This Social Casino platform ("Company", "we", "our" or "us") operates the offering of social casino-style games through its proprietary website, its subdomains and its related features ("Website") (together as the ("Services")).

The platform is dedicated to protecting your privacy rights and making our practices regarding your Personal Information more transparent and fair. This Privacy Notice ("Notice") is designed to help you understand how we collect, store, use and share your Personal Information. This Notice applies whenever you visit our Website or otherwise access or use any of our Services.

Specifically, this Notice describes –

1. What types of data we collect?
2. Tracking Technologies
3. Why we collect your Personal Information?
4. With whom we disclose your data?
5. Marketing and Advertising
6. Your rights
7. International Transfer Of Personal Information
8. Retention of Personal Information
9. Security
10. Minors
11. Updates to this Notice
12. Contact Us

We strongly urge you to read this Notice and make sure that you fully understand and agree to it. If you do not agree to this Notice, please discontinue and avoid using our Services. You have the right to cease using our Services, pursuant to this Notice, at any time.

You are not legally required to provide us with any Personal Information, but without it we will not be able to provide you with the full range or with the best experience of using our Services.

This Notice is integrated into and forms part of the Terms and Conditions.

What types of data we collect?

We collect Personal Information about you, meaning any information which potentially allows your identification with reasonable means (for example, email address or name, collectively "Personal Information"). This section sets out how and when we collect and process Personal Information about you. The information provided shall be used for the identification of the user and for account management by us.

1.1. Account Information.  If you choose to register an account with our Services, we collect your full name, email address, password, phone number, birthdate and user nickname, as well as voluntary information, such as your profile picture. If you choose to log in, access or otherwise connect to the Services through a social networking service (such as Facebook, Twitter, Instagram, etc.), we may collect your user ID and/or username associated with that social networking service, as well as any information you make public using that social networking service or that the social networking service allows us to access.

1.2. Usage Information. When you use our Services, we collect technical information about your interaction with our Services. Such information may include gameplay recordings, geolocation data, IP address, unique identifiers (e.g. MAC address and UUID), as well as other information which relates to your activity in the Services.

1.3. Communication Information. When you send us an email or contact us via the support in our Website, we collect the Personal Information you provide us to communicate and provide you with necessary information for your experience. This may include your name, email address and any other information you choose to provide.

1.4. Participant Behaviour and Game Play Information. We process your information on participation history, session duration, and behavioural monitoring. We process participant behavior information for the prevention of fraud, ensuring safe gaming environment, improvement of quality of service and customer recommendations.

1.5. Identification Documentation. We collect and store uploaded documents in order to identify users, to process your requests and/or to comply with effective security regulations. These documents are also used for the purpose of prevention and detection of fraud.

Tracking Technologies When you visit or access our Services, we use cookies, pixels, beacons, local storage and similar technologies ("Tracking Technologies"). These allow us to automatically collect information about you, your device, and your online behaviour, in order to enhance your navigation in our Services, improve our Services performance, perform analytics, customize your experience, and offer you, for example, tailored content and advertisements that better correspond with your interests.

Tracking Technologies may be placed by us or by third parties such as analytics providers, who run content on our Services.

We use the following categories of Tracking Technologies:

• Strictly Necessary Tracking Technologies - these Tracking Technologies are automatically placed when you access our Services and are essential to enable you to navigate around and use the features of our Services.
• Functionality Tracking Technologies - these Tracking Technologies allow our Services to remember choices you make (such as your language) and provide enhanced and personalized features. For example, these Tracking Technologies are used for authentication (to remember when you are logged-in) and support other features of our Services.
• Performance Tracking Technologies - these Tracking Technologies collect information about your online activity (for example the duration of your visit on our Services), including behavioural data and content engagement metrics. These Tracking Technologies are used for analytics, research and to perform statistics (based on aggregated information).
• Marketing Tracking Technologies - these Tracking Technologies are used to deliver tailored offers to you, based on your derived interests, as well as to perform email marketing campaigns. They are usually placed by our advertisers (for example advertising networks) and provide them insights about the people who see and interact with their ads, visit their websites or use their app.

You can manage your Tracking Technology preferences through your device or browser settings, also you may opt-out of many third-party ad networks, including those operated by members of the Network Advertising Initiative ("NAI") and the Digital Advertising Alliance ("DAA"). Please note that disabling some cookies may affect the functionality of the Services.

Why we collect your Personal Information?

This section explains for what purposes we use your Personal Information.

Purpose and Scope of Collected Information

Provision of our Services; support and customer relation. We use your Personal Information, such as your name and email address, for consumer services purposes. This includes, for example, responding to your inquiries.

Improve our Services. We collect and analyse information about you and your usage of our Services to improve the usability and effectiveness of our Services based on your common preferences and uses.

Marketing, Advertising and Analytics. We may use Tracking Technologies (which may collect Personal Information) in order to provide you with personalized marketing when you visit our Services, including personalized and non-personalized messaging, as part of your current interaction with us or collect your Personal Information to send you direct marketing communications (e.g., email). In addition, we may use your Personal Information for certain marketing and promotional activities as well as gather aggregate usage information for analytics, statistical and research purposes.

Prevention of fraud or violation of our policies. We may process your Personal Information to detect and prevent fraudulent and illegal activity or any other type of activity that may jeopardize or negatively affect the integrity of the Service, including by identifying risks associated with your activity on our Service. We may also investigate any violations of our policies and enforce them.

Dispute resolution and protection of our legal claims. We collect your Personal Information in order to investigate violation of our policies, enable us to resolve disputes in connection with your use of the Service and to establish and defend our legal claims.

Integrity. We may process certain information about you and your use of the Service in order to keep the integrity and security of the Services, prevent fraud, identify your identity and enforce our policies.

Compliance with applicable laws. We process your Personal Information in order to comply with our legal obligation under applicable laws, including your location data.

Legal Basis

The legal bases for processing this data are the performance of our contractual obligation towards you; your consent (where required) for example, when you agree to provide Personal Information by accepting our Cookie Notice, Notice and Terms of Use), compliance with our legal obligations; and our legitimate interests. Our legitimate interests in this case are enforcing our policies, protection against fraud and misuse of our Services.

The legal basis for processing this data is our legitimate interest. Our legitimate interests in this case are providing and improving our Services.

The legal bases for processing this data are your consent (where required) and our legitimate interests. Our legitimate interests in this case are providing you with tailored services, content and advertisements that better fit your interests and promoting our Services.

The legal basis for processing this data is our legitimate interests.

The legal basis for processing this data is our legitimate interests. Our legitimate interests in this case are to protect our platform and other users against fraud.

The legal basis for processing this data is our legitimate interests. Our legitimate interests in this case are to establish and defend our legal claims.

The legal bases for processing this data are compliance with our legal obligations and our legitimate interests. Our legitimate interests in this case are keeping the integrity of our Services and the safety of our end-users.

Our legal basis for processing such data is compliance with our legal obligations we may be required to collect, retain, or share your Personal Information under applicable laws.

Providing users with a fair, balanced, and competitive experience on our Services is extremely important to us. Therefore, we strictly enforce prohibitions against cheating, hacking, account stealing, and any other unauthorized or fraudulent activity. When you create an account, play our games, or otherwise interact with our Services, we may use a variety of anti-cheat and fraud prevention technologies to help us identify and prevent malicious activity. These services may collect and analyse data about the game binary or your computer to detect cheating and may be provided by us or by third party service providers.

Where you have not consented (or have withdrawn your consent) to the processing of your Personal Information by us, we may continue to process your Personal Information: (a) where processing is required for the performance of the contract (i.e. the Terms of Use) between you and us; and/or (b) where processing is necessary for compliance with a legal obligation to which we are subject; (c) where processing is necessary for the purposes of a legitimate interest of the platform and its affiliates (including for marketing).

With whom we disclose your data?

We do not sell or share your Personal Information with third parties for cross-context behavioural advertising. However, note that we may disclose your Personal Information described below:

In addition to the purposes listed in this Notice, we share Personal Information with those Recipients for any of the following purposes:

• Storing such information on our behalf, for example by using cloud computing service providers;
• Processing such information to assist us with our business operations (e.g. to authenticate your access; auditing our operations; detect and prevent fraudulent or illegal activity; etc.).
• Performing research, technical diagnostics or analytics;
• Communicating targeted advertising, as well as promotional and informational materials, in accordance with our marketing policy (see below, under "Marketing");
• Whenever we believe in good faith that disclosure is necessary to protect our rights or legal claims, enforce our policies, protect your safety or the safety of others, as well as to investigate or prevent any fraud, for security reasons or to help us with any other related technical issue.

Marketing and Advertising

We may use your Personal Information ourselves or by using our third-party subcontractors for the purpose of providing you with in-app promotional materials concerning the Services as well as products, services, websites and applications which relate to: (i) affiliated companies or (ii) our business partners and affiliates (collectively, "Marketing Affiliates"), which we believe may interest you.

These communications may be delivered through various channels, such as email, in-app notifications. We may also send you SMS upon obtaining your prior explicit consent.

You may at any time decline receiving further marketing offers from us or from our business partners and Marketing Affiliates by following the unsubscribe instructions provided in the message or by contacting us.

Please note that even if you unsubscribe from our marketing mailing list, we may continue to send you in-app service-related updates and notifications.

Your rights

Depending on the jurisdiction in which you reside, you may have certain rights under relevant applicable laws regarding the collection and processing of your Personal Information. To the extent these rights apply and concern you, you can contact us via the contact details available below and ask to exercise the following rights.

6.1. Rights of access to your Personal Information: You have the right to receive confirmation as to whether or not Personal Information concerning you is being processed and access your stored Personal Information, together with supplementary information.

6.2. Right of data portability: You have the right to request us to move, copy and transfer your Personal Information easily from one IT environment to another, in a safe and secure way, without affecting its usability.

6.3. Right of rectification: You have the right to request rectification of your Personal Information in our control in the event that you believe the Personal Information held by us is inaccurate, incomplete or outdated (except in cases where the information is required to be kept in its original format under any applicable laws and regulations).

6.4. Right of deletion/erasure: You have the right to request us to erase or delete Personal Information held about you at any time. You are, however, advised that with the deletion of your Personal Information, you might not be able to use the Service anymore or the account might be totally closed.

6.5. Right to limit use and disclosure of your sensitive Personal Information: You have the right to request to limit the collection of your sensitive Personal Information, to that use which is necessary to perform our Services.

6.6. Right to lodge a complaint: All requests, complaints or queries may be addressed to us with the subject 'Privacy'. We will consider any requests, complaints or queries and provide you with a reply in a timely manner. You also have the right to lodge a complaint with a supervisory authority. The list of supervisory authorities, and their contact details, can be found at https://www.edpb.europa.eu/about-edpb/about-edpb/members_en.

6.7. Right to restriction of processing objection to processing and withdrawal of consent: The participant may at any time request that we restrict or cease to conduct certain data processes provided that there exists no other lawful basis on which we are authorized to process said data.

6.8. Right to opt-out of the sale or share of Personal Information: In the event that we sell or share your Personal Information for behavioural advertising purposes, you have the right to submit a request to opt-out of the sale or share of your Personal Information. After you opt-out, we may continue disclosing some Personal Information to our partners to help us perform business-related functions such as, but not limited to, providing the Services, ensuring that the Services are working correctly and securely, providing aggregate statistics and analytics and preventing fraud.

Please note that these rights are not absolute and may be subject to our own legitimate interests, restrictions and regulatory requirements. You are welcome to contact us for any questions or requests through our contact details below. We take our obligations seriously and we ask that any concerns are first brought to our attention, so that we can try to resolve this.

We will make an effort to reply within a reasonable timeframe. Please feel free to reach out to us at any time. If you are unsatisfied with our response, you can lodge a complaint with the applicable data protection supervisory authority.

Authorized agent

(a) You can use an authorized agent to make a request to exercise your right under applicable laws on your behalf if: i. The authorized agent is a natural person or a business entity; and ii. You sign a written declaration that you authorize the authorized agent to act on your behalf. If you use an authorized agent to submit a request to exercise your right, please provide us with a certified copy of your written declaration authorizing the authorized agent to act on your behalf using the contact information below.

(b) The request must: i. Provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Information or an authorized agent. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you; and ii. Describe your request with sufficient details to allow us to properly understand, evaluate, and respond to it.

(c) We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

(d) Making a verifiable consumer request does not require you to create an account with us.

International Transfer Of Personal Information

Since we operate globally, it may be necessary for the provision of our services and to the extent required for the specific purpose, as stipulated in this Notice to transfer your Personal Information to countries outside the European Economic Area ("EEA"). The data protection and other laws of these countries may not be as comprehensive as those in the EEA, in these circumstances we will take reasonable steps to ensure that your Personal Information is protected in accordance with this Notice through contractual means (such as by using the standard contractual clauses approved by the relevant European Commission for data transfer, as available here) or other means (such as ensuring that the European Commission decisions determined that such jurisdictions offer an adequate level of protection as available here).

For more information about the international transfer of your Personal Information, our contact details are available under the section below "CONTACT US?".

Retention of Personal Information

If you have registered with an account through our Services, we will retain your Personal Information during the period your account is active. In addition, we will retain your Personal Information for additional periods, to enable us to meet our legal obligations under applicable laws or regulations.

In addition, we may retain your Personal Information for longer periods, provided that retaining such information is necessary for our legitimate interests, such as fraud prevention and record keeping. We will keep any relevant Personal Information that we may need to defend ourselves against any claim(s), challenge(s) or other such action(s) by you and/or third parties for such time as it is necessary. Where your Personal Information is no longer required by us, we will either securely delete or anonymize the Personal Information in question.

If for any reason you wish to delete your Personal Information, please send us an e-mail, and we will make reasonable efforts to address your request.

Security

We have implemented commercially reasonable administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your Personal Information. While we seek to protect your information to ensure that it is kept confidential, we cannot guarantee the security of any information. You should be aware that there is always some risk involved in transmitting information over the internet and that there is also some risk that others could find a way to thwart our security systems. Such breaches can lead to things such as reputational harm, fraud or identity theft. Therefore, we encourage you to exercise discretion regarding the Personal Information you choose to disclose. If you feel that your privacy was treated not in accordance with this Notice, or if any person attempted to abuse the Services or acted in an inappropriate manner, please contact us directly via our contact details available below.

Minors

We do not knowingly collect or solicit Personal Information from anyone under the age of consent (as determined under the applicable laws where the individual resides; "Age of Consent"). By accessing, using or interacting with our Services, you certify to us that you are not under the Age of Consent. In the event we learn that we have collected Personal Information from an individual under the Age of Consent, we will delete that information upon discovery. If you believe that we might have any information from or about an individual under the Age of Consent, then please contact us through the contact details available below.

Updates to this Notice

We reserve the right to change this Notice at any time. The most current version will always be posted on our Services (as reflected in the "Last Revised" heading). Your continued use of the Services after this Notice, or any subsequent update, is posted is deemed consent to the terms in this Notice.

Contact Us

For any privacy or data protection queries, our Data Protection Officer can be reached via email with the Subject 'Privacy'.

If you have any further questions, please contact us by email.

We will make an effort to reply within a reasonable timeframe. Please feel free to reach out to us at any time.