This website (the “Website”) is operated and owned by “ALRCD Services LTD” (“ALRCD Services LTD”, “we”, “us” or “our”). ALRCD Services LTD and its affiliates are committed to protecting and respecting your privacy.

This Privacy Policy together with the Terms and conditions apply to your use of this Website: https://ratingtheraces.com/ and any of the services accessible through this Website (the “Services”).

This Privacy Policy outlines the method and framework on which any personal data we collect from you, or that you provide to us, will be processed and used by us.

In the course of this Privacy Policy “personal data” (“personal data”, “personal information”, “your data”, “your information”) means data relating to natural person who is identified or can be identifiable directly or indirectly, in particular by reference to the data which is provided to us by you or collected by us from you and therefore come into the possession of the data controller, i.e. ALRCD Services LTD.

We have been making our best efforts in order to comply with European General Data Protection Regulation (“General Data Protection Regulation”, “GDPR”) as well other with other relevant EU data protection rules.

To be more specific, this Website is compliant with the following national and international legislation with regards to data protection and user privacy:

• UK Data Protection Act 1988 (DPA)
• EU Data Protection Directive 1995 (DPD)
• EU General Data Protection Regulation (GDPR)

Please take your time to read this Privacy Policy carefully and make sure you understand it clearly.

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.

This Website is not intended for children and we do not intentionally collect data relating to children.

This Website may include links to third-party websites, applications or plug-ins. 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.

ALRCD Services LTD (“ALRCD Services LTD”, “we”, “us”) – is a legal entity registered under the law of England and Wales with its registered number: 07635912. Our address is 5 Edgar Close, Swalecliffe, Whitstable, Canterbury, Kent, CT5 2SA, United Kingdom.

We act as Data Controller in respect of your personal data that we process. If you have any questions about how we collect, store or use your data, please contact us via live chat or our contact form.

When using this Website or during the registration process on this Website and when you subsequently use your account, you may be requested to submit specific personal data including but not limited to:

• your first and last name,
• date of birth,
• credit card or other payment data,
• home or another physical address,
• e-mail address,
• phone/mobile number,
• other contact data,
• your unique user name and password combination for your account.

Once you have created an account and have become our customer, additional information is processed on an on-going basis. Please be informed that we may also collect:

• a record of all internet communications and details of your visits to our Website;
• technical information relating to how you use our products, such as the type of device you are using and the browser you are using to access our Website;
• payment information and details of transactions you carry out through this Website;
• communications with us or our employees, for examples, calls, emails, and messages sent through the live chat service;
• information regarding your location, including IP address and traffic information;
• any additional information you submit through the website for example on forums, chat rooms, comment sections or in response to quizzes and questionnaires;
• pages that you visited including what you have clicked on. Please see the Cookie Policy for more information;
• sometimes we may also request photo ID, proof of address, transaction ID for payments;
• your ID in social networks.

To protect both you and us, we may Services which are provided by third parties to help us decide whether to accept transactions from you by assessing your method of payment, and the devices you use to visit our Website.

Every time when we are processing your personal data we are governed by following principles:

• personal data is processed lawfully, fairly and in a transparent manner in relation to you;
• personal data is collected only for specified, explicit and legitimate purposes;
• personal data is always adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
• accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay.

We may process your personal data for a number of different purposes. For each purpose we must have a legal ground for such processing.

Generally such legal grounds are as follows:

• you have given us explicit consent to the processing of your personal data;
• processing is necessary for the performance of a contract to which you are the party or in cases you requested us to process your prior to entering into a contract;
• processing is necessary for compliance with our legal obligation to which we are the subject;
• processing is necessary in order to protect your vital interests or of another natural person;
• processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority laid upon us as controller;
• processing is necessary for the purposes of the legitimate interests pursued by us or by third party.

What do we mean when we say “Legitimate interest” and “Performance of Contract”?

Legitimate Interest shall mean our interest as a business in conducting and managing. We hereby confirm that 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).

Performance of contract means processing of 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.

We use your personal data in order to provide you with best experience and to ensure we meet applicable regulatory and legal requirements and obligations.

For example, we generally process your personal data for the following purposes:

• Creating your account and providing you with full range of our services.

We use your personal data such as your name, date of birth, email address to help you to set up your account on this Website and, if necessary, to contact you via your registered contact information in connection with the management and operation of your account.

We also use your personal data such as your device type, location and browser preferences to manage your account. We want to ensure that you can use the best version of this Website or any of Services on your device and are authorised for such use in your current location.

• To ensure that our Website functions correctly or to identify any technical issues.

Since we always want to provide our users with the best experience, our use of your personal data may help us to conduct internal research and development, to diagnose technical system issues or to test our Services or make relevant improvement.

• To ensure you legal age and gamble responsibly.

According to our legal obligations we are committed to ensure your legal age and gamble responsibly. It helps us to provide you with a safe environment to gamble and to monitor you for potential at-risk behaviour. Also this includes the identification and verification of individuals under anti-money laundering legislation, ensuring customers are over 18 and to comply with responsible gambling rules and initiatives. In order to verify your legal age we may disclose such information to approved third parties with many safeguards in place.

• Legal and regulatory obligations.

According to law we are required to process and retain your personal data including but not limited to your name, account number, date of birth and location to prevent fraudulent activity, to detect and/or investigate crimes, and to ensure responsible gambling.

• Marketing.

Dependent on your marketing preferences, we may use your personal data to send you different marketing materials such as information about brands, products, services, prizes, special offers, etc.
You can choose not to receive marketing materials at any time by managing your marketing preferences in your account or by contacting us directly.

• Prevention of crime.

In order to comply with our legal obligations we use various policies and procedures designed to detect and prevent criminal activity. This includes fraud detection and anti-money laundering programme (AML). We carry out this processing to comply with our legal obligations.

• Processing your online financial and wagering transactions.

We may use your personal data such as your account details, payment type(s), transaction id for security measures and for our regulatory reporting.

• Profiling and your preferences.

We may create new data about you by processing your data including but not limited to your behaviour, interests, location and age to develop new features and improve functionality of this Website or Services. In addition to that, we may research your preferences to develop new features, functionality, products and services. Besides that profiling falls under the scope of our legal interests since we execute profiling of your personal data in order to meet applicable legal requirements with regards to anti-money laundering, age verification, prevention of fraud, sports integrity and responsible gambling.

• Risk management.

In course of implementation of our legitimate interest and legal obligations we may review your customer profile and your betting data for the purposes of enforcing our terms of service and managing our financial liabilities and risk on events and markets.

We may disclose your personal data if such disclosure is required or permitted by law.

In some cases personal data may be shared with certain third parties or third party service providers as well as between our internal departments (engineering, analytics, legal, customer and marketing, etc.) for the purposes specified 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.

Some of our external third parties may be based outside the European Union (EU) or European Economic Area (EEA) which means that the processing of your personal data will involve a transfer of data outside the EU or EEA.

Whenever we transfer your personal data out of the EU and EEA, we ensure that 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 European Commission;
• where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in the EU;
• where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the EU and the USA.

If there is neither adequacy decision nor appropriate safeguards implemented we still may transfer your personal data out of the EU or EEA due to following justifications:

• we have been informed you about the possible risks of transfers of your personal data and you has explicitly consented to the proposed transfer of your personal data out of the EU or EEA;
• the transfer is necessary for the performance of a contract concluded between you and us or if you requested us to perform any pre-contractual measures;
• the transfer is necessary for the conclusion or performance of a contract concluded between us and other natural or legal person for your benefit;
• the transfer is necessary for important reasons of public interest;
• the transfer is necessary for the establishment, exercise or defence of legal claims;
• the transfer is necessary in order to protect your vital interests or interests of other persons in cases where you are physically or legally incapable of giving consent;

We may also be required to disclose your information to government authorities, such as the police or our regulators, to comply with our legal obligations. Personal information may also be shared with regulators, agencies or relevant sports bodies where there are suspicions of involvement in match-fixing or breach of sports regulations. We will also disclose information as required to enforce our terms of use as stated in the Terms of Conditions.

In the event of the sale of our business, or other business event, which results in us having to transfer your personal data to a third party, you will be notified via email, or notice posted on our website, to explain the identity of the new data controller and your options regarding your personal data.

This Website may contain links to and from the Websites of third party organisations. Please note that these Websites may have their own privacy policies and that we do not accept any responsibility whatsoever for these policies. Please check these policies carefully before you submit any personal data to any third party organisations.

ALRCD Services LTD is incorporated in the UK and in most cases your data is stored within the EEA on our servers. However, we also work with third parties and eventually your personal data we collect from you may be transferred to, and stored at, a destination outside the EEA.
We ensure there are appropriate contractual controls over any third party that helps us process your data, which ensuring that your rights are upheld and your data is secure.
We store your data for as long as you are an active customer with us. Once you are no longer our customer, we will hold your personal data on our systems for as long as is necessary to comply our legal obligations in your jurisdiction, such those imposed by tax, gambling and AML laws.

Please feel free to contact us in case if you want to get more information on the specific mechanism used by us when transferring your personal data outside the EU or EEA.

Under EU data protection law you have certain rights in relation to the personal information that we hold about you. You may exercise these rights at any time by contacting us using the contact details set out in this Privacy Policy.

• The right to request access to your personal data. This means that you may request us to send you a copy of the personal data we hold about you and to check that we are lawfully processing it.
• The right to request correction of the personal data. This means that you may request any incomplete or inaccurate data we hold about you to be corrected.
• The right to 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, where we may have processed your information unlawfully or where we are required to erase your personal data in order to comply with any relevant applicable laws. Please note that sometimes we may be unable 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.
• The right to object to processing. You may object to processing of your personal data where you know or have grounds to assume that such processing impacts on your fundamental rights and freedoms. Also you have the right to object processing at any time where we are processing your personal data for direct marketing purposes. We may demonstrate that we are processing your data due to legitimate grounds which in certain circumstances override your rights and freedoms.
• The right to request restriction of processing of personal data. You may request us to suspend the processing when you want us to make the processed data accurate; or the processing of data is unlawful but you do not want us to erase it; or if 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 you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• The right to request the transfer of your personal data to you or to a third parties. It means that upon your request we will provide you, or a third party you have chosen, with your personal data in a structured, commonly used, machine-readable format. Please note that this right only applies to data which are processed by automated means and only in cases where you provided us with the relevant explicit consent to such processing or processing is used in course of performance of contract.
• The right to withdraw consent at any time. You may withdraw your consent to processing of your personal data at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

If you wish to exercise any of the rights set out above, please contact us directly via email specified in this Privacy Policy.

“Cookies” are small pieces of information that are stored by your browser on your device. Like most websites, we use cookies to keep track of your activity and enhance your experience. We also use cookies to assist us in the fight against fraud or malice. If you wish not to receive cookies, you can disable them on of the toolbar of your browser at any time. However, if you do that, you may not be able to access certain areas or features of this Website. Please see our Cookie Policy for further details.

We will keep your personal data only as long as it is necessary in order to fulfil the purposes the personal data was collected for, including without limitation the purposes of compliance with any relevant reporting, accounting or legal requirements.

When determining how long your personal data will be kept with us, we consider following factors: nature, sensitivity of the personal data and its amount; the potential risk of harm from unauthorised use or disclosure of your personal data; the purposes for which we collected your personal data and process it; applicable legal requirements.

Where we are processing your personal data for marketing purposes, we may contact you at least every month to ensure you are pleased to continue receiving our marketing communications. You may require us not to use your personal data for marketing purposes or object to such processing at any time by managing your marketing preferences in your account or by contacting us directly.

In some circumstances we may anonymise and/or pseudonymize your personal data for statistical research purposes. In such cases your personal data will not be longer associated with you and we may use this it indefinitely without further notice to you.

We reserve the right to change, amend or modify this Privacy Policy without notice at any time and from time to time, including as needed to comply with the appropriate laws and regulations. Any changes, amendments or modifications will be posted on this page. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of this Website or Services.

Sometimes we may need to request specific information from you in order to 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 will report any unlawful data breach of this Website’s database or the database(s) of any of our third party data processors to any and all relevant persons and authorities within 72 hours of the breach if it is apparent that personal data stored in an identifiable manner has been stolen.
In the UK, data breaches are to initially be reported to the Information Commissioner’s Office.

We will make our best efforts to respond to all your legitimate requests within 1 (one) month. Sometimes it may take us longer than a 1 (one) 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.

You have the right to lodge a complaint with a data protection authority, in particular in the state or country of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of your personal data infringes the applicable Data Protection Law.

However, we would appreciate the possibility to deal with your concerns before you send your complaint to supervisory authority so please contact us in the first instance.

If you have any questions or concerns about this Privacy Policy or the collection, use or handling of your personal information, feel free to contact us at any time via live chat or our contact form.

You may also contact us via mail at ALRCD Services LTD, 5 Edgar Close, Swalecliffe, Whitstable, Canterbury, Kent, CT5 2SA, United Kingdom