Live Solutions Ltd (“LSL”) respects the privacy of every individual whose personal information it handles. LSL will not be using your data to directly market products and services to you .
When this policy mentions “you” or “your” it refers to Presenters or anyone providing services from the Control Room or supervising the Services . When this policy mentions “we” , “us” or “our” it means LSL .
For the purposes of applicable legislation, including the EU General Data Protection Regulation, as amended or supplemented (the “Data Protection Laws”), LSL is the controller of your personal information which means that we determine the purpose of collecting the data and its processing. By processing we mean anything that can be done with the data e.g. obtaining it, holding it, organizing it disclosing it or destroying it . Your data includes non-digital data where it is held in a structured paper format and video recordings of you.
1 LAWFUL PROCESSING
In accordance with the Data Protection Laws, our legal basis for collecting and storing personal information about you is that such processing is necessary for our legitimate interest in running and promoting our business and is necessary for both you and us to perform our obligations under the Services Agreement. The key principles of Data Protection are attached – see Annex A.
2 INFORMATION WE COLLECT
There are three general categories of information we collect.
2.1 Information You Give Us
We collect information you share with us when you register as a Presenter.
(a) Account Information. When you sign up for a Presenter Account or to be part of the Control Room team we require certain information such as your name, email address, details concerning the location from which you will provide services to us and your date of birth. We also keep a record of your start and finish dates of your Services Agreement and the reasons for termination .
(b) Profile Information. We may also ask you to complete a profile, which may include your name and gender, your experience (whether sector specific or not ) and languages you speak and the degree of fluency. Certain parts of your profile (like your profile picture, first name or Presenter pseudonym and description) are a part of a Presenter profile page, and will be publicly visible to others. The latter will not apply to the Control Room team .
(c) Other Authentication-Related Information. To help create and maintain a trusted environment, we may collect identification (like a photo of your government-issued ID) or other authentication information.
(d) Payment Information. We (through our third party payment providers) collect your financial information to process payments to you via our third party payment providers (our “Payment Platform”) as well as keep records in connection with how we calculate sums we pay you and records of payment (“Compensation”)
(e) Communications with End Users and to and from the Control Room. When you communicate with End Users or Control Room ( or , in the case of the Control Room team when you communicate from the Control Room to a Presenter or the management at LSL), we collect information about your communication and any information you choose to provide.
(f) Other Information. Video footage of your providing Services to End Users ( for Presenters only) ; recruitment information including any data you provided to us during the recruitment process; videos or other information derived from your periodic check in when logging in to present Rounds to End Users (for Presenters only) ; and records of and concerning the training you have undertaken with us.
3 HOW WE USE INFORMATION WE COLLECT
We collect and use information about you for the purposes of providing, understanding, improving, and developing the LSL Websites , and to create and maintain a trusted and safer environment. Further, specific details of the purposes for which we collect and use your personal information are set out below.
3.1 Provide, Improve, and Develop the LSL Platform
3.1.1 We collect and use your personal information to:
(a) enable you to access and use the LSL Websites and back office ;
(b) enable you to communicate with us, End Users and the Control Room (in the case of Presenters ) and Presenters and us (in the case of the Control Room team ) ;
(c) operate, protect, improve and optimize the LSL services and experience, such as by performing analytics and conducting research;
(d) enable us to access and use our Payment Platform as well as calculate and pay the Compensation ;
(e) send you service or support messages, such as updates, security alerts, account notifications and training information.
3.2 Create and Maintain a Trusted and Safer Environment
3.2.1 We collect and use your personal information to:
(a) detect and prevent fraud, spam, abuse, security incidents, and other harmful activity;
(b) conduct investigations and risk assessments;
(c) verify or authenticate information or identifications provided by you;
(d) conduct checks against databases and other information sources;
(e) comply with our legal obligations under applicable laws;
(f) resolve any disputes with any of LSL, End Users and Third Party Operators and enforce our agreements with you and any third parties;
(g) enforce our End User Licence with End Users and the Services Agreement as well as other policies; and
(h) assist Third Party Operators to protect their businesses from End User fraud, disputes with End Users and in circumstances where the End User is displaying symptoms of problem gambling .
4 SHARING & DISCLOSURE
4.1 Profiles, Listings, and other Public Information
4.1.1 The LSL Websites allows us to publish Presenter information that may be visible to the general public in the games lobby For example, sections of Presenter pages, such as the Presenter’s picture and given name or pseudonym can be selected to be publicly visible to others;
4.1.2 Information we share publicly on the LSL websites may be indexed through third party search engines but this will normally require an End User to have logged on through his or her account . If public-facing content is amended, these search engines may not update their databases. We do not control the practices of third party search engines, and they may use caches containing your outdated information.
4.2 Service Providers
We share your personal information with a variety of third party service providers to help us provide services related to the LSL Websites. Service providers will be located inside or outside of the European Economic Area (“EEA”). For example, third party service providers may:
(a) verify or authenticate your identification;
(b) check information against public databases;
(c) assist us with background checks, fraud prevention, and risk assessments; and
(d) in the case of Third Party Operators to enable them to consider fraud by and disputes with End Users and whether an End User needs help for problem gambling.
4.3 LSL Payment Platform
LSL may share your personal information with third party payment providers as part of our provision of the Payment Platform.
4.4 Safety and Compliance with Law
4.4.1 LSL may disclose your information to courts, law enforcement or governmental authorities, or authorized third parties, if and to the extent we are required to do so by law or if such disclosure is reasonably necessary:
(a) to comply with legal process and to respond to claims asserted against you or LSL;
(b) to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability;
(c) to enforce and administer the Presenter Agreement the End User Licence and Control Room terms and conditions or other agreements with Third Party Operators (as defined in the Services Agreement);
(d) for fraud investigation and prevention, risk assessment, customer support, product development and debugging purposes; or
(e) to protect the rights, property or personal safety of LSL, its employees, its shareholders or officers , or members of the public.
4.5 Group companies
4.6 Content visible on third party websites
We will display parts of the LSL websites on sites operated by Third Parties using technologies such as widgets, iFrames and APIs. If your Listings are displayed on a third party site, information relating to you may also be displayed.
4.7 Tax Authorities
We will need to disclose to relevant fiscal authorities details of your Compensation and records of payment to you to administer our revenue and tax obligations.
4.8 Business Transfers
4.9 Aggregated Data
We may also share aggregated information (information about Presenters and the Control Room team) that we combine together so that it no longer identifies or references a Presenter and non-personally identifiable information for industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.
5 OTHER IMPORTANT INFORMATION
5.1 Analyzing your Communications
We may review, scan, or analyze your communications on the LSL websites for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, compliance by you with your Services Agreement and End Users support purposes. We use automated methods where reasonably possible. However, occasionally we may need to manually review some communications, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools. We will not review, scan, or analyze your communications to send third party marketing messages to you, and we will not sell reviews or analyses of these communications.
6 YOUR RIGHTS
6.1.2 If you reside in the EU and you request in writing copies of your personal information held by us, we will provide you with a copy of the personal information held by us as soon as practicable, and in any event not more than one month after receiving a valid request in writing. There will normally be no charge (or only a nominal one) to access your personal information.
6.2 Individuals also have the right to complain about the use of their personal information to the relevant body that governs information rights in the relevant jurisdiction, which in the UK, for example, is the Information Commissioner’s Office and in the Isle of Man, the Isle of Man Information Commissioner
6.3 Automated decision making - EU Residents: Access and Challenge Information Provided to Us By Third Parties
You are entitled to see within one month of receipt by us information third parties provide to us as part of our fraud detection, prevention and risk assessment efforts if all of the following factors apply:
(a) we use third parties to carry out automated checks or risk assessments;
(b) we make a decision which has legal consequences for you or which significantly affects you; and
(c) such decision is based solely on such automated checks or risk assessments.
If requested we will tell you the source and type of data obtained . You are entitled to challenge whether such data is correct .
7 YOUR ACCOUNT
7.1 Access and Update
Only you and we will have access to your account with us. You will access this via log in details known only to you comprising a user name and a password.
7.2 Account Cancellation
We will terminate your Account when your Services Agreement terminates.
We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. However, the Internet is not a 100% secure environment so we cannot guarantee the security of the transmission or storage of your information.
9 RETENTION OF PERSONAL INFORMATION
KEY PRINCIPLES OF DATA PROTECTION
LSL adheres to the principles relating to the processing of personal data set out in the General Data Protection Regulations which requires to be:
• Processed lawfully, fairly and in a transparent manner (Lawfulness, Fairness and Transparency);
• Collected only for specified, explicit and legitimate purposes (Purpose Limitation);
• Adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed (Data Minimisation);
• Not kept in a form which permits identification of Data Subjects for longer than is necessary for the purposes for which the data is Processed (Storage Limitation);
• Processed in a manner that ensures its security using appropriate technical and organizational measures to protect against unauthorised or unlawful Processing and against accidental loss, destruction or damage (Security, Integrity and Confidentiality);
• Not transferred to a country outside the EEA without appropriate safeguards being in place (Transfer Limitation);
• Made available to Data Subjects and Data Subjects’ rights in relation to their Personal Data should be respected (Data Subjects’ Rights and Requests).
LSL is responsible for and must be able to demonstrate compliance with the data protection principles listed above (Accountability).