Privacy Policy

Effective date May 1, 2020

This Privacy Policy describes the way in which CryptoGames collect, process and share the information and data you provide to us to enable us to manage your relationship with CryptoGames.

We will process any personal information provided to ys or otherwise held by us relating to you in the manner as set out in this Privacy Policy. Information may be provided via the CryptoGames website, email or any other means.

By accepting this Privacy Policy, you hereby agree that you understand and accept the use of your personal information as set out in this Privacy Policy. If you do not agree to any of the terms of this Privacy Policy, please do not use the website or otherwise provide us with your personal information.

1. Introduction

References in this Privacy Policy to “CryptoGames”, “we” or “our” relate to MUCHGAMING B.V., a company incorporated in Curacao, with its principal place of business at Korporaalweg 10, Willemstad, Curaçao. We control the ways your personal data is collected and the purpose for which your personal data is used by CryptoGames, acting as a “data controller” for the purposes of applicable European data protection legislation.

2. Types of information we collect

We may collect different categories of information from you, either personal or non-personal information, as defined below.

Non-personal information is information that may be made available or gathered through your use of the website and/or services and may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information such as: device brand, screen size, type of operating system, type of device, language preference, the time and date you access our website, your actions within our website (e.g., registration, pages viewed, etc.), the URLs from which you were directed to our website, etc.

Personal information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual. Personal information includes information voluntarily provided by you as well as certain identifiers, such as internet protocol (hereinafter referred to as »IP«) address.

You are not required by law to provide us with certain personal information. You can always refuse to provide certain personal information, however you acknowledge that such refusal may prevent you from engaging in certain activities within our website and/or services.

3. How we collect information

We may collect, use and process information about you as follows:

• provided by you voluntarily: you may provide us personal data voluntarily, such as when you register for a player account on our website (and provide us with your identity and contact details, scanned documents, financial statements and additional information as necessary to set up your account and verify your identity and eligibility to play at our website), when you contact us (through email or any other channel), or when you provide us your email address (such as when you sign-up to receive email updates), when you make any deposits or withdrawals, and when you play at our website.
• automatically: when someone visits or uses our website, we may collect or generate technical data about them. Such data consists of technical or usage data, such as IP address, non-identifying data regarding a device, operating system, browser, and user activity on our website.

Where it is reasonable for us to do so and not detrimental to your rights and freedoms, we also collect personal data from publicly available sources such as internet searches, companies house, and broadcast media.

4. Why we process your personal data

What we do?	How we use it?	How it is justified?
manage customer relationships develop new products and services grow our business learn from how our players use our services and website provide support for our services and website	maintain our records letting you know about relevant products and services developing or improving products or services	your consent fulfilling contracts our legitimate interest legal obligations
develop and manage our brand develop and manage our services and products test new services, products, systems manage our relationship with other companies that provide services to us and our customers	developing or improving products or services conducting brand image and reputation protection activities to support and grow the business being efficient how we fulfill our legal and contractual duties	fulfilling contracts our legitimate interest legal obligations
deliver quality services to you create and manage customer accounts, withdrawals responding to customer complaints complying with any applicable laws and regulations	being efficient how we fulfill our legal and contractual duties complying with applicable laws and regulations	fulfilling contracts our legitimate interest legal obligations
prevention of crime detect, investigate and report crime managing risk for us and our customers complying with any applicable laws and regulations	developing and improving how we deal with crime and attempted crime protecting our customers and ourselves from the impacts of crime complying with applicable laws and regulations being efficient how we fulfill our legal and contractual duties	fulfilling contracts our legitimate interest legal obligations
manage and run our business to efficiently and effectively provide quality services to exercise our rights as set out in agreements or contracts ensure corporate governance and compliance to all legal and regulatory obligations fulfill our obligations as an accountable and responsible company	complying with applicable laws and regulations being efficient how we fulfill our legal and contractual duties	fulfilling contracts our legitimate interest legal obligations

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 with our services.

5. Data retention

We retain personal data as long as it remains necessary for the purposes set forth above, all in accordance with applicable laws, or until individuals express a preference to delete their personal information. We may, at our sole discretion, delete or amend information from our systems, without notice, once we deem it is no longer needed for such purposes.

6. Protection of personal data

We have implemented reasonable security measures to protect the confidentiality, security and integrity of the collected information, and to prevent unauthorized access and the use of information contrary to this Privacy Policy. Although we use commercially reasonable efforts to assure that your information remains secure when maintained by us, please be aware that no security measures are perfect or impenetrable.

7. Disclosure of information

We do not disclose, share, sell, rent or otherwise distribute any of your personal information with or to any independent third parties, unless as specified herein:

• we may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.
• we may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes.
• in addition to the specific disclosures of personal data set forth herein, we may also disclose your personal data where such disclosure 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.

8. Third Party Sites and Services

This Privacy Policy applies solely to the information collected by CryptoGames through the website and does not apply to any other websites, applications or services. Portions of the website may involve linking to or using third-party services such as various icons, shortcuts, applications or other means of access. Though we make best efforts to review such services, we have no control over Third-Party Services and all use of such services is at your own risk. We cannot accept responsibility for the privacy practices of any such third-party services and we are not responsible for content made available by them. CryptoGames does not endorse any third-party services and we urge you to exercise caution in using them and to review their privacy practices.

9. The EU General Data Protection Regulation (EEA Residents)

As of May 25, 2018, a new data privacy law known as the EU General Data Protection Regulation (the “GDPR”) will be in effect through the EEA, Switzerland, and the UK. The GDPR requires CryptoGames and those using our Website to provide users with certain information about the processing of their “Personal Data.” “Personal Data” is a term used under the GDPR that means, generally, data that identifies or can identify a particular unique user or device – for instance, names, addresses, cookie identifiers, precise location data, and biometric data.

To comply with the GDPR, we provide the below representations and information, which are specific to persons located in the EEA, Switzerland, or the UK and to the processing of personal data in the context of the activities of CryptoGames.

1. Legal Grounds for Processing Personal Data

The GDPR requires us to tell you about the legal ground we are relying on to process any Personal Data about you. The legal grounds for us processing your Personal Data for the purposes set out herein will typically be because:


• You provided your consent. In order to store and gain access to information about you, we rely on your consent. We may choose to obtain consent in other cases as well, in which case we will adhere to applicable laws relating to such consent and its withdrawal;
• The processing is in our legitimate interest. In some cases, we rely on legitimate interest as a legal basis for processing Personal Data, in order to provide our and/or other data controllers’ services. A legitimate interest we rely on, for instance, is maintaining the security of our services, such as to detect fraud or to ensure that bugs are detected and fixed;
• Contractual relationships. Sometimes, we process certain data as necessary under a contractual relationship we have (such as our customer records and contact information);
• Legal obligations. Finally, some processing of data may be necessary for us to comply with our legal or regulatory obligations.


2. Transfers of Personal Data

As CryptoGames works with global companies and technologies, we may need to transfer your Personal Data outside of the country from which it was originally provided. For instance, we may transfer your data to third parties that we work with who may be located in jurisdictions outside of the EEA, Switzerland, or the UK, and which have no data protection laws or laws that are less strict in comparison to those in Europe.

When we transfer Personal Data outside of the EEA, Switzerland, or the UK, we take steps to ensure appropriate safeguards are in place to protect your Personal Data. Please contact us at the contact information below for more information about the safeguards we have put in place to protect your Personal Data and privacy rights in these circumstances.

3. Personal Data Retention

As a general matter, we retain your Personal Data for as long as necessary to provide our services, or for other important purposes such as complying with legal obligations, resolving disputes, and enforcing our agreements.

4. Your Rights as a Data Subject

The GDPR provides you with certain rights in respect to Personal Data that data controllers hold about you, including certain rights to access Personal Data, to request correction of the Personal Data, to request to restrict or delete Personal Data, and to object to our processing of your Personal Data.

• Right to object. You have the right to object to the processing of your personal information that is processed on the grounds of legitimate interests. You are always free to opt out from the future collection of your personal information by us and our partners by uninstalling all the Applications from each of your devices.
• Right of access. You have a right to know what information we hold about you and in some cases to have the information communicated to you. If you wish to exercise this right please contact us by letting us know that you wish to exercise your right of access and what information in particular you would like to receive. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information. Please note that we may not be able to provide all the information you ask for, for instance if the information includes personal information about another person. Where we are not able to provide you with information that you have asked for, we will explain to you why. We will try to respond to any request for a right of access as soon as possible, but we will always do so within 1 month of receipt of your request and verification of your identity.
• Right to correct personal information. We try to keep the information that we hold about you accurate and up to date. Should you realize that any of the information that we hold about you is incorrect, please contact us via [email protected] and we will correct it as soon as we can.
• Data deletion. You have a right to request deletion of the personal information that we hold about you. Should you wish to do that, please contact us [email protected]. We reserve the right to ask to provide us additional information to verify your identity before we can start processing your request. Once we receive all information we need in order to be able to identify you, we will delete your personal information you requested us to delete as soon as possible, but we will always do so within 1 month of receipt of your request and verification of your identity. Please note that we may still retain some or all of that information, for example for complying with our legal obligations and protecting or enforcing legal rights. We may also retain your information in an anonymised form.
• Data portability. In some circumstances, you have the right to request that we provide you with the personal information which you have provided to us, so you can transfer this information to another data controller. Should you wish to do that, please contact us via [email protected].
• Restriction of processing. In some cases, you may have the right to request a restriction of the processing of your personal information.
• Right to file a complaint. You have the right to file a complaint against us. To do so, contact the supervisory authority in your country of residence.

10. About Cookies

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.

Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

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.

10.1 We use cookies for the following purposes:

1. authentication - we use cookies to identify you when you visit our website and as you navigate our website;
2. status - we use cookies to help us to determine if you are logged into our website;
3. personalization - we use cookies to store information about your preferences and to personalize the website for you;
4. security - we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;
5. analysis - we use cookies to help us to analyze the use and performance of our website and services; and
6. cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally.

10.2 Cookies used by our service providers:

Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

We use Google Analytics to analyze the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy/.

The relevant cookies are:

• LongId is unique user identifier
• LongId2 is user session identifier
• __AntiXsrfToken is anti-CSRF cookie
• _ga is Google Analytics cookie
• _gid is Google Analytics cookie
• _gat is Google Analytics cookie

10.3 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). If you would like more information on how to disable cookies or change your privacy settings, please visit www.allaboutcookies.org. Your browser's 'help' function should also tell you how to do this.

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.

11. Changes to this Privacy Policy

This Privacy Policy may change from time to time and we will post the amended terms and in the event of substantial changes we will use reasonable endeavors to inform you in advance by email, notice on the website or other agreed communication channels. We will communicate the changes to you in advance, giving an appropriate amount of time for you to consider and understand the changes before they become effective. You should review the Privacy Policy periodically to remain informed of any changes. You agree to accept posting of a revised Privacy Policy as actual notice to you. Your continued use of the website following any changes to this Privacy Policy have been posted as of the “Last Updated” date below (or, if applicable, notified) signifies your acceptance of those changes. If you do not agree to the revised Privacy Policy, please refrain from using our website and contact us by sending an email to [email protected].

12. Contact us

If you have any comments or questions about our Privacy Policy, please contact us at [email protected]

Our data protection officer's contact details are [email protected].