Introduction
NGAME N.V. (“we”, “us”, “our”) is committed to protecting the privacy of any personal data that you provide to us or that we collect about you (“Personal Information”). Personal Information is information which identifies you and/or which relates to you, and may include your name, address, date of birth, payment card details, gaming history, account details, and any other information that we hold about you. We are a controller (also known as a “data controller”) in respect of your Personal Information. Controller is a legal term and means that we are responsible for determining the purposes for which your Personal Information is processed. We will ensure that your Personal Information is processed in compliance with data protection laws and regulations in the countries where we operate. Accordingly, we have set out in this Privacy Policy how we use your Personal Information. We may update this Privacy Policy from time to time, and therefore recommend that you review this Privacy Policy regularly. Where we make any material changes to this Privacy Policy, we will notify you that changes have been made.
How we collect your personal information
So that we can operate our websites and mobile applications, you will be asked to provide your Personal Information for the purposes of registering and opening an account with us. You are under no obligation to provide Personal Information to us. However, certain Personal Information is essential in order for us to provide you with our services (for example, enabling you to play the games on the website) and you might not be able to obtain certain services if you choose to withhold information we have requested that is required for those services. We also collect information about the transactions you make, including details of payment cards used. We may collect Personal Information through surveys which we, or companies engaged by us for such purpose, undertake. In addition, we collect information about your use of our websites, mobile applications and services. We will also collect other information necessary for us to process your Personal Information for the purposes set out in this Privacy Policy. If you provide your name, address or any other Personal Information on the public area of our websites, we will process this Personal Information also. We may also collect Personal Information from third party service providers, such as fraud prevention companies. Finally, we also use “cookies” which may collect certain information about you, such as your devices’ IP addresses, which constitutes Personal Information. You can learn more about the cookies we use in the ‘Cookies’ section below.
Why and how we use your personal data
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 proposes
- For purposes that constitute a legitimate interest of NGAME N.V. regarding direct marketing of its own similar goods and services via electronic mail as provided below; and
- For purposes that constitute a legitimate interest of NGAME N.V. regarding direct marketing via live telephone calls or postal mail as provided below
- For analytics purposes
Direct marketing
Direct Marketing of Own Similar Products and Services via electronic mail: In accordance with applicable laws and in reliance on Regulation 9(2) of the Processing of Personal Data (Electronic Communication sector) Regulations (S.L. 586.01) and Recital 47 of the GDPR, NGAME N.V. may be informing You, from time to time, via electronic mail (email or SMS) about its own similar products or services (for example any changes on the Website, new Games, own new services and promotions, bonuses and offers, loyalty programme/VIP experience). You may opt out at any time and free of charge of such service, as applicable, either by:
Activating the relevant link at the end of such message, or
Contacting us, or
Changing your Settings in your profile.
Live Direct Marketing Calls & Postal Mail: In accordance with applicable laws and in reliance on Regulation 9(3) of the Processing of Personal Data (Electronic Communications Sector) Regulations (S.L. 586.01) as well as Recital 47 of the GDPR, NGAME N.V. may place calls to You or send You postal mail for direct marketing purposes unless you oppose this. If You do not wish to receive such direct marketing calls or postal mail, You may opt out at any time and free of charge of such service either by:
- Contacting us, or
- the case of a phone call, or
- Changing your settings in your profile.
Please note that even if You object to receiving direct marketing material from, from time to time We may still need to send You certain important communications from which You cannot opt-out.
Retention of your personal information
We will retain your Personal Information for the period necessary for us to provide you with our services and to comply with our legal and regulatory responsibilities. Accordingly, your Personal Information will be retained for a minimum of five years following the closure of your account (if applicable) or the last contact with us from you. Where it is no longer necessary for us to process your Personal Information, we will delete it sooner. If you request that you should not be able to access our websites, mobile applications and services (i.e. self-exclude), we will retain this information for a minimum of seven years.
Recipients of your personal data
Recipients of your personal data As NGAME N.V.’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 are processed also by them for the above mentioned purposes on behalf of NGAME N.V. 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
Processors of personal data
- Game providers for the purpose of provision of games.
- Payment service providers to perform payment transactions (deposits and withdrawals).
- Marketing suppliers to perform certain marketing activities on behalf of NGAME N.V.
- Marketing partners to perform certain marketing activities on behalf of NGAME N.V.
- Marketing consultants to provide marketing advice to NGAME N.V.
- 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 or 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.
- 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.
- Professional advisers [acting as processors or joint controllers] including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
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.
Your rights
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,
- 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 our customer service.
Cookie Policy
Cookies are simple text files stored in your web browser that enable us to recognise you when you visit our website. Cookies are essential for running certain parts of our Website and we also use them to make your experience more personal and tailored to you. Cookies collect some personal information about you when you visit our website. Different Cookies collect different personal data. You can manage your Cookie preferences through your device’s browser settings: details of how to do this are set out in the section below. In order to help you make an informed decision about your Cookie preferences we have set out each type of cookie we use, what each does and what your experience may be like if you disable them.
What are they?
These cookies are essential required to make our website work; they enable you to navigate our website and also enable us to deliver content you play on in a way that works for your device.
What data do they collect?
These cookies collect details such as your user name, password, and browser settings.What happens if I disable these cookies?If your disable these cookies the website may not work correctly and not all some of the content may not be displayed on your device.
Analytic Cookies
What are they?
These cookies collect information on how you use our website and how the website performs. These cookies tell us how many players visit our website, which games they play on and any website errors players might encounter. These cookies provide us with aggregated statistics which we use to help us test and improve the performance of our website which in turn means we can provide you with a better experience.
What data do they collect?
We use third- party cookies to collect players’ data such as IP addresses, user IDs, location, device, browser, and frequency of visits. The third- party provides us with the data in an anonymised and aggregated form, which we then use to improve our service. Please note, this data is not accessible on an individual level by us, i.e. we can only access the anonymised aggregated data.
What happens if I disable these cookies?
You will still be able to visit and play on our site.
What are they?
These cookies are used to tailor the adverts that you see. By using these cookies we can ensure that any adverts you see are relevant to you, limit the number of times you see a particular given advertisement, and measure the effectiveness of our advertising. We share some of the information that the cookies collect with third parties we use for advertising services.
What data do they collect?
We use third -party cookies to collect players’ data such as IP addresses, user IDs, location, device, browser and frequency of visits. The third-party aggregates this data and then provides us with anonymised information on the players who play on our website, which we use in shaping our marketing campaigns. Please note, this data is not accessible on an individual level by us, i.e. we can only access the anonymised aggregated data.
What happens if I disable these cookies?
You will still be able to use all the great features of our website but the adverts you see will not be tailored to you.
Managing your cookiesYou can see your cookie preferences in your browser settings. You can choose which cookies you wish to enable and disable. Please see the instructional links below which explain how to do this on each of the popular browsers below.
- Internet Explorer
- Firefox
- Google Chrome
- Safari
If you access our website from your mobile phone, please search in your settings for “cookies” “and manage your preferences there. You can also find out more information on deleting or controlling cookies at www.aboutcookies.org and www.aboutads.info/choices.