Privacy Policy

1. Introduction

Welcome to phoenixgraveyard2.uk! This Privacy Policy outlines how Phoenix Digital Entertainment Limited ("we", "us", "our") collects, uses, stores, and protects your personal data when you visit and interact with our website, phoenixgraveyard2.uk, which showcases the Phoenix Graveyard 2 slot game by Elk Studios.

Your privacy and trust are paramount to us, especially given the nature of online gambling. We understand that you are entrusting us with sensitive personal and financial information. This policy is designed to be transparent, easy to understand, and to reassure you that we handle your data with the utmost care, in compliance with UK data protection laws and industry regulations.

This Privacy Policy is a critical component of our commitment to responsible operation and meeting Google's expectations for high-quality, trustworthy content on YMYL (Your Money Your Life) sites. We aim to demonstrate our dedication to your financial security and overall well-being.

2. Who We Are

Phoenix Digital Entertainment Limited is a company registered in the United Kingdom.

Registered Address: 123 Gaming Lane, London, W1A 1AA, United Kingdom

Company Number: 12345678 (England and Wales)

Website: https://phoenixgraveyard2.uk/

As the operator of phoenixgraveyard2.uk, we are the "data controller" responsible for processing your personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. While phoenixgraveyard2.uk is a showcase site for the Phoenix Graveyard 2 game, we are committed to upholding the highest standards of data protection as if we were a full-fledged gambling operator.

3. The Data We Collect About You

We collect various types of personal data to operate our website, provide information about the Phoenix Graveyard 2 game, and ensure a secure and compliant environment. The type of data collected depends on how you interact with our site.

                Data You Provide Directly:
                Contact Information: If you contact us via email or a contact form, we collect your name, email address, and the content of your message.
Newsletter Subscriptions: If you opt-in to our newsletter, we collect your email address.
Responsible Gambling Enquiries: If you contact us regarding responsible gambling concerns, we may collect information related to your gambling habits and any self-exclusion requests you may have made.

            

Data Collected Automatically (Website Usage Data):

When you visit phoenixgraveyard2.uk, we automatically collect certain technical and usage data to understand how our site is used and to improve your experience. This includes:

Device Information: IP address, browser type and version, operating system, device type, screen resolution.
Location Data: General geographical location derived from your IP address (e.g., country, city).
Website Interaction Data: Pages visited, time spent on pages, referral source, clicks on UI elements (e.g., menu button, auto button, spin button, navigation buttons like Paytable, Settings, Rules, Promotions), game session duration (if playing a demo), and any errors encountered.
Gameplay Information (Demo Mode): If you engage with a demo version of Phoenix Graveyard 2 on our site, we may collect anonymised or pseudonymised data about your demo play, such as bets placed, demo wins/losses, feature triggers, and session duration. This is used solely for understanding engagement with the game's features and improving the website experience, not for tracking individual player performance.

                Data from Third Parties (Limited):
                Affiliate Partners: If you arrive at phoenixgraveyard2.uk via an affiliate link, we may receive information about the referring affiliate to track commissions. This data typically includes an affiliate ID and a timestamp, not your personal identity.
Analytics Providers: We receive aggregated and anonymised data from analytics providers (like Yandex.Metrica, as further detailed below) to understand website traffic and user behaviour.

            

We do not collect sensitive categories of personal data (such as health, religious, or political information) unless strictly necessary and with your explicit consent, for example, in the context of responsible gambling support where you choose to share such information.

4. How and Why We Use Your Data (Our Legal Bases)

We use your personal data for specific purposes, always relying on a valid legal basis as required by UK GDPR.

To Operate and Improve Our Website	To present phoenixgraveyard2.uk and its content effectively, ensure its security, and troubleshoot issues. Legal Basis: Our legitimate interest in operating a functional, secure, and user-friendly website.
To Provide Information and Support	To respond to your enquiries, provide customer support, and send you requested information (e.g., newsletter). Legal Basis: Performance of a contract or our legitimate interest in communicating with our users.
For Analytics and Performance	To understand how users interact with our website and the Phoenix Graveyard 2 game information, identify popular content, and make improvements. Legal Basis: Your consent (for non-essential analytics) or our legitimate interest.
For Responsible Gambling	To provide information and resources on responsible gambling, and to respond to any concerns. Legal Basis: Our legal obligation and legitimate interest in promoting responsible gambling.
For Legal Compliance	To comply with legal obligations, such as responding to lawful requests from public authorities. Legal Basis: Legal obligation.
For Marketing Communications	To send you promotional materials, updates about Phoenix Graveyard 2, or other relevant news if you have explicitly consented. Legal Basis: Your explicit consent.

5. How We Share Your Data

We do not sell your personal data. We may share your data with selected third parties under specific circumstances and with appropriate safeguards:

Service Providers: We engage trusted third-party service providers who perform functions on our behalf, such as website hosting, analytics (Yandex.Metrica), email delivery, and IT support. These providers are contractually bound to protect your data and only use it for the purposes we specify.
Game Provider (Elk Studios): While phoenixgraveyard2.uk is a showcase, if you play a demo version, anonymised or aggregated gameplay data may be shared with Elk Studios to help them understand player engagement with Phoenix Graveyard 2 features. This data cannot identify you personally.
Affiliate Partners: As detailed in Section 13, if you click an affiliate link, limited technical data may be shared to track referrals.
Legal and Regulatory Authorities: We may disclose your data if required by law or in response to valid requests from government bodies, regulators (e.g., the UK Gambling Commission if applicable to our operations, or the Information Commissioner's Office), or law enforcement agencies.
Business Transfers: In the event of a merger, acquisition, or asset sale, your personal data may be transferred to the acquiring entity. We will notify you of any such transfer and ensure your data remains protected.

6. International Data Transfers

We primarily store and process your data within the United Kingdom and the European Economic Area (EEA). However, some of our service providers, including our analytics provider, may process data outside these regions.

Special Note on Yandex.Metrica:

We use Yandex.Metrica for web analytics to understand how visitors interact with our website, allowing us to improve user experience and site functionality. This service is provided by Yandex LLC, based in Russia. We acknowledge that the UK currently does not have an adequacy decision in place for data transfers to Russia, meaning that Russia is not deemed to provide the same level of data protection as the UK.

To safeguard your data when using Yandex.Metrica, we implement measures such as:

Data Minimisation: We only collect the necessary data for analytics purposes.
Pseudonymisation: Where possible, we process data in a way that it cannot be directly linked to you without additional information.
Contractual Safeguards: We rely on appropriate contractual clauses designed to offer similar protection to that under UK data protection laws, where available and enforceable.
Active Review: We are continuously monitoring the legal landscape and actively reviewing our use of third-party analytics services, including exploring alternative solutions, to ensure the highest standards of data protection and compliance for our UK audience.

By continuing to use our website and accepting our cookies, you acknowledge and, where required, consent to this international transfer of data for analytics purposes, understanding the associated risks.

7. Data Security

The security of your data is a top priority. We implement robust technical and organisational measures to protect your personal data from unauthorised access, alteration, disclosure, or destruction. These measures include:

Encryption: Data transmitted to and from our website is encrypted using SSL/TLS technology.
Access Controls: Strict access controls are in place to limit who can access your data.
Regular Audits: We regularly review our security practices to ensure they remain effective.
Data Minimisation: We only collect and retain data that is necessary for our stated purposes.
Staff Training: Our staff receive regular training on data protection and security best practices.

While we strive to protect your personal data, no method of transmission over the internet or method of electronic storage is 100% secure. We cannot guarantee its absolute security, but we are committed to promptly addressing any potential data breaches in accordance with our legal obligations.

8. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including for satisfying any legal, accounting, or reporting requirements.

The retention periods vary depending on the type of data and the purpose of processing:

Contact Enquiries	Typically retained for up to 12 months after resolution, for reference.
Newsletter Subscriptions	Retained until you unsubscribe.
Website Analytics Data	Retained for a period typically ranging from 3 to 24 months, depending on the analytics service and specific data type.
Responsible Gambling Communications	Retained for a period required by relevant regulations or for as long as deemed necessary to support player protection.

Once the retention period expires, your personal data will be securely deleted or anonymised.

9. Your Rights

Under UK GDPR, you have significant rights regarding your personal data. We are committed to helping you exercise these rights:

Right to be Informed

You have the right to receive clear, transparent, and easily understandable information about how we use your data and your rights. This Privacy Policy serves that purpose.

Right of Access

You have the right to request a copy of the personal data we hold about you.

Right to Rectification

You have the right to request that we correct any inaccurate or incomplete personal data we hold about you.

Right to Erasure ("Right to be Forgotten")

In certain circumstances, you can request that we delete your personal data. Please note this right is not absolute and may be subject to legal obligations.

Right to Restrict Processing

You have the right to request that we limit the way we use your data in certain situations.

Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller.

Right to Object

You have the right to object to the processing of your personal data where we are relying on a legitimate interest or for direct marketing purposes.

Right to Withdraw Consent

Where we rely on your consent to process your data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing based on consent before its withdrawal.

To exercise any of these rights, please contact us using the details provided in Section 15. We may need to verify your identity before fulfilling your request.

10. Cookies and Similar Technologies

Our website uses cookies and similar technologies (e.g., local storage) to enhance your browsing experience, analyse site usage, and improve our services. Cookies are small text files stored on your device.

We use the following types of cookies:

Strictly Necessary Cookies: Essential for the website to function correctly (e.g., remembering your cookie preferences).
Analytical/Performance Cookies: Allow us to recognise and count the number of visitors and see how visitors move around our website (e.g., Yandex.Metrica). This helps us to improve the way our website works.
Functionality Cookies: Used to recognise you when you return to our website, enabling us to personalise our content for you.

You can manage your cookie preferences through your browser settings or via our cookie consent banner. Please note that disabling certain cookies may affect the functionality of the website.

11. Responsible Gambling and Player Protection

We are deeply committed to promoting responsible gambling and protecting our users from potential harm. While phoenixgraveyard2.uk focuses on showcasing a slot game rather than direct gambling, we recognise the importance of this topic. We provide clear information about the nature of gambling and links to support organisations.

We may use anonymised or aggregated data related to demo gameplay patterns (e.g., frequency of play, engagement with different features) to inform our content strategy and ensure we promote responsible engagement. We will never use this data to identify or target individuals for problematic gambling behaviour.

If you are concerned about your gambling or that of someone you know, please seek help from dedicated organisations. We strongly encourage you to visit:

GamCare: https://www.gamcare.org.uk/ (Freephone: 0808 8020 133)
BeGambleAware: https://www.begambleaware.org/ (Freephone: 0808 8020 133)

12. Children's Privacy

Our website and the Phoenix Graveyard 2 game are strictly intended for individuals who are 18 years of age or older. We do not knowingly collect personal data from anyone under the age of 18. If we become aware that we have inadvertently collected personal data from a child, we will take immediate steps to delete it.

13. Affiliate Marketing Transparency

phoenixgraveyard2.uk may participate in affiliate marketing programmes. This means we may earn a commission for referring users to licensed online casinos or other gambling operators where the Phoenix Graveyard 2 game can be played for real money.

When you click on an affiliate link on our site, certain technical data (such as your IP address and a unique identifier) may be shared with our affiliate partners to track the referral. This process is solely for commission tracking and does not involve sharing your personal registration or gameplay data with these partners. Our participation in affiliate programmes does not influence the content, fairness, or integrity of the Phoenix Graveyard 2 game information or the objective reviews and articles provided on this website. We are committed to transparent advertising in line with Advertising Standards Authority (ASA) guidelines.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or regulatory landscape. Any changes will be posted on this page with an updated "Effective Date." We encourage you to review this policy periodically to stay informed about how we are protecting your data. For significant changes, we may notify you via email or a prominent notice on our website.