Privacy Policy for Users

The Company, which is identified in the User Agreement relevant to you, delivers a range of online gambling services, collectively called the 'Services'. As part of the SlotsOnline organization known as the 'Group', 'we', 'our', or 'us', details for contacting the various entities of the Group can be found under \"HOW TO CONTACT US\".

The Group is dedicated to protecting the privacy of its users, referred to as ‘User(s)’, ‘you’, or ‘your’. As such, we have established this Privacy Policy to delineate our practices regarding data protection, detailing how we collect, utilize, disclose, and safeguard your Personal Information, as well as inform you of your rights related to your data.

Within this Privacy Policy, you will discover information such as:

• WHAT INFORMATION WE COLLECT?
• CONDITIONS FOR PROCESSING OF PERSONAL INFORMATION
• MINORS
• HOW WE USE THE COLLECTED INFORMATION?
• MARKETING
• WITH WHOM WE SHARE INFORMATION?
• INTERNATIONAL TRANSFER OF INFORMATION
• THIRD PARTY TRACKING TECHNOLOGIES
• THIRD PARTY SERVICES
• RETENTION OF PERSONAL INFORMATION
• YOUR RIGHTS
• HOW WE KEEP YOUR INFORMATION SECURED
• CHANGES TO THE PRIVACY POLICY
• HOW TO CONTACT US

We highly recommend taking the time to thoroughly review this Privacy Policy to make well-informed decisions. By accessing the websites, mobile applications, or other online resources of the Group, or by setting up an account to utilize our Services, you confirm that you have read and comprehend this Privacy Policy.

If you are engaging with our sports betting services, the handling of your personal data will also be subject to this Privacy Policy or the privacy policy mandated by our service partner Kambi. Kambi supplies us with a sports betting risk management platform and assists in evaluating wagers placed through SlotsOnline. You can access Kambi’s privacy policy here.

The Group provides its Services through various applications and platforms collectively referred to as the “Platforms”:

• Websites on the internet, including this one;
• Downloadable applications and software (‘Software’), which may include native applications available through mobile app stores or desktop software for PC and Mac that can be downloaded on your computer;
• Web applications that do not require download (for instance, Flash applications, HTML5 applications, etc.); and
• Facebook applications.

WHAT INFORMATION WE COLLECT?

We obtain two distinct types of information from our Users:

• Personal Information

  The first type is information that can identify an individual or may do so with reasonable effort, referred to as “Personal Information.” The Personal Information collected may include:

  • Account details: When registering for an account to use the Services, you’ll be asked for specific information about yourself, such as your first and last names, email address, username, gender, date of birth, personal identification number, age, profile picture, home address, ID number, tax code, phone number, and occupation. Moreover, we may need to gather certain data as required by various gambling regulations, including Know Your Customer (‘KYC’) and Anti-Money Laundering (‘AML’) laws, such as information regarding your source of funds.
  • Government-issued ID: There may be situations where you are required to submit a copy of an ID issued by the government for identity verification. Please be aware that this information is necessary for accessing certain features of our Services.
  • Gaming information: To provide the Services effectively, we automatically collect various types of information related to your account and your interactions with our Services, including your transactions, deposits, balances, bets, withdrawals, bonuses, and winnings. We also collect data related to possible gambling issues or addictions based on your gaming behavior across our platforms, to foster a responsible gaming environment and adhere to legal standards.
  • Financial information: To allow you full access to the functionalities of our Services (like placing bets, making purchases, participating in tournaments, etc.), we collect payment details such as your currency, credit card number, chosen payment method, and banking information.
  • Voluntary information: We also gather information that you voluntarily provide, particularly from our VIP clients. For instance, this could include details from your responses to our communications, interactions through email, or additional insights you share while using the Services, such as information disclosed during chat or in games. This might involve sharing details that can help us enhance our relationship with you, as well as to ensure your satisfaction with our offerings (for example, your marital status, family details, interests, hobbies, and insights from surveys).
  • Device information: We gather specific details about your device connection and relevant information that may identify you, such as unique device identifiers (e.g., UDID, IMEI, MAC address), browser fingerprint, IP address, and location data.
  • Telephone calls: We may record or monitor telephone conversations for purposes related to customer support, training, and/or security.
  • Events: During our events, we may conduct interviews and capture photos and videos that could depict attendees, speakers, sponsors, or exhibitors. If you appear in any recordings made at events where you participated, we might utilize these visuals for promotional activities, including quoting from any interview you partake in.
  • Social networks: If you register using your social media account (for instance, your Facebook account), to access the Services or connect your player profile to that account, we will gain access to basic details from your social media profile, including your name, birth date, profile image, and friend list, along with any information you have made publicly accessible on that account.
  • Additionally, while using the Services, you may have the option to invite someone through your social media to use the Services. If they accept your invitation, we may acquire Personal Information from them, such as their name, email address, phone number, and date of birth. We will use this Personal Information for the purposes outlined in this policy and only share such information with third parties as per the specifications in this Privacy Policy.
  • Information we collect from third parties: We gather Personal Information from external service providers, which may include your credit history from credit bureaus and other financial data that are pertinent to the Services, as well as information needed to verify your identity and preempt fraudulent or illegal activities.
• Non-personal Information

  The second type of information we collect is anonymous and non-identifiable data associated with a User(s), which may be accessible or obtained through a User's utilization of the Services (“Non-Personal Information”).

  The Non-Personal Information collected includes technical and aggregated usage details and may encompass items like the User’s operating system, browser type, screen resolution, browser and keyboard languages, User’s click-stream activities on the Services, duration of the User’s sessions on the Services, and associated timestamps, etc.

  To clarify, any Non-Personal Information that is connected to or associated with any Personal Information shall be treated as Personal Information as long as that connection or association remains.

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

  • Log-in history and technical information: To enhance the performance of our Services and improve user experience, we collect technical data transmitted by your device, including relevant software and hardware details (like the type of browser and operating system in use, language settings, access times, and the domain name of the website from which you linked to the Services, etc.).
  • Gameplay information: We document game play data such as your deposits, bets, bonuses, game session lengths, and highest scores. This information might be shared or published across any of our Platforms.
  • Device and connection information: We collect specific information regarding the device you are currently using for security measures and to prevent fraud. This includes details about other software running alongside our Software that could indicate the use of fraudulent tools (like bots, malware, etc.) or to see if you're connected through a VPN or proxy.
  • Analytics information: We track how you utilize the Services, including information on application usage, log files, user activity (e.g., the pages viewed, duration spent on certain pages, online navigation, clicks, actions, etc.), timestamps, alerts, and so forth. This data is collected for troubleshooting issues as well as for research and analytics regarding your use of the Services.
  • Anonymous information: We might anonymize or de-identify the information gathered through the Services or by other means so that it cannot personally identify you. The treatment and disclosure of such aggregated or de-identified data bear no restrictions under this Privacy Policy, and we may share it with others without limitation for various purposes, including advertising or marketing.

CONDITIONS FOR PROCESSING PERSONAL INFORMATION

Your Personal Information will be utilized for several purposes, each aligned with the applicable data protection regulations.

• Contractual Obligations and Legal Compliance
  We need to handle your Personal Information to fulfill our contractual obligations (like those in the User Agreement) or to abide by different legal and regulatory duties we have. This includes adhering to the terms of our gambling licenses as well as following Anti-Money Laundering (AML) and Know Your Customer (KYC) laws.
• Legitimate interests
  Additionally, we may engage with your Personal Information when we believe it serves our legitimate interests or those of third parties, ensuring that your rights and freedoms remain intact. Examples of such legitimate interests include: (i) sharing your Personal Information within our corporate family after restructures or for internal management; (ii) identifying and retaining data linked to responsible gambling; (iii) processing to enhance the security of our networks, shielding unauthorized access; (iv) maintaining the integrity of our Services by identifying suspicious betting behaviors or fraudulent activities; (v) following legal and regulatory mandates; (vi) creating customized reward programs for players; and (vii) providing your personal data to our advisors and service professionals (like auditors) to ensure compliance with regulatory standards and best practices in the industry.
• Consent
  Although the primary reason for processing your Personal Information is to deliver our Services to you, there may be instances where we request your permission to process certain data. In these cases, your information will be handled as per your consent, which you can retract in writing at any time.
• Special Categories of Personal Data
  Our handling of your Personal Information may also encompass sensitive categories such as your racial or ethnic background, as defined by Article 9 of the GDPR. We will manage such sensitive data and may share it with relevant authorities (like regulatory bodies or law enforcement) when necessary for specific legal purposes, such as detecting or preventing unlawful actions, or addressing serious misconduct. Furthermore, we might use such data to ensure your financial safety or others', particularly regarding responsible gambling. We or our trusted partners may also process biometric information, derived from a photo you provide, to fulfill our legal obligation to verify your identity.

MINORS

Our Services are not intended for individuals under 18 years of age, who are referred to as being “Legally of Age.” If you are not Legally of Age, please refrain from downloading or using the Services, or providing any Personal Information to us.

We retain the authority to access and verify any Personal Information you provide. Should we discover that a user below the legal age has submitted information, we will remove it unless required by law to maintain that data. If you suspect that a minor has shared information with us, we encourage you to reach out to us (contact details can be found in the 'HOW TO CONTACT US?' section).

HOW WE USE THE COLLECTED INFORMATION?

Your Personal Information will be employed for the following purposes:

• To create, manage and refresh your account;
• To facilitate and deliver the Services (including betting and payment processing);
• To keep in touch and provide you with the latest updates and exclusive offers related to our Services;
• To determine your VIP status;
• To promote our Services (further details can be found in the 'Marketing' section) and to display advertisements, including targeted ads and updates on specific tournaments;
• To perform analytical tasks, engage in statistical research, and refine our Services based on your preferences and interests (like generating aggregate reports on the usage of certain features);
• For managing customer relations, supporting and troubleshooting our Services, as well as responding to your inquiries;
• To enable further development, customization, and enhancement of the Services, taking into account users’ common preferences and behaviors;
• To create a responsible gaming environment for users;
• To communicate with you and manage any requests you have related to your User Rights;
• To authenticate your access to specific features within the Services;
• To identify, prevent and address fraudulent activities or any other actions that could undermine or negatively impact the Services' integrity, including assessing risks associated with your activities on our platform;
• To investigate any breaches of our policies or the User Agreement and ensure compliance with those terms;
• To resolve conflicts related to your engagement with our Services;
• To assist with fulfilling our regulatory responsibilities or as necessitated by legal requirements, including compliance with gambling regulations, KYC, and AML laws, which may involve reviewing your financial sources or complying with governmental requests;
• Additionally, we may use your Personal Information based on your clear and informed consent for specific marketing and promotional initiatives.

If you do not provide consent (or have revoked your prior consent) for us to process your Personal Information, we will still process your data if (a) it’s necessary for fulfilling our contract (i.e., the User Agreement) with you; and/or (b) it’s required for complying with legal obligations we must meet; or (c) if processing is essential for a legitimate interest of the Company (including security or marketing reasons).

MARKETING

Our Group will utilize your Personal Information, such as your name, address, email, phone number, etc., either directly or through third party vendors, for the purpose of sending you promotional materials about the Services or products and services related to: (i) other companies within our Group; or (ii) our partners and affiliates (collectively referred to as “Marketing Affiliates”), which we feel may interest you.

We may also exchange and reveal Personal Information with our Marketing Affiliates to offer you various marketing options that we or they consider relevant. Our Marketing Affiliates might use this information for various marketing strategies, including targeted emails, postal mail, SMS, and telemarketing.

We will utilize your Personal Information to send you promotional content only when we possess a legitimate interest in doing so, or if we have received your clear agreement.

At any time, you can reject further marketing communications from us or our Marketing Affiliates by either following the instructions provided in our marketing messages (like opting out via links in promotional emails), through your “My Account” section on the site, or by reaching out to customer support (contact details are provided in the 'HOW TO CONTACT US?' section). Please be aware that even if you opt out of our marketing communications, you may still receive important updates and notifications related to our Service.

Please be aware: You have control over certain advertisements or social media campaigns through the settings provided by the third-party platforms (for example, Facebook).

Moreover, if you download any of our mobile apps from the Apple AppStore or Google Play, to stop receiving notifications, you must adjust the settings directly on your device.

TARGETED ADVERTISING

We employ third-party advertising technologies to display advertisements when you visit our Platform and make use of the Services. You may choose to opt-out of many third-party ad networks, including those associated with members of the Network Advertising Initiative ('NAI') and the Digital Advertising Alliance ('DAA').

For additional information regarding these practices by NAI and DAA members, along with your options for managing how your information is utilized by these companies, including opting out of third-party ad networks run by NAI and DAA members, please visit their official websites. http://www.networkadvertising.org/optout_nonppii.asp and http://www.aboutads.info/choices .

WITH WHOM WE SHARE INFORMATION?

We do not lease, sell, or share your Personal Information with third parties ('Recipients'), except as specified in this Privacy Policy. Any Personal Information shared with Recipients will be limited to what is necessary for the stated purposes outlined in this policy.

We disclose Personal Information to the following types of recipients:

• Any service provider who we engage to manage our Platforms;
• Entities within our Group and other associated companies;
• Gaming providers;
• Subcontractors and external service providers, which may include (but not be limited to) cloud computing services, marketing partners, identity verification, and fraud prevention services, as well as other data verification specialists;
• Credit reporting agencies, often referred to as CRAs, along with credit reference bureaus, are responsible for performing checks related to your name, address, and age. To create an account for you, we will share your personal details with these agencies, who will in turn provide us with information regarding your identity. This information might encompass:
  • Identity and contact data;
  • Data from your credit application;
  • Details about your financial status and past financial behavior;
  • Public records, including data from the electoral roll;
  • Shared credit details; and
  • Fraud prevention information.
  
  This process is essential in verifying your identity, managing your account, and preventing fraudulent activities. For a detailed understanding of the CRAs, their role in fraud prevention, the types of data they collect, how they use and share personal information, their data retention policies, and your rights concerning your data with the CRAs, please refer to the websites listed below:
  • TransUnion (formerly Callcredit): https://www.transunion.co.uk/crain
  • Equifax: https://www.equifax.co.uk/crain
  • Experian: https://www.experian.co.uk/crain/
• Service providers that handle payments, banks, and payment processors;
• External parties that offer services related to the brands operated by our Group;
• Any third-party offering you a physical prize;
• Organizations that arrange offline events or competitions for any companies within the Group or collaborate with them;
• Hotel and airline companies, particularly concerning offline events and special promotions;
• Auditors, contractors, or any legal, financial, or other advisors involved in the operations of the Group;
• Entities engaged in investigating, detecting, or preventing fraud or unlawful activities, which enable us to uphold our policies, including verifying the sources of your income or funds (for instance, government agencies, law enforcement, and banks). To assist in these efforts, we may share identifying information about your device, which can include personally identifiable information, with our trusted partner, iovation Inc., specializing in fraud prevention services – further details can be found in iovation Inc.'s documentation. privacy policy;
• Gambling addictions bodies;
• Licensing authorities, governmental, and regulatory organizations, as mandated by relevant laws and regulations; and
• Possible buyers, successors, or investors interested in any of the companies within the Group, or in case of any corporate actions (like a significant business sale, merger, restructuring, bankruptcy, consolidation, or asset transfer) related to any company within the Group. In such cases, the acquiring entity will inherit the rights and responsibilities outlined in this Privacy Policy.

Beyond the purposes mentioned in this Privacy Policy, we also share your personal data with those recipients for various additional reasons:

• Storing the information for us, potentially using cloud computing service providers;
• Processing the information to support our operations (such as managing payments and deposits, verifying user access, auditing our procedures, and preventing fraudulent or illegal activity);
• Conducting research, technical assessments, or analytics;
• Delivering targeted advertisements along with promotional and informative materials, consistent with our marketing strategy (refer to the section titled ‘Marketing’ for further details); and
• Whenever we genuinely believe that sharing information is crucial for protecting our rights or legal claims, enforcing our policies (including our User Agreement and Privacy Policy), ensuring your safety or others', or investigating/preventing fraud, we may disclose information for security purposes or to assist with relevant technical issues.
• For users of our betting services based in Germany, we also transmit personal data to SCHUFA, as detailed here:
  
  • Data sharing with SCHUFA involves our company sending personal information related to your requests, the execution, or the conclusion of the associated business relationship to SCHUFA Holding AG located at Kormoranweg 5, 65201 Wiesbaden, including information about any non-compliance or fraudulent activities during this relationship.
  • The legal grounds for these data transfers stem from Article 6(1)(b) and Article 6(1)(f) of the General Data Protection Regulation (GDPR). Transfers based on Article 6(1)(f) GDPR are permissible only if they are necessary to safeguard the legitimate interests of the business partner or a third party, provided these do not override the rights and freedoms of the data subject that necessitate personal data protection. The data interchange with SCHUFA also satisfies legal obligations to conduct creditworthiness checks on customers, as outlined in Sections 505a and 506 of the Civil Code. This is part of our fraud prevention strategies.
  • SCHUFA utilizes the received data, which also aids in scoring to provide its business clients within the European Economic Area, Switzerland, and possibly other countries (where the European Commission has acknowledged adequacy) with crucial information for assessing the creditworthiness of individuals. Beyond mere credit scoring, SCHUFA also assists its partners by crafting profiles to identify suspicious activities (for instance, for fraud detection in mail orders). Analyzing inquiries from SCHUFA's business partners helps identify potential irregularities. This analysis could include requests from the past ninety days and may also factor in address information, public records, and aggregated statistical data from SCHUFA's database. It's important to note that this process does not influence SCHUFA’s credit assessments or scoring.
  • For more details on SCHUFA's operations, refer to the SCHUFA Information Sheet or visit their website at www.schufa.de/datenschutz.

INTERNATIONAL TRANSFER OF INFORMATION

Given our global reach, it might be necessary to transfer your personal information to countries outside the European Economic Area to provide our Services, as specified in this Privacy Policy. Note that the data protection laws in these nations may not be as comprehensive as those in the European Economic Area.

We make every effort to safeguard your personal data in alignment with our Privacy Policy, utilizing contractual means (such as standard contractual clauses approved by the European Commission for international data transfers available here) or other measures (like ensuring jurisdictions deemed adequate by the European Commission for data protection, as found here).

For additional information regarding the transfer of your personal data beyond the EEA, please reach out to us (contact details can be found under the 'HOW TO CONTACT US?' section).

THIRD PARTY TRACKING TECHNOLOGIES

When you interact with our Services (such as visiting our websites), we employ (and authorize third parties to employ) technologies like web beacons, cookies, pixels, scripts, tags, and other similar methods (‘Tracking Technologies‘).

These Tracking Technologies help us automatically gather information about you, your online behavior, and your device (like your computer or smartphone) for various purposes, including enhancing your navigation within our Services, boosting the performance of our Services, and personalizing your experience. Additionally, we utilize this information to gather statistics regarding the usage of our Services, conduct analytics, deliver content tailored to your interests, and manage services for our users, advertisers, publishers, customers, and partners.

We also permit third parties to collect data about you through Tracking Technologies. To gain further insights, please refer to our Cookie Policy.

THIRD PARTY SERVICES

While utilizing our Services, you may find links leading to third-party websites, services, or applications. Please note that our Privacy Policy does not cover any such third-party entities, even if they are accessible or downloadable through our Services.

Be aware that these external websites, services, or applications operate independently from our Group. We do not assume any responsibility or liability regarding privacy issues or other legal matters concerning these third-party websites or services. We encourage you to thoroughly review the privacy policies and terms of use associated with any third-party sites or services, as those terms will govern any interactions you have with them.

Always scrutinize their privacy practices before you provide any personal information to these external entities.

You acknowledge and accept all risks associated with using any third-party websites, services, or applications. Thus, you agree that we hold no liability concerning such sites and your engagement with them.

RETENTION OF PERSONAL INFORMATION

Should you have created an account via our Services, the Group will retain your personal information for as long as your account remains active. Furthermore, we will keep your data for extended periods only as necessary to comply with legal obligations under applicable laws and regulations. This includes regulations related to gambling, Know Your Customer (KYC), and Anti-Money Laundering (AML), as well as fulfilling the Group's contractual duties.

Additionally, the Group may keep your information for longer durations if it is strictly needed to further legitimate interests, such as preventing fraud, maintaining records, responsible gaming measures, resolving or pursuing potential disputes, and when advised to do so by relevant supervisory bodies.

YOUR RIGHTS

You are welcome to reach out to us anytime via email (our contact information is available in the 'HOW TO CONTACT US?' section), and request:

1. You have the right to view or remove any Personal Information that pertains to you;
2. You can modify or refresh any of your Personal Information (for instance, if you think that your details are incorrect, you can request corrections or removal). Keep in mind that you are also entitled to ask us to amend inaccuracies in your Personal Information, unless certain regulations mandate us to retain that information unchanged;
3. You can ask us to limit or stop any further utilization of your Personal Information;
4. You have the right to obtain the Personal Information you have provided to us in a format that can be easily processed by machines;
5. You can oppose the processing of your Personal Information, especially if it's being used for marketing purposes;
6. You have the ability to withdraw your consent for our processing activities, but this applies only when such activities are based on your consent rather than on any other legal foundation;
7. You should not be subjected to decisions that are made solely through automated processes, including profiling, which have legal consequences for you or create significant impacts on your life, unless such procedures are essential for fulfilling our contract with you or are based on your explicit consent as described here.

It’s important to understand that these rights have limitations, and requests must comply with applicable legal standards, including those related to gambling and other legal or ethical documentation requirements. We reserve the right to correct, update, or eliminate information that is incomplete or incorrect at any time based on our internal policies.

HOW WE KEEP YOUR INFORMATION SECURED

We prioritize the security of your information and the Services we offer. We've adopted suitable physical and technological measures designed to prevent unauthorized access, ensure data protection, and properly manage the information we gather online. These measures are tailored according to the sensitivity of the collected data.

We implement widely accepted industry practices and controls to ensure the safety of your information, including:

• A secure network architecture that incorporates intrusion detection systems and firewalls;
• Encrypted communication;
• Authentication and Access Control;
• Conducting both external and internal audits to test for security vulnerabilities; among other practices.

While we take significant precautions to protect your information, we cannot guarantee complete security against those who might gain unauthorized access or misuse our Services, and we make no promises, explicit or implied, to completely prevent such incidents.

CHANGES TO THE PRIVACY POLICY

We retain the right to modify this Privacy Policy at any moment, so we encourage you to check this page frequently. We will do our best to inform you before any major adjustments to this Privacy Policy take effect. Noteworthy changes will generally come into play after a reasonable period following such notice, as specified in the proposed amendment. All other modifications to this Privacy Policy will take effect from the date labeled as 'Last Revised', and your ongoing use of the Services post that date will signify your acceptance of and agreement to those amendments.