When you interact with us through our website (or otherwise) you may provide, or we may collect, certain information from which you are personally identifiable (which may be referred to as personal data). For the purposes of the General Data Protection Regulation or “GDPR” (and all other laws relating to the use your personal data), we are the “data controller”, meaning that we are responsible for deciding how your personal data is used and more importantly, for keeping your data safe and only using it for legitimate reasons.
We are committed to protecting your privacy and will take all steps necessary to comply with our legal obligations when using your personal data. This Data Protection explains how we fulfill this commitment, so please read this carefully.
You may provide us with the following types of personal information when you register with Bespoken DMCC or otherwise when you directly interact with us (when using our website or otherwise):
|Reason why we use the data||What data||Legal ground for using the data|
|Register you as a Bespoken customer||Identity, Contact, Profile, Social||Performance of a contract with you|
|Enable you to log-in to your Bespoken account||Identity, Contact, Social||Performance of a contract with you|
|Enable you to participate in a Bespoken competition||Identity, Contact, Financial, Surprise||Performance of a contract with you|
|To process payments which you make through our website||Identity, Contact, Financial||Performance of a contract with you|
|For internal administration and record keeping purposes||All||Performance of a contract with you|
Necessary to comply with a legal obligation
Necessary for our legitimate interests (for effective business administration and service provision)
|Notify you of changes to our Data Protection, our Terms and Conditions or other changes to our services or products||Identity, Contact||Performance of a contract with you|
Necessary to comply with a legal obligation
|Answer your enquiries which may involve contacting you by post, e-mail or phone||Identity, Contact||Performance of a contract with you|
Necessary for our legitimate interests (to ensure our customers are informed and satisfied with our services)
|Get in touch with you about relevant Bepoken competitions, products and services||Identity, Contact, Profile||Necessary for our legitimate interests (to develop our business, including our competitions, products and services)|
|Improve and personalize your experience of the Bespoken website by delivering more relevant content and advertising whilst you browse||Identity, Contact, Profile, Usage, Technical||Necessary for our legitimate interests (to develop our business, improve our website and overall user experience and inform our marketing strategy)|
|Administer the Bespoken website, including website trouble shooting, testing and analysis and to enable you to participate in interactive features of our website||All||Performance of a contract with you|
Necessary for our legitimate interests (to ensure that our website is fully functional and operating in the most effective way for you)
|Verify your identity and detect fraud and security issues||All||Necessary for our legitimate interests (to prevent and detect fraudulent activity, security incidents and criminal activity)|
|Give you the opportunity to provide us with feedback through reviews and surveys||Identity, Contact, Profile, Usage, Technical||Necessary for our legitimate interests (to develop our business, promote new products and services, obtain feedback from customers to improve our services)|
Technical– IP address, browser type, hardware type, network and software identifiers, device information, operating system and system configuration
The table below sets out how we use your personal data and our lawful basis for doing so. We may process your personal data for more than one lawful basis depending on the specific purpose for which we are using it. Importantly, we will only use your personal data when the law allows us to.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
In addition to the above, we may also anonymous and aggregate your personal data in a way which means you cannot be identified. This may be helpful to us for testing our internal systems, carrying out research and general customer data analysis. Because this is not personally identifiable, we can use this for any purposes.
Importantly, we do not pass your personal data onto any third parties for them to market their products/services to you. If in the future we decide that we want to, we will only do so if we have your consent. We do however share your personal data with third parties to help us deliver our products and services to you in the most effective way possible. These include third parties who assist us with:
In addition to the above, we may also be required to share your personal data with third parties if required by law or regulation. In such circumstances, we will make sure that the disclosure is only to the extent required by law or regulation.
We adopt industry standard security processes to ensure your data is kept safe and secure and to prevent unauthorized access or use or loss of your data. By way of example, we use secure server software (EV SSL), which encrypts all information you input before it is sent to us. We also make sure that third parties who need to handle your data when helping us to deliver our services are subject to suitable confidentiality and security standards. Despite the security measures we implement, please be aware that the transmission of data via the Internet is not completely secure. As such, we cannot guarantee that information transmitted to us via the Internet will be completely secure and any transmission is at your own risk.
We will keep your data for as long as you hold a Bespoken account and/or where you are still happy to hear from us about our latest news, products and services. Once you no longer wish to be engaged with Bespoken we may still need to keep hold of your data if there is a legal reason for doing so (such as for tax purposes where you have made purchases to play in our competitions or where we need to resolve any disputes with you).
If we amend our Data Protection, or we make any substantial changes, we will email you if it’s appropriate.
In certain situations, you are entitled to:
If you want to exercise any of these rights, please contact us. You don’t have to pay a fee to exercise your rights, unless your request is clearly unfounded, repetitive or excessive (in which case we can charge a reasonable fee). Alternatively, we may refuse to comply with your request in these circumstances. Where your request is legitimate, we will always respond within one month (unless there is a legal reason to take longer, such as where your request is particularly complex). We may also need you to confirm your identity before we proceed with your request if it is not clear to us who is making the request. In addition to the above, you may get in touch with the ICO (Information Commissioner’s Office) if you are concerned about the way in which we are handling your personal data. However, where possible, we would really appreciate you speaking with us first if you have any concerns.
You can opt-out of any Bespoken marketing at any time either by contacting us or by using the opt-out function detailed in the relevant marketing email. Please note that we may still need to send you service notifications by email, such as advising you of updated privacy terms or terms of play.
We do not pass your data onto any third parties for their marketing purposes. However, should there be any need in the future we will always get your consent. You can then opt-out from any third party marketing at anytime following the same process as above.
If you would like to discuss anything in this policy or if you want to exercise your rights, please get in touch:
Telephone: +971 4 2438778