10 Lug Information Retention Policy for Wanted Dead Or a Wild Slot Game in the United Kingdom
Playing Wanted Dead Or a Wild Slot game means handing over personal data https://wanteddeadorwild.uk/. This document lays out exactly how long we retain it, the rationale, and what technical protections sit behind each category—all based on UK GDPR, the Data Protection Act 2018, and PCI DSS. We manage identity documents, financial transactions, gameplay telemetry, responsible gambling markers, and marketing consents, each with its own retention clock. Identity records stick around for five years after account closure. Financial logs stay for seven, matching HMRC requirements. Gameplay data receives 24 months before anonymisation takes effect. Full card numbers never reach our systems—only tokenised aliases—and every byte is protected. Independent auditors verify our automated deletion routines, and any schedule slip initiates a full incident response. A version-controlled policy log tracks every edit, and we provide you 30 days’ notice before material changes are implemented. Subject access and deletion requests are processed within statutory deadlines.
Marketing Approval and Communication Logs
We maintain your consent record—timestamped, IP-stamped, and method-recorded—for the duration of our relationship plus six years after revocation, to comply with PECR rules. Dispatch records for emails, push alerts, and SMS are kept for only thirteen months. Withdrawing consent immediately blocks communications while keeping historical proof. A divided database provides suppression without lag, and consent logs are stored in a dedicated compliance archive. Send logs contain metadata only—topic, timestamp, state—not full message content. The six-year post-withdrawal period reflects the statute of limitations for regulatory investigations. Quarterly audits check no expired consents trigger mailings. We never tailor offers with gameplay or financial data beyond explicit authorisations.
Essential Definitions and Scope of Personal Data

We take a broad view on what constitutes 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 includes session length, bet sizing, spin velocity, and how often feature triggers fire. Even pseudonymised logs can re-identify 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 begins counting from the last activity or transaction date, spelled out below. We review definitions every six months to stay aligned with regulatory guidance.
Monetary Transaction and Settlement Records
Deposit, withdrawal, and wager histories are retained for seven years from the transaction date, per HMRC and FCA rules. We never store full PANs or CVVs. We record only the BIN, last four digits, and a tokenised identifier. Chargeback disputes suspend the contested record until final outcome, after which the seven-year clock resumes. Data is partitioned quarterly so automated purging operates cleanly, with monthly deletion runs audited by auditors. Tokenised card references stay valid only while your account is active and are deleted within thirty days of closure. Combined, anonymised totals persist for financial reporting without any personal information. All financial data is secured and quarantined from marketing systems.
Tokenised Payment Instruments and Processor References
Payment gateways produce vaulted tokens that link your card to a non-sensitive alias. We store them for the account lifetime plus a thirty-day grace window, then transmit deletion commands to the processor and clear our own reference. The only evidence left behind is an anonymised transaction hash used in aggregate reports, themselves removed after seven years. No usable credentials ever exist on our systems. We monitor token revocation daily and raise incidents if deletion is unsuccessful. Tokens are bound to our merchant code and cannot be used other places. Weekly reconciliation confirms authenticity, and tokens tied to lost or stolen cards are cancelled immediately. All token operations are recorded and auditable. Aggregate reports never disclose individual transaction hashes.
Access Request and Erasure Workflows
When a subject access request arrives, we produce a formatted JSON/CSV export of all non-purged data within one month, extendable by two months for complex cases. The export spans live databases, encrypted archives, and processor tokens, provided via a one-time secure link that expires in 72 hours. For deletion, we implement a cascade: immediate account suppression and token revocation, then batched erasure of all personal data not subject to legal hold. We generate 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 logged immutably for five years.
Responsible Gambling and Voluntary Exclusion Registers
Betting limits, session reminders, and timeout settings are kept for your account’s lifetime and never purged while it stays active. If you opt for self-exclusion, your hashed identity and device fingerprints are placed into a specialized exclusion register maintained without time limit under UKGC licence requirements. The register is encrypted separately, queried only at login or registration, and never utilized for analytics. Entry is confined to qualified compliance staff, and all searches are tracked for three years. The register stores only identity blocks—no financial or gameplay records. We examine it annually to fix errors and remove deceased individuals. If not, it is kept indefinite. This retention is mandatory and free from deletion requests.
Time Check and Gaming Duration Enforcement
Reality check counters use temporary session counters that clear every 24 hours, restarting from your first spin after midnight. Your selected interval—say, 30 minutes—is saved persistently and instantly reactivates when you return, even after a long break. Modifying the interval mid-session sets the new value immediately for the next reminder. These settings are deleted only upon confirmed account deletion. Session timer data sits in a specialized, encrypted store separate from gameplay analytics. The 24-hour counter is based on play start, not midnight, for accuracy. All timer configurations are auditable through the same three-year access log standard. We at no time analyze or advertise based on these settings.
Infrastructure Setup and Data Location
All data sits in UK-based ISO 27001 Tier III+ data centres, not copied outside the UK. A hot disaster recovery site in a separate UK zone updates 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 triggers a Severity 1 incident, alerted to our DPO within four hours. We also keep an air-gapped backup rotated weekly, subject to the same deletion policies.
Key Lifecycle Administration
Master keys are renewed every 90 days automatically inside an HSM. New keys are not extracted 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 bind each key to a single data partition, do not reuse, and conduct quarterly witnessed key ceremonies logged immutably for five years. The offline archive of old keys needs dual control and is stored on write-once media in a fireproof safe. Annual recovery drills ensure forensic decryption works when needed. No plaintext key material ever leaves the HSM boundary.
Account Registration and Identity Verification Data
Core identity profiles—scans of government IDs, address verification, biometric selfie matches—are held for 5 years after your final session or account closure, whichever occurs later. This includes contractual time limits and anti-money laundering responsibilities. We retrieve only the essentials: document ID, validity, country of citizenship. The original image gets deleted right after extraction. Once 5 years pass, all original data is erased, but a hash of the verification result remains for an additional two years inside an audit trail. Identification data sits encrypted in storage with AES-256-GCM, kept separate from analytics, and every retrieval is logged for a three-year period. Unnecessary fields like birth location are discarded at verification stage to shrink the data volume. Yearly audits ensure precision and proactively delete expired entries.
Uploading Documents and Biometric Data Processing
Submit an ID through our safe portal and automated validation completes within a minute and a half. We extract the document number, expiry, country of citizenship, and a reliability score, then delete the original image immediately—it never touches disk. The source file stays in an in-memory buffer and is removed after handling. A reduced, watermarked preview is created for audit purposes and kept only for the ID lifecycle. That small image lives in a immutable vault with strict controls and is never exposed to customer support. Extracted fields are encoded and kept for the five-year-plus-two hash window. All handling runs on servers in the UK with ISO 27001, and every small image access is stored unchangeably.
Biometric Information Details
Liveness verifications collect a short video stream solely in memory. Images are analyzed and discarded within milliseconds. Only a data vector of facial landmarks persists. This vector contains no image data and cannot be reverse-engineered into a face. It remains for the time of identity verification and is permanently deleted upon closure of account or after a five-year period. The vector sits in a specialized HSM with self-expiry and is never exported. Authentication checks happen inside the HSM’s protected enclave without revealing the original vector. The data set is bound to a anonymous identifier separated from advertising profiles, which makes re-identifying extremely difficult. Even system administrators are unable to view or reconstruct facial attributes from the saved data.
Session Gameplay and Behavioral Analytics Data
All spins 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 compact them into an anonymous statistical digest employed for game design. Session behavioural profiles—average bet, spin cadence, feature buy-ins—stay for the same 24-month window and are then deleted. Feature trigger heatmaps remain for 12 months before merging into a global model. RNG seed audit trails receive 36 months. Error diagnostics receive 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 aggregated 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 merged into global model
- Error and crash diagnostic logs: 90 days, then rotated out
Policy Evaluation and Incident Reporting Protocols
We review 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 displayed in our privacy centre, minus confidential details. Material changes are communicated 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 post 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 model misconfigurations and ransomware to test our response.
Document Versioning and Change Log
We maintain a version-controlled history of this policy with semantic versioning and plain-English summaries of each change. The log details 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 access the full change log through a link in our privacy centre at any time. This transparent approach shows our commitment to accountable data governance.
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