Last updated 21-10-2020 - Version 2.1.
LeoVegas Gaming Plc respects your privacy and is committed to protecting your Personal Data and processing it in compliance with applicable laws – notably:
• The Maltese Data Protection Act (Chapter 586 of the Laws of Malta) as well as the various subsidiary legislation issued under the same – the ‘DPA’;
• The Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) – the ‘GDPR’.
• Purpose of processing: We process your Personal Data for the purpose of providing you with the services, to allow your access to the Website, to comply with our legal obligations such as anti-money laundering and responsible gaming, to detect and prevent fraud and to commercially grow our business (e.g. direct marketing, analyses);
• Controller: When processing your Personal Data, LeoVegas acts as a controller;
• Your rights: You have a number of rights afforded by applicable laws, especially a right to object to processing that is based on our legitimate interest such as direct marketing of our own goods and services, segmentation, loyalty programme and risk management. When we process your data on the basis of your consent, you can withdraw it at any time. Also, you have a right to receive an access to all of the Personal Data that is undergoing processing and a right to erasure of the data that is no longer necessary;
• Implications of processing: Processing of Personal Data will result in the provision of services (or denial thereof if certain data is not provided), receiving marketing communication, segmentation with respect to risk categories or bonuses and similar offers.
1. IMPORTANT INFORMATION AND WHO WE ARE
- Contact details
2. THE DATA WE COLLECT ABOUT YOU
- Personal Data
- Data Obtained from You
- Data obtained from other sources
- Special categories of Personal Data
- If you fail to provide data
3. WHY AND HOW WE USE YOUR PERSONAL DATA
- General purposes
- Detailed purposes and legal basis
- Direct marketing
- Criteria used to determine retention period
- Details on our retention periods
5. RECIPIENTS OF YOUR PERSONAL DATA
- Authorised disclosures
- Group companies/other brands for Responsible Gaming Purposes
- Group Companies/other brands for AML purposes
- Data sharing for AML and Responsible Gaming Purposes between brands
- Corporate restructuring
- Joint Controllers
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. YOUR RIGHTS UNDER DATA PROTECTION LAWS
- Right of access
- Right to rectification
- Right to Erasure (right to be forgotten)
- Right to data restriction
- Right to data portability
- Right to object to certain processing
- Right to withdraw consent
- Right to Lodge a complaint
- What we may need from you
- Time limit to respond
- Different brands
9. AUTOMATED PROCESSING – PROFILING
- Responsible Gaming Profiling
- AML profiling
- Key Account Profiling
- Direct Marketing Profiling
- Sports Risks Segments Profiling
- Games recommendation
1. IMPORTANT INFORMATION AND WHO WE ARE
This Website is not intended for children and we do not knowingly collect data relating to children (below 18 years of age).
1.3. CONTACT DETAILS
Our full details are:
General email address: email@example.com
DPO email address: firstname.lastname@example.org
Postal address: LeoVegas, Level 7, The Plaza Business Centre, Bisazza Street, Sliema SLM 1640, Malta
1.4. CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
2. THE DATA WE COLLECT ABOUT YOU
2.1. Personal Data: means any information that identifies You as an individual or that relates to an identifiable individual.
Whenever it is not possible or feasible for Us to make use of anonymous and/or anonymised data (in a manner that does not identify any Users of the Site or customers of Our services), We are nevertheless committed to protecting Your privacy and the security of Your Personal Data at all times.
2.2. Data obtained from You: We collect from You, through interaction with You or through Your interaction with Us or our Services, different kinds of Personal Data about You which we have grouped together follows:
a) Registration Data provided by You when You register and/or open Your Member Account including first name, last name, username or similar identifier, date of birth, territory applicable social security number where permitted or required by law, gender, country.
b) Contact Data includes permanent address, email address and telephone numbers.
c) Identification and Verification Data (Anti-Money Laundering/Due Diligence/KYC data) that include your name, surname, permanent address and proof, age, nationality, family members, degrees and qualifications, schools/universities attended, employment history and information, media involvement, financial status information (e.g. bank statement, source of income and source of wealth, tax information), masked credit card details, proof of e-wallet ownership such as Netller, Skrill, Paypal, Paysafe, KYC documentation (e.g. ID card, Power of attorney).
d) Responsible Gambling Data (RG) including name, surname, postcode, email, phone number, country, date of birth, territory applicable social security number where permitted or required by law, approved transactions (deposits and withdrawals), denied transactions (deposits and withdrawals), Identification and Verification Data, Self-exclusion Data.
e) Self-Exclusion Data including data pertaining to you and your self-exclusion such as your Registration and Contact Data and your self-exclusion info such as reason, start date, utilisation of self-exclusion tools such as exclusions, session limit, loss limit, wager limit, deposit limit, reality check.
f) Payments Data includes bank/payment account details, as well as information pertaining to a transaction such as currency, location, amount/value, client IP, user ID, token.
g) Transaction and Usage Data generated through your use of our Services (e.g. playing Games) and including payments to and from you (deposits, withdrawals, failed deposits and reversed withdrawals) and other details of Services you have purchased from Us (such as bets, wagers (real and bonus), wins), date and time of the transactions, account balances (bonus and real), bonuses used (conversion and forfeiture), bonuses turnover, bonuses balance, channels used, transaction games played, language, country, account balances.
h) Login Data includes internet protocol (IP) address, your logins (first login, last login, last failed login), duration of logins, 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 our Services.
i) Profile Data includes internal notes to your account, interests, preferences, feedback, information about events which you have attended; Your preferences as to whether you wish to attend any events, and what type of events you prefer; Any bonus/cash back deals, or bonus preference you have been offered or benefitted from; Whether you have received any giveaways, and your preferences regarding what type of gifts you would like to receive; Your preferences as to contact channels; information regarding your hobbies and interests.
j) Marketing Communications Data includes your preferences in receiving marketing from us (opt in/opt out), as well as your Contact and Registration Data.
k) Other Communication Data provided by you in communication with Us (via recorded calls, chats, emails, or SMS) which may include various data such as your intentions, interests, complaints, preferences, as well as internal communication and notes.
l) Analytics Data include various data provided by your observed with respect to your use of our Website and Services such as your player ID, language, location, browser data, campaigns utilised, channels used, device, payment provider, Transaction and Usage Data and in case of online acquisition analytics also pages visited, postcards clicked, scroll depth. Certain information is collected using cookies and/or similar tracking technology – please see further section “Cookies”.
2.3. Data from different sources
2.3.1 We collect information for AML/CFT/RG purposes on the background of the player, which we source from third party providers (private companies working mostly with public sources), namely Bisnode, Transunion International UK Limited (this will not negatively impact your Transunion credit score. More information including Transunion’s privacy notice can be found here) GB Group, HooYu Ltd (previously known as 192.com Ltd) and which includes information whether a player is a politically exposed person and whether any international and/or financial sanctions have been imposed and/or information on any corporate or property ownership, court judgements and/or insolvency. Moreover, background information is, using so-called OSINT analyses (Open-Source Intelligence) collected from publicly available sources (e.g. Google search, all social media services like Facebook, Twitter, Pinterest, Instagram, LinkedIn as well as other services/sites like pipl.com, https://www.zoopla.co.uk/, https://www.glassdoor.com, https://www.gov.uk/government/organisations/companies-house).
2.3.2 To comply with our legal obligations stemming from applicable laws and license conditions, when applicable, we collect Self-Exclusion Data also from other licensed gaming operators belonging to the same group of companies as LeoVegas (LeoVegas Mobile Gaming Group). Likewise, for the same purposes, LeoVegas uses Self-Exclusion Data collected with respect to any other brands under which LeoVegas operates its licensed gaming business.
2.3.3 If a player is registered with a National Self-Exclusion Register (incl. without limitation GAMSTOP) certain Self-Exclusion Data is also received from such register. In particular, information on whether you are/are not self-excluded. This information is received once you log-in. Registration with such a register means that you cannot register with LeoVegas and you will not be able to log on to your Member Account. You will also not be sent any commercial messages directed to you personally.
2.3.4 Profile data (e.g. hobbies, interests) are also gathered by search of publicly available sources such as Facebook, LinkedIn, Twitter, Instagram, and Google search.
2.3.5 In order to prevent and detect fraud and misuse of our systems (e.g. use of VPN), certain Login Data, such as; IP address, device model/type, browser information, operating system and other device identification data are sourced and processed by Us utilising a service of third-party fraud detection software provider.
2.3.6 We obtain information on your sports risk segment (Sports Risk Data) from our sportsbook provider Kambi Group plc (“Kambi”). All information on its processing activities may be found here: https://www.kambi.com/player-fair-processing-notice. As Kambi does not obtain a player's real name or email address and does not process any personal data of players on an identified basis, please contact us if you have any queries as to how Kambi processes your personal information or if you wish to exercise any of your data subject rights.
2.4. Special Categories of Personal Data
We do not collect any Special Categories of Personal Data about You (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). However, from our experience, we may not exclude that You, at your own discretion, send us such data in communication with Us.
Please note that although ID cards are processed, images contained therein are not specifically technically processed to allow or confirm unique identification. Therefore, such data is not to be considered biometric data (special category of data).
2.5. IF YOU FAIL TO PROVIDE PERSONAL DATA
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 Our Services).
Please make sure that your username does not contain any personally identifiable information, as the username is shared with certain partners and in the course of the sharing of the username, this is not, separately, considered Personal Data. Please contact us if your user name contains your personally identifiable data, so we can make proper arrangements to protect your data and guide you as to how to change the username.
3. WHY AND HOW WE USE YOUR PERSONAL DATA
3.1. We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:
- To allow You to participate in Games to provide ancillary services to You;
- To allow You access and use of the Website;
- For legal and regulatory reasons, to comply with our legal obligations and license conditions such as anti-money laundering and responsible gaming;
- For identification and verification purposes;
- For purposes that constitute a legitimate interest of LeoVegas regarding direct marketing of its own similar goods and services via electronic mail as provided below;
- For purposes that constitute a legitimate interest of LeoVegas regarding direct marketing via live telephone calls or postal mail as provided below; and
- For analytics purposes.
3.2. Detailed purposes and legal basis
3.2.1 We have set out below, in a table format, a description of all the possible 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. Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your Personal Data where more than one ground has been set out in the table below.
3.2.2 Please note that the below table sets out the general information about the Personal Data We process. Certain data categories and/or purposes may differ in different jurisdictions and/or brands under which LeoVegas provides its services. Please contact us if you need further details about the specific purpose for processing or data category in your jurisdiction.
|Purpose||Data Category||Legal Basis|
|To register you as a new player; to identify you and verify you when you access your account to allow you to participate in Games||Registration Data, Contact Data, Login Data||Performance of the contract with you|
|To allow your participation in the Games||Transaction and Usage Data||Performance of the contract with you|
|To process and manage payments transactions||Payments Data, Transaction and Usage Data||Performance of the contract with you|
|To manage our relationship with you, to communicate with you, to provide you with access to Games and any ancillary services||Registration Data, Contact Data, Profile Data, Other Communication Data, Transaction and Usage data, Self-Exclusion Data||Performance of the contract with you, Compliance with legal obligations|
|For AML/CTF/RG and due diligence purposes||Registration Data, Contact Data, Identification and Verification Data, Transaction and Usage Data (As further specified in Clause 9)||Compliance with legal obligations|
|To establish and investigate any suspicious behaviour in order to protect our business from any risk and fraud||Registration Data, Contact Data, Identification and Verification Data, Login Data, Payments Data, Other Communications Data||Legitimate interest (detection and prevention of fraud)|
|Identification and investigation of gaming activity for responsible gaming purposes||Responsible Gaming Data, Self-Exclusion Data, Other Communications Data||Compliance with legal obligations|
|Responsible gaming profiling||Responsible Gaming Data Transaction and Usage Data, Other Communication Data (As further specified in Clause 9)||Compliance with legal obligations|
|To ensure that self-excluded players with respect to LeoVegas or any other brand/company within the group are duly self-excluded and do not access Our Services (e.g. Games) and to handle and action requests made by the customer relating to the use of the Responsible Gaming Tools through the website||Self-Exclusion Data||Compliance with legal obligations|
|Direct Marketing of our own goods and services (Games) – incl. bonuses and offers||Marketing Communications Data||Legitimate interest (to promote our own Service, to develop our business and enhance relationship with), Consent|
|Direct Marketing of our own goods and services (Games) – loyalty programme||Registration data, Contact Data, Marketing Communications Data, Profile Data||Legitimate interest (to promote our own Service, to develop our business and enhance relationship with you by targeted offers), Consent|
|Social Media Marketing||Contact Data||Legitimate interest (to promote our own Service, to develop our business and enhance relationship with you by targeted offers), Consent|
|Customer segmentation for the purpose of tailored offers and bonuses sent via direct marketing||Transaction and Usage Data, Registration Data, Sports Risk Data (As further specified in Clause 9)||Legitimate interest (to promote our own Service, to develop our business and enhance relationship with you by targeted offers)|
|Loyalty programme purposes to (i) offer you attendance to events which would be of interest to you and possible guests, based on previous attendance; (ii) offering bonuses and other gifts which would be of interest to you, based on previous bonuses or gifts you may have benefitted from; (iii) contacting you on your preferred contact channels||Profile Data, Registration Data, Contact Data, Transaction and Usage Data||Legitimate interest (to promote our Services, improve your experience with our Services and for offer you tailored loyalty programme)|
|Customer segmentation for the loyalty program purposes and responsible gambling purposes||Transaction and Usage Data, Registration Data (As further specified in Clause 9)||Compliance with legal obligations, Legitimate interest (to promote our Services, improve your experience with our Services and to offer you a tailored loyalty programme)|
|To monitor player activity, detect and prevent fraud and to manage risk exposure||Sports Risk Data||Performance of the contract with you, Compliance with legal obligations, Legitimate interest (detection and prevention of fraud and management of risk exposure)|
|Commercial business analyses for the creation of standard, periodical as well as ad hoc reports||Transaction and Usage Data, Analytics Data (data is pseudonymised)||Legitimate interest (to develop our products/services and grow our business)|
|Web Analytics||Analytics Data, Transaction and Usage Data||Legitimate interest (to develop our products/services and grow our business)|
|Games recommendation||Transaction and Usage Data (As further specified in Clause 9)||Legitimate interest (to provide a customised, quality experience for the players)|
3.3. Direct Marketing
3.3.1 In accordance with the applicable laws (incl. local regulations) and on the basis of Our legitimate interest or Your consent, LeoVegas may, from time to time, inform You about its own similar products or services (incl. without limitation Own new services and promotions, bonuses and offers) via, as applicable:
- electronic mail (email or SMS), or
- social media, or
- live phone calls, or
- postal mail.
When relying on legitimate interest, LeoVegas will give you the opportunity to oppose such direct marketing when registering on Our site.
When relying on consent, the consent may be granted by You when registering on Our site.
In both cases, if you do not wish to receive direct marketing any longer, You may opt out at any time and free of charge, as applicable, either by:
- activating the relevant link at the end of an electronic message, or
- contacting us, or
- informing the caller (in the case of phone call), or
- changing your settings in your profile.
3.3.2 Please note that even if You object to receiving direct marketing material from Us, from time to time We may still need to send You certain important communications from which You cannot opt-out.
4.1. Criteria used to determine retention period: We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
The criteria We use to determine what is ‘necessary’ depends on the nature of the particular Personal Data in question. Our normal practice is to determine whether there is/are any specific EU and/or national law(s) (for example license requirement, tax or corporate laws) permitting or even obliging Us to keep certain Personal Data for a certain period of time (in which case We will keep the Personal Data for the maximum period indicated by any such law) and if not, whether there are any laws and/or contractual provisions that may be invoked against Us by You and/or third parties and if so, what the prescriptive periods for such actions are. In the latter case, We will keep any relevant Personal Data that We may need to defend Ourselves against any claim(s), challenge(s) or other such action(s) by You and/or third parties.
Where Your Personal Data is no longer required by Us, We will either securely delete or anonymise the Personal Data in question.
4.2. Details on our retention periods
4.2.1 We have set out below, in a table format, a description of all the possible data retention periods, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
4.2.2 Please note that the below table sets out the general information about the retention periods. Certain periods may differ in different jurisdictions. Please contact us if you need further details about the specific purpose for processing or data category in your jurisdiction.
|Retention scenario||Data Categories (HIGH LEVEL)||Purpose||Legal ground||Duration||Start of the period|
|1||Registration Data, Transaction and Usage Data||Tax & accounting||Legal obligation||10 years||Transaction|
|2||Identification and Verification Data (KYC/AML), Payments Data||AML||Legal obligation||Up to 10 years||Closure of account|
|3||Registration Data, Transaction and Usage Data, Other Communication Data, Profile Data, Payments Data||Defence of legal claims brought by customers||Legitimate interest||6 years, Up to 10 years||Closure of account|
|4||Registration Data, Contract Data, Identification and Verification Data, RG Data, Self-Exclusion Data, Transaction and Usage Data, Payments Data, Profile Data, Other Communication Data||Defence of claims brought by authorities (UK, MGA)||Legitimate interest||Up to 10 years||Closure of the account|
|5||Identification and Verification Data, Responsible Gaming Data, Self-Exclusion Data, Other Communication Data||RG (closure of the account)||Legal obligation||Up to 10 years||Closure of the account|
|6||Identification and Verification Data, Responsible Gaming Data, Self-Exclusion Data||Temporary exclusion||Legal obligation||Up to 10 years||Exclusion|
|7||Registration and Contact Data, Login Data||RG (permanent self-exclusion – MGA & DGA)||Legal obligation||Indefinite||Closure of the account/permanent self-exclusion|
|8||Transaction and Usage Data, Registration Data, Sports Risk Data||Possibility to communicate with the Player (in relation to tailored offers and bonuses) in case of the Account re-opening by the Player||Legitimate interest||2 years||Closure of the account|
Due to gaming authority restrictions relating to the use of multiple accounts, players are only permitted to create and use a single account per brand on the LeoVegas system as per our terms and conditions, therefore as long as we store, for the above mentioned purposes, all of the Personal Data of the player, the player may, following a closure only re-open their existing account, provided the account is eligible for opening.
Further details of retention periods for different aspects of your Personal Data are available in our retention policy which you can request from us by contacting us.
5. RECIPIENTS OF YOUR PERSONAL DATA
5.1. As LeoVegas’s business partners, suppliers or service providers are responsible for certain parts of the overall functioning or operation of the Website, Games and other services, Personal Data is processed also by them for the above-mentioned purposes on behalf of LeoVegas.
We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions, after thorough vetting of these partners and on the basis of strict data processing agreements.
5.1.1 Details on the categories of the processors of the Personal Data:
- Game providers for the purpose of provision of games
- Sportsbook provider for the purpose of provision of sportsbook service and risk management purposes
- Payment service providers to perform payment transactions (deposit and withdrawals)
- Marketing suppliers to perform certain marketing activities on behalf of LeoVegas
- Marketing partners to perform certain marketing activities on behalf of LeoVegas
- Marketing consultants to provide marketing advice to LeoVegas
- Service providers that technically enable communication with you (via email, chat, SMS, phone)
- Technical suppliers to support functioning of the Website and Our technical systems (both front and back end)
- Technical administrators of the database to maintain the functioning of the database
- AML providers providing and/or processing certain data for the purposes of compliance with our AML obligations
- Services providers regarding organisation and booking emails, trips and/or delivery of presents and gifts with respect to our loyalty programme
- Cloud services providers for provision of cloud-based services such as storage or hosting certain software
- Service providers for the purpose of data analytics and/or business intelligence
- Credit rating agencies, fraud detection agencies, anti-money laundering agencies for fraud detection and control purposes, in the processing of Your Member Account and associated transactions
- Companies within LeoVegas Mobile Gaming Group to provide certain services/support with functions of LeoVegas
- Professional advisers (acting as processors or joint controllers) including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
5.2. Authorised disclosure
If You are suspected to have breached our Terms and Conditions or any applicable laws (for example when we suspect that a crime may have been committed), or for the purpose of preventing, detecting or surpassing fraud or other criminal activity, LeoVegas has a right to:
- Forward Your Personal Data to the government authorities;
- Share any of Your Personal Data to the relevant gambling regulator;
- Share Your Personal Data with relevant law enforcement and/or crime investigation bodies or organisations and assist the same with any type of investigation into Your actions;
- Respond to any Court subpoena or order or similar official request for Personal Data.
5.3. Group companies/other brands for Responsible Gaming Purposes
When applicable, Your Self-Exclusion Data is, for the purpose of compliance with legal obligations, and Our license conditions, shared also with other companies within the same group. Likewise, for the same purposes, LeoVegas shares your Self-Exclusion data with other brands under which it operates its gambling activities.
5.4. Group companies/other brands for AML Purposes
Your Identification and Verification Data in the extent of first name, surname, date of birth and postcode is, for the purpose of compliance with legal obligations, shared between various brands under which LeoVegas operates its gambling activities.
5.5. Data sharing for AML and Responsible Gaming Purposes between brands
Your Identification and Verification Data, Transaction and Usage Data, Registration Data and Contact Data are for the purpose of compliance with legal obligations, shared with as well as sourced via various brands under which LeoVegas operates its gambling activities.
5.6. Corporate restructuring
5.7. Joint controllers
Certain data is shared with other parties, acting as joint controllers. The following are the details on the essence of the joint-controller arrangements:
• Payment services provider Citadel
The following data are processed with Citadel as joint controllers: Registration Data, Payment Data
Contact details: Citadel Commerce (Malta) Ltd. (“Citadel”), having its principal place of business at Lvl 5, ‘de Tigné’, 77 Fawwara Lane, Sliema SLM1670, Malta as agent on behalf of Citadel Commerce UK Limited, whose contact details are email@example.com. The essence of the Joint Controller Arrangement between LeoVegas and Citadel:
- LeoVegas collects data (except such data that Citadel may obtain from other sources through investigations) and informs data subjects;
- Citadel responds to data subjects' requests;
- Citadel records and makes all notifications of personal data breaches to supervisory authorities and/or affected data subjects when required;
- Citadel carries out data protection impact assessments and prior consultation with a supervisory authority regarding high risk processing when required.
• Sportsbook Provider Kambi
The following Data are processed with Kambi as joint controllers: Transaction and Usage Data in the extent: gender, first part of postcode, currency, language, last method of deposit, account balance and bet history, Player ID for the purpose of provision of the Sportsbook services. Kambi does not process a player's real name or email address but makes use of a pseudonymised ID relating to each player.
Further information on the Kambi’s processing activities may be found here: https://www.kambi.com/player-fair-processing-notice
The essence of the Joint Controller Arrangement between LeoVegas and Kambi:
- LeoVegas shares transaction and usage data in pseudonymised manner with Kambi for the purpose of provision of sportsbooks services;
- LeoVegas responds to data subjects' requests; and
- LeoVegas and Kambi also act as joint controllers when it come to any changes to the Sports Risk Segment.
In other cases, each party acts as a sole controller. However, we will in all cases be responsible for handling any queries that players may have with respect to Kambi's data processing activities.
The following Data are shared with Iovation: Login Data in the extent: Unique Account Identifier representing the Account End Users hold with LeoVegas, Device Attributes of the End User’s Electronic Device including, internet protocol (IP) address, End User logins (first login last login, last failed login), duration of logins, browser type and version, time zone setting and location, browser plug-in types and versions, operating system, device ID, IP Country, IP Region, IP ISP related to each player.
The essence of the Joint Controller Arrangement between LeoVegas and Iovation:
- LeoVegas and Iovation jointly process personal data for the purpose of Prevention and investigation of fraud.
- Iovation act as a separate and independent controller for the following activities: Improving services; Machine Learning; Sharing data across various operators/providers.
- LeoVegas responds to data subjects' requests.
In other cases, each Party acts as a sole controller. However, we will in all cases be responsible for handling any queries that players may have with respect to Iovation's data processing activities. Further information on the Iovation’s processing activities may be found at https://www.iovation.com/legal/privacy
If you wish to exercise such rights, or you have any questions or comments concerning your personal information, please contact firstname.lastname@example.org.
6. INTERNATIONAL TRANSFERS
Some of your suppliers and partners (as listed above) are based outside the European Economic Area (EEA) so their processing of your Personal Data will involve a transfer of data outside the EEA. Whenever we transfer your Personal Data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- Transfer your Personal Data is performed to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission. For further details, see here
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give Personal Data the same protection it has in Europe. For further details, see here.
Please Contact us if you want further information on the specific mechanism used by us when transferring Your Personal Data out of the EEA.
7. 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 order to comply with GDPR, various technical controls ensure data and information are always encrypted during transit and at rest using industry standard encryption techniques across the board. This ensures confidentiality and integrity at all times. At an organisation level, the handling of all information is governed by our comprehensive Information Security Policies. This is complemented by an information Security awareness programme designed to specifically ensure we embrace security best practices whenever it comes to handling information.
In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a need to know business requirement. 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.
8. YOUR RIGHTS UNDER THE DATA PROTECTION LAWS
8.1. Your Right of Access You may, at any time, with reasonable intervals, request Us to confirm whether or not We are processing Personal Data that concerns You and, if We are, you shall have the right to access that Personal Data and to the following information:
- What Personal Data We have,
- Why We process them,
- Who We disclose them to,
- How long We intend on keeping them for (where possible),
- Whether We transfer them abroad and the safeguards We take to protect them,
- What Your rights are,
- How You can make a complaint,
- Where We got Your Personal Data from, and
- Whether We have carried out any automated decision-making (including profiling) as well as related information.
The easiest way to obtain this information is to contact us on email@example.com or request this information via another channel. Upon such request, We shall (without adversely affecting the rights and freedoms of others including Our own) provide You with such information and/or with a copy of the Personal Data undergoing processing within one month of receipt of the request, which period may be extended by two months where necessary, taking into account the complexity and number of the requests. We shall inform You of any such extension within one month of receipt of the request, together with the reasons for the delay.
8.2. The Right to Rectification
Although all reasonable efforts will be made to keep Your Personal Data updated, you are kindly requested to inform Us promptly. With respect to your residential address and phone number, you can notify us of the change by amending Your profile of any changes to Your Personal Data. If the change pertains to data that cannot be amended by changing your profile, please contact us. To this end You have the right to ask Us to rectify inaccurate Personal Data and to complete incomplete Personal Data concerning You. We may seek to verify the accuracy of the data before rectifying it.
8.3. The Right to Erasure (The Right to be Forgotten)
You have the right to ask Us to delete Your Personal Data and We shall comply without undue delay but only where:
- The Personal Data is no longer necessary for the purposes for which it was collected; or
- You have withdrawn Your consent (in those instances where We process on the basis of Your consent) and We have no other legal ground to process Your Personal Data; or
- You shall have successfully exercised Your right to object (as explained below); or
- Your Personal Data has been processed unlawfully; or
- There exists a legal obligation to which We are subject; or
- Special circumstances exist in connection with certain children’s rights.
In any case, We shall not be legally bound to comply with Your erasure request if the processing of Your Personal Data is necessary:
- for compliance with a legal obligation to which We are subject (including but not limited to Our data retention obligations); or
- for the establishment, exercise or defence of legal claims.
There are other legal grounds entitling Us to refuse erasure requests although the two instances above are the most likely grounds that may be invoked by Us to deny such requests. You may request the erasure by contacting us.
8.4. The Right to Data Restriction
You have the right to ask Us to restrict (that is, store but not further process) Your Personal Data but only where:
- The accuracy of Your Personal Data is contested (see the right to data rectification above), for a period enabling Us to verify the accuracy of the Personal Data; or
- The processing is unlawful, and You oppose the erasure of Your Personal Data; or
- We no longer need the Personal Data for the purposes for which they were collected but You need the Personal Data for the establishment, exercise or defence of legal claims; or
- You exercised Your right to object and verification of Our legitimate grounds to override Your objection is pending.
Following Your request for restriction, except for storing Your Personal Data, We may only process Your Personal Data:
- Where We have Your consent; or
- For the establishment, exercise or defence of legal claims; or
- For the protection of the rights of another natural or legal person; or
- For reasons of important public interest.
You may request the restriction by contacting us.
8.5. The Right to Data Portability
You have the right to ask Us to provide Your Personal Data (that You shall have provided to us) to You in a structured, commonly used, machine-readable format, or (where technically feasible) to have it 'ported' directly to another data controller, provided this does not adversely affect the rights and freedoms of others. This right shall only apply where:
- The processing is based on Your consent or on the performance of a contract with You; and
- The processing is carried out by automated means.
If you would like us to assist you with the actual transfer of such data to another operator, please contact us.
If you are a customer of another gaming operator and would like to have your data “ported” to Us, please contact us. In this respect please note, that notwithstanding any portability right utilisation, you will still be expected to provide all Registration and Contact Data due to the requirements of our customer registration / sign up procedure requirements.
8.6. The Right to Object to Certain Processing
In those cases where We only process Your Personal Data when this is 1) necessary for the performance of a task carried out in the public interest right or in the exercise of official authority vested in Us, or 2) when processing is necessary for the purposes of the legitimate interests pursued by Us or by a third party (as indicated in the Table in the clause 3.2 above), You shall have the right to object to processing of Your Personal Data by Us.
When Your data is processed for direct marketing purposes, You have the right to object at any time to the processing of Your Personal Data, which includes profiling to the extent that it is related to such direct marketing.
For the avoidance of all doubt, when We process Your Personal Data when this is necessary for the performance of a contract, when necessary for compliance with a legal obligation to which We are subject or when processing is necessary to protect Your vital interests or those of another natural person, this general right to object shall not subsist.
With respect to Direct marketing of our own goods and services incl. related profiling, You may object such processing at any time, by contacting us or by selecting your preferences on your account Profile – Settings page.
8.7. Right to withdraw consent (when we process your data on the basis of consent)
In those cases where We process on the basis of Your consent (which We will never presume but which We shall have obtained in a clear and manifest manner from You), YOU HAVE THE RIGHT TO WITHDRAW YOUR CONSENT AT ANY TIME and this, in the same manner as You shall have provided it to Us.
Should You exercise Your right to withdraw Your consent at any time (by writing to Us at the physical or email address below), We will determine whether at that stage an alternative legal basis exists for processing Your Personal Data (for example, on the basis of a legal obligation to which We are subject) where We would be legally authorised (or even obliged) to process Your Personal Data without needing Your consent and if so, notify You accordingly.
When We ask for such Personal Data, You may always decline, however should You decline to provide Us with necessary data that We require to provide requested services, We may not necessarily be able to provide You with such services (especially if consent is the only legal ground that is available to Us).
Just to clarify, consent is not the only ground that permits Us to process Your Personal Data. In the last preceding section above We pointed out the various grounds that We rely on when processing Your Personal Data for specific purposes.
8.8 The Right to lodge a Complaint
You also have the right to lodge complaints with the appropriate Data Protection Supervisory Authority. The competent authority in Malta is the Office of the Information and Data Protection Commissioner (OIDPC). We kindly ask that You please attempt to resolve any issues You may have with Us first (even though, as stated above, You have a right to contact the competent authority at any time).
8.9 WHAT WE MAY NEED FROM YOU
When exercising your rights by contacting us, we may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
8.10 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.
8.11 DIFFERENT BRANDS
LeoVegas is also operating its gaming business under other brands and trademarks. For the purpose of the exercise of your rights as provided above, and for the purpose of clarity and legibility of our reply, we will initially comply with the requests with respect to data processed under the brand from where the request is originating. Should you wish your requests to be complied with respect to all of the brands with respect to which LeoVegas operates its business, please make sure to flag this in your request.
9. AUTOMATED PROCESSING - PROFILING
9.1. Meaningful information about the logic involved in the automated processing for responsible gaming purposes
LeoVegas is on the basis of the applicable laws and license conditions legally obliged to monitor its players in order to identify people who may be experiencing, or at risk of developing, problems with their gambling, and interact with them to offer help or support. To this end, and to fulfil this obligation, by using historic data describing behaviour of players, in particular certain Responsible Gaming Data, Transaction and Usage Data, and Other Communication Data (in particular notably sentiment used in message) LeoVegas has established rules regarding who is likely to suffer from gambling addiction and then take relevant action.
Our approach is based on classification trees because they allow for clear interpretation of why players get classified as potential gambling addicts. Based on data describing unique players, the algorithm provides us with an estimated probability of gambling addiction. Decisions, on the basis of the prediction, are not taken automatically without human intervention.
9.2. Meaningful information about the logic involved in the automated processing for AML purposes
LeoVegas is, on the basis of the applicable laws and license conditions, legally obliged to monitor its players in order to identify potentially suspicious activities regarding AML/CFT. Based on data describing the behaviour of players, in particular Transaction and Usage Data, the algorithm suggests a risk profile.
Decisions, on the basis of the prediction, are not taken automatically and require human intervention.
9.3. Meaningful information about the logic involved in the automated processing for loyalty segmentation purposes
By making use of the historical data that players generated in their first 2 days, We assess whether You will qualify for our loyalty program. This model is used on fresh players and depending on their involvement with our services a status is predicted. The result of the model is a prediction as to whether You will become managed by our Key Accounts team. Apart from gender, country and age, we do not make use of personally identifiable information as input in the model. Decisions, on the basis of the prediction, are not taken automatically without human intervention. The process is based on our compliance with legal obligation and with respect to the loyalty offers, on legitimate interest of LeoVegas regarding providing customised, quality experience for the players and reward loyalty of the players. You can object to such processing by contacting us or changing your preferences in your account.
9.4. Meaningful information about logic involved in automated processing with respect to direct marketing segments
By making use of Your Transaction and Usage Data, certain Registration Data such as gender, country, date of birth and Your overall interaction with our services, We analyse and establish various segments of the customers. These segments are then processed manually, in order to ensure that We provide the most appropriate offers and bonuses to our customers. These decisions are not taken automatically without human intervention. The process is based on legitimate interest of LeoVegas regarding providing customised, quality experience for the players and reward loyalty of the players. You can object to such processing by contacting us or changing your preferences in your account.
9.5. Meaningful information about logic involved in automated processing with respect to Sports Risks Segments
LeoVegas is manually processing your Sports Risks Segments as established by the sportsbook provider – Kambi. The Sports Risk Segments are established by Kambi on the basis of automated profiling performed by Kambi. They use automated processing to suggest a risk profile, however such risk profile is confirmed or amended by Kambi's personnel. In conjunction with provision of its services, Kambi uses automated risk management technology to assess the risk of particular betting activities. If You seek to undertake a bet that falls outside of the parameters associated with your risk profile, the bet is flagged for Kambi’s personnel to review. To safeguard your rights and interests, Kambi allows you to contest any decision that they make about your risk profiling or to object to our use of profiling. To this end, please contact us (LeoVegas). More information on processing activities performed by Kambi please consult Kambi’s privacy notice here: https://www.kambi.com/player-fair-processing-notice
9.6. Meaningful information about logic involved in automated processing with respect to Game recommendation
By making use of your Transaction and Usage Data, we provide You with a list of games that are aligned with Your taste. The system determines your affinity towards different games and generalises your preferences to unseen games. Ranking the computed preferences, an ordered list of games is produced and can be served as recommendations.
The game recommendations are produced without human intervention. The process is based on legitimate interest of LeoVegas regarding providing customised, quality experience for the players.
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