Last updated:
Privacy Policy
This policy explains what personal data Reluctant Gambler collects, why, what the law lets us do with it, how long we keep it, and the rights you have over it. It is written to meet the EU and UK General Data Protection Regulation (GDPR), and it applies wherever you live.
The short version
- This website sets no cookies, runs no analytics, shows no ads, and loads nothing from third parties.
- Our web host keeps standard server logs, which include your IP address, to deliver and protect the site.
- If you email us, we use your email to reply. If you win a giveaway, we use your PayPal email to pay you.
- We never sell your data, use it for advertising, or profile you.
- You can ask to see, correct, or delete your data at any time by emailing us.
Who is responsible for your data
The controller of your personal data is Reluctant Gambler, operator of the Reluctant Gambler YouTube channel and this website, based in Texas, United States.
For anything about your data or this policy, email info@reluctantgambler.com. We haven't appointed a data protection officer because the law doesn't require one for an operation of this size.
What we collect, why, and for how long
Visiting this website
- Data
- Your IP address, the date and time of your visit, the page you asked for, your browser and device type (user agent), and the page that linked you here (referrer).
- Purpose
- Our host's servers record this automatically for every request. It's needed to send you the page and to detect and block abuse, such as attacks or excessive traffic.
- Lawful basis
- Legitimate interests (Art. 6(1)(f)): running a secure, working website. We don't use these logs to identify you, track you, or build a profile.
- Kept for
- Kept by our host for a short period under its own log-retention schedule, then deleted. We don't download, combine, or analyze these logs.
Emailing us
- Data
- Your email address, your name if you include it, and whatever you write to us.
- Purpose
- To read and answer your message and to deal with any follow-up.
- Lawful basis
- Legitimate interests (Art. 6(1)(f)): replying to people who contact us. When your email is about a prize you've won, contract (Art. 6(1)(b)): carrying out the giveaway rules.
- Kept for
- Up to 12 months after our conversation ends, unless the email is part of a prize record (see below).
Entering a live stream giveaway
- Data
- Your YouTube display name and channel, and the chat message you post to enter. These are already public in the stream's live chat.
- Purpose
- To check entries against the giveaway rules (one per person, no bots or duplicate accounts), pick a winner at random, and announce the winner's display name on the stream.
- Lawful basis
- Contract (Art. 6(1)(b)): entering means taking part under the giveaway rules, and we need this data to run the draw.
- Kept for
- We don't keep our own list of entrants after the draw. The chat and the stream recording stay on YouTube, which controls how long they're kept.
Claiming and receiving a prize
- Data
- The email address you claim from, your PayPal email address, your name as it appears on PayPal, your confirmation that you meet the eligibility rules (18 or older, U.S. resident), and a record of the payment (amount, date, PayPal transaction ID).
- Purpose
- To confirm you're eligible, pay your prize, enforce the one-prize-per-30-days limit, and keep the financial records the law requires.
- Lawful basis
- Contract (Art. 6(1)(b)) to verify and pay you. Legitimate interests (Art. 6(1)(f)) to keep payment records for U.S. tax and accounting law, to enforce the giveaway rules, and to handle any dispute.
- Kept for
- Payment records are kept for up to 7 years, the longest period U.S. tax rules can require, then deleted. Your PayPal email is used only to pay your prize.
What we don't do
This site sets no cookies and stores nothing on your device, so there's no cookie banner. It has no analytics, tracking pixels, advertising, social-media widgets, or embedded videos. Its fonts and images are served from our own domain, so visiting it doesn't send your data to Google, YouTube, or anyone else.
We don't sell or rent personal data, share it for advertising, or use it for profiling. We make no decisions about you by automated means that have legal or similarly significant effects (Art. 22). The giveaway winner is chosen by a random draw, which doesn't evaluate anything about you.
Who else handles your data
We only share personal data with the services needed for the activities above:
- Netlify, Inc. (United States) hosts this website and keeps the server logs. It acts as our processor under a data processing agreement. See Netlify's privacy policy.
- Our email provider stores the messages you send us, as our processor.
- PayPal receives your PayPal email and the payment amount when we pay a prize. PayPal is an independent controller of the data it processes for the payment. See PayPal's privacy statement.
- YouTube (Google) runs the live stream and its chat. When you post in chat, YouTube is the controller of that data under its own terms. See Google's privacy policy.
- Authorities, such as tax authorities or courts, only if the law requires it.
International transfers
Reluctant Gambler is run from the United States, so your personal data is processed there. U.S. law may not protect personal data in the same way as the law where you live. Where our service providers move personal data out of the EU, EEA, UK, or Switzerland, they rely on the EU-U.S. Data Privacy Framework (and its UK and Swiss extensions) or on the European Commission's Standard Contractual Clauses. You can ask us for details of these safeguards.
Your rights
Under the GDPR you have the right to:
- Access the personal data we hold about you and get a copy (Art. 15).
- Correct data that's wrong or incomplete (Art. 16).
- Delete your data, unless we must keep it, for example payment records required by tax law (Art. 17).
- Restrict how we use your data while a concern is being resolved (Art. 18).
- Port data you gave us to you or another service, in a common machine-readable format (Art. 20).
- Object to processing based on legitimate interests (Art. 21). We'll stop unless we have compelling legitimate grounds that override your interests, or we need the data to establish, exercise, or defend legal claims.
To use any of these rights, email info@reluctantgambler.com. It's free. We'll reply within one month. If a request is complex, we may extend that by up to two more months and will tell you why. We may ask you to confirm your identity first, for example by emailing from the address the data relates to.
Complaints
Please contact us first so we can try to fix the problem. You also have the right to complain to a data protection supervisory authority, in particular in the country where you live, work, or think the problem happened. In the EU and EEA, see the list of national authorities. In the UK, contact the ICO.
Do you have to give us your data?
No. You can browse this site without giving us anything beyond the technical data every website receives. Emailing us and entering giveaways are optional. If you win, though, we can't pay your prize without a PayPal email address, as the giveaway rules explain.
Age
This site and its giveaways are for adults 18 and over. We don't knowingly collect data from anyone younger. If you think a minor has sent us personal data, email info@reluctantgambler.com and we'll delete it.
Security
The site is served only over HTTPS. We keep the personal data we hold to a minimum, store it in accounts protected by strong passwords and two-factor authentication, and limit access to the person who runs the channel. If a breach puts your rights at risk, we'll notify the relevant authority within 72 hours, and you directly where the law requires.
Links to other sites
This site links to YouTube, the National Council on Problem Gambling, and other sites. Those sites aren't covered by this policy and have their own privacy practices.
Changes to this policy
If we change how we handle personal data, we'll update this page and the date at the top. If a change significantly affects data we already hold about you, and we have your email address, we'll tell you before it takes effect.