Removalists
Playing Wanted Dead Or A Wild Slot game means submitting personal data. This document sets forth exactly how long we store it, the reasons, and what technical protections sit behind each category—all aligned with UK GDPR, the Data Protection Act 2018, and PCI DSS. We handle identity documents, financial transactions, gameplay telemetry, responsible gambling markers, and marketing consents, each with its specific retention clock. Identity records are kept for five years after account closure. Financial logs stay for seven, matching HMRC requirements. Gameplay data undergoes 24 months before anonymisation kicks in. Full card numbers never reach our systems—only tokenised aliases—and every byte is encrypted. Independent auditors verify our automated deletion routines, and any schedule slip triggers a full incident response. A version-controlled policy log records every edit, and we give you 30 days’ notice before material changes take effect. Subject access and deletion requests are handled within statutory deadlines.
Responsible Gambling and Player Ban Registers
Deposit limits, time checks, and timeout settings are saved for your account’s lifetime and never deleted while it is active. If you self-exclude, your hashed identity and device fingerprints are placed into a specialized exclusion register maintained without time limit under UKGC licence requirements. The register is coded separately, checked only at login or registration, and never employed for analytics. Entry is limited to qualified compliance staff, and all lookups are recorded for three years. The register contains only identity blocks—no financial or gameplay records. We check it annually to rectify errors and remove deceased individuals. Apart from that, it stays permanent. This retention is required and free from deletion requests.
Time Check and Session Limit Enforcement
Reality check counters use short-lived session counters that restart every 24 hours, restarting from your first spin after midnight. Your chosen interval—say, 30 minutes—is stored persistently and routinely reactivates when you come back, even after a long break. Modifying the interval mid-session applies the new value immediately for the next reminder. These settings are deleted only upon confirmed account deletion. Session timer data lies in a specialized, encrypted store separate from gameplay analytics. The 24-hour counter is based on play start, not midnight, for correctness. All timer configurations are checkable through the same three-year access log standard. We do not profile or advertise based on these settings.
User Account and Verification of Identity Data
Main identity data—scans of government IDs, proof of address, biometric selfie matches—are kept for a five-year period after your final session or closure of account, whichever occurs later. This encompasses statutory limitation periods and anti-money laundering responsibilities. We retrieve only the necessary details: document ID, validity, country of citizenship. The high-resolution image gets deleted immediately after extraction. Once five years pass, all original data is purged, but a hash of the verification data persists for two more years inside an audit log. Personal identity information sits encrypted in storage with AES-256-GCM, kept separate from analytics, and every data access is recorded for 3 years. Non-essential fields like place of birth are removed at verification stage to shrink the data volume. Yearly reviews ensure precision and automatically remove outdated records.
Uploading Documents and Biometric Processing
Provide an ID through our secure portal and automated checking completes within a minute and a half. We extract the document number, expiration date, citizenship, and a confidence score, then destroy the full-resolution image immediately—it never touches disk. The initial file stays in an memory buffer and is removed after analysis. A compressed, stamped preview is produced for auditing purposes and stored only for the ID lifecycle. That thumbnail lives in a write-once storage with tight controls and is never exposed to support staff. Retrieved data are encrypted and kept for the 5-year-plus-2-year hash period. All handling runs on servers in the UK with ISO 27001, and every thumbnail access is logged permanently.
Specifics of Biometric Data
Liveness checks collect a short video stream entirely in memory. Video frames are analysed and removed within milliseconds. Only a data vector of facial points persists. This data set lacks any image data and cannot be reconstructed into a face. It stays for the time of identity verification and is permanently deleted upon account closure or after a five-year period. The data set sits in a specialized HSM with self-expiry and is never transferred. Authentication checks happen inside the HSM’s secure enclave without revealing the raw vector. The numerical representation is bound to a anonymous identifier separated from advertising profiles, which makes reidentification very hard. Even system admins cannot view or reconstruct face characteristics from the kept numerical representation.
Marketing Approval and Message Logs
We maintain your consent document—with time stamp, IP-marked, and method-captured—for the entirety of our partnership plus six years after cancellation, to meet PECR obligations. Dispatch records for emails, push messages, and SMS are kept for only thirteen months. Cancelling consent instantly suppresses communications while retaining historical proof. A segmented database ensures suppression without lag, and consent logs are kept in a distinct compliance archive. Dispatch records hold metadata only—heading, timestamp, state—not full message body. The six-year post-withdrawal window mirrors the statute of limitations for regulatory investigations. Quarterly audits verify no expired consents trigger mailings. We never tailor offers with gameplay or financial data beyond explicit consents.
Data Subject Access Request and Deletion Workflows
Upon receiving an SAR, we produce a structured JSON/CSV export of all non-purged data within one month, extendable by two months for complex cases. The export covers live databases, encrypted archives, and processor tokens, delivered via a one-time secure link that expires in 72 hours. For deletion, we cascade: immediate account suppression and token revocation, then scheduled erasure of all personal data not subject to legal hold. We produce a confirmation report specifying erased versus retained categories and their justifications. This report is retained as auditable proof for as long as the longest surviving data category. All requests are logged immutably for five years.
Session Gameplay and Behavioral Analytics Data
Every spin on Wanted Dead Or a Wild records reel positions, RNG seed, and net outcome with microsecond precision. We retain these raw logs for twenty-four months, then compact them into an anonymous statistical digest utilized for game design. Session behavioural profiles—average bet, spin cadence, feature buy-ins—persist for the same 24-month window and are then deleted. Feature trigger heatmaps stay for 12 months before merging into a global model. RNG seed audit trails have 36 months. Error diagnostics get 90 days. No individual gameplay data flows into credit or marketing profiling. All logs are encrypted and off-limits to marketing teams.
- Spin-level logs: 24 months from event date, then aggregated aggregation
- Session behavioural profiles: 24 months from last session, then deleted
- RNG seed audit trails: 36 months to meet technical standards
- Feature trigger heatmaps: 12 months, then combined into global model
- Error and crash diagnostic logs: 90 days, then cycled out
Fundamental Definitions and Scope of Personal Data
We adopt a comprehensive approach on what constitutes personal data. Direct identifiers—name, email, billing address, masked payment details—coexist with indirect signals like hashed IP addresses, device fingerprints, browser agents, and advertising tokens. Behavioural data covers session length, bet sizing, spin velocity, and how often feature triggers fire. Even pseudonymised logs can link back to a person when stitched together, so we regard them as personal. Our lawful bases are contractual necessity, legitimate interest for fraud prevention, and explicit consent for game-related marketing. Full card numbers get tokenised before storage. We never collect special category data. Encryption and access controls apply uniformly, and retention rules extend across live databases, archives, and backups without exception. Each window begins counting from the last activity or transaction date, spelled out below. We revisit definitions every six months to stay aligned with regulatory guidance.
Technical Infrastructure and Data Storage
All data is stored in UK-based ISO 27001 Tier III+ data centres, never replicated outside the UK. A hot disaster recovery site in a separate UK zone syncs every six hours. Backups are encrypted client-side and follow identical retention rules. We enforce least privilege with hardware MFA for administrators, recording their sessions in an immutable three-year audit trail. Multi-factor authentication uses a hardware token and biometric check. Penetration tests run quarterly, and an independent auditor confirms automated purge schedules. Any deviation raises a Severity 1 incident, reported to our DPO within four hours. We also keep an air-gapped backup rotated weekly, following the same deletion policies.
Encryption Key Lifecycle Management
Master keys change every 90 days automatically inside an HSM. New keys are not extracted in plaintext. Rotated keys are stored for the data’s retention period plus 12 months for lawful forensic access. When a data category is purged, its key is destroyed inside the HSM, making any backups unrecoverable. We assign each key to a single data partition, avoid reuse, and conduct quarterly witnessed key ceremonies logged immutably for five years. The offline archive of old keys demands dual control and is stored on write-once media in a fireproof safe. Annual recovery drills guarantee forensic decryption works when needed. No plaintext key material ever leaves the HSM boundary.
Payment Transaction and Settlement Records
Deposit, withdrawal, and wager logs are retained for seven years from the transaction date, per HMRC and FCA rules. We do not store full PANs or CVVs. We record only the BIN, last four digits, and a tokenised reference. Chargeback disputes halt the contested record until final outcome, after which the seven-year clock resumes. Data is partitioned quarterly so automated purging operates cleanly, with monthly deletion runs verified by auditors. Tokenised card references stay valid only while your account is open and are wiped within thirty days of closure. Aggregated, anonymised totals persist for financial reporting without any personal identifiers. All financial data is coded and isolated from marketing systems.
Tokenised Payment Instruments and Processor References
Payment gateways produce vaulted tokens that map your card to a non-sensitive identifier. We hold them for the account lifetime plus a thirty-day grace window, then send deletion commands to the processor and clear our own mapping. The only remnant left behind is an anonymised transaction hash used in aggregate reports, themselves deleted after seven years. No usable credentials ever exist on our systems. We check token revocation daily and initiate incidents if deletion does not work. Tokens are linked to our merchant code and cannot be used other places. Weekly reconciliation verifies authenticity, and tokens tied to lost or stolen cards are invalidated immediately. All token operations are documented and verifiable. Aggregate reports never disclose individual transaction hashes.
Policy Evaluation and Incident Reporting Protocols
We assess this policy every six months or upon material change to the game or regulation. Reviews are minuted with DPO, CISO, and legal counsel. A public summary is published in our privacy centre, minus confidential details. Material changes are emailed 30 days ahead. Minor edits are silently recorded. If a breach occurs affecting data under this policy, we alert affected individuals within 72 hours if high risk, report with the ICO, and post a transparency notice. Third-party processor breaches must follow the same protocol. We maintain a breach notification log audited quarterly. Post-incident reviews revise controls as needed. Biannual tabletop exercises simulate misconfigurations and ransomware to test our response.
Document Versioning and Change Log
We preserve a version-controlled history of this policy with semantic versioning and plain-English summaries of each change. The log specifies exactly which sections changed and why. Previous versions remain accessible for comparison, so you can see precisely what was added or removed. Material modifications affecting your rights are communicated via email at least thirty days in advance. Minor typographical fixes are deployed silently but still recorded. Each entry is cryptographically signed to prove integrity, and annual independent audits check the log’s accuracy. The log is a living document reflecting our evolving data practices. You can access the full change log through a link in our privacy centre at any time. This transparent approach demonstrates our commitment to accountable data governance.