulfil the purposes for which it was collected and in accordance with legal and regulatory obligations. In many cases, applicable legislation requires records to be retained for a minimum period following the end of a customer relationship. Under the Money Laundering Regulations, certain records must be retained for a period of five years from the end of the business relationship or the date of an occasional transaction.

Where erasure of personal data is requested, the request will be assessed in accordance with UK GDPR. Erasure may be refused or delayed where retention is necessary to comply with a legal obligation or to establish, exercise or defend legal claims.

Les Ambassadeurs Club may share personal data with third parties in the following circumstances:

With risk and fraud prevention agencies for the purpose of detecting and preventing financial crime and other unlawful activity.
With payment processors and financial institutions where necessary for account management and transaction processing.
With law enforcement agencies, courts or regulators where required by law or where disclosure is necessary to protect the rights, property or safety of Les Ambassadeurs Club, its customers or others.
With the Gambling Commission and other regulatory bodies in connection with licence obligations.
With third-party service providers that process data on behalf of Les Ambassadeurs Club, including customer service providers and technology suppliers, under contractual arrangements that require them to protect personal data in accordance with applicable law.
With other companies within the same corporate group where necessary for internal administrative purposes.

Personal data is not sold to third parties. Any sharing of personal data is conducted on the basis of a lawful ground under UK GDPR and is limited to what is necessary for the relevant purpose.

7. International Transfers

Where personal data is transferred outside the United Kingdom, appropriate safeguards are implemented in accordance with UK GDPR. This may include transfers to countries that have been assessed as providing an adequate level of data protection, or transfers subject to standard contractual clauses or other approved transfer mechanisms.

8. Your Rights

Under UK GDPR and the Data Protection Act 2018, individuals have the following rights in relation to their personal data:

Right to be informed: The right to receive clear and transparent information about how personal data is used, as set out in this policy.
Right of access: The right to submit a Subject Access Request to obtain a copy of the personal data held. A response will be provided within one calendar month of receipt of a valid request.
Right to rectification: The right to request correction of inaccurate or incomplete personal data.
Right to erasure: The right to request deletion of personal data in certain circumstances, subject to legal retention obligations.
Right to restriction: The right to request restriction of processing of personal data in certain circumstances.
Right to data portability: Where processing is based on consent or contract and is carried out by automated means, the right to request that personal data is provided in a structured, commonly used and machine-readable format.
Right to object: The right to object to processing based on legitimate interests, including processing for direct marketing or profiling purposes. Where an objection is made to direct marketing, that processing will cease without delay.
Rights related to automated decision-making: Where decisions are made based solely on automated processing that produce legal or similarly significant effects, the right to request human review of that decision.
Right to withdraw consent: Where processing is based on consent, the right to withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
Right to lodge a complaint: The right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection matters, if personal data has not been handled in accordance with applicable law.

9. Cookies and Technical Data

Cookies and similar tracking technologies are used on digital services operated by Les Ambassadeurs Club. Information about the types of cookies used, their purposes and the options for managing cookie preferences is set out in a separate Cookie Policy.

10. Contact and Complaints

Questions about this Privacy Policy, requests to exercise data protection rights, or concerns about data processing practices can be raised using the contact details provided on the Contact page of the relevant website or service.

If a concern or complaint is not resolved, it may be escalated to the Information Commissioner’s Office. The ICO can be contacted via ico.org.uk or by post at:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

11. Updates to This Policy

This Privacy Policy is reviewed periodically and may be updated to reflect changes in practices, legal obligations or regulatory requirements. The current version of the policy is made available on the website. Where changes are material, reasonable steps will be taken to notify users.

Les Ambassadeurs Club Privacy Policy