The Company (as defined in the "HOW TO CONTACT US" section below), forms part of the 888 group of companies (the "Group", "we", "our" or "us"). The contact details of the different entities of the Group are available under the “HOW TO CONTACT US” Section.
- WHAT INFORMATION WE PROCESS?
- CONDITIONS FOR PROCESSING OF PERSONAL INFORMATION
- HOW WE USE THE COLLECTED INFORMATION?
- WITH WHOM WE SHARE INFORMATION?
- INTERNATIONAL TRANSFER OF INFORMATION
- THIRD PARTY TRACKING TECHNOLOGIES
- THIRD PARTY SERVICES
- RETENTION OF PERSONAL INFORMATION
- YOUR RIGHTS
- HOW WE KEEP YOUR INFORMATION SECURED
- HOW TO CONTACT US
The Group provided the Services through the following applications and platforms (collectively the “Platforms”):
- Internet websites;
- Downloadable applications and software ("Software"), such as native applications which are distributed through mobile application stores and PC and Mac desktop software which can be downloaded to your computer;
- Non-downloadable online applications (e.g. flash applications, HTML5 applications, etc.);
WHAT INFORMATION WE PROCESS?
We collect two types of information from our Users:
- Personal Information
The first type of information which we process is information that identifies or may reasonably identify an individual with reasonable effort (“Personal Information”). Personal Information may consist of the following:
- Account details: When you opened an account and registered to use the Services, you were asked to provide us certain details about yourself, such as: first and last name, email address, username, gender, birth date, personal numeric code, age, profile picture, physical address, ID number, fiscal code, phone number and occupation. In addition, we may have collected certain information as required under various gambling regulations, as well as Know Your Client (“KYC”) and Anti-Money Laundering (“AML”) regulatory requirements, such as your source of funds.
- Governmental-issued ID: In certain instances, you have been required to provide a copy of a governmental-issued ID, for identity verification process. Please note that this information was required for certain features of our Services.
- Gaming information: In order for us to provide the Services, we automatically recorded different information related to your account and use of our Services, including with respect to your transactions, deposits, balances, bets, withdraws, bonuses and winnings. We also collected information regarding potential gambling problems or addictions, based on your patterns of gambling across our services, in order to ensure a responsible gaming environment and as required by law.
- Financial information: In order for you to enjoy all of the functions of the Services (e.g. place bets, perform purchases, play in tournaments, etc.), payment information was collected from you, such as your currency, credit card number, payment method and bank account details.
- Voluntary information: We also process information which you provide us voluntarily, such as information provided by our VIP customers. For example, when you respond to communications from us, communicate with us via email or share additional information about yourself through your use of the Services, such as on the chat feature and in games. This includes information you are willing to share with us for the purpose of improving and developing our relationship with you, as well as for maintaining your stratification from our Services (for example, information about your marital status and family, your hobbies and interests, and other information you share with us through surveys).
- Device information: We process specific types of connection details and information with regard to your device, software or hardware that may identify you, such as: device’s unique identifiers (e.g. UDID, IMEI and MAC address), browser fingerprinting, IP address and geo-location data.
- Telephone calls: We record or monitor telephone calls for customer support, training and/or security purposes.
- Information we process from third parties: We process Personal Information from third party service providers, such as information about your credit history from credit agencies and other financial information which is relevant to the provision of the Services, as well as information which is gathered in order to verify your identity and prevent fraudulent or illegal activity.
- Non-personal Information
The second type of information is un-identified and non-identifiable information pertaining to a User(s), which may be made available or gathered via the User’s use of the Services (“Non-Personal Information”).
Non-Personal Information which is processed consists of technical information and aggregated usage information, and may contain, among other things, the User’s operating system, type of browser, screen resolution, browser and keyboard language, the User’s ‘click-stream’ and activities on the Services, the period of time the User visited the Services and related time stamps, etc.
For avoidance of doubt, any Non-personal Information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection or linkage exists.
Types of Non-personal Information processed about you:
- Log-in history and technical information: We process technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time and the domain name of the website from which you linked to the Services; etc.).
- Gameplay information: We recorded game play information including, amongst other things, your deposits, bets, bonuses, game session duration and your high scores.
- Device and connection information: we process information from the particular device you are using, for security and fraud detection and prevention purposes. For example, we may process information with regard to other software which is running simultaneously with the Software for detecting if you are using software which is associated with fraudulent activity (e.g. robots, malware, etc.).
- Analytics information: We process information about your use of the Services, such as applications' usage, log files, user activity (e.g. pages viewed, the amount of time spent on particular pages, online browsing, clicks, actions, etc.), time stamps, alerts, etc. This information is collected for amongst other things troubleshooting errors and bugs as well as for research and analytics purposes about your use of the Services.
CONDITIONS FOR PROCESSING PERSONAL INFORMATION
This section outlines the underlying purposes and legal bases for the processing of your Personal Information:
|Support and customer relations. We use your Personal Information, such as your name and email address, for consumer services purposes. This includes, for example, managing your account and responding to your inquiries.||The legal bases for processing this data are the performance of our contractual obligation towards you (Art. 6.1(b) GDPR); your consent (for example, when you provide Personal Data) (Art. 6.1(a) GDPR); compliance with our legal obligations (Art. 6.1ca) GDPR); and our legitimate interests (Art. 6.1(f) GDPR). Our legitimate interests in this case are enforcing our policies, protection against fraud and misuse of our Services.|
|Dispute resolution and protection of our legal claims. We process your Personal Information in order to investigate violation of our policies, enable us to resolve disputes in connection with your use of the Services and to establish and defend our legal claims.||The legal basis for processing this data is our legitimate interests (Art. 6.1(f) GDPR). Our legitimate interests in this case are to establish and defend our legal claims.|
|Corporate transactions. We may share your Personal Information with a potential purchasers, successors or investors in the Company or in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, reorganization, bankruptcy, consolidation or asset sale of an asset or transfer in the operation thereof) in relation to the Company.||The legal basis for processing this data is our legitimate interests (Art. 6.1(f) GDPR).|
|Prevention of fraud. 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 Services, including by identifying risks associated with your activity on our Services.||The legal basis for processing this data is our legitimate interests (Art. 6.1(f) GDPR). Our legitimate interests in this case are to protect our Company and customer against fraud.|
|Compliance with applicable laws. We process your Personal Information to comply with our various legal obligations such as responsible gaming, anti-money laundering, identity verification, prevention of fraud complying with data subject rights etc.||The legal basis for processing this data is to comply with our various legal obligations (Art. 6.1(f) GDPR) and our legitimate interests.|
The Services are not designed or directed to persons under the age of 18 with respect to the use of the Services (“Legally of Age”).
We reserve the right to access and verify any Personal Information collected from you. In the event that we become aware that a user who is not Legally of Age has shared any information, we may discard such information unless it is needed to comply with any legal or statutory obligation binding upon us. If you have any reason to believe that a minor has shared any information with us, please contact us (our contact details are available under the "HOW TO CONTACT US?" section).
WITH WHOM WE SHARE INFORMATION?
We share Personal Information with any of the following recipients:
- Companies within the Group and other affiliated companies;
- Gaming providers;
- Subcontractors and third party service providers, as well as their subcontractors, which by way of example include (but is not limited to) cloud computing companies, marketing affiliates, identity verification and fraud prevention services, and other data verifiers;
- Auditors, contractors or legal/financial/other advisers of any of the Group’s business processes;
- Any third parties who investigate, detect or prevent fraudulent or illegal activity or enable us to enforce our policies, including in order to ascertain your source of income or funds (e.g. governmental authorities, law enforcement bodies, banks and other investigatory bodies);
- Gambling addictions bodies;
- Licensing authorities, governmental and regulatory bodies, in accordance with applicable laws and regulations; and
INTERNATIONAL TRANSFER OF INFORMATION
Since we operate globally, it may be necessary to transfer your Personal Information to countries outside the European Economic Area. The data protection and other laws of these countries may not be as comprehensive as those in the European Economic Area.
For more information about the transfer of your personal data outside of the EEA, please contact us (our contact details are available under the "HOW TO CONTACT US?" Section).
THIRD PARTY TRACKING TECHNOLOGIES
When you visit or access our Services (for example when you visit our websites), we use (and authorize third parties to use) web beacons, cookies, pixels, scripts, tags and other technologies ("Tracking Technologies").
The Tracking Technologies allow us to automatically collect information about you and your online behavior, as well as your device (for example your computer or mobile device), for different purposes, such as in order to enhance your navigation on our Services, improve our Services’ performance and customize your experience on our Services. We also use this information to collect statistics about the usage of our Services, perform analytics, deliver content which is tailored to your interests and administer services to our Users, advertisers, publishers, customers and partners.
THIRD PARTY SERVICES
You should always review their privacy practices carefully before providing Personal Information to such third parties.
You are knowingly and voluntarily assuming all risks of using any third-party websites, services or applications. You agree that we shall have no liability whatsoever with respect to such third party sites and your usage of them.
RETENTION OF PERSONAL INFORMATION
If you have registered with an account through our Services, the Group will retain your Personal Information as strictly necessary to enable the Group to meet its legal obligations under applicable laws or regulations, such as the applicable gambling regulations, KYC and AML regulations, as well as to meet the Group’s contractual obligations.
In addition, the Group may retain your Personal Information for longer periods, provided that retaining such information is strictly necessary for the Group’s legitimate interests, such as fraud prevention and record keeping, responsible gaming reasons, resolving or exercising claims regarding potential disputes, and where the Group is guided to do so by the applicable supervisory authority.
You may contact us at any time by email (our contact details are available under the "HOW TO CONTACT US?" section), and request:
- To access or delete any Personal Information relating to you;
- To change or update any Personal Information relating to you (for example, if you believe that your Personal Information is incorrect, you may ask to have it corrected or deleted). Note that you may also request that we will correct errors with regard to your Personal Information (except in cases where the information is required to be kept in its original format under any applicable laws and regulations);
- That we will restrict or cease any further use of your Personal Information;
- That we will provide the Personal Information you volunteered to us in a machine-readable format;
- To object to the processing of your Personal Information (such as for marketing purposes);
- To withdraw your consent to our processing activities (provided that such processing activities rely on your consent, and not on a different legal basis);
- To not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, except where such processing is necessary for the performance of the contract between you and us, or it is based on your explicit consent, as provided hereunder.
Please note that these rights are not absolute and requests are subject to any applicable legal requirements, including gambling regulations and other legal and ethical reporting or document retention obligations. We may also rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion, in accordance with our internal policies.
HOW WE KEEP YOUR INFORMATION SECURED
We take great care in implementing and maintaining the security of the Services and your information. We have put in place appropriate physical and technological safeguards to help prevent unauthorized access, to maintain data security, and to use correctly the information we collect online. These safeguards vary based on the sensitivity of the information that we collect and store.
We employ industry standard procedures and controls to ensure the safety of our users’ information, such as:
- Secure network topology, which includes intrusion prevention and Firewall systems;
- Encrypted communication;
- Authentication and Access Control;
- External and Internal audit tests; etc.
Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse the Services, and we make no warranty, express, implied or otherwise, that we will prevent such access.
HOW TO CONTACT US?
If you have any general questions about the Services or the information that we process about you and how we use it, please contact us through one of the companies detailed below, as explained below:
|For the following jurisdictions:||Name of Data Controller in the Group entity||Contact details|
|If you play or register an account in the United Kingdom||888 UK Limited||Attn: Data Protection Officer
Suite 601-701 Europort Avenue, Gibraltar
|If you register an account in Canada||VDSL (International) Limited||Attn: Data Protection Officer
Suite 601-701 Europort Avenue, Gibraltar
|All other jurisdictions||Virtual Global Digital Services Limited||Attn: Data Protection Officer
Suite 601-701 Europort Avenue, Gibraltar
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 according to Art. 77 GDPR. According to Art. 77 GDPR every data subject shall have the right to lodge a complaint with a supervisory authority, in particular in the Member State of his or her habitual residence, place of work or place of the alleged infringement if the data subject considers that the processing of personal data relating to him or her infringes the GDPR.
Last updated on June, 2022