This policy explains how [LEGAL ENTITY NAME] ("Gaming Eminence", "we", "us") collects and uses personal data through gamingeminence.com, our newsletter, our editorial work and the Gaming Eminence intelligence platform at app.gamingeminence.com. It also explains how we handle information about people who are named in our industry data. We are the controller of this personal data under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
1. Who we are and how to contact us
[LEGAL ENTITY NAME], registered in England and Wales, company number [COMPANY NUMBER], registered office [REGISTERED OFFICE ADDRESS]. We are registered with the Information Commissioner's Office (ICO) under number [ICO NUMBER].
For anything about your personal data, email [PRIVACY EMAIL] or see our Data Rights page. We have not appointed a Data Protection Officer because the law does not require one for our activities; [PRIVACY EMAIL] reaches the person responsible for data protection.
2. Who this policy covers
- Website visitors: people who browse gamingeminence.com or the public pages of the platform.
- Newsletter subscribers: people who receive our monthly newsletter or other editorial emails.
- Access applicants and platform users: people who request access to the platform and, once approved, use it on behalf of their organisation.
- People named in our industry data: directors, executives, licence holders and other business professionals connected with gambling operators, suppliers, service providers and regulators, whose business information appears in the platform.
- Interviewees and contributors: people we interview or who contribute to our editorial content.
- Business contacts: people we deal with at customers, prospects, partners and suppliers.
3. The personal data we collect
From you directly
- Name, job title, organisation, work email address and phone number when you request access, subscribe, contact us or agree to an interview.
- Account details when you use the platform: login email, authentication records, the organisation you represent, your acceptance of our Platform Terms, and records of administrative actions taken on your account.
- What you tell us in correspondence, feedback, interviews and data rights requests.
Automatically
- Technical data: IP address, browser and device type, pages viewed, and timestamps, collected through server logs and the cookies described in our Cookie Policy.
- Platform usage: searches, filters and pages used within the platform, linked to your account, so we can run, secure and improve the service.
From other sources (people named in our industry data)
- Name, job title, employer, role history and business contact details.
- Regulatory information, such as being named as a licence holder or key person on a public gambling regulator register.
- The source of each item and the date we recorded it.
We collect this from public and professional sources: official regulator registers and enforcement notices; company registries and filings; official company announcements, annual reports and websites; trade press and industry reporting; and professional profiles that the individual has made public. We aim to hold business contact details only. We do not knowingly collect home addresses, personal phone numbers or personal email addresses, and we do not collect data about gamblers or consumers.
We do not seek to collect special category data (such as health, religion or political opinions) or criminal offence data. Where a public regulatory notice about a company names an individual, we record only what is needed to describe the regulatory event accurately.
4. Why we use your data and our lawful basis
| Purpose | Data used | Lawful basis |
|---|---|---|
| Reviewing and managing requests for platform access | Access request details | Legitimate interests: deciding who can use a B2B service |
| Providing the platform to approved organisations, including accounts, authentication and support | Account and usage data | Contract with your organisation; legitimate interests in providing the service to its users |
| Keeping the platform and website secure, preventing misuse and investigating breaches of our terms | Technical, account and usage data | Legitimate interests: security and protecting our database |
| Improving the website and platform | Technical and usage data, mostly in aggregated form | Legitimate interests: improving our service |
| Sending the newsletter and editorial updates | Name, email, subscription choices | Consent, or legitimate interests for business contacts at corporate addresses, with an unsubscribe link in every email |
| Building and maintaining the intelligence platform | Business data about people named in our industry data | Legitimate interests (see section 5) |
| Researching, writing and publishing journalism | Interview content and information about people in the news | Legitimate interests, and the journalism exemption in the Data Protection Act 2018 where it applies |
| Running our business: invoicing, accounts, legal claims and compliance | Business contact and transaction data | Contract; legal obligation; legitimate interests |
| Handling data rights requests and complaints | Details you give us | Legal obligation |
Where we rely on legitimate interests, we have weighed our interests against your rights and expectations. You can ask us for details of that assessment.
5. People named in our industry data
Gaming Eminence maps how the regulated gambling industry is structured: which companies operate which brands, which hold which licences, which suppliers serve which operators, and who holds senior roles. Business professionals are part of that picture, so the platform includes information about them in their professional capacity.
We rely on legitimate interests. Our interest, and our customers' interest, is in accurate, evidenced information about businesses operating in a regulated industry. We limit the impact on individuals by:
- holding professional information only, taken from public or professional sources, with the source recorded against each item;
- making the platform available only to approved business users who agree to our Platform Terms, which forbid scraping, resale and unlawful contact;
- recording an unconfirmed item as unconfirmed, rather than presenting it as fact;
- removing or correcting information promptly when told it is wrong or out of date; and
- always honouring an objection to our use of your data for this purpose.
Because we collect this information from public sources rather than from you, we publish this notice instead of contacting each person individually, as contacting everyone would involve disproportionate effort. If you want to know whether we hold information about you, or want it corrected or removed, see our Data Rights page.
If you object, we remove your contact details and stop including you in the platform. We keep a minimal record (your name, employer and the date of your request) on a suppression list, so that we do not add you again from public sources. Information that describes a company, such as a regulator recording that a company holds a licence, may remain without naming you.
Approved platform users who take personal data from the platform become responsible for their own use of it, including any contact they make. Our Platform Terms require them to comply with data protection and electronic marketing law and to respect objections we pass on.
6. Editorial content and interviews
When we interview you, we use your name, role, organisation, image (if you provide one) and what you tell us to prepare and publish the article and related posts, such as on LinkedIn. Before an interview we explain how it will be used. Published journalism is kept as part of our archive. If you think something we published about you is inaccurate, tell us and we will review it under our corrections process.
Some of our processing for journalism may be covered by the special purposes exemption in Schedule 2, Part 5 of the Data Protection Act 2018, which can limit certain rights where applying them would be incompatible with journalism in the public interest.
7. Marketing
We send our newsletter only to people who have subscribed or, for business contacts at corporate email addresses, where we have a legitimate interest and the law allows it. Every email contains an unsubscribe link, and you can also email [PRIVACY EMAIL]. We never sell or rent our contact lists.
8. Who we share personal data with
- Service providers acting on our instructions: Supabase (database and authentication), Vercel (platform hosting), Resend (transactional email), Wix (website hosting), [NEWSLETTER PROVIDER] (newsletter), [EMAIL AND OFFICE PROVIDER] (business email and documents), and Upwork and Payoneer (contractor engagement and payment).
- Contractors: developers and data specialists who build and maintain the platform under written confidentiality and data protection terms, with access limited to what their work requires.
- Platform users: business information about people named in our industry data is visible to approved users of the platform.
- Professional advisers: lawyers, accountants and insurers, under duties of confidentiality.
- Authorities: regulators, law enforcement and courts, where the law requires or allows it.
- A buyer or investor: if we sell, merge or restructure our business, or raise investment, personal data may transfer to the buyer or be disclosed to the investor under confidentiality terms, subject to this policy.
9. International transfers
Our production database is hosted in Ireland (AWS eu-west-1). Some of our service providers and contractors are based, or can access data, outside the UK, including in the United States, the European Union, Ukraine and Brazil. When personal data leaves the UK, we use one of the safeguards UK law provides: a UK adequacy decision (for example, for the EU and Israel), the UK Extension to the EU-US Data Privacy Framework where the US recipient is certified, or the UK International Data Transfer Agreement or UK Addendum to the EU Standard Contractual Clauses. You can ask for a copy of the relevant safeguard.
10. How long we keep data
| Data | Retention |
|---|---|
| Access requests that are declined or withdrawn | 12 months from the decision, then deleted |
| Platform accounts | For as long as your organisation has access, then 24 months, then deleted |
| Terms acceptance records | 6 years after the account ends (to evidence the contract) |
| Security and server logs | 12 months |
| Newsletter subscriptions | Until you unsubscribe; your address then stays on a do-not-contact list |
| Information about people named in our industry data | While it is relevant and supported by a source; reviewed at least every 24 months |
| Suppression list entries | For as long as we operate the platform |
| Data rights requests and complaints | 3 years after closure |
| Invoices and accounting records | 6 years after the end of the financial year, as UK tax law requires |
| Published editorial content | Kept as part of our archive |
11. Security
We use access controls, encryption in transit, role-based permissions, audit logging of administrative actions, and restricted credentials for contractors. No system is perfectly secure; if a breach is likely to put your rights at risk, we will tell you and the ICO as the law requires.
12. Your rights
You have the right to:
- access the personal data we hold about you;
- correct inaccurate or incomplete data;
- erase your data in certain circumstances;
- restrict how we use it while a concern is resolved;
- object to our use of it based on legitimate interests, including all direct marketing;
- data portability, for data you gave us under contract or consent; and
- withdraw consent at any time, where we rely on consent.
We do not make decisions about individuals based solely on automated processing that have legal or similarly significant effects. Qualification scores in the platform assess companies, not people.
To use any of these rights, email [PRIVACY EMAIL] or see our Data Rights page. We respond within one month. For complex requests we may extend this by up to two more months and will tell you why. We may need to confirm your identity first.
13. Complaints
If you are unhappy with how we have handled your personal data, please complain to us first at [PRIVACY EMAIL]. We acknowledge complaints within 30 days, investigate them without undue delay, keep you informed, and tell you the outcome.
You also have the right to complain to the Information Commissioner's Office: ico.org.uk/make-a-complaint, helpline 0303 123 1113.
14. Cookies
See our Cookie Policy.
15. Children
Our services are for business professionals. They are not directed at anyone under 18, and we do not knowingly collect data about children.
16. Changes to this policy
We will update this policy when our services or the law change. The date at the top shows when it was last updated. If we make a significant change that affects platform users, we will tell them by email or in the platform.