PRIVACY & COOKIE NOTICE
Version number 2.0 Dated 12th June 2020
This notice together with the General Terms and Conditions available on the site sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting and opening an account on our site you are accepting and consenting to the practices described in this policy.
Zecure Gaming Limited, a Maltese company having its registered address at ‘Betsson Experience Centre’, Ta’ Xbiex Seafront, Ta’ Xbiex, XBX 1027, Malta, is the data controller for your personal data.
When we mention “COMPANY”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company within the corporate group of companies that Zecure Gaming Limited belongs to, that is the Betsson Group (hereinafter referred to as the “Group”) that may be involved in the processing of your data to provide a particular service to you.
We have appointed a data protection officer (DPO). If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO on [email protected].
Information we collect About you
We will collect and process the following data about you:
· Information you give us. This is information about you that you give us by filling in our forms on our site or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, subscribe to our service, make deposits, bets or withdrawals on our site, participate in chat rooms, accept bonuses or other promotions available on our site, any due diligence documentation you share with us, including the source of wealth questionnaire and supporting documentation, and when you report a problem or make a complaint with us. The information you give us may include your name, username, address, date of birth, country of residence and nationality, identification number, e-mail address, and phone number, financial and credit card information, personal description, proof of identification, proof of address, proof of funds and photograph.
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the games or payment services). In this case, we may have to close your account.
· Information we collect about you. With regard to each of your visits to our site we will automatically collect the following information:
– technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
– information about your visit, including the full Uniform Resource Locators (URL), games you played and duration on each game and page, page interaction information.
– Information received from cookies. Please refer to our Cookie Notice for further details on the types of cookies in use.
· Information we receive from other sources. This is information we receive about you if you use any of our websites or services operated by entities within the Group or in reliance of licences held by different entities within the Group. In the event that you use accounts on multiple sites operated by the Group we may collate information about you generated from each site in one data repository. Such data is important to us for statistical purposes, but also particularly relevant within the context of our Anti-Money Laundering and Responsible Gambling responsibilities as arising out of law.
· During the course of delivering services to you, we are also working closely with third party data processors (including, for example, business partners, sub-contractors in technical, payment and delivery services as well as for delivery of marketing information (such as CRM Tool Providers, Email Marketing Partners, SMS Providers, Direct Mail Distributors and Outbound Call providers,) advertising networks and affiliate networks, analytics providers, due diligence intelligence companies, search information providers, credit reference agencies). This category includes information we receive from our Publishers, Advertisers and other Partners that we work with to help us deliver ads and personalized content to you and recognize you across browsers and devices. This may include pseudonymous advertiser identifiers that some Advertisers or other third-party ad platforms choose to share with us. Data processors process personal data according to our written instructions and their activities will be limited to those that are needed from them to assist us deliver the service to you.
· We may also receive personal information about you from the brand owner. For the purposes of transparency, brands may be owned by entities other than the data controller, and all information acquired through those brands will be accessible to the brand owners to whom we give access to our platform containing your personal data.
Categories of Data Held About You
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
The personal data collected and processed on you can be grouped into the following categories:
· Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, employment status and occupation.
· Contact Data includes residential address, email address and telephone numbers.
· Financial Data includes details of your salary and wealth, details of the sources of funds used to deposit with us, as well as bank account, payment card or payment account details, including information contained within any bank statements, payslips and similar documentation collected for KYC Purposes.
· Transaction Data includes details about deposits and withdrawals, wagering and other details of games you have played on our sites.
· Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
· Usage Data includes information about how you use our website, products and services, your username and password (encrypted), games played, login, logout times, duration of play, bonuses and promotions claimed, responsible gaming and AML classification.
· Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
In fulfilment of our legal obligations, we must also collect Special Categories of Personal Data about you such as details about any political or government positions you hold pursuant to our AML and due diligence obligations.
Uses made of the information (Purpose)
· Information you give to us. We will use this information:
– to carry out our obligations arising from the terms and conditions entered into between you and us and to provide you with gaming services that you request from us, to accept your deposits and process your withdrawals, to carry out fraud management processes, to answer to any query or complaint that you may have as well as other ancillary matters related to the main services we are providing to you;
– provided that you have granted consent to contact you with marketing information, to provide you with information about our services, bonuses schemes and promotions and information about the products and promotions, present or future, offered by the brand with whom you hold an account
– provided that you have granted consent to contact you with marketing information from our group companies, to provide you with information about our services, bonuses schemes and promotions and information about the products and promotions of related and group entities within the Group;
– to provide customised advertising on the site based on your interactions with the site or your Usage Data;
– to notify you about changes to our service;
– to ensure that content from our site is presented in the most effective manner for you and for your computer.
– to meet obligations arising from Anti-Money Laundering Legislation and rules and regulations thereunder and all other laws that we may be subject to from time to time.
· Information we collect about you. We will use this information:
– to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes. Such information will typically be collected through the use of Cookies. For more information on Cookies please refer to our Cookie Notice which also provides guidance on the manner in which Cookies may be disabled;
– to carry out fraud management and risk management activities, including assigning a risk profile or a risk status to your account;
– to assess your behaviour and patterns through the site which will be used to help build a detailed customer profile on you, on different subject matters, including but not limited to:
· A register of bonus abusers may be created by the company and persons on this list may be excluded from any future promotions or even blocked from using the services of the Company. This includes as well analysis of other types of fraud and fraudulent behaviour.
· We will also screen and monitor your transactions and behaviour for reasons of responsible gambling, ensuring that your interaction with us remains fun and entertainment and not dangerous to you. We may assign a Responsible Gambling score to your account based on the information we collect, which may at times be made available to you through your account. As a result of our assessment you may be tagged as a ‘Problem Gambler’ or vulnerable to the risks of gambling addiction.
· As part of our commitment to prevent money laundering and terrorist financing, we also analyse your personal data and compare it to third party data sources, build an AML profile on you and risk score your account based on the information you have provided to us and the information we have collected about you. We shall also keep a register of all high risk customers from an Anti-Money Laundering perspective.
· Please note that for these purposes we use profiling, however logic behind the profiling and information about it cannot be revealed since it would enable customers to bypass these control mechanisms aimed at the protection of Our business and compliance with legal obligations.
– to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
– to allow you to participate in interactive features of our service, when you choose to do so;
– as part of our efforts to keep our site safe and secure;
– to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant promotions to you;
– to make suggestions and recommendations to you about our products.
– We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
· Information we receive from other sources. We will combine this information with information you give to us and information we collect about you. We will use this information and combined information for the purposes set out above (depending on the types of information we receive). Other sources include third party service providers of age verification tools, identity or address verification services, regulators or entities that keep central databases of problem gamblers, providers of PEP and Sanction searches, and other similar providers who we may contract with from time to time. We may also receive information from companies within the Group about you which helps us deliver a better service to you or to keep away bonus abusers, problem gamblers from our services.
Creation of a User Account
All the information that we hold about you, whether provided to us by you, whether we have collected it from you or from third parties, is collated into one user profile (Player Account) that we create on you.
Lawful Basis for Processing of Personal Data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
| Purpose/Activity | Category of data | Lawful basis for processing including basis of legitimate interest |
| To register you as a new customer | (a) Identity
(b) Contact (c) Usage |
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation |
| To provide gaming services to you
(a) Manage deposits and withdrawals; (b) Deliver games to you |
(a) Identity
(b) Contact (c) Financial (d) Transaction (e) Marketing and Communications |
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation |
| To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy (b) Maintain a Player Account with us. |
(a) Identity
(b) Contact (c) Usage (d) Marketing and Communications |
(a) Performance of a contract with you
(b) necessary to comply with a legal obligation |
| To enable you to take part in a promotion | (a) Identity
(b) Contact (c) Usage |
(a) Performance of a contract with you;
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
| To inform you about a promotion/bonus or other offer | (a) Identity
(b) Contact (c) Usage (d) Marketing and Communications |
(a) Consent |
| To carry out segmentation and analysis | (a) Identity
(b) Contact (c) Usage (d) Marketing and Communications |
a) Necessary for our legitimate interests (such as being able to categorise customers as VIPs, knowing which customers are sportsbook customers as opposed to casino customers so as to receive relevant content and advertising)
b) Necessary to comply with a legal obligation (to prevent money laundering, fraud, and to fulfil our responsible gaming and social responsibility obligations) |
| To administer and protect our business and this website from any illegitimate activities, including money laundering, fraud, collusion and similar activities | (a) Identity
(b) Contact (c) Technical (d) Special Categories of Personal Data |
(a) Necessary to comply with a legal obligation (to prevent money laundering, fraud, collusion) |
| To analyse and study player behaviour, communications, depositing and player patters to determine whether you display any responsible gaming problems | (a) Identity
(b) Contact (c) Usage (d) Special Categories of Personal Data |
(a) Necessary to comply with a legal obligation (to prevent money laundering, problem gambling) |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity
(b) Contact (c) Technical |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation (to safeguard client funds) |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity
(b) Contact (c) Usage (d) Marketing and Communications (e) Technical |
(a) Necessary for our legitimate interests (to deliver relevant products to you through the site based on your past activity and preferences) |
| To use data analytics to improve our website, products, marketing, customer relationships and experiences | (a) Technical
(b) Usage |
(a) Necessary for our legitimate interests (to define types of customers for our products, to keep our website updated and relevant and to develop our business) |
Disclosure of your information
You agree that we have the right to share your personal information with:
· Any member of the Group which requires access to your personal information in order to provide the services you request. Data we receive and collect on you will be shared with our group companies and such data may be used by them for fraud and bonus abuse prevention, AML and Responsible Gaming Reasons in fulfilment of the Group’s legal obligations and legitimate business interests;
· To all members within the Group for the purposes of such other group entities to contact you with information on their products and services, provided that you have consented to receive direct marketing from group entities.
· Selected third parties, under a data processing agreement with us that ensures the safeguard of your personal information, including:
– the owner and/or operator of the site in the event that the site is owned by a company other than the Group. These persons would require your personal data in order to provide first line support or to answer initial queries and complaints from you. Where you consent to receiving direct marketing, the owners of such third party sites will also use your personal information to provide targeted advertising to you, run promotional campaigns, run behavioural advertising, and contact you in relation to the products and service, present and future.
– The supplier of the platform management system;
– With game suppliers who deliver gaming products on our sites who require such data in order to allow you to participate in a game and to determine the outcome of the game;
– Where you consent to receiving direct marketing material from us, to advertisers and advertising networks that require the data to select and serve relevant adverts to you and others, including promotional emails and SMS’, direct mail, and at times to makes calls to you.
– analytics, business intelligence partners and search engine providers that assist us in the improvement and optimisation of our site;
– credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you;
– suppliers of age and identity verification tools and other suppliers that can verify know your client information generally;
– with our banks or payment service providers or payment gateways in order to be able to complete payment instructions to you;
– with our lawyers, advisors, consultants who we may engage from time to time to advise on any matter which requires them to gain access to personal information;
– with any person, company, NGO, governmental body, regulatory authority that maintains a register of problem gamblers or for any other responsible gaming purpose.
– with any person, company, NGO, governmental body, regulatory authority that maintains a register or database having the objective of preventing crime, money laundering or terrorist and proliferation financing.
– in the event that we agree to transfer our business relating to this site, in which case we will disclose your personal data to the prospective buyer or their lawyers, consultants, financial advisers and employees both during the due diligence process and also as part of the transfer of the business. This includes any transfer of data required under any agreement between us and the owner and/or operator of the site on termination of our services by the owner and/or operator of the site.
· If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions and other agreements; or to protect our rights, property, or safety. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Where we store your personal data
· Primarily, the data we collect from you will be stored on servers in Europe. However, the data that we collect from you will be transferred/or accessed by third parties as mentioned in earlier parts of this policy and such data will therefore be stored/accessed by them. Some of the third parties that we share data with may have their servers at a destination outside the European Economic Area (“EEA”). It will also be processed by staff or company representatives operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy and that the persons we are sharing data with employ similar organisational and technical measures as us. When personal data is transferred outside the EEA we will seek to take additional steps such as entering into EU Standard Contractual Clauses.
· All information you provide to us is stored on our secure servers.
· Any payment transactions will be encrypted using SSL technology.
Your rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
· Request access to your personal data. You have the right to access information held about you. Some of the personal data held about you can be accessed by logging into your account. Additional information may be requested by contacting us on [email protected]. We shall comply with any reasonable access request. In the events that the access request involves a disproportionate amount of work, we reserve the right, in line with applicable law, to charge a fee covering the work involved. Please note that there are some legal limitations where we will not be able to provide you with all the data such as where this would be in conflict with other rights (third party right to privacy, trade secrets, etc), where we would be legally precluded (AML investigations, AML/TF/RG risk analysis) or where that would jeopardize our legitimate interests (risk analysis and scores in fraud prevention).
· Request correction of your personal data. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
· Request erasure of your personal data. You have the right to ask us to delete any information we hold about you which is not relevant to purpose for which we collect it. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You may also request for us to delete all your personal data, in which case we ask you to close your account. There may be legal obligations which may prohibit us from deleting all or any information held about you immediately at the time of the request (such as Anti-Money Laundering legislation), however we will process your request at the earliest opportunity whenever any applicable data retention period expires.
· Object to processing of your personal data. You have a right to object to our processing of personal data where we are relying on a legitimate interest (or those of a third party). You also have the right to object where we are processing your personal data for direct marketing purposes on ground of legitimate interest (as opposed to consent). You may also object to us showing you targeted ads on our site, in which case you will not see any less ads but you will see ads that are less relevant to your interests. When you object to processing based on legitimate interest, in each case we will have to evaluate your objection and see if we have compelling legitimate grounds to process your information which override your rights and freedoms (except for processing for direct marketing purposes).
· Request restriction of processing your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; or (b) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it; or (c) where you contest that our use of your personal data is unlawful.
· Request transfer of your personal data (data portability request). This enables you to request your personal data. We will provide to you, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
· Right to withdraw consent from direct marketing. You have the right at any time to change your mind in relation to us being able to contact you with direct marketing. You can exercise your right to stop receiving direct marketing by accessing your account and unticking the consent boxes related to direct marketing or by contacting customer support. You may also unsubscribe by following the unsubscribe instructions on the communication itself. Any withdrawal of consent from the processing of personal data for marketing purposes will apply for the site you make the request through. If you maintain accounts with various brands operated under the licences of the Group, you will need to withdraw consent on each of the sites on which you have an account. Alternatively, you may contact us on [email protected] and we will apply your preferences across all our sites.
· Right to Complain – You have a right to complain about our practices by lodging a complaint with the Information and Data Protection Commissioner on https://idpc.org.mt/en/Pages/contact/complaints.aspx.
· We will retain copies of any communications that you send to us (including copies of any emails) in order to maintain accurate records of the information that we have received from you.
· You can also exercise your rights at any time by contacting us at [email protected] All communications with us must be through the e-mail address that is associated with your account. We will verify your identity prior to responding to any request.
Time Limit to Respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Data Retention
We have to retain all basic information about you required by the law (such as AML or Gambling laws) of any jurisdiction or otherwise required by us for the purposes of defending any current or future legal claims.
You can ask us to delete your data by closing your account. In that case, where feasible, we will immediately delete all information aside from that which we are required to maintain to fulfil our legal obligations as indicated above.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Cookies
Our website uses cookies. A cookie is a small file of letters and numbers that we put on your computer. These cookies allow us to distinguish you from other users of our website, which helps us to provide you with a good experience when you browse our website and also allows us to improve our site.
For more information on Cookies, please see our Cookie Notice below.
On-Site Advertising
From time to time, we may place on-site advertising using information you make available to us when you interact with our sites, content, or services, based on your consent. On-site ads, also sometimes referred to as personalised or targeted ads, are displayed to you based on information collected through cookies.
You can choose not to receive on-site ads from us. You will still see ads but they will not be personalised. Please visit your Account page to modify the advertising settings.
Further, as described in the Cookie Notice below, you may modify the settings in most browsers to notify you when you receive a new cookie and disable cookies altogether.
Advertising on Third Party Sites
We use third parties who collect data about their apps’ and sites’ visitors through their own cookies, web beacons, and other technologies regarding your online activities, in an effort to understand your interests and deliver you advertisements that are tailored to your interests. We purchase ad space on third party sites and our ads may appear when the third party determines that our ad is relevant to your interest according to the information they have collected.
We do not provide any personal information to advertisers or to third party sites that display our interest-based ads, however they may have collected certain personal information from you through the use of their site (such as articles read, types of ads clicked etc.), or through data analytics platforms (such as Google Analytics – see Cookie Notice for more information) and they may therefore customise advertising material published on their site according to your interests.
Third party advertisers or advertising companies working on their behalf sometimes use technology to serve our advertisements. They automatically receive your IP address when this happens. They may also use cookies to measure the effectiveness of their advertisements and to personalise advertising content.
We do not have access to or control over cookies or other features that advertisers and third-party sites may use, and the information practices of these advertisers and third party websites are not covered by our Privacy Notice. Please contact them directly for more information about their privacy practices.
Changes to our privacy policy
Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy. In the event that you do not agree with any changes, we recommend that you contact customer support or otherwise close your account.
Cookie notice
Our website uses cookies. A cookie is a small file of letters and numbers that we put on your computer. These cookies allow us to distinguish you from other users of our website, which helps us to provide you with a good experience when you browse our website and also allows us to improve our site.
How to Control Cookies
You can manage cookie usage through your browser settings. The help function in your preferred browser should provide you with the correct information. Some browsers provide helpful cookie guides:
Alternatively, http://www.allaboutcookies.org provides advice on how to do this, and further information on cookies and how to manage them.
In addition Google Analytics provides its own opt-out options: http://tools.google.com/dlpage/gaoptout
N.B. In the case of some mobile devices, it may be necessary to consult the device’s instruction manual to manage cookies effectively.
| Cookie Classification | Description |
| Strictly necessary cookies | These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website.
Please note that strictly necessary cookies cannot be disabled. Blocking these cookies will prevent registration/authentication to the site and will make some content/functions unavailable. |
| Performance cookies | These cookies collect information about how customers use a website, for instance which pages customers go to most often, and if they get error messages from web pages. These cookies don’t collect information that identify a visitor. All information these cookies collect is aggregated and therefore anonymous. |
| Functionality cookies | These cookies allow the website to remember choices you make such as your username, language or the region you are in and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages you can customise. They may also be used to provide services you have asked for such as watching videos or commenting on a blog. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites. |
| Targeting/advertising cookies | These cookies record your visit, the pages you have visited, the games you have played, the financial transactions you have made, and your general behaviour on the Website. These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of time you see an advertisement as well as help measure the effectiveness of the advertising campaign. We will use this information to make our website and the advertising displayed or received by you more relevant to your interests. We may also share this information with third parties for this purpose who assist us in analytics. |
Third Party Cookies
Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies. The table below identifies those cookies that are third party cookies.
An example of a third-party website that may use cookies on our site are our suppliers of Games. We feature games on our site that are provided by third parties. Therefore you may receive a cookie from the third party whilst playing their games. Furthermore, if you use any of our ‘Share’ tools to share our content outside our sites (such as with Facebook), you may be sent cookies from these websites.
We don’t control the setting of these cookies, so it is recommended to check the third-party website for more information about their cookies and how to manage them.
Cookies Behaviour
Session Cookies
Session cookies are created temporarily when a user visits a website. Once the user leaves the site/closes the browser, the session cookie is deleted.
Persistent Cookies
A persistent cookie file remains on the user’s device and is re-activated when the user visits the website that created that particular cookie. These cookies expire after a certain period (set in the file), or can be removed manually.
We use both Session and Persistent Cookies as indicated under the section “Cookies Used” in the column Expiration Time.
For a full list of cookies used please click here.
Contact
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to [email protected].