This policy together with the Terms and Conditions available on the site define the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please have a look at the following paragraphs to understand our views and practices regarding your personal data and how we will treat it. By visiting our site you are accepting and consenting to the practices described in this policy.
Winludu is a data controller for the information that we obtain on you through this website.
We have appointed a data protection officer (DPO). If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO on firstname.lastname@example.org
Information we collect about you
We will collect and process the following data about you:
- Information you give us.
- This is information about you that you give us by filling in our forms on our site or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, subscribe to our service, make deposits, bets or withdrawals on our site, participate in chat rooms, accept bonuses or other promotions available on our site, any due diligence documentation you share with us, including the source of wealth questionnaire and supporting documentation, and when you report a problem or make a complaint with us. The information you give us may include your name, username, address, date of birth, country of residence and nationality, identification number, e-mail address, and phone number, financial and credit card information, personal description, proof of identification, proof of address, proof of funds and photograph.
- 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 the games or payment services). In this case, we may have to close your account.
Information we collect about you
With regard to each of your visits to our site we will automatically collect the following information:
- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- information about your visit, including the full Uniform Resource Locators (URL), games you played and duration on each game and page, page interaction information;
Information we receive from other sources
This is information we receive about you if you use any of our websites or services operated by entities within our group of companies. or in reliance of licences held by different entities within our group of companies. In the event that you use accounts on multiple sites operated by our group of companies. we may collate information about you generated from each site in one data repository. Such data is important to us for statistical purposes, but also particularly relevant within the context of our Anti-Money Laundering and Responsible Gambling responsibilities as arising out of law.
During the course of delivering services to you, we are also working closely with third party data processors (including, for example, business partners, sub-contractors in technical, payment and delivery services as well as for delivery of marketing information (such as CRM Tool Providers, Email Marketing Partners, SMS Providers, Direct Mail Distributors and Outbound Call providers,) advertising networks and affiliate networks, analytics providers, due diligence intelligence companies, search information providers, credit reference agencies). This category includes information we receive from our Publishers, Advertisers and other Partners that we work with to help us deliver ads and personalized content to you and recognize you across browsers and devices. This may include pseudonymous advertiser identifiers that some Advertisers or other third party ad platforms choose to share with us. Data processors process personal data according to our written instructions and their activities will be limited to those that are needed from them to assist us deliver the service to you.
We may also receive personal information about you from the brand owner. For the purposes of transparency, brands may be owned by entities other than the data controller, and all information acquired through those brands will be accessible to the brand owners to whom we give access to our platform containing your personal data.
Categories of data held about You
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
The personal data collected and processed on you can be grouped into the following categories:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, employment status and occupation.
- Contact Data includes residential address, email address and telephone numbers.
- Financial Data includes details of your salary and wealth, details of the sources of funds used to deposit with us, as well as bank account, payment card or payment account details, including information contained within any bank statements, payslips and similar documentation collected for KYC Purposes.
- Transaction Data includes details about deposits and withdrawals, wagering and other details of games you have played on our sites.
- Technical Data includes internet protocol (IP) address, your login data, 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 this website.
- Usage Data includes information about how you use our website, products and services, your username and password (encrypted), games played, login, logout times, duration of play, bonuses and promotions claimed, responsible gaming and AML classification.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
In fulfilment of our legal obligations, we must also collect Special Categories of Personal Data about you (this includes details about any political or government positions you hold, criminal convictions and offences and details of any problem gambling behaviour, admissions.).
Uses made of the information (Purpose)
Information you give to us.
We will use this information:
1. to carry out our obligations arising from the terms and conditions entered into between you and us and to provide you with gaming services that you request from us, to accept your deposits and process your withdrawals, to carry out fraud management processes, to answer to any query or complaint that you may have as well as other ancillary matters related to the main services we are providing to you;
2. for Marketing and Promotional purposes which are necessary for our legitimate interests:
- subject to any preferences you have expressed (where applicable), to provide you with information about our services, bonuses schemes and promotions and information about the products and promotions, present or future, offered by the brand with whom you hold an account;
- to provide customised advertising on the site (on-site advertising) or on your mobile (push notifications) based on your interactions with the site or your Usage Data;
We will, from time to time, subject to your prior consent, send you marketing material which may of particular interest to you about the products, services, active promotions or offers available to you by any company within our group of companies and information about products and services provided by our selected partners and third parties.
We will use personal data for marketing and promotional purposes during the period of your relationship with us (unless you have communicated preferences not to be contacted) and, unless specifically instructed otherwise by you, for a reasonable period of time after the relationship has ended in order to inform you about products, services, promotions and special offers which we think may be of interest to you.
3. to personalise content on the site which we consider to be according to your preferences;
4. to notify you about changes to our service;
5. to ensure that content from our site is presented in the most effective manner for you and for your computer.
6. to meet obligations arising from Anti-Money Laundering Legislation and rules and regulations thereunder and all other laws that we may be subject to from time to time.
Information we collect about you.
We will use this information:
2. to carry out fraud management and risk management activities, including assigning a risk profile or a risk status to your account;
3. to assess your behaviour and patterns through the site which will be used to help build a detailed customer profile on you, on different subject matters, including but not limited to:
- A register of bonus abusers may be created by the company and persons on this list may be excluded from any future promotions or even blocked from using the services of the Company.
- We will also screen and monitor your transactions and behaviour for reasons of responsible gambling, ensuring that your interaction with us remains fun and entertainment and not dangerous to you. We may assign a Responsible Gambling score to your account based on the information we collect, which may at times be made available to you through your account. As a result of our assessment you may be tagged as a ‘Problem Gambler’ or vulnerable to the risks of gambling addiction.
- As part of our commitment to prevent money laundering and terrorist financing, we also analyse your personal data and compare it to third party data sources, build an AML profile on you and risk score your account based on the information you have provided to us and the information we have collected about you. We shall also keep a register of all high risk customers from an Anti-Money Laundering perspective.
4. to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
5. to allow you to participate in interactive features of our service, when you choose to do so; as part of our efforts to keep our site safe and secure;
6. to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant promotions to you;
7. to make suggestions and recommendations to you about our products.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
Information we receive from other sources. We will combine this information with information you give to us and information we collect about you. We will use this information and combined information for the purposes set out above (depending on the types of information we receive). Other sources include third party service providers of age verification tools, identity or address verification services, regulators or entities that keep central databases of problem gamblers, providers of PEP and Sanction searches, and other similar providers who we may contract with from time to time. We may also receive information from companies within our group of companies about you which helps us deliver a better service to you or to keep away bonus abusers, problem gamblers from our services.
Creation of a User Account
All the information that we hold about you, whether provided to us by you, whether we have collected it from you or from third parties, is collated into one user profile (Player Account) that we create on you.
Disclosure of your information
You agree that we have the right to share your personal information with:
- Any member of our group of companies which requires access to your personal information in order to provide the services you request. Data we receive and collect on you will be shared with our group companies and such data may be used by them for fraud and bonus abuse prevention, AML and Responsible Gaming Reasons in fulfilment of the Group’s legal obligations and legitimate business interests;
- To all members within our group of companies for the purposes of such other group entities to contact you with information on their products and services, provided that you have provided your consent.
Selected third parties, under a data processing agreement with us that ensures the safeguard of your personal information, including:
- the owner and/or operator of the site in the event that the site is owned by a company other than our company. These companies would normally be owned by our subsidiary. These persons would require your personal data in order to provide first line support or to answer initial queries and complaints from you. Unless have updated your preferences otherwise, the owners of such third party sites will also use your personal information to provide targeted advertising to you, run promotional campaigns, run behavioral advertising, and contact you in relation to the products and service, present and future.
- game suppliers who deliver gaming products on our sites who require such data in order to allow you to participate in a game and to determine the outcome of the game;
- unless you have unsubscribed, to advertisers and advertising networks that require the data to select and serve relevant adverts to you and others, including promotional emails and SMS’, direct mail, and at times to makes calls to you.
- analytics, business intelligence partners and search engine providers that assist us in the improvement and optimisation of our site;
- credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you;
- suppliers of age and identity verification tools and other suppliers that can verify know your client information generally, specifically, but without limitation, Aristotle, C6, GB Group;
- with our banks or payment service providers or payment gateways in order to be able to complete payment instructions to you;
- with our lawyers, advisors, consultants who we may engage from time to time to advise on any matter which requires them to gain access to personal information;
- with any person, company, NGO, governmental body, regulatory authority that maintains a register of problem gamblers or for any other responsible gaming purpose.
- with any person, company, NGO, governmental body, regulatory authority that maintains a register or database having the objective of preventing crime, money laundering or terrorist and proliferation financing.
- in the event that we agree to transfer our business relating to this site, in which case we will disclose your personal data to the prospective buyer or their lawyers, consultants, financial advisers and employees both during the due diligence process and also as part of the transfer of the business. This includes any transfer of data required under any agreement between us and the owner and/or operator of the site on termination of our services by the owner and/or operator of the site.
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions and other agreements; or to protect our rights, property, or safety. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Storage of your personal data
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology.
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
Request access to your personal data. You have the right to access information held about you. Some of the personal data held about you can be accessed by logging into your account. Additional information may be requested by contacting us on email@example.com. We shall comply with any reasonable access request. In the events that the access request involves a disproportionate amount of work, we reserve the right, in line with applicable law, to charge a fee covering the work involved.
Request correction of your personal data. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. You have the right to ask us to delete any information we hold about you which is not relevant to purpose for which we collect it. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You may also request for us to delete all your personal data, in which case we ask you to close your account. There may be legal obligations which may prohibit us from deleting all or any information held about you immediately at the time of the request (such as Anti-Money Laundering legislation), however we will process your request at the earliest opportunity whenever any applicable data retention period expires.
Object to processing of your personal data. You have a right to object to our processing of personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes on ground of legitimate interest. You may also object to us showing you targeted ads on our site, in which case you will not see any less ads but you will see ads that are less relevant to your interests. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; or (b) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it; or (c) where you contest that our use of your personal data is unlawful.
Request transfer of your personal data (data portability request). This enables you to request your personal data. We will provide to you, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Right to unsubscribe from direct marketing. You have the right at any time to change your mind in relation to us being able to contact you with direct marketing. You can exercise your right to stop receiving direct marketing by accessing your account and unticking the boxes related to direct marketing or by contacting customer support. You may also unsubscribe by following the unsubscribe instructions on the communication itself. Your updated preferences will be applied in respect of the site you make the request through. If you maintain accounts with various brands operated under the licences of our group of companies., you will need to follow the same procedure on each of the sites on which you have an account.
Alternatively, you may contact us on firstname.lastname@example.org and we will apply your preferences across all our sites. Please allow up to 48 hours for any changes you make to your marketing preferences to be fully processed. Please remember that even if you opt out of receiving marketing emails, we may still send you important Service information related to your accounts and subscriptions.
Right to withdraw consent. In cases where we rely on your consent for the processing of personal data, you have a right to withdraw your consent at any time.
We will retain copies of any communications that you send to us (including copies of any emails) in order to maintain accurate records of the information that we have received from you.
You can also exercise your rights at any time by contacting us at email@example.com. All communications with us must be through the e-mail address that is associated with your account. We will verify your identity prior to responding to any request.
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.
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 addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
By law we have to keep basic information about you including Contact, Identity, KYC, Financial and Transaction Data for five years after you close an account with us, or any longer time period required by the law of any jurisdiction.
You can ask us to delete your data by closing your account. In that case, we will immediately delete all information aside from that which we are required to maintain to fulfil our legal obligations as indicated above.
In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
From time to time, we may place on-site advertising using information you make available to us when you interact with our sites, content, or services. On-site ads, also sometimes referred to as personalised or targeted ads, are displayed to you based on information collected through cookies.
You can choose not to receive on-site ads from us. You will still see ads but they will not be personalised. Please visit your Account page to modify the advertising settings.
Advertising on Third Party Sites
We use third parties who collect data about their apps’ and sites’ visitors through their own cookies, web beacons, and other technologies regarding your online activities, in an effort to understand your interests and deliver you advertisements that are tailored to your interests. We purchase ad space on third party sites and our ads may appear when the third party determines that our ad is relevant to your interest according to the information they have collected.
We do not provide any personal information to advertisers or to third party sites that display our interest-based ads, however they may have collected certain personal information from you through the use of their site (such as articles read, types of ads clicked etc.), or through data analytics platforms (such as Google Analytics) and they may therefore customise advertising material published on their site according to your interests.
Different kind of cookies
Strictly necessary cookies
These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website.
(Blocking these cookies will prevent registration/authentication to the site and will make some content/functions unavailable.)
These cookies collect information about how customers use a website, for instance which pages customers go to most often, and if they get error messages from web pages. These cookies don’t collect information that identify a visitor. All information these cookies collect is aggregated and therefore anonymous.
These cookies allow the website to remember choices you make such as your username, language or the region you are in and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages you can customise. They may also be used to provide services you have asked for such as watching videos or commenting on a blog. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
These cookies record your visit, the pages you have visited, the games you have played, the financial transactions you have made, and your general behaviour on the Website. These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of time you see an advertisement as well as help measure the effectiveness of the advertising campaign. We will use this information to make our website and the advertising displayed or received by you more relevant to your interests. We may also share this information with third parties for this purpose who assist us in analytics
Third Party Cookies
We don’t control the setting of these cookies, so it is recommended to check the third-party website for more information about their cookies and how to manage them.
Session cookies are created temporarily when a user visits a website. Once the user leaves the site/closes the browser, the session cookie is deleted.
A persistent cookie file remains on the user’s device and is re-activated when the user visits the website that created that particular cookie. These cookies expire after a certain period (set in the file), or can be removed manually.
We use both Session and Persistent Cookies as indicated above.