Leisure Gaming N.V., a company registered at Chuchubiweg 17, Willemstad, Curacao – Dutch Caribbean (hereinafter “the Company”), declares the following Privacy Policy, confirming that each defined word or term has the same meaning and purpose as set forth in its respective Website Terms and Conditions (“T&C”), in connection with:

I. any information that the Company collects about the User when visiting the Company’s Website and using the Service, and/or interacting in any other way with any member of the Company’s Team;

II. how the Company uses, shares, stores, and secures the information; and

III. how the User can access and control that information.

User Information. The Company may collect any “Personal Information,” which is any data, information, or combination of data and information provided by the User to the Company, or through the use of the Company’s Website and Service, and that relates to an identifiable individual.

The Company collects Personal Information when provided by the User or when the User visits the Website and uses the Service.

The Company does not collect sensitive data or special category data about the User. This includes details about race, ethnic origin, politics, religion, union membership, genetics, biometrics, health, or sexual orientation.

Use of Information

The Company will only use Personal Information as permitted by applicable law to:

provide customer support and personalized features, and to protect the security of the Website and the Service; fulfill a legitimate interest not overridden by the User’s fundamental rights or data protection interests, for example, for research and development purposes, and to protect the Company’s legal rights and interests; when the User gives consent for a specific purpose; when the Company needs to comply with a legal or regulatory obligation.

When the User has given consent to use any Personal Information for a specific purpose, they have the right to withdraw such consent at any time by contacting the Company, but this will not affect any use of Personal Information that has already taken place.

The Company does not share Personal Information with any companies outside its own group, if applicable, for marketing purposes unless there is specific express consent to do so.

For visitors or users of the Website in the European Union, the legal bases for processing their information are published in the Legal Bases Table at the end of this Policy under Clause 9.

Sharing Information

The Company may share Personal Information with third parties that help operate, provide, support, enhance, and market its Website, products, and services, for example, third-party service providers offering website and application development, data storage and backup, infrastructure, payment processing, customer support, business analytics, and Know Your Customer (“KYC”) verifications and other relevant services.

Third-party service providers have access to Personal Information solely for the purpose of performing their services and in accordance with applicable laws and regulations. These third-party service providers are required to maintain the confidentiality and security of all Personal Information they process on behalf of the Company, and to implement and maintain reasonable security measures to protect the confidentiality, integrity, and availability of any Personal Information.

The Company takes reasonable steps to confirm that all third-party service providers process Personal Information in a manner that provides at least the same level of protection as provided in this Privacy Policy. When a third-party service provider cannot meet these requirements, reasonable steps will be taken to prevent or stop non-compliant processing.

The Company may share aggregated or de-identified Personal Information with third parties for research and analysis, profiling, and similar purposes to help improve products and services.

If Users use third-party software in connection with the Company’s products or services, third-party software providers may access Personal Information. The policies and procedures of third-party software providers are not controlled by the Company, and this Privacy Policy will not cover how Personal Information is collected or used by third-party software providers. Users are encouraged to review the privacy policies of third-party software providers before using third-party software.

The Website may contain links to third-party websites over which the Company has no control. If Users follow a link to any of these websites or provide information to them, Personal Information will be subject to their policies. Users are encouraged to review the privacy policies of third-party websites before providing any information to them.

The Company may share any Personal Information with government officials and law enforcement to comply with applicable laws or regulations.

User-Provided Information:

Through the use of the Service, the User may provide us with the following information:

Account Information

This includes: name, email address, and password. If the User chooses to log in using another service, such as Google or Apple, we receive information about the service the User used to log in and, depending on the User’s chosen account settings with Google and Apple, details about the User, including the User’s name, email address, or unique user identifiers.

Profile Information. We ask the User to provide date of birth, pronouns, and employment status when registering in the applications.

Messages and Content

This includes messages that the User sends and receives through the applications, such as data the User may provide about themselves or the User’s life, and any photos, videos, and voice and text messages the User provides.

Interests and Preferences

The User can select conversation preferences, such as topics the User would like to discuss, and communication preferences, such as times of day the User would like to use the applications. We also learn about the User’s interests and preferences over time through the use of the Services to personalize conversations and features of the Services.

Storage of Information

All Personal Information provided by the User is stored on the Company’s servers or on third-party servers to which only the Company has access within the limits of applicable laws and regulations. The Company retains Personal Information only as long as reasonably necessary to fulfill the purposes for which it was collected, including legal, accounting, or reporting purposes.

International Transfer of Information

The Company collects Personal Information globally and transfers, processes, and stores Personal Information outside the User’s country of residence to provide products and services.

Some of the countries where the Company or third-party service providers operate or are located may not have privacy and data protection laws equivalent to those of the User’s country of residence. When Personal Information is shared with these companies or third-party service providers, contractual clauses, corporate rules, and other appropriate mechanisms are used to safeguard the transfer of Personal Information.

User Rights

The User has the following rights:

• To be informed about what the Company does with the relevant Personal Information.
• To request a copy of the relevant Personal Information the Company has.
• To demand the Company correct any inaccuracies or errors in the relevant Personal Information maintained.
• To request the deletion of the relevant Personal Information, except for information retained for record-keeping, transaction completion, or legal compliance purposes.
• To object to or restrict the processing of the relevant Personal Information (including for marketing purposes).
• To request to receive some of the relevant Personal Information in a structured, commonly used, and machine-readable format, and request that it be transferred to another party.
• To withdraw consent at any time when the Company is using consent to process the relevant Personal Information (although this will not affect the legality of any processing done before the withdrawal of consent).

The Platform and the Application allow Users to update certain information about themselves.

The User can opt out of receiving marketing materials from the Company by contacting the Company expressly. However, the User will continue to receive notifications or information necessary for the use of the Company’s products or services.

As a security measure, the Company may require specific information from the User to help confirm their identity when processing privacy requests or when exercising the rights outlined in this Clause.

Any request under paragraph 6.1 will normally be addressed at no cost. However, the Company may charge a reasonable administrative fee if the request is clearly unfounded, repetitive, or excessive.

The Company will respond to all legitimate requests approximately within one (1) month. Occasionally, it may take more than one (1) month if the request is particularly complex or if Users have made several requests.

Changes in the Policy

The Company reserves the right to modify this Privacy Policy from time to time by posting the updated Privacy Policy on the Website. By continuing to use the Website and the Company’s Service after the changes take effect, the User agrees to be bound by the revised policy.

Children’s Privacy Policy. The Company’s products and services are not directed or intended for individuals under the age of majority in their country of residence. The Company does not knowingly collect any personal information from individuals under the age of majority, and if detected, steps will be taken to delete such information.

European Union Users: General Data Protection Regulation (GDPR). If the User visits the Company’s Website from the European Union (“EU”), they may be subject to privacy laws different from those in other jurisdictions. The User acknowledges that they may be transferring relevant Personal Information to the Company for storage and processing in other countries worldwide for the purposes described in this Privacy Policy. The Company takes the utmost care in protecting Personal Information and has implemented appropriate mechanisms to protect it when transferred internationally.

The legal basis for collecting and using any relevant Personal Information if the User is a citizen or resident of the EU will depend on the specific Personal Information and the context in which it is collected:

Contractual Performance. The use of any relevant Personal Information may be necessary to fulfill the terms and conditions or other policies under which we operate our Website. Consent. The User’s consent is necessary if technical information, such as cookie data and geolocation data, is required, and if any relevant Personal Information is used for marketing purposes. The User can withdraw their consent at any time by contacting the Company directly. Legitimate Interests. The Company may use any relevant Personal Information for its legitimate interests to improve its Website, for security and fraud prevention purposes, and to share information with its affiliates for internal administration. In such circumstances, the Company ensures that these interests are not overridden by the User’s data protection interests or fundamental rights and freedoms.

Legal Bases Table:

Purpose of Processing Type of Data Processed Legal Basis Allow the User to access products and services. Account Data, Transaction Data, Support Data, Technical Data [and User Content]. Contractual performance. Administer and maintain the security of the Website. Technical Data. Contractual performance. Study the usage of products or services. Transaction Data, Support Data, Technical Data, Usage Data. Legitimate interest to improve the Website. Collect feedback on products, services, or features. Account Data. Legitimate interest to improve the Website.

Purpose of Processing Type of Data Processed Legal Basis Allow the User to access products and services Account Data, Transaction Data, Support Data, Technical Data [and User Content]. Contractual performance. Administer and maintain the security of the Website. Technical Data. Contractual performance. Study the usage of products or services. Transaction Data, Support Data, Technical Data, Usage Data. Legitimate interest to improve the Website. Collect feedback on products, services, or features. Account Data. Legitimate interest to improve the Website.

Rights under EU law: If the User’s relevant Personal Information is subject to the protections offered by EU law, the User may:

Access, correct, update, or request deletion of any relevant Personal Information at any time by contacting the Company using the contact details provided on the Website (in accordance with applicable data protection laws) or by writing to [email protected], provided that the Company may charge a reasonable fee for manifestly unfounded, excessive, or repetitive requests. Object to the processing of any relevant Personal Information, request the Company to restrict the processing of any relevant Personal Information, or request the portability of any relevant Personal Information for the legitimate interests mentioned above. In certain circumstances, the Company may not be able to stop using the Personal Information, with just cause. Withdraw consent at any time if the Company collected and processed any relevant Personal Information with consent. Opt out of receiving personalized advertising on the browsers of the User’s mobile device by visiting the corresponding device settings pages. Please note that, if the User opts out of receiving personalized advertising, they will still see online ads, but they will be less relevant to them.

 

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