Privacy notice: support, live chat and contact form
Draft for review by counsel. This is a template for the operator to publish under its own name. It is not legal advice. Text in [square brackets] must be filled in before publication. It covers only support and contact. The operator's main privacy notice covers accounts, payments, play and marketing, and should link here, or include this text.
Effective [date]. Version 0.1.
This notice explains how [Operator legal name] ("we") uses your personal data when you contact our support team by live chat, contact form, email or SMS. We are licensed by [regulator] under licence [licence]. We are the controller of your data.
1. Who to contact
[Operator legal name], [registered address]. Privacy questions: [privacy contact]. [Data protection officer: [DPO].]
2. What we collect
- Live chat: your messages, and the time you sent them. The chat does not ask who you are. We do not link the chat to your account unless you tell us who you are and a member of our team does so.
- Contact form: your email address and your message.
- Email and SMS: your address or phone number and your messages.
- If you are a player: our support team can see the account details needed to help you, such as your account status, verification status, limits, recent deposits and withdrawals, and earlier conversations with us.
Please do not send card numbers, passwords or copies of identity documents in a chat or form. The live chat refuses messages that contain a card number. Other contact and payment details are masked before a message is stored.
3. Why we use it, and our lawful basis
| Purpose | Lawful basis |
|---|---|
| Answering your question and solving your problem | Contract (if you have an account), otherwise our legitimate interest in answering people who contact us |
| Spotting signs of gambling harm in messages and acting on them, for example by stopping marketing, withdrawing offers, lowering a deposit limit or putting you in touch with our safer gambling team | Legal obligation under our licence, and to protect your vital interests in an emergency |
| Handling self-exclusion and account closure requests | Legal obligation |
| Anti-money laundering checks | Legal obligation |
| Keeping records of what was said and decided, for complaints and our regulator | Legal obligation, and our legitimate interest in handling complaints and legal claims |
| Improving our support | Legitimate interest. We use summaries, not your identity. |
4. How we use AI
- Live chat is answered by an AI assistant, which is labelled as one. It answers general questions about how our site, games, deposits and safer gambling tools work. It cannot see or change your account, and it never offers bonuses or promises winnings.
- If your message is about a crisis, self-exclusion, closing your account, your age, or your data protection rights, the AI does not answer it. You get a fixed reply, and a member of our team takes over.
- Replies from our support team by email, SMS, contact form or chat may be drafted with the help of AI. [Choose one. If Approve all is on:] A member of our team reads, edits and approves every one before it is sent, and is responsible for it. [If Approve all is off:] Short answers to simple questions may be written and sent by AI without a person reading them first. Anything about your account's safety, gambling harm, a complaint or your data rights goes to a member of our team. We are responsible for every reply.
- Before any message is sent to the AI service, your name, contact details, payment details and player id are removed or replaced with a code.
- Our safer gambling and anti-money laundering checks use rules that look at your account activity. They can stop marketing or lower limits automatically, because those steps only protect you. Any decision to hold a withdrawal, close an account or end a relationship is made by a person. You can ask for a person to review any decision about you, and you can give your point of view.
5. Who we share it with
- Our support platform, CasinoOS, provided by [CasinoOS legal entity], which processes data for us under a data processing agreement.
- AI service providers that generate chat answers and reply drafts, with identifiers removed: Anthropic (Claude).
- Our hosting, email and SMS providers: [names].
- Self-exclusion registers, such as [GAMSTOP / Spelpaus / OASIS / RGIAJ], to check whether you are excluded, where our licence requires it.
- Our regulator, law enforcement and financial intelligence units, where the law requires it.
6. International transfers
Some of these providers process data outside [the UK / the EEA]. Where they do, we rely on an adequacy decision or on standard contractual clauses. [List the countries.] Contact us for details.
7. How long we keep it
| Data | Kept for |
|---|---|
| Live chat and support messages | [2] years after the conversation ends |
| Records of safer gambling and self-exclusion actions | [5] years, or longer if our licence requires it |
| Anti-money laundering records | At least 5 years after our relationship with you ends |
| Audit trail of decisions | [5] years |
When a period ends, live chat and support messages are deleted automatically. If you ask us to delete your data, we delete your messages straight away, apart from anything we must keep by law.
[Operator: confirm these periods match the retention set for your markets in CasinoOS.]
8. Your rights
You can ask for a copy of your data, ask us to correct or delete it, object to or restrict how we use it, or ask to move it. Some data we must keep by law, such as anti-money laundering records, even if you ask us to delete it. We will tell you if that applies. Contact [privacy contact]. You can also ask in the live chat: the request goes to our data protection team. We reply within one month.
You can complain to [supervisory authority] at [authority website].
9. Help with gambling
If gambling is causing you problems, free and confidential help is available: [helpline names and numbers for each market].