INTERWETTEN GAMING LIMITED PRIVACY NOTICE



Last updated on 17/11/2022

Welcome to: http://www.interwetten.de (the “Website”)

1. Who We Are

1.1. The Data Controller of Your Personal Data is Interwetten Gaming Ltd, a Maltese Company with registration number C-35736 having its registered address at 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 reading and fully considering this Privacy Notice.

1.3. The Company acknowledges that in collecting Your Personal Data We are bound by the laws of Malta and will process Your Personal Data in accordance with the GDPR. For any further request or query about how We use Your Personal Data, You may address Us/Our Data Protection Officer through the following email address: dataprotection@interwetten.com.

1.4. Any notice, demand, request or other communication which You address to the Company shall either be sent by certified mail, return receipt requested, or by e-mail. All communication done by e-mail shall be deemed received on the business day following the day of transmission.

2. Definitions

Capitalised terms in this Notice shall have the meaning assigned to them under the GDPR and shall be construed accordingly. Furthermore, the following definitions shall apply:

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

2.2. GDPR – the General Data Protection 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of Personal Data and on the free movement of such data, and repealing Directive 95/46/EC, as amended, replaced or superseded and in force from time to time.

2.3. Services – the Services provided by the Company through the Website, as defined in our Terms and Conditions.

2.4. User – any person who registers an Account or accesses and browses the Website (“You”, “Your”).

3. Subject Matter

3.1. This Privacy Notice sets out the terms and conditions which the Company follows 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 how the Company collects, processes, uses, stores and protects Your Personal Data as well as the rights You have with respect to the processing of Your Personal Data.

3.2. The Company reserves the right to amend and update this Privacy Notice, whenever it deems appropriate, and any changes thereof shall come in force and effect from the instance they appear online on the Website. Any substantial modifications to this Privacy Notice will communicated to You.

4. Principles of Data Processing

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

4.1.1. We submit Your Personal Data only to lawful and fair processing, and We maintain full transparency vis-à-vis the way We handle Your Personal Data.

4.1.2. We collect and process Your Personal Data only for specified, explicit, and legitimate purposes as outlined in this Privacy Notice, and We do not process it further in any manner incompatible with these purposes.

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

4.1.4. We make reasonable efforts to ensure that Your Personal Data is accurate and updated, taking all reasonable steps to immediately delete or correct it in case of inaccuracy.

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

4.2. In general, We comply with all applicable laws and statutory obligations as Data Controller of Your Personal Data.

5. Types of Personal Data We Process

The Company collects and processes the following types of Personal Data:

5.1. At the point of Your access and use of the Website – “Technical Data”, automatically collected by our system and stored in logfiles on a temporary basis, including the following:

  • IP address;
  • Date and the time;
  • Operating system; and
  • Browser type.

5.2. At the point of Your Account registration– “Registration Data”, including the following:

  • First name and last name;
  • Gender;
  • Complete address;
  • Date and place of birth;
  • Email address;
  • Mobile phone number;
  • Username and password;
  • Personal security question and answer; and
  • ID-card or social security number (in certain countries).

5.3. During Your business relationship with Us – “Know Your Customer (KYC) Data” including the following:

  • Valid ID issued by the competent authority
  • Utility bill; and
  • Information from third party databases.

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

5.4. At the point of using payment services – “Payment Data”, including the following:

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

5.5. When communicating with Our customer support agents – “Communication Data”, including the following:

  • Chat content;
  • Email content; and
  • Telephone call recordings.

5.6. Any other Personal Data directly provided by You during Your interaction with Us.

6. Purposes and Legal Basis for Data Processing

6.1. The Company may process Your Personal Data to fulfill its obligations under the Terms and Conditions, for the following purposes:

  • Enabling Your use of the Website;
  • Processing Your Account registration and maintenance (including checks made to age verify You and to guard against fraud);
  • Identification of dysfunctions and abuse of Our Services;
  • Performing payment services;
  • Enhancement of User experience, including the provision of personalized Services and improvement of the Website and the Services;
  • Administering the Website; and
  • Responding to Your requests. 

6.2. The Company may process Your Personal Data to comply with its legal obligations, for the following purposes:

  • Detection, investigation and prevention of money laundering and the financing of terrorism;
  • Protection of minors; and
  • Implementation of responsible gaming measures.

6.3. The Company may process Your Personal Data based on Our legitimate interest to promote Οur Services and develop Our business, for the following purposes:

  • Commercial communication, marketing and advertising of Our Services;

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

  • Commercial communication, promotional campaigns, and advertising.

6.5. You have the right to withdraw Your consent at any time in writing to Our contact details mentioned in this Notice. Withdrawal of Your consent does not affect the lawfulness of the treatment of Your Data prior to its revocation.

7. Data Recipients

7.1. For the execution of the purposes mentioned in this Privacy Notice, We may disclose or transmit Your Personal Data to the following third party recipients (“Data Processors”):

  • Group companies for operational purposes;
  • Game providers for gameplay purposes;
  • Payment providers for payment facilitation purposes;
  • Information technology provider for Website operational purposes;
  • Statistics and reporting providers for data analysis and regulatory monitoring purposes;
  • Customer support providers; and
  • Sales and marketing partners for marketing related purposes;

7.2. The processing of Your Personal Data by Our Data Processors is done under a contract compelling Data Processors to the same level of data protection provided under this Privacy Notice.

7.3. We shall only disclose Your Personal Data to third parties located outside of the European Union in cases where:

  • The recipient is located in a jurisdiction which is subject to an Adequacy Decision issued by the European Commission.
  • The recipient guarantees a standard of data protection comparable to that in place in the European Union, through the implementation of the Standard Contractual Clauses issued by the European Commission.

7.4. Upon indication of transactions and/or activities that may raise suspicions of criminal activities, We will report to the relevant authorities, sporting bodies and associations (e.g. police, sporting bodies/associations, private associations aiming at the prevention of criminal and fraudulent activities in sports betting and/or games of chance). In this context, Your Personal Data may be disclosed.

7.5. In the event that We are required by a court or other administrative authority, pursuant to an investigation relating to unlawful activities such as money laundering and in any other case that We are legally bound to do so, We may transfer Your Personal Data to public authorities to the extent required by law.

7.6. In certain instances, We may transmit Your Personal Data to credit rating agencies that conduct creditworthiness assessments and identity verification checks.

8. Data Security and Confidentiality

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

8.2. The processing of Your Personal Data by the Company is conducted 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 for Your rights and freedoms, which are applicable in each circumstance.

8.3. In particular, payment information will always be encrypted. Whereas sensitive information is protected online by SSL encryption, We strive to ensure the protection of players' Data in all other areas. Only authorised employees, or employees of third parties contractually bound to confidentiality, have access to players' information. At regular intervals, all employees are given training on the applicable security and data protection standards. All relevant servers are located in a secure environment.

8.4. In order to protect players' Personal Data during communication with the web browser, We use encryption technology of Our certification partners. In addition, online transactions are shielded by the security system of a worldwide-accredited partner. In addition, all player Data is protected from unathorised access by firewall and intrusion prevention systems.

9. Retention of Personal Data

9.1. We retain Your Personal Data for as long as is necessary to fulfill the relevant purposes of processing explained in this Notice, in accordance with the Data Minimisation and Storage Limitation principles.

9.2. Furthermore, the Company may retain Your Personal Data after the expiration of the relevant processing purposes for the following reasons:

  • In case We have a legal obligation to retain Your Personal Data under a relevant statutory provision.
  • Based on Our legitimate interest to defend the Company against any potential legal claims, before any competent court or public authority.

9.3. Upon expiry of the retention period, Your Personal Data is erased from Our databases and systems.

9.4. For more information about data retention terms in relation to specific Personal Data, please contact Us at dataprotection@interwetten.com.

10. Your Rights

10.1. You have the right:

  • To request access to Your Personal Data and information related to its processing and obtain a copy thereof.
  • To request for the rectification of any inaccuracies or missing Personal Data.
  • To request the erasure of Your Personal Data.
  • To request the restriction of the processing of Your Personal Data in cases explicitly provided for by law.
  • To request the portability of Your Personal Data to another Data Controller in a structured, commonly used and machine-readable format.
  • To object to the processing of Your Personal Data in cases explicitly provided for by law.
  • To object to a decision taken solely on the basis of automated processing, including profiling, which has impact on You or significantly affects You.

10.2. Any requests relevant to the above Section 10.1 must be addressed in writing to dataprotection@interwetten.com.

10.3. If You feel that Your rights are infringed, You have the right to file a complaint with the Malta Office of the Information and Data Protection Commissioner at the following website https://idpc.org.mt/en/Pages/contact/complaints.aspx.

11. Your Obligations

11.1. By using Our Website and by providing Your Personal Data, You acknowledge that You are required to provide Your actual, accurate and complete data as requested by the Company. Furthermore, You must inform Us of any changes to Your information so as to ensure it is kept up-to-date and accurate.

12. Cookies

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