Last updated: October 24, 2024

1. What does this notice cover?

This notice describes how Fat Cats Poker Limited (“Fat Cats Poker“, “we“, “us” or “our“) processes your personal data online and offline, including where you engage with our website or contact us, if you supply or partner with Fat Cats Poker or seek to join the Fat Cats Poker Community. It also describes your data protection rights, including a right to object to some of the processing which we carry out. More information about your rights, and how to exercise them, is set out in the “Your choices and rights” section.

2. What categories of personal data we collect:

We collect and process personal data about you when you interact with us and our websites, when you seek to join or participate in the Fat Cats Poker Community, when we carry out market research and when you or your employer engages with us as a customer or supplier. This will typically be provided directly by you. Depending on your engagement with us, it will include:

• Personal  information: your name and contact information, such as postal address, email address and phone number;
• Employment and business information: your position and employer, your work contact details and your interaction with us in your role, including information provided in the course of the contractual or client relationship between you or your organisation and Fat Cats Poker, or otherwise voluntarily provided by you or your organisation;
• Eligibility and screening information: information provided in the submission form on our website, including your age, details of your involvement in poker [please add any further information specifically requested in the submission form, particularly if it might be considered intrusive or unusual], and information obtained as a result of eligibility checks.
• Profile, Analytics and Usage Data: includes passwords to Fat Cats Poker websites or password protected platforms or services, your preferences in receiving marketing information from us, your communication preferences and information about how you use our websites(s), including the services you viewed or searched for, page response times, download errors, length of visits and page interaction information (such as scrolling, clicks, and mouse-overs). To learn more about our use of cookies or similar technology please check our cookies information below and our cookie management platform;
• Technical data: information collected during your visits to our website(s), the Internet Protocol (IP) address, login data, browser type and version, device type, time zone setting, browser plug-in types and versions, operating system and platform.

We collect most of this information from you directly. For example, data is collected through communications you send, or your engagement with Fat Cats Poker. We may generate or collect information about you ourselves. In an online context, much of this is set out in our cookies information below.

Sometimes, we receive information about you from third parties. For example, we may make use of third party background check providers or seek information about you from public sources or social media sites to confirm and assess your suitability and ability to meet our criteria to join the Fat Cats Poker Community. If you use a “like” or a “share” button for a feature on our sites or apps, then the third party will share information with us. If you participate in activities on third party sites or apps – such as participating in a Meta application – you may allow us to have access to personal data held by Meta, or other site or app owners. Where you are engaged by a Fat Cats Poker supplier or customer, we may receive information about you from your employer.

Fat Cats Poker collects, uses and stores your personal data for the following purposes, which in each case are justified by the legal basis set out in bold:

• Where necessary to fulfil, administer or manage your contractual relationship with Fat Cats Poker: we process your personal data where you are accepted into the Fat Cats Poker Community, and take steps pursuant to you being accepted into the Fat Cats Poker Community, including verifying your identity, managing our relationship and communicating with you about your membership.
• Where necessary to enable Fat Cats Poker’s business to function and pursue our legitimate interests, where these interests are not overridden by your data protection rights, in particular:
  • to assess your submission and suitability as a member of Fat Cats Poker Community
  • to investigate and respond to any comments or complaints you may send us;
  • to monitor use of our websites, platforms and services, and use your information to help us analyse, monitor, improve and protect our websites, communications, content and services, both offline and online, including profiling and personalising our services to our members.
  • to protect the security of our premises, assets, systems, and intellectual property and enforce company policies, including protecting ourselves from fraud and verifying the individuals with which we interact as appropriate.
  • for general business operations, including in connection with legal claims, compliance, regulatory, audit and investigative purposes (including disclosure of such information in connection with legal process or litigation, or to law enforcement bodies or to employers where appropriate). 
  • for market research or inviting you to participate in market research
  • for marketing purposes, where we are entitled to send you direct marketing without your consent. 
• Where necessary to comply with applicable laws: we process data where necessary to comply with laws. Sometimes it is also necessary for us to comply with the orders or instructions of the UK court and tribunals, the UK government and government bodies, regulatory bodies and other legal or regulatory processes or law enforcement bodies.
• Where you have given your consent: in circumstances where we seek your consent, such as to place non-essential cookies or to carry out direct marketing where we are required to obtain your consent. We will explain the purpose of our processing in any request for consent. Such processing shall be truly voluntary, and you shall be able to withdraw this consent at any time.

3. Cookies

When you visit one of our websites, we may also collect, process and use information about you and your use of the website, including any forums you visit and how you arrived at our site. Such information may be collected through “traffic data” and may entail the use of “cookies” or other tracking technologies, IP addresses or other numeric codes used to identify your computer.  For more information on Cookies please click on the link to our Cookie Management Platform.

4. How we share your personal data

We share your data where necessary for the purposes set out above, including with:

Other Fat Cats Poker Community Members and Entities

We share your personal data with other Fat Cats Poker Community Members and group entities, where this is necessary for the purposes set out above.

Government or law enforcement bodies

Personal data may be shared with government authorities and/or law enforcement officials as required for the purposes described above.

Tournament Hosts

We may share your personal data with potential tournament hosts, including casinos in London or abroad, to allow us to arrange or facilitate your participation in proposed Fat Cats Poker Community events.

Third party service providers

Personal data will also be shared with Fat Cats Poker’s third-party service providers (who will process it on our behalf). These third parties include background screening providers, IT service providers, website hosting providers, marketing suppliers and identity checking services. Some of our suppliers may be separate data controllers, such as market research organisations, lawyers and accountants. Where appropriate, they may provide you with their own privacy notice.

Sale of our business

In the event that Fat Cats Poker’s business is sold or integrated with another business, your details may be disclosed to our advisers and any prospective purchaser’s advisers and will be passed to the new owners of the business as required for the purposes set out above.

5. Where we transfer your personal data

We may transfer your data to some third parties which host or access personal data outside of the UK and EEA. In the event such an organisation is in a country which is not subject to an adequacy decision by the UK government or otherwise considered adequate as determined by applicable data protection laws, we take steps to ensure your personal data is adequately protected, including by adopting standard contractual clauses, unless we can rely on a relevant exemption.

A copy of the relevant mechanism can be obtained for your review on request by using the contact details below.

6. Your choices and rights

You have the right to ask Fat Cats Poker for a copy of your personal data; to correct, delete or restrict processing of your personal data; and to obtain the personal data you provide in a structured, machine-readable format. In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement). Where we have asked for your consent, you may withdraw consent at any time. If you ask to withdraw your consent to Fat Cats Poker processing your data, this will not affect any processing which has already taken place at that time.

These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law or have compelling legitimate interests to keep. If you have unresolved concerns, you have the right to complain to a data protection authority. In the UK, this will be the Information Commissioner’s Office.

Where we collect personal data to administer our contract with you or to comply with our legal obligations, this is mandatory and we will not be able to manage our relationship with you without this information. In all other cases, provision of the requested personal data is optional, but this may affect your ability to participate in certain programs or systems, where the information is needed for those purposes. For example, you may not be able to participate in additional offered benefits or programs, or a team activity, if you choose not to provide the relevant information.

7. How long we retain your personal data

Fat Cats Poker will retain and process personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements and, where required for Fat Cats Poker to assert or defend against legal claims, until the end of the relevant limitation period or until the claims in question have been settled.

Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data indefinitely so that we can respect your request in future.

We use the following criteria to determine retention periods:

• how long the data is needed to provide our services and operate our business;
• whether there are contractual or legal obligations that exist that require us to retain the data for period of time;
• whether any law, statute, or regulation allows for a specific retention period;
• whether an individual has agreed to a longer retention period;
• whether the data is considered to be sensitive data, and
• what the expectation for retention was at the time the data was provided to us.

8. Updates to this privacy notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new updated privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal data.

9. Contact us

The data controller for your personal data will be Fat Cats Poker.

If you have questions about this privacy notice or wish to contact us for any reason in relation to our personal data processing, please contact us at info@fatcatspoker.com.