Privaatsuspoliitka

1. General

This Privacy Policy informs you about which personal data we process, in what manner, and for what purpose on our website as well as in the context of providing our services. Additionally, we inform you about your rights as a data subject concerning the processing of your personal data.

We kindly ask you to read this Privacy Policy carefully. By using our products and services, which involve the processing of your personal data by us, you confirm that you have been informed about the use of your personal data in accordance with this Privacy Policy.

The protection of your personal data is of utmost importance to us. If you do not wish for your personal data to be processed to the extent outlined in this Privacy Policy, please do not provide us with your personal data. In such a case, you will not be able to access those services and products for which the processing of your personal data is necessary.

Your contact for data processing is: [email protected]

Entity information and contacts: Kingswin online OÜ with registered address at Estonia, Harju maakond, Tallinn, Kesklinna linnaosa, Vesivärava tn 50-301.

2. Categories of data, purposes of processing, and legal basis

Personal data refers to any information relating to an identified or identifiable natural person. To deliver our services effectively, ensure compliance with applicable laws, and provide a secure gaming experience, we collect and process the following categories of data.

Below, we provide information on personal data that we may collect and process in connection with your use of our products and services, provided that a legal basis exists for such processing.

2.1. Categories of data we may process:

• Identity Data: full name, username, date of birth, gender, nationality, and identification numbers (e.g., ID or passport number), data regarding the application of due diligence measures.
• Contact Data: residential address, email address, phone number, and other available means of communication.
• Financial Data: bank account details, payment card information, and any documents confirming your source of funds or source of wealth, such as bank statements or proof of income.
• Transaction Data: details about your deposits, withdrawals, and other financial transactions.
• Gaming Data: details about the games you play on our website, login/logout times, wagering activity, bonuses claimed, and history of responsible gaming measures.
• Technical Data: IP address / location data, login information, browser type and version, time zone settings, operating system, platform, and other technology used to access our website.
• Marketing and Communication Data: your marketing preferences and communications with us.
• Or other data you provide us during communication.

2.2. Purposes of processing your data and its legal basis:

• To deliver our services: to process your deposits, wagers, and withdrawals, to manage your account, verify your identity, and create a unique player profile, to respond to your queries, complaints, or support requests, to provide access to bonuses, promotions, and loyalty programs.
  Legal basis: Performance of a contract.
• Compliance with legal obligations: to meet our obligations under Anti-Money Laundering (AML) and counter-terrorism financing laws, including performing KYC (Know Your Customer) checks and monitoring transactions; to enforce responsible gaming measures, such as identifying players vulnerable to gambling addiction; to comply with regulatory requirements, including reporting to relevant authorities.
  Legal basis: Legal obligation.
• Fraud prevention and risk management: to detect, investigate, and prevent fraud, bonus abuse, or any unauthorized activity; to perform risk profiling and maintain records of high-risk customers.
  Legal basis: Legitimate interests (to protect our business and users).
• Marketing and personalization: to send you promotional materials about our services or those of other brands within our group to which you have given consent; to provide tailored advertisements based on your preferences and usage behaviour.
  Legal basis: Consent or legitimate interest (to provide tailored offers and promotions of our services).
• Analytics and service improvement: to analyze website traffic, troubleshoot technical issues, and optimize our services for a better user experience, to conduct research and statistical analysis for business insights.
  Legal basis: Legitimate interest (to improve our services).
• Ensuring security: to monitor and enhance the security of our platform.
  Legal basis: Legitimate interest (to monitor and enhance the security); legal obligation.

3. Where we collect the data:

• Directly from you.
• Verification providers (e.g., age, identity, or address verification services).
• Financial institutions.
• AML and PEP (Politically Exposed Persons) databases.
• Regulatory authorities and databases of problem gamblers.
• Partners such as affiliate networks, advertising platforms, and analytics providers, which may provide pseudonymous data for targeted marketing purposes.

4. Data processors and recipients of the data

We engage data processors to process your data on our behalf within the legally prescribed framework.

We engage data processors outside the European Union only under the following conditions:

(i)If the European Commission has issued an adequacy decision for the respective third country; or

(ii) If we rely on the European Commission’s Standard Contractual Clauses; or

(iii) If appropriate safeguards have been established with the third country; or

(iv) If we have agreed on binding corporate data protection rules with the data processor.

Personal data may be transferred to the following recipients (or groups of recipients) as part of the fulfillment of contracts, compliance with legal obligations, or in order to pursue legitimate interests. These recipients may act as data controllers or data processors:

• Legal representatives, advisors, consultants;
• Courts and other regulatory and enforcement authorities;
• Banks and financial institutions
• Other contractual and business partners, including service providers.

5. Data retention

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this policy or to comply with legal obligations. To determine the suitable retention period for personal data, we evaluate several factors: the volume, nature, and sensitivity of the data; the potential risk of harm from unauthorized use or disclosure; the purposes of processing and whether these can be fulfilled through alternative methods; and relevant legal obligations. During the retention of personal data, we also consider the necessity to resolve disputes and/or enforce contractual agreements.

For example, AML regulations require us to retain certain financial data for a minimum of five years.

In accordance with gambling and anti-money laundering (AML) regulations, we are required to retain your financial transaction history for a minimum period of five (5) years. Once your data is no longer required, we will ensure its secure deletion or anonymization.

6. Automated decision-making and profiling

Certain aspects of our services involve profiling to ensure compliance with our legal and business obligations. Examples include:

• Responsible Gambling Profiling: Monitoring your gaming behavior to assess risks and provide support when necessary.
• Fraud and AML Profiling: Assigning risk scores based on transaction patterns to detect and prevent fraudulent activity.

Important Note: While profiling helps us manage risks and maintain compliance, final decisions are reviewed and approved by our human team to ensure fairness.

7. Security

We implement technical and organizational security measures to protect your data against manipulation, loss, destruction, and unauthorized access by third parties. Our security measures are continuously improved in line with technological advancements.

These measures include:

• Encryption of sensitive information
• Access controls to restrict unauthorized access
• Firewalls to safeguard against external threats
• Regular security audits to maintain and improve data protection

Despite our best efforts, no online platform can guarantee absolute security. You are responsible for ensuring the confidentiality of your login credentials.

In the event of a data breach, we will notify affected users and the relevant authorities, where legally required.

8. Cookies

We utilize cookies and similar tracking technologies to enhance user experience, analyze website performance, and deliver personalized content. Some cookies are essential for the website’s functionality, while others require your explicit consent. You can adjust your cookie preferences at any time through your browser settings.

9. Minors

Our services are strictly for individuals who are permitted to participate in games of chance under local laws. We do not knowingly collect personal information from anyone under the permitted age. Should we discover that we hold the personal information of a person under the gambling age (for example, due to reasons relating to abuse of our website), we will use reasonable endeavours to delete this data and ensure that it is not further used or shared.

10. Your rights

Under the General Data Protection Regulation (GDPR) and national data protection law, you have the following rights regarding the processing of your personal data:

• Right of Access: you have the right to request information whether we process your personal data, which personal data we process, to what extent your personal data is processed and a copy of the personal data we process about you.
• Right to Rectification: if we process your incomplete or incorrect personal data, you may request its correction or completion at any time.
• Right to Erasure (“Right to be Forgotten”): you can request the deletion of your personal data if: we are processing your data unlawfully, you object to the processing and there are no overriding legitimate grounds for the processing, the data is no longer necessary for the purposes for which it was collected, you have withdrawn your consent, and there is no other legal basis for the processing, deletion is required to comply with a legal obligation. Exceptions: Immediate deletion may not be possible due to legal retention obligations (e.g. regulatory requirements).
• Right to Restriction of Processing: you can request that we restrict the processing of your personal data if: you dispute the accuracy of the data, and we need time to verify it; the processing is unlawful, but you prefer restriction over deletion; we no longer need the data, but you require it to exercise or defend legal claims; you have objected to the data processing, and we are assessing the request.
• Right to Data Portability: you can request that we provide your personal data in a structured, commonly used, and machine-readable format and transmit it to another controller if: the processing is based on your consent or a contract and the processing is carried out by automated means.
• Right to Withdraw Consent: for direct marketing which is based on consent, you can withdraw consent by clicking the “unsubscribe” link in the email or contacting us via [email protected]. Note: Withdrawing consent does not affect the lawfulness of data processing before the withdrawal.
• Right to Object: you may object to the processing of your personal data if it is processed based on our legitimate interest or that of a third party or for direct marketing purposes. Once you object, we will stop processing your data, unless: there are compelling legitimate reasons that override your interests, rights, and freedoms or the processing is necessary for legal claims.
• Right to Lodge a Complaint: if you believe that our data processing violates data protection laws, please contact us so we can clarify any issues. You also have the right to file a complaint with the Data Protection Authority or another competent supervisory authority.

11. Changes

We reserve the right to update this Privacy Policy to reflect legal requirements or adjustments to our business practices. In the event of changes, we will notify you by publishing the updated version on our website.