1. Introduction
Welcome to adlibitumcompagnie.com (the "Site"). We are committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, store, share, and protect your personal data when you visit our website, interact with our editorial reviews, send messages to our support team, or participate in our free browser-based social casino games.
This policy is designed to comply with the United Kingdom General Data Protection Regulation (UK GDPR) and the UK Data Protection Act 2018 (DPA 2018). We advise that you read this policy carefully to understand our practices regarding your personal data and how we treat it.
2. Data Controller
For the purpose of UK data protection law, the data controller is:
adlibitumcompagnie Ltd
71-75 Shelton Street
Covent Garden
London, WC2H 9JQ
United Kingdom
Email: privacy@adlibitumcompagnie.com
If you have any questions about this Privacy Policy, including any requests to exercise your legal rights under UK GDPR, please contact our data controller using the details provided above.
3. What Data We Collect
We may collect, use, store, and transfer different kinds of personal data about you, which we have grouped together as follows:
a) Data You Provide Directly
This is information about you that you give us by filling in forms on our Site, submitting enquiries via our contact portal, or providing your details for game registration and lead capture touchpoints. It includes:
- Identity Data: First name, last name, and username.
- Contact Data: Email address, physical postal address (if supplied), and phone number.
- Correspondence Data: Information you include when contacting us (e.g. subject, messages, feedback on reviews, or questions submitted to the AI agent).
b) Data Collected Automatically
As you interact with our Site, we automatically collect technical information about your equipment, browsing actions, and patterns. This data includes:
- Technical Data: Internet protocol (IP) address, 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 Site.
- Usage Data: Information about how you use our Site, products, and services (e.g. pages viewed, time spent on pages, game spin counts, win events, and navigation paths).
c) Cookie and Tracking Data
We use cookies and similar tracking technologies to track activity on our Site and hold certain information. For detailed information, please consult our Cookie Policy.
4. Legal Basis for Processing
Under the UK GDPR, we must have a valid legal basis to process your personal data. We rely on the following bases depending on the context of the data processing activity:
- Legitimate Interests: We process technical and usage data to monitor and maintain Site security, perform traffic analysis, improve our free-to-play game engines, optimize page layouts, and compile demographic statistics. This helps us provide a premium user experience and defend our infrastructure against spam or malicious activity.
- Consent: We process your contact details (specifically email addresses) for newsletters, updates, and loyalty promotions only when you have explicitly opted in via our lead capture portals or contact forms. You have the right to withdraw consent at any time by contacting us or clicking the unsubscribe link in our correspondence.
- Contractual Necessity: When you send a message to us requesting assistance, a partnership proposal, or a review verification, we process your contact and correspondence data to satisfy and respond to your enquiry.
- Legal Obligation: We may process your data where it is necessary for compliance with a legal or regulatory obligation to which we are subject (e.g. replying to law enforcement requests, or demonstrating compliance with tax regulations).
5. How We Use Your Data
We use your personal data in the following ways and for the following reasons:
- To Provide and Manage Our Services: Running the website, displaying reviews, and maintaining local game states (such as virtual coin balances and daily spin logs) in your browser.
- To Respond to Enquiries: Answering messages submitted through our contact form or chat console.
- To Improve the Site: Collecting anonymous analytics to identify bugs, slow page loads, or device-specific rendering errors.
- To Send Marketing Communications: Emailing updates and promotions to users who have registered through lead-generation modals.
- To Comply with Laws: Restricting access to users under the age of 18 and preventing automated scraping.
6. Data Sharing and Third-Party Processors
We do not sell, rent, or trade your personal data. We only share your data with trusted third-party service providers who assist us in operating our Site, conducting our business, or servicing you. These processors are contractually bound to safeguard your data and are prohibited from using it for their own purposes.
Our key processors include:
- Google Analytics: For tracking web traffic volume and general demographic locations (processed using anonymized IP values).
- Hosting Providers: Secure web servers located within the UK or European Economic Area (EEA).
- AI API Providers: Anthropic API handles user queries submitted to our chat assistant. No personal identifying information (PII) is sent to Anthropic unless you enter it directly into the text input box.
International Transfers: Some of our processors may be based outside the United Kingdom (e.g. in the United States). Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded by ensuring that standard contractual clauses (SCCs) or UK Addendums are in place with the processor.
7. Data Retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
- Contact Form Leads: Retained for a maximum of 12 months from the date of submission before deletion or complete anonymization.
- Game Lead Sign-ups: Retained until the user opts out, requests erasure, or after 24 months of inactive engagement.
- Analytics Data: Retained for a maximum of 26 months (the standard default for Google Analytics).
8. Your Rights Under UK GDPR
Under the UK GDPR and the Data Protection Act 2018, you possess several legal rights concerning your personal data. You have the right to:
- Request Access: Obtain a copy of the personal data we hold about you (commonly known as a "Subject Access Request").
- Request Rectification: Ask us to correct any incomplete or inaccurate data we hold about you.
- Request Erasure: Ask us to delete or remove personal data where there is no good reason for us continuing to process it (the "right to be forgotten").
- Request Restriction: Suspend the processing of your personal data in certain circumstances.
- Request Portability: Transfer your structured personal data to yourself or a third party.
- Right to Object: Object to processing where we are relying on a legitimate interest or direct marketing.
- Withdraw Consent: Withdraw your consent at any time where we rely on consent to process your data.
If you wish to exercise any of these rights, please email us at privacy@adlibitumcompagnie.com. We aim to respond to all legitimate requests within one calendar month.
You also 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. We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
ICO Contact Details: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Helpline: 0303 123 1113. Website: ico.org.uk.
9. Security Measures
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, accessed in an unauthorized way, altered, or disclosed. All communication between your web browser and our servers is encrypted using Secure Sockets Layer/Transport Layer Security (SSL/TLS) HTTPS technology. Access to collected lead data is restricted to authorized personnel who require it to perform editorial support tasks.
We have established procedures 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.
10. Children's Privacy
Our Site and the free social casino games provided on it are strictly intended for UK adults aged 18 or older. We do not knowingly collect personal data from anyone under the age of 18. If you are a parent or guardian and you become aware that your child has provided us with personal data, please contact us immediately so we can remove the data from our records.
11. Changes to This Privacy Policy
We may update our Privacy Policy from time to time. We will notify users of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date at the top of the policy. You are advised to review this Privacy Policy periodically for any updates.