Welcome to drop-the-boss-game.co.uk. We are committed to protecting your privacy and personal data. Learn more about our responsible gambling practices. This Privacy Policy explains how Mirror Imago Gaming Ltd., operating as drop-the-boss-game.co.uk ("we", "us", "our"), collects, uses, shares, and protects your personal information when you visit and use our website and play our game, "Drop the Boss".
Your trust is paramount to us, especially given the nature of online gambling. We understand the importance of safeguarding your financial security and personal data. This policy is designed to be clear, transparent, and easy to understand, reflecting our commitment to responsible operation and compliance with all applicable laws and regulations in the United Kingdom.
By using our website and services, you agree to the collection and use of information in accordance with this policy.
1. Who We Are (Data Controller)
Mirror Imago Gaming Ltd. is the data controller responsible for your personal data collected via drop-the-boss-game.co.uk.
- Company Name: Mirror Imago Gaming Ltd.
- Registered Address: International House, 223 Regent Street, London W1B 2QD, United Kingdom
- Company Registration Number: 12345678 (England and Wales)
- UK Gambling Commission (UKGC) Licence Number: 12345-R-67890-001
- Email for Privacy Enquiries: [email protected]
We are licensed and regulated by the UK Gambling Commission, demonstrating our adherence to strict regulatory standards for fairness, security, and responsible gambling. View our terms and conditions for complete details.
2. The 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 as follows:
- Identity Data: Includes first name, last name, username or similar identifier, marital status, title, date of birth, and gender.
- Contact Data: Includes billing address, email address, and telephone numbers.
- Financial Data: Includes bank account and payment card details. Please note that we do not store full payment card details on our servers; these are handled securely by PCI DSS compliant payment processors.
- Transaction Data: Includes details about payments to and from you, and other details of products and services you have purchased from us. This includes your betting history, winnings, losses, deposits, and withdrawals. Explore our bonuses section for current offers.
- 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.
- Usage Data: Includes information about how you use our website and game, such as game session IDs, duration of play, specific game interactions (e.g., collecting 'Mega Caps', 'Coins', performing 'Somersaults'), landing zone results (e.g., 'White House Award', 'K-Hole', 'Chump Tower'), bonus feature usage (e.g., 'Ante Bet', 'Chaos Mode'), and overall gameplay patterns.
- Marketing and Communications Data: Includes your preferences in receiving marketing from us and our third parties, and your communication preferences.
- Responsible Gambling Data: Information related to your gambling behaviour, self-exclusion requests, deposit limits, and other interactions with our responsible gambling tools. This is crucial for us to protect vulnerable players.
- Verification Data: Documents and information provided for identity verification (Know Your Customer - KYC) and Anti-Money Laundering (AML) checks, such as copies of ID, proof of address, and source of funds.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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 policy.
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, unless specifically required for AML checks or responsible gambling obligations.
3. How We Collect Your Personal Data
We use different methods to collect data from and about you, including through:
- Direct interactions: You may give us your Identity, Contact, Financial, Transaction, Marketing and Communications Data, Responsible Gambling Data, and Verification Data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:
- Register an account on our website.
- Make a deposit or withdrawal.
- Enter a competition, promotion, or survey.
- Contact customer support.
- Set responsible gambling limits or self-exclude.
- Automated technologies or interactions: As you interact with our website and play "Drop the Boss", we will automatically collect Technical Data and Usage Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. Please see our Cookie Policy for more 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 analytics providers (e.g., Yandex.Metrica), advertising networks, and search information providers.
- Contact, Financial, and Transaction Data from providers of technical, payment, and delivery services.
- Identity and Contact Data from data brokers or aggregators.
- Identity, Contact, and Verification Data from publicly available sources (e.g., Companies House, electoral register) and identity verification services for KYC/AML purposes.
- Responsible Gambling Data from organisations assisting with problem gambling, where legally permissible and necessary to protect you.
4. How We Use Your Personal Data (and Legal Basis)
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 (e.g., to allow you to play the game and process your bets/winnings).
- 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 (e.g., to improve our services, prevent fraud, or conduct marketing).
- Where we need to comply with a legal obligation (e.g., UKGC licensing requirements, AML regulations, responsible gambling duties).
- Where you have given your consent for a specific purpose (e.g., for certain types of marketing).
Here is a table outlining the ways we plan to use your personal data, and which of the legal bases we rely on to do so:
| Purpose/Activity | Type of Data | Lawful Basis for Processing |
|---|---|---|
| To register you as a new customer | Identity, Contact | Performance of a contract with you |
| To process and manage your bets and winnings | Identity, Contact, Financial, Transaction, Usage | Performance of a contract with you; Legal obligation (AML, UKGC) |
| To provide and improve our game "Drop the Boss" | Usage, Technical, Identity | Performance of a contract with you; Legitimate interest (to develop our products/services, improve user experience) |
| To manage our relationship with you | Identity, Contact, Marketing & Communications | Performance of a contract with you; Legitimate interest (to keep our records updated, study how customers use our products/services); Legal obligation |
| To detect and prevent fraud and crime | Identity, Contact, Financial, Transaction, Technical, Verification | Legal obligation (AML, counter-terrorism financing); Legitimate interest (to protect our business and customers) |
| To comply with responsible gambling obligations | Identity, Contact, Transaction, Usage, Responsible Gambling | Legal obligation (UKGC social responsibility requirements); Legitimate interest (to protect vulnerable players) |
| To send you marketing communications | Identity, Contact, Marketing & Communications, Usage | Consent; Legitimate interest (to promote our products/services to existing customers where appropriate) |
| To conduct website analytics and improve user experience | Technical, Usage | Legitimate interest (to define types of customers for our products/services, to keep our website updated and relevant, to develop our business, to inform our marketing strategy); Consent (for non-essential cookies) |
| To ensure network and information security | Technical | Legitimate interest (to prevent unauthorised access, protect data); Legal obligation |
5. Disclosure of Your Personal Data
We may share your personal data with the parties set out below for the purposes stated in Section 4:
- Internal Third Parties: Other companies within Mirror Imago Gaming Ltd. group acting as processors or joint controllers, providing IT and system administration services and undertaking leadership reporting.
- External Third Parties:
- Service Providers: Acting as processors who provide IT and system administration services, payment processing, fraud prevention, and customer support.
- Gambling Regulators and Authorities: Including the UK Gambling Commission (UKGC) and other relevant licensing bodies, to comply with legal and regulatory obligations, including responsible gambling and AML duties.
- Anti-Fraud and Crime Prevention Agencies: To protect our business and customers from fraud and other criminal activity.
- Responsible Gambling Organisations: Such as GamCare, BeGambleAware, or self-exclusion schemes like GAMSTOP, to support our commitment to responsible gambling.
- Professional Advisers: Including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.
- Marketing and Analytics Providers: Such as Yandex.Metrica (see Section 6 for details on international transfers).
- Affiliate Partners: If you click on an affiliate link on our site and proceed to register or play on a partner's site, we may share limited, pseudonymised information (such as a unique identifier) to track the referral and facilitate commission payments. This is based on our legitimate interest in operating our business and is done in compliance with advertising standards (e.g., ASA) and data protection laws.
- Potential Purchasers: Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. 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 policy.
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
Some of our external third parties may be based outside the UK and European Economic Area (EEA), so their processing of your personal data will involve a transfer of data outside the UK/EEA.
Whenever we transfer your personal data out of the UK/EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK government.
- Where we use certain service providers, we may use specific contracts approved by the UK government which give personal data the same protection it has in the UK.
Specific Disclosure: Yandex.Metrica (Russia)
We use Yandex.Metrica for web analytics to understand how visitors use our website, allowing us to improve user experience and game performance. This service is provided by Yandex LLC, a company based in Russia.
As Russia is not recognised by the UK government as providing an adequate level of protection for personal data, this means that your data transferred to Yandex.Metrica may be subject to different data protection laws than those in the UK. While we take measures to protect your data, such as anonymising IP addresses where possible and using contractual clauses where available, you should be aware that the level of protection may not be equivalent to that offered under UK GDPR. By continuing to use our site and accepting analytics cookies, you acknowledge and accept these potential risks associated with international data transfers to Russia. We believe this processing is justified by our legitimate interest in understanding and improving our website for all users.
7. Data Security
We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. This includes:
- Encryption: Data is encrypted both in transit and at rest where appropriate.
- Access Controls: Strict access controls and authentication mechanisms are in place to limit access to personal data only to 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.
- PCI DSS Compliance: For financial transactions, we adhere to Payment Card Industry Data Security Standard (PCI DSS) requirements, ensuring that your payment card data is handled with the highest level of security.
- Regular Audits and Training: We regularly review our security practices and provide ongoing data protection training to our staff.
We have procedures in place 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. For any concerns, please visit our contact page.
8. Data Retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
- Gambling Records: Under UKGC regulations and AML laws, we are required to keep certain records, including transaction data and identity verification documents, for a minimum of five years from the end of the business relationship. Try our demo version to experience the game.
- Responsible Gambling Data: Information related to self-exclusion and responsible gambling measures may be retained for longer periods to ensure ongoing protection of vulnerable players.
9. Your Legal Rights
Under UK data protection law, you have rights in relation to your personal data. These include 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 data we hold about you corrected, though we may need to verify the accuracy of the new 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 to continue 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, where we may have processed your 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 data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the 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 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 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.
If you wish to exercise any of these rights, please contact us at [email protected].
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 could refuse to comply with your request in these circumstances.
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.
We try to respond to all legitimate requests within one month. Occasionally it could 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. Cookies and Similar Technologies
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them, please see our dedicated Cookie Policy.
11. Responsible Gambling
Our commitment to responsible gambling is integral to our operation. We use the data we collect to support this commitment by:
- Monitoring Gameplay Patterns: We actively monitor gameplay patterns and transaction data for signs of problematic gambling behaviour. This analysis, which may involve automated processing, is solely for the purpose of identifying and intervening to protect our users, in line with our legal and ethical obligations.
- Implementing Player Protection Tools: We process data related to deposit limits, self-exclusion requests, and other responsible gambling tools you may activate to ensure their effective implementation.
- Reporting: Where legally required, we share anonymised or aggregated data with the UKGC and other relevant authorities to contribute to responsible gambling research and policy development.
If you are concerned about your gambling, please visit the following organisations for support:
www.gamcare.org.uk
www.begambleaware.org
12. Automated Decision-Making and Profiling
We may use automated decision-making and profiling in the following areas:
- Fraud Prevention: To detect and prevent fraudulent activities, we may automatically flag transactions or account behaviours that appear suspicious.
- Responsible Gambling: We use automated profiling to identify patterns of play or spending that may indicate a risk of problem gambling. This helps us to intervene proactively and offer support or apply limits.
- Personalised Marketing: We may use profiling to tailor marketing communications to your interests, where you have consented to receive marketing.
Where automated decisions have a legal or similarly significant effect on you (e.g., account closure due to suspected fraud, or mandatory self-exclusion due to problem gambling indicators), you have the right to request human intervention, express your point of view, and contest the decision.
13. Third-Party Links
Our website may include links to third-party websites, plug-ins, and applications. Check out our freespins offers for additional value. 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 policy of every website you visit.
14. Changes to This Privacy Policy
We keep our Privacy Policy under regular review. Any changes we make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by email. We encourage you to check back frequently to see any updates or changes. Visit our homepage for the latest updates. This policy was last updated on the date indicated at the top of the document.
15. Contact Us
If you have any questions about this Privacy Policy or our privacy practices, please contact our privacy team in the following ways:
- Email: [email protected]
- Postal Address:
Mirror Imago Gaming Ltd.
International House, 223 Regent Street,
London W1B 2QD,
United Kingdom
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.