1. Introduction
This Privacy Policy applies to all websites owned and operated by the Company and all services provided by the Company, including online and mobile services and products. In this Policy, they will be referred to as ‘websites’ and ‘services’.
The term ‘Personal Data’ means personally identifiable information such as your name, email address, address, telephone number, payment profile details, payment information, support requests, betting history, chat comments, etc. If it is not possible to identify you, this Policy does not apply. For example, Personal Data is collected and anonymised.
This Policy may change from time to time. In the event of material changes, we will notify you by posting a notice on the Website or sending an email.
2. What data we collect and how
When you visit our website or use our services, we collect and process your personal data. The ways in which we collect data can be categorised as follows:
Information you give us directly
When you visit or use any part of our website and/or our services, we may ask you to provide us with personal information. For example, we ask you to provide contact information or certain documents during registration, verification and money laundering or fraud screening procedures, and when you contact us with questions or support requests.
The information is collected automatically
We automatically collect certain information about you when you visit our website, such as your IP address, operating system, device type and settings, browser type and settings, problem reports, system activity, and the date, time and URL of the page from which you accessed our website. This information is useful to us because it helps us to better understand how you use our website and services and to provide you with the best level of service. For example, using information from your browser, we can determine what language you speak.
Some of this information is collected using cookies, similar tracking technologies and third-party tools such as Google Analytics.
We also collect data about your transactions with us and your account activity.
Information received from third parties
Sometimes we may collect your personal data from other sources, such as publicly available materials or trusted third-party sources, such as our payment service providers. We use this information to refine your personal data, to better inform you, personalise and improve our services, and to verify the personal data you provide to us.
3. Legal basis of personal data processing
When we collect personal data, we will only process it if there is a lawful basis for such processing as set out in the relevant data protection laws. Such lawful grounds are:
Contract fulfilment
We may process your personal data where this is necessary to fulfil the terms of the contract. For example, when you register on the Websites, you enter into an agreement with us or when we perform actions related to the contract, in particular to carry out transactions on the Websites.
Legal Obligation
Various laws and regulations impose certain obligations on us. We need to process your personal data in order to comply with these obligations, for example, to comply with anti-money laundering legislation, responsible gambling requirements and the terms of our gambling licence.
Legitimate interests
Your personal data may be processed if we, other companies in our group of companies or third parties have a business or commercial reason to process your personal data.
Your consent
In certain limited circumstances, we process your personal data on the basis of your consent, for example if it is necessary for direct marketing purposes.
4. How we use Personal Data
To operate our websites, to ensure that our websites and services function properly, and to provide the services you have requested (fulfilment of contract, legitimate interests).
To verify your ability to use certain services, including verifying your age, geographic location, identity or self-exclusion status, and to create and manage your account (fulfilment of contract, legitimate interests).
To comply with legal obligations, responsibilities and duties, to comply with the laws and requirements applicable to us and the terms of our gambling licence, and to prevent illegal activity, including money laundering and match-fixing (legal obligations).
To support customers, including to help resolve technical and payment problems or other issues relating to the websites or services (performance of contractual obligations).
To improve our websites and services, to test and develop new features, and to conduct technical analysis of our websites and services to optimise your interaction with our websites and provide you with better tools (legitimate interests).
To prevent, detect and report crime, to protect you, other users and us, for example to ensure network and information security, to mitigate risks, to detect and prevent any fraudulent or malicious activity, and to ensure that you use our websites and services in good faith and comply with the Agreement (legal obligations, legitimate interests, contractual performance).
To analyse and summarise data and compile statistics, in particular to create aggregated and anonymous analyses and reports for internal use, public distribution or for third parties (legitimate interests).
To carry out, manage and validate financial transactions (contract fulfilment, legitimate interests).
To analyse your risk of fraud and validate your data with a third party, including financial institutions, identity verification agencies and credit information bureaus (legal obligations, contract performance, legitimate interests).
To assess your gaming activity to ensure responsible gaming (legal obligations, legitimate interests, fulfilment of contract).
To monitor your gaming activity and manage our risks and opportunities (legal obligations, legitimate interests, fulfilment of contract).
To protect our rights under the Agreement or other agreements with you (contractual performance).
To disclose information to our Group companies following a restructuring or for internal administrative purposes (legitimate interests).
To manage our relationship and communications with you. This may include operational communications such as notifications of changes to our websites or services, information about new features, bonuses and promotions, security updates or assistance in using our websites and services, marketing communications and providing you with information you have requested or information we are obliged to provide to you (fulfilment of contract, legitimate interests, your consent).
5. How we may share your Personal Data
We may need to disclose your personal data to a third party. We may disclose your personal data:
To other companies within our group of companies:
To third party service providers and partners who assist us in providing the Websites and Services you have requested, such as those who provide access to or operate the Websites or Services, or who promote our Websites and Services.
To regulatory, law enforcement, governmental authorities, courts, fraud prevention agencies, licensing authorities, cyber sports self-governing bodies or other third parties as we deem necessary to comply with relevant laws and requirements or to exercise, establish and protect our legal rights (we will notify you of such disclosure where possible and appropriate);
To partners or other persons who have introduced you to us;
To other persons, subject to your consent.
6. International data transfer
When information is processed and transmitted, it may be transmitted and processed in countries other than your country of residence. The laws of these countries may be different from those with which you are familiar. When we process personal data in another country, we take precautions to protect your personal data.
For individuals living in the European Economic Area (EEA), this means that your data may be transferred outside the EEA. If your data is transferred outside the EEA, it is transferred to countries where we have appropriate data transfer mechanisms in place to protect your personal data, in particular the application of the European Commission’s standard contractual clauses to contracts with organisations to which the information is transferred.
7. Safety
We are committed to protecting your personal data and take appropriate technical and organisational measures, including:
Data Encryption. To protect your personal and financial data, we encrypt all data exchanged with you using the industry standard TLS (Transport Layer Security) (Transport Layer Security protocol). Your data is also stored on our servers and transferred for backup and replication between data centres in encrypted form.
Access Restriction. Only our employees, contractors and agents who need to process this information have access to Personal Data.
Network Security. Access to our network space, both externally and internally, is protected by a multi-layered security system that includes firewalls, intrusion protection systems and network segmentation. Our security systems are configured, managed and maintained according to best practices. We partner with leading security vendors, leveraging their expertise and the threat intelligence they collect to protect our systems.
Secure data centres. Our servers are located in industrial-grade hosting centres that employ robust security systems to prevent physical access to secure servers. These security systems include 24/7 continuous monitoring and surveillance, on-site security personnel and regular security audits. We use geographically isolated copies of data to minimise the risk of data loss or failure.
Security Monitoring. Our security team continuously monitors security, event logs, notifications and alerts of all systems to identify and address threats.
8. Data storage
Some data you can delete at any time, some data is deleted automatically and some data we retain for a longer period of time if necessary. When you delete data, we ensure that it is securely and completely deleted from our servers or stored exclusively in an anonymised form. The information is stored until you delete it.
We offer a number of services that allow you to correct or delete data associated with or stored in your account. For example, you can:
- Change your information.
- Delete the chat copy.
- Delete the account completely.
To comply with regulatory requirements and legal obligations and to avoid any claims against us, we will retain your account information until your account is closed and then for five years after your account is closed (if applicable) or after your last contact with us.
Information is kept for a limited period of time for a limited number of people. In some cases, business and legal requirements may require us to retain certain information for specific purposes for an extended period of time. For example, if an individual has independently opted out of our services, we will retain their personal data for longer as required by responsible gambling.
Reasons why we may keep some data for longer include:
- Protecting you, others and us from fraud, abuse, criminal activity and unauthorised access, for example when we suspect someone of fraud, match-fixing or money laundering.
- Complying with tax laws, anti-money laundering measures and other financial requirements, maintaining accounting records or assisting in the resolution of disputes, for example when you are involved in financial transactions, including receiving your deposit and paying out your money.
- Complying with applicable laws, regulations, court procedures or executive requests and the need to honour agreements, including investigating possible breaches.
- Ensuring that our services run smoothly for you and other users.
- In the event that you contact us directly, such as through support or by submitting feedback or bug reports.
- We are committed to protecting the confidentiality of your personal data, collecting, using and/or storing it in accordance with applicable data protection laws and requirements and in particular the provisions of (country) data protection laws and other applicable international data protection regulations, such as the EU General Data Protection Regulation (GDPR) of 2016 (‘Data Protection Laws’).
9. Your rights
You have certain rights in relation to your Personal Data:
- To find out what personal data we hold about you.
- To correct or ask us to correct inaccurate personal data about you.
- To access your personal data and request a copy of it in machine-readable form.For example, if you want a backup copy.
- To object to the processing of your personal data where we are guided by our legitimate interests. Please note that we may continue to process your personal data if there are other appropriate legitimate grounds or compelling reasons to continue processing the data for our legitimate interests that do not conflict with your rights, interests and freedoms.
- Ask us to delete your personal data, including your account, only if (1) we no longer need to process it, (2) you have withdrawn your consent to processing and your consent was the lawful basis for processing your data, (3) you have exercised your right to object and there are no compelling legitimate grounds to continue processing the data, (4) your personal data has been processed unlawfully, (5) or the deletion of your personal data is necessary to fulfil legal obligations. Please note that we will not delete and will continue to retain data in particular if the retention of personal data is necessary for the realisation of our legitimate interests that override your request, to comply with legal obligations or if it is necessary for the formation, exercise or defence of legal claims.
- To ask us to restrict the processing of personal data in certain circumstances.
- To withdraw consent previously given if it was necessary for the processing of personal data. Please note that we may continue to process your personal data if we have other lawful grounds to do so.
Object to direct marketing and customer profiling (insofar as it relates solely to direct marketing). With regard to marketing messages, you can ask us to stop sending them at any time – just follow the instructions in the marketing message or send a request to support@1win.social.
Make a complaint to your local data protection authority.
Please note that not all of the above rights are absolute.
You can exercise your rights at any time by changing your account settings or sending an email to support@1win.social.
You will need to confirm your identity to perform the actions you have requested.
If you are unhappy with the way we process your personal data, please let us know at support@1win.social. We will consider your complaint and endeavour to respond to you within a reasonable time.
10. Using Google Analytics
We use Google Analytics to collect information about how you use this website. Google Analytics collects the following information: your visit to the website, which pages you view, and which other websites you visit before coming to our website. Google Analytics only collects the IP address assigned to you on the day you visit the website, not your name or other identifying information. We do not combine information collected through Google Analytics with your personal information. Although Google Analytics stores a persistent cookie on your web browser to identify you as a unique user the next time you visit this website, this cookie cannot be used by anyone other than Google. Google’s ability to use and share information about your visits to the website collected through the Google Analytics tool is restricted by the Google Analytics Terms of Use and Google’s Privacy Policy. You can prevent Google Analytics from recognising you when you revisit the website by disabling cookies on your browser.
If you wish, you can disable cookies in your browser settings. For more information about Google Analytics, please visit http://www.google.com/analytics/ . To learn more about how Google uses cookies, please visit https://policies.google.com/technologies/cookies
11. SSL encryption
All important correspondence between the user and the site is encrypted with Secure Socket Layer (SSL) using a 256-bit key.