Effective date: 3 December 2023
Last updated: 3 December 2023
The controller of your personal data is Open Smart Gambling Technology Ltd, a company registered in England and Wales under number 15326596, with its registered office at 122 Leadenhall Street, London, EC3V 4AB, United Kingdom (“OSGT”, “we”, “us”).
Questions about the processing of personal data and requests relating to your rights should be sent to legal@osgt.uk.
Our Data Protection Officer (DPO) is Kemal Kahraman. The DPO can be contacted at legal@osgt.uk.
This Policy applies to the osgt.uk website, the client portal and all services we provide, including deposit management, the referral programme and the intake of applications from analysts.
3.1. Data you provide:
3.2. Data generated through use of the service:
3.3. Technical data:
3.4. Data from external sources:
| Purpose | Categories of data | Legal basis (UK GDPR) |
|---|---|---|
| Registration, operation of the client portal and provision of services under the agreement | 3.1, 3.2 | Performance of a contract, Art. 6(1)(b) |
| Client identification, document verification, fraud prevention, sanctions and other compliance checks | 3.1, 3.4 | Performance of a contract, Art. 6(1)(b); legitimate interests, Art. 6(1)(f); legal obligation, Art. 6(1)(c), where applicable |
| Settlements, payouts, tax and accounting records | 3.1, 3.2 | Performance of a contract, Art. 6(1)(b); legal obligation, Art. 6(1)(c) |
| Platform security, prevention of fraud and abuse of the referral programme, logging | 3.2, 3.3 | Legitimate interests, Art. 6(1)(f) — protecting clients, funds and the integrity of the service |
| Evidencing the conclusion of the agreement and confirmations of transfer certificates | 3.2 | Performance of a contract, Art. 6(1)(b); legitimate interests, Art. 6(1)(f) |
| Responding to enquiries and complaints | 3.1 | Performance of a contract, Art. 6(1)(b); legitimate interests, Art. 6(1)(f) |
| Assessing analyst applications | 3.1 | Steps prior to entering into a contract, Art. 6(1)(b) |
| Sending reports, transaction notices and other service communications | email address, account and transaction data | Performance of a contract, Art. 6(1)(b); legitimate interests, Art. 6(1)(f) |
| Google Analytics | 3.3 | Consent, Art. 6(1)(a) |
| Cloudflare Web Analytics and technical performance analytics | 3.3 | Legitimate interests, Art. 6(1)(f) — security, performance and improvement of the service |
We do not use automated facial recognition or automated biometric matching of a client's image against an identity document. An ordinary digital photograph or document copy is not processed by us as a biometric template for automated identification.
Providing the data required for identification and performance of the agreement is mandatory. If you do not provide it, we will not be able to accept funds, provide services or make a payment, and we may suspend the services or terminate the agreement in accordance with its terms.
We may share personal data with the following categories of recipients, but only to the extent necessary for the relevant purpose:
We do not sell your personal data.
Some recipients or their infrastructure may be located outside the United Kingdom. Where a transfer is a restricted transfer under the UK GDPR, we use a legally recognised safeguard, including applicable UK adequacy regulations or appropriate standard contractual mechanisms such as the UK International Data Transfer Agreement (IDTA) or the UK Addendum to standard contractual clauses, together with any required transfer risk assessment.
We do not retain personal data for longer than is necessary for the purposes of processing, the contractual relationship, security, accounting and tax records, compliance with applicable requirements and the protection of legal rights.
In particular:
After the applicable period expires, data is deleted or anonymised unless continued retention is required by law or to protect the rights of OSGT or third parties.
We apply organisational and technical safeguards, including role-based access controls, encryption in transit, activity logging, backups and controlled access to systems. Cloudflare is used for website delivery and network protection. For security reasons, we do not publish a detailed map of our internal infrastructure or security configuration.
No measure provides absolute protection. You must keep your client portal credentials confidential and notify us immediately of their loss or unauthorised use.
The status (level) of an account is assigned automatically by the platform based on the amount of funds held in management. The status may affect predetermined contractual parameters, including the OSGT profit share. The system applies predetermined rules and does not evaluate the client's personal characteristics when making this calculation.
If you believe that an automated status or related calculation is incorrect, you may contact legal@osgt.uk to request an explanation, human review and an opportunity to challenge the result.
Depending on the circumstances, you have the right to: access your data; have inaccurate data corrected; request erasure; restrict processing; object to processing based on legitimate interests; request data portability; withdraw consent at any time without affecting the lawfulness of processing before withdrawal; and exercise rights that apply to automated decision-making.
Some rights may be limited where data is needed to comply with a legal obligation, establish or defend legal claims, or for another reason permitted by law.
Requests should be sent to legal@osgt.uk. We normally respond within one month, subject to the statutory rules on extensions and requests for additional information.
If you believe we have infringed your rights, you may lodge a complaint with the UK Information Commissioner's Office (ICO): Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF; ico.org.uk; 0303 123 1113. We would appreciate the opportunity to address your concern first.
Our use of cookies and similar technologies is described in the separate Cookie Policy available on osgt.uk.
The services are not intended for persons under 18 and we do not knowingly collect their data. If you become aware that a minor has provided us with data, please contact legal@osgt.uk.
We may update this Policy. The current version is published on the website with the date of the update; we may notify clients of material changes through the client portal or by email.
Open Smart Gambling Technology Ltd
122 Leadenhall Street, London, EC3V 4AB, United Kingdom
Company number 15326596
DPO: Kemal Kahraman
Email: legal@osgt.uk