This Privacy Policy is effective from 16th February 2017. We may change this Privacy Policy at any time and will post the changed policy to this page.



1 This Privacy Policy sets out the way in which Virtue Fusion (Alderney) Limited (“we”, “us” or “Virtue Fusion”), a company incorporated and registered in Alderney (company number 1628), collects and processes Personal Information (as defined in paragraph 2 below). Virtue Fusion is registered for the purposes of data protection with the Information Commissioner’s Office in the UK (Registration Reference ZA115640) and the Guernsey Data Protection Commissioner (Notification Number: 57103).

2 We operate the Website under a brand licence from Fraser Capital Management. We will share your Personal Information with Fraser Capital Management in accordance with our agreement with Fraser Capital Management.

3 By using the Services, you acknowledge that you have read, and agree to, the terms of this Privacy Policy and that you consent to the use by us and Fraser Capital Management (and any companies our Group or Fraser Capital Management’s Group, as well as their partners and subcontractors) of your Personal Information for the purposes set out in paragraph 3 of this Privacy Policy. If you do not wish to provide your Personal Information on the basis set out in this Privacy Policy, you should not enter the relevant information on the Website, or provide your Personal Information to us otherwise. However, if you do not provide your Personal Information, you may not be able to use all of the Services.

4 Capitalised terms not defined in this Privacy Policy shall be as defined in the Terms & Conditions. This Privacy Policy is incorporated into, and forms part of, the Terms & Conditions.


The information we collect


1 As part of operating the Website, we collect your Personal Information. “Personal Information” means any information from which you can be personally identified, including (for example) your name, email address, home address, telephone number, debit/credit card data and date of birth.

2 We collect your Personal Information when you register for an Account, through the use of online forms and when you email us your details. We also collect information about the transactions you undertake, including details of payment cards used. In addition, we collect Personal Information through surveys which we, or companies engaged by us for such purpose, undertake.


How we use your Personal Information


1 Your Personal Information is processed by us (including our agents, Group members, sub-contractors and/or employees) to provide you with the Services. In particular, we collect your Personal Information in order to enable us to:

  1. set-up, administer and manage your Account and records (including processing deposits and withdrawals);
  2. provide and personalise the Services (including to allow you to wager and play our games and to provide chat moderation);
  3. receive and respond to your communications and requests;
  4. notify you about updates to the Software and/or the Services;
  5. ensure that we are able to fulfil our regulatory obligations regarding your Account, including by verifying the accuracy of any information you give us;
  6. comply with our obligations under Applicable Laws (including the Gambling Act 2005) and to regulators in jurisdictions where we and members of our Group are licensed (including the Gambling Commission of Great Britain);
  7. investigate, and assist with the investigation of, suspected unlawful, fraudulent or other improper activity connected with the Services (including, where appropriate, dealing with requests from regulatory bodies for the sharing of information);
  8. carry out market research campaigns;
  9. prepare statistics relating to the use of the Services by you and other customers;
  10. provide you with information about, and support for, the Services, including changes to the Services, technical updates and changes to the Terms & Conditions (including this Privacy Policy);
  11. provided that you don’t “opt-out” from this option, keep you informed of offers and promotions relation to our products and services and those of other entities within our Group;
  12. provided that you don’t “opt-out” from this option, enable Fraser Capital Management to market its services and products and those of other entities within its Group; and
  13. support any other purpose necessary for performance of our contractual obligations or specifically stated at the time at which you provided your Personal Information.

2 ­These are the “Purposes” for which we may collect your Personal Information.

3 Telephone calls to and from our customer services representatives may be recorded for training and security purposes.


Disclosure of your Personal Information


1 We may, for the Purposes, disclose your Personal Information to any of the following recipients:

  1. any company within our Group (including to its employees and sub-contractors) which assists us in providing the Services or which otherwise has a need to know such information;
  2. any third party which assists us in providing the Services, including (but not limited to) payment processors and chat moderators;
  3. any third party which can assist us in verifying the accuracy of your Personal Information, including financial institutions and credit reference agencies (a record of the search may be retained by such third party);
  4. any third party which assists us in monitoring use of the Services, including the detection and prevention of fraud and collusion;
  5. Fraser Capital Management;
  6. any contractors or other advisers auditing any of our business processes or who have the need to access such information for the purpose of advising us;
  7. any law enforcement body which may have any reasonable requirement to access your Personal Information ­
  8. any regulatory body which may have any reasonable requirement to access your Personal Information; and
  9. any potential purchaser of Virtue Fusion’s business or any investors in it or in any company within our Group (including in the event of insolvency).

2 If at any time you wish us to stop processing your Personal Information for the above purposes, then you must contact us and we will take the appropriate steps to stop doing so. Please note that this may mean that your Account will be closed.

3 In addition to the above, we may disclose your Personal Information to another company (or another legal entity) if we restructure our business, if there is a sale of all or any part of our business or its assets, or if the operation of this Website (or a replacement website for this Website) is transferred to another company (or other legal entity).


Marketing Preferences


1. We and Fraser Capital Management (and, as relevant, any other company in our Group or Fraser Capital Management’s Group) will not send you unsolicited information regarding any third party’s products or services.

2. As part of the Account registration process, you will have the opportunity to choose whether or not to receive information on our offers and promotions and those of Fraser Capital Management (and any company in our Group or Fraser Capital Management’s Group).

3. We will send you promotional emails and updates until such time as you inform us that you do not wish to continue to receive them. You may update your marketing preferences at any time by: ­

  • clicking on the “unsubscribe” link in an email and following the instructions; or
  • contacting our Customer Services team.


Transfer of your Personal Information outside of the EEA 

Your Personal Information will be transferred outside of the European Economic Area, both to us and other members of our Group. This includes, but is not limited to, Israel, Guernsey and the Philippines.


Updating your Personal Information

You may update or delete your Personal Information at any time via the Website or by contacting Customer Services.


Contacting us


You can contact our Customer Services team at


1 You may obtain a copy of your Personal Information held by us by contacting our Customer Services team or by writing to us at Inchalla, Le Val, Alderney GY9 3UL. We require up to twenty-eight (28) days' notice to enable us to comply with such a request.

2 In accordance with Applicable Law, we reserve the right to charge a fee for providing such information.

3 If at any time you believe that we have not adhered to this Privacy Policy, please contact our Customer Services team and we will seek to promptly determine and correct the problem.



Advertising and use of Cookies


We may collect anonymous information about your use of the Website using “cookies”, pixel tags and similar functionality. A “cookie” is a small file of text which is downloaded onto your computer when you access the Website and it allows us to recognise when you come back to the Website. We use cookies for the operation of the Website, including (for example) to allow you to remain logged in as move between different parts of the Website. We also use cookies for our own analytical purposes so that we can identify where customers have encountered technical problems on the Website, and therefore help us improve our customers' experience.

If you object to cookies or want to delete any cookies that are already stored on your computer, you should follow the instructions for deleting existing cookies and disabling future cookies on your web browser or equivalent software. Further information is available at Please note that by deleting or disabling cookies you may not be able to access certain areas or features of the Website.

We (and any company in our Group) may use your username and/or first name for advertising or promotional purposes.

As part of the Website's operation, and for our own statistical analysis of site traffic, our Website automatically logs internet IP addresses. We do NOT log any e-mail address of visitors to the Website. Our advertising system logs IP addresses to supply more accurate advertising features, such as language-specific banners.

While the Website may contain links to websites operated by parties other than us, we are not responsible for the privacy practices or content of such websites.




1 We use a number of methods to ensure that all customer information remains confidential. Transferred information is sent using advanced encryption methods and, once stored in our servers, is protected by the most up-to-date firewall technology available to protect data from being misused and/or lost.

2 Your Winnings are kept strictly confidential, and winnings information is stored in secure operating environments. We do not provide winnings information to any third party unless such information is required to be disclosed by law, regulation or a similar governmental authority.

3 The Website is protected by industry-standard SSL (Secured Socket Layer) encryption. This technology encrypts all personal data transferred between you and us.