Privacy notice

A good club is discreet, and so are we. This notice explains what personal data is involved when you use Velvet Reel Club, why, and what you can do about it. It is written to meet the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

1. Who is responsible for your data

The data controller is velvetreelclub.com, hello@velvetreelclub.com, which operates Velvet Reel Club. For anything to do with privacy, write to hello@velvetreelclub.com and put “Privacy” in the subject line.

2. The short version

• There are no accounts, no sign-up and no passwords. We never ask for your name, address or date of birth.
• Your chip balance, age confirmation and settings are kept in your browser’s local storage, on your device. They are not sent to us.
• Our hosting provider keeps short-lived technical logs to deliver and protect the website.
• If you email us, we use your email to reply.
• Google measurement cookies are only ever used if the operator turns them on, and then only after you say yes.

3. Information kept on your device

To make the games work, the Club stores a few small values in your browser’s local storage and session storage: your Velvet Chips balance, the stake you last chose at each table, whether you have confirmed you are 18 or over, your reality-check interval, any break you have taken, and how long you have played in the current session. These values stay on your device. We cannot see them, and they are not transmitted to us or anyone else.

You can remove them at any time with the “Forget my settings” button on our responsible play page, or by clearing site data in your browser settings. Our Cookie policy lists them in detail.

4. Hosting and security logs

The website is delivered by our hosting provider, Cloudflare. When your browser requests a page, Cloudflare necessarily processes technical information such as your IP address, browser type (user agent), the page requested, and the date and time. This is used to deliver the website, keep it secure and protect it against abuse and attacks. These logs are kept for a short period, typically no more than a few days, unless they are needed longer to investigate a security incident. We do not use them to identify you or to build a profile.

5. Emails you send us

If you write to us, we receive your email address, the content of your message and anything you choose to include. We use it only to read and answer your message, to deal with any request you make, and to keep a record of the conversation. We keep correspondence for up to 24 months after the conversation ends, unless we need it longer to handle a complaint or a legal matter.

6. Google measurement tags, only with your consent

By default, the Club sets no cookies and loads no analytics or advertising tags. The operator may choose to enable Google measurement tags (Google Analytics or Google Ads conversion measurement) to understand how visitors find the site. If that is switched on:

• a banner will ask for your permission before any Google cookie is set or any tag measures your visit;
• if you decline, the games work exactly the same and no Google cookies are set;
• if you accept, Google may process information such as your IP address, device details, the pages you visit and the fact that you started a game, in order to produce aggregated statistics and measure advertising;
• you can change your mind at any time by clearing this site’s data in your browser, which brings the banner back.

Google acts as our processor or as an independent controller depending on the service. You can read how Google uses information at policies.google.com.

7. Lawful bases

• Hosting and security logs — our legitimate interests in delivering a working, secure website (UK GDPR Article 6(1)(f)).
• Emails — our legitimate interests in answering the people who contact us, or taking steps at your request (Article 6(1)(f) and (b)).
• Google measurement tags — your consent (Article 6(1)(a)), which you can take back at any time. Storage on your device for this purpose also relies on your consent under the Privacy and Electronic Communications Regulations.
• Game data in local storage — strictly necessary to provide the games you ask to play; it never leaves your device.

8. Who receives data

We do not sell personal data, and we do not share it for anyone else’s marketing. The only recipients are the service providers who help us run the Club: Cloudflare (hosting and security), our email provider (to receive and answer messages) and, only if enabled and only with consent, Google (measurement). We may also disclose information if the law requires it, or to protect the rights and safety of our users or ourselves.

9. International transfers

Some of our providers process data outside the United Kingdom, including in the United States and the European Economic Area. Where that happens, transfers are protected by UK adequacy regulations, the UK International Data Transfer Agreement or Addendum, or another safeguard recognised under UK data protection law.

10. How long we keep information

Local storage values stay on your device until you clear them. Hosting logs are kept for days rather than months. Emails are kept for up to 24 months after the conversation ends. If Google tags are enabled, Google cookies last for the periods set out in our Cookie policy.

11. Your rights

Under UK GDPR you have the right to ask for a copy of your personal data, to have inaccurate data corrected, to have data erased, to restrict or object to processing, to data portability where it applies, and to withdraw your consent at any time without affecting what came before. Because we hold so little, most requests will concern emails you have sent us. To make a request, write to hello@velvetreelclub.com. We will respond within one month.

12. Children

The Club is only for adults aged 18 and over. We do not knowingly collect information from anyone under 18. If you believe a child has contacted us, please tell us and we will delete what we hold.

13. Complaints

If you are unhappy with how we have handled your data, please tell us first so we can put it right. You also have the right to complain to the Information Commissioner’s Office (ICO), the UK’s data protection regulator, at ico.org.uk or on 0303 123 1113.

14. Changes to this notice

We will update this notice if the way we handle data changes — for example, if measurement tags are switched on. The date at the top shows the latest version.