1. Who We Are
Uplondex ("we", "us", "our") operates the website at uplondex.com. We are the data controller for personal data collected through this website. This Privacy Policy explains what data we collect, why we collect it, how we use it and your rights under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
If you have any questions about this policy or how we handle your data, please contact us through the details provided at the end of this document.
2. Data We Collect
We collect only the minimum data necessary to operate and improve this website:
- Usage data: IP address (anonymised), browser type, device type, operating system, pages visited, time spent on pages, referral source. Collected automatically via analytics tools.
- Cookie data: See our Cookies Policy for full details. We use strictly necessary cookies (age verification, cookie consent preference) and, with your consent, analytics cookies.
- Affiliate click data: When you click through to a casino via our links, your click may be tracked by third-party affiliate tracking systems. This is necessary for us to receive commission. The data processed by those systems is governed by the respective operator's privacy policy.
- Contact form data: If you contact us, we collect your email address and the content of your message to respond to your enquiry.
3. Legal Basis for Processing
We process your personal data on the following legal bases under UK GDPR Article 6:
- Legitimate interests (Art. 6(1)(f)): Analytics to understand how visitors use our website, enabling us to improve content and user experience.
- Consent (Art. 6(1)(a)): Non-essential analytics cookies placed only after you give consent via our cookie banner.
- Contract performance (Art. 6(1)(b)): Processing contact form data to respond to your enquiry.
- Legal obligation (Art. 6(1)(c)): Retaining records where required by law.
4. How We Use Your Data
- To deliver and maintain the website.
- To analyse website traffic and user behaviour (with consent).
- To track affiliate referrals for commission purposes.
- To respond to your enquiries.
- To comply with legal obligations.
- To detect and prevent fraud or abuse.
We do not sell your personal data. We do not use your data for automated decision-making or profiling that produces legal effects on you.
5. Data Retention
- Analytics data: Retained for up to 26 months then automatically deleted or anonymised.
- Contact form data: Retained for 12 months from last contact, then securely deleted.
- Cookie consent records: Retained for 12 months.
- Server/access logs: Retained for up to 90 days for security purposes.
6. Third Parties and Data Sharing
We may share data with the following categories of third party, strictly for the purposes described:
- Analytics providers (e.g. Google Analytics): Aggregate usage statistics. Data is anonymised where possible.
- Affiliate networks: Click and conversion tracking for casino referrals.
- Hosting providers: Server infrastructure. Data is processed under data processing agreements.
- Law enforcement / regulatory bodies: Where we are legally required to disclose data.
We do not transfer personal data to countries outside the UK/EEA unless appropriate safeguards (such as Standard Contractual Clauses) are in place.
7. Your Rights Under UK GDPR
You have the following rights in relation to your personal data:
- Right of access — request a copy of personal data we hold about you.
- Right to rectification — request correction of inaccurate data.
- Right to erasure — request deletion of your data in certain circumstances.
- Right to restriction — request that we limit how we process your data.
- Right to object — object to processing based on legitimate interests.
- Right to withdraw consent — withdraw consent for analytics cookies at any time via our cookie settings.
- Right to lodge a complaint — with the Information Commissioner's Office (ICO) at ico.org.uk or by calling 0303 123 1113.
To exercise any of these rights, contact us using the details below. We will respond within 30 days.
8. Security
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure or destruction. These include HTTPS encryption, access controls and regular security reviews. However, no method of internet transmission is 100% secure.
9. Children's Privacy
Uplondex is not directed at or intended for children under the age of 18. We do not knowingly collect personal data from anyone under 18. If we become aware that a child has provided us with personal data, we will delete it promptly. If you believe a child has submitted personal data to us, please contact us immediately.
10. Links to External Sites
This website contains links to third-party websites, including UKGC-licensed casino operators. We are not responsible for the privacy practices of those sites. We encourage you to read the privacy policy of each site you visit.
11. Changes to This Policy
We may update this Privacy Policy from time to time. When we do, we will update the "last updated" date at the top of this page. Material changes will be communicated via a notice on the website. Your continued use of the website after changes are posted constitutes acceptance of the updated policy.
12. Contact Us
For privacy-related enquiries, to exercise your data rights or to make a complaint, please contact us via the website. We aim to respond to all requests within 30 days in accordance with UK GDPR requirements.
If you are not satisfied with our response, you have the right to complain to the Information Commissioner's Office (ICO): ico.org.uk · Tel: 0303 123 1113.