1
Scope and Data Controller Identity
This Privacy Policy sets out how DoyleSports Ltd ("we", "us", "our") collects, holds, processes, and
protects the personal data of individuals ("you", "data subjects") who visit gamedoylesports.com.
For the purposes of the United Kingdom General Data Protection Regulation (UK GDPR) and the Data Protection
Act 2018 (DPA 2018), the designated Data Controller is:
- Organization: DoyleSports Ltd
- Registered Office: 46-48 E Smithfield, London E1W 1AW, United Kingdom
- Executive Lead: Berker Çetin (CEO)
- Data Protection Desk: doylesports@atomicmail.io
2
Categories of Personal Data Collected
We adhere to the principle of data minimization under Article 5(1)(c) of the UK GDPR. We collect only data
strictly necessary for our services:
- Directly Provided Data: Name, electronic mail address, game genre preferences, age
confirmation, and message content submitted via our contact or VIP Lead Test forms.
- Technical & Telemetry Data: IP addresses (truncated or anonymized for geographic
security), browser user-agent headers, operating system version, screen resolution, referral URLs, and
session timestamps.
- Preference Data: Local storage state indicators confirming 18+ age verification and
cookie consent choices.
3
Lawful Bases for Processing (Article 6 UK GDPR)
We process your personal information exclusively when an applicable lawful basis exists under Article 6(1)
of the UK GDPR:
- Legitimate Interests (Art. 6(1)(f)): To maintain website security, prevent fraudulent
bot activity, optimize server performance, and publish accurate social game reviews.
- Consent (Art. 6(1)(a)): When you voluntarily submit forms, join our VIP Club
newsletter, or accept non-essential analytical cookies. You maintain the right to withdraw consent at any
time.
- Legal Obligation (Art. 6(1)(c)): To comply with mandatory statutory obligations under
English law, including compliance with digital advertising standards and age verification protocols.
4
Purposes of Data Processing
The personal data gathered through gamedoylesports.com is deployed strictly for the following defined
purposes:
- To present responsive, high-performance editorial reviews of 20 social casino titles and Tower Dash
simulations.
- To validate submitted lead testing requests and verify transmission integrity via simulated webhook
endpoints.
- To enforce our strict 18+ age restriction gate for mature UK audiences.
- To answer technical inquiries, corporate proposals, and general feedback directed to our London office.
- To diagnose hosting faults, defend against malicious cyber attacks, and maintain platform uptime.
5
Cookies and Client-Side Storage Mechanisms
Cookies and browser `localStorage` are utilized on gamedoylesports.com to sustain operational state. We
divide these mechanisms into two categories:
- Strictly Necessary Storage: Local storage flags `gamedoylesports_age_verified` and
`gamedoylesports_cookie_consent` ensure you are not repeatedly prompted on subsequent page views. These
are essential for compliance and cannot be disabled.
- Functional / Analytical Storage: Anonymous metrics capturing aggregated page views and
game simulation clicks to understand editorial engagement.
You may adjust or clear cookies at any time through your browser settings or by utilizing the Cookie Notice
options on our Website.
6
Technical Log Data and Server Telemetry
Our web servers automatically record raw access logs whenever a request is received. These logs incorporate
your IP address, timestamp, HTTP status code, and resource path. Log files are held in secure,
access-controlled environments for thirty (30) days solely for network diagnostics, load balancing, and
forensic security audits, after which they are irreversibly overwritten.
7
Third-Party Processors and Service Providers
DoyleSports Ltd does not sell, rent, or trade your personal data to advertisers or data brokers. We engage
reputable third-party infrastructure providers who act strictly as Data Processors under binding Data
Processing Agreements (DPAs):
- Cloud hosting, content delivery networks (CDNs), and DDoS mitigation vendors.
- Encrypted email dispatch infrastructure for corporate correspondence via atomicmail.io.
- Diagnostic lead validation simulation pipelines for web development quality assurance.
8
International Data Transfers and Safeguards
Our primary hosting infrastructure resides within the United Kingdom and the European Economic Area (EEA).
In the event that any operational sub-processor processes information outside the UK, DoyleSports Ltd
guarantees that appropriate safeguards are instituted in accordance with Chapter V of the UK GDPR. Such
safeguards include UK International Data Transfer Agreements (IDTAs), European Commission Standard
Contractual Clauses (SCCs), or UK adequacy regulations.
9
Data Retention and Deletion Schedules
We retain personal data only for as long as is necessary to accomplish the purposes outlined in this Policy:
- Lead Test & Contact Inquiries: Stored for up to six (6) months following resolution
of the query, unless a longer retention period is mandated by law.
- Newsletter & VIP Subscriptions: Retained until such time as the subscriber
exercises their right to unsubscribe or withdraw consent.
- Technical Security Logs: Retained for a rolling period of 30 days and purged
automatically.
10
Technical and Organisational Security Measures
DoyleSports Ltd enforces robust administrative, physical, and technical safeguards to prevent unauthorized
access, disclosure, alteration, or destruction of personal data. These protocols include:
- Transport Layer Security (TLS 1.3) encryption across all public web traffic.
- Strict role-based access control (RBAC) and mandatory multi-factor authentication (MFA) for
administrative systems.
- Regular vulnerability scanning, static code analysis, and dependency patch cycles.
11
Data Subject Rights under UK GDPR
As a resident of the United Kingdom, you possess extensive statutory rights concerning your personal
information:
- Right of Access (Art. 15): Request a copy of the personal information we hold about
you.
- Right to Rectification (Art. 16): Request correction of inaccurate or incomplete
records.
- Right to Erasure / "Right to be Forgotten" (Art. 17): Request deletion of your personal
data where retention is no longer justified.
- Right to Restrict Processing (Art. 18): Request temporary freezing of data processing
under specific circumstances.
- Right to Data Portability (Art. 20): Request transfer of your personal data in a
structured, machine-readable format.
- Right to Object (Art. 21): Object to processing based on legitimate interests or direct
marketing.
To exercise any of these rights, email our team at doylesports@atomicmail.io. We will respond within one calendar
month without charge.
12
Protection of Minors (Strict 18+ Exclusion)
gamedoylesports.com does not knowingly target, market to, or collect data from children or individuals under
eighteen (18) years of age. Our 18+ Age Gate actively blocks minors from browsing our social casino
simulations. If a parent, guardian, or regulatory authority becomes aware that a minor has submitted
personal information to us, please notify us immediately at doylesports@atomicmail.io and we will expeditiously expunge
such records from our databases.
13
Direct Marketing and Opt-Out Mechanisms
If you opt-in to receive our weekly social casino review digest or new game demo alerts, we may transmit
informative communications to your verified email address. Every communication includes an accessible
one-click unsubscribe mechanism. Opting out from marketing does not affect non-marketing service
correspondence.
14
Automated Decision-Making and Profiling
DoyleSports Ltd does not engage in automated decision-making processes or profiling activities that produce
legal effects or similarly significantly affect data subjects under Article 22 of the UK GDPR.
15
Modifications and Version History
We may revise this Privacy Policy periodically to reflect changes in regulatory statutory guidance, digital
standards, or our operational practices. Any material updates will be clearly reflected by the effective
revision date at the top of this document. Continued interaction with our services signifies acceptance of
the amended terms.
16
Supervisory Authority (ICO) and Contact Desk
If you have questions, concerns, or complaints regarding our data protection practices, we encourage you to
contact our team first:
- Data Protection Officer: DoyleSports Ltd Privacy Office
- Address: 46-48 E Smithfield, London E1W 1AW, United Kingdom
- Email: doylesports@atomicmail.io
You also have the statutory right to lodge a formal complaint with the UK supervisory authority:
- Authority: Information Commissioner's Office (ICO)
- Website: ico.org.uk
- Helpline: 0303 123 1113 (UK)