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

Playing Wanted Dead Or a Wild Slot means submitting personal data. This document lays out exactly how long we retain it, the reasons, and what technical protections sit behind each category—all built around 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 unique retention clock. Identity records stick around for five years after account closure. Financial logs are stored for seven, meeting HMRC requirements. Gameplay data receives 24 months before anonymisation kicks in. Full card numbers never touch our systems—only tokenised aliases—and every byte is protected. Independent auditors verify our automated deletion routines, and any schedule slip triggers a full incident response. A version-controlled policy log documents every edit, and we provide you 30 days’ notice before material changes become effective. Subject access and deletion requests are managed within statutory deadlines.

Core Definitions and Scope of Personal Data

We take a broad view on what counts as personal data. Direct identifiers—name, email, billing address, masked payment details—are accompanied by 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 identify again a person when stitched together, so we handle 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 extend across live databases, archives, and backups without exception. Each window begins counting from the last activity or transaction date, spelled out below. We reassess definitions every six months to keep pace with regulatory guidance.

Marketing Consent and Message Logs

We store your consent record—timestamped, IP-stamped, and with capture method—for the duration of our relationship plus six years after revocation, to meet PECR rules. Dispatch records for electronic messages, push notifications, and SMS are kept for only thirteen months. Revoking consent instantly suppresses communications while retaining historical proof. A segmented database ensures suppression without latency, and consent logs are held in a distinct compliance archive. Dispatch records hold metadata only—subject, time, condition—not full message body. The six-year post-withdrawal window mirrors the statute of limitations for regulatory investigations. Quarterly audits confirm no expired consents trigger mailings. We never tailor offers with gameplay or financial data beyond explicit consents.

User Account and ID Verification Data

Main identity data—official ID scans, residence proof, biometric selfie matches—are kept for 5 years after your final session or closure of account, whichever occurs later. This covers statutory limitation periods and anti-money laundering duties. We retrieve only the essentials: document ID, validity, nationality. The full-resolution image gets deleted upon extraction. Once the five-year period pass, all original data is erased, but a cryptographic hash of the verification data lives on for another two years inside an logging system. Identity data sits encrypted in storage with AES-256-GCM, isolated from analytics, and every retrieval is recorded for three years. Unnecessary fields like place of birth are removed at verification stage to shrink the data footprint. Yearly reviews ensure correctness and actively purge outdated records.

Uploading Documents and Biometric Handling

Upload an ID through our protected portal and automatic verification finishes within ninety seconds. We extract the document ID, validity, citizenship, and a trust score, then shred the high-resolution image immediately—it never reaches storage. The original file stays in an in-memory buffer and vanishes after handling. A compacted, stamped preview is generated for auditing purposes and retained only for the identity lifecycle. That preview lives in a immutable vault with strict controls and is never exposed to client support. Extracted fields are encrypted and kept for the 5-year-plus-2-year hash period. All operations runs on UK-based ISO 27001 servers, and every small image access is stored unchangeably.

Specifics of Biometric Data

Liveness checks collect a short video stream solely in memory. Images are processed and removed within milliseconds. Only a numerical vector of facial landmarks remains. This numerical representation lacks any image data and cannot be reconstructed into a picture. It remains for the time of identity verification and is purged irrevocably upon closure of account or after 5 years. The vector sits in a specialized HSM with automatic expiration and is never sent out. Login comparisons happen inside the HSM’s secure enclave without revealing the unprocessed data. The data set is bound to a pseudonymous identifier disconnected from marketing data, which makes reidentification very hard. Even system administrators cannot view or rebuild facial features from the kept numerical representation.

Access Request and Erasure Workflows

When a subject access request arrives, we generate a structured JSON/CSV export of all non-purged data within one month, expandable by two months for complex cases. The export covers live databases, encrypted archives, and processor tokens, provided via a one-time secure link that expires in 72 hours. For deletion, we proceed sequentially: immediate account suppression and token revocation, then scheduled erasure of all personal data not subject to legal hold. We create a confirmation report outlining erased versus retained categories and their justifications. This report is kept as auditable proof for as long as the longest surviving data category. All requests are recorded immutably for five years.

Financial Transaction and Payment Records

Deposit, withdrawal, and wager records are maintained for seven years from the transaction date, per HMRC and FCA rules. We do not store full PANs or CVVs. We record only the BIN, last four digits, and a tokenised reference. Chargeback disputes freeze the contested record until final resolution, after which the seven-year clock resumes. Data is partitioned quarterly so automated purging works cleanly, with monthly deletion runs checked by auditors. Tokenised card references stay valid only while your account is live and are wiped within thirty days of closing. Aggregated, anonymised totals endure for financial reporting without any personal information. All financial data is encrypted and isolated from marketing systems.

Tokenised Payment Instruments and Processor References

Payment gateways generate vaulted tokens that associate your card to a non-sensitive alias. We hold them for the account lifetime plus a thirty-day grace interval, then transmit deletion commands to the processor and clear our own link. The only evidence left behind is an anonymised transaction hash used in aggregate statements, themselves deleted after seven years. No usable credentials ever reside on our systems. We monitor token revocation daily and initiate incidents if deletion fails. Tokens are tied to our merchant code and cannot be used elsewhere. Weekly reconciliation validates authenticity, and tokens tied to lost or stolen cards are invalidated immediately. All token operations are recorded and auditable. Aggregate reports never disclose individual transaction hashes.

Gaming Session and Behavioral Analytics Data

Each spin on Wanted Dead Or a Wild logs reel positions, RNG seed, and net outcome with microsecond precision. We store 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 get 36 months. Error diagnostics have 90 days. No individual gameplay data flows into credit or marketing profiling. All logs are encrypted and off-limits to marketing teams.

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

Technology Framework and Data Storage

All data sits in UK-based ISO 27001 Tier III+ data centres, with no replication outside the UK. A hot disaster recovery site in a separate UK zone synchronizes every six hours. Backups are encrypted client-side and adhere to identical retention rules. We implement least privilege with hardware MFA for administrators, recording their sessions in an immutable three-year audit trail. Multi-factor authentication integrates a hardware token and biometric check. Penetration tests are conducted quarterly, and an independent auditor verifies automated purge schedules. Any deviation generates a Severity 1 incident, alerted to our DPO within four hours. We also operate an air-gapped backup rotated weekly, following the same deletion policies.

Key Lifecycle Administration

Master keys change every 90 days automatically inside an HSM. New keys are never exported in plaintext. Rotated keys are retained 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 assign each key to a single data partition, avoid reuse, and conduct quarterly witnessed key ceremonies logged immutably for five years. The offline archive of old keys requires 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.

Policy Review and Breach Notification Protocols

We evaluate 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 displayed in our privacy centre, minus confidential details. Material changes are sent 30 days ahead. Minor edits are silently recorded. If a breach occurs affecting data under this policy, we inform affected individuals within 72 hours if high risk, submit with the ICO, and issue a transparency notice. Third-party processor breaches must follow the same protocol. We hold a breach notification log audited quarterly. Post-incident reviews adjust controls as needed. Biannual tabletop exercises test misconfigurations and ransomware to test our response.

Document Versioning and Update Log

We keep a version-controlled history of this policy with semantic versioning and plain-English summaries of each change. The log specifies exactly which sections changed and why. Previous versions remain accessible for comparison, so you can see precisely what was added wanteddeadorawildslot removed. Material modifications affecting your rights are communicated 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 confirm 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 demonstrates our commitment to accountable data governance.

Responsible Gambling and Voluntary Exclusion Registers

Betting limits, session reminders, and timeout settings are stored for your account’s lifetime and never purged while it remains active. If you choose to ban yourself, your hashed identity and device fingerprints are added to a specialized exclusion register kept indefinitely under UKGC licence requirements. The register is coded separately, accessed only at login or registration, and never used for analytics. Permission is limited to qualified compliance staff, and all queries are recorded for three years. The register stores only identity blocks—no banking or gameplay records. We check it annually to fix errors and remove deceased individuals. Otherwise, it stays indefinite. This retention is obligatory and excluded from deletion requests.

Reality Check and Session Limit Enforcement

Reality check counters use temporary session counters that restart every 24 hours, starting anew from your first spin after midnight. Your selected interval—say, 30 minutes—is stored persistently and automatically reactivates when you come back, even after a long break. Modifying the interval mid-session introduces the new value instantly for the next reminder. These settings are purged only upon validated 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 accuracy. All timer configurations are verifiable through the same three-year access log standard. We do not profile or market based on these settings.