Information Retention Policy for Wanted Dead Or a Wild Slot in UK

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Playing Wanted Dead Or a Wild Slot means submitting personal data wanteddeadorwild.uk. This document lays out exactly how long we store it, why, and what technical protections sit behind each category—all aligned with UK GDPR, the Data Protection Act 2018, and PCI DSS. We handle identity documents, financial transactions, gameplay telemetry, responsible gambling markers, and marketing consents, each with its specific retention clock. Identity records are retained for five years after account closure. Financial logs remain for seven, satisfying HMRC requirements. Gameplay data undergoes 24 months before anonymisation takes effect. Full card numbers never reach our systems—only tokenised aliases—and every byte is encrypted. Independent auditors review our automated deletion routines, and any schedule slip activates a full incident response. A version-controlled policy log tracks every edit, and we give you 30 days’ notice before material changes are implemented. Subject access and deletion requests are managed within statutory deadlines.

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Data Subject Access Request and Deletion Workflows

Upon receiving an SAR, we compile a structured JSON/CSV export of all non-purged data within one month, extendable by two months for complex cases. The export spans live databases, encrypted archives, and processor tokens, sent via a one-time secure link that expires in 72 hours. For deletion, we implement a cascade: immediate account suppression and token revocation, then queued erasure of all personal data not subject to legal hold. We generate a confirmation report outlining 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 recorded immutably for five years.

Marketing Approval and Message Logs

We store your consent record—timestamped, with IP address, and method-recorded—for the life of our relationship plus six years after cancellation, to satisfy PECR rules. Send logs for electronic messages, push alerts, and SMS are held for only thirteen months. Withdrawing consent immediately suppresses communications while keeping historical proof. A partitioned database provides suppression without delay, and consent logs are stored in a separate compliance archive. Send logs hold metadata only—topic, time, condition—not full message content. The six-year post-withdrawal timeframe matches the statute of limitations for regulatory inquiries. Quarterly audits check no expired consents activate mailings. We never tailor offers with gameplay or financial data beyond explicit authorisations.

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Technology Framework and Data Storage

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 synchronizes every six hours. Backups are encrypted client-side and follow identical retention rules. We apply least privilege with hardware MFA for administrators, recording their sessions in an immutable three-year audit trail. Multi-factor authentication uses a hardware token and biometric check. Penetration tests occur quarterly, and an independent auditor validates automated purge schedules. Any deviation generates a Severity 1 incident, notified to our DPO within four hours. We also maintain an air-gapped backup rotated weekly, following the same deletion policies.

Key Lifecycle Administration

Master keys are renewed every 90 days automatically inside an HSM. New keys are never exported in plaintext. Rotated keys are archived for the data’s retention period plus 12 months for lawful forensic access. When a data category is purged, its key is destroyed 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 confirm forensic decryption works when needed. No plaintext key material ever exits the HSM boundary.

Fundamental Definitions and Range 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 identify again 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 review definitions every six months to keep pace with regulatory guidance.

Safe Gambling and Voluntary Exclusion Registers

Betting limits, session reminders, and timeout settings are stored for your account’s entire duration and never purged while it remains active. If you choose to ban yourself, your hashed identity and device fingerprints are added to a specialized exclusion register maintained without time limit under UKGC licence requirements. The register is secured separately, queried only at login or registration, and never used for analytics. Entry is confined to qualified compliance staff, and all searches are logged for three years. The register contains only identity blocks—no banking or gameplay records. We review it annually to fix errors and remove deceased individuals. Apart from that, it is kept permanent. This retention is obligatory and excluded from deletion requests.

Reality Check and Gaming Duration Enforcement

Reality check counters use temporary session counters that restart every 24 hours, beginning again from your first spin after midnight. Your chosen interval—say, 30 minutes—is kept persistently and instantly reactivates when you come back, even after a long break. Modifying the interval mid-session sets the new value immediately for the next reminder. These settings are deleted only upon confirmed account deletion. Session timer data resides in a specific, encrypted store separate from gameplay analytics. The 24-hour counter is based on play start, not midnight, for precision. All timer configurations are verifiable through the same three-year access log standard. We never categorize or advertise based on these settings.

Account Registration and ID Verification Data

Core identity profiles—official ID scans, address verification, biometric selfie verifications—are retained for a five-year period after your last activity or account closure, whichever is later. This includes statutory limitation periods and anti-money laundering duties. We extract only the necessary details: ID number, expiry, citizenship. The full-resolution image gets shredded upon extraction. Once five years pass, all raw data is purged, but a hash of the verification result remains for another two years inside an logging system. Identification data sits stored encrypted with AES-256-GCM, stored away from analytics, and every access is tracked for three years. Non-essential fields like place of birth are removed at the time of verification to reduce the data footprint. Annual reviews confirm precision and proactively delete expired data.

Uploading Documents and Biometric Data Processing

Submit an ID through our safe portal and automated checking finishes within ninety seconds. We retrieve the ID number, expiry, nationality, and a trust score, then shred the original image immediately—it is never stored on disk. The original file stays in an in-memory buffer and disappears after processing. A compacted, stamped thumbnail is produced for compliance purposes and stored only for the identity verification period. That preview lives in a write-once storage with tight controls and is never exposed to support staff. Retrieved data are secured and stored for the five-year plus two-year hash timeframe. All handling runs on ISO 27001 certified UK servers, and every small image access is logged permanently.

Biometric Information Details

Liveness checks capture a brief video feed entirely in memory. Frames are analyzed and discarded within a few milliseconds. Only a numerical vector of face features remains. This vector contains no image data and cannot be reverse-engineered into a face. It stays for the entire identity verification process and is permanently deleted upon account closure or after five years. The data set sits in a dedicated HSM with self-expiry and is never exported. Login verifications happen inside the HSM’s protected enclave without revealing the unprocessed data. The numerical representation is linked to a pseudonymous identifier unlinked from advertising profiles, which makes re-identifying very hard. Even system admins cannot view or recreate facial features from the kept numerical representation.

Monetary Transaction and Payment Records

Funding, withdrawal, and wager records are maintained for seven years from the transaction date, per HMRC and FCA rules. We never store full PANs or CVVs. We collect only the BIN, last four digits, and a tokenised reference. Chargeback disputes freeze the contested record until final resolution, after which the seven-year clock continues. Data is partitioned quarterly so automated purging runs cleanly, with monthly deletion runs audited by auditors. Tokenised card references stay valid only while your account is open and are wiped within thirty days of closure. Summarised, anonymised totals endure for financial reporting without any personal information. All financial data is secured and separated from marketing systems.

Tokenized Payment Instruments and Processor References

Payment gateways produce vaulted tokens that map your card to a non-sensitive identifier. We hold them for the account lifetime plus a thirty-day grace period, then issue deletion commands to the processor and wipe our own link. The only evidence left behind is an anonymised transaction hash used in aggregate reports, themselves deleted after seven years. No usable credentials ever reside on our systems. We check token revocation daily and raise incidents if deletion does not work. Tokens are linked to our merchant code and cannot be used elsewhere. Weekly reconciliation validates validity, and tokens tied to lost or stolen cards are revoked immediately. All token operations are documented and verifiable. Aggregate reports never reveal individual transaction hashes.

Policy Assessment and Breach Notification Protocols

We review 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 published in our privacy centre, minus confidential details. Material changes are emailed 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, submit with the ICO, and publish a transparency notice. Third-party processor breaches must follow the same protocol. We hold a breach notification log audited quarterly. Post-incident reviews revise controls as needed. Biannual tabletop exercises simulate misconfigurations and ransomware to test our response.

Policy Version Control and Revision History

We keep 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 confirm 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 shows our commitment to accountable data governance.

Gaming Session and Behavioural Analytics Data

Every spin on Wanted Dead Or a Wild logs reel positions, RNG seed, and net outcome with microsecond precision. We retain these raw logs for twenty-four months, then compact them into an anonymous statistical digest used for game design. Session behavioural profiles—average bet, spin cadence, feature buy-ins—stay 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 have 36 months. Error diagnostics have 90 days. No individual gameplay data goes into credit or marketing profiling. All logs are encrypted and off-limits to marketing teams.

  • Spin-level logs: 24 months from event date, then anonymized 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 integrated into global model
  • Error and crash diagnostic logs: 90 days, then rotated out

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