PRIVACY POLICY

The Company (as defined in the User Agreement applicable to you), offers online gaming service. The company is deeply committed to safeguard the privacy expectations of its users (“User(s)”, “you” or “your”). Accordingly, we have put in place this Privacy Policy, which outlines our data protection practices, including how we collect, use, disclose and protect your Personal Information, as well as your rights with respect to your Personal Information.

In this Privacy Policy, you can learn about:

WHAT INFORMATION WE COLLECT?

CONDITIONS FOR PROCESSING OF PERSONAL INFORMATION

MINORS

HOW WE USE THE COLLECTED INFORMATION?

MARKETING

WITH WHOM WE SHARE INFORMATION?

RETENTION OF PERSONAL INFORMATION

YOUR RIGHTS

HOW WE KEEP YOUR INFORMATION SECURED

CHANGES TO THE PRIVACY POLICY

WHAT INFORMATION WE COLLECT?

We collect two types of information from our Users:

Personal Information.

The first type of information which we collect is information that identifies or may reasonably identify an individual reasonable effort (“Personal Information”). Personal Information which is being gathered may consist of the following:

Account 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 date, personal numeric code, age, physical address, ID number, fiscal code, phone number and occupation. In addition, we may collect certain information as required under various gambling regulations, as well as Know Your Client (“KYC”) and Anti-Money Laundering (“AML”) regulatory requirements, such as your source of funds.

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.

Gaming information: in order for us to provide the Services, we automatically record different information related to your account and use of our Services, including with respect to your transactions, deposits, balances, bets, withdraws, bonuses and winnings. We also collect information regarding potential gambling problems or addictions, based on your patterns of gambling across our services, in order to ensure a responsible gaming environment and as required by law.

Financial 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 currency, credit card number and bank account details.

Voluntary information: We also collect information which you provide us voluntarily, such as information provided by our VIP customers. 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. This includes information you are willing to share with us for the purpose of improving and developing our relationship with you, as well as for maintaining your stratification from our services (for example, information about your marital status and family, your hobbies and interests, and other information you share with us through surveys).

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 and MAC address), browser fingerprinting, IP address and geo-location data.

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

Events: during our events, we conduct interview and take photos and videos, which may feature attendees, speakers, sponsors or exhibitors. Where photos and videos are taken that feature you as an attendee, speaker, sponsor or exhibitor, we may use those photos and videos for promotional purposes. We may also use your interview for promotional purposes (such as by quoting you).

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.

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.

Non-personal Information

The second type of information is un-identified and non-identifiable information pertaining to a User(s), which may be made available or gathered via the User’s use of the Services (“Non-Personal Information”).

Non-Personal Information which is being collected consists of technical information and aggregated usage information, and may contain, among other things, the User’s operating system, type of browser, screen resolution, browser and keyboard language, the User’s ‘click-stream’ and activities on the Services, the period of time the User visited the Services and related time stamps, etc.

For avoidance of doubt, any Non-Personal Information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection or linkage exists.

Types of Non-Personal Information we collect from or about you:

Log-in history and 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.).

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.

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.

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.

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.

CONDITIONS FOR PROCESSING PERSONAL INFORMATION.

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

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 User Agreement) 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.

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.

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.

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, (i) 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).

MINORS.

The Services are not designed or directed to persons under the age of 18 with respect to the use of the Services (“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.

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 unless it is needed to comply with any legal or statutory obligation binding upon us. If you have any reason to believe that a minor has shared any information with us, please contact us (our contact details are available under the "HOW TO CONTACT US?" section).

HOW WE USE THE COLLECTED INFORMATION?

We use your Personal Information for the purposes listed below:

To set up, manage and update your account;

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

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

To determine your VIP status;

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

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);

For customer relationship management purposes, and to support and troubleshoot the Services and to respond to your queries;

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

To provide you with a responsible gaming environment;

To communicate with your and to process any of your requests to exercise your User Rights;

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

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;

To investigate violations of our policies and User Agreement as well as enforce our policies and the User Agreement;

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

To assist us with meeting our regulatory obligations or as required by law or regulation (such as gambling regulations, KYC and AML regulatory requirements), including for the purpose of ascertaining your source of funds or income, or as required by other governmental authorities, or to comply with a subpoena or similar legal process or respond to a government request; and

In addition, we use your Personal Information upon your specific and informed consent, such as for certain marketing and promotional activities.

Where you have not consented (or have withdrawn your consent) to the processing of your Personal Information by us, we may continue to process your Personal Information (a) where processing is required for the performance of the contract (i.e. the User Agreement) between you and us; and/or (b) where processing is necessary for compliance with a legal obligation to which we are subject; (c) where processing is necessary for the purposes of a legitimate interest of the Group (including for marketing).

WITH WHOM WE SHARE INFORMATION?

We do not rent, sell, or share your Personal Information with third parties (“Recipients”) except as described in this Privacy Policy. The Personal Information will be disclosed to Recipients only to the extent required for the specific purpose, as stipulated in this Privacy Policy.

We share Personal Information with any of the following recipients:

Any replacement service provider that we engage with to operate the Platforms;

Companies within the Group and other affiliated companies;

Gaming providers;

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;

Payment service providers, payment processors and banks;

Any third parties who provides services in relation to the operation or promotion of the applicable Group’s brands;

Any third party who provides you with a tangible prize;

Any third parties who organize offline events or tournaments on behalf of or in conjunction with any companies within the Group;

Hotels and flight companies (such as in the context of offline events and promotions);

Auditors, contractors or legal/financial/other advisers of any of the Group’s business processes;

Any third parties who investigate, detect or prevent fraudulent or illegal activity or enable us to enforce our policies, including in order to ascertain your source of income or funds (e.g. governmental authorities, law enforcement bodies, banks and other investigatory bodies);

Gambling addictions bodies;

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

Potential purchasers, successors or investors in any of the companies within the Group, or in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, reorganization, bankruptcy, consolidation or asset sale of an asset or transfer in the operation thereof) in relation to any company within the Group (in such event, the acquiring company or transferee will assume the rights and obligations as described in this Privacy Policy).

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

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

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.);

Performing research, technical diagnostics or analytics;

Communicating targeted advertising, as well as promotional and informational materials, in accordance with our marketing policy (see above, in the section titled "Marketing"); and

Whenever we believe in good faith that disclosure is necessary to protect our rights or legal claims, enforce our policies (including our User Agreement and Privacy Policy), 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.

RETENTION OF PERSONAL INFORMATION.

If you have registered with an account through our Services, the Group will retain your Personal Information during the period your account is active. In addition, the Group will retain your Personal Information for additional periods, as strictly necessary to enable the Group to meet its legal obligations under applicable laws or regulations, such as the applicable gambling regulations, KYC and AML regulations, as well as to meet the Group’s contractual obligations.

In addition, the Group may retain your Personal Information for longer periods, provided that retaining such information is strictly necessary for the Group’s legitimate interests, such as fraud prevention and record keeping, responsible gaming reasons, resolving or exercising claims regarding potential disputes, and where the Group is guided to do so by the applicable supervisory authority.

YOUR RIGHTS.

You may contact us at any time by email (our contact details are available under the "HOW TO CONTACT US?" section), and request:

To access or delete any Personal Information relating to you;

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);

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

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

To object to the processing of your Personal Information (such as for marketing purposes);

To withdraw your consent to our processing activities (provided that such processing activities rely on your consent, and not on a different legal basis);

To not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, except where such processing is necessary for the performance of the contract between you and us, or it is based on your explicit consent, as provided hereunder.

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.

HOW WE KEEP YOUR INFORMATION SECURED.

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:

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

Encrypted communication;

Authentication and Access Control;

External and Internal audit tests; etc.

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.

CHANGES TO THE PRIVACY POLICY.

We reserve the right to change this Privacy Policy at any time, so please re-visit this page frequently. We will provide notice of substantial changes of this Privacy Policy on the Services and/or we will send you an e-mail regarding such changes to the applicable e-mail address that you provided to us. Such substantial changes will take effect fourteen (14) days after such notice was provided on any of the above-mentioned methods. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” date, and your continued use of the Services after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes.