Privacy Policy

The Company is committed to securing your Personal Data and your privacy. According to this commitment We will uphold the following principles:

• To be transparent in respect of the collection and processing of Personal Data about you:

It is important to Us that at all times you will have all of the information required in order for you to make educated decisions about the processing of Personal Data about you. For this purpose, We will make use of various techniques and measures aimed to provide you with relevant information about the processing of Personal Data about you, in the proper manner and timing.

Our complete privacy policy is intended to provide you with the widest understanding of the types of Personal Data collected by Us and the manner in which We process it. It is therefore vital that you will review it at the first possible opportunity and from time to time.

In addition, where We find that you are required to be provided with specific information, We will provide it to you in the appropriate time and place.

We will also be happy to answer any question you have and provide you with any clarification you require, subject to legal limitations. For this purpose, you can approach Our data protection officer according to the following details:

Data Protection Officer, Progressplay Limited

E-mail: [email protected]

• To process Personal Data about you solely for the purposes outlined in the Policy:

The purposes for which We can process Personal Data about you include, inter alia, the provision of Our products and services requested by you, enhancing the user experience in Our products and services, to improve Our products and services, to protect Our rights and interests, to perform business and administrative activity that supports the provision of Our products and services to Our customers and/or to uphold any legal and/or regulatory requirements. The entire list of the purposes for which We use Personal Data about natural persons is listed in section 7 in the Policy.

In addition, We will process Personal Data about you in order to understand your personal needs and preferences and provide you with personally tailored offers. You may request at any time that We will stop sending you personally tailored offers, and We will act according to such a request.

• To invest significant resources in order to respect your rights in connection with Personal Data about you:

We apply significant resources in order to allow you to exercise your rights as a data subject. Therefore, you may approach Us any time you wish to review Personal Data about you, to have us amend it, erase it, cease using it for specific purposes or in general or that We will transfer it to you or to a third party, and We will fulfill your wishes in accordance with the law.

• To secure Personal Data about you:

While We cannot promise absolute protection of the Personal Data about you, We can promise that We use and will continue to use a wide array of means and measures that are aimed ensuring that the Personal Data about you is secured.

Our Complete Privacy Policy

1. To What Does This Privacy Policy Apply?

This Policy describes what kind of Personal Data does the Company collect about natural persons, how does it collect it, use it, share it with third parties, secure it, process it etc.

In this Policy, and reference to “Personal Data” is to any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or in combination with additional information that We have or that We have access to.

In this policy, wherever We refer to the “processing” of Personal Data, We refer to any operation or set of operations which is performed on Personal Data, including the collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

2. Data Controller

The Company is the data controller in respect of the Personal Data about you. In addition, SpinzWin.com (the “Partner”) is also a data controller in respect of the Personal Data about you; however, the rights of the Partner as a data controller in respect of the Personal Data about you shall enter into force only upon the termination of Our contractual relationship with SpinzWin.com, at which time we shall cease to be the data controller.

3. Data Protection Officer

4. When Do We Collect Personal Data About You?

We collect Personal Data about you whenever you use Our products and services, use the Website or Application, Our service channels and/or contact Us. In some instances, you will actively provide Us with the Personal Data, and in other instances We will collect the Personal Data about you from examining and analyzing your use of Our products and services and/or Our service channels.

5. No Obligation To Provide Personal Data To The Company And Its Implications

You are not obligated to provide Us with any Personal Data about you. However, in some instances, not providing such Personal Data will prevent Us from providing you with the products or services you request Us to provide you. Please see below a detailed description of such instances:

A legal obligation of the Company: there are certain legal obligations that require the Company to collect certain Personal Data as a precondition to providing products and services. In these instances, while you are not obligated to provide the Personal Data about you, if you will not provide the Company with such Personal Data, We will not be able to provide you with such products and services.

By way of example, We are required to collect your physical address and country of residence under our regulatory requirements as holders of online gambling licenses. While you are not obligated to provide Us with such information, if you will not provide it to Us, We will not be able to register you as a customer and provide you with Our products and services.

A contractual obligation of the Company: in some instances, the Company is contractually obligated to provide Personal Data about you. In these instances, while you are not obligated to provide the Personal Data about you, if you will not provide the Company with such Personal Data, We will not be able to provide you with the products and services to which the contractual obligation applies.

By way of example, if you do not provide Us with your credit card details, We will not be able to execute your withdrawal request via such credit card.

Providing Personal Data for the purpose of contracting with you: in some instances, providing Personal Data about you is a precondition to executing a contract between yourself and the Company. In these instances, while you are not obligated to provide the Personal Data about you, if you will not provide the Company with such Personal Data, We will not be able to contract with you and therefore will not be able to provide you with Our products and services

By way of example, in order to provide you with certain operational messages, relating to the products and services We provide, We will require to receive your email address.

6. What Personal Data About You Do We Collect?

Personal Data We collect upon registration: email address, first name, last name, gender, date of birth, physical address, city of residence, country of residence, zip code, phone number, mobile phone number, currency of account, language of account, occupation, publicly available data from the world wide web and social networks.

Personal Data We collect upon each logging in into your account: IP address, device info, operating system info, browser info, screen resolution, flash version, current and previous webpages browsed, date and time of login, location data.

Personal Data We collect during your use of Our products and services: your deposits, wagers, bonuses, game session (including date, time and duration), winnings and losses.

Personal Data We collect via Our support: passport / ID / driving license number and photo, utility bill.

Personal Data We collect upon receiving a deposit of funds and upon a withdrawal request: bank account details, e-wallet details, credit card details and photo, source of funds details, phone bill, bank statement.

Personal Data We receive from you: any Personal Data you provide to Us on your own free will when contacting Us, including via customer support, chat, social networks or in any other manner, including complaints, requests and comments. Our customer support representatives may record and/or document in writing your calls.

7. The Purposes Of The Processing Of Personal Data And Their Legal Basis

The Company processes your Personal Data for one or more of the purposes outlined in this section and according to the appropriate legal basis.

The Company shall not process Personal Data about you unless there is a legal basis for such processing. The legal bases according to which the Company may process Personal Data about you are as follows:

1. Your consent that the Company will process Personal Data about you for one or more specific purposes. By way of example, for the purpose of sending you marketing materials.Where the legal basis for the processing of the Personal Data about you is consent, you may at any time to withdraw your consent for the purposes for which you provided your consent by sending a notice free of charge to the following email address [email protected], or by changing your settings in your account.Where you withdraw your consent for the processing of Personal Data about you, We might not be able to provide you with some or all of the products and services you requested or in the form intended to be provided to you, and you will have no claim in respect of that.
2. Processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract. By way of example, for registering you as an account holder, or for allowing you to withdraw funds from your account.
3. Processing is necessary for compliance with a legal obligation to which the Company is subject. By way of example, on account of Our licensing obligations as holders of online gambling licenses.
4. Processing is necessary for the purposes of the legitimate interests pursued by the Company or by a third party. By way of example, for the purpose of improving our products and services, or for the exercise or defense of legal claims.

Whenever the processing of Personal Data about you is necessary for the purpose of the legitimate interests pursued by the Company or by a third party, the processing is conditional upon such interests not overridden by your interests or fundamental rights and freedoms which require protection of Personal Data about you. At any time, you may approach Us by sending a notice to the following email address [email protected] in order to receive information concerning the review performed by Us in order to reach the conclusion that We may process the Personal Data about you on account of such processing being necessary for the purposes of the legitimate interests pursued by the Company or by a third party.