Last modified: 2018-05-23
This Policy explains how Global Gaming ("We", "Us") uses your personal data, when you are visiting one of our websites or playing one of our games.
Updates will occur from time to time and in case of significant changes, which could affect you, you will have to approve the policy again when accessing the service.
Who are we?
From where is your personal data is collected?
We collect information about you through traditional registration or Pay & Play (using bank-issued eIDs for verification) depending on jurisdiction. When you interact with us we also collect information for example in relation to your bet placement or your contact with the support team.
When you interact with our sites we collect information including, but not limited to, IP address, computer hardware specs, settings, server logs and which site or service you were using prior to visiting our site.
- Information we get from external companies
To help us comply with our legal and regulatory obligations we need to undertake additional checks to verify information or to investigate activity that could indicate a risk. To do this we use organisations such Comply Advantage for PEP-checks (politically exposed persons), Freshdesk for support tickets, Trustly and Entercash regarding payment providers.
- Information we get from your device
When you access one of our sites we collect information from the devices you use. Information such as: IP address, hardware, software, operating system, settings, network information, location data, server logs and the third-party site or app you were using prior to visiting our site.
When you use any of our websites you can choose which cookies you wish to accept or reject. Depending on which cookies you accept or reject influences your experience on our sites. Certain cookies are required for our sites to work properly, for example to keep you logged in during a visit to one of our sites or to enhance user experience by giving customised experience to users that visit the site more than once. To be able to do this we store a persistent cookie that can be used to find session and user data stored server side. The cookie itself only stores a random id string.
- Cookie Storage, Usage and Data Processors, Analytics/Marketing
In general, we use both 1st party and 3rd party cookies across all our brand websites. We also, in most cases, use Local Storage and Session Storage for 1st party tracking markers because of them being more efficient and, in the case of LS, more permanent than the old cookie system.
This includes 3rd party processors for:
If you would like more information on how to disable cookies or change your privacy settings, please visit www.allaboutcookies.org.
- Analytics/Tracking/Performance monitoring
- Google Analytics
- Google Data Studio
- Targeted Advertising and conversion tracking - includes us sending interaction and transaction data that is then joined with the external partners data to form a behavioural profile.
- Delta Projects
- FreshDesk - CS Live Chat and ticket management
- GoRoost - Marketing Push notifications
- CrazyRewards/Income Access/MyAffiliates - Affiliate attribution system
Why do we collect your Personal Data and on what basis?
We use your personal information in a range of different ways, which fall into these categories:
- Provide the products and services requested by you
To be able to access the services we provide, as you would expect, we use your personal information given through traditional registration or Pay & Play (using bank-issued eIDs for verification) depending on jurisdiction. When you interact with us we also collect information for example in relation to your bet placement or your contact with the support team. To be able to present you with the correct version of our site and keep it functioning securely and properly we store technical information about your device, for example operating system, browser and your location. When you contact our Customer Support through email or chat, your contact details (email, name, IP) will be stored in accordance with this Policy. By contacting our Customer support you also accept to receive a response to your support query.
- Business purposes
There are some things we do to help us operate as a commercial organisation. We have a legitimate interest in carrying out these activities, and where they involve using your personal information we are careful to carry them out in a way that minimises any impact on your privacy.
We perform analysis on which product are use and when certain products are used to properly manage our staff count during peak and non-peak hours, content presentation etc. This also helps us to get a better picture of our customers in general and what type of broad demographic groups they fit into (e.g. age group, gender, location, etc.). According to the information given to us by you, we personalize the layout and content of our sites based on your preferences.
We reserve the right to use this information to make decisions regarding imposing limitations on player accounts.
- Legal and regulatory purposes
Due to internal policies of this firm, we will assess any money laundering and terrorist financing risk presented by our clients and business partners in order to mitigate such risk by applying an appropriate level of client due diligence. Customer or business partners undergo a risk assessment according to procedures outlined in our policies and all staff are trained and recognize the risk-based approach necessary.
This participation has as its objectives:
To fulfil these objectives we perform identity verification, fraud prevention and anti-money laundering checks. The information shared with us is screened with third party organisations for validation purposes. We cannot provide you with our products without your consent to use your data for this purpose
- ensuring the firm's compliance with all applicable laws, statutory instruments of regulation, and requirements of the firm's supervisory body
- protecting the firm and all its staff as individuals from the risks associated with breaches of the law, regulations and supervisory requirements
- preserving the good name of the firm against the risk of reputational damage presented by implication in money laundering and terrorist financing activities
- making a positive contribution to the fight against crime and terrorism
- Third party organizations
We will share personal data within the Global Gaming Group. Instances may arise, however, wherein we would need to pass on your personal information to trusted third parties who assist us in operating our sites, conducting our business, or servicing you. The main functions that are or may be carried out, fully or in part can be found below;
The third-party organisations we work with are also obliged to process your information in accordance with data protection law, and we are also required to put in place contractual measures reinforcing those obligations. The personal data that we collect from you may be transferred and be processed by third parties outside of the European Economic Area (EEA), for instance when using a website hosting service located outside the EEA
We will not share your personal information with third parties beyond what is described above unless we are required or permitted by law to do so. In the rare circumstance when we are required to share information with police or other law enforcement bodies in any of the countries we operate.
- Customer services
- Payment processing and verification
- Anti-fraud and -money laundering checks and ID verification
- Checks to detect unfair use of our products and services
- Web hosting, online content services and data storage
- Management of competitions, contests and offers
- Data analytics and data cleansing
- Market research and collecting or analysing customer feedback
- IT services and support
Your privacy rights
- The right to opt out of having your information used for marketing
You have the right to withdraw your consent of having your information used for direct marketing at any time.
- The right to have any inaccuracies in your personal information corrected
Should any of your personal information be inaccurate you have the right to have this personal data corrected, without undue delay.
- Your 'right of objection' to certain processing and the right to limit the processing
You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data that concerns you.
You have the right to request that the processing of your personal data is limited.
- Your right to Data portability
You have the right to receive your personal data, which you has provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from us.
- Your Right to be forgotten
You have the right to have your personal data deleted in certain situations. 'Right to be forgotten' is in support of - freedom of expression. If you want to have your personal data deleted, you should contact us at email@example.com and we will respond to you within a month. If we agree to erase your data we will also notify any relevant third party, where possible, and inform you who they are. Should your request be denied, you will be informed why and you have the right to complain to the supervisory authority.
- Right to complain to the supervisory authority
Should you believe that we have infringed on your privacy rights, you have the right to complain to the supervisory authority. You are recommended to initiate contact with the regulator in the country of residence.
How long will we keep your data?
To be able to satisfy our obligations, both contractually and legally, we will only need to retain your information as long as we have a valid legal reason to do so, also if you cease to use our services. The length of time for which we keep different types of personal information we take into account a range of e.g. regulatory, anti-money laundering, taxation.
When we no longer need to fulfil the above requirements, we delete it securely. Normally, we will need to keep your information for a period of 5 years after you cease being a customer of Global Gaming.
We take all reasonable steps to protect your data from unauthorised access and improper use in accordance with this Policy and security standards. Accordingly, we have taken rigorous steps in becoming ISO27001 compliant.
We implement a variety of security measures to ensure that your information is kept safe. A secure server is made use of, and all sensitive/credit information supplied is transmitted via Secure Socket Layer (SSL) technology. The database is only accessible by individuals having special access rights to such systems.
Any transfer of your personal information to a location outside the EEA will be based on:
- the contractual Model Clauses adopted by the European Commission or a relevant data protection authority; or
- an adequacy decision from the European Commission, confirming that the third country provides adequate protection for your personal information; or
- Privacy Shield when transferring to the US (this is a form of certification which ensures that your data is handled in a way that is compatible with the strong EU protections); or
- Your consent, or another legal basis on which we are entitled to make the transfer.
Third Party Privacy Policies
Our site will provide links to third parties and these parties will have their own privacy policies which will not be the same as ours.
Should you have any issues or concerns or simply would like to know in depth how we process your personal data, you can contact us through firstname.lastname@example.org