Playing Wanted Dead Or a Wild Slot means submitting personal data https://wanteddeadorwild.uk. This document sets forth exactly how long we retain it, the reasons, and what technical protections underpin each category—all based on UK GDPR, the Data Protection Act 2018, and PCI DSS. We process identity documents, financial transactions, gameplay telemetry, responsible gambling markers, and marketing consents, each with its unique retention clock. Identity records stick around for five years after account closure. Financial logs are stored for seven, matching HMRC requirements. Gameplay data gets 24 months before anonymisation is applied. Full card numbers never touch our systems—only tokenised aliases—and every byte is secured. Independent auditors review our automated deletion routines, and any schedule slip triggers a full incident response. A version-controlled policy log tracks every edit, and we give you 30 days’ notice before material changes take effect. Subject access and deletion requests are managed within statutory deadlines.
Essential Definitions and Scope of Personal Data
We adopt a comprehensive approach on what qualifies as personal data. Direct identifiers—name, email, billing address, masked payment details—are accompanied by indirect signals like hashed IP addresses, device fingerprints, browser agents, and advertising tokens. Behavioural data encompasses 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 cover live databases, archives, and backups without exception. Each window commences from the last activity or transaction date, spelled out below. We revisit definitions every six months to remain compliant with regulatory guidance.
Monetary Transaction and Billing Records
Deposit, withdrawal, and wager logs are retained for seven years from the transaction date, per HMRC and FCA rules. We never store full PANs or CVVs. We record only the BIN, last four digits, and a tokenised identifier. Chargeback disputes suspend the contested record until final resolution, after which the seven-year clock continues. Data is partitioned quarterly so automated purging operates cleanly, with monthly deletion runs verified by auditors. Tokenised card references are valid only while your account is live and are wiped within thirty days of termination. Summarised, anonymised totals endure for financial reporting without any personal information. All financial data is coded and isolated from marketing systems.
Tokenised Payment Instruments and Processor References
Payment gateways create vaulted tokens that link your card to a non-sensitive reference. We keep them for the account lifetime plus a thirty-day grace period, then transmit deletion commands to the processor and wipe our own reference. The only evidence left behind is an anonymised transaction hash used in aggregate reports, themselves deleted after seven years. No usable credentials ever sit on our systems. We track token revocation daily and initiate incidents if deletion fails. Tokens are tied to our merchant code and cannot be used in other contexts. Weekly reconciliation validates correctness, and tokens tied to lost or stolen cards are cancelled immediately. All token operations are recorded and auditable. Aggregate reports never reveal individual transaction hashes.
Registration Account and Verification of Identity Data
Primary identity records—official ID scans, proof of address, biometric selfie verifications—are kept for 5 years after your last session or closure of account, whichever is later. This covers statutory limitation periods and anti-money laundering responsibilities. We obtain only the necessary details: document ID, validity, citizenship. The original image gets shredded upon extraction. Once 5 years pass, all original data is erased, but a cryptographic hash of the verification outcome remains for another two years inside an logging system. Identification data sits stored encrypted with AES-256-GCM, isolated from analytics, and every data access is logged for 3 years. Non-essential fields like birthplace are removed at verification stage to reduce the data footprint. Annual reviews verify correctness and proactively delete outdated records.
Uploading Documents and Biometric Handling
Provide an ID through our protected portal and automatic verification finishes within ninety seconds. We pull the ID number, expiration date, nationality, and a confidence score, then shred the full-resolution image instantly—it never reaches storage. The source file stays in an in-memory buffer and disappears after analysis. A compressed, stamped thumbnail is produced for audit purposes and stored only for the identity lifecycle. That preview lives in a immutable vault with strict controls and is never shown to customer support. Collected information are encrypted and saved for the 5-year-plus-2-year hash period. All processing runs on UK-based ISO 27001 servers, and every preview retrieval is stored unchangeably.
Biometric Information Details
Live detection checks record a short video stream completely in memory. Video frames are analyzed and removed within milliseconds of time. Only a data vector of face features survives. This data set lacks any image data and cannot be turned back into a face. It remains for the duration of identity verification and is purged irrevocably upon account closure or after five years. The numerical representation sits in a hardware security module with automatic expiration and is never exported. Authentication checks happen inside the HSM’s secure enclave without exposing the original vector. The numerical representation is bound to a pseudonymous identifier disconnected from marketing profiles, which makes re-identification very hard. Even system admins are unable to view or recreate face characteristics from the stored vector.
Session Gameplay and Analytics of Behavior Data
All spins on Wanted Dead Or a Wild tracks reel positions, RNG seed, and net outcome with microsecond precision. We keep these raw logs for twenty-four months, then compress them into an anonymous statistical digest used 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 get 36 months. Error diagnostics receive 90 days. No individual gameplay data feeds 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 erased
- RNG seed audit trails: 36 months to satisfy technical standards
- Feature trigger heatmaps: 12 months, then merged into global model
- Error and crash diagnostic logs: 90 days, then cycled out
Access Request and Erasure Workflows
When an SAR lands, we generate a organized JSON/CSV export of all non-purged data within one month, extendable by two months for complex cases. The export includes live databases, encrypted archives, and processor tokens, delivered via a one-time secure link that expires in 72 hours. For deletion, we proceed sequentially: immediate account suppression and token revocation, then scheduled erasure of all personal data not subject to legal hold. We produce a confirmation report detailing erased versus retained categories and their justifications. This report is kept as auditable proof for as long as the longest surviving data category. All requests are documented immutably for five years.
Marketing Approval and Correspondence Records
We maintain your consent document—time-stamped, IP-marked, and method-recorded—for the duration of our association plus six years after revocation, to meet PECR obligations. Delivery logs for emails, push notifications, and SMS are retained for only thirteen months. Revoking consent instantly suppresses communications while keeping historical proof. A segmented database guarantees suppression without lag, and consent logs are kept in a distinct compliance archive. Dispatch records contain metadata only—subject, timestamp, status—not full message text. The six-year post-withdrawal timeframe reflects the statute of limitations for regulatory inquiries. Quarterly audits check no expired consents activate mailings. We never personalise offers with gameplay or financial data beyond explicit permissions.
Controlled Gambling and Player Ban Registers
Deposit limits, session reminders, and timeout settings are kept for your account’s entire duration and never removed while it is active. If you self-exclude, your hashed identity and device fingerprints enter a specific exclusion register kept without time limit under UKGC licence requirements. The register is secured separately, accessed only at login or registration, and never used for analytics. Permission is limited to trained compliance staff, and all searches are tracked for three years. The register contains only identity blocks—no financial or gameplay records. We check it annually to correct errors and remove deceased individuals. Apart from that, it remains everlasting. This retention is obligatory and free from deletion requests.
Reality Check and Play Time Restriction Enforcement
Reality check clocks use transient session counters that restart every 24 hours, restarting from your first spin after midnight. Your chosen interval—say, 30 minutes—is stored persistently and automatically reactivates when you come back, even after a long break. Altering the interval mid-session applies the new value instantly for the next reminder. These settings are purged only upon verified 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 accuracy. All timer configurations are verifiable through the same three-year access log standard. We at no time profile or advertise based on these settings.
Technology Framework and Data Location
All data sits in UK-based ISO 27001 Tier III+ data centres, not copied outside the UK. A hot disaster recovery site in a separate UK zone syncs every six hours. Backups are encrypted client-side and adhere to identical retention rules. We enforce least privilege with hardware MFA for administrators, logging their sessions in an immutable three-year audit trail. Multi-factor authentication uses a hardware token and biometric check. Penetration tests are conducted quarterly, and an independent auditor verifies automated purge schedules. Any deviation raises a Severity 1 incident, notified to our DPO within four hours. We also operate an air-gapped backup rotated weekly, under the same deletion policies.
Management of Encryption Keys
Master keys are renewed every 90 days automatically inside an HSM. New keys are kept internal 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 removed inside the HSM, making any backups unrecoverable. We link each key to a single data partition, never reuse, and conduct quarterly witnessed key ceremonies logged immutably for five years. The offline archive of old keys needs 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 exits the HSM boundary.
Policy Review and Incident Reporting Protocols
We assess this policy every six months or upon material change to the game or regulation. Reviews are recorded with DPO, CISO, and legal counsel. A public summary is displayed in our privacy centre, minus confidential details. Material changes are sent 30 days ahead. Minor edits are silently recorded. If a breach occurs affecting data under this policy, we inform 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 update controls as needed. Biannual tabletop exercises test misconfigurations and ransomware to test our response.
Document Versioning and Change Log
We maintain 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 transmitted 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 verify the log’s accuracy. The log is a living document reflecting our evolving data practices. You can retrieve the full change log through a link in our privacy centre at any time. This transparent approach reflects our commitment to accountable data governance.
