1. Introduction
Welcome to PyroFox.uk. This website is operated by PyroFox Gaming Ltd., an official platform for the slot game "PyroFox" provided by Backseat Gaming (Hacksaw Gaming). We are committed to protecting your personal data, ensuring your privacy, and promoting responsible gambling. We understand that as an online gambling site, we fall under Google's "Your Money or Your Life" (YMYL) category, specifically impacting "Financial Security." Therefore, transparency, security, and trust are at the core of our operations and this Privacy Policy.
This policy explains how we collect, use, store, share, and protect your personal data, as well as your rights in relation to that data. It reflects our dedication to compliance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and the specific requirements of the UK Gambling Commission (UKGC) and other relevant regulatory bodies.
2. Who We Are
PyroFox.uk is operated by:
PyroFox Gaming Ltd.
Registered in England and Wales.
Registered Office Address: 123 Gaming Lane, London, W1A 0AA, United Kingdom.
Company Registration Number: 12345678 (example)
UKGC Licence Number: 12345-R-67890-001 (example, for illustrative purposes of compliance)
For the purposes of applicable data protection laws, PyroFox Gaming Ltd. is the Data Controller responsible for your personal data collected through this website. This means we determine the purposes and means of processing your data.
3. The Data We Collect About You
We may collect, use, store, and transfer different kinds of personal data about you, which we have grouped together as follows:
- Identity Data: Includes first name, last name, username or similar identifier, marital status, title, date of birth, and gender. We collect this for age verification, Know Your Customer (KYC) checks, and anti-money laundering (AML) compliance.
- Contact Data: Includes billing address, email address, and telephone numbers. Used for account management, customer support, and essential communications.
- Financial Data: Includes bank account and payment card details (though we do not directly store full card numbers, we receive tokenised data from our payment processors). Necessary for deposits, withdrawals, and compliance with PCI DSS standards.
- Transaction Data: Includes details about payments to and from you, and other details of products and services you have purchased from us. This specifically includes records of your bets (e.g., min/max bet, specific bonus buy selections like 'WILDFIRE FEATURESPINS™', 'BLAZE OF GLORY', 'BLAZE OF GLORY'), winnings, losses, game outcomes (e.g., results of Fiery Wheel of Fortune gambles), and complete game history for "PyroFox" and other titles. This data helps us ensure game fairness and regulatory compliance.
- Technical Data: Includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device identifiers, and other technology on the devices you use to access this website. This also includes specific game version (e.g., PyroFox v1.0.0), server version (e.g., 2.0.235), and rules generation dates. Collected for security, site functionality, and troubleshooting.
- Usage Data: Includes information about how you use our website, products, and services. This encompasses how you interact with the game's UI elements (e.g., spin button, bonus buy menu, info screens, keyboard shortcuts like 'SHIFT + S' for sound, 'SHIFT + I' for game info), game states (e.g., interrupted game information, demo mode usage and associated balances/bets), and general browsing patterns. Used for site improvement and analytics.
- Profile Data: Includes your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.
- Marketing and Communications Data: Includes your preferences in receiving marketing from us and our third parties, and your communication preferences.
- Responsible Gambling Data (Special Category Data): Information related to your gambling behaviour, such as self-exclusion requests, deposit limits, loss limits, time-outs, and patterns of play (e.g., high frequency of bonus buys, bet size fluctuations) that may indicate vulnerability or potential harm. This data is treated with the utmost sensitivity and is crucial for our player protection obligations.
- KYC/AML Data: Documents and information required to verify your identity, address, and source of funds as part of our legal and regulatory obligations to prevent money laundering and fraud.
We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature or playing a specific bonus game like 'FLAME FOX'S FRENZY'.
4. How Your Personal Data is Collected
We use different methods to collect data from and about you, including:
Direct interactions
You provide us with your Identity, Contact, Financial, Transaction, Profile, Responsible Gambling, and KYC/AML Data when you:
- Register for an account on PyroFox.uk.
- Make deposits or withdrawals.
- Participate in games like "PyroFox".
- Contact customer support.
- Set responsible gambling limits.
- Complete verification checks.
- Subscribe to our marketing communications.
Automated technologies or interactions
As you interact with our website, we automatically collect Technical and Usage Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. We also use Yandex.Metrica for web analytics.
Third parties or publicly available sources
We may receive personal data about you from various third parties and public sources, including:
- Technical and Usage Data from analytics providers (e.g., Yandex.Metrica).
- Financial and Transaction Data from payment service providers.
- Identity and Contact Data from identity verification services, public databases, and regulatory bodies (e.g., for age verification or self-exclusion checks with GamStop).
- Game providers (e.g., Backseat Gaming) provide us with gameplay data to ensure fair play and system integrity.
5. How We Use Your Personal Data
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:
To provide and manage your gaming account and services: This includes setting up your account, processing your bets and payouts for "PyroFox", managing your gameplay (including interrupted game states and history), and providing customer support.
Lawful Basis: Performance of a contract with you.
To process and facilitate payments: Managing your deposits and withdrawals securely and efficiently.
Lawful Basis: Performance of a contract with you; Legal obligation (e.g., AML).
To ensure site security and prevent fraud: Monitoring for suspicious activities, protecting our systems, and verifying your identity.
Lawful Basis: Legitimate interests (to protect our business and users); Legal obligation (e.g., AML).
To comply with legal and regulatory obligations: This includes age verification, KYC/AML checks, responsible gambling measures, reporting to the UKGC, and adherence to other applicable laws.
Lawful Basis: Legal obligation; Substantial public interest (for responsible gambling data).
To promote Responsible Gambling: Using your data (including patterns of play and self-exclusion requests) to identify and support vulnerable players, provide tools (like deposit limits, self-exclusion), and intervene where necessary.
Lawful Basis: Legal obligation; Substantial public interest (under the Gambling Act 2005).
To improve our website, game ("PyroFox"), and services: Analysing Technical and Usage Data (e.g., interaction with UI elements, effectiveness of bonus buy options, keyboard shortcut usage, demo mode engagement) to enhance user experience, troubleshoot issues, and optimise game performance.
Lawful Basis: Legitimate interests (to develop our products/services and grow our business); Consent (for certain analytics cookies).
For marketing purposes: Sending you promotional offers and updates about "PyroFox" or other games, where you have consented to receive such communications.
Lawful Basis: Consent; Legitimate interests (for existing customers, subject to opt-out).
For affiliate marketing transparency: Where you accessed our site via an affiliate partner, we may process anonymised or pseudonymised data (e.g., a unique referral ID) to track the referral and correctly attribute commissions. This ensures transparency in our marketing efforts and compliance with advertising standards (e.g., ASA).
Lawful Basis: Legitimate interests (to manage our affiliate programme efficiently); Consent (for specific tracking cookies).
6. Disclosure of Your Personal Data
We may share your personal data with the following categories of recipients:
- Game Providers: Such as Backseat Gaming (Hacksaw Gaming) for "PyroFox", to ensure the game functions correctly, verify outcomes, and for regulatory reporting.
- Payment Processors: To facilitate secure deposits and withdrawals. These providers are PCI DSS compliant.
- Identity Verification and Fraud Prevention Services: To conduct KYC/AML checks and prevent fraudulent activities.
- IT System and Service Providers: For hosting, maintenance, technical support, and security of our website and systems.
- Regulatory Bodies and Law Enforcement: Including the UK Gambling Commission (UKGC), other gambling authorities, and law enforcement agencies, when required by law or to protect our rights, property, or safety, or that of our users.
- Responsible Gambling Organisations: Such as GamStop and BeGambleAware, for self-exclusion and player protection purposes.
- Affiliate Partners: As described in Section 5, we may share limited, pseudonymised data to track referrals and attribute commissions.
- Professional Advisors: Including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.
- Corporate Transaction Parties: In the event of a merger, acquisition, or sale of all or part of our business, your data may be transferred to the new owner.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
7. International Data Transfers
As a global industry, some of our service providers or partners may be located outside the UK or the European Economic Area (EEA). This means your personal data may be transferred to, stored, and processed in countries that may not have the same level of data protection laws as the UK or EEA.
Specific Disclosure Regarding Yandex.Metrica:
We utilise Yandex.Metrica, a web analytics service provided by Yandex Oy, to understand how users interact with our website. This involves the transfer of your Usage and Technical Data (such as IP address, browser type, device information, and activity on our site) to Yandex servers located in Russia.
The European Commission has not issued an adequacy decision for data transfers to Russia, meaning that Russia is not deemed to provide an equivalent level of data protection to the UK or EEA. To safeguard your data, we rely on Standard Contractual Clauses (SCCs) approved by the UK Information Commissioner's Office (ICO) for such transfers, combined with robust technical and organisational safeguards. We also conduct Transfer Impact Assessments (TIAs) to evaluate the risks of such transfers and implement additional measures where necessary.
While we strive to protect your data, you should be aware that data protection laws in Russia may not be as comprehensive as those in the UK or EEA. By using our site, you acknowledge and accept this transfer and the associated risks.
For other international transfers, we ensure appropriate safeguards are in place, such as:
- Transferring data to countries deemed to provide an adequate level of protection by the UK Government or European Commission.
- Using specific contracts approved by the UK Government or European Commission which give personal data the same protection it has in the UK/EEA (Standard Contractual Clauses).
8. Data Security
We have implemented robust technical and organisational security measures to protect your personal data from accidental loss, unauthorised access, use, alteration, or disclosure. These measures include:
- Encryption: Using Secure Socket Layer (SSL) technology to encrypt data during transmission.
- Access Controls: Restricting access to your personal data to employees, agents, contractors, and other third parties on a strict need-to-know basis, subject to confidentiality obligations.
- Regular Audits: Conducting regular security assessments and penetration testing.
- PCI DSS Compliance: Adhering to Payment Card Industry Data Security Standard requirements for handling payment card data.
- Employee Training: Ensuring our staff are regularly trained on data protection and security best practices.
- Incident Response Plan: Having procedures in place to deal with any suspected personal data breach.
Despite our efforts, no system is entirely secure. We encourage you to also take steps to protect your personal data, such as using strong, unique passwords and keeping them confidential.
9. Data Retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
For example, due to our legal obligations under anti-money laundering regulations and UKGC licensing conditions, we are required to retain certain customer data (including Identity, Contact, Financial, Transaction, and KYC/AML Data) for a minimum of five (5) years after the termination of your account or the last transaction.
In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
10. Your Legal Rights
Under UK GDPR, you have the following rights regarding your personal data:
- The right to be informed: To be informed about how we collect and use your personal data (which is what this Privacy Policy aims to do).
- The right of access: To request a copy of the personal data we hold about you.
- The right to rectification: To request that we correct any inaccurate or incomplete personal data we hold about you.
- The right to erasure ("right to be forgotten"): To request that we delete your personal data where there is no good reason for us to continue processing it. Please note, this right is subject to certain legal obligations (e.g., AML laws) that may require us to retain some data.
- The right to restrict processing: To request that we suspend the processing of your personal data in certain circumstances.
- The right to object to processing: To object to our processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
- The right to data portability: To request the transfer of your personal data to you or to a third party in a structured, commonly used, machine-readable format.
- The right to withdraw consent: Where we are relying on consent to process your personal data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of any processing carried out before you withdraw your consent.
To exercise any of these rights, please contact us using the details provided in Section 15. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
11. Cookies and Tracking Technologies
Our website uses cookies and similar tracking technologies to enhance your experience, analyse site usage (including through Yandex.Metrica), and for marketing purposes. Cookies are small text files placed on your device.
- Essential Cookies: Necessary for the website to function correctly (e.g., remembering your login, managing your game session for "PyroFox").
- Performance and Analytics Cookies: Used to collect information about how you use our website, including which pages you visit and if you experience any errors. This includes cookies set by Yandex.Metrica to gather anonymous usage statistics.
- Functionality Cookies: Used to remember choices you make (e.g., language preferences, bet sizes in demo mode) to provide a more personalised experience.
- Marketing/Advertising Cookies: Used to deliver relevant advertisements to you and measure the effectiveness of our campaigns.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more detailed information on the cookies we use and your choices, please refer to our dedicated Cookie Policy.
12. Responsible Gambling and Player Protection
Your well-being is paramount. We are dedicated to providing a safe and responsible gambling environment. We use personal data to implement and enforce our responsible gambling policies, which include:
- Age Verification: Ensuring no underage individuals can access our services.
- Self-Exclusion and Time-Outs: Processing and respecting your requests to self-exclude or take a break from gambling, including sharing relevant data with national self-exclusion schemes like GamStop.
- Deposit and Loss Limits: Allowing you to set financial limits on your gambling activity.
- Behavioural Monitoring: Analysing gameplay patterns (e.g., frequency of 'BONUSHUNT FEATURESPINS™' purchases, bet amount changes) to identify potential signs of problem gambling and intervene with appropriate support.
- Direct Support: Providing access to tools and resources to manage your gambling.
We strongly encourage you to gamble responsibly. If you feel your gambling is becoming a problem, please seek help from organisations such as:
- BeGambleAware: www.begambleaware.org
- GamStop: www.gamstop.co.uk (for self-exclusion from all UK-licensed online gambling sites)
13. Children's Privacy
Our services are strictly for individuals aged 18 or over. We do not knowingly collect personal data from children under this age. If we become aware that a child under 18 has provided us with personal data, we will take steps to delete such information from our files as quickly as possible.
14. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or regulatory landscape (e.g., new UKGC guidelines, updates to UK GDPR). We will notify you of any significant changes by posting the new policy on our website and, where appropriate, by email. We encourage you to review this policy periodically.
15. Contact Us
If you have any questions about this Privacy Policy, our data protection practices, or if you wish to exercise your legal rights, please contact our Privacy Team:
Email: [email protected]
Address: Privacy Team, PyroFox Gaming Ltd., 123 Gaming Lane, London, W1A 0AA, United Kingdom.
You also have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
ICO Website: www.ico.org.uk
ICO Helpline: 0303 123 1113