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PRIVACY POLICY

V1, dd/mm/yyyy


1. WHO ARE WE?


Any references in this Privacy Policy to ''Elvel'', the ''Company'', ''We'', ''Us'' or ''Our'' refer to Elvel Limited, a company having registration number C109723 and registered at Level 3, (Suite No. 3078) Tower Business Center, Triq it-Torri, Swatar, Birkirkara, BKR 4013, Malta. Any references to ''You'', ''Your'', or ''User'' mean anyone who uses the Service provided on this Website.


For the purposes of this Privacy Policy, "Personal Data" refers to any information related to the Data Subject that can be used to directly or indirectly identify them.


In this Privacy Policy, We describe how We handle Your personal information and data. Any personal information You provide Us through Your use of this Website or the operation of Your account is kept strictly confidential by Us.


You can contact Us via Live Chat or email accessrequest@tastevegas.com.  We have appointed a Data Protection Officer, who You may contact for any queries about this Privacy Policy or how We handle Your data by sending an email to dpo@elvelltd.com.


When processing Personal Data, we follow the obligations stipulated in Regulation (EU) 2016/679 of the European Parliament and of the Council, referred to as "GDPR".


2. WHY DO WE COLLECT PERSONAL DATA?


To provide You with the Service and register an account on [brand] Casino, We need to collect Your personal data. The provision of the Service by Us includes creating, operating, and managing Your account and allowing You to play games and perform relevant activities related to games.


Processing is necessary for the purposes of the legitimate interests pursued by the Controller or by a third party, except where such interests are overridden by the interests of fundamental rights and freedoms of the data subject, which require protection of personal data, in particular where the data subject is a child.


The personal data that We collect from You when registering and operating Your account on [brand] Casino to comply with Our legal, licensing and regulatory requirements and obligations, including data protection obligations and those for the operation of Our license issued by the Malta Gaming Authority, and under its regulations and guidelines, and to meet Our obligations related to the Financial Intelligence Analysis Unit (FIAU) and other relevant competent authorities, when required to do so, to assist in any law enforcement investigation relating to fraud, money laundering, and/or terrorist financing, amongst others.

If You fail to provide Us with the necessary personal data and/or information upon Our request, We will terminate the relationship with You. The processing is necessary for compliance with a legal obligation to which the Controller is subject.


Apart from having a legal obligation to collect Your personal data and information, We also have a legitimate interest in protecting Our Casino from being misused for fraudulent and/or illegal activities.


These include but are not limited to promotional abuse, fraudulent activities, money laundering and/or terrorist financing, and online security risks. We collect personal data to carry out identification and verification checks on you. We collect personal data to create user profiles for Anti-Money Laundering Risk Assessment purposes.


To prevent illegal use of Our Website, we must profile our users and their activities using automated processes. However, any decisions made based on these profiles are made by natural persons.  Collecting Your personal data allows Us to ensure the security, accessibility and availability of Our Website's Service to You.


Sometimes, We may send You marketing communications, but only if You have consented to this, either during the registration process or by changing Your settings from Your account profile.


These marketing communications will help You to stay updated with the latest news about the new games, products, bonuses, offers and other related promotions.


You have the right to change Your marketing preferences at any time at no cost by either changing these settings from Your account profile, unsubscribing directly from the marketing communication, or contacting Our Player Support Team on Live Chat or emailing accessrequest@tastevegas.com.


The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. The legal basis for processing Personal Data is GDPR Article 6(1)(a), where the data subject has given consent to the processing of their personal data for one or more specific purposes or GDPR Article 6(1)(f), where processing is necessary for the purposes of the legitimate interest pursued by the Controller or by the third party, except, where such interests are overridden by the interests of fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.


We also collect your Personal Data regarding financial information and aspects of Your financial transactions through the use of Your account on the Website. We collect Personal Data so You can place Your bets online and so we can process online payments. The processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract.


In order to resolve issues related to the provision of goods and services by providing Player Support, We collect Personal Data such as Live Chats and email correspondence with Our Player Support Team. The processing is necessary for the purposes of the legitimate interests pursued by the Controller or by the third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.


In order to be aware of and act accordingly regarding Your ability to participate in gambling, we may process special categories of Personal Data. This would be a situation where You inform Us that You have a gambling addiction. The processing relates to personal data, which are manifestly made public by the data subject.


3. WHAT CATEGORIES OF PERSONAL DATA DO WE COLLECT?


The categories of personal data that We collect from You and process are as follows:

Personal identification and communication details are provided to Us when You complete the registration process to register for an account on Our Casino, personal identification and communication details are provided to us. This includes collecting Your details such as Your full name, date of birth, residential address, and communication details, including Your email address and/or phone number.


Your personal data and information may also be collected through other means, such as through documentation or data information that You provide Us upon Our request. Documents are provided for identity, age and address verification, and payment verification purposes. However, We may request other documentation from You as part of Our legal and regulatory obligations and to maintain Your account with Us.


We also hold records of Your financial accounts' information and some aspects of Your financial transactions through the use of Your account on this Website. In addition, We record Your logins and visits to this Website, such as through geolocation information, traffic data, and weblogs, amongst other information. Moreover, all Live Chats and email correspondence held with Our Player Support Team is recorded and maintained for security and training/educational purposes.


Although We do not collect special categories of data regularly, We may receive such data from You. For instance, if You inform Us that You have a gambling problem, We would treat such information as being equivalent to a special category of Personal Data (for example, health information), and so We will protect it.


4. COLLECTION OF INFORMATION FROM COOKIES


We use Cookies to collect information transferred to Your device (computer, mobile, tablet) by Your internet browser. Such Cookies help us improve Our Website and provide You a superior experience.


We obtain Your consent for non-essential Cookies for the successful operation of the Website. However, for Cookies essential for the Website to operate successfully, We are not obliged to seek Your prior consent.


For further information on Cookies, please read Our Cookie Policy or contact Us at dpo@elvelltd.com.


5. WHY DO WE PROCESS YOUR DATA?


We collect and process Your personal data for the following reasons:


  • Creating, operating, and managing Your account;
  • To play games and perform relevant activities related to games;
  • For Us to carry out identification and verification checks about You;
  • For You to place Your bets and process online payments;
  • Complying with Our legal, licensing and regulatory requirements, including those related to Data Protection;
  • Creating User profiles for Anti-Money Laundering Risk Assessment purposes. To prevent the illegal use of Our Website, We need to profile Our Users and their activities using automated processes. However, any decisions taken based on these profiles are taken by natural persons;
  • Monitoring and tracking transactions to prevent fraud, abnormal betting patterns, money laundering and/or terrorist financing, including the transferring of personal data to Our payment processing service providers;
  • Meeting Our obligations with the relevant authorities, including informing and assisting them in any potential criminal activities investigations, such as those related to fraud, money laundering and/or terrorist financing amongst others; and
  • For marketing purposes, only when You actively consent to receive marketing material about new games, bonuses, offers and promotions. You may opt-out at any time.


6. WHERE DO WE KEEP YOUR PERSONAL DATA?


We ensure We take all the necessary security and standard precautions to keep your personal data safe. We take all reasonable steps to safeguard the personal data we hold, and we have in place appropriate technical and organisational security measures in order to protect personally identifiable detailed policies, procedures and training of our people relating to data protection, confidentiality, and information security.


Our servers are physically located within the European Union, and they may only be accessed online through encrypted connections by authorised persons. In following best security practices and standards, We only contract with third-party providers who follow and ensure an adequate level of security similar to Ours.


We may also store Your data within our Group of companies. Because these may be located outside the EEA, We will still ensure to have adequate security measures in place and that Your personal data is always protected, for instance, by having in place Standard Contractual Clauses as per the European Commission.


7. WHO DO WE SHARE YOUR PERSONAL DATA WITH?


Your personal data may also be exchanged with certain third-party providers to be able to carry out the following processes and provide Our Service to You:


  • Payment processing;
  • Marketing, where Your consent was obtained;
  • Anti-Fraud, Anti-Money Laundering and/or Combatting Terrorist Financing checks;
  • Other Data Controllers;
  • Joint Controllers; and
  • Data Processors.


A list of our third-party providers may be provided to You upon request.


Please note that We may be required to disclose Your personal details to such third-party service providers to satisfy Our regulatory obligations and legitimate interests.


Anti-fraud, anti-money laundering and combating terrorist financing checks are used to verify Your personal details, which is done via electronic means by matching Your details against third-party databases to assess whether:


  • You may be a Politically Exposed Person (PEP) or a close associate of a PEP.
  • You are subject to Financial Sanctions.
  • Your personal details are close to or match people with adverse media results.


Where Our payment providers request such information for fraud enquiries, We will provide such personal data on the basis that the request for information is to either protect Your rights or for a legitimate interest to protect against fraud.


We ensure that data transfers with any third-party service providers are covered with appropriate contracts and safeguards that are put in place between the Data Controller (Us) and the Data Processor (the third party) under the General Data Protection Regulation (GDPR). These contracts will include references to confidentiality, strict processing rules, security safeguards, breach notification requirements and provision of assistance to Us so that Your rights are satisfactorily exercised.


In case of a change in the Data Controller, We will attempt to inform You about this and the identity of the new Data Controller either by contacting You directly or by placing notices on this Website or by using other communication methods.


We must also disclose Your personal data to the relevant regulatory authorities to satisfy Our legal obligations. These include, but are not limited to the:


  • Malta Gaming Authority (MGA)
  • Financial Intelligence Analysis Unit (FIAU)
  • Sanctions Monitoring Board (SMB)
  • Other relevant law enforcement entities


In disclosing to the relevant authorities, We are obliged to provide all personal details and documents, the payment and betting transaction history, the communication history, and any other information We hold about You. All personal data and records, including the documents, are transferred to the relevant authority through secure means, as may be prescribed by authorities beyond our control.


In cases where We would need to supply Your personal data to third-party providers, such as for marketing purposes, We will provide You with a specific opt-in possibility where Your active consent is required to transfer Your data to such third-party providers.


Such marketing partners are limited to only receiving Your contact details, for instance, Your email address and/or mobile phone number, that is only when You consent to receive marketing communications.


Suppose You choose to withdraw Your consent for marketing purposes, which You may do at any time. In that case, We will inform the relevant marketing partner to stop sending You marketing communications upon receiving your request.


8. DATA TRANSFERS TO THIRD COUNTRIES


When We share Your personal data with third-party providers located outside of the European Economic Area (EEA), We will always ensure to have a similar degree of protection to transfer Your personal data.


We only transfer to countries deemed to hold a sufficient level of data protection measures in place as per the European Commission and/or putting in place Standard Contractual Clauses in line with the European Commission.


9. FOR HOW LONG DO WE KEEP YOUR DATA?


We are obliged to retain some elements of Your personal data after Your account termination for a maximum period of up to 10 years to meet Our legal obligations regarding Anti-Money Laundering and Combating Terrorist Financing laws and regulations.


Particularly as follows:


  • For up to one (1) year from Your last account activity: Details of Your logins and visits to the Website, traffic data, weblogs, and communications to and from our Player Support Team;
  • For up to five (5) years from Your last account activity: Personal identification details and documents, Your communication details, contact information through the Website, whether by email, Live Chat or other media;
  • For up to ten (10) years from Your last account activity: Financial accounts information and game transactions.

We will also keep Your personal data for more extended periods if We are required to do so by the relevant authorities. This is especially in case of litigation or a legal process to which You, the relevant authorities or Us may be a party due to Our Service provision to You.


All Your personal data, details, information and documentation are stored securely in accordance with this Privacy Policy.


10. YOUR RIGHTS


You have the right to:

  • Access Your personal data and information that We hold on You; you can ask us for a copy of the personal data that we hold on you.
  • Request rectification of Your personal data that You consider incorrect; if you become aware of any errors or inaccuracies concerning your personal data, please let us know.
  • Request for restriction or objection of processing of Your personal data; you can ask to restrict or object to our processing of your personal data.
  • Request erasure of Your personal data; you can ask to erase your personal data when we no longer need it for the purposes for which it was obtained.
  • File an objection about the processing of Your personal data;
  • Request to export Your personal data and information; you can ask for your personal data to be sent to you or to another organisation.
  • Request to be informed about any automated individual decision-making that We have in place, including risk profiling; if we make an automated decision about you, you can ask for those decisions to be reviewed and
  • Object at all times to the processing of Your personal data and information and withdrawing Your consent; where we process personal data based on consent, you have the right to withdraw consent at any time.


Your rights may only be exercised in accordance with the law. This might include restrictions on when you can exercise the rights listed above due to laws that supersede the GDPR. You can exercise these rights by contacting Us at dpo@elvelltd.com.


You also have the right to file a complaint with the Office of the Information and Data Protection Commissioner in Malta by visiting their Website.


However, You may also decide to file a complaint with Your local Data Protection Authority, where You may find a list of their contact details by visiting this Website.


11. CHANGES TO THIS PRIVACY POLICY


This Privacy Policy is subject to changes from time to time. Any changes we may make in the future will be published on this page of our Website.


The changes will be effective from the date of publication. You can request the previous versions of such Privacy Policy by emailing Us at accessrequest@tastevegas.com.