Privacy Notice

Luxury Leisure Talarius (and “we”, “us”, or “our”), owned by Novomatic Group, is always committed to protecting your privacy. We aim to respect any personal information you share with us, or that we receive from others, and keep it safe. This Privacy Notice sets out our data processing practices and your rights and options regarding the ways in which your personal information is collected and used, including through our websites and applications.

Luxury Leisure Talarius refers to the companies operating under the control of Luxury Leisure and Talarius Ltd and includes RAL Ltd. Luxury Leisure company number 02448035 and Talarius Ltd company number 05382157.

Luxury Leisure Talarius is the controller for the personal information we process, unless otherwise stated.

What we’ll tell you:

1. How we collect personal information about you
2. What personal information we use
3. How and why we use your personal information
4. Lawful basis
5. Communications for marketing
6. How long we keep your personal information
7. Will we share your personal information?
8. Security/storage of, and access to your personal information
9. International Data Transfers
10. Your data protection rights
11. Changes to this Notice
12. Links and third parties
13. How to contact us

1. How we collect personal information about you

We collect personal information about you:

When you give it to us directly, for example, personal information that you give to us when you communicate with us by email, telephone or letter etc.

When we obtain it indirectly, for example, your personal information may be shared with us by a third party.

When it is available publicly. Your personal information may be available to us from external publicly available sources. For example, depending on your privacy settings for social media services.

When you visit our premises, for example, CCTV recordings and other recordings as the Company deems appropriate for the business.

When you visit our website or use our Wi-Fi services, we automatically collect the following types of personal information:

• Technical information, including a truncated and anonymised version of your internet protocol (IP) address used to connect your device to the internet, browser type and version, time zone setting, browser plug-in types and versions and operating systems and platforms.
• Information about your visit to the websites, including the uniform resource locator (URL) clickstream to, through and from the website (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, referral sources, page interaction information (such as scrolling and clicks) and methods used to browse away from the page.

When you register for or use the Admiral Advan+age App or any other customer loyalty application, we collect:

• Registration details you provide during onboarding, such as your name, email address, date of birth, mobile phone number, gender, and contact preferences.
• Behavioural and analytical data about how you interact with the App, including offers you view, click, save, or redeem, session duration, navigation patterns, and search queries.
• Location data, where you grant explicit permission, either as an approximate location derived from your IP address or precise GPS location if you enable location services.
• Technical device data, including device type and model, operating system, screen resolution, browser type and version, and unique device identifiers.
• Two-factor authentication event logs, including login timestamps and device identifiers linked to each session.

Analytical and behavioural data is collected through Google Analytics 4 (GA4) integrated via Firebase. IP addresses are anonymised by default within GA4; however, other identifiers such as device and session data are pseudonymised and remain personal data under UK GDPR.

We collect and use your information by using cookies on our website — please see our Cookie Policy for more information.

2. What personal information we use

We may collect, store and otherwise process the following kinds of personal information:

• your name and contact details including postal address, telephone number, email address and emergency contact details and, where applicable;
• your date of birth and gender;
• your financial information, such as bank details and credit/debit card details;
• information about your computer/mobile device and your visits to, and use of this website;
• location data (where you have provided explicit consent);
• communication preferences and consent records, including opt-in/opt-out selections, unsubscribe requests, and preferred channels (email, push notification, SMS);
• two-factor authentication event logs, including login timestamps and device identifiers.

Special categories of data

The General Data Protection Regulation (“GDPR”) recognises certain categories of personal information as sensitive and therefore requiring more protection, for example information about your health, ethnicity, and religious beliefs.

In certain situations, Luxury Leisure Talarius may collect and/or use these special categories of data for example, information on customer medical conditions, if they are required to use our services. We will only process these special categories of data if there is a valid reason and where the GDPR allows us to do so.

3. How and why we use your personal information

Your personal information, however it is provided to us, will be used for the purposes specified in this Notice. In particular, we may use your personal information:

• to provide you with services, products or information that you have requested;
• to communicate as necessary with you;
• to provide further information about our work, services or activities (where necessary, only where you have provided your consent to receive such information);
• to answer your questions/requests and communicate with you in general;
• to manage relationships with our partners and service providers;
• to analyse and improve our work, services, activities, products or information (including our website), or for our internal records;
• to keep our facilities safe and secure;
• to run/administer the activities of Luxury Leisure Talarius, including our website, and ensure that content is presented in the most effective manner for you and for your device;
• to audit and/or administer our accounts;
• to satisfy legal obligations which are binding on us, for example in relation to regulatory, government and/or law enforcement bodies with whom we may work (for example, requirements relating to the payment of tax or anti-money laundering);
• for the prevention of fraud or misuse of services;
• for the establishment, defence and/or enforcement of legal claims; and/or
• to notify you about changes to our services;
• to operate and deliver our customer loyalty programme (including the Admiral Advan+age App), personalise offers and rewards based on your preferences and legitimate interest, and manage your loyalty account and redemption history;
• to personalise the offers and content you see within the App based on your interests and prior interactions;
• to fulfil our safer gambling obligations, including identifying and managing customers who have been excluded from our services, and ensuring excluded individuals are not permitted to re-engage with the loyalty programme;
• to deliver marketing communications via push notification, SMS, and email through the App, where you have provided consent.

4. Lawful basis

Under the UK GDPR, the lawful basis we rely on for processing this information are:

• Where necessary to comply with a legal obligation (for example, where we are obliged to share your personal information with regulatory bodies which govern our work and services).
• Where necessary for the performance of a contract to which you are a party, or to take steps at your request prior to entering a contract.
• Where there is a legitimate interest in us doing so.
• Where you have provided your consent for us to use your personal information.

In the context of the Admiral Advan+age App, the specific lawful bases applied are:

• Consent (Article 6(1)(a)): for marketing communications and promotional offers delivered through the App, the collection of location data, and the use of non-essential cookies and analytics tracking. You may withdraw consent at any time through the App settings.
• Contract (Article 6(1)(b)): for processing necessary to operate your loyalty account, including account setup, eligibility verification, preference management, and offer redemption tracking.
• Legal Obligation (Article 6(1)(c)): Added for regulatory purposes such as age verification, AML/KYC checks, and self-exclusion control measure.

• Special Category Data: Health or vulnerability data in relation to safer gambling (Self Exclusions, interactions, national bans) is processed under Article 9(2)(g)

• Legitimate Interests (Article 6(1)(f)): for personalising offers based on your prior behaviour and circumstances, where this falls within your reasonable expectations as a loyalty programme member.

The UK GDPR allows us to collect and process your personal information if it is reasonably necessary to achieve our or others’ legitimate interests (as long as that processing is fair, balanced and does not unduly impact your rights as an individual).

When we process your personal information to achieve such legitimate interests, we consider and balance any potential impact on you (both positive and negative), and on your rights under data protection laws. We will not use your personal information for activities where our interests are overridden by the impact on you, for example where use would be excessively intrusive (unless, for instance, we are otherwise required or permitted to by law).

5. Communications for marketing

We may use your contact details to provide you with information about our work, services and/or activities which we consider may be of interest to you.

Where we do this via email, SMS or telephone, we will not do so without your prior consent (unless allowed to do so via applicable law).

Where you have provided us with your consent previously but do not wish to be contacted by us about our work, services and/or activities in the future, you can opt out of receiving communications from us at any time by clicking the “unsubscribe” link at the bottom of our emails/texts. You can also change your preferences at any time by following the information provided within the communication or contacting us by the contact details below.

Where you use the Admiral Advan+age App, you may manage your communication preferences — including opting in or out of email, push notifications, and SMS — through the preferences section within the App. Any changes you make will be synchronised with our CRM platform within 24 hours to ensure they are respected across all channels.

6. How long we keep your personal information

We will not retain personal information for longer than is necessary and it will only be held for the purposes for which it was obtained.

If you request to receive no further contact from us, we may keep some basic information about you on our suppression list in order to comply with your request and avoid sending you unwanted materials in the future.

In relation to the Admiral Advan+age App:

• Personal data is retained for as long as you maintain an active account and continue to use the App.
• Where your account becomes inactive, your personal data will be deleted after 12 months of inactivity.
• Where you have been excluded from the loyalty scheme, your personal data will be retained for as long as necessary to fulfil our safer gambling obligations and meet regulatory requirements.
• Once the purpose for retaining your personal data has been fulfilled, it will be securely deleted or anonymised in accordance with our data retention policies.

7. Will we share your personal information?

We do not share, sell or rent your personal information to third parties for marketing purposes. However, in general we may disclose your personal information to selected third parties in order to achieve the purposes set out in this Notice.

These parties may include (but are not limited to):

• local authorities and other public bodies;
• establishments/prospective employers (for example if a reference is sought);
• suppliers and sub-contractors for the performance of any contract we enter into with them, for example IT service providers such as website hosts or cloud storage providers;
• professional service providers such as accountants and lawyers;
• parties assisting us with research to monitor the impact/effectiveness of our work, events, services and activities;
• the police;
• regulatory bodies who govern our work, such as the Gambling Commission.

In connection with the Admiral Advan+age App, we share personal data with the following third-party processors, each acting solely on our instructions under formal data processing agreements:

• Amazon Web Services provides cloud infrastructure and hosting for the App and its associated data storage.
• Salesforce: provides the CRM platform used to manage customer accounts, communication preferences, and marketing communications.
• Ornex (Cloudsmart): provides the proprietary messaging system used to deliver email and SMS communications to customers.
• Google (GA4/Firebase): provides analytics infrastructure for the App. IP addresses are anonymised by default within GA4.

In particular, we reserve the right to disclose your personal information to third parties:

• in the event that we sell or buy any business or assets;
• if substantially all of our assets are acquired by a third party, personal information held by us may be one of the transferred assets;
• if we are under any legal or regulatory duty to do so; and/or
• to protect the rights, property or safety of Luxury Leisure Talarius, its personnel, users, visitors or others.

8. Security/storage of and access to your personal information

Luxury Leisure Talarius is committed to keeping your personal information safe and secure and we have appropriate and proportionate security policies and organisational and technical measures in place to help protect your information.

Your personal information is only accessible by appropriately trained staff and is stored on secure servers which have features to prevent unauthorised access.

In relation to the Admiral Advan+age App, additional security measures include: encryption of all data in transit and at rest; network security maintained through Barracuda and Amazon Web Services; two-factor authentication for all database and CRM users; role-based access controls restricting access based on business need; and regular security monitoring and access logging. Incident response procedures are in place to ensure any data breach is identified, contained, and reported to the ICO within 72 hours where required under UK GDPR.

9. International Data Transfers

Given that we are a UK-based organisation we will normally only transfer your personal information within the European Economic Area (“EEA”), where all countries have the same level of data protection law as under the UK GDPR.

We may use agencies and/or suppliers to process personal information on our behalf, it is possible that personal information we collect from you will be transferred to, and stored, in a location outside the EEA, for example the United States.

Please note that some countries outside of the EEA have a lower standard of protection for personal information, including lower security requirements and fewer rights for individuals. Where your personal information is transferred, stored and/or otherwise processed outside the EEA in a country that does not offer an equivalent standard of protection to the EEA, we will take all reasonable steps necessary to ensure that the recipient implements appropriate safeguards designed to protect your personal information.

In connection with the Admiral Advan+age App, personal data may be transferred outside the UK by our processors Amazon Web Services and Salesforce. Both organisations rely on UK International Data Transfer Agreements (IDTAs) and, where applicable, Standard Contractual Clauses approved by the Information Commissioner’s Office to provide a lawful mechanism for such transfers. We have assessed the associated risks and are satisfied that the safeguards in place provide adequate protection.

Unfortunately, no transmission of your personal information over the internet can be guaranteed to be 100% secure. However, once we have received your personal data, we use strict procedures and security features to try and prevent unauthorised access.

10. Your data protection rights

Where we rely on your consent to use your personal information, you have the right to withdraw that consent at any time. This includes the right to ask us to stop using your personal information for marketing purposes or to unsubscribe from our mailing list at any time. You also have the following rights:

• Right of access — you have the right to ask us for copies of your personal information.
• Right of erasure — at your request we will delete your personal information from our records as far as we are required to do so.
• Right of rectification — if you believe our records of your personal information are inaccurate, you have the right to ask for those records to be updated. You also have the right to ask us to complete information you think is incomplete.
• Right to restrict processing — you have the right to ask for processing of your personal information to be restricted if there is disagreement about its accuracy or legitimate usage.
• Right to object — you have the right to object to processing where we are (i) processing your personal information on the basis of our legitimate interests, (ii) using your personal information for direct marketing or (iii) using your information for statistical purposes.
• Right to data portability — where we are processing your personal information either by relying on your consent or because such processing is necessary for the performance of a contract, and we are processing using automated means, you may ask us to provide the personal information in a machine-readable format.
• Rights related to automated decision-making — you have the right not to be subject to a decision based solely on automated processing of your personal information which produces legal or similarly significant effects on you.

In relation to the Admiral Advan+age App, you may also: manage your communication preferences and consent settings directly within the App at any time; withdraw consent for location data collection or analytics tracking through the App settings; and request deletion of your App account, which will result in removal of your personal data from all active systems.

If you wish to exercise any of your rights, please complete the relevant form or contact us at groupgdpr@luxury-leisure.co.uk.

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address:
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk

11. Changes to this Notice

We keep our Privacy Notice under regular review and may change it from time to time. If we make any significant changes, we will post the changes on this page.

12. Links and third parties

Where we provide links to websites of other organisations, this Notice does not cover how that organisation processes personal information and we are not responsible for the privacy practices of those organisations. We encourage you to read the privacy notices on the other websites you visit.

13. How to contact us

There are many ways you can contact us, including email, phone and post. Please let us know if you have any questions or concerns about this Notice or about the way in which Luxury Leisure Talarius processes your personal information by contacting us.

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