INTERWETTEN GAMING LIMITED PRIVACY NOTICE

INTERWETTEN GAMING LIMITED PRIVACY POLICY


Last updated 20/03/2023

Welcome at https://www.interwetten.de (the “website”)

1. About us

1.1. The controller of your personal data is Interwetten Gaming Ltd, a Maltese company with registration number C-35736 and registered address 2nd Floor, Lifestar Building, Testaferrata Street, Ta' Xbiex, XBX 1403, Malta. (“company” “we” “us” “our”).

1.2. By visiting Our website and using Our services, you acknowledge that you have read and fully considered this Privacy Policy.

1.3. The Company confirms that We are bound by Maltese laws when collecting Your Personal Data and will process Your Personal Data in accordance with the GDPR. For further inquiries or questions about how We handle Your Personal Data, you may contact Us/Our Data Protection Officer at the following email address: [email protected].

1.4. Any notices, requests, inquiries or other communications with the Company must be sent either by certified mail with requested confirmation of receipt or by email. All notices sent by e-mail shall be deemed received on the next business day after sending.

2. Definitions

Capitalized terms in this Statement shall have the meanings assigned to them under the GDPR and shall be interpreted accordingly. Furthermore, the following definitions apply:

2.1. Account – an account provided to you by the Company upon your registration and acceptance of the Terms and Conditions for the use of the Services

2.2. DSGVO – The General Data Protection Regulation (GDPR) (EU) 2016/679 of the European Parliament and Committee of 27 April 2016 on the protection of individuals with regard to the processing of personal data, on the free movement of such data and repealing Directive 95/46/EC, as amended, replaced and in force from time to time.

2.3. Services – The services offered by the Company through the Website, as defined in our General Terms and Conditions of Business.

2.4. User –  any person who creates an account or accesses and browses the Website („You“, „Yours“).

3. Subject

3.1. This Privacy Policy sets out the terms and conditions that the Company adheres to in order to protect the privacy of Our users. It describes the conditions under which We collect and process Your Personal Data and informs You about how the Company collects, processes, uses, stores and protects Your Personal Data and the rights You have in relation to the processing of Your Personal Data.

3.2. The Company reserves the right to change and update this Privacy Policy whenever it deems it appropriate, and any changes will be effective and take effect as soon as they appear online on the Website. Any material changes to this Privacy Policy will be communicated to you.

4. Principles of data processing

4.1. We respect your fundamental rights and consider the protection of your Personal Data a priority. Accordingly, We respect the following basic principles when processing Your Personal Data:

4.1.1. We process Your Personal Data lawfully and fairly and maintain full transparency regarding the manner in which We handle Your Personal Data.

4.1.2. We collect and process your Personal Data only for specified, explicit and legitimate purposes as described in this Privacy Policy and do not process it in any way incompatible with those purposes.

4.1.3. We process your Personal Data only to the extent necessary and appropriate for the purposes for which it is collected.

4.1.4. We will use reasonable efforts to ensure that your Personal Information is accurate and up to date and will take all reasonable steps to promptly delete or correct any inaccuracies.

4.1.5. We process your Personal Data in a secure manner by using appropriate technical and organizational measures.

4.2. In general, We, as data controller, comply with all applicable laws and legal obligations.

5. Personal data that we process

The company collects and processes the following personal data:

5.1. During your access and use of the Website - "Technical Data" is automatically collected by our system and temporarily stored in log files, including the following:

  • IP address
  • Date and time
  • Operating system and
  • Browser.

5.2. During your registration - "Registration Data", including the following:

  • First name and last name
  • Gender
  • Full address
  • Date and place of birth
  • E-mail address
  • Cell phone number
  • Username and password
  • personal security question and answer and
  • Identity card or social security number (in certain countries)O
  • Player ID

5.3. During Our Business Relationship - "Know Your Customer (KYC) Data" including the following:

  • valid identity cards issued by the competent authority
  • Consumption bills and similar documents and information
  • Information from third party databases including credit rating data

Depending on the circumstances of the relationship, We may collect additional KYC Data.

5.4. During the use of payment services - "payment data", including the following:

  • Credit card information (e.g., cardholder name, credit card number, credit card expiration date, CVC code); and
  • Bank account information (e.g. name of account holder, IBAN and SWIFT code).

5.5. During communication with Our customer service representatives - " Communication Data", including the following:

  • Chat content
  • Email content and
  • Records of telephone conversations.

5.6. During our business relationship - "game-related data" including the following:

  • Limits including provider-related and cross-provider limits (LUGAS)
  • Player locks (OASIS)
  • User data
  • Account balances
  • Game scores
  • Transactions with payment service providers
  • Game progress including wins and losses
  • Gaming behaviour (Monitoring)
  • Login and logout histories

5.7 Any Personal Data that you provide directly to Us during Our interaction.

6. Purposes and legal bases of data processing

6.1. In order to fulfill its obligations under the General Terms and Conditions, the Company may process your Personal Data for the following purposes:

  • To enable you to use the website
  • Process your account registration and management (including age verification and fraud protection controls)
  • Identify malfunctions and misuse of Our services
  • Perform payment services
  • Improve the user experience, including the provision of personalized services and the Website and Services.
  • manage the website and
  • To answer your inquiries.

6.2. In order to fulfill its legal obligations, the Company may process your Personal Data for the following purposes:

  • Identity and age verification
  • Evaluation and verification of creditworthiness
  • Detection, investigation and prevention of money laundering and terrorist financing
  • Protection of minors and
  • Implementation of Responsible Gaming measures including monitoring
  • Compliance with tax requirements
  • Compliance with any other applicable legal, regulatory or governmental requirements.

6.3. In order to promote Our Services and develop Our business, the Company may process your Personal Data on the basis of Our legitimate interest for the following purposes:

  • Commercial communication, marketing and advertising for our services
  • Review and enforcement of contractual claims

6.4. The Company may process your Personal Data only with your consent for the following purposes:

  • Commercial communication, promotional campaigns and advertising.

6.5. You have the right to withdraw your consent in writing at any time to our contact details mentioned in this statement. The revocation of your consent does not affect the lawfulness of the treatment of your data before the revocation.

7. Data recipient

7.1. In order to carry out the purposes set out in this Privacy Policy, We may disclose or transfer Your Personal Data to the following third party recipients:

  • Processors such as technical service providers
  • Group companies for operational purposes
  • Gaming provider for gaming purposes
  • Payment provider to facilitate payment purposes
  • Information technology provider for the operation of the website
  • Statistical and reporting providers for data analysis and regulatory purposes
  • Credit bureaus and operators of identity and age verification companies
  • Customer Support Provider
  • Sales and marketing partners for marketing-related purposes
  • Regulators
  • Courts, authorities in particular in connection with the enforcement of contract performance claims
  • Legal and tax advisors

The recipients include the following companies:

  • Schufa Holding AG, Kormoranweg 5, 65201 Wiesbaden
  • IDNow GmbH, Auenstraße 100, 80469 München
  • Insic GmbH, Brookweg 6a, 22941 Jersbek
  • AUTHADA GmbH, Julius-Reiber-Straße 15a, 64293 Darmstadt
  • Sofort GmbH, Theresienhöhe 12, 80339 München
  • Card Complete Service Bank AG, Lassallestraße 3, 1020 Wien
  • Unzer Austria GmbH, Kolumbusplatz 7 - 8, 1100 Wien
  • Paysafe Prepaid Services Ltd., 4 Grand Canal Street, Upper, Dublin, Irland

7.2 We transmit your personal data to operators of official databases (OASIS and LUGAS) for supervisory purposes. The operator of the OASIS transnational blocking system is the Darmstadt Regional Council, Wilhelminenstraße 1-3, 64283 Darmstadt. Further information on the OASIS blocking system can be found at https://rp-darmstadt.hessen.de/sicherheit-und-kommunales/gluecksspiel/spielersperrsystem-oasis. The cross-state gambling evaluation system LUGAS is managed by the Joint Gambling Authority of the Federal States and operated by Dataport, as a service provider for the public administration of the state of Saxony-Anhalt. Further information on LUGAS can be found at https://www.gluecksspiel-behoerde.de/de/aufsichtssysteme/verpflichtende-it-systeme-fuer-veranstalter-und-vermittler-von-gluecksspielen.

 

7.3. We transfer your personal data to third parties outside the European Union only if:

  • the recipient is located in a country that is subject to an adequacy decision of the European Commission
  • the Recipient guarantees a standard of data protection comparable to that of the European Union by implementing the standard contractual clauses issued by the European Commission

7.4. If there are indications of transactions and/or activities that raise suspicion of criminal activity, We will report this to the relevant authorities, sports organizations and associations (e.g. police, sports organizations/associations, private associations for the prevention of criminal and fraudulent activities in the sports betting and/or gambling sector). In this context, your Personal Data may be disclosed.

7.5. We may disclose your Personal Data to authorities as required by law, in the event that We are required by a court or other administrative authority to do so as a result of an investigation related to unlawful activities such as money laundering, and any other case in which We are required to do so by law.

7.6. In certain cases, we may transfer your Personal Data to credit rating agencies and credit reporting agencies that perform credit checks and identity verification.

8. Data security and confidentiality

8.1. In order to ensure the proper use and integrity of your Personal Data and to prevent unauthorized or accidental access, processing, deletion, modification or other use, the Company applies internal policies and adopts all appropriate organizational, technical and procedural security measures and technical standards, in accordance with applicable laws and regulations.

8.2. The processing of your Personal Data by the Company will be carried out in a secure and confidential manner, taking into account the latest developments, implementation costs and the nature, scope, context and purposes of the processing, as well as the risks to your rights and freedoms, as applicable.

8.3. Payment information in particular will always be encrypted. While sensitive information online is protected by SSL encryption, We strive to ensure the protection of player information in all other areas. Only authorized employees or employees of third parties who are contractually bound to confidentiality have access to player information. Periodic training is provided to all employees on applicable security and privacy standards. All relevant servers are located in a secure environment.

8.4. In order to protect Players' Personal Data when communicating with the web browser, We use the encryption technology of Our certification partners. In addition, online transactions are shielded by the security system of a globally accredited partner. Furthermore, all player data is protected from unauthorized access by firewall and attack defense systems.

9. Storage of personal data

9.1. We will retain your Personal Data for as long as is necessary to fulfill the processing purposes explained in this Statement in accordance with the principles of data minimization and retention limitation.

9.2. In addition, the Company may retain your Personal Data after the expiration of the respective processing purposes for the following reasons:

  • If We are legally required to retain Your Personal Data due to a relevant legal provision
  • Due to Our legitimate interest in defending the Company against possible legal claims before any competent courts or authorities.

9.3. After the retention period has expired, your personal data will be deleted from our databases and systems.

9.4. For more information about the terms of data retention with respect to certain Personal Data, please contact Us at [email protected].

10. Your rights

10.1. You have the right:

  • Request access to and obtain a copy of your Personal Data and information regarding its processing.
  • To request the correction of inaccuracies or missing personal data
  • To request the deletion of Personal Data.
  • To request the restriction of the processing of your Personal Data in cases expressly provided for by law.
  • Request the portability of your personal data to another data controller in a structured, commonly used and machine-readable format
  • Object to the processing of your Personal Data in cases expressly provided for by law
  • To object to a decision taken solely on the basis of automated processing, including profiling, which produces an effect concerning you or significantly affects you

10.2. All inquiries regarding the foregoing Section 10.1 shall be made in writing to [email protected].

10.3. If you believe that your rights have been violated, you have the right to lodge a complaint with the Maltese Information and Data Protection Commissioner at the following website https://idpc.org.mt/en/Pages/contact/complaints.aspx.

11. Your duties

11.1 By using Our website and submitting Your Personal Data, You acknowledge that You are required to provide Your true, accurate and complete data as requested by the Company. In addition, You must notify Us of any changes to the data to ensure that it is current and accurate.

12. Cookies

12.1.Our website uses cookies. For more information, please visit our Cookie Notice.