Privacy Policy

We understand that your privacy is important to you and that you care about how your Personal Data is used and shared online. We respect and value the privacy of everyone who visits (the “Website”) and will only collect and use Personal Data in ways that are described here, and in a manner that is consistent with Our obligations and your legal rights.


GAN PLC and all its US subsidiaries comply with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States.  GAN PLC has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.  If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification, please visit


The Federal Trade Commission has jurisdiction over GAN PLC’s compliance with the Privacy Shield.


Please read this Privacy Policy carefully and ensure that you understand it. You will be required to read and accept this Privacy Policy when signing up for an Account. If you do not accept and agree with this Privacy Policy, you must stop using the Website immediately.



In this Policy the following terms shall have the following meanings:


“Account” means your account with us as is required to access and/or use certain areas and features of the Website;


“Cookie” means a small text file placed on your computer or device by the Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the Cookies used by the Website are set out in section 13 below;


“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;


“Personal Data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means Personal Data that you give to Us via the Website. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and


“We/Us/Our” means GAN PLC of 2nd Floor, Axe and Bottle Court, 70 Newcomen Street, London, SE1 1YT, United Kingdom, and GameAccount Alderney Limited of Inchalla Le Val, Alderney GY9 3UL



The Website is operated by GAN plc and GameAccount Alderney Limited pursuant to its licences granted by the Gambling Commission of Great Britain and the Alderney Gambling Control Commission.


GAN plc is the “Data Controller” (as defined by the GDPR).


Our Data Protection Officer can be contacted by email at [email protected].



This Privacy Policy applies only to your use of the Website. The Website may contain links to other Websites. Please note that We have no control over how your data is collected, stored, or used by other Websites and We advise you to check the privacy policies of any such Websites before providing any data to them.



4.1 As a data subject, you have the following rights under the GDPR, which this Policy and Our use of Personal Data have been designed to uphold:


4.1.1 the right to be informed about Our collection and use of Personal Data; 4.1.2 the right of access to the Personal Data We hold about you (see section 12);


4.1.3 the right to rectification if any Personal Data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14);


4.1.4 (subject to section 6.5) the right to be forgotten – i.e. the right to ask Us to delete any Personal Data We hold about you;


4.1.5 The right to restrict (i.e. prevent) the processing of your Personal Data;


4.1.6 The right to data portability (obtaining a copy of your Personal Data to re-use with another service or organisation);


4.1.7 The right to object to Us using your Personal Data for particular purposes; and


4.1.8 Rights with respect to automated decision making and profiling.


4.2 If you have any cause for complaint about Our use of your Personal Data, please contact Us and We will do Our best to resolve the problem for you.

In compliance with the Privacy Shield Principles, GAN PLC commits to resolve complaints about our collection or use of your personal information.  European Union individuals with inquiries or complaints regarding our Privacy Shield policy should first contact GAN PLC by email at [email protected], or by post at 2nd Floor, Axe and Bottle Court, 70 Newcomen Street, London, SE1 1YT, United Kingdom.

GAN PLC commits to cooperate with the panel established by the EU data protection authorities (DPAs) and comply with the advice given by the panel with regard to data transferred from the EU.

An individual has the possibility, under certain conditions, to invoke binding arbitration for complaints regarding Privacy Shield compliance not resolved by any of the other Privacy Shield mechanisms. For additional information please see the following link:

4.3 For further information about your rights, please contact the Information Commissioner’s Office at



Depending upon your use of the Website, We may collect some or all of the following personal and non-Personal Data (please also see section 13 on Our use of Cookies and similar technologies):


5.1 name;


5.2 date of birth;


5.3 gender;


5.4 contact information such as email addresses and telephone numbers;


5.5 demographic information such as post code, preferences and interests;


5.6 financial information such as credit / debit card numbers;


5.7 IP address;


5.8 web browser type and version;


5.9 operating system.



6.1 All Personal Data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security, please see section 7 below.


6.2 Our use of your Personal Data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your Personal Data or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:


6.2.1 Providing and managing your Account;


6.2.2 Providing and managing your access to the Website;


6.2.3 Personalising and tailoring your experience on the Website;


6.2.4 Supplying Our services to you (please note that We require your Personal Data in order to enter into a contract with you);


6.2.5 Personalising and tailoring Our services for you;


6.2.6 Replying to calls or emails from you;


6.2.7 Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by adjusting your setting in your Account);


6.2.8 Market research;


6.2.9 Analysing your use of the Website to enable Us to continually improve the Website and your user experience;


6.2.10 Complying with our regulatory duties, obligations and responsibilities including under the Gambling Act 2005 and the Gambling (Licensing and Advertising) Act 2014 and to the Alderney Gambling Control Commission and the Gambling Commission of Great Britain and under any other valid and applicable legislation and to any other competent authority.


6.3 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email, telephone, text message, post with information, news and offers on Our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.


6.4 Subject to section 6.5, you have the right to withdraw your consent to Us using your Personal Data at any time, and to request that We delete it.


6.5 In certain circumstances, We may not be able to comply with your request to be forgotten and we may refuse to comply with any such request for erasure where your Personal Data is being processed for the following reasons:


(a) to exercise the right of freedom of expression and information;


(b) to comply with a legal obligation for the performance of a public interest task or exercise of official authority;


(c) for public health purposes in the public interest;


(d) archiving purposes in the public interest, scientific research historical research or statistical purposes; or


(e) the exercise or defence of legal claims.


For example, We are required by the Gambling Commission to retain your Personal Data for a period of one (1) year after you have closed your Account in order to deal with unsettled wagers or complaints. We may also be required to retain certain records in relation to any self-exclusion functionality and to ensure that We are complying with all of Our obligations as to responsible gambling.



7.1 We only keep your Personal Data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it. However, we may be required to continue to retain records containing Your information for legitimate business, regulatory, compliance and/ or legal purposes.


7.2 Some or all of your data may be stored outside of the European Economic Area (“the EEA”) including but not limited to the United States of America.


7.3 We will only send your data outside of the European Economic Area (‘EEA’) to:


(i) follow your instructions;


(ii) comply with a legal duty; or


(iii) work with our agents and advisers who we use to help run your accounts and services.


7.4 If we do transfer information to our agents or advisers outside of the EEA, we will make sure that it is protected in the same way as if it was being used in the EEA. We’ll use one of these safeguards:


(i) transfer it to a non-EEA country with privacy laws that give the same protection as the EEA. Learn more on the European Commission Justice website;


(ii) put in place a contract with the recipient that means they must protect it to the same standards as the EEA. Read more about this on the European Commission Justice website.


(iii) transfer it to organisations that are part of Privacy Shield. This is a framework that sets privacy standards for data sent between the US and EU countries. It makes sure those standards are similar to what is used within the EEA. You can find out more about the Privacy Shield on the European Commission Justice website.


7.5 You are deemed to accept and agree to this by using the Website and submitting information to Us.



8.1 We may share your data with other companies in Our group for data processing purposes. This includes Our holding company and its subsidiaries.


8.2 We may sometimes contract with third parties to supply services to you on Our behalf. These may include age verification, payment processing, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under applicable laws.


8.3 We may compile statistics about the use of the Website including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of applicable laws.


8.4 We may sometimes use third party data processors that are located outside of the European Economic Area (“the EEA”). Where We transfer any Personal Data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the GDPR.


8.5 In certain circumstances, We may be legally required to share certain data held by Us, which may include your Personal Data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, a governmental authority, or in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.


8.6 As a Privacy Shield organization, GAN PLC has responsibility for the processing of personal information it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. GAN PLC shall remain liable under the Principles if its agent processes such personal information in a manner inconsistent with the Principles, unless GAN PLC proves that it is not responsible for the event giving rise to the damage.



We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Any Personal Data that you have provided will, where it is relevant to any part of Our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which it was originally collected by Us.



10.1 When you submit Personal Data via the Website, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details and by managing your Account).


10.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.



11.1 You may access certain areas of the Website without providing any data at all. However, to use all features and functions available on the Website you may be required to submit or allow for the collection of certain data.


11.2 You may restrict Our use of Cookies. For more information, please see section 13.



You have the right to ask for a copy of any of your Personal Data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at [email protected], or using the contact details below in section 14.



13.1 The Website may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of the Website and to provide and improve Our services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and Personal Data is protected and respected at all times.


13.2 All Cookies used by and on the Website are used in accordance with current Cookie Law.


13.3 Before Cookies are placed on your computer or device, you will be shown a pop-up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.


13.4 Certain features of the Website depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in section 13.5. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 13.9, but please be aware that the Website may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.


13.5 GAN uses 1st party cookies that may store a player's alias or email address if and only if the user elects to 'remember login details' on the site. This will store only the alias/email address, and not the password.


13.6 The Website uses website analytics provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how the Website is used. This, in turn, enables Us to improve the Website and the services offered through it. You do not have to allow Us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of the Website, it does enable Us to continually improve the Website, making it a better and more useful experience for you.


13.7 The analytics service(s) used by the Website use(s) Cookies to gather the required information.


13.8 GAN uses the following 3rd party cookies for anonymised data analytics purposes: doubleclick media, hotjar, facebook,, None of these cookies use, store, or send personally identifiable information, user aliases, or IP addresses. Reels Royale only uses the hotjar cookie.


13.9 In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.


13.10 You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, login and personalisation settings.


13.11 It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.



If you have any questions about the Website or this Privacy Policy, please contact Us by email at [email protected], or by post at 2nd Floor, Axe and Bottle Court, 70 Newcomen Street, London, SE1 1YT, United Kingdom. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as set out at section 12 above).



We may change this Privacy Policy from time to time (for example, if the law changes). If we make any changes that could affect you, we’ll let you know before they happen and you will be asked to accept the updated terms of the Privacy Policy on your first use of the Website following the alterations.


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