Data Retention Policy for Wanted Dead Or a Wild Slot Game in UK

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Playing Wanted Dead Or a Wild Slot means handing over personal data. This document details exactly how long we keep it, the rationale, and what technical protections underpin 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 stick around for five years after account closure. Financial logs remain for seven, matching HMRC requirements. Gameplay data undergoes 24 months before anonymisation kicks in. Full card numbers never enter our systems—only tokenised aliases—and every byte is protected. Independent auditors verify our automated deletion routines, and any schedule slip initiates a full incident response. A version-controlled policy log documents every edit, and we give you 30 days’ notice before material changes become effective. Subject access and deletion requests are handled within statutory deadlines.

Core Definitions and Range of Personal Data

We cast a wide net on what constitutes personal data. Direct identifiers—name, email, billing address, masked payment details—sit alongside 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 link back to a person when stitched together, so we treat 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 span live databases, archives, and backups without exception. Each window commences from the last activity or transaction date, spelled out below. We reassess definitions every six months to stay aligned with regulatory guidance.

Financial Transaction and Billing Records

Deposit, withdrawal, and wager logs are retained 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 identifier. Chargeback disputes halt the contested record until final outcome, after which the seven-year clock continues. Data is partitioned quarterly so automated purging operates cleanly, with monthly deletion runs checked by auditors. Tokenised card references are valid only while your account is open and are erased within thirty days of closing. Combined, anonymised totals remain for financial reporting without any personal identifiers. All financial data is coded and quarantined from marketing systems.

Tokenised Payment Instruments and Processor References

Payment gateways produce vaulted tokens that link 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 clear our own link. The only evidence left behind is an anonymised transaction hash used in aggregate summaries, themselves purged after seven years. No usable credentials ever exist on our systems. We track token revocation daily and raise incidents if deletion does not work. Tokens are tied to our merchant code and cannot be used elsewhere. Weekly reconciliation confirms correctness, and tokens tied to lost or stolen cards are cancelled immediately. All token operations are documented and auditable. Aggregate reports never expose individual transaction hashes.

Gaming Session and Behavioral Analytics Data

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

  • Spin-level logs: 24 months from event date, then aggregated aggregation
  • Session behavioural profiles: 24 months from last session, then deleted
  • RNG seed audit trails: 36 months to meet technical standards
  • Feature trigger heatmaps: 12 months, then combined into global model
  • Error and crash diagnostic logs: 90 days, then cycled out

Account Registration and ID Verification Data

Core identity profiles—scans of government IDs, proof of address, biometric selfie matches—are retained for a five-year period after your last session Wanted Dead Or A Wild Slot closure of account, whichever occurs later. This includes contractual time limits and anti-money laundering duties. We obtain only the key information: ID number, validity, nationality. The original image gets destroyed upon extraction. Once five years pass, all original data is purged, but a encrypted hash of the verification data persists for an additional two years inside an audit log. Personal identity information sits encrypted at rest with AES-256-GCM, stored away from analytics, and every data access is logged for three years. Non-essential fields like birthplace are removed at the time of verification to shrink the data size. Yearly reviews verify correctness and actively purge outdated records.

Document Upload and Biometric Data Processing

Upload an ID through our safe portal and automatic verification wraps up within a minute and a half. We pull the ID number, validity, citizenship, and a confidence score, then shred the original image instantly—it never reaches storage. The source file stays in an temporary memory and is removed after handling. A compressed, marked thumbnail is created for audit purposes and retained only for the identity lifecycle. That thumbnail lives in a write-once vault with strict controls and is never exposed to customer support. Extracted fields are secured and kept for the 5-year-plus-2-year hash period. All processing runs on UK-based ISO 27001 servers, and every small image access is logged permanently.

Specifics of Biometric Data

Live detection checks record a quick video solely in memory. Images are processed and removed within milliseconds. Only a numerical vector of facial landmarks survives. This data set lacks any image data and cannot be turned back into a facial image. It is kept for the duration of identity verification and is permanently deleted upon account closure or after five years. The vector sits in a dedicated HSM with automatic expiration and is never exported. Login verifications happen inside the HSM’s secure enclave without exposing the original vector. The numerical representation is associated with a pseudonymous identifier separated from advertising profiles, which makes re-identification extremely difficult. Even system administrators cannot view or recreate facial attributes from the stored vector.

Responsible Gambling and Voluntary Exclusion Registers

Betting limits, reality checks, and timeout settings are saved for your account’s entire duration and never removed while it remains active. If you opt for self-exclusion, your hashed identity and device fingerprints are placed into a dedicated exclusion register held without time limit under UKGC licence requirements. The register is secured separately, checked only at login or registration, and never utilized for analytics. Access is limited to educated compliance staff, and all lookups are logged for three years. The register stores only identity blocks—no banking or gameplay records. We review it annually to correct errors and remove deceased individuals. If not, it stays everlasting. This retention is required and exempt from deletion requests.

Session Awareness and Play Time Restriction Enforcement

Reality check clocks use temporary session counters that restart every 24 hours, starting anew from your first spin after midnight. Your preferred interval—say, 30 minutes—is kept persistently and automatically reactivates when you come back, even after a long break. Modifying the interval mid-session applies the new value instantly for the next reminder. These settings are removed only upon confirmed account deletion. Session timer data sits in a dedicated, encrypted store separate from gameplay analytics. The 24-hour counter is based on play start, not midnight, for precision. All timer configurations are checkable through the same three-year access log standard. We do not profile or advertise based on these settings.

Data Subject Access Request and Deletion Workflows

When a subject access request arrives, we produce a formatted JSON/CSV export of all non-purged data within one month, prolongable by two months for complex cases. The export spans live databases, encrypted archives, and processor tokens, delivered via a one-time secure link that expires in 72 hours. For deletion, we implement a cascade: immediate account suppression and token revocation, then scheduled 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 maintained as auditable proof for as long as the longest surviving data category. All requests are documented immutably for five years.

Consent for Marketing and Message Logs

We store your consent document—time-stamped, IP-stamped, and method-recorded—for the life of our association plus six years after withdrawal, to comply with PECR requirements. Delivery logs for e-mails, push notifications, and SMS are retained for only thirteen months. Withdrawing consent instantly halts communications while preserving historical proof. A partitioned database provides suppression without lag, and consent logs are kept in a distinct compliance archive. Send logs contain metadata only—subject, timestamp, state—not full message text. The six-year post-withdrawal window reflects the statute of limitations for regulatory probes. Quarterly audits verify no expired consents initiate mailings. We never tailor offers with gameplay or financial data beyond explicit authorisations.

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Infrastructure Setup and Data Location

All data is stored in UK-based ISO 27001 Tier III+ data centres, not copied outside the UK. A hot disaster recovery site in a separate UK zone syncs every six hours. Backups are encrypted client-side and maintain identical retention rules. We implement least privilege with hardware MFA for administrators, capturing their sessions in an immutable three-year audit trail. Multi-factor authentication combines a hardware token and biometric check. Penetration tests occur quarterly, and an independent auditor verifies automated purge schedules. Any deviation triggers a Severity 1 incident, reported to our DPO within four hours. We also operate an air-gapped backup rotated weekly, under the same deletion policies.

Encryption Key Lifecycle Management

Master keys are renewed every 90 days automatically inside an HSM. New keys are kept internal 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 removed inside the HSM, making any backups unrecoverable. We bind each key to a single data partition, do not 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 guarantee forensic decryption works when needed. No plaintext key material ever exits the HSM boundary.

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Policy Review and Incident Reporting Protocols

We assess 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 communicated 30 days ahead. Minor edits are silently recorded. If a breach occurs affecting data under this policy, we alert affected individuals within 72 hours if high risk, file with the ICO, and issue a transparency notice. Third-party processor breaches must follow the same protocol. We keep a breach notification log audited quarterly. Post-incident reviews adjust controls as needed. Biannual tabletop exercises model misconfigurations and ransomware to test our response.

Policy Version Control and Change Log

We maintain a version-controlled history of this policy with semantic versioning and plain-English summaries of each change. The log details 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 conveyed 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 check 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 reflects our commitment to accountable data governance.

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