1.1 We believe that everyone has rights with regard to the way in which their personal data is handled. During the course of our activities, we will collect, store and process personal data about our customers, suppliers and other third parties, and we recognise that the correct and lawful treatment of this data will maintain confidence in our organisation and will facilitate successful business operations. In furtherance of this belief and with the objective of perpetuating a regard for Data Subjects and their Personal Data, the Board of SV Gaming Limited (‘BetKing’, ‘Company’, ‘We’, or ‘Our’) has approved this Data Protection Policy (‘Policy’) under the guidance of the Office of the Data Protection Commissioner.
1.2 Data Administrators and Data Processors (‘Data Users’) are obliged to comply with this Policy when processing personal data on our behalf. Any breach of this policy may result in appropriate disciplinary action.
2.1 The types of personal data that SV Gaming Limited (‘BetKing’, ‘Company’, ‘We’, or ‘Our’) may be required to handle include information about current, past and prospective punters, suppliers, customers, and others that we communicate with. The personal data, which may be held on a computer or other media, is subject to certain legal safeguards specified in the Data Protection Act of 2019
2.2 This Policy and any other documents referred to in it sets out the basis on which we will process any personal data we collect from data subjects or that is provided to us by data subjects or other sources.
2.3 This Policy does not form part of any employee's contract of employment and may be amended at any time.
2.4 This Policy has been approved by the Board of the Company. It sets out rules on data protection and the legal conditions that must be satisfied when we obtain, handle, process, transfer and store personal data.
2.5 The Data Protection Officer is responsible for ensuring compliance with the Regulations and this Policy. The post will be held by such officer as may be designated by the Company from time to time. Any questions about the operation of this policy or any concerns that the policy has not been followed should be referred in the first instance to the Data Protection Officer. Questions or concerns about the operation of the Policy may also be sent to [email protected]
3.1 Data means characters, symbols and binary on which operations are performed by a computer. Which may be stored or transmitted in the form of electronic signals is stored in any format or any device.
3.2 Data Subjects for the purpose of this policy means an identifiable person; one who can be identified directly or indirectly, in particular reference to an identification number or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity.
3.3 Personal Data means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person; It can be anything from a name, address, a photo, an email address, bank details, posts on social networking websites, medical information, and other unique identifier such as but not limited to Media Access Control (MAC) address, Internet Protocol (IP) address, International Mobile Equipment Identity (IMEI) number, International Mobile Subscriber Identity (IMSI) number, Subscriber Identification Module (SIM) and others.
3.4 Data Controllers means a person who either alone, jointly with other persons or in common with other persons or as a statutory body determines the purposes for and the manner in which personal data is processed or is to be processed. We are the Data Controller of all Personal Data used in our business for our own commercial purposes.
3.5 Data Administrators are those of our employees and agents whose work involves processing Personal Data. Data Administrators must protect the data they handle in accordance with this Policy and any applicable data security procedures at all times.
3.6 Data Processors include any person or organisation that is not a data user that processes Personal Data on our behalf and on our instructions. Employees of data controllers are excluded from this definition but it could include suppliers who handle Personal Data on our behalf.
3.7 Processing means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
3.8 Regulation means the Data Protection Act of 2019 Regulations and its subsequent amendments and where circumstance requires it shall also mean any other Regulations on the processing of information relating to identifiable individual’s Personal Data, including the obtaining, holding, use or disclosure of such information to protect such information from inappropriate access, use, or disclosure.
3.9 Sensitive Personal Data includes information about a person's racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health or condition or sexual life, or about the commission of, or proceedings for, any offence committed or alleged to have been committed by that person, the disposal of such proceedings or the sentence of any court in such proceedings. Sensitive Personal Data can only be processed under strict conditions, including a condition requiring the express permission of the person concerned.
3.10 Third-Party means any natural or legal person, public authority, establishment or any other body other than the Data Subject, the Data Controller, the Data Administrator and the persons who are engaged by the Data Controller or the Data Administrator to process personal data.
4.1. Anyone processing personal data must comply with the enforceable principles of good practice. These provide that Personal Data must be:
(a) Collected and processed fairly and lawfully.
(b) Processed for limited purposes and in an appropriate way.
(c) Adequate, relevant and not excessive for the purpose consented to by the Data Subject.
(e) Not kept longer than necessary for the purpose.
(f) Processed in line with Data Subjects' rights.
(g) Secured against foreseeable hazards, breaches such as theft, cyberattack, viral attack, dissemination, manipulations of any kinds, damage by rain, fire or exposure to other natural elements.
(h) Not transferred to people or organisations situated in countries without adequate protection.
4.2 Anyone who is entrusted with the Personal Data of a Data Subject or who is in possession of the Personal Data of a Data Subject shall be accountable for his acts and omissions in respect of data processing and in accordance with the principles contained in this Policy.
5.1. The Policy is not intended to prevent the processing of Personal Data but to ensure that it is done fairly and without adversely affecting the rights of the Data Subject.
5.2. For Personal Data to be processed lawfully, they must be processed on the basis of one of the legal grounds set out in the Regulations. These include, among other things, the Data Subject's consent to the processing, or that the processing is necessary for the performance of a contract with the Data Subject, for the compliance with a legal obligation to which the Data Controller is subject, or for the legitimate interest of the Data Controller or the party to whom the data is disclosed. When Sensitive Personal Data is being processed, additional conditions must be met. When processing Personal Data as Data Controllers in the course of our business, we will ensure that those requirements are met.
6.1. In the course of our business, we may collect and process the Personal Data set out in the Schedule. This may include data we receive directly from a Data Subject (for example, by completing forms or by corresponding with us by mail, phone, email or otherwise) and data we receive from other sources including, for example, business partners, sub-contractors in technical, payment and delivery services, credit reference agencies and others.
6.2. We will only process Personal Data for the specific purposes set out in the Schedule to this Policy or for any other purposes specifically permitted by the Regulations. We will notify the Data Subject of those purposes when we first collect the data or as soon as possible thereafter.
7.1. If we collect Personal Data directly from Data Subjects, we will inform them about:
(a) The purpose or purposes for which we intend to process Personal Data.
(b) The types of third parties, if any, with which we will share or to which we will disclose that Personal Data.
(c) The means, if any, with which Data Subjects can limit our use and disclosure of their Personal Data.
7.2. If we receive Personal Data about a Data Subject from other sources, we will provide the Data Subject with this information as soon as possible thereafter.
7.3. We will also inform Data Subjects whose Personal Data we process that we are the Data Controller with regard to that data, and the contact details of the Data Protection Officer.
We will only collect Personal Data to the extent that it is required for the specific purpose notified to the Data Subject.
We will ensure that the Personal Data we hold is accurate and kept up to date. We will check the accuracy of any Personal Data at the point of collection and take reasonable steps to destroy or amend inaccurate or out-of-date data upon being notified by the Data Subject.
We will not keep Personal Data longer than is necessary for the purpose or purposes for which they were collected. We will take all reasonable steps to destroy, or erase from our systems, all data which is no longer required.
We will process all Personal Data in line with Data Subjects' rights, in particular, their right to:
(a) Request access to any data held about them by a data controller.
(b) Prevent the processing of their data for direct marketing purposes.
(c) Ask to have inaccurate data amended.
(d) Prevent processing that is likely to cause damage or distress to themselves or anyone else.
(e) Withdraw consent at any time, provided that the withdrawal of consent shall not affect the lawfulness of processing based on consent prior to the withdrawal
12.2. We will put in place procedures and technologies to maintain the security of all Personal Data from the point of collection to the point of destruction. Personal Data will only be transferred to a data processor if he agrees to comply with those procedures and policies, or if he puts in place adequate measures himself.
12.3. We will maintain data security by protecting the confidentiality, integrity and availability of the Personal Data, defined as follows:
(a) Confidentiality means that only people who are authorised to use the data can access it.
(b) Integrity means that Personal Data should be accurate and suitable for the purpose for which it is processed.
(c) Availability means that authorised users should be able to access the data if they need it for authorised purposes. Personal Data should, therefore, be stored on Company’s central computer system instead of individual personal computer systems.
12.4. Security procedures include:
(a) Entry controls. Any stranger seen in entry-controlled areas should be reported.
(b) Secure lockable desks and cupboards. Desks and cupboards should be kept locked if they hold confidential information of any kind. (Personal information is always considered confidential.)
(c) Methods of disposal. Paper documents should be shredded. Digital storage devices should be physically destroyed when they are no longer required.
(d) Equipment. Data Users must ensure that individual monitors do not show confidential information to passers-by and that they log off from their computers or other information technology systems when it is left unattended.
13.1 We may transfer any Personal Data we hold to a country outside Ghana, provided that one of the following conditions applies:
(a) Subject to the provisions of the Data Protection Act of 2019, the country to which the Personal Data is transferred ensures an adequate level of protection for the Data Subjects' rights and freedoms.
(b) The Data Subject has given his consent.
(c) The transfer is necessary for one of the reasons set out in the Data Protection Act of 2019 Regulations, including the performance of a contract between us and the Data Subject, or to protect the vital interests of the Data Subject.
(d) The transfer is legally required on important public interest grounds or for the establishment, exercise or defence of legal claims.
(e) The transfer is authorised by the relevant data protection authority where we have adduced adequate safeguards with respect to the protection of the Data Subjects' privacy, their fundamental rights and freedoms, and the exercise of their rights.
13.2 Subject to the requirements in clause 13.1 above, Personal Data we hold may also be processed by staff operating outside Ghana who works for us or for one of our suppliers. That staff maybe engaged in, among other things, the fulfilment of contracts with the Data Subject, the processing of payment details and the provision of support services.
14.1 We may share Personal Data we hold with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 338 the Companies and Allied Matters Act 2004.
14.2 We may also disclose Personal Data we hold to third parties:
(a) In the event that we sell or buy any business or assets, in which case we may disclose Personal Data we hold to the prospective seller or buyer of such business or assets.
(b) If we or substantially all of our assets are acquired by a third party, in which case Personal Data we hold will be one of the transferred assets.
14.3 We may also disclose Personal Data we hold if we are under a duty to disclose or share a Data Subject's Personal Data in order to comply with any legal obligation, or in order to enforce or apply any contract with the Data Subject or other agreements; or to protect our rights, property, or safety of our employees, customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
14.4 We may also share Personal Data we hold with selected third parties for the purposes set out in the Schedule.
15.1 Data Subjects can make a formal request for information we hold about them. This must be made in writing. Employees who receive a written request should forward it to the Data Protection Officer immediately.
15.2 When receiving telephone enquiries, we will only disclose Personal Data we hold on our systems if the following conditions are met:
(a) We will check the caller's identity to make sure that information is only given to a person who is entitled to it.
(b) We will suggest that the caller put their request in writing if we are not sure about the caller’s identity and where their identity cannot be checked.
15.3 Our employees will refer a request to their line manager or the Data Protection Officer for assistance in difficult situations. Employees should not be bullied into disclosing personal information.
We reserve the right to change this Policy at any time. Where appropriate, we will notify Data Subjects of those changes by mail or e-mail.