Privacy Policy

1. General rules

1. This Privacy Policy gives you an overview of the processing of your personal data in the context when using the Services of our Website, subpages of the Website, and associated domains. Please be reminded that our Services might be embedded on online resources operated by independent third parties using our Services to integrate the gaming applications into their own web offerings on their own websites or applications also including, without limitation, third-party social media platforms and vice versa.

2. This privacy policy also informs you about your legal rights under data protection laws and the possibilities to control your personal data and to protect your privacy.

3. We have taken technical and organizational measures to ensure the security of your personal data.

4. Please note:

1. You are not obliged by law to provide us with the personal data stated in this Privacy Policy. Specifically, the contractual relationship (General Terms) that you have entered into with us by agreeing to our General Terms and Terms of Use does not imply any obligation to provide your personal data.

2. However, the transmission of the personal information provided by you to us is a basic requirement for the conclusion of a contract with us (General Terms). In addition, you may not use the Website and/or Services or only to a limited extent if you do not provide us with certain data or object to the use of this data.

5. The original text of this Privacy Policy is in English and any interpretation of it will be based on the original English text. If the Privacy Policy or any documents or notices related to it are translated into any other language, the original English version will prevail.

2. Which personal data we process and from which sources

1. When we make our Services available to you, we process personal data from various sources. On the one hand, these are data that we automatically process for every visitor when the Website and/or Services are accessed. However, this may also be data that you have voluntarily provided to us or that we receive from our partners or other source. What personal data exactly will be collected will depend on how exactly you as a user access our Services. Please be reminded that, as a matter of principle, Partner Websites will process data as independent data controllers. This means: The explanations provided in this Privacy Policy relate exclusively to the processing of personal data regarding our Services. If you would like to learn more about the privacy practice of the respective Partner Website, please review the Partner Website’s privacy statement.

2. Data that we automatically collect when you use our Services:

1. As soon as you launch one of our Services, you send technical information to our web servers.

2. In any case, we collect the following access and web access data (which we call “Usage Data”):

1. Technical information: In order to enhance the functionality of the Services and to provide you with a better user experience, we collect technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time and the domain name of the website from which you linked to the Services; etc.).

2. Gameplay information: We record game play information including, amongst other things, your deposits, bets, bonuses, game session duration and your high scores. We may also share and publish such information through any of our Platforms.

3. Device and connection information: If you download the Software to your device, we may collect information from the particular device you are using, for security and fraud detection and prevention purposes. For example, we may gather information with regard to other software which is running simultaneously with the Software for detecting if you are using software which is associated with fraudulent activity (e.g. robots, malware, etc.) or checking if the connection you are using is via a VPN or proxy.

4. Analytics information: We collect information about your use of the Services, such as applications' usage, log files, user activity (e.g. pages viewed, the amount of time spent on particular pages, online browsing, clicks, actions, etc.), time stamps, alerts, etc. This information is collected for amongst other things troubleshooting errors and bugs as well as for research and analytics purposes about your use of the Services.

5. Anonymous information: We may anonymize or de-identify the information collected by the Services or via other means so that the information cannot, on its own, personally identify you. Our use and disclosure of such aggregated or de-identified information is not subject to any restrictions under this Privacy Policy, and we may disclose it to others without limitation and for any purpose, such as for advertising or marketing purposes.

3. We process the Usage Data in order to enable you to use the Services and to ensure the functionality of the Website and Services.

4. In addition, we process the Usage Data to analyze the performance of the Services, continuously improve the Services and correct errors or personalize their content for you. However, we also process Usage Data in order to guarantee IT security and the operation of our systems and to prevent or detect misuse, in particular fraud.

5. 'We use cookies and similar technologies for automatic processing of Usage Data. We use our own cookies and similar technologies, but we also use cookies and tracking tools provided by third parties such as advertisement networks, Google and Facebook.

6. While using the Services you may encounter links to third party websites, services or applications. Please keep in mind that this Privacy Policy does not apply to any third-party websites, services or applications, even if they are accessible, downloadable, or otherwise distributed through the Services.

3. Personal Data that you yourself transmit to us, or that we collect ourselves:

1. Registration details: When you open an account and register to use the Services, you will be asked to provide us certain details about yourself, such as: first and last name, email address, gender, birth data, physical address, ID number, phone number, etc.

2. Governmental-issued ID: In certain instances, you will be required to provide a copy of a governmental-issued ID, for identity verification process. Please note that this information is required for certain features of our Services.

3. Payment information: In order for you to enjoy all of the functions of the Services (e.g. place bets, perform purchases, play in tournaments, etc.), payment information will be collected from you, such as your debit card number and bank account details.

4. Voluntary information: We also collect information which you provide us voluntarily. For example, when you respond to communications from us, communicate with us via email or share additional information about yourself through your use of the Services, such as on the chat feature and in games.

5. Device information: We collect specific types of connection details and information with regard to your device, software or hardware that may identify you, such as: device’s unique identifiers (e.g. UDID, IMEI, MAC address), browser fingerprinting, IP address and geo-location data.

6. Telephone calls: We record or monitor telephone calls for customer support, training and/or security purposes.

7. Social networks: When you register through your social network account (such as your Facebook account), to use the Services or connect your player account with such account, we will have access to basic information from your social network account, such as your name, birthdate, profile picture and friends' list, as well as information you made publicly available on such account. In addition, when using the Services, you may be able via your social network to "Invite a Friend" to use the Services. Should the person accept your invitation, we may obtain Personal Information from him/her such as: name, email address, phone number and date of birth. We will use the Personal Information for the purposes set out herein and disclose such information only to third parties as detailed in this Privacy Policy.

8. Feedback, reviews and testimonials: We also collect and display personal testimonials, reviews and feedback of satisfied Users on the Services in addition to other endorsements. With your consent, we may post your testimonial along with your name, on the Services. If you wish to update or delete your testimonial, you can contact us.

9. Information we collect from third parties: We collect Personal Information from third party service providers, such as information about your credit history from credit agencies and other financial information which is relevant to the provision of the Services, as well as information which is gathered in order to verify your identity and prevent fraudulent or illegal activity.

4. We will process your Personal Information for a variety of reasons, each of which is prescribed by relevant data protection laws.

1. Fulfillment of a contract, compliance with a legal obligation It is necessary for us to process your Personal Information where it is necessary for the performance of a contract (such as for the General Terms of Use of the Services) or in order for us to comply with our various legal and/or regulatory responsibilities, including, but not limited to, complying with the conditions of our gambling licenses and complying with any AML and KYC legislation.

2. Legitimate interests: We also process your Personal Information where we deem such processing to be in our (or a third party's) legitimate interests and provided always that such processing will not prejudice your interests, rights and freedoms. Examples of us processing in accordance with legitimate interests would include: (i) where we disclose your Personal Information to any one or more of our associate/subsidiary companies following a restructure or for internal administrative purposes; (ii) detection and retention of information pertaining to those with responsible gambling issues; (iii) processing for the purposes of ensuring network and information security, including preventing unauthorized access to our electronic communications network; (iv) safeguarding the integrity of our Services by combatting, reporting and sharing information related to suspicious betting patterns or fraudulent activities; (v) adhering to regulatory and statutory requirements; (vi) devising a tailored reward scheme for players; and (vii) sharing personal information with our advisers and professional services providers (such as auditors) for ensuring our compliance with regulatory requirements and industry best practices.

3. Consent: Our processing of your Personal Information will primarily be necessary for us to provide you with the Services. However, on certain occasions we may ask for your consent to processing Personal Information. In these instances, your Personal Information will be processed in accordance with such consent and you will be able to withdraw this consent in writing at any time.

4. Special Categories of Personal Data: Our processing of your Personal Information may also involve special categories of personal data, such as your racial or ethnic origin. We will process such information, as well as disclose it to competent authorities (such as licensing bodies or law enforcement bodies), where it is necessary for the following purposes (to the extent permissible by applicable law): (i) prevention or detection of an unlawful act, (ii) prevention of dishonesty, malpractice or other seriously improper conduct, provided that obtaining your consent may prejudice those purposes. In addition, we may process and disclose such information where it is necessary for the purposes of safeguarding your (or others’) economic well-being (such as detection and retention of information pertaining to those with responsible gambling issues).

5. MINORS:

1. The Services are not designed or directed to persons under the age of 18 or persons under the age of legal consent with respect to the use of the Services of any jurisdiction, whichever is higher (“Legally of Age”). If you are not Legally of Age, you should not download or use the Services nor provide any Personal Information to us.

2. We reserve the right to access and verify any Personal Information collected from you. In the event that we become aware that a user who is not Legally of Age has shared any information, we may discard such information. If you have any reason to believe that a minor has shared any information with us, please contact us.

3. The legal basis for processing

1. When processing your personal data, we rely on various legal bases in accordance with the so-called General Data Protection Regulation, an EU-wide legal framework for standardizing data protection laws (“GDPR”).

2. We use your Personal Information for the purposes listed below:

1. To set up, manage and update your account;

2. To provide and operate the Services (such as for betting and payment processing);

3. To communicate with you and to keep you informed of our latest updates to our Services and special offers;

4. To market our Services (see more below under “Marketing”), as well as to serve you advertisements, including behavioral advertising;

5. To promote our Services by displaying Users’ testimonials of our Services. The testimonials are displayed on our Services as well as on websites operated by our affiliates and partners.

6. To conduct analytics, statistical and research purposes, in order to improve and customize the Services to your needs and interests (such as by compiling aggregated reports about the usage of certain features of our Services);

7. For Customer Management purposes, and to support and troubleshoot the Services and to respond to your queries;

8. To enable us to further develop, customize and improve the Services based on Users’ common preferences and uses;

9. To provide you with a responsible gaming environment;

10. To identify and authenticate your access to certain features of the Services;

11. To detect and prevent fraudulent and illegal activity or any other type of activity that may jeopardize or negatively affect the integrity of the Services, including by identifying risks associated with your activity on our Services;

12. To investigate violations of our policies and Terms of Use as well as enforce our policies and the Terms of Use;

13. To investigate and resolve disputes in connection with your use of the Services; and

14. As required by law or regulation (such as Know Your Customer ("KYC") and Anti-Money Laundering regulatory requirements), or as required by other governmental authorities, or to comply with a subpoena or similar legal process or respond to a government request.

4. Marketing

1. Our group will use your Personal Information, such as your name, home address, email address, telephone number etc., ourselves or by using our third party subcontractors for the purpose of providing you with promotional materials, concerning the Services as well as products, services, websites and applications which relate to: other companies within our group; (ii) White Label Brands; or (iii) business partners and affiliates (collectively: “Marketing Affiliates"), which we believe may interest you.

2. We may also share and disclose Personal Information with our Marketing Affiliates for the purpose of providing you different marketing offers, which we, or our Marketing Affiliates, believe are relevant for you, where we have a legitimate interest to do so or where we obtained your consent. Our Marketing Affiliates may use this Personal Information for different marketing techniques, such as direct email, post, SMS and telephone marketing purposes.

3. You may at any time decline receiving further marketing offers from us or from our business partners and marketing affiliates by contacting us. Please note that even if you unsubscribe from our marketing mailing list, we may continue to send you service-related updates and notifications.

4. We will occasionally send you push notifications concerning the Services and products, services, websites and applications which relate to us, as well as to keep you informed of the latest improvements, features and other developments related to the Service. You may opt-out of receiving these types of communications by turning off push notifications at the device level at any time.

5. With whom we share your information

1. We share Personal Information with any of the following recipients:

1. White Label Brands, including any replacement service provider that the White Label Brand may engage to operate the White Label Brands (if applicable;

2. Companies within our group and other affiliated companies;

3. Subcontractors and third-party service providers, as well as their subcontractors, which by way of example include (but is not limited to) cloud computing companies, marketing affiliates, identity verification and fraud prevention services, and other data verifiers;

4. Payment service providers, payment processors and banks;

5. To any third parties who organize offline events or tournaments on behalf of or in conjunction with any companies within our group;

6. To hotels and flight companies (such as in the context of offline events and promotions);

7. Auditors, contractors or advisers of any of our group’s business processes;

8. To any third parties who investigate, detect or prevent fraudulent or illegal activity (e.g. governmental authorities, police, banks and other investigatory organizations);

9. Licensing authorities, governmental and regulatory bodies, in accordance with applicable laws and regulations; and

2. In addition to the purposes listed in this Privacy Policy, we share Personal Information with those Recipients for any of the following purposes:

1. Storing such information on our behalf, for example by using cloud computing service providers;

2. Processing such information to assist us with our business operations (e.g. to process payments and your deposits; authenticate your access; auditing our operations; detect and prevent fraudulent or illegal activity; etc.);

3. Performing research, technical diagnostics or analytics;

4. Communicating targeted advertising, as well as promotional and informational materials, in accordance with our marketing policy; and

5. Whenever we believe in good faith that disclosure is necessary to protect our rights or legal claims, enforce our policies, protect your safety or the safety of others, as well as to investigate or prevent any fraud, for security reasons or to help us with any other related technical issue.

6. Transfer of information

1. Since we operate globally, it may be necessary to transfer your Personal Information to countries outside the country of your residence. The data protection and other laws of these countries may not be as comprehensive as those in the country of your residence.

2. We use best efforts to ensure that your Personal Information is protected in accordance with our privacy policy, through contractual means (such as by using the contractual clauses approved by the relevant regulators for data transfer) or other means (such as ensuring that the jurisdiction imposes adequate safeguards for data protection).

7. Data retention periods

1. We process and store your personal data insofar as this is necessary to fulfil our contractual or legal obligations. Therefore, we store the data for as long as our contractual relationship with you exists and after termination only to the extent and for as long as required by the law. If the remaining data is no longer required to fulfil legal obligations (e.g. in accordance with licensing, tax or commercial law), it will be regularly deleted, unless further processing is necessary to preserve evidence or to defend against legal claims against us. For the preservation of evidence, for example, your IP address and the exact time of issue are required if you have given us your consent (e.g. to receive a newsletter).

8. Information security

1. We take great care in implementing and maintaining the security of the Services and your information. We have put in place appropriate physical and technological safeguards to help prevent unauthorized access, to maintain data security, and to use correctly the information we collect online. These safeguards vary based on the sensitivity of the information that we collect and store. We employ industry standard procedures and controls to ensure the safety of our users’ information, such as:

1. Secure network topology, which includes intrusion prevention and Firewall systems;

2. Encrypted communication;

3. Authentication and Access Control;

4. External and Internal audit tests; etc.

2. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse the Services, and we make no warranty, express, implied or otherwise, that we will prevent such access.

9. Your Rights

1. You may contact us at any time and request:

1. To access or delete any Personal Information relating to you;

2. To change or update any Personal Information relating to you (for example, if you believe that your Personal Information is incorrect, you may ask to have it corrected or deleted). Note that you may also request that we will correct errors with regard to your Personal Information (except in cases where the information is required to be kept in its original format under any applicable laws and regulations);

3. That we will restrict or cease any further use of your Personal Information;

4. That we will provide the Personal Information you volunteered to us in a machine-readable format.

2. Please note that these rights are not absolute and requests are subject to any applicable legal requirements, including gambling regulations and other legal and ethical reporting or document retention obligations. We may also rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion, in accordance with our internal policies.

10. Changes to this Privacy Policy

1. In order to keep this information up to date, this Privacy Policy will be amended if the underlying data processing is changed. We will not limit your rights under this Privacy Policy without your prior written consent. We will publish any intended changes to this privacy statement as long as their content changes and not merely editorial changes (e.g. to correct typing errors) are made.

11. Vulnerabilities found in Websites

1. If you believe you have found a vulnerability in any sub-page of the Website or Service or application, please inform us confidentially support service.

12. COOKIE POLICY

1. When you visit or access our Websites or applications operated by us, or when you interact or engage with our content ("Services"), we use (and authorize third parties to use) web beacons, cookies, pixel tags, scripts, tags, API and other technologies ("Tracking Technologies"). The Tracking Technologies allow us to automatically collect information about you and your online behavior, as well as your device (for example your computer or mobile device), in order to enhance your navigation on our Services, improve our Services performance and customize your experience on our Services. We also use this information to collect statistics about the usage of our Services, perform analytics, deliver content which is tailored to your interests and administer services to our Users, advertisers, publishers, customers and partners.

2. We also allow third parties to collect information about you through Tracking Technologies. What are cookies? Cookies are small text files (composed only of letters and numbers) that a web server places on your computer or mobile device when you visit a webpage. When used, the cookie can help make our Services more user-friendly, for example by remembering your language preferences and settings.

3. Cookies are widely used in order to make websites work in an efficient way. The use of cookies allows you to navigate between pages efficiently. Cookies remember your preferences, and make the interaction between you and the Services smoother and more efficient. Cookies are also used to help ensure that the advertisements you see online are relevant to you and your interests.

4. Storing Tracking Technologies. We store Tracking Technologies when you visit or access our Services (for example when you are visiting our Websites) – these are called "First Party Tracking Technologies". In addition, Tracking Technologies are stored by other third parties (for example our analytics service providers, business partners and advertisers) who run content on our Services – these are called "Third Party Tracking Technologies"

5. Both types of Tracking Technologies may be stored either for the duration of your visit on our Services or for repeat visits.

6. There are five main types of Tracking Technologies:

1. Strictly necessary Tracking Technologies: These Tracking Technologies are essential to enable you to login, navigate around and use the features of our Services, or to provide a service requested by you (such as your username). We do not need to obtain your consent in order to use these Tracking Technologies. These Tracking Technologies can be used for security and integrity reasons - for example to detect violation of our policies and for support or security features.

2. Functionality Tracking Technologies: These Tracking Technologies allow our Services to remember choices you make (such as your language) and provide enhanced and personalized features. For example, these Tracking Technologies are used for authentication (to remember when you are logged-in) and support other features of our Services.

3. Performance Tracking Technologies: These Tracking Technologies collect information about your online activity (for example the duration of your visit on our Services), including behavioral data and content engagement metrics. These Tracking Technologies are used for analytics, research and to perform statistics (based on aggregated information).

4. Marketing or Advertising Tracking Technologies: These Tracking Technologies are used to deliver tailored offers and advertisements to you, based on your derived interests, as well as to perform email marketing campaigns. They can also be used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by our advertisers (for example advertising networks) and provide them insights about the people who see and interact with their ads, visit their websites or use their app.

5. Social media Tracking Technologies: Our website includes social media features, such as the Facebook "Like" or "Share" buttons. These features are either hosted by a third party or hosted directly on our Services. Your interactions with these features are governed by the privacy statement of the company providing these features.

7. Please note that we do not recognize or respond to automated browser signals regarding Tracking Technologies, including "Do Not Track" requests. However, there are various ways in which you can manage and control your cookie settings. Please remember that, by deleting or blocking cookies, some of the features of the Services may not work properly or as effectively:

1. Turning off cookies via your web browser: Most web browsers will provide you with some general information about cookies, enable you to see what cookies are stored on your device, allow you to delete them all or on an individual basis, and enable you to block or allow cookies for all websites or individually selected websites. You can also normally turn off third party cookies separately. Please note that the settings offered by a browser or device often only apply to that particular browser or device.

2. Turning off third party cookies: you can turn off certain third-party cookies for advertising purposes by visiting the Network Advertising Initiative.

13. Cookies