Privacy Policy

PRIVACY POLICY for www.winner.com and related mobile applications (" Website").

This Privacy Policy is effective from 25 May 2018. We may change this Privacy Policy at any time, and if we do so will post the changes to this page as well as the date that the changes take effect.

This policy is made compliant with the General Data Protection Regulation (the “GDPR”), (Regulation (EU) 2016/679).

Our Privacy Policy below sets out in detail how we process your personal data, and we encourage and recommend that you read it in full. We understand that people have busy lives though, and so wanted to help you by providing a brief overview of how and why we process your personal data.

In general, we will only collect the personal data that we need from you to offer you our services. For example, if you want to gamble with us then we'll collect your name, username, contact details, date of birth and address in order to set you up with an account. We’ll process data on any games that you play so that we can identify if you have won and, of course, pay any winnings to you.

The other main reason we will process your personal data is to comply with our legal and regulatory obligations. As you may know, in order to provide you with gambling services, we are required to have a licence. As such, we will need to comply with our licence, and this may involve us collecting additional information about you.

Ultimately, we aim to only process your personal data where it is necessary. We will always keep your personal data secure. Your enjoyment of our services and your safety are our primary concerns.

1. Introduction

1.1. This Privacy Policy sets out the way in which Universe Entertainment Services Malta Limited ("we", " us" or "UEM"), a company incorporated and registered in Malta (company number C 60452), collects and processes Personal Information (as defined in paragraph 2.1 below). If you have any questions about this Privacy Policy or the processing of your Personal Information, please contact us at casino@winner.com.

1.2. By using our Services, you acknowledge that you have read, and agreed to, the terms of this Privacy Policy and that you consent that UEM and any company in our Group, as well as any partners and subcontractors, will process your Personal Information in accordance with this Privacy Policy, including for the purposes set out in paragraph 5 below. If you do not wish to provide your Personal Information on the basis set out in this Privacy Policy, you should not enter the relevant information on the Website, or otherwise provide us with your Personal Information. However, if you do not provide your Personal Information, you may not be able to use all of the Services.

1.3. Capitalized terms not defined in this Privacy Policy are as defined in the Terms & Conditions. This Privacy Policy is incorporated into, and forms part of, the Terms & Conditions.

2. The information we collect

2.1. As part of operating the Website, we collect your Personal Information. "Personal Information" means any information from which you can be personally identified, including your name, email address, home address, telephone number, debit/credit card data, and date of birth.

2.2. We collect Personal Information which you provide to us, including when you register for an Account and information you provide in communications with us. We also collect information about the transactions you undertake, including details of payment cards used. We may also collect Personal Information through surveys which we, or companies engaged by us for such purpose, undertake, as well as information about anyone who visits our Website. In addition, we collect information about your use of the Website and our Services. We will also collect other information necessary for us to process your Personal Information for the purposes set out in this Privacy Policy.

3. Information we collect through Cookies and similar technologies

3.1. We collect information through "Cookies" and other similar technologies (e.g. pixel tags or links). This helps us to remember you when you visit the Website, and to improve your experience.

3.2. We also use information collected through "Cookies" and other similar technologies to detect any fraudulent behavior, improper transactions and/or abuse of our Website and Services, and to help verify your identity by registering and remembering your device information.

3.3. To find out more about "Cookies" and similar technologies please see paragraph 11 of this Privacy Policy. More information about the purposes of the "Cookies" we use can be found in paragraph 5.

4. Information collected from third parties and how we use it

We use information from third party service providers, such as fraud prevention companies. This information may be used in various ways, such as to help us: (i) decide whether to accept transactions from personal computers, mobile phones or other devices by checking whether these devices have been identified with fraudulent or abusive transactions in the past; (ii) detect the inappropriate use of promotions we may run; (iii) detect whether you have (or may have) cheated or colluded with others; and (iv) investigate, mitigate and/or prevent identity theft, account takeovers or malware attacks. Third party service providers also help us verify your identity by registering and remembering your device information (such as the model, operating system, browser version and IP address), which is used to confirm device identification.

5. How we use your Personal Information

5.1. In accordance with data protection laws, we will only process your Personal Information where we have a lawful basis for doing so. In respect of your Personal Information, these bases are: (i) where it is necessary to provide services to you under the performance of the contract we have with you; (ii) where we are required to do so in accordance with legal or regulatory obligations; (iii) where you have given your consent; and, (iv) where it is in our legitimate interests to process your Personal Information, provided that none of these prejudice your own rights, freedoms and interests.

5.2. The following are a list of the "Purposes " for which we (including any of our agents, Group members, sub-contractors and/or employees) process your Personal Information, and the lawful basis on which we carry out such processing:

Purpose	Lawful Basis
To set-up, administer and manage your Account and records (including processing deposits and withdrawals)	Necessary for the performance of a contract
To provide and personalise our Services (including to allow you to wager and play our games, and (if applicable) to provide chat moderation)	Necessary for the performance of a contract
To receive and respond to your communications and requests	Necessary for the performance of a contract where such communication relates specifically to our Services, otherwise consent
To notify you about updates to our Website and Services	Necessary for the performance of a contract
To ensure that we are able to fulfil our regulatory obligations regarding your Account, including by verifying the accuracy of any information you provide us	Necessary to comply with a legal or regulatory obligation
To comply with our obligations under applicable laws and to regulators in jurisdictions where we and members of our Group are licensed (including the Malta Gaming Authority)	Necessary to comply with a legal or regulatory obligation
To investigate, and assist with the investigation of, suspected unlawful, fraudulent or other improper activity connected with our Website and Services (including, where applicable, dealing with requests from authorised entities (e.g. sports governing bodies and law enforcement agencies) for the sharing of information and disclosure to such authorised entities)	Necessary to comply with a legal or regulatory obligation
To carry out market research campaigns	Legitimate interests so that we can better understand the products and services that our customers most enjoy
To prepare statistics relating to the use of our Website and Services by you and other customers	Legitimate interests so we can understand the use of, and therefore improve, our Website and Services
To provide you with information about, and support for, our Services, including changes to our Services, technical updates for the Website and changes to the Terms & Conditions (including this Privacy Policy)	Necessary for the performance of a contact and necessary to comply with a legal or regulatory obligation
To keep you informed of offers and promotions relating to our Services and those of other entities within our Group, provided that you don't "opt-out" from this option	Legitimate interests so we can send you information about our Services (and promotions and offers) that you may be interested in
To keep you informed of offers and promotions for which you have specifically opted-in	Consent
To support any other purpose necessary for performance of our contractual obligations or specifically stated at the time at which you provided your Personal Information	Necessary for the performance of a contract
To record telephone calls to and from, and live chats with, our customer services representatives for training and security and identification purposes	Legitimate interests in respect of training so that we improve our customer services, and necessary for a legal or regulatory obligation in respect of security and identification
To prevent you from using our Services if you have requested that we do so	Necessary to comply with a legal or regulatory obligation
To comply with any deposit, spend or loss limits that you have set	Necessary to comply with a legal or regulatory obligation
To use your name, image, username or location in publicity and marketing, but only where you have provided your express and informed consent for us to do so	Consent
Cookies: Those that are necessary for the operation of the Website, including allowing you to interact with our Website and to recall selections as you move between pages	Necessary for the performance of the contract
Cookies: Those that analyses your use of our Website, monitor our web audience and populate certain content on our Website in line with your usage	Legitimate interest so we can continue to analyse and improve our Website and Services
Cookies: Those that track your journey to and from our Website	Legitimate interest so we can understand how players come to and from our Website and give effect to any commercial arrangements
Cookies: Those that are necessary for regulatory compliance, including identifying multiple accounts, false logins or potential fraud	Necessary to comply with a legal or regulatory obligation
Cookies: Those that are used for third party marketing	Consent

6. Disclosure of your Personal Information

6.1. Except as described in this Privacy Policy, we will not disclose your Personal Information to third parties without your consent. We may disclose your Personal Information to third parties if you consent to us doing so, and for the Purposes, we may also disclose your Personal Information to any of the following recipients:

6.1.1. any company within our Group (including to its employees and sub-contractors) which assists us in providing our Services, including (but not limited to) hosting services, customer services, marketing services, advisory services or which otherwise has a need to know such information;

6.1.2. any third party which assists us in providing our Services, including (but not limited to) payment processors, customer services representatives and chat moderators;

6.1.3. any third party which can assist us in verifying the accuracy of your Personal Information, including financial institutions and credit reference agencies (a record of the search may be retained by such third party);

6.1.4. any third party which assists us in monitoring use of our Services, including the detection and prevention of fraud and collusion,

6.1.5. any contractors or other advisers auditing any of our business processes or who have the need to access such information for the purpose of advising us;

6.1.6. any law enforcement body which may have any reasonable requirement to access your Personal Information;

6.1.7. any regulatory body or authorised entity (e.g. a sporting body or law enforcement agency) which may have any reasonable requirement to access your Personal Information; and

6.1.8. any potential purchaser of UEM's business or any investors in it or in any company within our Group (including in the event of insolvency).

6.2. We may also use and disclose information in aggregate (so that no individuals are identified) for marketing and strategic development purposes.

6.3. If at any time you wish us to stop processing your Personal Information for the above Purposes, you should contact us, and we will take the appropriate steps to stop doing so. Please note that this may mean that your Account will be closed.

7. Marketing Preferences

7.1. The Service may contain features or links to web sites and services provided by third parties. UEM and any company in our Group will not send you unsolicited information regarding any third party's products or services. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through the Service. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through the Service. We encourage you to learn about third parties’ privacy and security policies before providing them with information. If our practices change, we will do so in accordance with applicable laws and will notify you in advance.

7.2. As part of the Account registration process, you will have the opportunity to choose whether or not to receive information on offers and promotions from us and any company in our Group.

7.3. Unless you have informed us at the time of setting up your Account that you do not wish to receive promotional text messages and/or emails, we will send you such communications until you inform us that you no longer wish to receive them. You may update your marketing preferences at any time by:

7.3.1. if you are receiving emails, clicking on the "unsubscribe" link in an email and following the instructions;

7.3.2. if you are receiving text messages, by following the instructions to unsubscribe; or

7.3.3. contacting our Customer Services team at support.

8. Transfer of your Personal Information outside of the EEA

8.1. The data that we collect from you and process as a result of your use of the Services may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. By browsing this Website, communicating electronically with us and submitting your personal data, you acknowledge and agree to the transfer, storing and processing of your Personal Information in this way and acknowledge the transfer of the Personal Information we collect to authorized recipients outside the EEA. This includes, but is not limited to, the Mohawk Territory of Kahnawake, Israel, and the Philippines.

8.2. Where we transfer your Personal Information outside of the EEA, we will put in place adequate measures to ensure that your Personal Information is kept secure (and such adequate measures shall include: (i) transferring to a jurisdiction which the European Commission recognises as providing adequate protection for the rights and freedoms of data subjects in connection with the processing of their personal data; and (ii) transfers pursuant to standard contractual clauses in accordance with European Commission decisions on transferring personal data).

9. Updating your Personal Information

You may update or erase your Personal Information at any time by contacting our Customer Services team at support.

10. Your rights

10.1. We respect your privacy rights and provide you with reasonable access to the Personal Information that you may have provided through your use of the Services. Your principal rights under data protection law are:

10.1.1. a right to access your Personal Information as held by us (also known as a subject access request);

10.1.2. a right to receive Personal Information in machine-readable format;

10.1.3. a right to object to processing where the lawful basis is that it is in our legitimate interests, but please note that we may still process your Personal Information where there are other relevant lawful bases or where we have compelling grounds to continue processing your Personal Information in our interests which are not overridden by your rights, interests or freedoms;

10.1.4. a right to have inaccurate Personal Information rectified;

10.1.5. a right to have certain Personal Information erased where it is no longer necessary for us to process it, where you have withdrawn your consent pursuant to paragraph 10.1.8, where you have objected pursuant to paragraph 10.1.3, where your Personal Information has been unlawfully processed, or where erasing your Personal Information is required in accordance with a legal obligation;

10.1.6. a right to request an explanation of the logic involved where we make decisions about you solely through automated means;

10.1.7. a right to complain to your national data protection supervisory authority;

10.1.8. where we have specifically requested your consent to process your Personal Information and have no other lawful conditions to rely on, you have the right to withdraw this consent; and

10.1.9. a right to object to direct marketing, which can be done by opting-out of direct marketing either through your Account or by opting out via the communication itself. You also have a right to object to any profiling to the extent that it relates to direct marketing only;

10.1.10. a right to be notified of data breaches.

10.2. If you are unsure about your rights or are concerned about how your Personal Information may be processed, you should contact your national data protection regulator.

10.3. If you would like to exercise any of your rights, then you can do so by contacting us as described below. Please be aware that while we will try to accommodate any request you make in respect of your rights, they are not absolute rights. This means that we may have to refuse your request or may only be able to comply with it in part.

10.4. Where you make a request in respect of your rights we will require proof of identification. We may also ask that you clarify your request. We will aim to respond to any request within one month of verifying your identity, with a possibility to extend this period for particularly complex requests in accordance with applicable law. If we receive repeated requests or have reason to believe requests are being made unreasonably, we reserve the right not to respond.

10.5. In accordance with applicable law, we reserve the right to withhold personal information if disclosing it would adversely affect the rights and freedoms of others.

11. Retention of your Personal Information

11.1. 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. We will retain your Personal Information for as long as your Account is active or otherwise for a limited period of time needed to fulfil the purposes for which such Personal Information was initially collected, unless otherwise required by law.

11.2. Accordingly, your Personal Information will be retained for a minimum of five (5) years following the closure of your Account (if applicable) or the last activity made on your Account. Where it is no longer necessary for us to process your Personal Information, we will erase it sooner.

11.3. We may retain your Personal Information 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.

12. Contacting us

12.1. You can contact our Customer Services team using the details here.

12.2. If at any time you believe that we have not adhered to this Privacy Policy, please contact customer services and we will seek to promptly determine and correct the problem if applicable.

13. Advertising and use of Cookies

13.1. We may collect anonymous information about your use of the Website using "cookies", pixel tags and similar functionality. A "cookie" is a small file of text which is downloaded onto your computer when you access the Website, and it allows us to recognise when you come back to the Website. We use cookies for the operation of the Website, including (for example) to allow you to remain logged in as you move between different parts of the Website. We also use cookies for our own analytical purposes so that we can identify where customers have encountered technical problems on the Website, and therefore help us improve our customers' experiences. We also use services provided by third parties for fraud prevention purposes. For these purposes, Cookies are placed on your device to identify it in the future when you visit our Website or connect with our applications.

The cookies used on this Website are either set by us or by our third-party service providers, and fall into the following categories:

1) Strictly Necessary - these cookies are essential in order to enable you to move around the Website and use its features. If you remove or disable these Cookies, we cannot guarantee that you will be able to use our Websites or benefit from all our security features.

2) Performance - these Cookies collect information about how visitors use our Website. They allow us to recognise and count the number of visitors and to see how visitors move around our Website.

3) Functionality - these Cookies are used to provide services or to remember choices you make so we can personalise our content for you. We use this information to customise your experience of our Website to meet your preferences for content layout, text size etc. You can manage these Cookies using your browser settings. However, if you block them we may not be able to offer you certain services that you have chosen

4) Targeting - these Cookies record the fact that you have visited our Website, including which web pages you have accessed, which device you have accessed them from and which links you have followed. We use this information to make our Website relevant to your interests and for fraud and website abuse detection purposes, including detecting players who have abused bonus schemes or other promotions.

Some of these are "session cookies", which stay in place only for the duration of your visit to our website and are deleted at the end of your browsing session. Others are "persistent cookies", which remain on your device for a period of time after you have left the Website.

13.2. Most browsers have cookies enabled by default, but you are able to change your cookies settings, which are usually found in the 'options' or 'preferences' menu of your internet browser. You can block any cookies from any website by activating the setting on your browser that allows you to refuse the setting of some or all cookies. However, if you block all cookies you may not be able to access all or part of our Website. You can also use your browser settings to delete cookies. For more information about how to disable cookies in your browser please visit www.allaboutcookies.org.

13.3. As part of the Website's operation, and for our own statistical analysis of site traffic, our Website automatically logs internet IP addresses. We do NOT log any e-mail address of visitors to the Website. Our advertising system logs IP addresses to supply more accurate advertising features, such as language-specific banners.

13.4. While the Website may contain links to websites operated by parties other than us, we are not responsible for the privacy practices or content of such websites.

14. Security

14.1. We are committed to ensuring that your Personal Information is secure. In order to prevent unauthorized access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the Personal Information that we collect.

14.2. All the Personal Information that you provide us is stored in a secure computing environment protected by secure firewalls to prevent unauthorized access. We control access so that only people who need to access the Personal Information can. All staff are provided security training and are required to adhere to a comprehensive set of security policies, procedures, and standards related to their jobs.

14.3. When you use secure areas of our Website, we use SSL with 256 -bit encryption. This means that all the information sent between your computer and our secure computer environment is encrypted or scrambled so that no one can read it in transit. Secure areas of the site have a time-out feature. If you leave your secure session inactive for some time, it times-out to prevent unauthorized access.

14.4. Where your Personal Information needs to be disclosed to our service providers, we require them to process and protect your Personal Information in a manner consistent with this Privacy Policy and applicable laws.

14.5. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We cannot ensure or warrant the security of any information you transmit to us or store on the Service, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If you believe your Personal Data has been compromised, please contact us as set forth in the “Contacting us” section.

14.6. If we learn of a security systems breach, we will inform you of the occurrence of the breach in accordance with applicable law.

15. Data Protection Officer

Universe Entertainment Services Malta Limited has a Data Protection Officer (“ DPO”) who is responsible for matters relating to privacy and data protection. The DPO can be reached at the following address:

privacy@winner.com