INTRODUCTION
The Company, outlined in the User Agreement relevant to
you, supplies online gambling services, together known as the
“Services.” This Company is included in the SlotsOnline
corporate group, frequently termed the 'Group', or referred to
with the pronouns 'we', 'our', or 'us'. Should you need to
contact us, the details of various Group entities are provided
in the section titled “HOW TO CONTACT US”.
The Group is strongly dedicated to protecting the privacy
expectations of our users, who are referred to as “User(s)”,
“you” or “your.” For this reason, we have established this
Privacy Policy to clarify our data protection methods. This
document details how we collect, utilize, disclose, and secure
your Personal Information, along with your rights regarding that
information.
Within this Privacy Policy, you'll find information regarding:
- WHAT INFORMATION WE COLLECT?
-
CONDITIONS FOR PROCESSING PERSONAL INFORMATION
- MINORS
-
HOW WE UTILIZE THE INFORMATION WE COLLECT?
- MARKETING
- WITH WHOM WE SHARE INFORMATION?
- INTERNATIONAL INFORMATION TRANSFER
- THIRD PARTY TRACKING TECHNOLOGIES
- THIRD PARTY SERVICES
- RETENTION OF PERSONAL INFORMATION
- YOUR RIGHTS
-
HOW WE ENSURE YOUR INFORMATION REMAINS SAFE
- CHANGES TO THE PRIVACY POLICY
- HOW TO CONTACT US
We highly recommend that you review the Privacy Policy
thoroughly, using it to make well-informed decisions. By
accessing the Group’s websites, mobile applications, or any of
our online platforms, or by creating an account through our
Services, you are indicating your acknowledgment and
comprehension of this Privacy Policy.
For users utilizing our sports betting services, the use of your
personal information will be dependent on this Privacy Policy or
the privacy policy set forth by our service partner Kambi. Kambi
provides us a sports betting risk platform and aids in
evaluating bets placed via SlotsOnline. You can view Kambi’s
privacy policy here.
The Group offers its Services via the following platforms and
applications, which are collectively referred to as the
“Platforms”:
-
Websites on the internet, including the one you are currently
visiting;
-
Applications and software available for download ('Software'),
like native applications distributed through mobile app stores
and desktop applications for PC and Mac that can be installed
on your computer;
-
Online applications that do not require downloading (such as
flash or HTML5 applications); and
- Facebook applications.
WHAT INFORMATION WE COLLECT?
We gather two primary types of information from our Users:
-
Personal Information
The first category involves
information that can identify an individual, or may reasonably
be used to do so (referred to as “Personal Information”). This
Personal Information we collect may include:
-
Account Information: When you set up an account to use our
Services, we ask for specific details about you, including
your first and last name, email address, username, gender,
birth date, personal identification number, age, profile
picture, residential address, ID number, tax identification
number, phone number, and occupation. Furthermore, we may
collect additional data as required by gambling regulations,
alongside Know Your Client (“KYC”) and Anti-Money Laundering
(“AML”) stipulations, such as insights regarding your funding
sources.
-
Government-issued Identification: In particular situations,
you may need to present a copy of a government-issued ID for
identity verification. It's essential to understand that this
information is necessary to access some features of our
Services.
-
Gaming Activity: To provide our Services effectively, we
automatically record various aspects related to your account
usage, which includes details about your transactions,
deposits, account balances, wagers, withdrawals, bonuses, and
winnings. We also monitor information regarding potential
gambling issues or dependencies, evaluating your gambling
behavior using our services to maintain a safe gaming
environment as mandated by law.
-
Financial Details: To enable the full range of functionalities
within our Services—like placing bets, making purchases, or
competing in tournaments—we collect your payment information,
which could include your currency, credit card details,
payment methods, and bank account information.
-
Voluntarily Provided Information: We also obtain information
you voluntarily share with us, particularly from our VIP
customers. This could be through replies to our
communications, emails, or sharing details about yourself
while using our Services, such as during chats and games. It
includes info that you'd like us to know to enhance and
nurture our relationship, as well as to ensure you are
satisfied with our services (for instance, your marital
status, familial details, interests, or responses to surveys).
-
Device Information: We collect specific connection details and
information about your device, software, or hardware that may
facilitate your identification, such as unique device
identifiers (e.g., UDID, IMEI, and MAC address), browser
fingerprints, IP addresses, and geographic location data.
-
Telephone Conversations: We may record or monitor phone calls
for the purposes of customer support, training, and security.
-
Event Activities: During our events, we may conduct interviews
and capture photos and videos that could include attendees,
speakers, sponsors, or exhibitors. If we take photos and
videos that feature you in any of these roles, we might use
them for promotional activities. Additionally, your interview
could be utilized for such purposes as well (e.g., citing your
comments).
-
Social Networks: When you register using your social media
account (like Facebook) to access our Services or link your
player account to that account, we gain access to basic
information from your social network, which includes your
name, birth date, profile picture, and friend list, alongside
any publicly available information you have shared.
-
Moreover, while using our Services, you might have the option
to 'Invite a Friend' from your social network. If the invitee
accepts, we could receive Personal Information about them,
such as their name, email address, phone number, and date of
birth. We will utilize this Personal Information as described
here and share it with third parties only under the terms set
forth in this Privacy Policy.
-
Information from Third Parties: We collect Personal
Information from external service providers, such as data
about your credit history from credit bureaus and other
financial details pertinent to the Services we provide, as
well as information collected to confirm your identity and
prevent fraudulent or illegal behavior.
-
Non-personal Information
The second category consists of
non-identifiable information related to User(s) that might be
made available or collected based on the User’s usage of the
Services (termed “Non-Personal Information”).
Non-Personal Information encompasses technical and aggregated
usage data and may include, but is not limited to, details about
the user’s operating system, browser type, screen resolution,
browser and keyboard language, click-stream data, activities
within the Services, time spent on the Services, and related
timestamps.
To clarify, any Non-personal Information associated or linked
with Personal Information will be treated as Personal
Information as long as that linkage remains.
Here are some types of Non-personal Information we compile from
or about you:
-
Login activity and technical details: To enhance the services
and provide a more enjoyable user experience, we track
technical details shared by your device. This includes
specific software and hardware information such as the type of
browser and operating system you utilize, language
preferences, access times, and the domain names of referring
websites linking you to our Services.
-
Gameplay Data: We log information about your gameplay
activities, including details such as your deposits, bets,
bonuses acquired, the duration of gaming sessions, and your
highest scores. Such information may also be shared or
published across any of our Platforms.
-
Device and Connection Information: We gather data regarding
the specific device you are using for security purposes and
fraud detection. For example, we may collect details about
other software running concurrently with our Software to
identify if it’s associated with fraudulent activities (e.g.,
bots or malware) or if your connection is through a VPN or
proxy.
-
Analytical Data: We monitor your interaction with our
Services, gathering information about application usage, log
files, user activities (for example, which pages you view,
time spent on particular pages, online browsing behaviors,
clicks, and actions), timestamps, alerts, etc. This
information serves various purposes, including troubleshooting
issues and conducting research on how you use our Services.
-
Anonymous Data: We may anonymize or de-identify data collected
through the Services or any other means, ensuring that it
cannot identify you on its own. The use and disclosure of this
aggregated or de-identified data is not restricted by this
Privacy Policy, allowing us to share it with others without
limits and for any purpose, including advertising or
marketing.
CONDITIONS FOR PROCESSING PERSONAL INFORMATION
We will process your Personal Information for various reasons,
all of which adhere to applicable data protection laws.
-
To fulfill contractual obligations and comply with legal
requirements.
We must handle your Personal Information
when it's essential for fulfilling a contract, such as the
User Agreement, or to meet our legal and regulatory
obligations. This also includes ensuring that we adhere to the
terms of our gambling licenses and following any relevant AML
and KYC regulations.
-
Legitimate interests
We also manage your Personal
Information when we believe it's in our legitimate interests
or those of a third party, as long as it doesn't interfere
with your rights or interests. For instance, examples of such
processing include: (i) sharing your Personal Information with
our related companies due to organizational changes or for
administrative reasons; (ii) identifying and retaining data
related to individuals facing responsible gambling issues;
(iii) processing information to maintain network security and
prevent unauthorized access to our electronic communication
systems; (iv) protecting our Services' integrity by
investigating and reporting any suspicious betting behaviors
or fraudulent actions; (v) complying with industry
regulations; (vi) creating a personalized rewards program for
players; and (vii) sharing information with our consultants
and service providers, like auditors, to ensure adherence to
regulations and best practices.
-
Consent
Primarily, we process your Personal Information
to deliver our Services effectively. However, there might be
instances where we require your consent for such processing,
and in those cases, your information will be handled according
to your expressed wish. You will have the option to withdraw
your consent at any moment in writing.
-
Special Categories of Personal Data
Our handling of your
Personal Information may include sensitive data categories,
such as your ethnic or racial background (as specified in
Article 9 of the GDPR). We will manage this data and disclose
it to relevant authorities, like licensing or law enforcement
agencies, when necessary for applicable legal purposes,
including: (i) the prevention or detection of illegal
activities, (ii) deterring dishonest, unethical, or
exceedingly inappropriate behavior, provided that obtaining
your consent could jeopardize these objectives. We may also
process and disclose this information to protect your economic
well-being (like identifying individuals with responsible
gambling issues). Additionally, we or third-party agents may
handle your biometric data, derived from a photo you provide,
to fulfill our legal requirement of identity verification.
MINORS
Our Services are not intended for individuals below the age of
18, which is considered the minimum legal age for utilizing
these Services. If you are not of legal age, please refrain from
downloading, using the Services, or providing any Personal
Information.
We maintain the right to review and validate any Personal
Information that we collect from you. If we discover that a user
who is underage has provided information, we might discard that
data unless it is needed to uphold legal obligations. If you
suspect that a minor has given us their information, please
reach out to us (contact information can be found in the ‘HOW TO
CONTACT US?’ section).
WHAT DO WE DO WITH THE COLLECTED INFORMATION?
We utilize your Personal Information for the following reasons:
- To create, maintain, and refresh your account;
-
To facilitate and manage our Services effectively (including
betting and payment processing);
-
To engage with you and keep you up-to-date on the latest
developments and special offers related to our Services;
- To determine your VIP status;
-
To promote our Services (as further detailed under the
'Marketing' section), as well as to provide advertisements
tailored to you, including behavioral targeting and specific
event promotions;
-
To gather data for analytics, statistics, and research,
enabling us to enhance and better align our Services to meet
your preferences and interests (for example, by preparing
aggregated reports about the use of certain Service features);
-
For managing customer relationships, assisting with Service
support, and addressing your inquiries;
-
To help us develop, tailor, and enhance the Services based on
collective user behaviors and preferences;
-
To ensure that we provide a responsible gaming atmosphere;
-
To communicate with you and facilitate any requests you have
for exercising your User Rights;
-
To verify and authenticate your access to specific Service
features;
-
To identify and prevent fraudulent or illicit activities, or
any other behaviors that could compromise the integrity of our
Services, including assessing risks associated with your
activities on them;
-
To investigate any breaches of our policies or User Agreement
and ensure compliance with these guidelines;
-
To examine and resolve any disputes related to your Service
usage;
-
To support our regulatory compliance obligations, or as
mandated by law or regulations (including gambling laws, KYC,
and AML requirements), such as understanding your sources of
funds or income, responding to governmental inquiries, or
complying with subpoenas;
-
Furthermore, we process your Personal Information based on
your informed consent, particularly for specific marketing and
promotional efforts.
If you have not consented (or have
retracted your consent) regarding the processing of your
Personal Information, we may still process your data (a) when
needed for upholding the contract (i.e., the User Agreement)
between you and us; (b) to fulfill legal obligations we must
comply with; and/or (c) for legitimate interests of the
Company (including for security measures or marketing
initiatives).
MARKETING
The Group will use your
Personal Information—such as your name, residential address,
email address, and phone number—either ourselves or through
third-party contractors for sending promotional content related
to the Services and other products or services from our group
companies or business partners that may be of interest to you.
We may also share and reveal your Personal Information with our
Marketing Affiliates for delivering various marketing
propositions that we or our Affiliates consider pertinent to
you. Our Marketing Affiliates could use this data for diverse
marketing strategies, such as direct email campaigns, postal
mail, SMS, and telemarketing.
We will only use your Personal Information to provide
promotional content when there is a legitimate interest in doing
so or when we have your explicit consent.
At any point, you can opt-out of receiving further marketing
communications from us or our Marketing Affiliates by following
the instructions found in the promotional emails (like using the
unsubscribe link), visiting the 'My Account' section on our
website, or contacting customer support (details are provided in
the 'HOW TO CONTACT US?' section). Please be aware that even if
you unsubscribe from our marketing list, we may still send you
updates and notifications related to our services.
Additionally, you can manage certain advertising or social media
campaigns through settings provided by third-party platforms
(e.g., Facebook).
Furthermore, for any mobile applications downloaded from the
Apple App Store or Google Play, the only way to stop receiving
notifications is to adjust the settings on your device.
TARGETED ADVERTISING
We employ
third-party advertising technology to display advertisements
while you visit the Platform and utilize the Services. You have
the option to opt-out of numerous third-party advertising
networks, including those affiliated with the Network
Advertising Initiative (‘NAI’) and the Digital Advertising
Alliance (‘DAA’).
For additional details concerning these practices by NAI and DAA
members, as well as your options regarding the use of your
information by these companies—including how to opt-out of
third-party ad networks—please consult their respective
websites: http://www.networkadvertising.org/optout_nonppii.asp
and http://www.aboutads.info/choices.
WITH WHOM WE SHARE INFORMATION?
We do not
sell, rent, or otherwise share your Personal Information with
other parties (‘Recipients’) except as outlined in this Privacy
Policy. Personal Information will only be disclosed to
Recipients as required for the specific reasons detailed in this
Privacy Policy.
We may share your Personal Information with the following types
of recipients:
-
Any replacement service provider that we employ to manage the
Platforms;
-
Companies that are part of our Group and other associated
entities;
- Gaming providers;
-
Third party service providers and subcontractors (including,
but not limited to, cloud services, marketing partners,
identity verification and fraud prevention services, and other
validators);
Credit reporting organizations, often
referred to as credit reference agencies (CRAs), play a
crucial role in verifying personal details such as your name,
address, and age. To facilitate account creation for you, we
will share your personal information with these agencies, who
will then provide us with relevant details about you. This
information might include:
- Identity and contact data;
- Details from your credit application form;
-
Insights regarding your financial circumstances and past
financial activities;
-
Public records, which can include information from the
electoral roll;
- Shared credit details; and
- Fraud prevention information.
This process is implemented to confirm your identity, oversee
your account, and thwart potential criminal activities. We
provide additional information about the identity of these CRAs,
their function in fraud prevention, the kind of data they
manage, their method of utilizing and disseminating personal
information, how long they retain data, and your rights
concerning data privacy on their respective websites, as
outlined below:
-
TransUnion (formerly Callcredit):
https://www.transunion.co.uk/crain
- Equifax: https://www.equifax.co.uk/crain
- Experian: https://www.experian.co.uk/crain/
-
Payment facilitators, transaction processors, and banking
institutions;
-
Any external entities that deliver services pertinent to the
functioning or marketing of the Group’s brands;
- Any third parties that offer you physical rewards;
-
Organizations that host offline events or competitions on
behalf of or in collaboration with any associated companies
within the Group;
-
Accommodations and airline companies, particularly in the
context of offline promotions and events;
-
External auditors, contractors, or advisors in legal,
financial, or other fields concerning any business operations
of the Group;
-
Any external parties that investigate, identify, or avert
fraudulent or illegal actions, or support us in enforcing our
guidelines. This could include verifying your income sources
or financial resources (e.g., government bodies, law
enforcement agencies, banks, and other investigative
organizations). In this capacity, we share device-specific
identifiers, which may encompass personal information, with
iovation Inc., a reliable partner specializing in fraud
prevention solutions – for further details, please refer to
iovation Inc.'s privacy policy;
- Gambling addictions bodies;
-
Regulatory authorities and government bodies, complying with
relevant legal statutes and regulations;
-
Potential acquirers, successors, or investors in any of the
Group’s companies, especially during corporate transactions
(such as selling a substantial portion of our business,
merging, reorganizing, filing for bankruptcy, consolidating,
or transferring any asset). In such situations, the acquiring
entity will inherit the rights and responsibilities outlined
in this Privacy Policy.
Beyond the purposes specified in
this Privacy Policy, we may share your Personal Information
with recipients for additional reasons such as:
-
Storing this data on our behalf, for instance, by leveraging
cloud service providers;
-
Processing this information to aid in our business functions
(such as handling payments and your deposits, verifying your
access, auditing our activities, preventing and detecting
fraudulent or illegal actions, etc.);
-
Conducting research, technical diagnostics, or analytics;
-
Delivering targeted advertising along with promotional and
informational content in line with our marketing strategy
(refer to the section labeled ‘Marketing’ above); and
-
Whenever we genuinely believe that sharing this information is
vital to safeguard our rights or legal interests, implement
our regulations (including our User Agreement and Privacy
Policy), ensure your safety or the safety of others, along
with investigating or preventing fraudulent activities or
addressing security concerns, or assisting with other related
technical issues.
-
For users of our betting services based in Germany, personal
data will also be forwarded to SCHUFA, as detailed below:
-
The company sends personal data relevant to the initiation,
execution, and termination of the respective business
relationship to SCHUFA Holding AG, located at Kormoranweg 5,
65201 Wiesbaden, including data concerning any non-compliant
or fraudulent actions observed during this contractual
relationship.
-
The legal foundation for these data transfers is contained in
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 essential to
safeguard the legitimate interests of either the business
partner or a third party, and do not outweigh the data
subject’s fundamental rights and freedoms that necessitate the
protection of personal data. Exchanging data with SCHUFA also
fulfills legal responsibilities for conducting
creditworthiness evaluations of clients (Sections 505a and 506
of the Civil Code). This process encompasses fraud prevention
efforts as well.
-
SCHUFA processes the information received and employs it for
scoring purposes, providing its contractual partners within
the European Economic Area and Switzerland, as well as other
nations (where an adequacy decision by the European Commission
is applicable), with insights primarily for assessing
individual creditworthiness. Besides credit rating scores,
SCHUFA aids its business associates by creating profiles aimed
at identifying unusual patterns, particularly for fraud
prevention in mail order transactions. To achieve this,
inquiries from SCHUFA business partners are scrutinized for
potential irregularities. This calculation, which is tailored
for each specific business partner, may not only include
inquiries from the last ninety days but also integrate address
information, noting whether an entry in public records exists
involving matching identifiable details, as well as
consolidated statistical data from the SCHUFA database. This
methodology does not influence SCHUFA’s credit assessment or
the overall credit score.
-
For more detailed insights regarding SCHUFA's operational
practices, please consult the SCHUFA Information Sheet or
visit their website at www.schufa.de/datenschutz.
INTERNATIONAL DATA TRANSFERS
Given our
global operations, transferring your Personal Information to
countries outside the European Economic Area may be required for
service provision, strictly according to the specified purposes
outlined in this Privacy Policy. The legal standards for data
protection in these nations may not be as robust as those found
in the European Economic Area.
We strive to ensure that your Personal Information is adequately
safeguarded in line with our Privacy Policy, using contractual
arrangements (like standard contractual clauses approved by the
European Commission for data transfers, accessible here) or
alternative methods (ensuring jurisdictions recognized by the
European Commission are deemed to provide adequate levels of
protection, details of which can be found here).
For additional information about transferring your personal data
beyond the EEA, please reach out to us (our contact details can
be found in the ‘HOW TO CONTACT US?’ section).
THIRD PARTY TRACKING TECHNOLOGIES
When
you interact with our Services (for instance, accessing our
websites), we utilize (and permit third parties to use) web
beacons, cookies, pixels, scripts, tags, and similar
technologies (‘Tracking Technologies’).
These Tracking Technologies allow us to gather information
automatically regarding your online activities and device
characteristics (such as your computer or mobile device) for
various purposes, including enhancing your navigation through
our Services, improving the performance of our Services, and
personalizing your experience. This data is also employed to
compile usage statistics, conduct analysis, and deliver content
tailored to your preferences, while managing services for our
users, advertisers, publishers, customers, and partners.
We also permit third-party entities to gather information about
you using Tracking Technologies. For further details, please
consult our Cookie Policy.
THIRD PARTY SERVICES
While utilizing our
Services, you may come across links to third-party websites,
services, or applications. Please be aware that our Privacy
Policy does not extend to these external entities, even if they
can be accessed, downloaded, or otherwise accessed through our
Services.
It’s important to recognize that these third-party websites,
services, or applications operate independently of the Group. We
do not accept any responsibility or liability concerning privacy
issues or any other legal considerations related to these
external websites and services. We strongly recommend that you
carefully review the privacy policies and terms of service
associated with these third parties, as their regulations,
rather than our own, will govern any interactions you may have
with them.
Always ensure that you diligently examine their privacy
practices before sharing your Personal Information with these
external entities.
By engaging with any third-party websites, services, or
applications, you acknowledge and willingly accept all
associated risks. You agree that we bear no liability concerning
those third-party sites and your engagements with them.
RETENTION OF PERSONAL INFORMATION
If you
have created an account using our Services, the Group will
retain your Personal Information while your account remains
active. Furthermore, the Group will keep your Personal
Information for additional periods deemed necessary to comply
with legal obligations under relevant laws or regulations,
including applicable gambling, KYC, and AML regulations,
alongside fulfilling the Group's contractual commitments.
Moreover, the Group may store your Personal Information for
extended durations, provided such retention is essential for the
Group's legitimate interests, like preventing fraud, maintaining
records, ensuring responsible gaming, settling or asserting
claims in case of disputes, and where advised by relevant
supervisory authorities.
YOUR RIGHTS
Feel free to reach out to us
any time via email. You can find our contact information in the
‘HOW TO CONTACT US?’ section, and you may ask for:
-
Access to or deletion of any Personal Information that
pertains to you;
-
Modification or updates to any of your Personal Information
(for instance, if you think the information we have is
inaccurate, you can request corrections or deletion). It's
important to note that you can also ask us to rectify mistakes
in your Personal Information, unless your information must be
preserved in its original state due to relevant laws and
regulations;
-
A limitation or halt on the further use of your Personal
Information;
-
The Personal Information you provided to us in a format that
can be easily read by machines;
-
To raise an objection against the processing of your Personal
Information (such as in relation to marketing activities);
-
The withdrawal of your consent for our processing activities
(as long as those activities depend on your consent and not
another legal foundation);
-
To avoid being subjected to decisions made solely through
automated processes, which includes profiling, that result in
binding legal effects against you or similarly impact you
significantly, unless such processing is essential for the
fulfillment of the contract between us, or is based on your
explicit consent, as outlined herein.
Please be aware that these rights aren't absolute and any
requests must comply with relevant legal stipulations, including
those related to gambling and other legal or ethical
documentation retention requirements. Additionally, we retain
the right to edit, improve, or eliminate incomplete or erroneous
information at any point at our discretion, following our
internal protocols.
HOW WE KEEP YOUR INFORMATION SECURED
We
are committed to ensuring the protection of our Services and
your information. To this end, we have established various
physical and technical safety measures to prevent unauthorized
access, uphold data protection, and ensure appropriate use of
the information we gather online. These protective measures are
tailored according to the sensitivity of the data we collect and
maintain.
We utilize standard industry practices and controls to safeguard
the information belonging to our users, such as:
-
A secure network architecture, which encompasses systems for
preventing intrusions and firewalls;
- Encrypted communication;
- Authentication and Access Control;
-
Conducting both external and internal auditing tests; among
other measures.
Even though we take significant precautions to secure
information, we cannot be held accountable for the actions of
individuals who access our Services unlawfully or misuse them,
and we do not guarantee that we can completely prevent such
breaches.
CHANGES TO THE PRIVACY POLICY
We have the
right to amend this Privacy Policy at any time, so it's
advisable to check this page often. We will do our best to
inform you in advance of major modifications to this Privacy
Policy. Substantial changes will take effect within a reasonable
timeframe after we have provided such notification, as specified
in the notice. For all other alterations to this Privacy Policy,
they will be effective as of the date marked as “Last Revised,”
and your continued engagement with the Services after this date
indicates your acceptance of the new terms.
