River Game Operations Limited Privacy and Cookies Policy
1.1 The following terms, when capitalised, shall have the meanings ascribed to them below:
- “Account Data” means all information required by Us to open a Gaming Account in Your name, as well as all activity that occurs in and through such Gaming Accountincluding Your name, residential address, telephone number, email address, credit card details, transactional details, details of Your activity in the Gaming Account and on the Website and all communications between You and Us;
- “Data Protection Regulation”means Regulation (EU) 2016/679 of the European Parliament and of the Council;
- “FIAU”means the Financial Intelligence Analysis Unit;
- “Enquiry Data”means information contained in any enquiry You submit to us regarding Games and other products and/or services, including the communication content and metadata associated with the communication;
- “Games”means the casino games and other games, which are available on the Website;
- “Gaming Account”means a virtual account created with Us, in the name of a person who has completed registration in accordance with Clause 8 hereunder;
- “Identification Details”means the username and password chosen by You when opening a Gaming Account in accordance with Clause 7 hereunder, and/or any other means used to access your Gaming Account;
- “MGA”means the Malta Gaming Authority;
- “Notification Data”means Information that You provide to us for the purpose of subscribing to our email notifications and/or newsletters;
- "Personal Data"means any information considered to be personal data in accordance with the EU General Data Protection Regulation
- “Usage Data”means data about Your use of the Website. Usage data may include Your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views, website navigation paths, and information about the timing, frequency and pattern of Your use;
- “We”means River Game Operations Limited, a company incorporated under the laws of Malta, having its registered office at Regent House, Office 21, Bisazza Street, Sliema SLM1640, Sliema registration number C84393; and any reference to “Our” and/or “Us” shall be construed accordingly;
- “Website”means VegasCasino.com
- “You” means the individual currently reading these T&Cs for any reason and in any manner whatsoever, and any reference to “Your” shall be construed accordingly;
2. WHO WE ARE
2.1 The Website is owned and operated by River Game Operations Limited.
2.2 You can contact us:
(a) by post, using the postal address above;
(b) using the Website contact form;
(c) by email, on firstname.lastname@example.org
2.3 Data protection officer
Our data protection officer's contact details are: Luke Ciantar
Regent House, Office 21, Bisazza Street Sliema, SLM 1640 – Malta
Please note that River Game Operations Limited commenced operations on the [2ndAugust 2018]. River Game Operations Limited did not process any of Your data before this date and is not responsible for any such processing which may have occurred before the aforementioned date. You have any queries, issues or complaints in relation to the processing of Your data prior to the aforementioned date, kindly contact email@example.com.
3. WHAT THIS POLICY IS FOR
3.1 We want You to know exactly how We process Your Personal Data, that’s why we have put this page together. The way we do things depends on HOW You are using the Website:
3.1.1 If You’re just taking a look, seeing what Games We offer, or if You wish to enquire about the Games or to subscribe to our email notifications and/or newsletters, without actually registering a Gaming Account, Clause 4 is of particular importance to You. What We do with Your data in these situations is entirely up to You, and You can change Your decision at any time by clicking here. You also have a number of rights that apply to You.
3.1.2 If You have taken a look and You like what You see, You may wish to play some of Our Games. In order to do so, You will need to register aGaming Accountwith Us.This is mandatory in accordance with applicable gaming and anti-money laundering legislation in Malta. Also mandatory is all the information we need to ask You for in order to complete registration, and at various stages throughout Your relationship with Us. We will also need to monitor Your activity on the Website and in Your Gaming Account and keep a record if it. Please read Clause 5well in this case as it details specifically how We process Your data. Please note that in this case, due to the fact that all this information is required under legal obligations that apply to us, You will not be able to opt out of our processing of such information. Your only option will be not to make use of the Games. You do, however have a number of rights that apply to You.
4. PROCESSING YOUR PERSONAL DATA FOR MARKETING PURPOSES
4.1 In this clause we have set out:
(a) the general categories of Personal Data that we may process for marketing purposes;
(c) the purposes for which Personal Data may be processed; and
(d) the legal bases underlying the processing.
4.2 We may process Usage Data. We obtain Usage Data from Our analytics tracking system and may also personally identifiable information from Our fraud detection system. We process Usage Data with the intent of analysing the use of the Website and to ensure that You have a better Website experience. We also process this data with a view to offering, marketing and selling other relevant products and/or services to You. Our legal basis for processing Usage Data isOur legitimate business interest to ensure that the services that We offer are relevant and compare well with those offered by the competition, as well as Your consent - we generally carry out any tracking of personal data if You have consented to it on the Options pageof the Website.We may, however, keep Usage Data in an anonymized form for the purpose of improving our products, service and the information on the Website.
4.3 We will process Notification Data. We obtain Notification Data from You when You subscribe to our email notifications and/or newsletters. Such data may be processed with a view to sending You the relevant notifications and/or newsletters and to offer, market and sell other relevant products and/or services to You. Our legal basis for processing Usage Data is Your consent, which is given by You on the Options pageof the Website, and which can be withdrawn at any time by updating Your preferences through the same link.
4.4 We will process Enquiry Data.We obtain Enquiry Data from You. The Website will also generate metadata associated with communications made using the Website contact forms or through any chat function that We may provide. We process this data to respond to a query You have made to Us and to offer, market and sell other relevant products and/or services to You. The legal basis for this processing is Our legitimate interest based on reasonable expectations that You need to be tracked in order for Your enquiry to be able to be processed. We may also, keep Enquiry Data in an anonymized form for the purpose of improving our products, service and the information on the Website.
4.5 Any of Your Personal Data identified in the other provisions of this policy may be processed where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interest, embodied in the protection and assertion of our legal rights, Your legal rights and the legal rights of others.
4.6 Further to the specific purposes for which we may process Your Personal Data as detailed in the present clause, we may also process any of Your Personal Data where such processing is required to enable Us to comply with any other legal obligation to which We are subject.
5. PROCESSING PERSONAL DATA RELATING TO YOUR GAMING ACCOUNT
5.1 In this clause we have set out:
(a) the general categories of Personal Data that we process, in order to open and to operate Your Gaming Account;
(c) the purposes for which Personal Data may be processed; and
(d) the legal bases underlying the processing.
5.2 We will process Your Account Data on a daily basis. We obtain Account Data (a) from You when (i) You register a Gaming Account with Us or (ii) You agree to transfer Your existing Gaming Account to Us and (b) from software applications, databases and information systems that We operate to collect data about all Your activity on Your Gaming Account. If You agree to transfer Your existing Gaming Account to Us, We will receive all data which relates to Your existing Gaming Account and which was in the possession of the previous operator (who will also retain Your data for the period mandated by law), The Account Data may be processed for the purposes of operating the Website, to allow You to play the Games and to makes wagers, to withdraw and deposit funds (upon Your instructions) from and to Your credit cards and/or bank accounts, to verify Your identity, to ensure that funds deposited into Your Gaming Account were obtained legally, to ensure that Your Activity in playing the Games and on the Website is legal, fair and in compliance with the T&Cs and with all applicable legislation. We will monitor all Your activity in the Gaming Account and We will record it. We do this in order to: (a) comply with gaming and anti-money laundering legislation, and other regulation applicable in Malta, (b) to ensure the security of the Website and the Games, (c) to provide You with a service and (d) to communicated with You in relation to that service. Our legal basis for processing of Account Data is our legitimate interest to ensure the proper administration of the Website, the Games and the business, the proper performance of a contract between You and Us, the holding of records for business purposes, and our legal duty to comply with all legislation applicable to the gaming sector in Malta. We also rely on Your consent to process Account Data, in the sense that You are able to close Your Gaming Account and to request erasure of all information related thereto; however, it is NOT possible to have an active Gaming Account without allowing us to process all the Account Data as described in this clause and in the rest of this policy.
5.3 Any of Your Personal Data identified in the other provisions of this policy may be processed where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interest, embodied in the protection and assertion of our legal rights, Your legal rights and the legal rights of others.
5.4 Further to the specific purposes for which we may process Your Personal Data as detailed in the present clause, we may also process any of Your Personal Data where such processing is required to enable Us to comply with any other legal obligation to which We are subject.
6. WHO HAS ACCESS TO YOUR DATA IN OUR ORGANISATION
6.1 In this clause we explain who, within our organization, has access to which data, and how access is restricted.
6.2 Each office will designate an individual(s) to be responsible for assuring that protected information, as well as the hardware or electronic media on which it is stored, is properly destroyed and cannot be re-created.
6.3 Each office will designate an individual(s) to oversee the monitoring process and another individual(s) to document disposal information beginning with the point of designation for destruction to final disposal.
6.4 The chain of custody of the data will be established and maintained in the disposal documentation and will clearly identify the asset or media to be disposed, as well as the individual(s) responsible for its disposal.
6.5 Disposal information will be kept for a period and each office will submit a report to the ISO on a semi-annual basis.
6.6 All employees responsible for disposal activities will receive periodic training on IT policies and procedures on the use of software and tools utilized to prepare and audit media and devices for disposal.
6.7 Employees or systems administrators or managers who willfully or knowingly violate or otherwise abuse the provisions to this policy may be subject to either disciplinary action or criminal prosecution.
7. PROVIDING YOUR PERSONAL DATA TO OTHERS
7.1 In this clause we explain when Your Personal Data may be transferred to third parties.
7.2 The Website VegasCasino.comis physically hosted in Frankfurt.
7.3 Your Personal Data may be disclosed to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as this is reasonably necessary for the purposes mentioned in this policy.
7.4 Your Personal Data may be disclosed to our insurers and/or professional consultants, service providers, advisers and business partners inasmuch as this is reasonably necessary for the purposes of carrying on our business, marketing, obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes.
7.5 We may disclose email addresses, phone addresses for email or sms marketing communication purposes that You would have agreed upon at registration or at any other time. The recipients of this data will not send You, marketing communications on Our behalf. The data is simply entered into their system (API connection) and enables Our employees to run CRM activities. Our employees have access to this data on a strict ‘need to know’ basis.
7.6 The majority of the service providers/partners/other recipients of data who are able to access the data We collect about You in accordance with this Privacy Notice are located within the EEA, and we have data processing agreements in place with these parties. We also work service providers/partners/other recipients of data located outside the EEA. We have appropriate legal and security relationships with these parties and have taken steps to ensure that they are complying with the General Data Protection Regulation, including, as necessary, execution of contracts based on the European Union’s Standard Contractual Clauses for cross-border data transfers and/or Binding Corporate Rules as necessary or applicable.
7.7 We may disclose Your Personal Data where such disclosure is required in order to comply with any legal obligation to which we are subject, or in order to protect Your vital interests or the vital interests of another natural person. Please note that if We suspect You are in violation of any anti-money laundering legislation, we will be obliged to inform the relevant authorities. Please see Clauses 4.3 and 8.12 of the T&Cs for more detail.
8. RETAINING AND DELETING PERSONAL DATA
8.1 In this clause we explain our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of Personal Data.
8.2 Personal Data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
8.3 We will retain and delete Your Personal Data as follows:
(a) We will retain your information for as long as Your account is active or as needed to provide any services to You.
(b) If you wish to cancel your account or request that we no longer use your information to provide you services contact us at firstname.lastname@example.org.
8.4 In some cases it is not possible for us to specify in advance the periods for which Your Personal Data will be retained. In such cases, we will determine the period of retention based on the following criteria: compliance with relative legislation/ instruction from relevant authorities, dispute resolution and agreement enforcement.
8.5 Notwithstanding the other provisions of this Clause, we may retain Your Personal Data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect Your vital interests or the vital interests of another natural person.
9.1 We reserve the right to modify this policy from time to time by publishing a new version on [www.vegascasino.com]. Additionally, we will notify You about any significant changes through notice on the Website and upon Your next login into Your Gaming Account.
9.2 You will be required to re-confirm Your acceptance of this policy before using the Games on our Website. If you do not agree to the updated policy, You will no longer be able to use the Games on our Website.
10. YOUR RIGHTS
10.1 You may instruct us to provide You with any personal information we hold about You by completing this form; provision of such information will be subject to the supply of appropriate evidence of Your identity. For this purpose, we will usually accept a photocopy of Your passport certified by a lawyer, notary, accountant or bank, together with an original copy of a utility bill showing Your current residential address.
10.2 We may withhold personal information that You request to the extent permitted by law. In the event that We refuse Your request, we will provide you with a reason. You have the right to complain as detailed in Clause 15 below.
10.3 You may instruct us at any time not to process Your personal information for marketing purposes by simply changing Your preferences on the Options page.
10.4 You also have the following rights:
- Right to be forgotten – in certain circumstances You can ask for the data we hold about you to be completely erased from our records.
- Right to restriction of processing – in some situations You have a right to restrict the processing.
- Right of portability – You have the right to have the data we hold about You transferred to another organization.
- Right to object to automated processing, including profiling – You have the right to be subject to the legal effects of automated processing or profiling.
- Right to judicial review:
All of the above requests will be passed on, where applicable, to the relevant third parties outlined in Clause 7 above.
11. THIRD PARTY WEBSITES
11.1 The Website may include hyperlinks to, and details of, third party websites. We have no control over, and are not responsible for, the privacy policies and practices of third parties.
12. PERSONAL DATA OF CHILDREN
12.1 The Website and Games are only accessible by individuals over the age of 18. If we have reason to believe that we hold Personal Data of a person under that age, we will delete it immediately.
13. UPDATING INFORMATION
13.1 Please let us know if the personal information that we hold about You needs to be corrected or updated.
14.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
14.2 Some types of cookies may be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date. Other types of cookies expire at the end of the user session, when the web browser is closed.
14.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about You may be linked to the information stored in and obtained from cookies.Some cookies come directly from our Website and others come from third parties which place cookies on our site, this is explained here Cookies we use.
14.4 Most browsers allow You to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
14.5 Blocking all cookies will have a negative impact upon the usability of many websites. If You block cookies, You will not be able to use all the features on the Website.
15.1 Should You wish to make a complaint about how your Personal Data is being processed by Us (or third parties as described in Clause 7 above), or how Your complaint has been handled, You have the right to lodge a complaint directly with Office of the Information and Data Protection Commissioner (https://idpc.org.mt/) and with Our Data Protection Officer.
The version of this Privacy & Cookies Policy is currently Version 1.1 and was last updated on [26/06/2018]. It is valid and applies to You until a new version uploaded on the Website and is accepted by You.