UK: Sponsorship And Gambling In England And Wales In 2007: New Opportunities Or New Pitfalls?

Last Updated: 20 May 2008
Article by Paul Renney and Jona Weber

Originally published in Journal of Sponsorship Vol. 1, No. 2, pp. 194-201

ABSTRACT

The paper discusses the changes introduced by the Gambling Act 2005 to gambling advertising with a particular emphasis on the sponsor's involvement. Now all key parties in any way involved with an advertising campaign are caught by the Act and will need to be aware of its relevant provisions. The effect of the Committee of Advertising Practice and Broadcast Committee of Advertising Practice advertising standard codes, as well as the recent Gambling Industry Code for Socially Responsible Gambling, is assessed in relation to advertising and sponsorship, and new opportunities for gambling operators and brand owners are highlighted. Traps for the unwary are discussed and a sponsorship agreement terms checklist for brand owners and gambling operators is included. Reference to recent Advertising Standards Authority adjudications is made as they provide a useful guide on running advertising campaigns without attracting complaints and the regulator's attention.

INTRODUCTION

Much has been made recently of the new opportunities that the Gambling Act 2005 provides, not just for gambling operators, but for parties on both sides of the sponsorship business and those looking to associate themselves with the more trusted gambling brands. The types of new opportunity being considered concern both access to new markets/customers as well as raising profile and extending business offerings. But behind the hype, what is the true position? How do sponsors, those approached by or those actively looking for sponsors in the gambling business approach the issues?

FIRST, THE BACKGROUND

The Gambling Act 2005 ('the Act'), which came into force fully on 1st September, 2007, seeks to unify and update the existing legislation governing gaming, betting and participating in lotteries, all now coming under the definition of gambling. It is designed to govern all forms of gambling, apart from the National Lottery, and spread betting. The following sectors are therefore now included: casinos, bingo, gaming machines, betting, arcades, lotteries (except the National Lottery) and, for the first time, remote gaming. At its core are three key licensing objectives to ensure that:

  • gambling is fair and transparent;

  • gambling is free from crime;

  • children and other vulnerable people are protected from being harmed or exploited by gambling.

In order to achieve these objectives a new licensing regime regulating gambling has been established, under the auspices of the Gambling Commission ('the Commission'), which has taken over from the previous regulator, the Gaming Board for Great Britain. All gambling operators based here must ensure that they have all the necessary licences in place from the Commission before conducting their operations, as it is unlawful to operate, or to advertise a forthcoming service, without the necessary licences being in place. Responsibility for the regulation of advertising by gambling operators is shared between the Office for Communication (Ofcom), The Secretary of State for the Department of Culture, Media and Sport (DCMS), the Commission, the Committee of Advertising Practice (CAP), the Broadcast Committee of Advertising Practice (BCAP) and the Advertising Standards Authority (ASA).

PREVIOUS PROBLEMS

Before the new gambling advertising rules came into effect on 1st September, 2007, such advertising was regulated by different pieces of legislation, and various broadcast and non-broadcast advertising codes of practice. Inconsistencies between the different sectors of the gambling industry were not uncommon. To give two often-cited examples: bingo clubs and lotteries were generally able to advertise on television, while betting operators and casinos were not, and bookmakers were able to advertise in newspapers, while again casinos were not, other than by a minimal amount of factual information in the classified advertisements, itself the result of a relaxation of the otherwise stringent rules. It was possible for betting operators and casinos to sponsor events, including events shown on television; however, the old legislation was not only piecemeal and inconsistent in its approach, it was also not designed to accommodate the recent rapid changes in technology, especially commercial use of the internet, since its enactment over 40 years ago. While the changes that the Act makes affect the whole of the gambling industry, and those working with it, this paper is focused on certain changes to the gambling advertising rules, with particular regard to the new possibilities and pitfalls in relation to sponsorship agreements.

It should be noted at this point that the Act does not apply to Northern Ireland, where the position remains basically the same as pre-September in England and Wales, although it should also be borne in mind that the CAP code and BCAP code on advertising — both updated with effect from 15th September, 2007 to take account of the liberalisation of gambling advertising by the Act — do still apply in Northern Ireland, therefore specific advice in relation to Northern Ireland should always be sought.

THE EFFECT OF THE ACT ON GAMBLING ADVERTISING

The Act modernises the gambling advertising rules by creating consistency across the industry, and introducing a new definition of advertising in s. 327, which is considerably broader in its application than was previously the case. Now a person can be advertising gambling in three different ways:

  • if he does anything to encourage people to take advantage (directly or indirectly) of facilities for gambling;

  • if he brings information about such facilities to people's attention with a view to increasing the use being made of such facilities;

  • if he takes part in, or facilitates, an activity which either he knows, or believes, to be designed to encourage people to use gambling facilities, or he brings such facilities to people's attention with a view to increasing their use.

To bring such gambling facilities to people's attention with a view to increasing their use includes arrangements where a name is displayed in connection with an event or product, and gambling is either the only or the main activity under that name, or the way the name is displayed has been designed to indicate that gambling is taking place under that name. This means that all the key parties in any way involved in an advertising campaign are caught by the Act. The new definition is clearly intended not only to catch the gambling operator placing an advertisement, but also the media agents working on the advertising campaign, the owner of the media channel over which the advertisement is carried, as well as any venue owner, or promoter, or artist, or other act which becomes involved in a promotion, sponsorship, brand-sharing arrangement etc where the gambling operator gets promoted in association with such an event, match or the like. It can reasonably be expected that the new freedoms on the part of gambling brands (for example, on television advertising) will enable other non-gambling entities to cannibalise sponsorship revenues from this sector and, particularly so, for major sporting brands.

THE ADVERTISING CODES

It is important to note that, in order to comply with the gambling advertising rules, consideration also has to be given not only to the Act itself, but also the CAP and BCAP advertising standard codes (which govern television and radio advertising) as well as the recently agreed, albeit currently voluntary, Gambling Industry Code for Socially Responsible Gambling ('the Industry Code'). Each of these codes has also been updated with effect from 1st September, 2007, to tie in with the Act, following quite extensive public consultation. The respective codes in full should always be considered in devising any gambling advertising strategy, sponsorship and/or campaign, and legal advice should be sought. In a very broad summary, the updated CAP and BCAP codes provide that advertisements must not:

  • portray, condone or encourage gambling behaviour that is socially irresponsible or could lead to financial, social or emotional harm;

  • exploit the susceptibilities, aspirations, credulity, inexperience or lack of knowledge of children, young people or other vulnerable people;

  • suggest that gambling can be a solution to financial concerns;

  • link gambling to seduction, sexual success or enhanced attractiveness or

  • be likely to be of particular appeal to children or young persons, especially by reflecting or being associated with youth culture.

The Industry Code provides for:

  • a ban on all broadcast gambling advertising before the traditional 9pm watershed, except for bingo and lottery advertisements (which were already permitted under the old regime) and sports betting advertising around sports events (this exception, both in the Act and this code, the authors are told, has led in part to the Tote's recent indication of its withdrawal with effect from 2008 from its Channel 4 sponsorship of racing coverage, driven in part by the perhaps greater likelihood of ambush marketing advertisements in the breaks);

  • a ban on all gambling logos on merchandise aimed at children, in particular on children's replica sports kits, which was the subject of a considerable campaign in the press last autumn in the run-up to Christmas. Children's sports kits and other children's merchandise include all those that do not attract VAT.

It also follows from the application of the codes that gambling operators may not sponsor any television and/or radio programmes or stations that are aimed at children or young persons. While a gambling operator is not prevented from sponsoring a television or radio channel which is primarily aimed at adults, but which also features programmes which are aimed at or likely to appeal to children/young persons, the sponsorship may not be advertised during the time when those programmes are aired. The Act defines children as those aged under 16, and young persons as those aged 1617. The only exception appears to be the sponsoring surrounding televised sporting events, which is also exempt from the otherwise applicable 9pm watershed, in accordance with the Industry Code.

Those affected by the gambling industry decision in the self-imposed gambling Industry Code for socially responsible advertising to ban gambling logos on children's replica sports kit, most notably football clubs where such deals were previously worth up to £70m (this was the 2006 offer made to Manchester United by Gibraltar-based betting company Mansion — the club apparently refused the deal because it was unhappy about being associated with gambling), might well find this ban disproportionate, particularly as the Commission's findings following its public consultation in January 2007 showed that the majority of respondents were opposed to it. Thereupon the Commission, in its own position statement, established that removing sponsor branding from children's shirts would not be justifiable and arguably would be counter-productive. Among its reasons was that a ban on official sales would not suppress the desire of children and young persons to wear shirts matching exactly those of the club players and could possibly lead to a black market for shirts bearing the banned logos. It also could be presumed that teenagers would purchase and wear adult shirts. But it required gambling operators to consider excluding their logos from children's replica shirts in any new sponsorship deals.

The gambling industry then proceeded to volunteer a self-imposed ban on children's replica shirts, possibly because it felt it could not refuse after the Portman Group offered a self-imposed ban on the inclusion of alcohol branding on children's replica shirts, and/or possibly because it hoped that the Commission would now not feel the need to regulate further.

THE STATUTORY OFFENCES

The seriousness of compliance, not only with the advertising codes, but also with the Act itself, is to be found in the broad range of offences listed in the Act. The Act gives the Secretary of State the power to make regulations that control the form, content, timing and location of gambling advertisements. At the time of writing (October, 2007), no such regulations have been made, and generally it is hoped that the updated advertising codes, taken together with the Industry Code, will remove the need for such regulations to be put in place. Widespread disregard of the codes by those in the gambling industry, however, would almost certainly result in such regulations being made possibly more restrictive than the current position. This should be checked carefully when any gambling advertising strategy and/or campaign is devised. It would be particularly important to comply with the regulations as noncompliance is an offence punishable by imprisonment for a maximum term of 51 weeks and/or a fine not exceeding level five on the standard scale (which currently stands at £5,000).

Equally punishable is the offence of advertising foreign gambling, other than a lottery which can still be advertised. The content of the advertisement is irrelevant, as the offence is territory specific and attempts to regulate which overseas operators can and cannot advertise their products in Great Britain. Foreign gambling is defined as:

  • non-remote gambling taking place in a non-European Economic Area (EEA) state or outside Gibraltar (ie face to face or gambling on licensed premises);

  • remote gambling (non-face to face) which is not subject to the relevant laws of an EEA state or Gibraltar.

In addition, the Secretary of State has the power to designate a country or place to be treated as if within an EEA state. This is known as the 'White List' and currently includes Alderney and the Isle of Man; Gibraltar is specifically mentioned in the Act as is treated like the EEA. Therefore, and to give a counter-example to the relaxation of the regime, it is now no longer possible for a gambling operator based outside those named territories to sponsor a British-based entity.

While it is certainly important for all the parties involved in an advertising campaign to ensure that both the regulations and the foreign gambling rules are not contravened, the principal statutory offence in relation to advertising gambling is to advertise so-called unlawful gambling. Unless a licence, notice permit, registration or exception to the Act can be relied on, all gambling is classified as unlawful. Again it is punishable by imprisonment for a maximum term of 51 weeks and/or a maximum fine of £5,000.

It is a defence for those parties more loosely associated with promoting or advertising gambling, which could include newspapers, magazines, websites etc that are carrying the advertisements, to show that they did not know, or could not have known that the advertised gambling was unlawful. But no such statutory defence is available to the venue owner or promoter or artist or act which becomes involved in a promotion, sponsorship, brand-sharing arrangement etc. While the gambling rules provide for exciting new business opportunities between gambling operators and other rights holders (discussed below), the latter will need to be aware of how the rule change may affect their liability, and will need to have effective protection built into any agreements preventing contravention of any of the rules unknowingly. (Please note that this paper is not intended to be an exhaustive guide to the statutory offences, the Act should therefore always be consulted in full.)

For gambling operators, there is an additional incentive to comply with the codes, especially the social responsibility parts. The Commission, in the June issue of the Licence Conditions and Codes of Practice document, states specifically that such compliance is a condition of the operator's licence, issued by the Commission; it follows that noncompliance could lead to such licence being withdrawn or not renewed, which is no better way to ensure such matters are taken seriously.

GAMBLING ADVERTISING IN AN INTERNATIONAL CONTEXT

The position in the USA, to say the least, is very confused. While the USA has not outlawed gambling advertising as such, the 2006 enactment of the Unlawful Internet Gambling Enforcement Act 2006 has effectively made online gambling, and thereby its advertisement, unlawful in the USA. While such online gambling may yet be legalised at least partially (the Skill Game Protection Act, which would legalise internet poker, bridge, chess and other games of skill was introduced in June 2007), many online betting providers such as Sportingbet, 888 and Paddy Power have decided to leave the US market for the moment.

Online gambling advertising may create other problems — and not just in the USA. This is because online advertisements might be available outside the jurisdiction (say the UK) for which they were created. While they might comply with UK legislation they might breach applicable laws and regulations (including conduct codes) in other countries. This could entail undesired liability issues. Within the European Union (EU) at least the E-Commerce Directive offers some protection. Under the Directive a company based in the UK only needs to ensure compliance with UK law and regulations, and those of the other member states can effectively be ignored (subject to important exceptions such as the terms of consumer contracts). This protection applies even where the advertised products are sold in such member states. The problem remains that, in certain mainland European territories, France in particular, the current local laws which are intended to preserve local state-controlled monopolies and which are themselves in breach of the free movement of goods and services provisions under the EU treaty are still being enforced against operators based outside those territories who may seek to promote their offerings in such territories. A good example of this was when bwin sponsored the Monaco football team and the directors were arrested when the team launched the sponsorship at a French football ground.

NEW BUSINESS OPPORTUNITIES

The modernisation of the gambling rules results in new permitted forms of advertising, such as perimeter signage at sports grounds by online gaming operators inviting participation in their services, which in turn creates new business opportunities for gambling operators and brand owners. Gambling operators may negotiate access to the brand owners' mailing lists, subject to necessary data protection consents, in order to organise joint marketing activities, such as holding a football club's members' only betting tournament in the club's stadium, organised by the gambling operator, or similar such events. While these new opportunities are exciting news for the industry, brand owners have to be aware that they are now also under a duty to comply with the gambling advertising rules, as discussed above. Gambling operators should be familiar with the rules, individual rights holders may not be.

SPONSORSHIP AGREEMENTS AS OF 1ST SEPTEMBER, 2007

Non-Exhaustive Checklist For Brand Owners/Right Holders

In order to protect their interests under sponsorship agreements entered into after 1st September, 2007, brand owners or other rights holders looking to enter into agreements with gambling operators may want to consider inclusion of the following terms:

  • a warranty from the gambling operator that all the necessary licences have been obtained and will remain valid prior to the launch of and during any advertising campaign;

  • a warranty that the rights holder will be informed immediately should the necessary licences have been revoked, or are threatened to be revoked;

  • a warranty that the gambling operator will comply with the gambling advertising rules including the Industry Code, CAP and BCAP codes;

  • an indemnity from the gambling operator should the rights holder incur any costs in relation to the breach of the advertising rules;

  • a right of prior approval of all advertising campaigns and marketing campaigns which makes reference to the rights holder's products;

  • a notification of, and the rights to participate in, any regulatory complaint or investigation following any complaint to the ASA about a relevant campaign.

Non-Exhaustive Checklist For Gambling Operators

Gambling operators may want to negotiate the incorporation of the following terms within the agreement:

  • access to rights holder's customer/ members mailing list, subject to the necessary data protection consents having been obtained, in order to stage joint or single marketing activities;

  • a right to stage events at the rights holder's grounds for a fixed number of days a year;

  • a general obligation to work on developing suitable joint products;

  • an obligation on the brand owners/rights holders to undertake a certain number of mailings jointly with the operators each year;

  • a first right to renew the arrangements, once the initial term expires, to maximise the value of the relationship;

  • introductions to all other relevant suppliers to the rights holders/brand owners to explore possible affiliate arrangements.

In addition to these, and as pointed out above, gambling operators must take account of the new CAP and BCAP updated sections of their codes and the Industry Code.

THE ASA'S ADJUDICATIONS

It is worth noting the recent ASA investigation of Ladbroke's first television advertising campaign, albeit not directly related to sponsorship arrangements. Once ruled upon it can be taken as a useful guide on running advertising campaigns and sponsorships without attracting the regulator's attention or giving competitors reason to complain to the regulator. Such attention is worthwhile avoiding, because aside from the negative publicity that can result from an adverse adjudication on such a complaint, the ASA can require the advertiser to submit future advertising to them for pre-clearance, or even instruct their members to deny the advertiser media space to run future advertising campaigns. Ladbroke's television advertising campaign starring ex-footballers such as Ian Wright being challenged to 'put his money where his mouth is' by his mates will be the first test case for the new rules and regulations under the Act. The ASA has received four complaints so far and has now launched its investigation. It has been alleged that the advertisement targets young males and, more specifically, 'male bravado and peer pressure'.

CONCLUSION

Potentially, this is a new minefield for many gambling operators which have not been used to advertising or promoting their product in any public space before.

It is also an unknown area for those looking to link up with such operators, with the hope of substantially increasing their business. This is also new law, with no decided rulings or cases to help guide the unwary; ignorance is not a good defence, so taking advice from those more familiar with this space and the new rules makes sense, especially while some of the grey areas remain to be clarified. Opportunities are there for those who can work within the new framework to maximise their return, but pitfalls exist at many turns for those who cannot.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

To print this article, all you need is to be registered on Mondaq.com.

Click to Login as an existing user or Register so you can print this article.

Authors
 
In association with
Related Video
Up-coming Events Search
Tools
Print
Font Size:
Translation
Channels
Mondaq on Twitter
 
Register for Access and our Free Biweekly Alert for
This service is completely free. Access 250,000 archived articles from 100+ countries and get a personalised email twice a week covering developments (and yes, our lawyers like to think you’ve read our Disclaimer).
 
Email Address
Company Name
Password
Confirm Password
Position
Mondaq Topics -- Select your Interests
 Accounting
 Anti-trust
 Commercial
 Compliance
 Consumer
 Criminal
 Employment
 Energy
 Environment
 Family
 Finance
 Government
 Healthcare
 Immigration
 Insolvency
 Insurance
 International
 IP
 Law Performance
 Law Practice
 Litigation
 Media & IT
 Privacy
 Real Estate
 Strategy
 Tax
 Technology
 Transport
 Wealth Mgt
Regions
Africa
Asia
Asia Pacific
Australasia
Canada
Caribbean
Europe
European Union
Latin America
Middle East
U.K.
United States
Worldwide Updates
Check to state you have read and
agree to our Terms and Conditions

Terms & Conditions and Privacy Statement

Mondaq.com (the Website) is owned and managed by Mondaq Ltd and as a user you are granted a non-exclusive, revocable license to access the Website under its terms and conditions of use. Your use of the Website constitutes your agreement to the following terms and conditions of use. Mondaq Ltd may terminate your use of the Website if you are in breach of these terms and conditions or if Mondaq Ltd decides to terminate your license of use for whatever reason.

Use of www.mondaq.com

You may use the Website but are required to register as a user if you wish to read the full text of the content and articles available (the Content). You may not modify, publish, transmit, transfer or sell, reproduce, create derivative works from, distribute, perform, link, display, or in any way exploit any of the Content, in whole or in part, except as expressly permitted in these terms & conditions or with the prior written consent of Mondaq Ltd. You may not use electronic or other means to extract details or information about Mondaq.com’s content, users or contributors in order to offer them any services or products which compete directly or indirectly with Mondaq Ltd’s services and products.

Disclaimer

Mondaq Ltd and/or its respective suppliers make no representations about the suitability of the information contained in the documents and related graphics published on this server for any purpose. All such documents and related graphics are provided "as is" without warranty of any kind. Mondaq Ltd and/or its respective suppliers hereby disclaim all warranties and conditions with regard to this information, including all implied warranties and conditions of merchantability, fitness for a particular purpose, title and non-infringement. In no event shall Mondaq Ltd and/or its respective suppliers be liable for any special, indirect or consequential damages or any damages whatsoever resulting from loss of use, data or profits, whether in an action of contract, negligence or other tortious action, arising out of or in connection with the use or performance of information available from this server.

The documents and related graphics published on this server could include technical inaccuracies or typographical errors. Changes are periodically added to the information herein. Mondaq Ltd and/or its respective suppliers may make improvements and/or changes in the product(s) and/or the program(s) described herein at any time.

Registration

Mondaq Ltd requires you to register and provide information that personally identifies you, including what sort of information you are interested in, for three primary purposes:

  • To allow you to personalize the Mondaq websites you are visiting.
  • To enable features such as password reminder, newsletter alerts, email a colleague, and linking from Mondaq (and its affiliate sites) to your website.
  • To produce demographic feedback for our information providers who provide information free for your use.

Mondaq (and its affiliate sites) do not sell or provide your details to third parties other than information providers. The reason we provide our information providers with this information is so that they can measure the response their articles are receiving and provide you with information about their products and services.

If you do not want us to provide your name and email address you may opt out by clicking here .

If you do not wish to receive any future announcements of products and services offered by Mondaq by clicking here .

Information Collection and Use

We require site users to register with Mondaq (and its affiliate sites) to view the free information on the site. We also collect information from our users at several different points on the websites: this is so that we can customise the sites according to individual usage, provide 'session-aware' functionality, and ensure that content is acquired and developed appropriately. This gives us an overall picture of our user profiles, which in turn shows to our Editorial Contributors the type of person they are reaching by posting articles on Mondaq (and its affiliate sites) – meaning more free content for registered users.

We are only able to provide the material on the Mondaq (and its affiliate sites) site free to site visitors because we can pass on information about the pages that users are viewing and the personal information users provide to us (e.g. email addresses) to reputable contributing firms such as law firms who author those pages. We do not sell or rent information to anyone else other than the authors of those pages, who may change from time to time. Should you wish us not to disclose your details to any of these parties, please tick the box above or tick the box marked "Opt out of Registration Information Disclosure" on the Your Profile page. We and our author organisations may only contact you via email or other means if you allow us to do so. Users can opt out of contact when they register on the site, or send an email to unsubscribe@mondaq.com with “no disclosure” in the subject heading

Mondaq News Alerts

In order to receive Mondaq News Alerts, users have to complete a separate registration form. This is a personalised service where users choose regions and topics of interest and we send it only to those users who have requested it. Users can stop receiving these Alerts by going to the Mondaq News Alerts page and deselecting all interest areas. In the same way users can amend their personal preferences to add or remove subject areas.

Cookies

A cookie is a small text file written to a user’s hard drive that contains an identifying user number. The cookies do not contain any personal information about users. We use the cookie so users do not have to log in every time they use the service and the cookie will automatically expire if you do not visit the Mondaq website (or its affiliate sites) for 12 months. We also use the cookie to personalise a user's experience of the site (for example to show information specific to a user's region). As the Mondaq sites are fully personalised and cookies are essential to its core technology the site will function unpredictably with browsers that do not support cookies - or where cookies are disabled (in these circumstances we advise you to attempt to locate the information you require elsewhere on the web). However if you are concerned about the presence of a Mondaq cookie on your machine you can also choose to expire the cookie immediately (remove it) by selecting the 'Log Off' menu option as the last thing you do when you use the site.

Some of our business partners may use cookies on our site (for example, advertisers). However, we have no access to or control over these cookies and we are not aware of any at present that do so.

Log Files

We use IP addresses to analyse trends, administer the site, track movement, and gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.

Links

This web site contains links to other sites. Please be aware that Mondaq (or its affiliate sites) are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of these third party sites. This privacy statement applies solely to information collected by this Web site.

Surveys & Contests

From time-to-time our site requests information from users via surveys or contests. Participation in these surveys or contests is completely voluntary and the user therefore has a choice whether or not to disclose any information requested. Information requested may include contact information (such as name and delivery address), and demographic information (such as postcode, age level). Contact information will be used to notify the winners and award prizes. Survey information will be used for purposes of monitoring or improving the functionality of the site.

Mail-A-Friend

If a user elects to use our referral service for informing a friend about our site, we ask them for the friend’s name and email address. Mondaq stores this information and may contact the friend to invite them to register with Mondaq, but they will not be contacted more than once. The friend may contact Mondaq to request the removal of this information from our database.

Security

This website takes every reasonable precaution to protect our users’ information. When users submit sensitive information via the website, your information is protected using firewalls and other security technology. If you have any questions about the security at our website, you can send an email to webmaster@mondaq.com.

Correcting/Updating Personal Information

If a user’s personally identifiable information changes (such as postcode), or if a user no longer desires our service, we will endeavour to provide a way to correct, update or remove that user’s personal data provided to us. This can usually be done at the “Your Profile” page or by sending an email to EditorialAdvisor@mondaq.com.

Notification of Changes

If we decide to change our Terms & Conditions or Privacy Policy, we will post those changes on our site so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any point we decide to use personally identifiable information in a manner different from that stated at the time it was collected, we will notify users by way of an email. Users will have a choice as to whether or not we use their information in this different manner. We will use information in accordance with the privacy policy under which the information was collected.

How to contact Mondaq

You can contact us with comments or queries at enquiries@mondaq.com.

If for some reason you believe Mondaq Ltd. has not adhered to these principles, please notify us by e-mail at problems@mondaq.com and we will use commercially reasonable efforts to determine and correct the problem promptly.