Last Updated 11th January 2022
the “Website” applies to any and all Websites operated by Prozone Limited
OUR COMMITMENT TO PRIVACY PLEASE READ THIS PRIVACY STATEMENT CAREFULLY BEFORE SUBMITTING ANY PERSONAL INFORMATION.
The Website is owned and operated by Prozone Limited, regulated under license number MGA/B2C/908/2021, with its registered address at Floor 2, Block 6, Paceville Road, St. Julians, Malta (“we” or “us” or “our”). We are committed to protecting and respecting your privacy. Your privacy is important and to better protect your privacy we provide this statement to explain how we collect, use and share any personal data belonging to you and the choices you can make about the way your Personal Information is collected and used.
To make this policy easy to find, we make it available from every page on our Website. It is intended to help you understand:
• What information we collect from you
• How we use the information we collect
• How we share the information we collect
• How we store and safeguard the information we collect
• How to access and control the information we hold
APPLICATION OF THIS NOTICE
- THE INFORMATION WE COLLECT
When you use our Services, we collect the following type of information:
Information you provide us with:
• Personal information provided when you register for an Account on our Website such as your name, date of birth, postal address, email address, phone number and any other details as may be requested from you either at the time of registration of thereafter as necessary for the continued use of our services.
• Information that you provide if you enter a competition or promotion on the Website or when you report a problem with the Website.
• Correspondence passing between you and us, including, but not limited to, any interactions with us on our customer service or social media channels.
• Responses to any surveys that we use for research purposes, although you do not have to participate in such surveys.
Additional Information Collected
• Details of transactions you carry out through the Website and of the processing of your Account including details of your payment history, and amounts that you have staked on games and the amounts that you have won or lost.
• Details of your visits to the Website including, but not limited to, traffic data, location data, device data, weblogs and other communication data (including IP address and browser type).
• Your social media profile details (name, profile photo and other information you make available to us) when you connect with or contact us through a social media account.
• Information gathered based on profiling activity (as further described below).
• Information from our partners and service providers, third party databases and other publicly available sources (such as social media) to comply with our legal and regulatory obligations in relation to confirming the age and identity of our users.
- HOW WE USE YOUR INFORMATION
We will use the information we collect about you as described above for specific purposes, which shall include the following:
• Account Creation, Verification and Administration: We use personal information to create and verify your account with us. This is because we need to know that you are who you say you are and that you are at least 18 years of age. We also require this information to ensure the continued safe and secure administration of your account, to notify you of important changes to our service, provide customer or technical assistance, facilitate deposits and withdrawals and to ensure the continued compliance by you of our General Terms and Conditions.
• Customisation and Personalisation: We want to ensure that content from the Website is presented in the most effective manner for you and for your computer and we use information we collect to deliver you with information, products, offers or promotions that you request from us or which we feel may be relevant or of interest you.
• Legal and Regulatory Obligations: We are required to use and retain personal information to comply with our legal and regulatory obligations, such as the verification of your identity, the prevention , detection of investigation of a crime, the promotion of responsible gaming, sport integrity investigations, etc. We may also be required to use or disclose your personal information to respond or comply with any requests from any competent court of jurisdiction, regulatory agency or such other enforcement or governmental authority or otherwise to protect our legitimate business interests.
• Statistical analysis and research: We are always looking for ways to make our Services smarter, faster, secure and more personalised to you and we use collected learnings, analytics and data from the information you provide us with to help us troubleshoot system problems, to improve and test the features and products on our Website, to measure the performance of our Services and marketing, and to identify trends, usage, activity patterns and behaviour so as to provide a more personalised and relevant experience. If you choose to participate in a survey, any personal information you provide us with may be used for such research purposes.
• Profiling: We use information collected from you to carry out profiling of our customers based on a number of factors including your age, address, gaming activity, transactional data, interests and other similar such information in order to (i) personalise the Services, notifications and promotions we offer you; (ii) evaluate and mitigate risks to our business; (iii) to comply with our legal and regulatory obligations; and (iv) to show you and like-minded individuals relevant, targeted and personalised advertisements across the internet and on social media.
• Consent: We may use information collected by us where you have given us consent to use it for a particular purpose not specified above.
Third party content may from time to time appear on the Website or be accessible from the Website via links to other websites. If you follow a link to any of these websites, you leave the Website and enter sites that may or may not have their own privacy statements. We have not reviewed, do not monitor and are not responsible for the content on such websites or for the terms of their privacy statements. Please check these statements before you access or submit any personal data to these websites.
- HOW WE SHARE THE INFORMATION WE COLLECT
We may disclose or transfer the information we collect from you to any of our associated companies or partners necessary for the provision of the Services to you. But note, we are not in the business of selling information about you to advertisers or other third parties.
We may disclose your personal information:
• if required to do so by law; • if we believe in good faith that such action is necessary to: • comply with any legal process served on us; • protect and defend our rights of property; or • protect the personal safety of Users of this Website, the Company or the public; • to any regulatory body, licensing body or authority; • to any platform or games supplier used in the operation of the Website or to otherwise provide the Services; • to any other trusted and vetted third parties who provide services to or on our behalf through the course of the operation of the Website or the provision of the Services, including, but not limited to services such as information technology, payment processing, marketing, customer support, data analysis, identity and source of wealth verification and risk management; and • to any third party that purchases our company or our business.
Any third parties, agents or sub-contractors who are given access to your personal information will be required to keep the information confidential and not use it for any other purpose than to carry out the services they are performing for us.
The Operator is obliged to comply with applicable Anti-Money Laundering (“AML”) and Countering the Financing of Terrorism (“CFT”) legislation for the time being in force. We reserve the right to use third party verification services, including credit reference agencies to authenticate your Account information and identity, and to conduct any necessary checks relating to potential fraud, responsible gaming and affordability or to ensure compliance with our anti-money laundering protocols and obligations, and you expressly acknowledge and agree that we may share any Account information with such third parties.
- HOW WE STORE AND SAFEGUARD THE INFORMATION WE COLLECT
Your personal data will be stored and processed on servers located in Malta. From time to time your data may also be transferred to and processed on servers situated in other jurisdictions for the purposes set out above, including backup and disaster recovery. Such processing may be performed by us or on our behalf, by our staff, agents and sub-contractors who may be located anywhere in the world. Some third party processors we engage to process information on our behalf may be based outside the European Economic Area ("EEA"). By submitting your personal data, you agree to the storing, transfer and processing of your information in this way, both within and outside the EEA. Countries outside the EEA do
not always have strong data protection laws. However, where any storing, transfer or processing of your information is required outside of the EEA, we will always take all steps reasonably necessary to ensure that your information is used securely and in accordance with this Policy.
We will retain and store your personal information for as long as we reasonably require it for legal or business purposes. In most circumstances, your information will not be kept longer than 7 years provided there are no legal or regulatory requirements for us to retain your information for longer.
We will take all steps reasonably necessary to ensure that your data is used and retained securely and in accordance with this privacy statement and will encrypt certain portions of your personal data where appropriate, including payment transactions if applicable. If we ever decommission or reallocate any computer equipment we will ensure that all sensitive information contained on such equipment will be permanently erased either using specialist software or by physically damaging the equipment.
Where you have chosen a password which enables you to access certain parts of the Website, you are responsible for keeping this password confidential and for preventing any unauthorised use of your Account. We do not permit you to share your user name and password with any other person.
We maintain appropriate technical and physical safeguards to protect your personal information against accidental or unlawful destruction or loss, alteration, unauthorised disclosure or access, use and all other unlawful forms of processing of the data in our possession. Unfortunately however, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data you provide us with, which takes place at your own risk and we shall accept no liability for any direct, consequential, incidental, indirect, or punitive losses or damages arising out of any such data breach.
- HOW TO ACCESS AND CONTROL THE INFORMATION WE HOLD
You have certain choices available to you when it comes to the information we hold about you as detailed below. Some of these only apply in certain situations and may be subject to exemptions under data protection legislation. We will advise you in response to any request by you if any such limitations or exemptions apply.
• Access to Information: You can request a copy of the personal information that we have collected about you free of charge via the Website by contacting our Customer Services team at firstname.lastname@example.org. For the added security of your personal information, when you request a copy of the personally-identifiable information that we hold, you will be asked to provide us with proof of identification. Any such request will be dealt with within a reasonable time-frame and in most cases within 30 days from the date we have verified the identity of the person making the request, provided that we reserve the right to extend this time frame by a further 60 days if necessary. • Correction of Information: You can also request that factual inaccuracies in the personal information that we hold about you be corrected by contacting our Customer Services team, who may require you to send in supporting documentation.
• Right to Withdraw or Suspend Consent: Where we have relied upon your consent to process your personal data in accordance with this policy, you have the right to withdraw or suspend that consent. Any such withdrawal or suspension shall not affect any processing of your information that has taken place prior to your withdrawal. You can opt out of receiving marketing communications directly from any message received or by updating your preferences via your Account or by sending us an email to email@example.com. • Right of Deletion: You may request us to delete the information we hold about you. Please note, this right only applies in certain circumstances and we may need to retain information to continue to comply with our legal and/or regulatory obligations. • Right to Transfer Data: This right allows you to obtain some of your personal information in a format that enables you to transfer it across to another organisation where technically feasible. • Right to Object to the Processing of Information: You have the right to object to our use of your personal information which we use for our legitimate business interests. However, we may continue to process your personal data, despite your objection, where there are compelling legitimate grounds to do so or we need to process your personal data in connection with any legal claims. • Rights related to Automated Profiling: You have the right not to be subject to a decision which is based solely on automated processing (i.e without human involvement) where that decision produces a legal effect or otherwise significantly affects you. This right means you can request that we involve one of our employees or representatives in the decision-making process. • Right to Complain: If you are not satisfied with how we manage your personal information, you have the right to make a complaint to your local Data Protection Authority. You may find a list with your local Data Protection Authority at: http://ec.europa.eu/justice/data-protection/article-29/structure/data- protection-authorities/index_en.htm.
- ACCOUNT SECURITY
The security of your account relies on your protection of your password and computer/mobile device. You are responsible for maintaining the security of your password and computer/mobile device. You are solely responsible for any and all activities that occur under your account. You should not share your password with anyone. If you do share your password with a third party for any reason, you will be responsible for actions taken using your password. If you believe someone else has obtained access to your password, please change it immediately.
We will never ask you to send your password or other sensitive information to us in an email, though we may ask you to enter this type of information on the Website. Any email or other communication requesting your password or asking you to provide sensitive account information via email should be treated as unauthorized and suspicious and should be reported to us immediately at firstname.lastname@example.org.
We may amend or vary this statement at any time and with immediate effect by updating this web page and, whilst we will seek to notify you of such changes beforehand, we may not always be able to do so, so you should check this web page every time you visit the Website to review the then current privacy statement in force. Continued use of the Website following any such posting shall constitute acceptance of the revisions or changes.
THESE TERMS ARE GOVERNED BY THE LAWS OF MALTA AND SUBJECT TO THE EXCLUSIVE JURISDICTION OF THE COURTS OF MALTA. ANY DISPUTE ARISING OUT OF OR RELATING TO THIS POLICY WILL BE GOVERNED BY THE LAWS AND THE COURTS OF MALTA.
HOW TO CONTACT US
If you would like to contact us for any reason regarding our privacy practices or to request a copy of the personally-identifiable information that we have collected about you via the Website please write to our Customer Services team at email@example.com or in writing to the following address:
Data Protection Officer Prozone Limited Floor 2, Block 6, Paceville Road, St. Julians Malta Last Updated 8th November 2021
- WHAT IS A COOKIE?
Cookies are small text files that contain information that are downloaded to your computer, tablet, smartphone or any other such device that you use to access our Website. Each time you return to our Website, the cookies are sent back to us so we can recognise who you are and what device you are using. You can find more information about cookies at http://allaboutcookies.org.
The Cookies we use generally fall into four main categories as follows:
• Essential Cookies: These cookies are essential to enable you to navigate our Website, use our Services and to allow you to return to pages previously visited. • Functionality Cookies: These cookies allow us to recognise you when you return to our Website and remember any of your user preferences (e.g. preferred language). Our ability to recognise you helps us improve your user experience. • Fraud Prevention Cookies: These cookies store information that helps us prevent any fraudulent or unlawful use of our Website. • Tracking Cookies: These cookies allow us to identify where a user has come from before they accessed our Website. • Performance and Analysis Cookies: These cookies are used to collect information on our Website’s usage and to enable us to deliver you relevant information and measure the effectiveness of the content you are seeing.
- HOW TO MANAGE COOKIES
For more general information on cookies and their use, please visit http://allaboutcookies.org
For more information about online behavioural advertising cookies and opt-out controls, please go to http://www.youronlinechoices.eu/".
More information regarding opting out of platform based advertising can be found at https://www.appnexus.com/cookie-policy.