Privacy Policy
Welcome to the Dunder Ltd’s (“Dunder”) Privacy Policy relating to the
provision of our services (games and/or sportsbetting) on dunder.com and
and/or any local country-code websites and/or any sub-website and/or
associated domains (and/or sub-domains) and any related software
applications (“Site”, “Website”), where Personal Data is processed by
the same relating to You.
We respect your privacy and we are committed to protecting your personal
data. This commitment exists throughout the lifecycle of the personal
data which you provide to us, from the design of any Dunder service
which uses personal data to the deletion of that data. We process your
personal data in compliance with the EU General Data Protection
Legislation (the “GDPR”), (Regulation 2016/679) and the Maltese Data
Protection Act (Chapter 586 of the Laws of Malta) as well as the various
subsidiary legislation issued under the same – the ‘DPA’.
This Privacy Policy will inform you as to how we use and look after your
personal data. This Policy covers, among other topics:
- Information about who we are and how to contact us;
- Transparency about how we collect and use your personal data,
including when and how it is shared and the categories of
recipients;
- Information on how we protect your personal data;
- Information about your rights, the choices available to you, and how
we will facilitate your rights and respond to your questions.
This Privacy Policy is provided in a layered format so you can click
through to the specific areas set out below.
- IMPORTANT INFORMATION AND WHO WE ARE
- THE DATA WE MAY COLLECT ABOUT YOU
- HOW IS YOUR DATA COLLECTED
- HOW WE USE YOUR PERSONAL INFORMATION
- SHARING OF YOUR PERSONAL DATA
- INTERNATIONAL TRANSFER
- DATA SECURITY
- DATA RETENTION
- YOUR LEGAL RIGHT
- AUTOMATED PROCESSING – PROFILING
- CHANGES TO THE PRIVACY POLICY AND YOUR DUTY
TO INFORM US OF CHANGES
1. IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY POLICY
This privacy policy (the “Privacy Policy” or the
“Policy”) aims to give you information on how
Dunder collects and processes your personal data, including any data
you may provide through this website https://www.dunder.com/en (the
“Website” or the “Site”) when you
sign up to our registration form, send us an email, make a phone
call or use our Live Chat service and any data we may collect on you
to provide you with our online gaming and betting services (the
“Services”) with respect to our relationship with
you as a player.
It is important that you read this Privacy Policy together with any
other privacy or fair processing notice we may provide on specific
occasions when we are collecting or processing personal data about
you so that you are fully aware of how and why we are using your
data. This Privacy Policy supplements the other notices and is not
intended to override them.
This Website and our Services are not designed or directed to persons
under the age of 18 with respect to the use of the Services
(“Legally of Age”). If you are not Legally of Age,
you should not use the Services nor provide any personal information
to us.
CONTROLLER
This Privacy Policy is issued on behalf of Dunder Limited, which is
the controller (“Controller”) and responsible for
your personal data, is referred to as “Dunder”, the “Company”, “we”,
“us” or “our” in this Privacy Policy. Dunder is a company registered
under the laws of Malta and it is licensed and regulated by the
Malta Gaming Authority under license number MGA/CRP/217/03.
The Controller is part of the Casumo Group (which means those
companies having Casumo Holdings PLC, CRN- C 63156 as their ultimate
parent company).
The Casumo Group has established an Intra Group Data Transfer
Agreement which governs any transfer of personal data within the
companies form part of the Casumo Group.
The Company has appointed a data protection officer
(“DPO”) who is responsible for overseeing questions
in relation to this Privacy Policy. If you have any questions
relating to this Privacy Policy, including any requests to exercise
your rights, please contact the DPO using the details given below.
CONTACT DETAILS
- Our full details are:
- Full name of legal entity: Dunder Limited
- Company registration number: C72889
- Email address: help@dunder.com
- Postal address: The Unicorn Centre, Triq Il-Uqija, Swieqi, SWQ
2335, Malta
- Data Protection Officer: dpo@dunder.com
2. THE DATA WE MAY COLLECT ABOUT YOU
Personal data, or personal information, means any information about
an individual from which that person can be identified, directly or
indirectly. It does not include data where the identity has been
removed (anonymous data).
We may collect personal data from you because of a legal reason or
because you have consented us to do so for a specific purpose. We
may collect, use, store and transfer different categories of
personal data about you, which we have grouped together as follows:
-
Registration Data includes first and last
name, username or similar identifier, date of birth,
territory applicable social security number where permitted
or required by law, gender, country.
-
Contact Data includes postal address, email
address and telephone number(s).
-
Identification and Verification Data (Anti-Money
Laundering/Due Diligence/KYC data) includes
first and last name, permanent address and proof of address,
date of birth, nationality, employment history and
information, adverse media report, financial status and
information (e.g. bank statement, source of income and
source of wealth, tax information), Politically Exposed
Person check, Sanction check screening, masked credit card
details, proof of e-wallet ownership such as Neteller,
Skrill, Paypal, Paysafe, KYC documentation (e.g. ID card,
passport, utility bill, any other document as may be
specified in sectoral implementing procedures issued by the
relevant regulator authorities).
-
Responsible Gambling Data (RG) including
name, surname, Zip Code, email, phone number, country, date
of birth, territory applicable social security number where
permitted or required by law , approved transactions
(deposits and withdrawals), denied transactions (deposits
and withdrawals), Identification and Verification Data,
Self-exclusion Data
-
Self-exclusion Data includes data pertaining
to you and your self-exclusion such as your Registration and
Contact Data and your self-exclusion details such as reason,
start and date, utilisation of self- exclusion tools such as
exclusions, session limit, loss limit, wager limit, deposit
limit, reality check.
-
Financial Data includes payment card details
and bank account details.
-
Transaction and Usage Data includes details
generated through your use of our Services (e.g. playing
Games) and include payments to and from you (deposits,
withdrawals, failed deposits and reversed withdrawals) and
other details of Services you have purchased from us (such
as bets, wagers (real and bonus), wins), date and time of
the transactions, account balances (bonus and real), bonuses
used (conversion and forfeiture), bonuses turnover, bonuses
balance, channels used, transaction games played, language,
country, account balances.
-
Log in Data includes internet protocol (IP)
address, your logins (first log in last login, last failed
login), duration of log ins, browser type and version, time
zone setting and location, browser plug-in types and
versions, operating system and platform and other technology
on the devices you use to access our Services.
-
Profile Data internal notes to your account,
interests and preferences.
-
Marketing Communications Data includes your
preferences in receiving marketing from us (opt in/opt out).
-
Other Communication Data provided by you in
communication with us (via recorded calls, chats, emails, or
SMS) which may include various data such as your intentions,
interests, complaints, preferences, as well as internal
communication and notes.
-
Analytics Data include various data provided
by your observed with respect to your use of our Website and
Services such as your player ID, language, location, browser
data, campaigns utilised, channels used, device, payment
provider, Transaction and Usage data and in case of online
acquisition analytics also pages visited, postcards clicked,
scroll depth. Certain information is collected using cookies
and/or similar tracking technology.
We do not collect any Special Categories of Personal
Data about you (this includes details about your race
or ethnicity, religious or philosophical beliefs, sex life or sexual
orientation, political opinions, trade union membership, information
about your health and genetic and biometric data). However, there
may be times when you may voluntarily choose to disclose information
like this to us, such as when you are speaking with our Ambassadors
or Responsible Gaming Specialists, and these chats and emails are
assigned to your account with us. Where you have a health condition
that affects your ability to control your gambling behaviour and you
choose to provide us with documentation to support this, we will
make note that you have a health condition but delete the
documentation you provide to us. Where you disclose a health
condition which we feel may impact your ability to make rational
decisions around your gameplay, we may take the decision to block
you from our Services for your own safety.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We collect your personal data through different methods, including:
-
Direct interactions - you may give us your
Registration, Contact, Identity and Verification, Marketing
and Communications and Financial Data by filling in forms or
by corresponding with us by phone, email or otherwise when
you engage with us to provide you with our Services.
-
Third parties and publicly available
sources- We may combine the information we
collect from you with information that we receive about you
from other sources, such as public databases, providers of
demographic information and other third parties. Due to
regulatory requirements we collect know your customer (KYC)
information from specialised third parties. Such information
is collected only when it is reasonably necessary for the
organisation’s activities.
-
Automated technologies or interactions - We
and our third-party service providers may collect
information automatically from your device in a variety of
ways, including:
- Through your browser or device: Certain information is
collected by most browsers or automatically through your
device, such as your IP, device type, language and the
Internet browser type you are using.
- Through your use of an app: When you download and use
our apps, we may track and collect app usage data, such
as the date and time the app on your device accesses our
Servers and the information and files that have been
downloaded to the app.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of
a contract we have with you and you fail to provide that data when
requested, we may not be able to perform the contract we have or are
trying to enter into with you (for example, to provide you with
information related to your query).
4. HOW WE USE YOUR PERSONAL INFORMATION
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 process your registration, set up and look after your account
(including checks made to age verify you and to guard against
fraud);
- To provide and operate the Services (such as for gaming/betting
and payment processing);
- To communicate with you and to keep you informed of our latest
updates to our Services and special offers;
- For legal and regulatory reasons, to comply with our legal
obligations and license conditions such as Anti-money laundering
and responsible gaming; including for the purpose of
ascertaining your source of funds or income, or as required by
other governmental authorities, or to comply with a subpoena or
similar legal process or respond to a government request;
- Providing, maintaining, enhancing and personalizing the Services
and analysing how customers use the Services and the Website;
- To know your preferences and to try to ensure that the content
on our Website is presented in the most effective manner for you
and your computer or mobile device;
- To market our Services (see more below under “Marketing”), as
well as to serve you advertisements, including behavioral
advertising;
- To communicate with your and to process any of your requests to
exercise your Legal Rights;
- To identify and authenticate your access to certain features of
the Services;
- To detect and prevent fraudulent and illegal activity or any
other type of activity that may jeopardize or negatively affect
the integrity of the Services, including by identifying risks
associated with your activity on our Services;
- To investigate violations of our policies and Terms and
Condition as well as enforce our policies and the Terms and
Conditions; and
- To investigate and resolve disputes in connection with your use
of the Services.
Generally, we do not rely on consent as a legal basis for processing
your personal data other than in relation to sending direct
marketing communications to you via email, text message or by post.
You have the right to withdraw consent to marketing at any time by
either unsubscribing from our mailing list or by contacting our DPO.
PURPOSE FOR PROCESSING YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the
ways we use your personal data, and which of the legal bases we rely
on to do so. We have also identified what our legitimate interests
are where appropriate.
Note that we may process your personal data for more than one lawful
ground depending on the specific purpose for which we are using your
data. Please contact us if you need details about the specific legal
ground, we are relying on to process your personal data where more
than one ground has been set out in the table below.
Purpose/Activity |
Type of data |
Lawful basis for processing including basis of
legitimate interest |
To register you as a new player, identify you and verify
you when you access your Account to allow you to
participate in games. |
- (a) Registration Data
- (b) Contact Data
- (c) Log-in Data
|
Performance of a contract with you |
To allow you participate in the games. |
- (a) Transaction and Usage Data
|
Performance of a contract with you |
To process and manage transactions |
- (a) Financial Data
- (b)Transaction and Usage Data
|
Performance of a contract with you |
To manage our relationship with you, to provide you with
access to our Services. |
- (a) Registration Data
- (b) Contact Data
- (c) Profile Data
- (d) Other Communication Data
- (e) Transaction and Usage Data
- (f) Self-exclusion Data
|
- (a) Performance of a contract with you
- (b) Compliance with legal obligations
|
For AML/CTF and due diligence purposes |
- (a) Registration Data
- (b) Contact Data
- (c) Identity and Verification Data
- (d) Transaction and Usage Data
|
Necessary to comply with legal obligations |
To establish and investigate any suspicious behaviour in
order to protect our business from any risk and fraud
|
- (a) Registration Data
- (b) Contact Data
- (c) Identity and Verification Data
- (d) Log-in Data
- (e) Financial Data
- (f) Other Communication Data
|
Legitimate interests (detection and prevention of fraud)
|
Identification and investigation of gaming activity for
responsible gaming purpose |
- (a) Responsible Gaming Data
- (b) Self-exclusion Data
- (c) Other Communication Data
|
Necessary to comply with legal obligations |
Responsible gaming profiling |
- (a) Responsible Gaming Data
- (b) Self-exclusion Data
- (c) Other Communication Data
|
Necessary to comply with legal obligations |
To ensure that self-excluded players with respect to
Dunder or any other brand/company within Casumo Group
are duly self-excluded and do not access our Services.
|
|
Necessary to comply with legal obligations |
Direct marketing of our own Services including bonuses,
news, and promotions. |
- (a) Contact Data
- (b) Marketing and Communication Data
|
- (a) Legitimate Interests (to promote our own
Services and to develop our business)
- (b) Consent
|
Direct marketing of products and services including
promotions of any other brand/company within Casumo
Group. |
- (a) Contact Data
- (b) Marketing and Communication Data
|
Consent |
Social Media Marketing |
|
- (a) Legitimate Interests (to promote our own
Services and to develop our business)
- (b) Consent
|
Customer segmentation for the purposes of tailored
offers and bonuses sent via direct marketing. |
- (a) Registration Data
- Transaction and Usage Data
|
Legitimate Interests (to promote our own Services, to
develop our business and enhance our relationship with
you by targeted offers) |
To administer and protect our business and this portal
(including troubleshooting, data analysis, testing,
system maintenance, support, reporting and hosting of
data) |
- (a) Registration
- (b) Contact
- (c) Analytics data
|
- (a) Necessary for our legitimate interests (for
running our business, provision of
administration and IT services, network
security, to prevent fraud and in the context of
a business reorganisation or group restructuring
exercise)
- (b) Necessary to comply with a legal obligation
|
MARKETING
We may use your personal data, such as your email address and
telephone number, ourselves or by using our third party
subcontractors for the purpose of providing you with promotional
materials (including news and bonuses), concerning our Services as
well as products, services and promotions which relate to other
companies within the Casumo Group, which we believe may interest
you.
We will use your personal data for the purpose of providing you with
promotional materials solely where we have a legitimate interest in
doing so, or where we have obtained your affirmative consent.
When relying on legitimate interest, Dunder will give you the
opportunity to oppose to such direct marketing when registering on
our Site.
When relying on consent, the consent may be granted by you when
registering on our Site.
In both cases, if you do not wish to receive direct marketing any
longer, you may opt out, easily, at any time, either by:
- activating the relevant link at the end of an electronic
message, or
- contacting us, or
- changing your Settings in your profile.
In case of social media marketing, you can control the delivery of
certain advertising or social campaigns through the settings offered
by the respective third-party platforms (e.g. Facebook).
In addition, if you download our mobile application to your device
from the Apple AppStore or Google Play, the only way to prevent
receipt of notifications is by changing the settings on the device
itself.
THIRD PARTY TRACKING TECHNOLOGIES
When you visit or access our Services (for example when you visit our
Website), we use (and authorise third parties to use) cookies,
pixels other technologies ("Tracking
Technologies").
The Tracking Technologies allow us to automatically collect
information about you and your online behaviour, as well as your
device (for example your computer or mobile device), for different
purposes, such as in order to enhance your navigation on our
Services, improve our Services’ performance and customize your
experience on our Services. We also use this information to collect
statistics about the usage of our Services, perform analytics,
deliver content which is tailored to your interests and administer
services to our users and players.
For further information on what Tracking Technologies/cookies are,
which cookies we use, how and why we use cookies, and how you can
control which cookies are dropped, please read our Cookie Policy.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we
collected it, unless we reasonably consider that we need to use it
for another reason and that reason is compatible with the original
purpose. If you wish to get an explanation as to how the processing
for the new purpose is compatible with the original purpose, please
contact our DPO.
If we need to use your personal data for an unrelated purpose, we
will notify you and we will explain the legal basis which allows us
to do so.
Please note that we may process your personal data without your
knowledge or consent, in compliance with the above rules, where this
is required or permitted by law.
5. SHARING OF YOUR PERSONAL DATA
We do not rent, sell, or share your personal data with third parties
(“Recipients”) except as described in this Privacy
Policy. The personal information will be disclosed to Recipients
only to the extent required for the specific purpose(s), as
stipulated in this Privacy Policy.
We may have to share your personal data with the following categories
of Recipients:
- Professional advisers including lawyers, bankers, auditors and
insurers based in Malta who provide consultancy, banking, legal,
insurance and accounting services.
- Any service providers that may have access to your personal data
in rendering us with their support services, for example, IT
service providers, payment service providers, game providers for
the purpose of provision of games, AML providers providing
and/or processing certain data for the purposes of compliance
with our AML obligations, analytic services providers, service
providers that technically enable communication with you (via
email, chat, SMS, phone), marketing service providers, data
hosting service providers, Website performance and security
systems service providers.
- Casumo Group companies. We may disclose personal data processed
to other companies within the Casumo Group in accordance with
Intra Group Data Transfer Agreement.
- Third parties to whom we may choose to sell, transfer, or merge
parts of our business or our assets. Alternatively, we may seek
to acquire other businesses or merge with them. If a change
happens to our business, then the new owners may use your
personal data in the same way as set out in this privacy policy.
We require all third parties that are acting as processers to Dunder
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.
Where required by law, your personal information may be disclosed to
an applicable governmental, regulatory, sporting or enforcement
authority. Your personal information may also be disclosed to any
regulatory or sporting body in connection with policing the
integrity or enforcing the rules of a sport or game and/or
prevention and detection of crime and where the Company considers
that there are reasonable grounds to suspect that you may be
involved in a breach of such rules or the law, have knowledge of a
breach of such rules or the law or otherwise pose a threat to the
integrity of the relevant sport or game. Those bodies may then use
your personal information to investigate and act on any such
breaches in accordance with their procedures.
6. INTERNATIONAL TRANSFERS
Wherever possible, Dunder keeps your information within the European
Economic Area (“EEA”). However, it may be necessary
for the provision of Services and to the extent required for the
specific purpose, as stipulated in this Privacy Policy to transfer
your personal information to countries outside the EEA. The data
protection and other laws of these countries may not be as
comprehensive as those in the EEA.
Where your personal data is transferred outside the EEA, we use best
efforts to ensure that your personal information is protected
through contractual means (such as by using the standard contractual
clauses (“SCCs”) approved by the European
Commission for data transfer) or other means (such as ensuring that
the European Commission decisions determined that such jurisdictions
offer adequate level of protection).
7. DATA SECURITY
We have put in place appropriate security measures to prevent your
personal data from being accidentally lost, used or accessed in an
unauthorised way, altered or disclosed. In addition, we limit access
to your personal data to those employees, agents, contractors and
other third parties who have a business need to know. They will only
process your personal data on our instructions, and they are subject
to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal
data breach and will notify you and any applicable regulator of a
breach where we are legally required to do so.
8. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
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, or reporting requirements.
To determine the appropriate retention period for personal data, we
consider the amount, nature, and sensitivity of the personal data,
the potential risk of harm from unauthorised use or disclosure of
your personal data, the purposes for which we process your personal
data and whether we can achieve those purposes through other means,
and the applicable legal requirements.
Details of retention periods for different aspects of your personal
data are available in our Data Retention Policy which you can
request from us by contacting our DPO.
Where your personal data is no longer required by us, we will either
securely delete or anonymise the personal data in question.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection
laws in relation to your personal data. You have right to:
Request access to your personal data (commonly known
as a “data subject access request”). This enables you to receive a
copy of the personal data we hold about you and to check that we are
lawfully processing it.
Request correction tof the personal data that we
hold about you. This enables you to have any incomplete or
inaccurate data we hold about you corrected, though we may need to
verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables
you to ask us to delete or remove personal data where there is no
good reason for us continuing to process it. You also have the right
to ask us to delete or remove your personal data where you have
successfully exercised your right to object to processing (see
below), where we may have processed your information unlawfully or
where we are required to erase your personal data to comply with
local law. Note, however, that we may not always be able to comply
with your request of erasure for specific legal reasons which will
be notified to you, if applicable, at the time of your request.
Object to 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 as you feel it impacts
on your fundamental rights and freedoms. You also have the right to
object where we are processing your personal data for direct
marketing purposes. In some cases, we may demonstrate that we have
compelling legitimate grounds to process your information which
override your rights and freedoms.
Request restriction of processing of your personal
data. This enables you to ask us to suspend the processing of your
personal data in the following scenarios: (a) if you want us to
establish the data’s accuracy; (b) where our use of the data is
unlawful but you do not want us to erase it; (c) where you need us
to hold the data even if we no longer require it as you need it to
establish, exercise or defend legal claims; or (d) you have objected
to our use of your data but we need to verify whether we have
overriding legitimate grounds to use it.
Request the transfer of your personal data to you or
to a third party. We will provide to you, or a third party you have
chosen, your personal data in a structured, commonly used,
machine-readable format. Note that this right only applies to
automated information which you initially provided consent for us to
use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on
consent to process your personal data. However, this will not affect
the lawfulness of any processing carried out before you withdraw
your consent. If you withdraw your consent, we may not be able to
provide certain products or services to you. We will advise you if
this is the case at the time you withdraw your consent.
WHAT WE MAY NEED FROM YOU
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. We may also contact you to ask you
for further information in relation to your request to speed up our
response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month.
Occasionally it may take us longer than a month if your request is
particularly complex or you have made a number of requests. In this
case, we will notify you and keep you updated.
RIGHT TO MAKE A COMPLAINT
You have the right to make a complaint at any time to the Information
and Data Protection Commissioner Office (IDPC), the Maltese
supervisory authority for data protection issues. We would, however,
appreciate the chance to deal with your concerns before you approach
the IDPC so please contact us in the first instance. The IDPC’s
contact details are as follows,
10. AUTOMATED PROCESSING – PROFILING
AUTOMATED PROCESSING FOR RESPONSIBLE GAMING
PURPOSES
Dunder is on the basis of the applicable laws and license conditions
legally obliged to monitor its players in order to identify people
who may be experiencing, or at risk of developing, problems with
their gambling, and interact with them to offer help or support. To
this end, and to fulfil this obligation, by using historic data
describing behaviour of players, in particular certain Responsible
Gaming Data, Transaction and Usage Data, and Other Communication
Data (in particular notably sentiment used in message). Dunder has
established rules regarding who is likely to suffer from gambling
addiction and then take relevant action.
Decisions, on the basis of the prediction, are not taken
automatically without human intervention.
AUTOMATED PROCESSING FOR ANTI-MONEY LAUNDERING
PURPOSES
Dunder is, on the basis of the applicable laws and license
conditions, legally obliged to monitor its players in order to
identify potentially suspicious activities regarding AML/CFT. Based
on data describing the behaviour of players, in particular
Transaction and Usage Data, the algorithm suggests a risk profile.
Decisions, on the basis of the prediction, are not taken
automatically and require human intervention.
AUTOMATED PROCESSING FOR DIRECT MARKETING
SEGMENTS
By making use of Your Transaction and Usage data, certain
Registration Data such as gender, country, date of birth and Your
overall interaction with our services, we analyse and establish
various segments of the customers/players. These segments are then
processed manually, in order to ensure that we provide the most
appropriate offers and bonuses to our players. These decisions are
not taken automatically without human intervention. The process is
based on legitimate interest of Dunder regarding providing
customised and quality experience for the players. You can object to
such processing by contacting us or changing your preferences in
your account.
11. CHANGES TO THE PRIVACY POLICY AND YOUR
DUTY TO INFORM US OF CHANGES
This version was last updated on [DATE] and historic versions can be
obtained by contacting us.
It is important that the personal data we hold about you is accurate
and current. Please keep us informed if your personal data changes
during your relationship with us.