TheGambleDoctor takes the processing of your personal data seriously. We advocate fair and transparent data processing in accordance with the applicable rules.
This privacy policy explains how we process your personal data on this website.
Data responsibility and contact information
TheGambleDoctor is the data controller for the processing of the personal data that we obtain from you. Our contact details are the following:
E-mail address: support @thegambledoctor.com
You are welcome to contact us should you have any questions regarding our processing of your personal data.
TheGambleDoctor is based in Denmark and act under Danish law. This privacy policy is originally written in Danish. If any translated versions of this privacy policy conflicts with the original Danish version, then the Danish version applies. We reserve the right to make changes to our Privacy Policy and any such changes shall become effective immediately.
We process the following data about you
We may process the following personal data about you:
- Name
- E-mail address
- Phone number
- User-ID
- Facebook-image
- IP-addresses
- Log files about your behaviour on the website, including pages you have visited on the domain.
- Time stamp
- Address
- Country
- Date of birth
- Other cookie data that may contain personally identifiable data.
Purpose and legal basis for processing
Purpose
The purpose with our processing of your personal data is the following:
- To market offers that are presented on this website and to send newsletters, if you have given your consent.
- To process customer support related inquiries.
- Analysis of on-page activities and the visitors’ use of the website.
- To prevent hacker attacks.
When you use the website we collect personal data from you. You cannot use the website without us collecting some personal data about you, which you are noticed about in the pop-up consent form when you visit the website the first time. The personal data we collect from is your behaviour on the site. For example, which pages you visit, when, how long, and your IP-address. IP-addresses are collected to monitor any irregular traffic patterns and is an important tool for us in prevent hacker attacks. Furthermore we are able to block visitors if their IP-addresses show that they are in a location with gambling restrictions.
We only process your personal data in the scope necessary to fulfil the purposes described above, for which the data is collected.
Legal basis
We are obligated to inform you about the legal basis for processing your data, which is the following:
- That you have given consent to the processing, cf. Databeskyttelsesforordningen (Data Protection Regulation) article 6, paragraph 1, point a.
- That the processing of personal data is made in consideration of preventing hacker attacks based on a balancing of interests that precedes your basic rights and freedom right, cf. Databeskyttelsesforordningen (Data Protection Regulation) article 6, paragraph 1, point f.
Profiling
Profiling is defined as “any form of automatic processing of personal data that consists of using personal data to evaluate certain personal data regarding the person’s work, economic situation, health, personal preferences, interests, trustworthiness, behaviour, geographical position or movements.”
We use automatic decisions, hereunder profiling to define target groups based on geographical locations and interests. The profiling is taking place based on you having expressed interest for gambling by visiting this website. Hereafter you can expect to be presented for banners on other websites, just as you may be presented for adverts on Facebook and other social media channels we use to reach our target audience(s). Furthermore it will be registered wherefrom you access this website, and the geographical location may influence how we create campaigns. We will target campaigns to specific geographic locations in the event we based on accumulative profiling data can conclude that there is a big interest for our marketing in specific cities/areas.
Where your personal data stems from
It is registered when you interact with us either by visiting this website directly or indirectly. This could be by interacting with our Facebook page or if you have signed up on the site’s mailing list. This can lead to you being presented with targeted marketing ads.
All data stems from the registered. In the case that you have interacted with our brand on Facebook then Facebook acts as an intermediary between the registered and us, because we receive the data through Facebook.
Facebook does not provide us with personally identifiable data about you when we use their platform other than the outlined types of personal data in paragraph 3, unless you actively interact with our brand on Facebook.
Business partners
Transmission
We transmit your data to third parties if we have received your explicit consent to do so or if it is necessary in order to fulfil a legitimate interest. These third parties are listed below:
- Authorities to the extent we are committed by legislation.
Data processors
To be able to provide you the best service we use the following data processors:
- LeadByte Ltd.
- Google Ltd.
- Facebook Ltd.
- Sendgrid Ltd.
- Campaign Monitor Ltd.
- Ubivox Danmark ApS
- Microsoft Ltd.
- Innocraft Ltd.
- Match2One AB
- Digital Ocean LLC
- DRH Internet Inc. (Green Arrow)
- Ontraport
- SendX
- Aweber
Transfer to a third country
We will transfer your personal data to recipients outside the EU and EEA.
The transfer will be to the following U.S.-based organizations: Facebook Ltd., Google Ltd., Sendgrid Ltd., Microsoft Ltd. and Campaign Monitor Ltd. Furthermore a transfer of personal data will happen to Innocraft Ltd. which is based in New Zealand.
The EU Commission has made a decision on the level of security of personal data and in this it appears that the level of security in the U.S. is not sufficient. However, the EU Commission has determined that organizations based in the U.S. are ’safe areas’, if they have joined the EU-U.S. Privacy Shield agreement.
The EU Commission considers New Zealand a safe third country.
We transfer data to following U.S.-based organizations that are part of the Privacy Shield agreement:
- Facebook Ltd.
- Google Ltd.
- Sendgrid Ltd.
- Microsoft Ltd.
- Ontraport
- SendX
The transfer of personal data to Campaign Monitor Ltd. is in accordance with the EU Commission’s Standard Contract.
Deletion
Your personal data is only stored as long as it is necessary to fulfil the purpose unless other is demanded in accordance to legislation, hereunder especially the accounting law’s rules on storing accounting records for 5 years, as well as the current year.
Log files, including IP-addresses, is stored for 5 years before they are deleted. Google Analytics data is stored for 26 months before they are deleted.
Your rights
Contact information, if you want to use your rights
If you wish to use the rights stated below you must contact us through the contact information listed in the top of this privacy policy.
- Right to insight (see personal data): You have a right to get insight in the personal data about you that we process as well as a number of additional information. The access to insight must not violate others’ rights and freedom rights.
- Right to correction: You have a right to get untrue personal data about you corrected.
- Right to deletion of personal data: In special cases you have the right to get personal data about you deleted before the general timeline of the deletion occurs.
- Right to restriction of processing: In some cases you have the right to get the processing of your personal data restricted. If you have the right to get the processing restricted, we may only process the data – except for storing – with your consent, or if legal requirements demand it, or to protect a person or important public interests.
- Right to transmit data (data portability): When our processing of your personal data is based on consent or a contract and the processing takes place automatically data portability is your right. This right entails that you have the right to get the personal data sent to you in a structured, normally applied and machine-readable format that you have the right to transmit to another service provider.
- Right to objection: In some cases you have the right to make objection against our otherwise legal processing of your personal data. You may as well object to our processing of your personal data to direct marketing.
- Right to withdraw consent: If we base our processing on your consent you have the right to withdraw your consent to us processing of your personal data completely or partially. The withdrawal of your consent will not influence the legitimacy of the processing that we have conducted before the withdrawal of consent. If you withdraw your consent it will only come into effect from the moment of the withdrawal.
You can read more about your rights in the Danish DPA’s guide to the rights of the registered, which you can find on www.datatilsynet.dk.
Complaint
If you want to complain of the processing of your personal data you have the right to file a complaint to the Danish DPA, who have the following contact information:
Datatilsynet (DPA)
Address: Borgergade 28, 5, 1300 Copenhagen
E-mail: dt @ datatilsynet.dk
Phone number: + 45 33 19 32 00
Homepage: www.datatilsynet.dk
Cookie Policy
This agreement was written in Danish (DK). To the extent any translated version of this agreement conflicts with the Danish version, the Danish version apply. We reserve the right to make changes to our Cookies and Privacy Policy. Any such changes shall appear here and become effective immediately.
What are cookies?
This website uses – like most other sites – cookies. Cookies are small text files that will be stored on your computer, phone, tablet or comparable unit with the purpose of recognizing the device, remembering preferences, create statistics and target adverts. Cookies can contain text, numbers or dates but no personal data is stored in a cookie, and they cannot contain malicious code (e.g. a virus). We, and the following data processors have access to the data stored: Microsoft Ltd., Google Ltd., Match2One AB and Facebook Ltd.
When you use our website you accept the use of cookies, including third party cookies, but it is at any given time possible to delete or block for cookies. In the bottom of this page you can see which cookies are stored on your computer, mobile phone, tablet or other device when you use our website.
If you delete or block cookies adverts will become less relevant for you and appear more often. You may also experience that the website does not function perfectly and there may be content you do not have access to.
Cookies are also stored in log files that are collected from the site’s users. Log files are generated from all websites and this site is no exception. Basically log files contain an overview over 1) which pages that has been visited on the site, 2) when they have been visited, and 3) where they have been accessed from, which means the log files collect the user’s IP address. Based on the collected log file data we are only able to see what city you access the site from and not your exact geographic location. You can read more about how we process your personal data, including your IP address in our privacy policy.
Said log files will be used both for monitoring traffic on the site and as a security measure. One of the reasons why we collect IP-adresses is that we can use them to prevent hacker attacks.
If we in the log files can see an unusual pattern in where the traffic is coming from it can be a sign of an attempted hacker attack. By monitoring the users’ location via IP-addresses we are better equipped to prevent hacker attacks.
Log files, including IP-addresses are stored for 5 years before they are deleted.
What do we use cookies for?
We use cookies for an array of purposes, such as optimizing our marketing efforts and your user experience and also to secure and improve our websites technical functionality.
Some of the data we collect through cookies is used to analyse our users’ behaviour on the site. The cookies can give us an overview of what type of devices the site is accessed via, what pages the users visit, what marketing channels the users come from, and how long time they spend on the site. If users click on ads or affiliate links on the site it will also be registered and included in our analyses of the site.
We use the data to optimize our own marketing efforts and as a tool to improve user experience and optimize our website plus to target online ads, so you will be presented for ads that are more relevant for you.
Cookies are also used to make the website more functional for its users. The use of cookies means that the users do not have to download as much data when revisiting the site, and that the site can remember the users’ preferences. That optimizes the user experience, the loading of content and the site’s response time.
The use of cookies makes it possible to make on-going adaptions on the site to match the user needs identified through their behaviour.
Besides us certain third parties also leave cookies on your hard drive when using the site. You can read more about, which third parties under “Third party plugins that leaves cookies”.
What cookies do we use?
You can see a list of the cookies that are stored on your hard drive, mobile or tablet when you use our site, in the bottom of this page. In the following we will elaborate on the use of different types of cookies.
Heat maps:
Periodically the website uses heat maps, which show the users whereabouts on the site. These data and information about this will be stored.
Specifically heat map is a tool to identify how the specific movement of the users on the website happens, and can be useful to know in the process of optimizing our website and its layout.
Cookies used for analysis
The site uses the programs ”Google Analytics” and ”Matomo” to analyse from which geographical locations the users access the site. That can be identified via the users’ IP-addresses.
The geographical location means – as mentioned earlier – that we are unable to see the users’ addresses or exact locations, however the level of detail is that we can see from which city the user access the site from.
The reason why we obtain information on the user’s geographical location is first and foremost to make sure that we only permit access to user’s that are not restricted due to local legislation on gambling.
The site also collects anonymous statistics of the user’s visits on the site, including the number of visits, the average time spent on the site and which pages have been loaded. The aim is to segment the site’s users based on factors such as demographics and geography, which makes it possible to structure and understand the target audience with a view to present online ads to them.
Targeted advertising
When you use this site cookies are stored on your hard drive, mobile or tablet that ensures that online ads can be targeted to be especially relevant for you, when you use social media like Facebook and Instagram, and when you visit other websites. It may also mean you are presented banner ads from us when you browse on other websites.
The targeted marketing efforts ends no later than 180 days from the time you last visited the site. You can also avoid targeted ads by deleting or blocking cookies.
Third party cookies that leaves cookies
On the website you may encounter various external plugins, such as embedded Youtube videos or similar features. These plugins may leave a cookie on you hard drive, mobile phone or tablet. This category of cookies stems from third party services on the site.
Common third party cookies include:
- Youtube – May figure on the site due to embedded videos on the site
- Affiliate link cookies – May figure on the site du to us linking to the gaming providers (casinos, poker sites, bingo sites and betting sites)
The reason why we have included these features on the site is that it may allow us to offer our users more features (such as videos) and other advantages.
How long do we store user information?
Information about the users’ visits on the site is store up to 26 months in Google Analytics. If a user visits the site again during the 26 months the storage period will restart and be stored for 26 months from that moment. That is also known as ‘data retention’.
Data collection is in accordance with Google’s guidelines and do not contain any personal information of the users.
The aim of the on-going collection of data and storage of data in up to 26 months is to give our users the best possible experience on our site.
Google Analytics data is stored up to 26 months to be able to create statistics of the site’s annual development and to have comparable data going back, and to measure the site’s traffic.
Users that have interacted with or visited the site via Facebook Marketing will be stored in a Facebook Pixel for up to 180 days, in accordance with Facebook’s guidelines. All data is anonymised by Facebook.
The aim of the Facebook Pixel is to target ads and marketing from the site via Facebook and to present the users for ads matching their interests and needs.
How can I avoid cookies?
If you do not want to store cookies on your hard drive, mobile phone or tablet you can delete them any time, which is simple and not very time consuming. You can find a guide to deleting cookies on the following link: https://www.digitaltrends.com/computing/how-to-delete-cookies/
If you do not wish that your hard drive, mobile phone or tablet stores cookies when you are surfing online you can choose to block all cookies or to receive a warning every time you computer, mobile phone or tablet wants to store a cookie. In the following link you can find a guide on how to change the settings of your browser to block cookies: https://www.wikihow.com/Disable-Cookies
Contact information
If you have any complaints or questions about how cookies, personal data or other information about your behaviour on the site is used, you are welcome to contact us via email. All inquiries and questions will be treated seriously and answered as quickly as possible.
Contact: [email protected] thegambledoctor.com
Updated: 14/08/2023
