Terms and conditions

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Customer and Supervision Register of Casino Helsinki

PRIVACY POLICY

- Combined description of file and information document
Personal Data Act (523/1999), sections 10 and 24
19 September 2011

1. Controller

Veikkaus Oy (hereinafter referred to as “Veikkaus”)

Casino Helsinki (hereinafter referred to as “CH”)
Mikonkatu 19
00100 Helsinki
Phone: switchboard +358 (0)200 55000 (pvm/mpm)

2. Contact person in register matters

Marko Hurme
Mikonkatu 19
00100 Helsinki
Phone: +358 (09) 43701

3. Name of register

Customer and supervision register of Casino Helsinki (CH)

4. Purposes of use of personal data

Based on section 51 of the Lotteries Act (1047/2001), casino operators are entitled to keep a personal register (casino customer and supervision register) for the purposes of supervising gaming activities.

In addition to what is provided in the Lotteries Act, the Personal Data Act (523/1999) also applies to the casino customer and supervision register.

The purposes of use of customer and supervision register of Casino Helsinki are:
- Supervision of gaming activities. Ensuring the quality and safety of operations.
- Identification, authentication and authorisation of customers. Access control.
- Execution of CH’s activities, games and services, as well as analysis, reporting, development and personalisation. Verification and administration of gaming, service and payment events.
- Customer service and operative management, administration and development of customer relationship. Management of customer information and customer and contact history.
- Execution and monitoring of customer and marketing communications. Processing of customer feedback. Management of communications and campaign history.
- Analysis, grouping and development of customer relationships. Research and statistical analysis.
- Focusing of customer and marketing communications, development of product and service offering as well as development and reporting of business operations.
- Prevention and investigation of misuse and problem situations.
- Ensuring the legal protection of customers and Veikkaus and following the obligations resulting from legislation and regulations of the authorities.

Recordings of phone calls with customers are used for ensuring the legal protection of customers and Veikkaus, developing the quality of service and for security reasons.

The purpose of the Casino Club loyal customer register, which is a subregister of the customer and supervision register, is additionally used for the specific care of the customer relationship and the focusing of rewards to customers.

5. Information content of the register

CH’s customer and supervision register contains the following information:
Basic information of the customer:

- First name and family name
- Gender
- Date of birth
- Nationality
- Contact details: Address in Finland (updated from the Population Information System), mail address (provided by the customer), phone number, e-mail address
- For foreign customers: passport number, date and place of issue
- Photo of the customer

Unique identifiers
Unique identifiers of the customer
- Personal ID number
- Name, number of other identifying information of the document used for the verification of identity, or a copy of the document
- Customer number
- Customer card number

Information concerning the customer relationship
- Start and end date of customer relationship
- Time of arrival at casino
- Prohibition on admission or play
- Information on gaming activities at the casino
- Suspected or proven gaming fraud
- Information on any disturbance-causing behaviour
- Information concerning the prevention of misuse
- Gaming restrictions and blocks and their periods of validity (see section 11 for more details)
- Customer grouping information
- Information from external sources of information (see section 6 for more details)
- Recordings of phone calls with customers
- Customer feedback
Gaming, service and payment event information
- Gaming event information
- Game purchases
- Information on cashing of winnings and payouts

Information on Casino Helsinki employees collected using observation or filming with technical equipment may also be gathered and stored in the register (Lotteries Act, section 51.2).

The Casino Club loyal customer register, which is a subregister of the customer and supervision register, additionally contains the following information:
- Loyal customer status
- Start and end date of loyal customer relationship
- Personalisation information provided by the customer

CH only keeps information necessary for the operations of CH and the intended uses of information, when legal preconditions are present for the processing of such information. Information which has become unfit for the intended purpose of use, expired information or information for which the basis of processing no longer exists, is destroyed in a manner which observes the requirements of information security.

6. Regular sources of information

Customer information is primarily collected from the customer themselves upon registration, use of services and customer service, based on information provided by the customer and by means of viewing or filming using a technical device. Gaming event information is collected when the customer uses the services. Customer information is updated and reviewed from the Population Information System in order to ensure that the information is correct and up to date. CH updates prohibitions on direct marketing directly from the direct marketing limitation service of the Finnish Direct Marketing Association, or the so-called Robinson register. In cases allowed by the legislation, information concerning the customer may also be obtained and updated from other external sources of information, which the customer has been informed of.

7. Disclosure and transfer of information

The customer’s personal information is not disclosed outside the controller, with the exception of customers who have ordered a mobile customer card, whose name and phone number information is disclosed to a third party participating in the production of the service on assignment for CH. Information is disclosed to the authorities when it is legally required, such as for the investigation and prevention of misuse.

Personal information of the customer is transferred to the Act on Detecting and Preventing Money Laundering and Terrorist Financing on preventing and clearing of money laundering and terrorist financing (503/2008).

Personal information of the customer may be transferred outside the European Union or the European Economic Space in ways allowed in the Personal Data Act, such as when the data subject has given their consent for it, when an adequate level of information security can be guaranteed by means of agreements, or when information is transferred to a country in which the level of information security is adequate as determined by the European Commission.

8. Principles of protection of the register

Information security of CH’s customer and supervision register as well as the confidentiality, integrity and availability of personal data is ensured by means of appropriate technical and administrative measures. Personal data is protected against unauthorised access and illegal or unintentional data processing. Personal data is only processed by those employees of the controller who need the information in order to carry out their tasks and only to the extent required for their duties.

9. Right of inspection

The customer has the right based on section 26–28 of the Personal Data Act to inspect what information concerning them has been stored in the register. Access to some information has been restricted, however, for the purposes of crime prevention and investigation of crimes, for example. Customers may request access to their records by sending a written and signed inspection request to: Casino Helsinki, turvallisuuspäällikkö, Mikonkatu 19, 00100 Helsinki. The inspection request shall detail the name, personal identity number and mail address.
A reply to the inspection request will be sent to the address verified from the Population Information System.

10. Rectification of information

According to section 29 of the Personal Data Act, the customer is entitled to update and change their information when they are authenticated.
CH ensures the accuracy and timeliness of customer information by updating the official personal and contact information of customers from the Population Information System. Any changes made in the Population Information System, such as change of address, are updated automatically in CH’s customer and supervision register, although with a short delay.

11. Consents and prohibitions of direct marketing

The customer has the opportunity to update their consents and prohibitions concerning direct marketing when they are authenticated.

The customer may give their consent for direct marketing
- by e-mail
- by mobile phone

The customer may prohibit
- direct marketing using the mail address
- CH updates prohibitions for direct marketing using the mail address also from the direct marketing restriction service of The Finnish Direct Marketing Association.

If the customer has not provided any consents for CH and they have prohibited all direct marketing, no direct marketing, telesales or marketing and opinion surveys will be carried out by phone, mail or e-mail.

12. Gaming restrictions or prohibitions

The customer may set a prohibition of admission or gaming for themselves and update such prohibitions when they are authenticated.

Veikkaus' Marketing Register

PRIVACY POLICY

- Combined description of file and information document

Personal Data Act (523/1999), sections 10 and 24

22 August 2012
 
1. Controller

Veikkaus Oy (hereinafter referred to as “Veikkaus”)
Turuntie 42
02650 Espoo
Phone: switchboard +358 9 43701

2. Contact person in register matters

Vivi Orkola
Turuntie 42
02650 Espoo
Phone: switchboard +358 9 43701

3. Name of register

Veikkaus’ marketing register

4. Purposes of use of personal data

Processing of personal data is based on section 8 or 19 of the Personal Data Act.

Purposes of use of personal data are:
- Marketing of products and services offered by Veikkaus
- Focusing, execution and monitoring of marketing communications
- Data analysis, preparation of statistical analyses
 
5. Information content of the register
Veikkaus’ marketing register contains the following information on data subjects:
- name
- contact details (address, e-mail address, phone number)
- date of birth
- title or profession
- gender
- mother tongue
- grouping information of the person
In addition, information on marketing consents and prohibitions stated by the data subject are stored in the register.
 
6. Regular sources of information
Personal information is primarily obtained from the person themselves when they use Veikkaus' products and services and when they reply to campaigns and surveys, if any. Identification or the Population Information System service is used for verifying that the person is of age.
Veikkaus may update address information of data subjects from the Population Information System service.
Veikkaus updates prohibitions on direct marketing directly from the direct marketing limitation service of the Finnish Direct Marketing Association, or the so-called Robinson register.
In cases allowed by the legislation, information concerning the person may also be obtained and updated from other external sources of information for the above mentioned purposes of use of the register.
 
7. Disclosure and transfer of information
Personal information of the data subject is not disclosed outside Veikkaus with the exception of disclosure to third parties participating in the maintenance and development or the production of the service on assignment by Veikkaus. Personal information of the customer may be transferred outside the European Union or the European Economic Space in ways allowed in the Personal Data Act, such as when the data subject has given their consent for it, when an adequate level of information security can be guaranteed by means of agreements, or when information is transferred to a country in which the level of information security is adequate as determined by the European Commission.
 
8. Principles of protection of the register
Information security of Veikkaus’ marketing register as well as the confidentiality, integrity and availability of personal data is ensured by means of appropriate technical and administrative measures. Personal data is protected against unauthorised access and illegal or unintentional data processing. Only persons specified by Veikkaus and third parties maintaining or developing services on assignment by Veikkaus participate in the processing of personal data. Such persons authenticate themselves in the system using a personal username and password.
 
9. Right of inspection
The data subject has the right based on section 26 and 28 of the Personal Data Act to inspect what information concerning them has been stored in the register. Customers may request access to their records by sending a written and signed inspection request to: Veikkaus Oy, Asiakkuudenhallinta/ tarkastuspyyntö, PL 32, 02601 Espoo. The inspection request shall detail the name, personal identity number, mail address and phone number. Reply to the inspection request will be sent to the address verified from the Population Information System.
 
10. Rectification of information
According to section 29 of the Personal Data Act, the data subject is entitled to update and change their information. Updates and changes may be requested by sending a written and signed request to: Raha-automaattiyhdistys, Asiakkuudenhallinta/muutospyyntö, PL 32, 02601 Espoo. The change request shall detail the name, personal identity number, mail address and phone number.
 
11. Consents of electronic direct marketing and prohibitions of direct marketing
The data subject may give their consent to electronic direct marketing (e-mail and/or mobile marketing) by e-mail or mobile phone and in competitions and surveys, for example.
Based on section 30 of the Personal Data Act, the data subject has the right to prohibit the processing of their information for direct marketing, for example. To prohibit direct marketing and sending of marketing and opinion surveys, the data subject may send a prohibition to: Veikkaus Oy, Asiakkuudenhallinta/kielto, PL 32, 02601 Espoo. In electronic direct marketing, the prohibition option is available in each contact.
Veikkaus updates prohibitions for direct marketing using the mail address also from the direct marketing restriction service of The Finnish Direct Marketing Association.