GambleAware is an independent charity (Registered Charity England & Wales 1093910, Scotland SC049433, Registered Company Number 4384279) tasked to fund research, prevention and treatment services to help to reduce gambling-related harms in Great Britain.
Please read this policy carefully, along with our Terms of Use and any other documents referred to in this policy, to understand how we collect, use and store your personal information.
If you have any questions regarding our Privacy Policy, please write to:
GambleAware
5th Floor Lincoln House
296-302 High Holborn
London WC1V 7JH
Email: info@gambleaware.org
GambleAware is a commissioning and grant-making body, not a provider of services. Guided by the National Strategy to Reduce Gambling Harms, the charity’s strategic aims are to: broaden public understanding of gambling-related harms, in particular as a public health issue; advance the cause of harm-prevention so as to help build resilience, in particular in relation to the young and those most vulnerable to gambling-related harms; and help those who do develop gambling-related harms get the support that they need quickly and effectively.
The objects of the charity are here.
As you browse our website, get in touch with us, or provide donations to us we collect personal information. This deepens our understanding of what you are interested in, and helps us to improve the efficiency of our work.
GambleAware will never exchange or sell your information to another organisation for their own marketing purposes. We know that this is important to you, and want to reassure you that you’re always in control of how we use your personal information in regards to marketing and fundraising activities.
We do however need to collect and use your personal information for carefully considered and legitimate business purposes, which help ensure we can run GambleAware efficiently, raise funds effectively and meet our charitable objects. This policy explains how your personal information will be used, what data we collect, our legal basis for its use, along with outlining your rights in respect of personal information.
In simple terms, your personal information may be used to help us effectively meet our charitable objects or to help us raise funds for those charitable activities we commission.
We always strive to provide a clear, honest and transparent approach regarding how and when we may collect and use your personal information. The overview below summarises the different reasons why we do this. We may not use your personal information for all of these purposes – it will depend on the nature of our relationship with you, and how you interact with our charitable and fundraising activities, and websites:
GambleAware needs a lawful basis to collect and use your personal information. The law sets out six lawful bases. The following are relevant to GambleAware’s use of your personal information:
We may also share your personal information where we are compelled by law to do so.
There are times when it is neither practical nor appropriate to ask a person for consent. In many situations, the best approach for GambleAware and our supporters is to process personal information on the basis of our legitimate interests, rather than consent.
Please read our Legitimate Interests Statement below.
We collect and use personal information such as name and address details along with other contact information such as email addresses and telephone numbers. We also collect information about the services you use, any purchases or financial transactions you make (including payment details), or any marketing contact preferences you give. We maintain a record of communications we send to you and we will log any communications that you send to us.
Under data protection law, certain categories of personal information are recognised as sensitive and requiring greater protection, including personal information about your health, race, religious beliefs, and political opinions (‘sensitive personal data’, also known as special category data). In limited cases, we may collect sensitive personal data about you, such as information about your health. We would only collect sensitive personal data if there is a clear reason for doing so, such as where we need this information to ensure that we provide you with appropriate information and advice and we will either rely on your explicit consent or rely on a further basis that is in the substantial public interest (e.g. for the provision of confidential counselling, advice or support or of another similar service provided confidentially) or, in some cases, we may process sensitive personal data in order to protect your vital interests.
We collect information in the following ways:
You may give us personal information about you by filling in forms on (or downloaded from) our website or by corresponding with us by post, phone, e-mail or otherwise, by making a donation to us, or by fundraising on our behalf. This includes personal information you provide when you register to use our site (if applicable), subscribe to our service, and when you report a problem with our site.
Your information may be shared with us by independent event organisers, for example Charity Challenge or fundraising sites like Just Giving or Virgin Money Giving. These independent third parties will only do so when you have indicated that you wish to support GambleAware and where necessary with your consent. You should check their privacy policies when you provide your personal information to them to understand fully how they will process (and share) it.
We may combine personal information you provide to us with information available from external sources in order to gain a better understanding of our supporters to improve our fundraising methods, products and services.
The personal information we get from other organisations may depend on your privacy settings or the responses you give to them, so you should regularly check your preferences and settings. This information comes from the following sources:
We may receive information about you if you use any of the other websites we operate or the other services we provide. We also work closely with third parties (including, for example, business partners, trade associations, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them. For example, we receive information from GamCare and other partners via GambleAware’s ‘Data Reporting Framework’, which is a recognised industry tool for the collection of data on individuals accessing treatment. You are always in control of the provision of personal information to the Data Reporting Framework.
Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) will have their own cookie policies. These policies are likely to be analytical/performance cookies or targeting cookies.
You can find out more about how Google stores, uses and manages this data via Google's Privacy and Terms.
Depending on your settings or the privacy policies for social media and messaging services like Facebook, WhatsApp or Twitter, you might give us permission to access information from those accounts or services. We use third party agencies including Socialbakers, Goodstuff and Eight&four to conduct social media marketing on our behalf.
This may include information found in places such as Companies House, Gambling Commission Register, Charity Commission Register, and information that has been published in articles/ newspapers.
With regard to each of your visits to our site we may automatically collect the following information:
Our marketing agencies use tools available on social media such as Facebook in order to help direct our services to the right audiences. Learn more about interest-based advertising from Facebook.
Follow these instructions to opt-out from Facebook’s interest-based ads.
Visit the Facebook Privacy Policy for more information about how Facebook manages Personal data or contact Facebook online, or by mail: Facebook, Inc. ATTN, Privacy Operations, 1601 Willow Road, Menlo Park, CA 94025, United States.
Our agencies may also use the Facebook Insights function in order to obtain anonymised statistical data about users who visit our Facebook page. For this purpose, Facebook places a Cookie on the device of the user visiting our Facebook page. Each Cookie contains a unique identifier code and remains active for a period of two years, except when it is deleted before the end of this period.
For more information on the privacy practices of Facebook, please visit Facebook’s Privacy Policy.
In general, unless we still require the personal information for the purpose for which we collected and/ or process it, we remove your personal information from our records seven years after the date it was collected. However, if before that date (i) your personal information is no longer required in connection with such purpose(s), (ii) we are no longer lawfully entitled to process it or (iii) you validly exercise your right of erasure (see Data Protection Rights below), we will remove it from our records at the relevant time.
If you ask not to receive any further contact from us, we will keep some basic information about you in order to avoid sending you unwanted materials in the future.
GambleAware will not exchange or sell your personal information to another organisation for their own marketing purposes. However, there are some situations where we may have to share your personal information with other organisations, including:
In these situations, the relationship between GambleAware and the third party data processor will generally be governed by a contract and strict security requirements will be in place to protect your personal information. GambleAware will never sell or rent your personal information to other organisations.
We may also disclose your personal information to other organisations:
Where GambleAware is using your personal information on the basis of your consent, you have the right to withdraw that consent at any time. You also have the right to ask GambleAware to stop using your personal information for direct marketing purposes. Simply contact us. You also have the following rights which apply in certain circumstances and subject to exemptions:
Like most websites, we use ‘cookies’ on the GambleAware website. For more information regarding out use of cookies including a description of the cookies we use please see our Cookie Policy.
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the UK and EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the provision of support services.
Some countries outside the UK and EEA have a lower standard of protection for personal information, including lower security requirements and fewer rights for individuals. In these cases we will take all steps reasonably necessary to ensure that adequate safeguards have been put in place to protect your personal information, such as European Commission-approved contracts, and that it is always treated securely in accordance with this Privacy Policy.
Unfortunately, no transmission of information via the internet is completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your data in transit online. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
This Privacy Policy may change from time-to-time. We will continue to update it to reflect new legal requirements. Please visit this website page to keep up-to-date with the changes to our Privacy Policy. If we update this Privacy Policy in a way that significantly changes how we use your personal information, we will bring these changes to your attention where possible.
In the first instance, please talk to us directly so we can help resolve any problem or query. You can contact us using this email address: info@gambleaware.org.
You can also register with the Fundraising Preference Service (FPS). This service is run by the Fundraising Regulator and allows you to stop receiving fundraising email, telephone, addressed post, and/or text messages from a selected charity or charities by using the online service or by calling 0300 303 3517. Once you have made a request through the FPS, we will ensure that your new preferences take effect within 28 days.
You also have the right to complain to the Information Commissioners Office (ICO) at any time if you have any concerns about Data Protection using their help line 0303 123 1113 or website.
Data privacy law requires us to have specific lawful reasons in order that we can use (or 'process') your personal information. One of the reasons is called 'legitimate interests'. Broadly speaking Legitimate Interests means that we can process your personal information if we can identify a legitimate interest (which can be ours or another’s), that our use is reasonably necessary to further that interest and we are not harming any of your rights and interests.
If you would like to know more about legitimate interests under data privacy law see the Information Commissioners Office (ICO) website.
This statement explains GambleAware’s legitimate interests.
Generally, GambleAware’s legitimate interests are the running of GambleAware as a charity and a business and pursuing our charitable objects.
This includes (non-exhaustively):
Delivery of our charitable purpose as set out in our governing document, and our charitable objects
Reporting criminal acts and compliance with law enforcement agencies
Internal and external audit for financial or regulatory compliance purposes
Statutory reporting
Conventional direct marketing and other forms of marketing, publicity or advertisement (where we are not required to rely on consent – see the note on corporate subscribers below)
Unsolicited commercial or non-commercial messages, including campaigns, income generation or charitable fundraising
Personalisation content used to tailor and enhance the customer experience in our digital and postal communications
Exercise of the right to freedom of expression or information, including in the media and the arts
Analysis, targeting, and segmentation of our database to develop corporate strategy and improve communication efficiency
Processing for research purposes (including marketing research)
Employee and volunteer recording and monitoring for recruitment, safety, performance management or workforce planning purposes
Provision and administration of staff benefits such as pensions
Physical security, IT and network security
Maintenance of suppression files
Processing for historical, scientific or statistical purposes
Processing of financial transactions and maintaining financial controls
Prevention of fraud, misuse of services, or money laundering
Enforcement of legal claims including debt collection via out-of-court procedures
Responding to any solicited enquiry from any of our stakeholders
Thank you communications and receipts
Administration of existing financial transactions
Administration of Gift Aid
Maintaining “Do not contact lists” (suppression lists)
Receiving data for research commissioning purposes and sharing it with researchers we commission. GA does NOT control or process research data, i.e. any data used by or generated within research and evaluation projects. This is entirely the responsibility of the teams funded by GA – it is not at any time specified by or provided to GA or stored or analysed by GA.
No Education Team data is personal, and GA does not qualify as either a data processor or controller for this workstream.
Patient records for the purposes of investigating serious incidents
Pseudonymised and anonymised patient data for the purposes of managing treatment grant-funding, and quality assurance
When we process your personal information for our legitimate interests, we will consider and balance any potential impact on you and your rights under data protection and any other relevant law. Our legitimate business interests do not automatically override your interests – we will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Where we are processing your personal information based on legitimate interests, you have a right to object to this use which can be exercised by contacting us. Please note that in some cases we will continue to process your personal information where the law allows us to – such as if there are compelling legitimate grounds for the processing which override your interests or if the processing is for the establishment, exercise or defence of legal claims.
Our charity processes personal information to deliver marketing and fundraising content to company representatives working at and/or for corporate bodies and entities who derive an income from the gambling industry in Great Britain, with the aim of obtaining the companies’ support, as well as when sending follow up communications (incl. thank you messages, progress reports, invitation to stewardship events, etc). Moreover, we process personal data from individuals working at and/or for a wide range of relevant stakeholders such as legislators (e.g. Gambling Commission, DCMS, Charity Commission), professional trade associations and professional bodies (e.g. Betting & Gaming Council, Lotteries Council, IGRG) and other relevant bodies and organisations (e.g. ABSG).
GambleAware relies on legitimate interest as its legal basis to process personal data and send direct marketing communications promoting our charity and charitable objectives to companies who fall under the ‘corporate subscriber’ category of recipients (as opposed to the ‘individual subscriber’ category of recipients). The law requires us to have consent to send email marketing to ‘individual subscribers’, but not for marketing to corporate addresses. We do so on the basis that:
The organisation the individual works for is a corporate entity.
The basis of the communication is relevant to the individual’s work within the organisation, as opposed to contacting them in a personal capacity.
Our marketing is relevant to the work of the organisation and the individual would reasonably expect this communication given the work that the organisation does.
We give the individual our identity and contact details in order for them to be able to request to stop using their personal information for marketing where they wish to; and in the case that we receive such a request, we comply with the request.
We provide a privacy notice in our communications with them to cover how we will process the individual’s personal information and their rights in respect of it.
We have considered the individual’s reasonable expectations and interest against our own by doing a legitimate interest assessment (LIA). Further information on legitimate interest assessments can be found in the ICO Guide to GDPR.
Read further guidance on GDPR and Corporate Fundraising produced by the Institute of Fundraising and the Fundraising Regulator.
GambleAware runs various events from time to time to update, educate inform its stakeholders and to raise awareness for its work, encouraging debate and a range of thoughts and opinions (“Events”). This privacy notice provides you with information about how GambleAware uses your personal data when you register for and attend an Event run by GambleAware.
If you register with an Event App, GambleAware will receive the following information:
If you choose not to share your information but sign-in to an Event App account when accessing the guide, GambleAware will see your first and last name, email, avatar image, and any company information you’ve chosen to include in your Event App profile. Usage details will not be shared with GambleAware.
If you register for an Event with GambleAware directly, the information you provide us will include:
GambleAware may photograph and film the Event which will be used to market our services and to promote future events. GambleAware will therefore process your image. You will be notified if we intend to photograph/film an Event, for example, in the invitation and on signs at the entrance to the Event. If you do not wish to be photographed or filmed at an Event, please contact us. Where possible, we will provide photo- and film-free zones for those who do not want their picture taken can sit.
GambleAware will process your personal data for the following purposes:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Page last updated: January 2021 (with amendments to the Event section in June 2023).