Data Retention Policy for Wanted Dead Or a Wild Slot in the United Kingdom

Playing Wanted Dead Or a Wild Slot game means submitting personal data wanteddeadorwild.uk. This document lays out exactly how long we retain it, why, and what technical protections underpin each category—all based on 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 own retention clock. Identity records are kept for five years after account closure. Financial logs stay for seven, matching HMRC requirements. Gameplay data receives 24 months before anonymisation is applied. Full card numbers never reach our systems—only tokenised aliases—and every byte is secured. Independent auditors review our automated deletion routines, and any schedule slip initiates a full incident response. A version-controlled policy log documents every edit, and we provide you 30 days’ notice before material changes take effect. Subject access and deletion requests are processed within statutory deadlines.

Fundamental 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—coexist with indirect signals like hashed IP addresses, device fingerprints, browser agents, and advertising tokens. Behavioural data covers 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 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 span live databases, archives, and backups without exception. Each window commences from the last activity or transaction date, spelled out below. We revisit definitions every six months to keep pace with regulatory guidance.

Controlled Gambling and Self-Exclusion Registers

Betting limits, time checks, and timeout settings are kept 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 specific exclusion register kept indefinitely under UKGC licence requirements. The register is encrypted separately, queried only at login or registration, and never utilized for analytics. Permission is restricted to trained compliance staff, and all queries are recorded for three years. The register stores only identity blocks—no monetary or gameplay records. We examine it annually to rectify errors and remove deceased individuals. Apart from that, it remains everlasting. This retention is mandatory and excluded from deletion requests.

Reality Check and Session Limit Enforcement

Reality check counters use short-lived session counters that clear 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 return, even after a long break. Modifying the interval mid-session applies the new value instantly for the next reminder. These settings are deleted only upon confirmed account deletion. Session timer data resides in a dedicated, encrypted store separate from gameplay analytics. The 24-hour counter is based on play start, not midnight, for correctness. All timer configurations are verifiable through the same three-year access log standard. We never profile or promote based on these settings.

User Account and ID Verification Data

Primary identity records—scans of government IDs, residence proof, biometric selfie verifications—are kept for 5 years after your final session or account termination, whichever comes later. This covers contractual limitation periods and anti-money laundering duties. We obtain only the essentials: document number, expiration date, nationality. The original image gets destroyed immediately after extraction. Once five years pass, all source data is removed, but a cryptographic hash of the verification data persists for another two years inside an logging system. Identification data sits encrypted at rest with AES-256-GCM, stored away from analytics, and every data access is tracked for 3 years. Optional fields like birth location are discarded at the time of verification to reduce the data size. Yearly reviews verify correctness and actively purge expired data.

Uploading Documents and Biometric Data Processing

Provide an ID through our protected portal and automated checking finishes within 90 seconds. We retrieve the document ID, expiry, citizenship, and a confidence score, then shred the original image right away—it never touches disk. The initial file stays in an in-memory buffer and disappears after handling. A reduced, stamped preview is produced for compliance purposes and kept only for the ID lifecycle. That small image lives in a write-once storage with tight controls and is never shared to client support. Retrieved data are encoded and stored for the 5-year-plus-2-year hash period. All handling runs on servers in the UK with ISO 27001, and every small image access is recorded immutably.

Biometric Data Specifics

Live detection checks capture a brief video feed completely in memory. Frames are analyzed and deleted within milliseconds. Only a numerical vector of facial landmarks survives. This numerical representation contains no image data and cannot be reverse-engineered into a facial image. It stays for the duration of identity verification and is purged irrevocably upon account termination or after 5 years. The vector sits in a dedicated HSM with auto-expiry and is never sent out. Login comparisons happen inside the HSM’s safe environment without revealing the unprocessed data. The vector is bound to a pseudonym separated from marketing data, which makes reidentification extremely difficult. Even system administrators are unable to view or reconstruct facial attributes from the stored vector.

Consent for Marketing and Communication Logs

We maintain your consent record—time-stamped, with IP address, and with capture method—for the entirety of our relationship plus six years after cancellation, to meet PECR requirements. Dispatch records for e-mails, push messages, and SMS are retained for only thirteen months. Cancelling consent immediately halts communications while retaining historical proof. A partitioned database ensures suppression without latency, and consent logs are held in a dedicated compliance archive. Dispatch records contain metadata only—heading, timestamp, condition—not full message text. The six-year post-withdrawal window reflects the statute of limitations for regulatory inquiries. Quarterly audits check no expired consents initiate mailings. We never tailor offers with gameplay or financial data beyond explicit authorisations.

Payment Transaction and Billing Records

Deposit, withdrawal, and wager records are kept 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 suspend the contested record until final resolution, after which the seven-year clock continues. Data is partitioned quarterly so automated purging operates cleanly, with monthly deletion runs audited by auditors. Tokenised card references remain valid only while your account is open and are erased within thirty days of closing. Summarised, anonymised totals endure for financial reporting without any personal information. All financial data is coded and isolated from marketing systems.

Secured Payment Instruments and Processor References

Payment gateways generate vaulted tokens that link your card to a non-sensitive reference. We keep them for the account lifetime plus a thirty-day grace interval, then issue deletion commands to the processor and wipe our own link. The only evidence left behind is an anonymised transaction hash used in aggregate reports, themselves purged after seven years. No usable credentials ever reside on our systems. We monitor token revocation daily and raise incidents if deletion does not work. Tokens are bound to our merchant code and cannot be used in other contexts. Weekly reconciliation confirms validity, and tokens tied to lost or stolen cards are invalidated immediately. All token operations are logged and verifiable. Aggregate reports never reveal individual transaction hashes.

Session Gameplay and Behavioral Analytics Data

All spins on Wanted Dead Or a Wild tracks reel positions, RNG seed, and net outcome with microsecond precision. We store these raw logs for twenty-four months, then compact them into an anonymous statistical digest used for game design. Session behavioural profiles—average bet, spin cadence, feature buy-ins—persist 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 receive 36 months. Error diagnostics have 90 days. No individual gameplay data goes into credit or marketing profiling. All logs are encrypted and off-limits to marketing teams.

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

Infrastructure Setup and Data Residency

All data resides in UK-based ISO 27001 Tier III+ data centres, not copied 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, logging their sessions in an immutable three-year audit trail. Multi-factor authentication integrates a hardware token and biometric check. Penetration tests run quarterly, and an independent auditor verifies automated purge schedules. Any deviation raises 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 rotate every 90 days automatically inside an HSM. New keys are not extracted 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 destroyed inside the HSM, making any backups unrecoverable. We bind each key to a single data partition, never 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 confirm forensic decryption works when needed. No plaintext key material ever departs the HSM boundary.

Data Subject Access Request and Deletion Workflows

Upon receiving an SAR, we produce a formatted JSON/CSV export of all non-purged data within one month, prolongable 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 queued erasure of all personal data not subject to legal hold. We create a confirmation report detailing 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.

Policy Review and Incident Reporting Protocols

We assess this policy every six months or upon material change to the game or regulation. Reviews are minuted with DPO, CISO, and legal counsel. A public summary is published in our privacy centre, minus confidential details. Material changes are emailed 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, report with the ICO, and publish 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 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 outlines 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 transmitted 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 view 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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