1. Definitions of the Policy
1.1. “cookie” means a small text file stored on your computer or mobile device when you visit a website. It is kept by your browser and sent back to the site on your return, allowing the site to recognise your device so the Provider can monitor activity, offer tailored services and improve usability.
1.2. “consent” of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which they, through a statement or a clear affirmative action, agree to the processing of personal data relating to them.
1.3. “controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of processing personal data; where those purposes and means are set by Union or Member State law, the controller or the criteria for its nomination may be provided for by that law.
1.4. “data subject” means an individual to whom personal data relates.
1.5. “personal data breach” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.
1.6. “personal data” means any information relating to an identified or identifiable natural person; an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or one or more factors specific to their physical, physiological, genetic, mental, economic, cultural or social identity.
1.7. “processing” means any operation or set of operations performed on personal data, whether or not by automated means — such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
1.8. “processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
1.9. “profiling” means any form of automated processing of personal data that uses it to evaluate certain personal aspects of a natural person, in particular to analyse or predict their performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
1.10. “recipient” means a natural or legal person, public authority, agency or other body to which personal data is disclosed, whether a third party or not. Public authorities that may receive personal data within a particular inquiry under Union or Member State law are not regarded as recipients, and their processing of that data must comply with the applicable data-protection rules.
1.11. “restriction of processing” means the marking of stored personal data with the aim of limiting its processing in the future.
1.12. “third party” means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and the persons who, under the direct authority of the controller or processor, are authorised to process personal data.
2. Collection of Personal Data and Information
2.1. The Provider may store and process the following data about the user:
- Email address
- Nickname
- Date of birth
- Sex
- Location data and time zone
- Postal code and address
- Phone number
- Site language (interface) settings
- History of gaming activity
- Behavioural history in the entertainment offered on the Site (games, tournaments, lotteries)
- History of financial transactions
- Financial transaction data
- Any documents and data confirming a payment made by the client
- Data on requests to the support service
2.2. The Provider does not store the user’s credit-card information. The following are exceptions:
- Where the transfer of such data is required by applicable law, the Provider must provide personal information to the relevant authorities, including in response to legal subpoenas and court orders
- Where the user has previously consented to the transfer, including where, within the Provider’s Services, the user was informed that the information provided would be used in that way and supplied the data themselves
- Where the user has breached applicable law or was found by the Provider to be involved in fraud or money laundering
2.3. Processing of personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade-union membership, and the processing of genetic data, biometric data used to uniquely identify a person, data concerning health, and data concerning a person’s sex life or sexual orientation, are prohibited.
2.4. We do not use automated decision-making or profiling to process and use the data subject’s personal data.
3. Collection Purposes
3.1. We collect your personal data only by lawful and fair means, and not in an intrusive way, to operate our business as a licensed Provider, for the following purposes:
- Know-your-customer (KYC) identity verification
- Marketing communications
- Processing your application, maintaining your account, and providing and improving our services to you
- Identifying you and authenticating your identity for security and to meet our legal obligations
- Upgrading and enhancing your experience on the Website
- Providing you with information about our services by email, SMS or telephone
- Responding to your questions, comments or requests
- Complying with our contractual, legal and statutory obligations
- Taking appropriate action where we suspect serious unlawful activity or misconduct relating to our functions and activities
- Establishing, exercising or defending legal claims
- Running and managing our affiliate programme
- Analysing user trends through market-study assessments
- Conducting research and statistical analysis of aggregated data
3.2. From time to time we may use your personal data to tell you about our products, services or promotions, by email, SMS, telephone or mail. If you no longer wish to receive marketing or promotional material from us, in any form, you may contact us at any time by emailing [email protected].
3.3. The Website lets users subscribe to a newsletter. The sign-up form determines the personal data transmitted and records the details provided. To receive the newsletter, the individual must (1) have a valid email address and (2) sign up for delivery. Under a double opt-in process, a confirmation email is sent to the address provided on first registration to verify that the recipient is authorised to receive the newsletter. The Website also stores the IP address assigned by the user’s internet service provider at the time of registration, together with the date and time of registration. The personal data collected at newsletter registration is used solely to send the newsletter.
3.4. We may contact you about the management and administration of your account, through any of the contact methods recorded at registration. Such communication does not affect your opt-in or opt-out status for direct-marketing communications.
3.5. By registering on the Website, you gave us consent to use your personal data for advertising, PR and marketing purposes. Such data includes, without limitation, your name and surname, and any reviews, videos or images you provide (the “Content”). Unless otherwise specified, the Provider may (i) collect, (ii) keep, (iii) systematise, (iv) clarify, (v) depersonalise, and (vi) share with other users on the internet the data received. You confirm that, as a result of the Provider using your Content for these purposes, you will not bring court claims, monetary claims or other negative actions against the Provider that could harm the reputation of the Website or the Provider.
3.6. The controller processes and stores the data subject’s personal data only for as long as necessary to achieve the purpose of storage. Where the purpose no longer applies, or the storage period expires, the personal data is routinely blocked or erased.
4. Rights of the Data Subject
4.1. As a data subject, you have the following rights under the applicable law, which this Policy is designed to uphold:
- To be informed about the collection and use of your personal data
- To access the personal data we hold about you
- To have inaccurate or incomplete personal data we hold about you rectified
- The right to be forgotten — to ask us to delete the personal data we hold (note that some legal obligations, such as Anti-Money Laundering legislation, may prevent us from deleting all or any of it)
- To restrict the processing of your personal data, and to object to our using it for certain purposes, such as marketing
- To data portability — to obtain a copy of your personal data to reuse with another service or organisation; we provide this free of charge unless the request is manifestly unfounded or excessive, in which case a reasonable administration fee may apply
- Certain rights concerning automated decision-making and profiling
4.2. Under the applicable law, the data subject also has the right to complain to a supervisory authority.
5. Cookie Policy
5.1. When you visit the Website, our system automatically collects information about your visit, such as your browser, IP address and the referring website. This may be done together with our platform providers and partners, from whom we may receive general demographic or usage data about our visitors. We do not use automatically collected information to identify you personally without additional consent.
5.2. To collect this information we use cookies and similar tracking tools. Some cookies are essential for the Website to operate; others improve your experience and help us deliver a better service. The types of cookies we use, and their purposes, are set out below.
5.3. Required cookies enable navigation and basic functionality, such as access to members’ areas. Some cookies are needed for technical reasons for the Website to work — for example, on a page refresh, data you entered before the refresh is retrieved from cookies to prevent data loss and provide continuity, especially when filling out forms or entering information.
5.4. Functional cookies let us analyse how you use the Website and the choices you make (such as your session key, language or region) so we can save those settings and offer a more personalised experience.
5.5. Advertising cookies let us measure how effective our content marketing is. They are provided by our partners to track Website visits and new player registrations from advertising. We do not share your personal information (such as your name or email) with affiliated partners, except for on-site-visit data collected directly by these cookies. Your on-site-visit data may, however, be linked by the providers with other personal information they collect from other sources; that external processing is governed by the privacy notices and policies of those third-party providers.
5.6. We also use several third-party service providers that set cookies on this Website to deliver the services they provide to us. These services include, without limitation, improving your experience by tracking your activity on the Website and measuring the effectiveness of the Website and of our marketing campaigns.
5.7. Most browsers accept cookies automatically. If you prefer, you can block some or all cookies, or delete cookies already set, by changing your browser settings (see the help pages of your browser, such as Chrome, Firefox, Safari or Edge). We recommend that you do not block or delete cookies, as this may restrict your use of our Website.
6. Disclosure
6.1. We do not sell or rent your personal data to third parties. We may disclose information we collect about you to affiliated companies and to non-affiliated third parties — including non-financial companies such as service providers and fraud-verification services, and others such as users with whom you transact. We may make such disclosures:
- To service providers that perform services on our behalf, provided a non-disclosure agreement is in place
- For everyday business purposes, such as processing transactions, maintaining accounts, responding to court orders and legal investigations, or reporting to credit bureaus
- Where we are under a duty to disclose or share your information to comply with our legal obligations
- Where we need to disclose or share your information to comply with our contractual relations with our partners, provided such data is securely kept and processed under a non-disclosure agreement
6.2. The third parties that support our customer-identification and anti-fraud controls may retain and use information about you to perform services on our behalf and to improve their own services; by using our Website, you consent to this. We may also share aggregated or de-identified information — which cannot reasonably be used to identify you — with our affiliated companies or non-affiliated third parties.
6.3. We may disclose your personal information to third parties and to legal and regulatory authorities, and may transfer it outside the EEA. It may be processed by a staff member operating outside the EEA who works for us or one of our suppliers, engaged in matters such as fulfilling your order, processing your payment details and providing support. By submitting your personal data, you agree to this transfer, storage and processing. We will take all steps reasonably necessary to ensure your data is treated securely and in accordance with this Policy.
7. Security
7.1. The Provider safeguards the user’s personal information in the following ways:
- By strictly following established security standards when receiving and transmitting data
- By protecting user information with transport-layer encryption — TLS 1.2 — and AES application-layer encryption with a 256-bit key
- By not transferring user data to undefined third parties; the Provider takes effective measures to protect personal data from unauthorised use and makes it available only to parties involved in providing gambling services through the Website, ensuring that such third parties — for example game providers, payment service providers or affiliates — are bound by a non-disclosure agreement and take all necessary steps to keep the data safe
7.2. You are solely responsible for keeping your username, password and any account information secret. Please take care whenever using the internet and our Website.
7.3. In the event of a leak of personal data, or a technical problem causing a failure of the security system that protects data, we will contact and inform the data-protection regulator and the affected data subjects as soon as possible, and in any case within 72 hours of the problem being discovered. We will do our best to prevent such leaks or to minimise the consequences of any leak or security failure that does occur.
8. Contact Us
8.1. If you have any questions about this Policy, please contact us by email at [email protected]. Please make sure your query is clear, particularly where it is a request for information about the personal data we hold about you.