Privacy Policy
This Privacy Policy together with the Terms and Conditions available on this Website sets out how personal data collected from you through this Website will be processed.
By accessing and using the Website, you acknowledge and accept the privacy practices described in this Privacy Policy and adopted on this Website.
This Website is owned and operated by MOUNTBERG B.V. MOUNTBERG B.V is the data controller & processor of the information that we collect from you through this Website.
All references to “Player”, “end user”, “you”, “yours” and/or “your”, in this Privacy Policy refers to any user which accesses and plays on this Website.
Any reference to “Games” or “Game” in this Privacy Policy refers to the gaming products offered on this Website.
We have appointed a Data Protection Officer (DPO). If you have any questions about this Privacy Policy, including any requests to exercise your rights as a data subject, please contact the DPO on: [email protected]
Which information do we collect and process on this website?
Registration Information
This is the information you give us when you fill in the registration form on this Website in order to register an account with us. This includes:
| “Identity Data” | First and Last Name, Date of Birth, Place of Birth, Residential Address (including City, ZIP Code and Country), Nationality, Identity Reference Number or Passport Number, Age. |
|---|---|
| “Contact Data” | Username, Phone Number and Email Address |
Customer Support Correspondence
When you ask for assistance from our Customer Support team through Live Chat or the Contact Form, we will collect and store the contact information you provide (generally your name and e-mail address), information about your game play or activity on the Website, and your user ID number.
Account Limits
You may choose to set limits on your accounts including daily deposit limits (“Limit Data”).
Financial Data
You might be required to provide the following “Financial Data” – card number, expiry date, security code.
Self-Exclusions
You may choose to set a self-exclusion on your account (“Self-Exclusion Data”) by contacting our Support team.
Know Your Customer
We collect your information when applying our Know Your Customer procedures in line with our Terms and Conditions. These procedures allow us to verify the identity of our customers in line with our obligations under Anti-Money Laundering and Funding of Terrorism Laws. We generally collect the following information for these purposes (“KYC Data”):
- Valid ID (Passport, National ID Card or Driving License)
- Utility Bill or other proof of address document (cannot be older than 3 months)
- Bank statement (with clear visibility of your name and address, IBAN and BIC) (“Bank Account Data”)
Depending on the circumstances of the relationship, we may collect additional information.
Information we collect when you are making use of your account on the website
While you are using your account and playing games, we will collect the following information about your account (“Account Data”):
- Activity Logs – playing history and activity logs including login session activity: start, end, end reason, start balance, start bonus, end balance, end bonus balance, game sessions, game rounds, sportbook rounds, total bets, total wins, income and IP address;
- Account Balance – total, real and bonus balance, pending withdrawals, pending deposits, reserved bets, income, total deposits, withdrawals, bonuses, average deposit and bonus, and maximum balance;
- Game Analytics – recently played, most played, favorite provider, biggest win, most rounds per session, average income per session, average rounds per session, free rounds.
Upon your visit to our site or usage of our site we will also collect the following information about you:
- Technical Data including your Internet Protocol – IP (address used to connect your computer to the internet) and device, 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 of each game and page, page interaction information (“Usage Data”);
- Information received from cookies including details of your visits to this site for traffic overview, games you played, duration on each game and in general your behavior on the website. This information is collected in line with our Cookie Policy (add link) (“Cookie Data”).
Information collected from third party or publicy available sources
We may receive personal data about you from various third parties and public sources as set out below (“Public Sources Data”):
- Google searches
If we start to collect any other data that is not in line with the above, this Privacy Policy shall be updated.
If you provide us with any additional data which is special category data because for example it relates to your health, we will provide you with a separate Privacy Policy in relation to such data.
How do we use your personal data?
We will only use your personal data when the law allows us to. Generally, this would be in the following circumstances:
When we need to in order to be able to provide you with gaming services in line with the contract we have with you or are about to enter into with you (please see our Terms & Conditions);
Where it is necessary for our legitimate interests and your interests do not override those interests;
Where we need to comply with an obligation under law including Anti-Money Laundering and Funding of Terrorism Laws, and gaming laws
We do not generally rely on your consent as a basis for processing your personal data other than in relation to sending of marketing communications. You are not obliged to give your consent and refusing to give your consent will not lead to any detriment to you. You have the right to withdraw your consent at any time by ticking the opt-out option on your profile. You may also opt out by contacting our DPO at any time or clicking the ‘unsubscribe’ link in any marketing material sent to you.
Purposes of collecting and processing the information
We collect, store and use your information to provide you with a safe, smooth, efficient, and customized experience. We use the information collected from you for the following purposes:
| Type of data | Lawful basis for processing | Purpose for which the data will be processed |
|---|---|---|
| Identity Data
Contact Data Public Sources Data |
Performance of a contract with you
Complying with our legal obligations |
Registering you as a user to create your account and allow you to play Games in order to provide you with gaming services in line with our contract with you (see Terms and Conditions) and performing our obligations arising from the Terms and Conditions including contacting you where contact is necessary to perform our obligations towards you e.g. customer support matters
Complying with our legal obligations under Anti-Money Laundering and gaming laws |
| Financial Data
Identity Data Contact Data Bank Account Data |
Performance of a contract with you | To process your deposit/withdrawal of funds and payouts in relation to Games played on our website and in accordance with the Terms & Conditions. |
| Identity Data
Contact Data Technical Data Account Data Usage Data Cookie Data |
Legitimate interests | Our legitimate interest for administering, protecting and developing of our business and the website, provision of administration and IT services, network security, to prevent fraud, including through troubleshooting, data analysis, testing, system maintenance, and support |
| Identity Data
Contact Data Technical Data Usage Data Account Data Cookie Data |
Legitimate interests | Our legitimate interest to see how customers use our products in order to develop them and to grow our business and form our marketing strategy and to deliver relevant website content and advertisements to users |
| Technical Data
Usage Data Cookie Data |
Legitimate interests | Our legitimate interests to use data analytics to improve our website, products and services, customer relationships and marketing strategy and to define types of customers for our products, to keep our website updated and relevant, and to develop our business |
| Identity Data
Contact Data Technical Data Usage Data Account Data Cookie Data |
Consent | Marketing products or services which might be of interest to you
Contacting you with bonuses schemes and promotional offers Contacting you with game updates |
| Account Data
Usage Data Identity Data |
Consent | Collecting information to help improve use of our website, Games and customer experience through participation in surveys and/or contests |
| Identity Data
Contact Data |
Complying with our legal obligations | Notifying you of changes to this Privacy Policy in line with our obligations under GDPR |
| Account Data
Usage Data Identity Data |
Legitimate interests | Our legitimate interest to develop our products, grow our business and improve customer relationships by providing game leader boards and promote in-game player achievements |
| Account Data
Usage Data Identity Data |
Legitimate interests | Our legitimate interests to solicit input and feedback in order to study how our customers use our products in order to develop and improve our Games and services and customize your user experience and customer relationship |
| Identity Data
Contact Data Technical Data Usage Data Account Data Bank Account Data |
Complying with our legal obligations | Complying with our legal obligations under money laundering and gaming laws to prevent money laundering, fraud and collusion by analyzing and studying player behavior, communications, depositing and player patterns |
| Limit Data
Identity Data Contact Data Technical Data Usage Data Account Data |
Complying with our legal obligations | Complying with our legal obligations under gaming laws for the allowance of the setting of player limits and processing of data to ensure that player and website do not exceed set limits |
| Self-Exclusion Data
Identity Data Contact Data Technical Data Usage Data Account Data |
Complying with our legal obligations | Complying with our legal obligations under gaming laws for the allowance of the setting of self-exclusions and processing of data to ensure that player and website abide by such exclusions |
| KYC Data
Public Sources Data Bank Account Data PEP Data |
Complying with our legal obligations | complying with our legal obligations under anti-money laundering and gaming laws to verify your identity and establish source of wealth, source of funds and politically exposed person status. |
Your information may also be used for legal and regulatory compliance purposes, including as necessary: to respond to governmental or regulatory entities requests; to comply with our legal obligations under current Anti-Money Laundering laws and Regulations and any applicable current local and international Tax laws; to identify misuse of our systems and any fraud or other illegal or unlawful activity or any other activity which is or may be contrary to our legal and regulatory compliance obligations.
We have a legal obligation to keep a copy of your gambling history and to employ measures to detect and identify problem gaming using analytical tools and/or behavior monitoring systems, and to take steps to prevent further harm. We will also use such data to initiate customer interaction where we have concerns that your behavior may indicate problem gambling.
We will also use and study your Usage Data, Technical Data and Account Data to target marketing activities for persons of the same age as you. This activity includes the processing of your age. We consider this to be in our legitimate interests to develop our products, form our marketing strategy, deliver website content and advertisement to users, to keep our website updated and relevant and overall to provide a better customer experience to our players. You have a right to object to such processing (see section Rights and Data Subject Requests).
We will further process your IP address in order to confirm your location, in line with our verification requirements under anti-money laundering laws, and to ensure that you do not have multiple accounts on our website in line with our obligations under gaming laws.
Your personal data will be processed automatically with the aim of evaluating certain personal aspects (profiling). We use profiling for the purposes of complying with our anti-money laundering and funding of terrorism obligations. As a rule, we do not make decisions based solely on automated processing as defined in Article 22 of the GDPR to establish and implement the business relationship, as there is always an element of human involvement in such decisions. If we use these procedures in individual cases, we will inform you of this separately, provided this is allowed by law.
Only Adults (18+) are allowed to use this website
It is prohibited for Individuals under the age 18 to use, play or utilize in any manner our Website. We will use the data provided to us to verify your age.
We invite you to report to us any information you may have regarding this at [email protected] so we take appropriate measures.
We do not collecting your credit card information
We do not collect your credit card and financial information and the process of payment is done through our payment gateway providers.
Our payment gateways providers use secure server software’s (SSL – an SSL Certificate enables encryption of sensitive information during online transactions.) which is the industry standard and among the best software available today for secure commerce transactions.
We do not have access to any information about the card or your bank account.
Disclosing your Personal Data
Your personal data will be disclosed to the third parties set out below for the purposes listed in the table above.
We shall only disclose your personal data to third parties where lawful to do so including where we:
- Need to in order to provide you with the service;
- Need to in order to obtain services from third parties in order to provide you with the service;
- Have a legal duty to do so e.g. assisting with detecting and preventing fraud and crime or regulatory reporting or in relation to problem gaming;
- Have a legitimate interest for the purposes of litigation or asserting and defending our legal rights and interests;
- Have a legitimate business interest to do so for managing risk;
- Have been instructed by you to do so;
- Are required to disclose the information in response to legal process (for example, a court order, search warrant or subpoena);
- Believe that our Website and its content is being used in the commission of a crime, including to report such criminal activity or to exchange information with other companies and organizations for the purposes of fraud or money-laundering protection;
- Have a reasonable and good faith belief that there is an emergency that poses a threat to the health, life and/or safety of you, another person or the public generally; and
- In order to protect the rights or property of MOUNTBERG B.V.., including to enforce our Terms and Conditions.
We will disclose your personal data to third parties which include:
- Regulators and other authorities as may be required by law or by courts of law;
- Law enforcement, government, courts, dispute resolution bodies, regulators and any party appointed or requested by regulators to carry out investigations or audits of our activities
We will disclose your personal data to external service providers and third-party vendors. We shall only disclose the personal data which is necessary for such third parties to deliver the required service. These include:
- MaxMind (provides IP intelligence to locate visitors and show them relevant content and ads, perform analytics, enforce digital rights and efficiently route internet traffic)
- Customer.io (email newsletter platform)
- Payment IQ (payment getaway provider)
- Professional advisors including lawyers, compliance officers, auditors and insurers;
- Mountberg Ltd – Player Payment processor and subsidiary of Mountberg B.V
These third parties act as data processors on behalf of MOUNTBERG B.V. We shall obtain guarantees from such third parties to ensure that they process your data in line with the GDPR, to keep your information secure and not to use it for their own purposes.
Where you are disputing payments or losses charged on your account, we shall disclose your KYC Data, Bank Account Data, Usage and Account Data to your bank to settle the dispute.
Relevant authorities, employees of MOUNTBERG B.V., in particular Customer support agents and other employees with relevant roles shall also have access to your personal data for the purpose of executing their duties and providing you with assistance and the service.
Data Transfers
We will only transfer your data to the European Union or to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
We shall only transfer data to providers based in the US if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
Marketing
We would like to send you information about our services which may be of interest to you. If you have consented to receive marketing, you have a right at any time to opt out from receiving such marketing material. You may opt out at any time as set out below:
- Email [email protected] and say that you would like to opt out
- Tick the ‘opt out’ option on your profile;
- Press ‘unsubscribe’ on any marketing material received.
Security
We are committed to ensuring that your information is secure. We have implemented measures and procedures to prevent unauthorised access or disclosure of your information. Likewise, we seek to keep confidential all information you send to us.
This site uses Secure Sockets Layer (SSL) to ensure secure transmission of your personal data. You should be able to see the padlock symbol in the status bar on the bottom right hand corner of the browser window. The URL address will also start with https:// depicting a secure webpage. SSL applies encryption between two points such as your PC and the connecting server.
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 personal data breach and will notify you and the relevant regulator of a breach where we are legally required to do so.
Data Retention
We will only retain your personal data for as long as necessary to fulfil the purposes for which they were collected.
All data will be maintained for the duration of your relationship with us. Following termination of the relationship, the following data will be retained in the following manner:
| Data Type | Retention Period | Retention Basis |
|---|---|---|
| Identity Data, Contact Data, Technical Data, Usage Data, Account Data, KYC Data, Public Sources Data, Self-Exclusion Data and Financial Data | Five years | Legal obligation
Personal data may be held longer where required for a legal investigation or litigation or where there is a reasonable suspicion that a player has been involved in criminal activity by virtue of his/her gaming activities The five years’ retention period for self-excluded players shall begin to run from the lapse of the self-exclusion period. |
| Contact Data | Five Years | Legitimate interest where needed for the establishment, exercise or defence of legal claims, disputes and judicial investigations |
| Account Data | Nine Years | As required by income tax laws to abide with our obligations thereunder |
| Record of Player interactions in relation to problem gaming | Two years unless required further to fulfil other obligations/retention periods | As required by gaming laws |
Rights & Data subject requests
Right to Transparent Information – you have the right to be informed in a clear manner on any personal data pertaining to you that may be processed by us. Such information is being provided to you in this Privacy Policy.
Right of Access to Information – you have the right to request confirmation from us whether personal data relating to you is being processed and if so to access such personal data.
To lodge a request, contact our DPO on the details above. If you would only like to receive information on a specific category of data, please indicate such category e.g. ‘Identity Data’ or ‘Contact Data’.
Right to Rectification – you have the right to request from us the rectification, without delay, of any inaccurate personal data pertaining to you.
You may change your data in the following manner:
- Through your Profile: by accessing the ‘Account Details’ page on the platform;
- By email: by emailing: [email protected]
Please note that your username may not be changed.
Right to Be Forgotten – you have the right to request from us the erasure of all personal data pertaining to you without delay, where the data has been processed with your consent as the basis for processing and/or where the processing is no longer lawful.
Right to Restrict Processing – you have the right to request from us the restriction of processing if: processing is unlawful; you are contesting the accuracy of data; the data is no longer required by the controller but you require us to keep it in order to establish, exercise, or defend a legal claim; or if you have previously objected to the processing. Once data is restricted, we cannot process it in any way other than to store it unless: we have your consent; or if it is required for the establishment, exercise, or defence of legal claims; or if it is for the protection of the rights of other persons; or if it is for reasons of important public interest.
Please note that this does not extend to personal data which is inferred or derived by us.
Right to Data Portability – you have the right to receive from us personal data which you have provided to us and to transmit that data to another controller without hindrance from us. This right applies where the data is being processed with your consent, or for the performance of a contract, and when processing is carried out by automated means.
Right to Object – you have the right to object at any time to the processing of personal data pertaining to you where the processing is based: on our legitimate interest; or the performance of a task in the public interest/exercise of official authority; or on direct marketing (including profiling); or on processing for purposes of scientific/historical research and statistics.
You also have the right to object to profiling based on our legitimate interests or on the performance of a task in the public interest/exercise of official authority.
You also have the right to object to automated decision making, including profiling, and therefore to not be subject to a decision which is based solely on automated processing, including profiling, which produces legal effects or significantly affects you.
What we will need from you
Whenever we receive a request in line with the above rights, we might need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or exercise any of your other rights). This is a security measures to ensure that personal data is not disclosed to any person who has no right to receive it.
Keep your data updated
We have an obligation to keep your data updated, and for this reason you may be asked about changes to your personal data at various intervals. You may help us in this process by informing us whenever your data has changed. You are entitled to ask us to modify your personal data if you ascertain that the personal data which we hold is not accurate or updated.
Am I obliged to provide you with my personal data?
Since we require your data for the purposes of accepting and carrying out a relationship with you and fulfilling our contractual and legal obligations, should you choose not to provide us with such data, we might not be in a position to enter into a business relationship with you and fulfil the Terms and Conditions applicable between us and our obligations thereunder. Anti-money laundering obligations require us to verify your identity at certain intervals, for example, by means of your passport and to record your personal details. In order for us to be able to comply with this statutory obligation, we will ask you to provide us with the necessary information and documents and notify us without undue delay of any changes that may arise during the course of the business relationship. Should you choose not to provide us with such data, we might not be in a position to enter into or continue our business relationship and fulfil the Terms and Conditions applicable between us and our obligations thereunder as we would be in breach of our anti-money laundering and funding of terrorism obligations.
Reference is made to the Terms and Conditions whereby you have undertaken to provide us with certain personal data, including documentation, and to inform us of any changes to such data. In these circumstances, the provision of personal data is a contractual requirement.
You are never obliged to provide us with any data which we request on the basis of your consent.
Processing data through consent
The processing of data highlighted above, with the exception of processing for marketing purposes does not require your consent as it relies on another legal basis.
We may however also request to process additional personal data on the basis of your consent. You are not obliged to give us your consent. Once you have granted us consent to the processing of personal data for an identified specific purpose, the processing becomes lawful on the basis of such consent. You can withdraw your consent at any time. Withdrawal of consent does not affect the legality of data processed prior to withdrawal.
You can withdraw your consent at any time by: [email protected]
At the time of withdrawal of consent, we may determine that there is another legal ground allowing us to process your data and we shall inform you accordingly.
Privacy Policies of linked websites and advertisers
MOUNTBERG B.V. Website may contain reference and linked third party Website and advertisers. We are not responsible for the privacy practices or the content of such Websites. By clicking on those links you may be directed to those Websites which are not under the control of MOUNTBERG B.V. and will need to comply with those respective third party privacy policies. If you have any questions about how these other Websites use your information, you should review their policies and contact them directly.
Surveys & Contests
From time-to-time we collect information via surveys or for participation of any contests organized by us on the Site. Participation in these surveys and/or contests is completely voluntary and any information provided to us will be provided on the basis of your consent. You may choose whether or not to participate and thereby disclose any information about you. There will be no detriment towards you for not participating in such survey and contests. You may wish to revoke your consent at any time.
By agreeing to participate in the survey, you agree to provide us with any such required information.
Survey information will be used only for purposes of improving the use and customer satisfaction of the Site.
Changes of Privacy Policy
This policy was updated on 12.09.2018.
We retain the right to change our Privacy Policy at any time in case update is needed. Any new change shall apply from the date we publish them.
Any further updates will be listed on this web page, so please check back periodically.
Contact us
If you are unhappy with the way in which we have processed your personal data, you may contact our Data Protection Officer/Data Protection Representative on the below details.
Email Address: [email protected]
You also have a right to lodge a complaint with the Office of the Information and Data Protection Commissioner, or other supervisory authority of your habitual residence, place of work or place of alleged infringement, and the right to seek an effective judicial remedy before courts.
Mountberg B.V.