Twinkle Casino ("we", "us", "our") is committed to protecting the privacy of any personal data that you provide to us or that we collect about you ("Personal Information"). Personal Information is information which identifies you and/or which relates to you, and may include your name, address, date of birth, payment card details, gaming history, account details, and any other information that we hold about you. We will be a controller (also known as a "data controller") in respect of your Personal Information. Controller is a legal term and means that we will be responsible for determining the purposes for which your Personal Information is processed.
We are part of the Jackpotjoy group of companies, which is headed by Jackpotjoy Plc. Our group owns and/or operates a number of great gambling brands, such as Jackpotjoy; Starspins; Jackpot Happy; Twinkle Casino; InterCasino; Costa Bingo; Sing Bingo; City Bingo; Costa Games; Slot Crazy; and Fantastic Spins. You can find a full list of our gambling brands here (https://www.verajohn.com/about/whoweare). Our Group includes companies such as Jackpotjoy Operations Ltd and Jet Management Group Ltd.
How we collect your Personal Information
If you provide your name, address or any other Personal Information on the public area of our websites, we will process this Personal Information also.
We may also collect Personal Information from third party service providers, such as fraud prevention companies.
Finally, we also use "cookies" which may collect certain information about you, such as your devices' IP addresses, which constitutes Personal Information. You can learn more about the cookies we use in the 'Cookies' section below.
How will we use your Personal Information?
In accordance with data protection laws, we will only process your Personal Information where we have a lawful basis for doing so. In respect of your Personal Information, these bases are: (i) where it is necessary to provide services to you under the performance of the contract we have with you; (ii) where we are required to do so in accordance with legal or regulatory obligations; (iii) where such processing is in the public interest; (iv) where you have given your consent; and, (v) where it is in our legitimate interests to process your Personal Information, provided that none of these prejudice your own rights, freedoms and interests.
The following are a list of the purposes for which we process your Personal Information, and the lawful basis on which we carry out such processing:
Disclosing your Personal Information
We may also disclose your Personal Information in the following circumstances:
・where required by applicable law or regulation to a governmental, regulatory or enforcement authority;
・in order to defend ourselves legally and/or in relation to legal proceedings; and
・if we undertake a group restructuring, and transfer the operation of this website to another member of our group;
・if we choose to outsource the operation of this website to a third party service provider; and/or
・whilst negotiating a takeover, sale, purchase or merger, financing, investment, restructuring or other proceeding involving the sale, transfer, divestiture or disclosure of all or a portion of our business or assets, and pursuant to the same.
Transferring your Personal Information outside of the EEA
We have implemented extensive technical and organisational measures to protect your data from loss, manipulation and unauthorised access. We are continuously monitored and reviewed by the regulatory authorities in the jurisdictions where we have gaming licenses. Security measures include, but are not limited to, digital and physical perimeter protection, asset management, access control and operational security controls. While we will use all reasonable endeavours to keep your Personal Information safe and secure at all times, you should note acknowledge that security can never be guaranteed and we may not be liable to you unless will not hold us liable save where your security is compromised due to our negligence.
We may engage the services of third party service providers and members of our Group to provide you with certain marketing services. We take steps to ensure that arrangements with these parties protect your privacy by ensuring that these parties comply strictly with our instructions when they are processing your Personal Information.
Marketing communications about the website
As a users of our website, you can tell us whether or not you wish to be contacted for marketing purposes and, if so, how we can contact you.
We may use your Personal Information to offer you personalised experiences on our website. We may deliver from time to time personalised content by using cookies to understand your behaviour and online preferences. To understand how cookies are used, please see the table above and the 'Cookies' section below.
Marketing communications about the website may contain details about:
・new games, jackpots and promotions available to you on our website;
・our loyalty programme (e.g. VIP), your rewards and promotional pay-outs on our website; and
・other promotional information about our website.
You can choose to opt-in to receive marketing communications from us about the website via the following channels:
・email marketing: when you opt-in on the website to receive marketing communications by email;
・SMS marketing: when you opt-in on the website to receive marketing communications by SMS;
・Phone Marketing: when you opt-in on the website to receive marketing communications by telephone;
・Post marketing: when you provide your contact details and have not opted-out from receiving marketing communications by post; and
・Push notifications: when you have installed our app on your device and enable push notifications in your device settings.
You can opt-out from receiving marketing communications from us about the website at any time by following the instructions below:
・Email marketing: to opt-out from emails, use the unsubscribe link provided within any email you receive or manage your preferences in your account;
・SMS Marketing: to opt-out from SMS, you can use the STOP code provided in any SMS you receive or manage your preferences in your account;
・Phone Marketing: to opt-out from being contacted by telephone for marketing purposes, you can manage your preferences in your account;
・Post Marketing: to opt-out from receiving mail marketing, you can manage your preferences in your account; and
・Push notifications: to opt-out from receiving push notifications, you can disable push notifications in your device settings.
When you choose to opt-out from email, SMS or phone marketing channels about the website, you will stop receiving marketing communications within 72 hours.
When you decide to opt-out from receiving post marketing about the website, please be aware it may take up to 28 days for your request to take effect.
Marketing communications about the other great gaming websites in our group
You can choose to opt-in to receive marketing communications from us about the other great gaming websites owned by companies in our group (https://www.verajohn.com/about/whoweare). These include other websites owned by us, and websites owned by Jackpotjoy Operations Ltd and Jet Management Group Limited. Don't worry, unless you register directly with those other gaming websites, they will not be able to send you marketing messages directly, and we will remain in control of whether marketing messages are sent to you. To the extent any members of our group are engaged by us to process your Personal Information on our behalf, we will ensure that these sister companies comply strictly with our instructions regarding such processing.
You can always change your contact preferences in the Account Settings section of Twinkle Casino.
Social Media Marketing
We may also use information you provide to us to show you relevant advertising and personalised content about our group's gaming websites on certain third party social media platforms (“Social Media Sites”) made available to us through those services (e.g. Facebook, Twitter). We do not control the way these Social Media Sites operate and collect your information, and you should read their respective privacy policies to understand how they use your personal information.
Cookies may be set by the website you are visiting (“first party cookies”) or they may be set by other websites who run content on the page or application you are viewing (“third party cookies”).
Our Cookies: We use a number of different cookies on this Website to help us to recognise you, track your activity and improve your use and experience of the Website.
In addition, we use a number of third party service providers, who also set cookies on this Website, in order to deliver the services that they are providing to us. Such services include, but are not limited to, helping us to improve your use and experience of the Website by tracking your activity on the Website, measuring the effectiveness of the Website and the effectiveness of our marketing campaigns.
What to do if you don’t want Cookies to be set: Some people find the idea of a website storing information on their computer or mobile (or other) device intrusive, particularly when this information is stored and used by a third party without them knowing. Although this is generally quite harmless, you may not, for example, want to see advertising that has been targeted to your interests. If you prefer, it is possible to block some or all cookies, or even to delete cookies that have already been set but you need to be aware that you might lose some functions of that website. Most online browsers automatically accept cookies. However, if you wish to restrict or block cookies you can modify your browser settings. Information on deleting or controlling cookies is available at www.AboutCookies.org.
Retention of your Personal Information
We will retain your Personal Information for the period necessary for us to provide you with our services and to comply with our legal and regulatory responsibilities. Accordingly, your Personal Information will be retained for a minimum of five years following the closure of your account (if applicable) or the last contact with us from you. Where it is no longer necessary for us to process your Personal Information, we will delete it sooner. If you request that you should not be able to access our websites, mobile applications and services (i.e. self-exclude), we will retain this information for a minimum of seven years.
Updating Your Personal Information
You can update your Personal Information at any time via your account. We request that where your Personal Information changes you update your account as soon as possible.
You have the following rights in relation to your Personal Information:
・a right to access your Personal Information as held by us (also known as a subject access request);
・a right to receive certain Personal Information in machine-readable format;
・a right to have inaccurate Personal Information rectified;
・where we have specifically requested your consent to process your Personal Information and have no other lawful basis to process it, you have the right to withdraw this consent; and ・a right to have certain Personal Information erased where it is no longer necessary for us to process it, where you have withdrawn your consent pursuant to the paragraph above, where you have objected pursuant to the paragraph below, where your Personal Information has been unlawfully processed, or where erasing your Personal Information is required in accordance with a legal obligation;
・a right to object to processing where our lawful basis for processing it is that it is in our legitimate interests, but please note that we may still process your Personal Information where there are other relevant lawful bases or where we have compelling grounds to continue processing your Personal Information in our interests which are not overridden by your rights, interests or freedoms;
・a right to request an explanation of the logic involved where we make decisions about you solely through automated means;
・a right to complain to your national data protection supervisory authority;
・a right to object to direct marketing, which can be done by opting-out of direct marketing either through your account or by opting out via the communication itself. You also have a right to object to any profiling to the extent that it relates to direct marketing only.
If you are unsure about your rights or are concerned about how your Personal Information may be processed, you should contact your national data protection supervisory authority.
If you would like to exercise any of your rights then you can do so by contacting us as described below. Please be aware that while we will try to accommodate any request you make in respect of your rights, they are not necessarily absolute rights. This means that we may have to refuse your request or may only be able to comply with it in part.
Where you make a request in respect of your rights we will require proof of identification. We may also ask that you clarify your request. We will aim to respond to any request within one month of verifying your identity. If we receive repeated requests, or have reason to believe requests are being made unreasonably, we reserve the right not to respond.