Privacy Policy

1. Introduction & Commitment to Privacy

Welcome to our online casino. We are deeply committed to protecting the privacy and security of your personal information. This Privacy Policy outlines our practices regarding the collection, use, processing, and disclosure of your information when you access or use our services, including our website, mobile applications, and any related platforms (collectively, "our service" or "our online casino"). As an online gambling operator, we understand the critical importance of handling your personal data with the utmost care, transparency, and in strict compliance with applicable data protection laws.

Our commitment extends to upholding the highest standards of data protection, ensuring that your privacy is respected and safeguarded at every interaction with our platform. This policy is designed to be clear, comprehensive, and easily understandable, providing you with full transparency about your data rights and how we manage your information. We continually review our privacy practices to ensure they meet, and where possible exceed, the requirements of global data protection regulations, including the General Data Protection Regulation (GDPR) for users in the European Union, the California Consumer Privacy Act (CCPA) for residents of California, and other relevant international data protection laws.

The scope of this policy applies to all users of our service, regardless of their geographical location. By accessing or using our online casino, you acknowledge that you have read, understood, and agree to the terms of this Privacy Policy. If you do not agree with any aspect of this policy, you should refrain from using our services. Your continued use signifies your ongoing agreement to our data processing practices as described herein. We encourage you to read this policy carefully and contact us if you have any questions or concerns regarding your privacy.

This Privacy Policy was Last Updated: January 2025. We may update this policy periodically to reflect changes in our practices or legal obligations, and we encourage you to review it regularly.

2. Information We Collect

To provide you with a secure, enjoyable, and compliant online gaming experience, we collect various types of information. This information helps us to operate our services, manage your account, process transactions, prevent fraud, and comply with our legal and regulatory obligations. The information we collect falls into several categories, detailed below.

2.1 Personal Information

Personal Information, also referred to as Personally Identifiable Information (PII), is data that can be used to identify you directly or indirectly. We collect this information primarily when you register an account, make deposits or withdrawals, participate in promotions, or contact our customer support. The types of personal information we collect include:

• Full Name, Date of Birth, and Gender: Essential for identity verification, age verification (to confirm you are 18 years or older as required by law), and personalizing your account. Your date of birth is crucial for preventing underage gambling and ensuring compliance with responsible gaming regulations.
• Email Address and Phone Number: Used for account registration, communication purposes (e.g., account updates, password resets, security alerts, marketing communications where you have consented), and for facilitating multi-factor authentication. Your email also serves as a primary contact point for customer support.
• Residential Address and Postal Code: Required for identity and location verification, anti-money laundering (AML) checks, and compliance with various regulatory requirements specific to your jurisdiction. This also helps us ensure that we are not offering services in restricted territories.
• Payment Information: When you make financial transactions on our platform, we collect necessary payment details. This may include credit/debit card numbers (typically encrypted and tokenized, not stored in their raw form), bank account details, e-wallet identifiers (e.g., PayPal, Skrill, Neteller accounts), and other payment method details. We process this information securely through PCI DSS compliant payment gateways to facilitate deposits and withdrawals. We do not store full payment card details on our servers; instead, we rely on secure, third-party payment processors who are responsible for the encryption and storage of such sensitive data.
• Identity Verification Documents (KYC Documentation): As part of our Know Your Customer (KYC) and Anti-Money Laundering (AML) obligations, we are legally required to verify your identity. This involves collecting copies of official identification documents such as your passport, national identity card, driving license, or other government-issued photo identification. We may also request proof of address, such as utility bills, bank statements, or other official documents. These documents are used solely for verification purposes, to confirm your age, identity, and residential address, and to prevent fraudulent activities, including identity theft and money laundering.
• Other Identifying Information: This might include a username, password (stored in an encrypted format), security questions and answers, and any other information you provide when setting up your account profile or interacting with our services.

2.2 Automatically Collected Information

When you access and use our service, certain information is collected automatically through technological means. This data helps us to improve our service, ensure technical functionality, and understand user behavior. This includes:

• IP Address: Your Internet Protocol (IP) address is a unique numerical label assigned to your device when it connects to the internet. We use IP addresses to identify your general geographic location, detect potential fraud or unauthorized access, and ensure that our services are available in your region, complying with geo-blocking regulations. It helps us with security monitoring and to protect our systems from malicious activities.
• Browser Type and Version: Information about the web browser you are using (e.g., Chrome, Firefox, Safari) and its version helps us to optimize our website's display and functionality for different browser environments, troubleshoot technical issues, and ensure compatibility.
• Device Information and Operating System: We collect data about the device you use to access our service, such as the device type (e.g., desktop, mobile, tablet), device identifier, and the operating system (e.g., Windows, iOS, Android). This information is vital for ensuring cross-device compatibility, optimizing performance, and diagnosing technical problems unique to certain devices or operating systems. It also aids in fraud prevention by identifying unusual device access patterns.
• Pages Visited and Time Spent: We track which pages you visit on our website, the order in which you visit them, and the duration of your visit on each page. This usage data helps us understand user engagement, identify popular content, and improve the navigation and layout of our platform, thereby enhancing the overall user experience.
• Cookies and Tracking Technologies: We utilize cookies, pixel tags, web beacons, and similar tracking technologies to collect information about your browsing activities. Cookies are small text files stored on your device that allow us to remember your preferences, track your session, analyze website traffic, and deliver personalized content or advertisements. These technologies are crucial for the functionality of our website and for understanding how users interact with our service. A more detailed explanation of our use of cookies is provided in Section 9 of this policy.
• Session Data: This includes information related to your activity during a single visit to our website, such as your login and logout times, the features you use, the settings you select, and other interactions. Session data is used to maintain your login status, manage your gaming sessions, and ensure a seamless user experience.

2.3 Gaming Activity Data

As an online casino, a significant portion of the data we collect relates directly to your gaming activities on our platform. This information is integral to providing our services, managing your account, complying with regulatory requirements, and supporting responsible gaming initiatives.

• Games Played and Bets Placed: We record details of the specific casino games you play (e.g., slots, blackjack, roulette, live casino games) and the amount of money you wager on each game or bet. This data is essential for calculating your winnings and losses, determining your eligibility for bonuses, and providing you with a personalized gaming experience. It also helps us to monitor gameplay for fairness and integrity.
• Wins and Losses: We track the outcomes of your bets and games, including the amounts won and lost. This information is fundamental for managing your account balance, providing accurate financial statements, and fulfilling tax reporting obligations where applicable. It also forms a basis for analyzing your playing patterns, which can be useful for responsible gaming monitoring.
• Account Balance: Your current account balance, including both real money and bonus funds, is continuously updated and stored. This allows you to manage your funds, initiate transactions, and participate in games. It is also critical for our financial reconciliation and regulatory reporting.
• Transaction History: A comprehensive record of all financial transactions associated with your account is maintained. This includes deposits made, withdrawals requested and processed, bonus credits applied, and any fees incurred. This detailed history is vital for financial auditing, dispute resolution, anti-money laundering (AML) compliance, and providing you with a transparent overview of your financial activities on our platform.
• Bonus Usage Patterns: We track your participation in promotions and bonuses, including the types of bonuses claimed, how they are wagered, and your progress towards fulfilling any associated wagering requirements. This data enables us to manage bonus programs effectively, ensure fair play, and personalize future offers. It also helps us to identify and prevent bonus abuse.
• Gameplay Logs: Detailed logs of your interactions within games, including timestamps, actions taken, and game outcomes. These logs are critical for verifying game fairness, resolving disputes regarding game results, and assisting with technical support.
• Chat Logs and Communication within Games: Any communications made through in-game chat features or live casino interactions may be recorded. This is primarily for security purposes, to prevent abusive behavior, address potential collusion, and ensure compliance with our terms of service and responsible gaming policies.

3. How We Use Your Information

The information we collect from you is used for various essential purposes, all aimed at providing you with a secure, efficient, and enjoyable online gaming environment while complying with our legal and regulatory obligations. Our primary uses of your information are categorized as follows:

3.1 Service Provision

The core function of collecting your data is to deliver the services you expect from our online casino. Without this information, we would be unable to provide our platform.

• Account Creation and Management: We use your personal information (e.g., name, email, date of birth) to create and maintain your user account. This includes setting up your profile, allowing you to log in securely, and managing your preferences, balances, and gaming history. Your information ensures that your account is unique to you and securely managed.
• KYC (Know Your Customer) Verification: As part of our regulatory obligations, we use your identity verification documents and personal details to perform KYC checks. This is critical for confirming your identity, age, and address, thereby preventing underage gambling, identity fraud, and account misuse. These checks are fundamental to maintaining a secure and compliant gaming environment.
• Payment Processing (Deposits/Withdrawals): Your payment information and related personal data are processed to facilitate secure and efficient deposits to your account and withdrawals of your winnings. We work with trusted payment processors to ensure that your financial transactions are handled securely and in compliance with financial regulations. This includes processing transactions, issuing refunds, and resolving payment-related queries.
• Customer Support Delivery: When you contact our customer support team, we use your account information and any details you provide to identify you, address your inquiries, resolve technical issues, provide assistance with account management, and handle any complaints or feedback you may have. This ensures that you receive prompt and personalized support.
• Promotional Communications (Opt-in): If you have explicitly given us your consent, we will use your email address, phone number, or other contact details to send you promotional communications about our new games, special offers, bonuses, and other marketing materials that we believe may be of interest to you. You always have the right to withdraw this consent and opt-out of marketing communications at any time.

3.2 Legal Compliance

Operating an online casino involves stringent legal and regulatory requirements. We use your information to ensure we meet these obligations, protecting both our service and our users.

• Anti-Money Laundering (AML) Checks: We are legally mandated to prevent money laundering and terrorist financing. We use your personal information, transaction history, and identity verification documents to conduct ongoing AML checks, monitor for suspicious transactions, and report any relevant activities to the appropriate regulatory authorities as required by law.
• Age and Location Verification: To comply with gambling laws, we must verify that all our users are of legal gambling age (18 or older) and that they are not accessing our services from restricted jurisdictions. Your date of birth, residential address, and IP address are used for these critical verifications.
• Regulatory Reporting: As a licensed operator, we are required to submit various reports to gambling regulatory authorities. These reports may contain aggregated or anonymized data, and in some cases, specific personal and transaction data, to demonstrate our compliance with licensing conditions, responsible gaming mandates, and financial regulations.
• Fraud Prevention and Detection: We employ sophisticated systems and processes to detect and prevent fraudulent activities, including bonus abuse, payment fraud, identity theft, and collusion. We analyze personal information, transaction patterns, device data, and gaming activity to identify suspicious behavior and protect the integrity of our platform and the security of our users' funds.
• Responsible Gaming Monitoring: We are committed to promoting responsible gaming. We use your gaming activity data (e.g., betting patterns, wins/losses, time spent) to monitor for signs of problematic gambling behavior. This enables us to intervene, offer support, apply self-exclusion measures, or direct users to responsible gaming resources in accordance with our policies and regulatory requirements.

3.3 Service Improvement

We continuously strive to enhance your experience on our platform. The data we collect helps us understand how our service is used and identify areas for improvement.

• User Experience Optimization: By analyzing how users interact with our website and games (e.g., pages visited, clicks, time on site), we can identify bottlenecks, popular features, and areas where the user interface or navigation can be improved. This allows us to make data-driven decisions to enhance usability and overall satisfaction.
• Product Development: Insights gained from aggregated and anonymized user data, including game preferences and feature usage, inform our product development roadmap. This helps us introduce new games, features, and functionalities that align with user demand and market trends, creating a more engaging and competitive offering.
• Personalization: We may use your gaming activity, preferences, and demographic information (if provided) to personalize your experience. This could involve recommending games you might enjoy, tailoring bonus offers, or customizing the content displayed on your dashboard, making your interaction with our service more relevant and engaging.
• Market Research and Analysis: We conduct market research and data analysis to understand broad user trends, preferences, and demographic patterns. This may involve using aggregated and anonymized data to gain insights into our target audience, identify market opportunities, and assess the effectiveness of our marketing campaigns. This helps us refine our strategies and offerings.
• Analytics: We use various analytics tools to measure website traffic, user engagement, and performance metrics. This data provides insights into how our service is performing, identifies areas for technical optimization, and helps us understand the effectiveness of different aspects of our platform. This often involves the use of cookies and other tracking technologies as detailed in Section 9.

4. Legal Basis for Processing (GDPR)

Under the General Data Protection Regulation (GDPR) and similar data protection laws, we are required to have a valid legal basis for processing your personal data. We rely on several legal bases, depending on the specific purpose for which we are processing your information.

4.1 Contractual Necessity

This legal basis applies when the processing of your personal data is necessary for the performance of a contract to which you are a party, or in order to take steps at your request prior to entering into a contract. For our online casino, this primarily relates to the provision of our services as outlined in our Terms & Conditions.

• Performance of Terms & Conditions: When you register an account and agree to our Terms & Conditions, you enter into a contract with us. Processing your personal data is essential for us to fulfill our obligations under this contract. This includes:
  • Creating and managing your account.
  • Processing your deposits and withdrawals.
  • Allowing you to participate in games and place bets.
  • Calculating and awarding winnings.
  • Providing customer support related to your account and transactions.
  • Communicating with you about service-related matters, such as important updates, security alerts, and changes to our terms.
  • Delivering specific features and functionalities that form part of the gaming service you expect.
  • Ensuring the integrity of the games and fair play, which is a fundamental aspect of the contractual agreement.
  • Resolving disputes that may arise in connection with your use of our service.

Without processing your data under this legal basis, we would be unable to provide the core services of our online casino.

4.2 Legal Obligation

We are subject to various legal and regulatory obligations that require us to process certain personal data. Where processing is necessary for compliance with a legal obligation to which we are subject, this legal basis applies.

• Compliance with Gambling Regulations: As a licensed online gambling operator, we are governed by specific laws and regulations in the jurisdictions where we operate. These regulations impose strict requirements regarding customer identification, transaction monitoring, and responsible gaming. Processing data is necessary to comply with:
  • Licensing requirements set by gambling authorities.
  • Reporting obligations to regulatory bodies.
  • Age verification laws to prevent underage gambling.
  • Geo-blocking requirements to restrict access from prohibited jurisdictions.
• Anti-Money Laundering (AML) and Know Your Customer (KYC) Requirements: We are legally required to prevent money laundering and terrorist financing. This involves:
  • Collecting and verifying identity documentation (KYC checks) to establish your identity.
  • Monitoring transaction patterns for suspicious activities.
  • Reporting suspicious transactions to financial intelligence units or other relevant authorities.
  • Maintaining records of customer identification and transactions for specified periods.
• Fraud Prevention and Detection: While also falling under legitimate interests, certain aspects of fraud prevention are mandated by legal requirements to protect financial systems and consumers. We process data to:
  • Detect and investigate fraudulent activities, including identity theft, payment fraud, and bonus abuse.
  • Cooperate with law enforcement agencies in investigations where legally compelled.
• Tax and Accounting Obligations: We are legally required to maintain financial records and report on financial activities to tax authorities. This includes processing data related to your deposits, withdrawals, and winnings.
• Responsible Gaming Obligations: Regulations often mandate that we implement measures to identify and assist individuals who may be experiencing gambling-related harm. This involves processing data related to your gaming behavior to monitor for signs of problem gambling, apply self-exclusion, and provide information on support services.
• Requests from Law Enforcement and Judicial Authorities: We are legally obliged to respond to valid requests for information from law enforcement, regulatory bodies, or court orders.

4.3 Legitimate Interests

We may process your personal data where it is necessary for our legitimate interests or the legitimate interests of a third party, provided that these interests are not overridden by your fundamental rights and freedoms. When we rely on legitimate interests, we conduct a balancing test to ensure that the processing is proportionate and that your privacy rights are protected.

• Service Improvement and Optimization: To enhance your experience, ensure the stability of our platform, and develop new features, we process data for:
  • Analyzing user behavior to understand how our services are used and identifying areas for improvement (e.g., website analytics, A/B testing).
  • Conducting internal research and development to improve our games, services, and technologies.
  • Personalizing your user experience and tailoring content or offers based on your preferences, without relying on consent for the core personalization activity itself if it’s an intrinsic part of the service provided.
• Fraud Prevention (beyond legal obligation): Beyond what is legally mandated, we have a legitimate interest in preventing fraud, security breaches, and other illegal activities to protect our business, our systems, and our customers. This includes:
  • Implementing security measures to protect our systems and data from unauthorized access or cyber threats.
  • Monitoring accounts for suspicious or unusual activity that could indicate fraud or abuse.
  • Investigating and responding to security incidents.
• Network and Information Security: We have a legitimate interest in ensuring the security of our network and information systems. This involves processing technical data to:
  • Detect and prevent malicious attacks, viruses, and unauthorized access.
  • Troubleshoot technical issues and maintain system performance.
• Business Operations and Management: We process data to efficiently run our business, including:
  • Administering and managing our internal operations, such as accounting, financial management, and reporting.
  • Enforcing our Terms & Conditions and other policies to maintain a fair and safe environment for all users.
  • Managing and maintaining our IT infrastructure.
  • Analyzing business performance to make informed strategic decisions.
• Marketing (Non-Consent Based): In some jurisdictions, and under specific conditions, we may have a legitimate interest in sending direct marketing communications to existing customers regarding similar products or services, especially if you have an active relationship with us and have not opted out. This is strictly managed and always subject to your right to object.

4.4 Consent

In specific situations, we will ask for your explicit consent before processing your personal data. Where consent is the legal basis, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

• Marketing Communications: We will only send you promotional emails, SMS messages, or other direct marketing communications about our new games, bonuses, or special offers if you have explicitly opted-in and given us your consent to do so. This applies particularly to new customers or for certain types of marketing channels.
• Non-Essential Cookies and Tracking Technologies: While essential cookies are processed under legitimate interests or contractual necessity, we will seek your consent for the use of non-essential cookies and similar tracking technologies (e.g., performance, functional, and marketing cookies) that are not strictly necessary for the operation of our website but enhance your experience or help us with analytics and advertising.
• Specific Data Uses: In certain other limited circumstances, we may request your specific consent for a particular processing activity that does not fall under contractual necessity, legal obligation, or legitimate interests. We will clearly explain the purpose of the data processing when we ask for your consent.

You can manage your consent preferences, particularly for marketing communications and cookies, through your account settings or by following the instructions provided in our communications or cookie policy.

5. Data Sharing and Disclosure

We understand that the sharing of your personal data is a significant concern. We are committed to minimizing data sharing and ensuring that when we do share information, it is done securely, lawfully, and only for legitimate purposes necessary for the provision of our services and compliance with our obligations. We do not sell your personal data to third parties.

5.1 Third-Party Service Providers

To operate our online casino effectively and provide you with a comprehensive service, we engage various third-party service providers who perform functions on our behalf. These providers are carefully selected, contractually bound to protect your data, and only permitted to use your information for the specific purposes for which it was shared. They act as data processors, operating under our strict instructions.

• Payment Processors: To facilitate secure deposits and withdrawals, we share necessary financial information with reputable payment gateways and financial institutions. These entities are responsible for processing your transactions securely and are typically PCI DSS compliant. They receive information such as your name, payment method details (e.g., truncated card number, e-wallet ID), and transaction amounts.
• Identity Verification Services: To fulfill our KYC and AML obligations, we utilize third-party identity verification services. We share your personal details (name, date of birth, address) and copies of your identity documents (e.g., passport, driving license, utility bills) with these providers to authenticate your identity, age, and address, and to screen against sanctions lists and politically exposed persons (PEP) databases.
• Customer Support Platforms: We may use external platforms to manage and deliver our customer support services, including live chat, email support, and ticketing systems. When you interact with our support team, your inquiries, account details, and contact information may be processed by these third-party systems to ensure efficient resolution of your issues.
• Analytics Providers: We employ analytics services (e.g., Google Analytics) to understand how users interact with our website, track performance metrics, and gather insights for service improvement. These providers collect anonymized or pseudonymized data about your browsing behavior, device information, and IP address (often truncated or anonymized) to generate reports on website traffic and usage.
• Marketing Services (Consent-Based): If you have provided explicit consent for marketing communications, we may share your contact information (e.g., email address) with third-party marketing platforms or advertising partners to deliver personalized promotional offers and information about our services. These partners are strictly limited to using your data for the purposes for which consent was given and must adhere to unsubscribe requests.
• Cloud Hosting and Infrastructure Providers: Our services rely on robust cloud infrastructure. We may store your data on servers provided by reputable cloud hosting companies who are responsible for the physical and environmental security of the data centers. Access to data within these environments is strictly controlled by us.
• Fraud Prevention and Security Services: We partner with specialized providers that offer tools and services for advanced fraud detection, anti-collusion monitoring, and cybersecurity. These providers may receive anonymized data, IP addresses, device fingerprints, and transaction patterns to help identify and mitigate security risks.
• Game Providers: When you play games developed by third-party studios on our platform, certain data (such as your unique player ID, balance, and game outcomes) may be shared with the game provider to ensure fair play, record game progress, and resolve any game-related technical issues.

5.2 Legal Requirements

We may disclose your personal data when we believe it is necessary to comply with a legal obligation, protect our rights, or ensure the safety of our users.

• Law Enforcement: We may disclose your information to law enforcement agencies or other governmental bodies if required by law, in response to a subpoena, court order, or other legal process. This includes cooperating with investigations related to criminal activities, fraud, or violations of law.
• Regulatory Authorities: As a licensed online casino, we are subject to oversight by gambling regulatory bodies. We may be required to share your personal data, transaction history, or gaming activity with these authorities to demonstrate compliance with our licensing conditions, responsible gaming mandates, or anti-money laundering regulations.
• Court Orders and Legal Proceedings: In the event of litigation or other legal proceedings, we may be compelled to disclose your information to courts, tribunals, or other parties involved in the legal process, as required by applicable law or judicial order.
• Protecting Our Rights and Safety: We may disclose your information when we believe it is necessary to investigate, prevent, or take action regarding potential violations of our Terms & Conditions, suspected fraud, situations involving potential threats to the physical safety of any person, or as evidence in litigation in which we are involved. This also extends to protecting our intellectual property rights and ensuring the security of our platform.

5.3 Business Transfers

In the event that we are involved in a merger, acquisition, reorganization, sale of assets, or bankruptcy, your personal data may be transferred as part of that transaction. We will notify you via email and/or a prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information. In such cases, the acquiring entity will be bound by the commitments in this Privacy Policy unless otherwise communicated to you.

6. Data Security

The security of your personal data is paramount to us. We implement robust technical, administrative, and physical security measures designed to protect your information from unauthorized access, disclosure, alteration, and destruction. Our commitment to data security is integral to our operations, and we continually review and update our security protocols to adapt to evolving threats and technologies.

6.1 Security Measures

We employ a multi-layered approach to security, integrating industry-standard practices and technologies to safeguard your data at all stages of its lifecycle:

• SSL/TLS Encryption: All communications between your device and our servers, including login credentials, financial transactions, and personal data submissions, are encrypted using Secure Socket Layer (SSL) or Transport Layer Security (TLS) technology. This ensures that data transmitted over the internet is protected from interception by unauthorized parties.
• Encrypted Data Storage: Your personal data, especially sensitive information like identity documents and parts of your payment information (e.g., hashed passwords, tokenized card details), is stored in encrypted databases. This means that even if unauthorized access to our storage systems were gained, the data would be unreadable without the decryption key.
• Secure Payment Processing: We do not directly store full credit card details on our servers. Instead, we utilize PCI DSS (Payment Card Industry Data Security Standard) compliant third-party payment processors. These processors are specifically designed to handle sensitive payment information securely, employing their own advanced encryption and security protocols to protect your financial data during transactions.
• Regular Security Audits and Penetration Testing: We engage independent security experts to conduct regular security audits, vulnerability assessments, and penetration tests of our systems and applications. These proactive measures help us identify and address potential weaknesses or vulnerabilities before they can be exploited.
• Access Controls: Access to your personal data within our organization is strictly limited on a "need-to-know" basis. Only authorized employees who require access to perform their job functions (e.g., customer support, compliance, IT) are granted access. All access is logged and monitored for unusual activity.
• Firewall Protection: Our network infrastructure is protected by advanced firewall systems that prevent unauthorized access to our internal systems and databases. These firewalls filter incoming and outgoing network traffic, blocking suspicious connections and malicious data packets.
• Multi-Factor Authentication (MFA): Where feasible and appropriate, we implement multi-factor authentication for accessing sensitive internal systems and, where offered, for user accounts. MFA adds an extra layer of security by requiring more than one method of verification (e.g., password plus a code from a mobile device) to confirm identity.
• Data Minimization: We adhere to the principle of data minimization, meaning we only collect and retain personal data that is strictly necessary for the purposes for which it is processed. This reduces the amount of data at risk in the unlikely event of a breach.
• Employee Training: Our employees receive regular training on data protection, privacy best practices, and security protocols. They are educated on their responsibilities in handling personal data and the importance of maintaining confidentiality.
• Incident Response Plan: We have a comprehensive incident response plan in place to effectively manage and address any potential data breaches or security incidents. This plan includes procedures for detection, containment, eradication, recovery, and notification to affected individuals and regulatory authorities, where legally required.
• Physical Security: Our data centers and server environments, whether owned or managed by third-party hosting providers, are subject to stringent physical security measures, including restricted access, surveillance, and environmental controls, to protect the hardware where your data resides.

While we strive to use commercially acceptable means to protect your personal information, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee its absolute security. We encourage you to also take steps to protect your account, such as using strong, unique passwords, not sharing your login credentials, and logging out of your account after each session, especially when using public or shared computers.

7. Data Retention

We retain your personal data only for as long as is necessary to fulfill the purposes for which it was collected, including for the purpose of satisfying any legal, accounting, or reporting requirements. Our data retention policy is designed to comply with applicable data protection laws, including GDPR, and specific industry regulations related to online gambling and anti-money laundering.

7.1 Active Accounts

While your account with our online casino is active, we will retain your personal data for the duration of your contractual relationship with us. This is necessary to:

• Provide you with our services: To allow you to log in, play games, process transactions, and access customer support.
• Maintain your account history: Including your gaming activity, transaction records, and bonus usage, which is essential for both your access to historical data and our operational needs.
• Ensure ongoing legal and regulatory compliance: Such as continuous KYC and AML monitoring, age verification, and responsible gaming checks.
• Support legitimate business interests: Including fraud prevention, security, and service improvement.

During this period, all data collected and processed will be subject to the security measures and data protection principles outlined in this policy.

7.2 Closed Accounts

Even after you choose to close your account or if your account is terminated by us in accordance with our Terms & Conditions, we are legally obliged to retain certain personal data for a specified period. This post-closure retention is crucial for several reasons:

• Legal and Regulatory Compliance Requirements (5-7 years typical):
  • Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Laws: Gambling regulations often mandate that operators retain customer identification data, transaction records, and communication relating to financial activities for a minimum period, typically five (5) to seven (7) years after the business relationship has ended. This is critical for preventing and detecting financial crimes.
  • Gambling Licensing Obligations: Our licenses require us to maintain records for a certain period to demonstrate compliance with responsible gaming measures, age verification, and other operational standards.
  • Tax and Accounting Laws: Financial records, including details of your deposits, withdrawals, and winnings, must be retained for periods specified by tax authorities and accounting standards, which can also extend up to seven (7) years or more in some jurisdictions.
  • Regulatory Reporting: We may need to provide historical data to regulatory bodies for audits or investigations, even after an account is closed.
• Fraud Prevention Needs: Retaining data from closed accounts helps us to:
  • Prevent re-registration by individuals who have previously engaged in fraudulent activities, bonus abuse, or other violations of our Terms & Conditions.
  • Detect patterns of fraudulent behavior that may span multiple accounts or involve individuals attempting to circumvent our security measures.
  • Protect other users and our platform from financial harm.
• Dispute Resolution: In the event of a dispute or legal claim arising from your past use of our services, we may need to retain relevant data to establish, exercise, or defend our legal rights. This includes records of your account activity, communications, and transaction history.
• Responsible Gaming Measures: If you have self-excluded from our service or have been identified as a problem gambler, we are legally and ethically obligated to retain information about your exclusion for a period that ensures we can prevent you from re-opening an account or accessing our services during the exclusion period. This data is critical for upholding responsible gaming commitments.

Once the applicable retention period expires, your personal data will be securely deleted, anonymized, or aggregated in such a way that it can no longer identify you. We conduct regular reviews of our data to ensure that we are not holding onto information for longer than is necessary.

8. Your Rights (GDPR & Data Protection)

Under GDPR and other comprehensive data protection laws (such as CCPA, subject to specific applicability for California residents), you, as the data subject, have specific rights concerning your personal data. We are committed to facilitating the exercise of these rights and providing you with mechanisms to manage your privacy effectively.

8.1 Right to Access (Right of Access)

You have the right to request a copy of the personal data that we hold about you. This is often referred to as a "Data Subject Access Request" (DSAR). Upon receiving a valid request, we will provide you with:

• Confirmation that your data is being processed.
• A copy of your personal data we are processing.
• Information about the purposes of the processing.
• The categories of personal data concerned.
• The recipients or categories of recipients to whom the personal data has been or will be disclosed.
• The envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period.
• The existence of the right to request rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing.
• The right to lodge a complaint with a supervisory authority.
• Information about the source of the data if it was not collected directly from you.
• The existence of automated decision-making, including profiling, and meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

We aim to respond to all legitimate requests within one month. If the request is complex or numerous, it may take us longer, in which case we will notify you and keep you updated.

8.2 Right to Rectification (Right to Correction)

You have the right to request that we correct any inaccurate or incomplete personal data we hold about you. If you believe any of the information we have about you is incorrect, please contact us immediately. We will take reasonable steps to verify the accuracy and, where appropriate, correct the data without undue delay. You may also be able to update certain information directly through your account settings.

8.3 Right to Erasure ("Right to be Forgotten")

You have the right to request the deletion or removal of your personal data where there is no compelling reason for its continued processing. This right applies in specific circumstances, such as:

• The personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed.
• You withdraw consent on which the processing is based, and there is no other legal ground for the processing.
• You object to the processing, and there are no overriding legitimate grounds for the processing.
• The personal data has been unlawfully processed.
• The personal data has to be erased for compliance with a legal obligation.

However, this right is not absolute and is subject to certain limitations. We may refuse your request for erasure if the processing is necessary for:

• Compliance with a legal obligation (e.g., AML, responsible gaming, tax laws which require data retention).
• The establishment, exercise, or defense of legal claims.
• Reasons of public interest in the area of public health.
• Archiving purposes in the public interest, scientific or historical research purposes or statistical purposes where erasure is likely to render impossible or seriously impair the achievement of that processing.
• Exercising the right of freedom of expression and information.

Given the stringent regulatory requirements for online gambling operators, particularly concerning AML, responsible gaming, and fraud prevention, it may not always be possible to fully erase all your data immediately upon request. We will inform you of any such limitations and the reasons for them.

8.4 Right to Restriction of Processing

You have the right to request that we restrict or suppress the processing of your personal data in certain circumstances. When processing is restricted, we are permitted to store your personal data, but not to use it. This right applies when:

• You contest the accuracy of your personal data, for a period enabling us to verify the accuracy of the personal data.
• The processing is unlawful, and you oppose the erasure of the personal data and request the restriction of its use instead.
• We no longer need the personal data for the purposes of the processing, but you require them for the establishment, exercise, or defense of legal claims.
• You have objected to processing based on legitimate interests, pending the verification whether our legitimate grounds override yours.

8.5 Right to Data Portability

You have the right to receive your personal data, which you have provided to us, in a structured, commonly used, and machine-readable format, and you have the right to transmit that data to another controller without hindrance from us. This right applies only to:

• Personal data you have provided to us directly.
• Processing carried out by automated means.
• Processing based on your consent or for the performance of a contract.

This enables you to move, copy, or transfer your personal data easily from one IT environment to another.

8.6 Right to Object

You have the right to object to the processing of your personal data where we are relying on legitimate interests as the legal basis for processing, or for direct marketing purposes.

• Objection to Legitimate Interests: If you object to processing based on our legitimate interests, we will stop processing your data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or for the establishment, exercise, or defense of legal claims.
• Objection to Direct Marketing: You have an absolute right to object to the processing of your personal data for direct marketing purposes. If you object, we will cease processing your data for this purpose immediately. This includes profiling to the extent that it is related to such direct marketing. You can exercise this right by opting out through your account settings or by clicking the "unsubscribe" link in any marketing email.

8.7 Right to Withdraw Consent

Where we rely on your consent as the legal basis for processing your personal data, you have the right to withdraw that consent at any time. Withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.

• If you withdraw your consent for marketing communications, we will stop sending you promotional materials.
• If you withdraw consent for certain non-essential cookies, your browsing experience may be affected, but you can continue to use our essential services.

To withdraw consent, you can use the mechanisms provided (e.g., unsubscribe links, account settings) or contact our customer support.

8.8 Rights in Relation to Automated Decision-Making and Profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, unless certain exceptions apply (e.g., it is necessary for entering into, or performance of, a contract between you and us, or based on your explicit consent). In such cases, you have the right to obtain human intervention, express your point of view, and contest the decision. This is further elaborated in Section 16.

8.9 Right to Lodge a Complaint

If you are unsatisfied with our handling of your personal data or believe that we have breached your data protection rights, you have the right to lodge a complaint with the relevant data protection supervisory authority in your country of residence (if in the EU/EEA) or with the Data Protection Officer (DPO) designated for our service. We encourage you to contact us first so we can attempt to resolve any concerns you may have directly.

To exercise any of these rights, please refer to Section 14 (Contact Information) of this Privacy Policy for details on how to get in touch with us. We may require specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

9. Cookies and Tracking Technologies

Our website and online casino services use "cookies" and similar tracking technologies to enhance your user experience, analyze site usage, and support our marketing efforts. This section provides detailed information about what cookies are, the types we use, and how you can manage your preferences.

9.1 What Are Cookies

Cookies are small text files that are downloaded to your computer or mobile device when you visit a website. They contain information that can be read by the website that set the cookie (first-party cookies) or by a third party (third-party cookies). Cookies serve various functions, such as remembering your preferences, enabling secure login, tracking your activity across sites for analytics, or serving personalized advertisements. They do not typically contain personally identifiable information themselves, but they can be linked to personal information we hold about you if you have registered an account.

9.2 Types of Cookies

We utilize different types of cookies to operate and improve our service:

• Essential Cookies (Strictly Necessary Cookies): These cookies are fundamental for the basic functionality of our website and online casino. They enable core features such as secure login, account management, transactional processes (deposits/withdrawals), and ensuring the security of your session. Without these cookies, our services would not function correctly, and you would not be able to use features like placing bets or accessing your account. These cookies do not store any personally identifiable information directly and are always active. We do not require your consent for these cookies as they are necessary for the performance of our contract with you.
• Performance Cookies (Analytics Cookies): These cookies collect information about how visitors use our website, such as which pages are visited most often, the duration of visits, and if users encounter error messages. This data is aggregated and largely anonymous, used solely to help us understand and improve the performance and usability of our website and services. For example, they help us to identify popular content, troubleshoot technical issues, and ensure that our platform is performing efficiently. We typically seek your consent for these cookies.
• Functional Cookies (Preference Cookies): Functional cookies allow our website to remember choices you make (such as your username, language preference, or region) and provide enhanced, more personal features. For example, they can remember your display settings, last played games, or preferred currency. These cookies help us tailor your experience to make it more convenient and personalized. If you disable these cookies, some functionalities may be affected. We typically seek your consent for these cookies.
• Marketing Cookies (Targeting/Advertising Cookies): These cookies are used to deliver advertisements more relevant to you and your interests. They are often placed by third-party advertising networks with our permission. They remember that you have visited our website and this information may be shared with other organizations, such as advertisers. This means that after you have been to our website, you may see advertisements about our services elsewhere on the internet. These cookies also help us measure the effectiveness of our advertising campaigns. We always require your explicit consent before placing marketing cookies on your device.

9.3 Cookie Management

You have control over the use of cookies. Most web browsers allow you to manage your cookie preferences.

• Browser Settings Control: You can typically configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is being sent. The settings are usually found in the "options" or "preferences" menu of your browser. For mobile devices, settings are often available within the operating system or application preferences. Please refer to your browser's help section for specific instructions.
• Cookie Consent Banner: Upon your first visit to our website, you will be presented with a cookie consent banner that allows you to accept or decline different categories of non-essential cookies. You can manage your preferences at any time by revisiting the cookie settings link usually found in the footer of our website.
• Impact of Disabling Cookies: If you choose to disable all cookies (including essential ones) through your browser settings, you may find that certain parts of our website and services do not function correctly. For example, you may not be able to log in, make transactions, or experience personalized features. Disabling non-essential cookies may limit some functionalities but will not typically prevent you from using the core services.

9.4 Third-Party Cookies

In addition to our own cookies, we may use various third-party cookies for analytics, advertising, and social media integration. These cookies are set by third-party services that appear on our pages. We do not have direct control over how these third parties collect or use your data.

• External Services: Examples include Google Analytics for website traffic analysis, advertising networks for serving relevant ads, and social media platforms for sharing content. These third parties have their own privacy policies which govern their use of information. We encourage you to review their respective privacy policies to understand their data processing practices.
• Opting Out of Third-Party Cookies: Many advertising networks and analytics providers offer mechanisms to opt out of their data collection. For example, you can opt-out of Google Analytics without affecting how you visit our site by installing the Google Analytics opt-out browser add-on. You can also visit websites like the Network Advertising Initiative (NAI) Opt-Out Page or the Digital Advertising Alliance (DAA) Opt-Out Page to learn more about interest-based advertising and manage your preferences.

By continuing to use our service without adjusting your cookie settings, you agree to our use of cookies as described in this policy, unless we explicitly ask for your consent for specific cookie types.

10. International Data Transfers

As an online casino operating globally, our services and operations may involve the transfer of your personal data across international borders. This section explains where your data may be processed and the safeguards we put in place to ensure its protection during such transfers.

10.1 Data Location

Your personal data may be stored and processed in various locations around the world, including countries outside of your country of residence, particularly outside the European Economic Area (EEA) and the United Kingdom. This is due to the global nature of our operations, the location of our servers, our service providers, and our affiliates.

• Processing Locations: We utilize data centers and service providers located in various jurisdictions. For instance, while our primary servers might be in the EEA, some of our customer support, payment processing, or analytics providers may operate from countries such as the United States, Canada, India, or other regions.
• Countries Involved: The countries where your data might be processed or stored include, but are not limited to, those within the European Union (EU) and European Economic Area (EEA), the United Kingdom, the United States, Canada, and other jurisdictions where our chosen third-party service providers are located or operate.

When your personal data is transferred to, and processed in, a country outside of the EEA/UK, the data protection laws in that country may differ from those in your jurisdiction. We take appropriate measures to ensure that such transfers comply with applicable data protection regulations and that your data remains protected to the standards outlined in this Privacy Policy.

10.2 Safeguards for International Transfers

To ensure that your personal data receives an adequate level of protection when transferred outside the EEA/UK, we implement various safeguards as required by GDPR and other relevant data protection laws. These safeguards are designed to ensure that your data is treated securely and in accordance with the principles outlined in this Privacy Policy.

• Standard Contractual Clauses (SCCs): We primarily rely on the Standard Contractual Clauses (SCCs) issued by the European Commission or the UK Information Commissioner's Office (ICO). These are pre-approved contractual terms that impose specific data protection obligations on the data importer and ensure that your data receives an equivalent level of protection to that provided within the EEA/UK. We ensure that our contracts with third-party service providers who process data outside the EEA/UK include these SCCs, or equivalent clauses, and that additional supplementary measures are implemented where necessary to address local risks.
• Adequacy Decisions: We may transfer data to countries that have been deemed by the European Commission or the UK government to provide an adequate level of data protection. These "adequacy decisions" signify that the legal framework of that country is considered to offer comparable protection to the GDPR/UK GDPR. Examples include transfers to countries like Canada (for certain commercial organizations) and New Zealand.
• Binding Corporate Rules (BCRs): For transfers within our own corporate group or to affiliates, we may utilize Binding Corporate Rules (BCRs). These are internal codes of conduct approved by data protection authorities, providing a legally binding framework for transfers within a multinational organization to ensure consistent data protection standards.
• Consent: In specific and limited circumstances, we may seek your explicit consent to transfer your personal data to a third country after having informed you of the possible risks of such transfers for you due to the absence of an adequacy decision and appropriate safeguards. This consent would be requested only when other transfer mechanisms are not applicable or feasible.
• Other Transfer Mechanisms: In certain rare cases, we may rely on other specific derogations or approved mechanisms under applicable data protection laws, such as transfers necessary for the performance of a contract between you and us, or transfers necessary for the establishment, exercise, or defense of legal claims.

Before engaging any third-party service provider, especially those located outside the EEA/UK, we conduct thorough due diligence to assess their data protection practices and ensure they can meet our stringent security and privacy requirements. We also monitor their compliance regularly and ensure that data processing agreements are in place to govern the handling of your data.

By using our service, you acknowledge and agree that your personal data may be transferred to and processed in countries outside your jurisdiction, with the assurance that we will implement the appropriate safeguards to protect your privacy rights.

11. Children's Privacy

Protecting the privacy of children is of paramount importance to us, and we are strictly committed to preventing underage gambling. Our online casino services are not intended for, nor are they directed at, individuals under the legal gambling age.

11.1 Age Restriction

Our online casino service is designed for and intended solely for use by individuals who are 18 years of age or older, or the legal age of majority in their respective jurisdiction, whichever is higher. We have strict age verification procedures in place as part of our Know Your Customer (KYC) processes to ensure that no one under the legal gambling age can register an account or use our services.

• Mandatory Age Verification: During the account registration process, users are required to confirm that they are of legal age. This is further substantiated by our collection and verification of identity documents (e.g., passport, national ID card) that clearly state the date of birth.
• Prohibition of Underage Gambling: We unequivocally prohibit individuals under the legal gambling age from creating accounts, participating in games, or using any aspect of our service. This policy is enforced rigorously to comply with gambling regulations and to promote responsible gaming practices.

11.2 Parental Notice and Immediate Deletion if Minor Detected

We do not knowingly collect personal data from children. If we become aware that we have inadvertently collected personal information from an individual under the legal gambling age without verifiable parental consent, we will take immediate steps to delete that information from our records.

• Detection Procedures: Our systems are designed to flag and identify potential underage users. If we identify that an account holder is underage based on our verification processes or other credible information, the account will be immediately closed, and all associated funds may be frozen in accordance with our terms and conditions and regulatory obligations.
• Reporting: In certain jurisdictions, we may be legally obligated to report instances of attempted underage gambling to relevant authorities.
• Parental Guidance: We encourage parents and guardians to monitor their children's online activity and use parental control tools to help prevent children from accessing inappropriate online content, including gambling websites. If you are a parent or guardian and believe that your child under the legal gambling age has provided us with personal information, please contact us immediately using the details provided in Section 14 (Contact Information) so we can take appropriate action.

Our commitment to children's privacy is unwavering, and we continuously strive to implement and maintain effective measures to prevent underage access to our online casino services.

12. Marketing Communications

We believe in providing you with control over the marketing communications you receive from us. This section details our approach to sending promotional materials and how you can manage your preferences.

12.1 Opt-In for Marketing

We respect your privacy and will only send you direct marketing communications if you have provided us with your explicit consent to do so. This "opt-in" approach ensures that you only receive promotional materials that you are interested in.

• Consent Requirement: When you register for an account or at various points during your interaction with our service, we will provide you with clear options to opt-in to receive marketing communications. This consent typically covers communications sent via email, SMS, push notifications, or other electronic means.
• What Marketing Includes: Our marketing communications may include information about:
  • New games and features available on our platform.
  • Special promotional offers, bonuses, and free spins.
  • Updates on tournaments, events, and loyalty programs.
  • Personalized recommendations based on your gaming preferences (where you have consented to such personalization).
• Clear Opt-In Mechanisms: We ensure that the opt-in process is clear, transparent, and easy to understand. You will always know what you are consenting to receive.

12.2 Opt-Out of Marketing

You have the absolute right to withdraw your consent and opt-out of receiving marketing communications from us at any time. We make this process simple and accessible.

• Unsubscribe Link in Emails: Every marketing email you receive from us will contain a clear and prominent "unsubscribe" link, usually located at the bottom of the email. Clicking this link will typically remove you from our marketing mailing list for that specific communication channel.
• Account Settings: You can manage your marketing preferences directly through your account settings on our website or mobile application. This section usually provides granular control, allowing you to choose which types of marketing communications you wish to receive or to opt-out entirely.
• Customer Support Contact: If you encounter any difficulties with the unsubscribe link or account settings, you can always contact our customer support team. They will be able to assist you in updating your marketing preferences.
• Processing Time: Please note that it may take a short period (typically a few business days) for your opt-out request to be fully processed and for marketing communications to cease. You may still receive a few communications during this transition period.

12.3 Transactional Communications

Please be aware that even if you opt-out of marketing communications, you will continue to receive essential service-related or transactional communications from us. These communications are not promotional in nature and are necessary for the proper functioning of our service and the management of your account. Examples of transactional communications include:

• Account registration confirmations.
• Password reset emails.
• Security alerts (e.g., login from a new device).
• Notifications regarding deposits, withdrawals, or other financial transactions.
• Updates to our Terms & Conditions or Privacy Policy.
• Important information regarding your account status or responsible gaming.

These essential communications are a vital part of our contractual relationship with you and cannot be opted out of, as they are crucial for your security and the operational integrity of our service.

13. Responsible Gaming and Self-Exclusion

Our online casino is deeply committed to promoting responsible gaming and providing a safe and supportive environment for our users. A core part of this commitment involves the collection and use of specific data to identify, assist, and protect individuals who may be at risk of developing gambling problems.

13.1 Data for Protection

We utilize various data points to monitor and analyze gaming behavior, allowing us to detect potential signs of problem gambling and intervene proactively. This use of data is primarily driven by our legal and ethical obligations to protect our users.

• Problem Gambling Detection: We collect and analyze data related to your gaming activity, which includes:
  • Betting patterns: Changes in wager size, frequency of bets, and types of games played.
  • Wins and losses: Patterns of significant wins followed by increased betting, or sustained losses.
  • Time spent: The duration and frequency of your gaming sessions, including unusual increases in play time.
  • Deposits and withdrawals: Rapid increases in deposit amounts, frequent deposits, or attempts to reverse charge transactions.
  • Account changes: Frequent changes to deposit limits, self-exclusion requests, or attempts to open multiple accounts.
  • Interactions with customer support: Queries or statements that might indicate distress or concerns about gambling habits.
• Behavioral Analytics: We employ specialized algorithms and tools to analyze these data points, often on an anonymized or pseudonymized basis, to identify behaviors that align with known indicators of problem gambling.
• Proactive Intervention: Based on these analyses, our trained responsible gaming team may reach out to you, offer information about responsible gaming tools (e.g., deposit limits, session limits, reality checks), provide links to professional support organizations, or, in severe cases, impose temporary cooling-off periods or self-exclusion on your behalf.
• Support Resources: The data helps us direct you to appropriate resources and support mechanisms available to assist with gambling-related harm, both within our platform and via external organizations.

This processing of data is based on our legal obligation to promote responsible gaming and our legitimate interest in protecting our users and maintaining a safe gaming environment.

13.2 Self-Exclusion Data

Self-exclusion is a critical tool for individuals who feel they need a break from gambling. When you choose to self-exclude from our service, we collect and retain specific data to ensure that this exclusion is effectively enforced.

• Retention During Exclusion Period: If you opt for self-exclusion, we will retain necessary personal data, including your name, date of birth, residential address, email address, and any specific identifiers, for the entire duration of your chosen self-exclusion period. This data is retained primarily to:
  • Prevent Account Reopening: Ensure that you cannot re-register a new account or access your existing account on our platform during the self-exclusion period.
  • Cross-Referencing: If we operate multiple brands or are part of a wider network, your self-exclusion data may be shared across these platforms to prevent you from accessing gambling services elsewhere within our group. This is vital for the effectiveness of the self-exclusion.
  • Regulatory Compliance: We are legally required to maintain records of self-exclusion and to enforce them effectively.
• Post-Exclusion Retention: Even after the formal self-exclusion period has ended, we may retain certain anonymized or pseudonymized records for a longer period for statistical purposes, to understand long-term trends in responsible gaming, and to demonstrate our historical compliance with regulatory requirements.
• Prevention of Circumvention: We monitor for attempts to circumvent self-exclusion (e.g., attempting to register with different details). Data collected during your initial registration and self-exclusion period is crucial for identifying such attempts and upholding the integrity of the self-exclusion system.
• Data Minimization: While we retain this data for critical reasons, we ensure that only the minimum necessary information required for effective self-exclusion is kept, in accordance with data minimization principles.

The processing of self-exclusion data is based on our legal obligation to uphold responsible gaming measures and our legitimate interest in protecting vulnerable individuals from gambling-related harm. Your decision to self-exclude is treated with the utmost seriousness, and the data collected helps us honor that commitment.

14. Contact Information

We are committed to transparent and accessible communication regarding your privacy. If you have any questions, concerns, or wish to exercise your data protection rights, please do not hesitate to contact us.

14.1 Privacy Questions

For general inquiries about this Privacy Policy, our data processing practices, or any other privacy-related concerns, please contact our dedicated privacy team.

• Email: privacy@casino.com

We aim to respond to all privacy-related questions promptly and comprehensively.

14.2 Exercise Your Rights

If you wish to exercise any of your data protection rights as outlined in Section 8 (e.g., Right to Access, Rectification, Erasure, Restriction, Data Portability, Object, or Withdraw Consent), please direct your request to our data requests team.

• Data Requests Email: datarequests@casino.com

When submitting a request to exercise your rights, please provide the following information to help us process your request efficiently and securely:

• Your full name: As registered on your account.
• Your username: If applicable.
• Your registered email address: This helps us verify your identity.
• Details of your request: Clearly state which right you wish to exercise and provide as much detail as possible regarding the personal data concerned or the specific action you would like us to take.
• Any supporting documentation: (e.g., if you are requesting rectification, provide the correct information).

We may require further information or proof of identity to confirm that you are the individual whose personal data is subject to the request. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We will endeavor to respond to your request within the legally stipulated timeframe (typically one month under GDPR, with extensions for complex requests).

Data Protection Officer (DPO)

For more complex data protection issues, or if you wish to contact our designated Data Protection Officer directly, you may do so via:

• Email: dpo@casino.com

The DPO is responsible for overseeing compliance with data protection laws and for serving as a point of contact for data subjects and supervisory authorities.

We encourage you to contact us first so we can attempt to resolve any concerns you may have directly. However, you also have the right to lodge a complaint with your local data protection supervisory authority if you believe we have not adequately addressed your concerns or have breached your data protection rights.

15. Third-Party Links

Our online casino website and services may contain links to external websites, services, or applications that are not operated by us. These third-party links are provided for your convenience or as part of our collaborations (e.g., links to responsible gaming organizations, payment providers, game developers' websites, or promotional partners).

• Disclaimer about External Sites: Please be aware that once you click on a link that takes you to a third-party website, you will be leaving our platform, and this Privacy Policy will no longer apply. We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third-party sites or services.
• Recommendation to Review Their Policies: We strongly advise you to review the privacy policy and terms and conditions of any third-party website or service you visit. Each external site operates under its own data collection and processing rules, which may differ significantly from ours. Your interactions with these third-party websites are subject to their respective privacy policies.
• No Endorsement or Responsibility: The inclusion of any link does not imply endorsement by us of the third-party website or its operators. We cannot be held liable for any damages or losses incurred as a result of your reliance on the information, content, or services provided by these external sites.

We recommend exercising caution and vigilance when navigating away from our platform to external links.

16. Automated Decision-Making and Profiling

In our commitment to providing a secure, compliant, and personalized gaming experience, we utilize automated decision-making and profiling processes. This section explains how these technologies are used and your rights in relation to them.

16.1 Profiling Use

Profiling involves any form of automated processing of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements. Automated decision-making refers to decisions made solely by automated means without any human involvement.

On our platform, automated decision-making and profiling are used for legitimate and necessary purposes:

• Fraud Detection and Prevention: We employ automated systems to analyze transaction patterns, betting behaviors, IP addresses, device identifiers, and other data points to identify and prevent potential fraudulent activities, such as bonus abuse, payment fraud, or collusion. These systems flag suspicious activities, which may lead to automated decisions like temporary suspension of an account or cancellation of a transaction. For instance, if an account exhibits unusual deposit patterns coupled with multiple login attempts from different geographical locations in a short period, an automated system might temporarily lock the account as a security measure.
• Risk Assessment and Compliance: Automated processes assist us in fulfilling our legal and regulatory obligations, particularly related to Anti-Money Laundering (AML) and responsible gaming. We use profiling to:
  • AML Screening: Screen users against sanctions lists, politically exposed persons (PEP) databases, and other watchlists to assess financial crime risks.
  • Responsible Gaming Monitoring: Analyze gaming activity data (e.g., deposit frequency, wager amounts, session duration, win/loss ratio) to identify patterns indicative of problematic gambling behavior. This may trigger automated interventions, such as reality checks, recommendations for setting limits, or, in some cases, temporary account suspensions or self-exclusion in accordance with our responsible gaming policy.
• Offer Personalization and User Experience Optimization: We may use profiling to personalize your experience on our platform. This involves analyzing your gaming preferences (e.g., preferred game types, betting habits, bonus engagement) to tailor promotional offers, recommend games, or customize content that we believe is most relevant and appealing to you. This type of profiling is generally designed to enhance your enjoyment and engagement with our service. Where this involves direct marketing, it is subject to your consent and right to object.
• Age and Location Verification: While typically involving human review for identity documents, initial automated checks on provided age and location data (e.g., IP address) contribute to immediate risk assessment and compliance.

16.2 Your Rights Regarding Automated Decision-Making and Profiling

You have specific rights concerning automated decision-making and profiling, particularly when such decisions produce legal effects concerning you or similarly significantly affect you (e.g., account suspension, denial of a withdrawal, mandatory self-exclusion).

• Right to Object: You have the right to object to processing that is based on profiling if you believe it is being used inappropriately or unfairly, particularly when based on our legitimate interests.
• Right to Human Review: Where a decision is based solely on automated processing and produces legal effects concerning you or similarly significantly affects you, you have the right to:
  • Obtain Human Intervention: Request that a member of our team reviews the automated decision. Our trained personnel will assess the decision, consider all relevant information, and have the authority to overturn or adjust the automated outcome if deemed appropriate.
  • Express Your Point of View: Present your perspective and explain your circumstances concerning the automated decision.
  • Contest the Decision: Formally challenge the automated decision if you believe it is incorrect or unjust.
• Right to Explanation: We will provide you with meaningful information about the logic involved in the automated decision-making process, as well as the significance and the envisaged consequences of such processing for you.

Automated decisions that are necessary for entering into or performance of a contract between you and us (e.g., processing transactions, allowing you to play games), or based on your explicit consent, are generally exempt from the right to human intervention, provided that suitable safeguards are in place (such as the right to human review).

To exercise these rights, please contact us using the details provided in Section 14 (Contact Information), specifying that your request relates to automated decision-making or profiling. We are committed to ensuring fairness, transparency, and accountability in all our data processing activities, including those involving automation.

17. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our data processing practices, legal or regulatory requirements, or technological advancements. We reserve the right to modify this policy at any time, so please review it frequently.

• Notification of Changes: When we make significant changes to this Privacy Policy, we will notify you by:
  • Posting the updated policy on our website with a revised "Last Updated" date.
  • Providing notice through a prominent banner or pop-up on our website or within your account dashboard.
  • Sending you an email notification to the email address registered with your account, particularly for material changes that affect your rights or the way we process your personal data.
• Effective Date: Any changes to this Privacy Policy will become effective immediately upon being posted on this page, unless otherwise stated. We encourage you to regularly review this page for the latest information on our privacy practices.
• Your Responsibility: Your continued use of our services after any changes to this Privacy Policy signifies your acceptance of those changes. If you do not agree with the terms of the updated policy, you should discontinue using our services.

We encourage you to periodically review this Privacy Policy to stay informed about how we are protecting the personal information we collect. The "Last Updated" date at the beginning of this document indicates when the policy was last revised.