PRIVACY POLICY

Data Protection & Security Standards

UK GDPR COMPLIANT
ICO REGISTERED
TRANSPARENT
SECURE
Effective Date: 26 October 2023 Last Updated: 26 October 2023

Your privacy and trust are paramount to us. As an online gambling service, we understand that you are entrusting us with sensitive personal and financial information. This Privacy Policy is designed to clearly explain how we collect, use, protect, and share your data when you visit chickenzombies.uk and play our "Chicken Zombies" game, developed by InOut.

We are committed to full transparency, adhering to the highest standards of data protection, and promoting responsible gambling. This document is crafted not just to meet legal obligations, but to address your specific concerns about security, fairness, and our legitimacy, ensuring you feel safe and confident using our services.

1. Who We Are

Chicken Zombies Gaming Limited ("we", "us", "our") operates chickenzombies.uk. We are a company registered in the United Kingdom, committed to providing a secure and enjoyable gaming experience.

Registered Company Name
Chicken Zombies Gaming Limited
Registered Address
71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom
Company Registration Number
12345678
ICO Registration Number
Z1234567 (Information Commissioner's Office)
Website
chickenzombies.uk
Privacy Concerns Email
Data Protection Officer

2. Key Definitions

  • Personal Data: Any information relating to an identified or identifiable natural person.
  • Processing: Any operation performed on Personal Data, such as collection, recording, storage, use, disclosure, or deletion.
  • Controller: The entity that determines the purposes and means of processing Personal Data (that's us, Chicken Zombies Gaming Limited).
  • Processor: An entity that processes Personal Data on behalf of the Controller (e.g., our game provider, payment processor).
  • You/Your: Refers to you, the user of chickenzombies.uk.

3. What Personal Data We Collect

We collect various types of information to provide our services, ensure security, and meet our legal and regulatory obligations. This data can be categorised as follows:

a. Information You Provide Directly to Us:

  • Account Registration Data: When you create an account, we collect your username (e.g., "User f959ab..."), email address, and a password.
  • Identity Verification (KYC/AML): To comply with anti-money laundering (AML) and responsible gambling regulations, we may collect your full name, date of birth, residential address, nationality, and copies of identity documents (e.g., passport, driving licence, utility bills).
  • Financial Data: To process deposits and withdrawals, we collect payment method details (e.g., bank account number, card details, e-wallet information). Note: We do not store full payment card details; these are handled by PCI DSS compliant payment processors.
  • Communications Data: Records of your interactions with our customer support, including emails, chat transcripts, and any feedback you provide.
  • Responsible Gambling Data: Information you provide relating to self-exclusion, deposit limits, or other responsible gambling measures.
  • Preferences: Your chosen avatar from the "Change avatar" menu, and in-game settings such as fullscreen mode, sound/music preferences, and keyboard shortcuts (e.g., "<Space> to spin & go").

b. Information We Collect Automatically from Your Use of the Game and Website:

  • Gameplay Data: Details of your activity in the "Chicken Zombies" game, including:
    • Bet amounts, currency (e.g., RUB), and chosen difficulty levels (Easy, Medium, Hard, Hardcore).
    • Win/loss outcomes, multipliers achieved, and cashout amounts.
    • Your "My bet history" records (Date, Bet, Mult., Win).
    • Game session duration and interactions (e.g., pressing "Play" or "Cashout").
  • Provably Fair Data: We generate and display client seeds and server seed SHA256 values within the "Provably fair settings" to allow you to verify game fairness. While these seeds are not directly "personal data," their generation and your interaction with these settings are logged as part of your gameplay activity.
  • Technical Data: Your IP address, device type, operating system, browser type and version, time zone setting, browser plug-in types and versions, and other technical identifiers.
  • Usage Data: Information about how you use our website and game, including pages visited, links clicked, time spent on pages, and referring URLs.
  • Cookies and Tracking: Data collected via cookies and similar technologies (see Section 11).

c. Information We Receive from Third Parties:

  • Identity Verification Providers: To assist with KYC and AML checks.
  • Payment Processors: Confirmation of successful transactions.
  • Gambling Self-Exclusion Databases: Information regarding your self-exclusion status with other operators or national schemes.
  • Affiliate Partners: If you arrive at our site via an affiliate link, we may receive information about the referring source (see Section 14).

4. How We Use Your Personal Data and Our Legal Basis

We process your Personal Data for specific purposes and rely on clearly defined legal bases as required by the UK General Data Protection Regulation (UK GDPR) and other applicable laws.

a. To Fulfil Our Contract with You:

  • Account Management: To create and manage your account, including username and avatar.
  • Game Operation: To enable you to play "Chicken Zombies," process your bets, manage your in-game balance, and record your wins and losses.
  • Transactions: To process your deposits and withdrawals securely.
  • Customer Support: To respond to your queries, resolve issues, and provide technical assistance.
  • Fairness Verification: To provide "Provably fair settings" and allow you to verify game outcomes, ensuring transparency and trust in our game.
  • Preferences: To save and apply your in-game settings (e.g., sound, music, fullscreen, keyboard shortcuts) and avatar choice.

b. To Comply with Our Legal and Regulatory Obligations:

  • Age Verification: To confirm you are 18 years or older, preventing underage gambling as required by the UK Gambling Commission (UKGC) and other regulators.
  • Anti-Money Laundering (AML): To conduct due diligence checks (KYC) and monitor transactions for suspicious activity, reporting to relevant authorities if necessary.
  • Responsible Gambling: To monitor gameplay patterns, enforce self-exclusion requests, apply deposit limits, and identify potential signs of problem gambling. This proactive approach helps protect vulnerable players.
  • Regulatory Reporting: To report necessary information to gambling authorities (e.g., UKGC) and other government bodies.
  • Fraud Prevention: To detect and prevent fraudulent activities, including bonus abuse and payment fraud.

c. For Our Legitimate Business Interests (where your rights do not override these interests):

  • Improving Our Services: To analyse gameplay and website usage data (e.g., which difficulty levels are most popular, how players interact with controls) to enhance the "Chicken Zombies" game, develop new features, and improve user experience.
  • Security: To maintain the security of our website, systems, and your data, and to protect against cyber threats.
  • Marketing: To send you marketing communications about our game or promotions that may be of interest, where permitted by law (e.g., soft opt-in for existing customers). You can opt-out at any time.
  • Affiliate Management: To track and manage our relationships with affiliate partners (see Section 14).
  • Business Operations: For internal administration, record-keeping, and the exercise or defence of legal claims.

d. With Your Consent:

  • For specific marketing activities that require your explicit consent.
  • For the use of non-essential cookies and tracking technologies (see Section 11).
  • You have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

5. Disclosure of Your Personal Data

We may share your Personal Data with the following categories of recipients:

  • Game Provider: InOut, for the operation, maintenance, and technical support of the "Chicken Zombies" game, and to ensure game fairness.
  • Payment Processors: Secure third-party providers who handle your deposits and withdrawals, ensuring PCI DSS compliance.
  • Identity Verification & AML Providers: Services that help us verify your identity and conduct background checks to meet our legal obligations.
  • Responsible Gambling Organisations: We may share anonymised or aggregated data, or specific data as required by law, with organisations dedicated to preventing and treating gambling addiction (e.g., GamCare, National Gambling Helpline).
  • Regulators & Law Enforcement: We will disclose your data when legally required by the UK Gambling Commission, other relevant gambling authorities, law enforcement agencies, or other government bodies.
  • Fraud Prevention Agencies: To detect and prevent fraud and other criminal activity.
  • Analytics Providers: Yandex.Metrica, to help us understand website and game usage (see Section 7 for details on international transfers).
  • Affiliate Partners: Limited data may be shared with our affiliate partners for tracking referral commissions, but this typically involves anonymised identifiers or aggregated data (see Section 14).
  • IT & Hosting Providers: Companies that provide us with essential IT infrastructure, hosting, and technical support.
  • Professional Advisors: Lawyers, auditors, and other consultants who provide professional services to us.
  • Business Transfers: In the event of a merger, acquisition, or sale of assets, your Personal Data may be transferred to the new owner or entity. We will ensure appropriate safeguards are in place.

We ensure that all third parties with whom we share data are contractually obligated to protect your data to the same standards as set out in this Privacy Policy and comply with UK GDPR.

6. International Data Transfers

Your Personal Data may be transferred to, and stored at, a destination outside the UK and European Economic Area (EEA). This includes processing by staff operating outside these areas who work for us or for one of our service providers.

Important: Yandex.Metrica Data Transfer

We use Yandex.Metrica, a web analytics service provided by Yandex Oy. This involves the transfer of data (such as IP address, device information, and usage data) to servers located in Russia. It is important for you to be aware that the European Commission has not issued an adequacy decision for data transfers to Russia, meaning it does not consider Russia to offer an equivalent level of data protection to the UK/EEA. To safeguard your data, we rely on standard contractual clauses (SCCs) approved by the UK Information Commissioner's Office (ICO) to ensure appropriate safeguards are in place for these transfers. We also take measures to minimise the data shared and anonymise it where possible. By using our site, you acknowledge and accept this data transfer.

Other International Transfers: For other international transfers, we ensure that appropriate safeguards are in place, such as:
  • Standard Contractual Clauses (SCCs) approved by the ICO or European Commission.
  • Binding Corporate Rules (BCRs).
  • Ensuring the recipient country has been deemed "adequate" by the UK government or European Commission.

We will always take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

7. Data Security

We take the security of your Personal Data very seriously and implement robust technical and organisational measures to protect it from unauthorised access, disclosure, alteration, or destruction. These measures include:

  • Encryption: Using SSL/TLS encryption for all data transmitted between your browser and our servers.
  • Access Controls: Restricting access to Personal Data to authorised personnel only, on a "need-to-know" basis.
  • Pseudonymisation/Anonymisation: Where possible, we pseudonymise or anonymise data to reduce identification risks.
  • Network Security: Implementing firewalls, intrusion detection systems, and regular security audits.
  • Payment Security: Adhering to Payment Card Industry Data Security Standard (PCI DSS) requirements for all payment processing. We do not store sensitive payment card details directly.
  • Staff Training: Regularly training our staff on data protection best practices and security awareness.
  • Incident Response: Maintaining a clear data breach response plan to address any potential security incidents promptly and effectively.
Security Notice

While we strive to protect your Personal Data, no system can be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please notify us immediately using the contact details in Section 16.

8. Data Retention

We will retain your Personal Data only for as long as necessary to fulfil the purposes for which it was collected, including for satisfying any legal, accounting, or reporting requirements.

Key retention periods are determined by:

  • Legal & Regulatory Obligations: For example, AML regulations require us to retain certain customer identification and transaction data for a minimum of five years after the business relationship ends.
  • Responsible Gambling: Data related to self-exclusion and responsible gambling measures may be kept for extended periods to ensure ongoing protection.
  • Contractual Necessity: Data required to provide our services and manage your account.
  • Legitimate Interests: Data used for analytics and service improvement, often in an anonymised or aggregated form.

Once the retention period expires, your Personal Data will be securely deleted or anonymised.

9. Your Rights

Under the UK GDPR and other applicable data protection laws, you have the following rights regarding your Personal Data:

  • Right to Be Informed: To receive clear, transparent, and easily understandable information about how we use your Personal Data and your rights. This Privacy Policy serves that purpose.
  • Right of Access: To request a copy of the Personal Data we hold about you.
  • Right to Rectification: To request that we correct any inaccurate or incomplete Personal Data we hold about you.
  • Right to Erasure ("Right to be Forgotten"): To request the deletion of your Personal Data in certain circumstances (e.g., if the data is no longer necessary for the purposes for which it was collected, or if you withdraw consent and there is no other legal ground for processing).
  • Right to Restrict Processing: To request that we limit the processing of your Personal Data in certain situations (e.g., if you contest the accuracy of the data, or if the processing is unlawful).
  • Right to Data Portability: To receive your Personal Data in a structured, commonly used, and machine-readable format and to transmit that data to another controller, where technically feasible.
  • Right to Object: To object to the processing of your Personal Data where we are relying on a legitimate interest (including for direct marketing purposes).
  • Rights in Relation to Automated Decision-Making and Profiling: To object to decisions based solely on automated processing (including profiling) that produce legal effects concerning you or similarly significantly affect you. This is particularly relevant for responsible gambling monitoring, where we use automated systems to identify at-risk behaviour. We ensure human oversight in such cases.
  • Right to Withdraw Consent: Where we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time.
  • How to Exercise Your Rights: To exercise any of these rights, please contact our Data Protection Officer at [email protected]. We will respond to your request within one month. 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).

    10. Children's Privacy

    Our services are strictly not intended for individuals under the age of 18. We do not knowingly collect Personal Data from anyone under 18. If we become aware that Personal Data from an underage individual has been collected, we will take immediate steps to delete such information and close the associated account.

    11. Cookies and Other Tracking Technologies

    We use cookies and similar tracking technologies to enhance your experience on chickenzombies.uk, analyse website traffic, and deliver relevant content.

    What are Cookies?

    Cookies are small text files stored on your device when you visit a website. They help the website remember your preferences and actions over time.

    Types of Cookies We Use:

    • Strictly Necessary Cookies: Essential for the operation of our website and game, enabling core functionalities like secure login, account management, and payment processing. Without these, our services cannot function correctly.
    • Analytical/Performance Cookies: These cookies (including those from Yandex.Metrica) allow us to recognise and count the number of visitors and to see how visitors move around our website and interact with the "Chicken Zombies" game. This helps us improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
    • Functionality Cookies: These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by username, and remember your preferences (e.g., your chosen avatar, sound/music settings).
    • Targeting/Advertising Cookies: These cookies record your visit to our website, the pages you have visited, and the links you have followed. We may use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

    Yandex.Metrica

    As mentioned in Section 6, we use Yandex.Metrica for web analytics. This service collects anonymised data about your usage patterns, such as your IP address, browser type, and pages visited, to help us understand and improve our website performance.

    Managing Cookies

    You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. However, this may prevent you from taking full advantage of the website. You can also manage your cookie preferences through our dedicated cookie consent tool, usually found in a banner or footer on our website.

    12. Responsible Gambling and Player Protection

    As a responsible gambling operator, we are deeply committed to protecting our players from potential harm. We use your data in the following ways to support responsible gambling:

    • Monitoring Gameplay: We analyse gameplay patterns, bet sizes, session durations, and deposit/withdrawal frequency to identify potential indicators of problem gambling.
    • Self-Exclusion & Limits: We process and enforce your requests for self-exclusion and any limits you set on your deposits, losses, or session times.
    • Intervention: Where patterns suggest potential harm, we may use your contact information to reach out and offer support or direct you to responsible gambling resources.

    Support & Resources

    We encourage you to gamble responsibly. If you feel you may have a gambling problem, please seek help from:

    GamCare
    www.gamcare.org.uk
    Freephone: 0808 8020 133
    National Gambling Helpline
    Freephone: 0808 8020 133
    Gamblers Anonymous
    www.gamblersanonymous.org.uk

    13. Commercial Transparency: Affiliate Marketing

    To support the operation and promotion of chickenzombies.uk, we may participate in affiliate marketing programs. This means that if you click on certain links on our site that lead to third-party online casinos or other gambling services, and you subsequently register or make a deposit with them, we may receive a commission from that third party.

    • No Impact on Game Fairness: This commercial arrangement does not influence the fairness, RTP (95.5%), or operation of the "Chicken Zombies" game itself, which is provably fair and independently verified.
    • Data Handling: Our participation in affiliate programs does not affect how your personal data is handled by us, nor does it mean we share your sensitive personal data with our affiliate partners beyond anonymised or aggregated referral data.
    • Transparency: We are committed to transparent advertising practices and aim to comply with all applicable advertising standards, including those set by the Advertising Standards Authority (ASA) in the UK, to ensure any affiliate relationships are clearly identifiable where required.

    14. Changes to This Privacy Policy

    We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or regulatory landscape. Any changes will be posted on this page with an updated "Last Updated" date. We will notify you of any significant changes where required by law (e.g., via email or a prominent notice on our website). We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your data.

    15. How to Complain

    If you have any concerns or complaints about how we process your Personal Data, please contact our Data Protection Officer at [email protected] in the first instance. We will do our best to resolve your concerns.

    If you are not satisfied with our response, you have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK's supervisory authority for data protection issues.

    Information Commissioner's Office
    Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
    ICO Helpline
    0303 123 1113
    ICO Website
    www.ico.org.uk

    16. Contact Information

    If you have any questions about this Privacy Policy or our data protection practices, please contact us:

    Privacy Concerns Email
    Data Protection Officer
    Registered Address
    Chicken Zombies Gaming Limited, 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom