Privacy Policy and Cookies

Apricot Investments Limited

Privacy Notice (Website)

Welcome to our website privacy notice (Website Privacy Notice).  We are Apricot Investments Limited (formerly Microgaming Software Systems Limited) of Sixty-Two Circular Road, Douglas, Isle of Man. We are committed to being fully compliant with all applicable Isle of Man data protection legislation and the General Data Protection Regulation as applied to the Isle of Man (GDPR) in respect of personal data, as well to safeguarding the rights and freedoms of natural persons whose information we collect.

This Website Privacy Notice is broken down into segments that cover specific areas, below are the categories covered, please scroll down to read the whole notice in detail. Please also use the Glossary to understand the meaning of some of the terms used in this Website Privacy Notice.

1. Important information and who we are

2. The personal data we collect about you

3. How is your personal data collected?

4. How we use your personal data

5. Disclosures of your personal data

6. International transfers

7. Data security

8. Data retention

9. Your legal rights

10. Glossary

 

1.               Important information and who we are

Purpose of this Website Privacy Notice

This Website Privacy Notice aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you sign up to our vacancy notifications.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this Website Privacy Notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your personal data.  This privacy notice supplements the other notices and is not intended to override them.

Controller

We are the Controller of all personal data relating to our personnel and personal data used in our business for our own commercial purpose.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this Website Privacy Notice.  If you have any questions about this Website Privacy Notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details

The Data Protection Officer

dpo@microgaming.co.uk

Sixty Two, Circular Road, Douglas, Isle of Man, IM1 1AE

You have the right to make a complaint at any time to the Information Commissioner, the Isle of Man supervisory authority for data protection issues (www.inforights.im).  We would, however, appreciate the chance to deal with your concerns before you approach the Information Commissioner so please contact us in the first instance.

Changes to the Website Privacy Notice and your duty to inform us of changes

This version was last updated on 22 August 2018; any historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you.  We do not control these third-party websites and are not responsible for their privacy statements.  When you leave our website, we encourage you to read the privacy notice of every website you visit.

2.               The personal data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes address, email address and telephone numbers.
  • Curriculum Vitae Data includes employment and education data such as previous employers, roles and qualifications
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other  technology on the devices you use to access this website.
  • Profile Data includes your username and password, your interests, preferences, feedback and survey responses. 
  • Usage Data includes information about how you use our website.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that personal data when requested, we may not be able to perform the contract we have or are trying to enter into with you.  We will notify you if this is the case at the time.

3.               How is your personal data collected?

We use different methods to collect personal data from and about you including through:

  •  Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise.  This includes personal data you provide when you:
  • create an account on our website;
  • subscribe to our service or publications;
  • request marketing to be sent to you; or
  • give us some feedback.
  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns.  We collect this personal data by using cookies, server logs and other similar technologies.  We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy (https://www.successfactors.com/en_us/about-successfactors/privacy.html) for further details.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below

Technical Data from the following parties:

(a)                analytics providers such as Google based outside the EEA;

(b)                search information providers such as Google based outside the EEA.

4.               How we use your personal data

We will only use your personal data when the law allows us to.  Most commonly, we will use your personal data in the following circumstances:

  •  Where we need to perform the contract we are about to enter into, or have entered into, with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  •  Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message.  You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your personal data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity                                           Type of data                                           Lawful basis for processing including basis of legitimate interest

To register you                                                              (a) Identify                                                            Performance of a contract with you
                                                                                      (b) Contact

 

Purpose/Activity                                           Type of data                                           Lawful basis for processing including basis of legitimate interest

To manage our relationship                                         (a) Identity                                                            (a) Performance of a contract with you
with you which will include:                                          (b) Contact                                                            (b) Necessary to comply with a legal obligation
(a) Notifying you about changes                                  (c) Profile                                                              (c) Necessary for our legitimate interests
to our terms or privacy policies                                    (d) Marketing and                                                 (to keep our records updated and to study how
(b) Asking you to leave a review                                  Communications                                                   how customers user our products/services)
or take a survey

 

Purpose/Activity                                           Type of data                                           Lawful basis for processing including basis of legitimate interest

To enable you to partake in a prize                               (a) Identify                                                            (a) Performance of a contract with you
draw, competition or complete a                                   (b) Contact                                                            (b)  Necessary for our legitimate interests (to
survey                                                                           (c) Profile                                                              study how our customers use our products/services,
                                                                                     (d) Usage                                                               to develop them and grow our business)
                                                                                     (e) Marketing and Communications    

 

Purpose/Activity                                           Type of data                                           Lawful basis for processing including basis of legitimate interest

To administer and protect our                                        (a) Identity                                                            (a) Necessary for our legitimate interests (for
business and this website (including                             (b) Contact                                                            running our business, provision of administration
troubleshooting, data analysis,                                      (c) Technical                                                          and IT services, network security, to prevent fraud
testing, system maintenance,                                                                                                                     and in the context of a business reorganisation or
support, reporting and hosting of data)                                                                                                       group restructuring exercise)
                                                                                                                                                                    (b) Necessary to comply with a legal obligation

 

 

Purpose/Activity                                           Type of data                                           Lawful basis for processing including basis of legitimate interest

To deliver relevant website content and                       (a) Technical                                                         Necessary for our legitimate interests (to study how
advertisements to you and measure or                        (b) Usage                                                              customers use our products/services, to develop them,
understand the effectiveness of the                                                                                                           to grow our business and to inform our marketing strategy)
advertising we serve to you

 

Purpose/Activity                                           Type of data                                           Lawful basis for processing including basis of legitimate interest

To use data analytics to improve our                           (a) Technical                                                         Necessary for our legitimate interests (to define types of
website, products/services, marketing,                        (b) Usage                                                              customers for our products and services, to keep our website
customer relationships and experiences                                                                                                   updated and relevant, to develop our business and to inform 
                                                                                                                                                                   our marketing strategy)

 

Purpose/Activity                                           Type of data                                           Lawful basis for processing including basis of legitimate interest

To make suggestions and                                            (a) Identify                                                             Necessary for our legitimate interests (to develop our
recommendations to you about goods                         (b) Contact                                                            products/services and grow our business)
or services that may be of interest to you                    (c) Technical
                                                                                     (d) Usage
                                                                                     (e) Profile

 

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Opting out

You can ask us to stop sending you messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your preferences or by following the opt-out links on any message sent to you or by contacting us at any time.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies.  If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.  For more information about the cookies we use, please see https://www.successfactors.com/en_us/about-successfactors/privacy.html.

Change of purpose

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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at dpo@microgaming.co.uk.

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.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5.               Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

·        Internal Third Parties as set out in the Glossary.

·        External Third Parties as set out in the Glossary.

·        Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.  Alternatively, we may seek to acquire other businesses or merge with them.  If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6.               International transfers

We share your personal data within the Group Companies as set out in the Glossary.  This may involve transferring your personal data outside the European Economic Area (EEA).

We ensure your personal data is protected by requiring all the Group Companies to follow the same rules when processing your personal data.

7.               Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.  In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.  They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8.               Data retention

We will only retain your 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.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us

In some circumstances you can ask us to delete your personal data: see the Glossary below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9.               Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

·        Request access to your personal data.

·        Request correction of your personal data.

·        Request erasure of your personal data.

·        Object to processing of your personal data.

·        Request restriction of processing your personal data.

·        Request transfer of your personal data.

·        Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights).  This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month.  Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests.  In this case, we will notify you and keep you updated.

10.            Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience.  We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests.  We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).  You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

In addition, your information may be made available to companies within our group (individually a “Group Company” and jointly the “Group Companies”), to allow us to provide you with information about other roles that you may find of interest or may be more suited to you.  These companies are:

Company name                                                      Address

Derivco Ipswich Limited                                           4th Floor East Wing Crown House, Crown Street, Ipswich, Suffolk, England, IP1 3HS

Derivco Sweden AB                                                 Sveavagen 24-26, 111 57 Stockholm, Sweden

Derivco Estonia OU                                                 Kai 1, 10111, Tallinn, Estonia

Derivco Australia PTY Ltd                                       29/340 Hope Island Road, Hope Island, 4212 Queensland, Australia

Derivco Costa Rica Limitada                                   Fourth Floor, Building A, Forum II, Pozos, Santa Ana, San Jose, Costa Rica

Derivco Malta Limited                                             Ground Floor The George Complex, Triq Ball, San Giljan STJ3123, Malta

Betstone Systems SL (trading As Derivco Spain)  PG TiL.Lers, Num.3, 08034, Barcelona, Spain

Prima Networks Limited                                         Ground Floor, The George Complex, Triq Ball, Paceville, San Giljan, STJ 3123, Malta

Oakwood Systems Limited                                    57/63 Line Wall Road, Gibraltar

Derivco Isle of Man Limited                                   PO Box 227, Clinch’s House, Lord Street, Douglas, Isle of Man, IM99 1RZ, Isle of Man

Where a Group Company or more than one Group Company decides to consider you as a candidate for a position that they have open, they will become Joint Controllers with us and will process your data in accordance with this privacy notice.  Where there are Joint Controllers, we will remain, for the duration of the application process, the contact point for you in all matters relating to this privacy notice.

The following Group Companies (the “External Companies”) are not within the EEA nor are they within a country that the European Commission has determined as having an adequate level of protection:

Company name                                                  Address

Derivco Australia PTY Ltd                                   29/340 Hope Island Road, Hope Island, 4212 Queensland, Australia

Derivco Costa Rica Limitada                               Fourth Floor, Building A, Forum II, Pozos, Santa Ana, San Jose, Costa Rica

Where we need to transfer your personal data to one or all of the External Companies, such transfers being necessary for you to enter into a contract of employment with them or, with your consent, for them to carry out pre-contractual steps towards employing you, we will only transfer such personal data that is adequate, relevant and necessary to enable them to process your application.

We will not share your personal data with other third parties, unless your application for employment is successful and we make you an offer of employment. We will then share only what is necessary of your personal data with former employers to obtain references for you, employment background check providers to obtain necessary background checks and the Disclosure and Barring Service to obtain necessary criminal records checks.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a "data subject access request").  This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you.  This enables you to have any incomplete or inaccurate personal data we hold about you corrected, though we may need to verify the accuracy of the new personal data you provide to us.

Request erasure of your personal data.  This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it.  You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your personal information unlawfully or where we are required to erase your personal data to comply with local law.  Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.  You also have the right to object where we are processing your personal data for direct marketing purposes.  In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data.  This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the personal data's accuracy; (b) where our use of the personal data is unlawful but you do not want us to erase it; (c) where you need us to hold the personal data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your personal data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party.  We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the personal information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data.  However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.  If you withdraw your consent, we may not be able to provide certain products or services to you.  We will advise you if this is the case at the time you withdraw your consent.