Ellmount Entertainment Ltd

The purpose of this Privacy Policy is to explain how SITE collects, protects and uses personal information.
SITE is committed to ensuring that any personal information supplied by our customers or otherwise generated by our business activities is collected and processed fairly and lawfully.

Version 1.1, 2018-10-30

SUMMARY

By approving our terms and conditions for using our services, you agree to the use of your personal data stated in this policy, which includes but are not limited to; processing of your personal data in order to provide you with more specific marketing material or if applicable excluding you from receiving marketing material or blocking you from our services due to self exclusion.

Further we will store your personal data for purposes such as financial records, transaction data for prevention of fraud and other suspicious activities. And if applicable report the relevant authorities in your region if there is a legal requirement for us to do so.

We will also share your data with service providers to us in order to be able to fulfill our contractual agreement when you become a customer to us. For specific details on how we handle your personal data, please consult this Privacy Policy.

Since this Policy is a part of our terms and conditions when you become a customer to CasinoRoom, we want to urge you to read them thoroughly and secure that you understand all parts of the policy.

Since this Policy is a part of our terms and conditions when you become a customer to CasinoRoom, we want to urge you to read them thoroughly and secure that you understand all parts of the policy.

1. WHO WE ARE

In this policy references to “we”, “us” and “our”and “Ellmount” shall mean any company in the Ellmount Group. The Ellmount Group consists of Ellmount Gaming LTD, Ellmount Interactive AB and Ellmount N.V. Whereas “CasinoRoom” is a registered brand fully owned by Ellmount Gaming LTD.

The company organisation number is C52868, the address is Ewropa Business Center, Level 3/Suite 701, Dun Karm Street, Birkirkara BKR 9034, Malta. The company is licensed and regulation by the Maltese Gaming Authority with license number MGA/B2C/202/2011, that was som assigned the company on September 30th of 2011 and renewed on the 30th of September 2016.

References to “you” and “your” shall refer to the person using our Website and providing personal information to us.

2. THE PURPOSE OF THIS POLICY

We are fully committed to adhering with the relevant legislation on handling of personal data in order to protect and process your personal data in a compliant manner. The main regulation that we are obliged to follow is “The Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation). This legislation is in the following referred to as the “GDPR”.

This Privacy Policy describes the way in which Ellmount deals with the information and data you provide to us to enable us to manage your relationship with us. We will process any personal information provided to us or otherwise held by us relating to you in the manner set out in this Privacy Policy. Information may be provided via the CasinoRoom website (the "Website"), telephone calls, live chat or by any other means. By submitting your information to Ellmount and using our Website you confirm your consent to our use of your personal data as set out in this policy. If you do not agree with the terms of this Privacy Policy you may not use the Website, our services or otherwise provide us with your personal information.

3. HOW TO GET IN CONTACT WITH US

If you wish to get in contact with us regarding your personal data in any way, such as a request of data or general questions regarding your data, you can either send a letter to the address mentioned above marked with “DPO” (DPO means Data Protection Officer) or contact us via privacy@casinoroom.com. You can also get in touch with us through our customer service.

4. THE RIGHT TO LODGE A COMPLAINT

If you want to leave a compliant or in any other way know more on how we handle your personal data, you are welcome to contact our DPO via email; privacy@casinoroom.com

Further, you have a right to be informed on the right to lodge a complaint to the relevant Data Supervisory Authority in Malta.

If you are living in another region within the European Union, we wish to inform you of your right to leave a compliant with the supervisory authority in your region. You can see the relevant authority in your region here:

https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

5. YOUR RIGHTS

You need to be informed that you have rights by law that states that you have a right to access, rectify and erase your personal data with us. Further, you have a right to object to the processing your personal data and to be informed about the purpose of processing your personal data. And, you also own the right to lodge a complaint with us or the relevant supervisory authority (see section 4).

The mentioned rights are only valid if there is no other legal obligation that requires us to keep or handle your personal data, these could be, but are not limited to; accounting, anti-money laundering, anti-terrorist financing or other legal obligations.

6. THE PERSONAL DATA WE COLLECT AND PROCESS

In the following table you can see what type of personal data we process, the purpose of the process and the legal grounds for the processing. If you choose not to provide your Personal Data it may prevent us from meeting legal obligations, fulfilling a contract, or performing services required to run your account. Not providing your Personal Data may mean we are unable to provide you with products or services. Your personal information collected is necessary to deliver our Services to you and for the following purposes:

Personal data used Full name
Purpose Used for engaging in the customer relationship as a part of the identification process.
Legal ground /
Legitimate interests
In order to fulfill the contractual agreement between the company and the customer.
Personal data used Address
Purpose Used for engaging in the customer relationship as a part of the identification process.
Legal ground /
Legitimate interests
In order to fulfill the contractual agreement between the company and the customer.
Personal data used Mobile number
Purpose Used for engaging in the customer relationship as a part of the identification process. Sending of marketing information – if we have your consent.
Legal ground /
Legitimate interests
In order to fulfill the contractual agreement between the company and the customer.
Personal data used Email address
Purpose Used for engaging in the customer relationship as a part of the identification process. Sending of marketing information – if we have your consent.
Legal ground /
Legitimate interests
Complying with a legal obligation.
Personal data used Date of Birth
Purpose Used for engaging in the customer relationship as a part of the identification process.
Legal ground /
Legitimate interests
In order to fulfill the contractual agreement between the company and the customer.
Personal data used Gender
Purpose Used for statistical reasons for different Gaming Authority.
Legal ground /
Legitimate interests
Complying with a legal obligation.
Personal data used IP address
Purpose To verify which country, you as a customer is connecting from. It is further used for preventing fraud and improper use of our systems of different types.
Legal ground /
Legitimate interests
In order to fulfill the contractual agreement between the company and the customer. Also used for complying with regulatory and legal responsibilities.
Personal data used Cookies
Purpose To customize web content displayed to user.
Legal ground /
Legitimate interests
This data is used in compliance with legitimate interests of the company, such as but not limited to providing the services expected.
Personal data used Identity verification documents
Purpose Used for engaging in the customer relationship as a part of the identification process.
Legal ground /
Legitimate interests
In order to fulfill the contractual agreement between the company and the customer. Also used for complying with regulatory and legal responsibilities.
Personal data used Transaction history, regarding deposits, withdrawals, and in game results connected to your account
Purpose Used for book keeping/financial records, anti-money laundering reporting, counter terrorist financing reporting and other financial legislation. Also used for processing your bets and transactions including your use of credit cards and on-line payment systems.
Legal ground /
Legitimate interests
The legal basis for processing this data is to uphold the company’s legal requirements according to external legislation such as the 4th AML Directive on combatting money laundering and terrorist financing. Further, it is used for book keeping as required by law.
Personal data used Other type of information that you provide to us by filling in forms on the Website or any other information you submit to us via the Website, email or web chat
Purpose Providing customer support for our products and services. Used for answering your questions and offering support within the contractual agreement.
Legal ground /
Legitimate interests
In order to fulfill the contractual agreement between the company and the customer.
Personal data used Records of correspondence, whether via the Website, email, telephone and web chat or through other means of communication.
Purpose Providing customer support for our products and services. Used for answering your questions and offering support within the contractual agreement.
Legal ground /
Legitimate interests
In order to fulfill the contractual agreement between the company and the customer.
Personal data used Your responses to surveys or customer research that we carry out from time to time Details of the transactions you carry out with us, whether via the Website or other means of communication.
Purpose Used for improving our services and offer
Legal ground /
Legitimate interests
This data is used in compliance with legitimate interests of the company, such as but not limited to providing the services expected.
Personal data used Gaming behavior and use of the site, transaction history and personal pre-requisites related to the use of our services
Purpose Used for improving our services and offer.
Legal ground /
Legitimate interests
This data is used in compliance with legitimate interests of the company, such as but not limited to providing the services expected.

7. THIRD PARTY REFERALS

From time to time, we could offer different types of bonuses in relation to third party referrals. Those bonuses could be based on a situation where you as a customer to us could refer a friend of yours to us. If this would in any type be applicable and if you give us information about someone else, regardless if that person is a customer to us or not, you must seek approval from that person approval for referring the person to us before you do so.

If we would send out a referral link that you as a customer could send to a friend and then receive a referral bonus for, you must also seek that person’s approval before doing so.

The referred person will regardless be informed on our Privacy Policy when entering into a customer relationship with us and the data belonging to that person will be handled in accordance with this Privacy Policy as well as the applicable law.

8. AUTOMATED DECISION MAKING

We are obliged by law to give you information about the type of logic behind the processing that could be applicable on your personal data. The purposes and legal grounds for the processing are stated in section 7. The following is a short summary of the type of logic that is applied in each case.

8.1 RISK BEHAVIOR / RESPONSIBLE GAMING CasinoRoom is legally bound by law to monitor our players from a risk perspective related to responsible gaming. In order to identify players who shows risk behavior and contact these players with support or help in accordance with our Responsible Gaming obligations to protect you from harmful use of our services, CasinoRoom monitors gameplay/deposits and other transactions to be able to find these players.

There is always a human decision in the end, but your personal data is subject to this automation in the form of triggers related to your general player behavior, for your protection.

8.2 RISK BEHAVIOR / AML & CFT CasinoRoom is legally obliged by laws and various regulations to take actions against possible money laundering and financing of terrorist activities. Therefore, your behavior is monitored for these purposes when using our services. The identification for your personal data, transaction behavior and other relevant factors are being processed with regards to the relevant risks that could be connected to the region you are active in, your type of player behavior and other factors related to your person.

These factors are monitored, and alarms are triggered if any of your actions pose as a possible risk related to these matters. The alarm then triggers an operator that will create an assessment based on the alarm.

8.3 VIP/LOYALTY/MARKETING In order to provide you as a player with the best possible experience we always strive to improve our services to you as a customer. A part of that includes our VIP and Loyalty programs. In order to be included in any of the programs we monitor, process and store your transactions and behavior to see if you could be eligible for participation. The logic is based on different aspects such as a general turnover perspective, your country of residence and other factors of information that you provided us with during registration and during your customer life cycle.

9. MARKETING

In order to provide you as a player with the best possible experience we always strive to improve our services to you as a customer. Therefore, we try to contact you, from time to time and only with your consent, with campaigns based on your pre-requisites and behavior on our site. This could include your behavior such as signing up but not depositing, signing up and depositing or depositing only once. In those cases, we could come to contact you with relevant offers to make your signing process smoother.

The logic behind this automation is that we sort out players based on different activities.

10. DATA RETENTION

We will keep your data for the period that you are a customer to us. If you are no longer a customer, we will keep your data for the minimum length of time required by law. Data shall only be used should it be required in cases of enquiries relating to financial, fraud, money laundering or investigations into any other illegal activity or by any other legal obligations.

11. INFORMATION SHARING AND DISCLOSURE

We may share your Personal Data that you have given to us to other companies within the Ellmount group and with other organizations including:

  • Law enforcement agencies, regulators and other authorities.
  • Fraud prevention agencies.
  • Identity verification agencies.
  • Payment processing agencies.
  • Credit Reference agencies.
  • Organizations that introduce you to us.
  • Third parties you ask us (or permit us) to share your data with.
  • Game providers for the purpose of providing different games.
  • Marketing providers for providing marketing activities on behalf of CasinoRoom.
  • Service providers of technical communication in order to communicate with you.
  • Other organizations that helps us understand and process data in a secure and standardized manner.

Data Processing of your information may be undertaken by any company within the Ellmount Group, which may use a third party to fulfill such data processing needs. Where your Personal Data is transferred outside of the European Economic Area (“EEA”), we shall take all reasonable steps to ensure that your information and data is treated securely and in accordance with this Privacy Policy as well as complies with all legal requirements associated with such a transfer. We do not sell personal data to third parties however, your personal data may be transferred if the Ellmount Group is acquired by a third party, merged with a third party or if Ellmount sells all or substantially all of its assets, or otherwise transfers substantially all of its assets to a third party. In this event, we will inform you prior to affecting such transfer of the personal data.

12. DATA GATHERING

12.1 LEGAL OBLIGATIONS We will gather data from different types of sources depending on what purpose we need to use them for. Regarding AML/CFT, sanctions screening, fraud related issues and controls of politically exposed persons we could gather data from different providers, primarily ZignSec AB. Please be advised that we have a legal obligation to gather data on your person (defined in section 6) in order to be compliant with our legal obligations, such as the 4th AML and CFT Directive (EU) 2015/849 on the prevention of the financial system for the purposes of money laundering or terrorist financing.

12.2 CUSTOMER DATA In order to be compliant with the relevant Responsible Gambling regulation by as well as segmenting our customers in order to provide the most relevant offers, we also use providers such as Bisnode AB, Google and Quantcast. Apart from this purpose, we use data so that we can segment our customers and provide our customers with the most relevant offers such as our VIP offering. We also use the data in some cases exclude our customers from marketing if needed due to self-exclusion purposes. We could also come to use different national self-exclusion registers in order to block customers from using our services when / if they chose to self-exclude themselves from all online-gambling providers.

13. YOUR RIGHTS

You have the right to access and rectify your personal information we have collected. This right includes:

  • Confirmation of the accuracy of the personal data we have collected,
  • Request the deletion or rectification of personal data that is inaccurate
  • Provide details as to the use of your personal information,
  • Prohibit future use of your data for marketing purposes.

If you wish to contact us regarding your personal information, please send an email to privacy@casinoroom.com.

14. CHANGES TO PRIVACY STATEMENT

We may update the terms of this policy from time to time and we will notify changes to you by posting the modified terms on the Website. We recommend that you revisit this Privacy Policy regularly. We will store earlier versions of this policy if you wish to receive a copy.

15. SENSITIVE DATA AND DATA OF CHILDREN AND MINORS

We do not store sensitive personal data such as information on health, ethnic origin, political views etc. However, we might have to store sensitive personal data related to our responsibilities in accordance with Responsible Gaming. That means, if you for example applied for self-exclusion due to gambling addiction or likewise, we will store that information in order for blocking you from our services or marketing campaigns, we might however still contact you with other purposes, such as support for withdrawal of funds or likewise.

We do not accept minors or children to use our services and we do not store personal data that belongs to minors or children.

16. USE OF COOKIES

By registering an account and/or using our services, for example using our website, you acknowledge that we use cookies.

16.1 WHAT IS A COOKIE? Cookies are small text files containing information which are sent to and stored on your computer, smartphone or other device when you access a website. Cookies are then sent back to the originating website on each subsequent visit or to another website that recognises that cookie. Cookies are useful because they allow a website to recognise a user's device. You can find more information about cookies at www.allaboutcookies.org

16.2 USE OF COOKIES ON THE WEBSITE We use cookies to collect information including the type of browser you use and your IP number. This information is collected for security reasons and with the aim of constantly improving our service to better meet your needs. Ellmount also uses a session-cookie to authenticate our customers after login. This cookie will be terminated as soon as you log out from your account. We will always strive for no unnecessary use of cookies.

16.3 MANAGING COOKIES If you want to delete any cookies already stored on your computer or stop the cookies that keep track of your browsing patterns on the Website, you can do so by deleting your existing cookies and/or altering your browser's privacy settings (the process you follow will differ from browser to browser). Please note that deleting our cookies or disabling our future cookies means that you may not be able to access certain areas or features of the Website.

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