White Label Partners
Request
One thing that I wanted to clarify. It was noted on two occassions that white label partners are "not transacting with customers". Is there any more you are able to tell me about this? It is the only time I have heard of a business not transacting with customers. As this statement can't be a reflection on these white label partners' customer numbers, does this mean that these white label partners are not permitted to accept customers? If that is so, what is the purpose of their partnership? Is this the same with all white label agreements? Are you able to disclose the relevant clauses in the license around this point?
Response
Thank you for your request which has been processed under the Freedom of Information Act 2000 (FOIA).
In your email you have requested:
One thing that I wanted to clarify. It was noted on two occasions that white label partners are "not transacting with customers". Is there any more you are able to tell me about this? It is the only time I have heard of a business not transacting with customers. As this statement can't be a reflection on these white label partners' customer numbers, does this mean that these white label partners are not permitted to accept customers? If that is so, what is the purpose of their partnership? Is this the same with all white label agreements? Are you able to disclose the relevant clauses in the license around this point?
Transacting with consumers in Great Britain to offer facilities for gambling is an activity reserved by law, for the holder of a gambling licence. In this case facilities for gambling are offered by TGP Europe Limited, which you will be aware are licensed by the Gambling Commission.
White label marketing partners, that do not hold a licence, would be committing an offence under section 33 of the Gambling Act 2005 (opens in a new tab) by engaging with customers directly to offer facilities for gambling. White label partners would have a business-to-business contract with a licensed operator.
Review of the decision
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The ICO can be contacted at: The Information Commissioner’s Office (opens in a new tab), Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.
Information Management Team
Gambling Commission
Victoria Square House
Victoria Square
Birmingham B2 4BP