HarbourPlay
18+

Privacy Policy

Last updated: 10 November 2025

1. Introduction

HarbourPlay Ltd ("we", "us", "our") is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, store, and protect information when you use our website and social gaming services at harbourplay.co.uk (the "Platform").

We are the data controller responsible for your personal data. This policy is designed to comply with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

2. Information We Collect

2.1 Information You Provide

We collect information you voluntarily provide when you:

  • Confirm your age (18+ requirement)
  • Contact us via email, telephone, or post
  • Provide feedback or participate in surveys

This may include: name, email address, telephone number, correspondence content, and any other information you choose to provide.

2.2 Information Automatically Collected

When you visit our Platform, we automatically collect certain technical information:

  • Device information: IP address, browser type and version, operating system, device identifiers
  • Usage data: Pages visited, time spent on pages, click patterns, referring URLs
  • Cookies and similar technologies: See our Cookie Policy for details

2.3 Information We Do Not Collect

Because HarbourPlay operates as a social gaming platform with no real-money transactions, we do not collect payment information, financial data, or identity documents.

3. How We Use Your Information

We process your personal data for the following purposes:

3.1 Platform Operation

  • Providing access to social games and online social slots
  • Verifying age compliance (18+ requirement)
  • Maintaining platform functionality and security
  • Troubleshooting technical issues

Legal basis: Legitimate interests (providing our services) and legal obligation (age verification).

3.2 Communication

  • Responding to your enquiries and requests
  • Sending important service updates and notices
  • Providing customer support

Legal basis: Legitimate interests (customer service) and contract performance.

3.3 Improvement and Analytics

  • Analysing platform usage to improve user experience
  • Understanding which games and features are most popular
  • Testing new features and functionality

Legal basis: Consent (for non-essential analytics cookies) and legitimate interests (platform improvement).

3.4 Security and Compliance

  • Detecting and preventing fraud, abuse, or illegal activity
  • Enforcing our Terms of Use
  • Complying with legal obligations

Legal basis: Legal obligation and legitimate interests (security and compliance).

4. Data Sharing and Disclosure

We do not sell or rent your personal data. We may share information in the following limited circumstances:

4.1 Service Providers

We work with trusted third-party service providers who assist with hosting, analytics, customer support, and platform operations. These providers access personal data only as necessary to perform services on our behalf and are contractually obligated to protect your data.

4.2 Legal Requirements

We may disclose personal data if required by law, court order, or government request, or if necessary to protect our rights, property, or safety, or that of our users.

4.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your personal data may be transferred to the acquiring entity. We will notify you of any such change.

5. Data Retention

We retain personal data only as long as necessary to fulfil the purposes described in this policy, unless a longer retention period is required or permitted by law.

  • Age verification data: Retained for the duration of your use and up to 1 year after last activity
  • Contact correspondence: Retained for up to 3 years after resolution
  • Technical logs: Retained for up to 12 months
  • Cookie data: Varies by cookie type; see our Cookie Policy

6. Your Rights Under UK GDPR

You have the following rights regarding your personal data:

  • Right of access: Request a copy of the personal data we hold about you
  • Right to rectification: Correct inaccurate or incomplete data
  • Right to erasure: Request deletion of your personal data in certain circumstances
  • Right to restriction: Limit how we use your data
  • Right to data portability: Receive your data in a structured, commonly used format
  • Right to object: Object to processing based on legitimate interests
  • Right to withdraw consent: Withdraw consent for processing that requires it (e.g., analytics cookies)

To exercise any of these rights, please contact us using the details in Section 11. We will respond within one month.

7. International Transfers

Our Platform is hosted within the UK and European Economic Area (EEA). If we transfer personal data outside the UK/EEA, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses or transfers to countries with adequate data protection standards as recognised by the UK government.

8. Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, destruction, or alteration. These measures include:

  • Encryption of data in transit (HTTPS/TLS)
  • Access controls and authentication
  • Regular security audits and updates
  • Staff training on data protection

While we take security seriously, no method of transmission or storage is 100% secure. You use our Platform at your own risk.

9. Children's Privacy

Our Platform is strictly for users aged 18 and over. We do not knowingly collect personal data from individuals under 18. If we become aware that we have inadvertently collected data from a minor, we will delete it promptly. If you believe a child has provided us with personal data, please contact us immediately.

10. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will post the updated policy on this page with a revised "Last updated" date. Significant changes will be communicated via prominent notice on our Platform. Your continued use after changes indicates acceptance of the updated policy.

11. Contact Us

If you have questions about this Privacy Policy or wish to exercise your data rights, please contact us:

Data Protection Officer
HarbourPlay Ltd
123 Gaming Street
London, EC1A 1BB
United Kingdom

Email: privacy@harbourplay.co.uk
Telephone: +44 20 1234 5678

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK's supervisory authority for data protection:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF
Website: ico.org.uk