PRIVACY NOTICE

KENILWORTH PROPRIETARY LIMITED

AFFILIATE PRIVACY NOTICE

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice explains how we collect, use, and process your personal information through your use of the Affiliate Programme, including any information you may provide when you register as an affiliate on the Affiliate Site. We will ensure that the personal information we collect from yourself is protected and processed carefully and responsibly.

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

WHO IT APPLIES TO

This notice applies to all affiliates of Kenilworth Racing trading as Lucky fish, (“Lucky fish”).

We may need to update this privacy notice periodically and encourage you to check our privacy notice regularly so that you remain up to date on how we process and protect your personal information.

If you have any questions about this notice, please email us at [email protected]

WHAT PERSONAL INFORMATION WE COLLECT AND GENERATE

Personal information means any information about a natural or legal person from which that person can be identified. It does not include information where the identity has been removed (anonymous information).

We collect the personal information we require to register you as an affiliate and to communicate with you.

3.1 The following is the information we collect:

• Full name and Last name
• Company name
• Legal nature of entity
• Registration number
• Contact information (e.g. title, physical and postal address, email address, mobile number/telephone number)
• Skype name
• Website URL
• Bank Account information: IBAN, Account number, Bank name, SWIFT/BSB

3.2 We generate information about you in the form of:

• Quick summary reports and customer earning reports
• Affiliate stats
• Records of payments
• Registration reports
• Mailing lists
• Customer stats
• Email reports
• Traffic reports

We do not collect any special categories of personal information 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 information).

WHEN AND WHY WE COLLECT AND PROCESS YOUR PERSONAL INFORMATION

4.1 We process your personal information to meet our contractual obligations with you, as well as collect and use your personal information for the following purposes:

Let you register an affiliate account with us.

Process and track your customers qualifying betting transactions against your unique affiliate account number.

Notify you of the outcome of your customers betting transactions in the form of reports (these reports contain no personal information on the customers themselves).

Notify you of changes to the affiliate programme, approved promotional material and intellectual property or any other information relevant to your role as an affiliate.

Process a payment to you in respect of monthly affiliate commission.

Reply when you contact us for support or information.

Investigate and resolve your queries, complaints or requests.

4.2 We are legally required to collect and process certain information, including:

• To identify and validate our affiliates and for purposes related to the prevention of financial crime, including sanctions screening, monitoring of anti-money laundering and financing of terrorist activities.
• To report suspicious activity on your account to the relevant authorities.
• To report to other governmental agencies, for example the South African Revenue Service.

When you register an account with Lucky Fish, you can choose if you want to receive promotional material from us. We may send you information about our services, products and promotional activities via the communication channels you selected. You can unsubscribe at any time by following the unsubscribe link or by contacting us.

CHILDREN’S INFORMATION

• You have to be 18 years or older to make use of our services.
• When you register as an affiliate we will ask you to confirm that you are 18 or older.
• We do not knowingly collect the personal information of persons under 18 years of age.

WE ONLY SHARE YOUR INFORMATION WITH OTHERS WE TRUST

We only use service providers we trust and who have agreed to keep your personal information secure and confidential and to only use it for the purposes for which we shared it with them.

We may use service providers to assist with the following:

• communicate with you
• verify your identity
• verify your address
• verify your banking details
• monitor the effectiveness of our services
• store information
• manage our business, for instance accountants and professional advisors
• provide IT services and infrastructure

Some of the service providers that we use may be located in other countries. These countries may not have the same levels of protection of personal information as South Africa, in which case the foreign service providers must undertake to protect the personal information of our affiliates to the same level that we do.

We provide for appropriate safeguards by means of contracts between us and our foreign service providers.  By using our website, you agree to not being notified of details regarding the level of protection afforded to your information in the relevant country/countries.

We may be required to share your personal information with regulatory and law enforcement bodies.

REASONABLE STEPS TAKEN TO SAFEGUARD YOUR PERSONAL INFORMATION

We take reasonable steps to protect your personal information against the following:

• loss;
• interference;
• unauthorised access;
• use;
• modification;
• disclosure;
• or other misuse.

These steps include password protection for electronic files, securing paper files and physical access restrictions.  We will continuously review our security controls and processes to ensure that security risks are identified and addressed.

If something should happen, we will take the necessary steps to minimise the threat to your privacy and we will let you know if your personal information has been compromised. We will also let you know how you can help minimise the impact of a breach.

WE DO NOT KEEP YOUR PERSONAL INFORMATION LONGER THAN WE NEED TO

We will not keep your personal information longer than we need to unless we are legally required to do so. We take legal requirements, contractual obligations and the expectations and requirements of our affiliates into account when we determine how long we should retain information. When we no longer need your personal information, we will securely delete or destroy it in line with the Protection of Personal Information Act (POPIA) requirements.

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

We keep our privacy notice under regular review and therefore encourage you to check our privacy notice regularly so that you remain up to date on how we process and protect your personal information.

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

IF YOU FAIL TO PROVIDE PERSONAL INFORMATION

Where we need to collect personal information by law, or under the terms of a contract we have with you, and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to allow you to place a bet). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

ACCESS AND CORRECTION OF PERSONAL INFORMATION

You have the right to:

• be notified that your personal information is being collected;
• be notified of security compromises where reasonable grounds exist for us to believe that your personal information has been accessed or acquired by an unauthorised person;
• ask us what we know about you and request access to such information; ask what personal information was sent to our service providers or any other third party;
• ask us to update, correct or delete any out-of-date or incorrect personal information we hold about you; where it is inaccurate, irrelevant, excessive, out of date, incomplete, misleading or obtained unlawfully;
• unsubscribe from any direct marketing communications we may send you and object to the processing of your personal information;
• request us to delete or remove your personal information where there is no good reason for us continuing to process, although this will be subject to Lucky Fish requiring the information for legal and legitimate reasons;
• request restrictions on processing of your personal information;
• withdraw your consent at any time where we are relying on consent to process your personal information;
• submit a complaint to the Information Regulator. You have the right to submit a complaint to the Information Regulator regarding an alleged interference with the protection of your personal information. However, please note that until POPIA is in force, the Information Regulator does not have the power to enforce your protection under POPIA;

You can request access to the personal information we hold about you or correct your personal information. It can take us up to 21 days to respond to your request due to procedures that we are required to follow. In certain cases, we may require proof of your identity and sometimes changes to your personal information may be subject to additional requirements such as valid proof of residence.