Privacy Policy
Introduction
Data controller: The name and address of the Data Controller can be found in the footer of thiswebsite.
This Privacy Policy, which was last updated on 03/05/2022, sets out the data processing practices
carried out by the Casino.
Here at the Casino, we like making things simple and easy for our customers and that includes being
clear, transparent and open about what we collect, and how and why we use the data we collect, so
this page goes into great detail.
Our Policy explains how we use your personal data, whether you are just visiting, making a deposit
or playing one of our games. This policy includes information you may not already know about yourdata privacy rights, circumstances in which we share and obtain information about you and how we
use it to personalize the marketing you receive, so please take time to read all the sections carefully.
If we make any material updates to this Policy, we will inform you.
Please note that all our employees undertake regular training on Information Security and are
required to comply with confidentially obligations as well as internal policies and procedures
whenever they handle your information.
We hope you will find this page helpful, but should you have any concerns or questions, regarding
Data Protection, please feel free to contact our Data Protection Officer.

Our Privacy Policy Promise
The Casino will always value and respect the privacy of each and every one of its customers. Yourprivacy is important both to you and to us and we make the following promise to you:
The Casino is committed to protecting your privacy. We believe in using your personal information
to make things simpler and better for you. We will always keep your personal information safe. We’ll
be clear and open with you about why we collect your personal information and how we use it.
Where you have choices or rights, we’ll explain them to you and respect your wishes.

The Types of Information We Collect
We collect two types of data and information from our customers.
Personal Information
Personal Information which can be used to identify an individual. The Personal information wecollect through our Services includes information which is submitted directly by the you, such as:phone number; full name; e-mail address; home address; date of birth; payment means (e.g. credit
card number); and other financial information that we may need in order to provide our Services.
We also collect Personal Information from your device (e.g. geolocation data, IP address) andinformation on your activity on the Services (e.g. pages viewed, online browsing, clicks, actions, etc.).

Non-personal Information
The second type of information is un-identified and non-identifiable information pertaining to you
which may be made available or gathered via your use of the Services We are not aware of theidentity of the user from which the Non-personal Information was collected. Non-personal
Information which is being collected may include your aggregated usage information and technicalinformation 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 andthe domain name of the website from which you linked to the Services; etc.), in order to enhance
the functionality of our Services.
If we combine Personal Information with Non-personal Information, the combined information willbe treated as Personal Information for as long as it remains combined.

How We Collect Your Information
Collecting Information about you, from you
The Casino collects personal information about you whenever you use our services. Some of it you
provide directly to us, for example, when you register an account or fund your account. Other
information is collected during your interactions with us, such as the bets you place or online chatswith our customer services team and through Cookies (Please refer to the dedicated section about
Cookie’s for more information on our usage of cookies) . Also, if you consent we will also record all
telephone conversations.. We also collect information about the way you access, view, share,contribute to and communicate with and through our services, for example when you postcomments via our social media channels or chat functionalities.

Collecting Information about you, from your device
We collect information from the devices you use when using the Casino content, products andservices. This includes but is not limited to the following: your IP address (a number that identifies a
specific device on the internet and is required for your device to communicate with websites),
hardware model, operating system and version number.

Collecting Information about you, from Cookies
We may collect information about your computer, including where available your IP address,
operating system and browser type, for system administration and to report aggregate information
to our advertisers. This is statistical data about our users’ browsing actions and patterns and does
not identify any individual.
For the same reason, we may obtain information about your general internet usage by using a
cookie file which is stored on your browser or the hard drive of your computer. Cookies contain
information that is transferred to your computer’s hard drive. They help us to improve our site andto deliver a better and more personalised service. Some of the cookies we use are essential for thesite to operate. The cookies we use can be grouped into four separate categories and are explainedin the section further below set out for Cookies.

Collecting Information about you, from external companies
To help us comply with our legal and regulatory KYC and Social Responsibility obligationsa) when you open your account, we may cross reference the information you supplied to us
with external/governmental companies for AML and ID verification processes, as well as toascertain whether you are registered with them because you asked not to be allowed togamble or receive marketing.
b) We use publicly available information (on social media sites and the like) to help verify
information provided to us and we log and save the results.
Where we acquire personal data from a third party as part of a business or asset transfer:
We may also collect personal data about you from third parties from time to time. For example, if
you are a former customer of a Casino partner and your data was passed to the Casino we will haveacquired the following categories of your personal data from your previous online betting andgaming provider in order to integrate your former account into the Casino’s platforms and systems,
and to provide our gambling services to you in accordance with our Terms and Conditions. A nonexhaustive example (which may or may not be applicable depending on the process) of such data is:a) Your account balances – to allow you to access your funds;b) Your former providers username and password (hashed and non-decipherable by us) – toallow you to continue to access your account using the same login details;c) Your personal registration details originally supplied to your former provider, such as name,
DOB, address, email address, telephone number and occupation;d) Other account data such as your player ID, registration and login dates, country code,
currency, first deposit amounts and dates, number of wins, device details (where held),gambling limits but in most cases excluding payment details and itemised, historic gaming
and financial transactions. Please note, if you require access to your historic, itemised
gaming and financial transactions with your former provider please contact them inaccordance with the instructions on their Privacy Policy on their website in the first instance;e) Copies of your existing KYC, identification and Enhance Customer Due Diligence documents
originally supplied to your former provider – where we can, we will process these
documents to allow you to access the Casino’s services without have to ask you to supply
updated documents.
f)

If you are a ‘time out’ or ‘self-excluded’ customer, your account status and duration of any
relevant live time out or exclusion period.

We will process the above categories of personal data for the reasons outlined in this Privacy Notice
and in accordance with the relevant data protection legislation.

How do we use the information we collect?
We (which has the meaning of any company within the same group that operates ##skin#) use andshare Personal Information in the manners described in this Privacy Policy. The Personal Information
will be disclosed to a third party only to the extent required for the specific purpose, as stipulated inthis Privacy Policy, and in such cases, we require the relevant third party to agree to process suchinformation in compliance with our Privacy Policy.
We will not disclose your Personal Data with any third parties outside of the European Union incountries where there is no adequate data protection regime. However, in the event that such adata transfer occurs, we will take all reasonable steps possible to ensure that your data is treated as
securely as it is within the European Union and in accordance with this Privacy Policy and theapplicable legislation. Additionally, we will update the current Privacy Policy in order to reflect thecross-border data transfer and the relevant safeguards for your privacy.
The information we collect, which may include “Personal Information”, is used for the following
purposes:•

To set up your account and to provide our Services (e.g. Identification and verification of yourpersonal details, send out cash-out checks, process your payments, consult the national selfsuspension register to determine whether we can allow you access to gambling/receive
marketing. The legal basis for this processing activity is the performance of the contract,fulfilment of a legal obligation/regulatory obligation.

•

To identify and authenticate your access to certain features. The legal basis for this processing
activity is your consent.

•

To indicate that you had a win (in winners announcements on our website or on a tournament
leaderboard) by using your Username. We advise against using anything that can identify you
personally, however this is your choice. The legal basis for this processing is your consent.

•

To communicate with you and to keep you informed of our latest updates; The legal basis for thisprocessing activity is your consent.

•

To market our website and products or those of any of our business partners and affiliates. The
legal basis for this processing activity is the performance of the contract.

•

To serve you advertisements. The legal basis for this processing activity is your consent.

•

To perform a research or to conduct anonymous analytics in order to improve and customize our
Services to your needs and interests; The legal basis for this processing activity is your consent.

•

To support and troubleshoot our Services and to respond to your queries; The legal basis for thisprocessing activity is your consent; and•To investigate violations and enforce our policies, as required by law, regulation or othergovernmental authority, or to comply with a subpoena or similar legal process or respond to agovernment request. The legal basis for this processing activity is the legal obligations.

•

To audit certain elements of our business practices. The legal basis for this processing activity is
the legal obligations.

•

Where we decide or sell, transfer or otherwise dispose of any part of our business in the future,
we may share your information with prospective purchasers and our professional advisors forthat purpose.

Where the data processing is in accordance with your consent, you have the right to withdraw yourconsent at any time in writing to our contact details mentioned in this Policy, or by following any
relevant process to withdraw your consent (eg, unsubscribing from marketing). Withdrawal of yourconsent does not affect the lawfulness of the treatment of your data prior to its revocation.

Companies that provide services on our behalf
We share your personal information with external organizations that carry out a range of services onbehalf of the Casino. We carry out checks to ensure that the companies we work with will give yourinformation the same level of care and protection as we do. Both we and they are obliged to handle
your information in accordance with data protection law, and we are also required to put in place
contractual measures reinforcing those obligations.
The main functions that are or may be carried out, fully or in part, by third parties are listed below:•

Management and execution of marketing campaigns•

Payment processing and verification•

Credit Reference Agencies including but limited to affordability checks. For more information on
how Credit Reference Agencies collect/handle and process your personal data please check
Credit Reference Agency Information Notice (CRAIN)•

Anti-fraud and Anti-money laundering checks (Including but not limited to Enhance Due
Diligence reports utilizing publicly available sources and ID verification•

Checks to detect unfair use of our products and services•

Web hosting, online content services and data storage•

Management of competitions, contests and offers•

Data analytics and data cleansing•

Market research and collecting or analysing customer feedback•

IT services and support•

Audit-, Legal- & Compliance- related services•

Storing data for regulators to access and view•

When your activity reaches certain internal thresholds, we will supply your personal information
to credit reference agencies, and they will provide us information about you. This may include:
Information from your credit application, Information about your financial situation and financial
history, Public information (CCJs, Debt Collection), Information generated by activity in yourbank accounts, shared credit details – the legal basis for processing this data is Legitimate
Interest. If you wish for your data not to be processed in this way please contact DPO before you
make any further deposits on your account and wait for a response.

•

Analysis of gambling habits to ascertain potentially risky behaviours.

Information demands from Regulators:
On a regular basis, in all licensed jurisdictions, we are regulatory required to produce reports
containing non-Personal Data. The reports consists of things such as number of self exclusions,
number of registrations, number of complaints, number of suspicious transactions reported toauthorities.

Other information sharing with third parties:
We may also share personal data with selected third parties in order to measure and improvecustomer experience, to circulate new offers and promotions that may be of interest on various
similar third parties’ products/services and to facilitate the resolution of customer complaints anddisputes. This sharing takes place further to legitimate interests (which do not override yourfundamental rights and freedoms) or under another suitable lawful basis identified by us .
We may also process your personal data for the purposes of any future acquisitions, sales,
restructuring or other business or asset disposals or transfers of any part of our business from time
to time. This may include sharing your personal data with third party prospective purchasers,
bidders, investors, professional advisors and other relevant persons in respect of the transaction.
Such data sharing will take place further to our legitimate interests (which do not override yourfundamental rights and freedoms) in disposing of or restructuring our business interests, or underanother suitable lawful basis identified by us under the relevant data protection legislation at theappropriate time. Where this is the case, you will receive notice of any such transfer before it takes
place, along with further details about how your personal data will be processed at the relevanttime.

How long do we keep your information?
We hold your personal information only as long as we have a valid legal reason to do so, which
includes providing you with the services you have requested, meeting our legal and regulatory
obligations, resolving disputes and enforcing our agreements.
The length of time for which we keep different types of personal information can vary, depending on
why we originally obtained them, the reason we process them and the legal requirements that apply
to them. When setting our data retention and deletion timescales we take into account a range offactors including applicable regulations and standards relating to gambling and gaming, anti-money
laundering, taxation, payment processing and complaint handling, the need to prevent or detect
crime or other misuse of our services, and audit requirements. To fulfil our requirements, some ofyour personal data will need to be retained for a period of time after you cease to be a customer.
When we no longer need it to fulfil the above requirements, we delete it securely or anonymize it.

Your Rights
You have the following Data Subject Rights:•

The right to be informed. Transparency in how we are using personal data. Hence, this detailed
Privacy Policy.

•

The right of access. This enables you to e.g. receive a copy of the personal data we hold aboutyou.

•

The right to rectification. Correction/Rectification of the personal data we hold about you. This
enables you to have any incomplete or inaccurate data we hold about you corrected/rectified.

•

The right to erasure. This enables you to ask us to erase your personal data [known as the ‘rightto be forgotten’] where there is no good reason for us continuing to process it.

•

The right to data portability. This gives you the right to receive personal data they have provided
to a controller in a structured, commonly used and machine-readable format. It also gives you
the right to request that a controller transmits this data directly to another controller.

•

The right to restrict processing. This enables you to ask us to restrict the processing of yourpersonal data, i.e. use it only for certain things, if:➢ it is not accurate,➢ it has been used unlawfully but you do not wish for us to delete it,➢ it is not relevant any more, but you want us to keep it for use in possible legal claims,➢ You have already asked us to stop using your personal data, but you are waiting us
to confirm if we have legitimate grounds to use your data.
• The right to object. This gives you the right to object to the processing of your personal data.
For example, if you object to receiving marketing material you can remove consent for us tosend it. The right to object only applies in certain circumstances. Whether it applies depends on
your purposes for processing and the lawful basis for processing. Individuals have the absoluteright to object to the processing of their personal data if it is for direct marketing purposes.
Individuals can also object if the processing is for:➢ a task carried out in the public interest;➢ the exercise of official authority vested in you; or➢ your legitimate interests (or those of a third party);➢ in relation to automated decision making and profiling.

In order to exercise any of your rights over your Personal Data, please contact DPO.
We are permitted to ask for your ID in order to verify your identity prior to fulfilling your request.
However, we reserve our right, in certain situations, to request for your Identity to be verified via
additional methods/ways up to the point we are satisfied of the veracity and/or legality of therequest. Such additional verification measures are applied to ensure that Personal Data are under nocircumstances released to unauthorised persons.

If you believe your privacy rights have been infringed, or you disagree with a decision we have madeabout your privacy rights, you have the right to complain to the relevant supervisory authority.

Cookie Section
What are Cookies?
'Cookies' are small text files stored in your web browser that enable us to recognize your computerwhen you visit our website. Cookies are essential to keep certain parts of our website functioning
correctly and securely. We also use them to make things quicker, easier and more personal to you
and to help us understand how our website is used. They can also be used to present you with more
tailored advertising content.
To do all these things, cookies collect some personal information about you whenever you use our
website. You can choose whether to accept or reject some or all types of cookies and control thisthrough your device’s browser settings. We will make you aware of this by showing you our cookie
banner when you visit our site. If you then continue to use our website without adjusting yourbrowser settings, we will use cookies as set out in the sections below, so to help you make an
informed choice it’s important to know why we use the different types of cookie and what thatmeans for your online experience. This section provides you with a summary of the main points andtells you how switching off the different types of cookie will affect your experience on our website.
They also enable the Casino to find out which advertisement brought you to our website, we may
use the Casino cookies on your computer. In the event that we do collect such information, you willremain personally unidentifiable, and we will not share this information with any unconnected thirdparty.

The Cookie Categories
The Cookies we use fall into the following categories:•

Strictly Necessary
This type of cookie allows you to navigate the website and use essential features like secureareas and online registration. These cookies don’t gather any information about you that
could be used for marketing or remembering where you’ve been on the internet. These
cookies are essential in our being able to guarantee the performance of our website, should
you disable them we won’t be able to ensure your security or predict how our website will
perform during your visit.

•

PerformanceThis type of cookie collects information about how you use our website e.g. which pages you
visit, and if you experience any errors. The information collected is anonymous and is onlyused to help us improve how our website works, gauge what interests our users and assess
the effectiveness of advertising.

•Functionality
This type of cookie remembers your preferences for tools found on our website, so you
don’t have to re-set them each time you visit. Some of them are managed by third parties.
They may for instance determine whether you see the latest or oldest comments made in
relation to an article first. They may also help us greet you by name or remember yourchoice of language or region).

•Targeting/Tracking
These cookies are used to analyse what advertising might be most relevant to a user of thewebsite based on the areas of the website that the user visits.

Controlling my Cookies
All modern browsers allow you to see what cookies you have, and to clear them individually or in
their entirety by changing your cookie settings. Cookie settings are typically found in the 'options' or'preferences' menu of your browser, otherwise you should use the 'Help' option in your browser for
more details. You may also find the links below helpful:•

Cookie settings in Chrome•

Cookie settings in Firefox•

Cookie settings in Microsoft Edge•

Cookie settings in Safari

You can block cookies by activating the settings on your browser which allows you to refuse thesetting of all or some cookies. However, if you use your browser settings to block all cookies(including essential cookies) you may not be to access all or parts of our site. We endeavour to makeall parts of our site accessible to everyone but if you block some cookies, particularly Strictly
Necessary cookies, your access might be impaired. Unless you have adjusted your browser settings
so that it will refuse cookies, our system will issue cookies as soon you visit our site.
Your first visit to our site will generate a pop-up header alerting you to this privacy policy and will reappear only in the event that you change your cookie settings from time to time.

The Use of Google Analytics
We use Google Analytics for ‘analytical’ purposes such as to keep track of user/customer browsing
patterns and to build up a profile for a customised browser experience for you. Google Analytics is a
popular web analytics service provided by Google, Inc. Google Analytics uses cookies to help us toanalyse how customers use our Website.
Your opt-out choice is applied only to the browser from which you make the choice, so if you use
different browsers you will need to opt out in each one. This opt-out is cookie based, so if you delete
your cookies, you will no longer be opted out and will need to opt out again. Google Analytics, fromwhich you can control through your browser settings: opt out.
https://tools.google.com/dlpage/gaoptout

Security
The Casino goes to great lengths to guarantee that your personal and financial information remains
100% secure and confidential. We employ industry standard security protocols (The connection tothis site is encrypted and authenticated using TLS 1.2 (a strong protocol), ECDHE_RSA with X25519 (astrong key exchange), and AES_128_GCM (a strong cipher) to ensure that all transactions including
deposits and withdrawals are carried out in a totally secure manner. This technology protects you
from having your information intercepted by anyone other than the Casino while it is beingtransmitted between you and the Casino.

Limits of Confidentiality
For legal reasons, the Casino may be required under certain circumstances to disclose your personal
information. Reasons for this may include:
1. to protect and defend our rights or property.
2. to comply with any legal process served on us.