Zopte Technologies LLP is committed to safeguarding the privacy expectations of its users ("you" or "your"). Accordingly, we have put in place this Privacy Policy, which outlines our data protection practices, including how we collect, use, disclose and protect your Personal Information, as well as your rights with respect to your Personal Information.
This Privacy Policy, covers the following areas:
* THE INFORMATION WE COLLECT
* CONDITIONS FOR PROCESSING OF PERSONAL INFORMATION
* MINORS
* USING THE COLLECTED INFORMATION
* MARKETING
* SHARING INFORMATION
* INTERNATIONAL TRANSFER OF INFORMATION
* THIRD PARTY TRACKING TECHNOLOGIES
* THIRD PARTY SERVICES
* RETENTION OF PERSONAL INFORMATION
* YOUR RIGHTS
* HOW We KEEP YOUR INFORMATION SECURED
* CHANGES TO THE PRIVACY POLICY
* HOW TO CONTACT US
Account details: When you download the App and register to use the services the App provides by creating an account, you will be asked to provide the following details about yourself: * We encourage you to read the Privacy Policy carefully. By installing the CCCasino App and by creating an account, you hereby indicate that you have read and understood this Privacy Policy.
THE INFORMATION WE COLLECT We collect two types of information from our users: Personal Information The first type of information that we collect is information that identifies or may reasonably identify an individual ("Personal Information"). Personal Information that is being gathered may consist of the following:
- First name
- Last name
- Address
- Birth date
- Mobile telephone number
- Email address
- Password
1. - Photographic facial image
2. Address information: We store your home address and country. This is in order to confirm
(via
our payment processor) when you use a debit card to purchase play credit, the
card is registered to the same address.
3. Gaming information: In order for us to provide the Services, we automatically record
information related to your account and use of our Services, including with respect to your
transactions, deposits, balances, withdraws, bonuses and winnings. We may also collect
information that indicates potential gambling problems or addictions in order to ensure a
responsible gaming environment and as required of the operators by law.
4. Financial information: In order for you to enjoy all of the functions of the Services and
use
Credit to play on gaming and non-gaming machines, payment information will be collected from
you, including full records of your financial transactions, such as purchases/withdrawals of
Credit as well as allowing you to set your safe bet limit, take a break from your account
and
close your account.
5. Voluntary information: We collect information which you provide us voluntarily, such as
when
you respond to communications from us, communicate with us via email or share additional
information about yourself through your use of the Services. This includes information you
are
willing to share with us for the purpose of improving and developing our relationship with
you.
6. Geolocation information: If you allow geolocation services on your device we shall store
your
geolocation details including your longitude and latitude against each financial transaction
(machine deposits and withdrawals and card deposits into your account and withdrawals back
to
card), in order to detect suspicious patterns of play and to enhance the Services by
understanding regional play.
7. Device information: We may collect specific types of connection details and information
with
regard to your device, software or hardware that may identify you, such as: device's
unique
identifiers (e.g. UUID and MAC address), browser fingerprinting and IP address.
8. Telephone calls: We may record or monitor telephone calls for customer support, training
and/or security purposes.
9. Information we collect from third parties: We may collect Personal Information from third
party service providers, such as information about your credit history from credit agencies
and
other financial information which is relevant to the provision of the Services, as well as
information which is gathered in order to verify your identity and prevent fraudulent or
illegal
activity.
In addition, we may collect certain information as required under various gaming regulations, as well as Know Your Client ("KYC") and Anti-Money Laundering ("AML") regulatory requirements, such as your source of funds.
Non-personal Information The second type of information is un-identified and non-identifiable information pertaining to you, which may be made available or gathered via your use of the Service ("Non-Personal Information").
1. Log-in history and technical information: In order to enhance the functionality of the
Services and to provide you with a better user experience, we collect technical information
transmitted by your device, including certain software and hardware information (e.g. the
type
of operating system your device uses, language preference, access time of the App;
etc.).
2. Gameplay information: We record game play information including, amongst other things,
your
deposits, bonuses and game session duration.
Non-Personal Information which is being collected consists of technical information and aggregated usage information, and may contain, among other things, your operating system, screen resolution, keyboard language, your activities on the App, the period of time you visited the App and related time stamps, etc.
For avoidance of doubt, any Non-personal Information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection or linkage exists. Types of Non-personal Information we collect from or about you:
1. Device and connection information: We collect information from the particular device
you
are using, for security and fraud detection and prevention purposes. For example, we may
gather
information with regard to other software which is running simultaneously with the App for
detecting if you are using software which is associated with fraudulent activity (e.g.
robots,
malware, etc.) or checking if the connection you are using is via a VPN or proxy.
2. Analytics information: We collect information about your use of the Services, such as App
usage, log files, user activity (e.g. pages viewed, the amount of time spent on particular
pages, online browsing, clicks, actions, etc.), time stamps, alerts, etc. This information
is
collected for amongst other things troubleshooting errors and bugs as well as for research
and
analytics purposes about your use of the Services.
3. Anonymous information: We may anonymise or de-identify the information collected by the
Services or via other means so that the information cannot, on its own, personally identify
you.
Our use and disclosure of such aggregated or de-identified information is not subject to any
restrictions under this Privacy Policy, and we may disclose it to others without limitation
and
for any purpose, such as for advertising or marketing purposes.
CONDITIONS FOR PROCESSING PERSONAL INFORMATION
We will process your Personal Information for a variety of reasons, each of which is
prescribed
by relevant data protection laws.
* Fulfilment of a contract, compliance with a legal obligation
It is necessary for us to process your Personal Information where it is necessary for the performance of a contract or in order for us to comply with our various legal and/or regulatory responsibilities, including, but not limited to complying with any AML and KYC legislation. * Legitimate interests
We also process your Personal Information where we deem such processing to be in our (or a
third
party's) legitimate interests and provided always that such processing will not prejudice
your
interests, rights and freedoms. Examples of us processing in accordance with legitimate
interests would include:
(i) where we disclose your Personal Information to any one or
more
of
our associate/subsidiary companies following a restructure or for internal administrative
purposes;
(ii) detection and retention of information pertaining to those with
responsible
gaming issues;
(iii) processing for the purposes of ensuring network and information
security,
including preventing unauthorised access to our electronic communications network;
(iv)
safeguarding the integrity of our Services by combatting, reporting and sharing information
related to suspicious betting patterns or fraudulent activities;
(v) adhering to
regulatory
and
statutory requirements;
(vi) devising a tailored reward scheme for players; and (vii)
sharing
personal information with our advisers and professional services providers (such as
auditors)
for ensuring our compliance with regulatory requirements and industry best practices.
* Consent Our processing of your Personal Information will primarily be necessary for
us to
provide you with the Services. However, if you provide your consent to receive marketing we
will
on certain occasions provide marketing information (such as promotions and marketing
material).
If you have agreed to receive marketing you can opt out at a later date. If you no longer
wish
to be contacted for marketing purposes, please update your account preferences within the
App.
MINORS
Use of the Services in relation to gaming machines is not designed or directed to persons
under
the age of 18.
We reserve the right to access and verify any Personal Information collected from you. In
the
event that we become aware that a person under the age of 18 is using the Services in
relation
to gaming machines and has shared any information, we may discard such information unless it
is
needed to comply with any legal or statutory obligation binding upon us.
USING THE COLLECTED INFORMATION
We may use your Personal Information for the purposes listed below:
* To set up, manage and update your account.
* To provide and operate the Services (such as for purchasing Credits and payment
processing).
* To communicate with you and to keep you informed of our latest service updates.
* To market our Services (see more below under "Marketing"), as well as to serve you
advertisements, including behavioural advertising.
* To conduct analytics, statistical and research purposes, in order to improve and customise
the
Services to your needs and interests (such as by compiling aggregated reports about the
usage of
certain features of our Services).
* For customer relationship management purposes, and to support and troubleshoot the
Services
and to respond to your queries.
* To enable us to further develop, customise and improve the Services based on your common
preferences and uses.
* To provide you with a responsible gaming environment.
* To communicate with you and to process any of your requests to exercise your user
rights.
* To identify and authenticate your access to certain features of the Services.
* To detect and prevent fraudulent and illegal activity or any other type of activity that
may
jeopardise or negatively affect the integrity of the Services, including by identifying
risks
associated with your activity on the App.
* To investigate violations of our policies and the Terms as well as enforce our policies
and
the Terms.
* To investigate and resolve disputes in connection with your use of the Services.
* To assist us with meeting our regulatory obligations or as required by law or regulation,
including for the purpose of ascertaining your source of funds or income, or as required by
other governmental authorities, or to comply with any legal process or respond to a
government
request.
* In addition, we use your Personal Information upon your specific and informed consent,
such as
for certain marketing and promotional activities.
Where you have not consented (or have withdrawn your consent) to the processing of your
Personal
Information by us, we may continue to process your Personal Information
(a) where
processing
is
required for the performance of the contract (i.e. the Terms) between you and us; and/or
(b)
where processing is necessary for compliance with a legal obligation to which we are
subject;
(c) where processing is necessary for the purposes of a legitimate interest of
Machanti
Limited.
MARKETING
Subject to your express consent, We will use your Personal Information, such as your name,
home
address, email address, telephone number etc., ourselves or by using our third party
subcontractors for the purpose of providing you with promotional materials, concerning the
Services as well as products, services, websites and applications which relate to the
Services
("Marketing Affiliates"), which we believe may interest you.
If you have consented to receiving marketing offers, you may at any time decline receiving
further marketing offers from us or from Marketing Affiliates by updating your account
preferences within the App.
SHARING INFORMATION
We do not share your Personal Information with third parties ("Recipients") except as
described
in this Privacy Policy. The Personal Information will be disclosed to Recipients only to the
extent required for the specific purposes, as stipulated in this Privacy Policy.
We may share Personal Information with any of the following recipients:
* Any replacement service provider that we engage with to operate the App.
* Companies within ourgroup and other affiliated companies.
* Subcontractors and third-party service providers, as well as their subcontractors, which
by
way of example include (but is not limited to) cloud computing companies, marketing
affiliates,
identity verification and fraud prevention services, and other data verifiers.
* Payment service providers, payment processors and banks.
* Auditors, contractors or legal/financial/other advisers of any of the business
processes.
* Any third parties who investigate, detect or prevent fraudulent or illegal activity or
enable
us to enforce our policies, including in order to ascertain your source of income or funds
(e.g.
governmental authorities, law enforcement bodies, banks and other investigatory
bodies).
* Gambling addictions bodies.
* Licensing authorities, governmental and regulatory bodies, in accordance with applicable
laws
and regulations.
* Potential purchasers, successors or investors in We, or in the event of a corporate
transaction (e.g. sale of a substantial part of our business, merger, reorganization,
bankruptcy, consolidation or asset sale of an asset or transfer in the operation thereof) in
relation to us (in such event, the acquiring company or transferee will assume the rights
and
obligations as described in this Privacy Policy).
In addition to the purposes listed in this Privacy Policy, we share Personal Information
with
those Recipients for any of the following purposes:
* Storing such information on our behalf, for example by using cloud computing service
providers.
* Processing such information to assist us with our business operations (e.g. to process
payments and your deposits; authenticate your access; auditing our operations; detect and
prevent fraudulent or illegal activity; etc.).
* Performing research, technical diagnostics or analytics.
* Communicating targeted advertising, as well as promotional and informational materials, in
accordance with our marketing policy (see above, in the section titled "Marketing").
* Whenever we believe in good faith that disclosure is necessary to protect our rights or
legal
claims, enforce our policies (including our Terms), protect your safety or the safety of
others,
as well as to investigate or prevent any fraud, for security reasons or to help us with any
other related technical issue.
INTERNATIONAL TRANSFER OF INFORMATION
It may be necessary for the provision of Services and to the extent required for the specific purpose, as stipulated in this Privacy Policy to transfer your Personal Information to countries outside the European Economic Area. The data protection and other laws of these countries may not be as comprehensive as those in the European Economic Area. We use best efforts to ensure that your Personal Information is protected in accordance with our Privacy Policy, through contractual means (such as by using the standard contractual clauses approved by the European Commission for data transfer, as available at https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-sccen) or other means (such as ensuring that the European Commission decisions determined that such jurisdictions offer adequate level of protection).
THIRD PARTY TRACKING TECHNOLOGIES
When you access our Services (for example when you use the App), we use (and authorize third
parties to use) web beacons, cookies, pixels, scripts, tags and other technologies
("Tracking
Technologies").
The Tracking Technologies allow us to automatically collect information about you and your
device (for example your computer or mobile device), for different purposes, such as in
order to
enhance your navigation on our Services, improve the performance of our Services and
customize
your experience on our Services. We also use this information to collect statistics about
the
usage of our Services, perform analytics, deliver content which is tailored to your
interests
and administer services to our users, advertisers, publishers, customers and partners.
THIRD PARTY SERVICES
While using the Services you may encounter links to third party websites, services or
applications. Please keep in mind that this Privacy Policy does not apply to any third-party
websites, services or applications, even if they are accessible, downloadable, or otherwise
distributed through the Services.
RETENTION OF PERSONAL INFORMATION
If you have registered an account through our Services, We will retain your Personal
Information
during the period your account is active. In addition, We will retain your Personal
Information
for additional periods, as strictly necessary to enable We to meet its legal obligations
under
applicable laws or regulations, such as the applicable gaming regulations, KYC and AML
regulations, as well as to meet our contractual obligations.
In addition, the Group may retain your Personal Information for longer periods, provided that retaining such information is strictly necessary for our legitimate interests, such as fraud prevention and record keeping, responsible gaming reasons, resolving or exercising claims regarding potential disputes, and where We is guided to do so by the applicable supervisory authority.
YOUR RIGHTS
You may contact us by raising a support ticket within the "Support" section of the App, and
request:
* With regard to consent-based processing, access or delete any Personal Information
relating to
you.
* To change or update any Personal Information relating to you (for example, if you believe
that
your Personal Information is incorrect, you may ask to have it corrected or deleted). Note
that
you may also request that we will correct errors with regard to your Personal Information
(except in cases where the information is required to be kept in its original format under
any
applicable laws and regulations).
* That we will restrict or cease any further use of your Personal Information.
* That we will provide the Personal Information in a machine-readable format.
* To object to the processing of your Personal Information (such as for marketing
purposes).
* To withdraw your consent to our processing activities (provided that such processing
activities rely on your consent, and not on a different legal basis).
* To not be subject to a decision based solely on automated processing, including profiling,
which produces legal effects concerning you or similarly significantly affects you, except
where
such processing is necessary for the performance of the contract between you and us, or it
is
based on your explicit consent, as provided hereunder.
Please note that these rights are not absolute and requests are subject to any applicable legal requirements, including gaming regulations and other legal and ethical reporting or document retention obligations. We may also rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion, in accordance with our internal policies.
HOW WE KEEP YOUR INFORMATION SECURED
We take great care in implementing and maintaining the security of the Services and your
information. We have put in place appropriate physical and technological safeguards to help
prevent unauthorised access, to maintain data security, and to use correctly the information
we
collect online. These safeguards vary based on the sensitivity of the information that we
collect and store.
We employ industry standard procedures and controls to ensure the safety of our users’
information, such as:
* Secure network topology, which includes intrusion prevention and Firewall systems.
* Encrypted communication.
* Authentication and Access Control.
* External and Internal audit tests; etc.
CHANGES TO THE PRIVACY POLICY
We reserve the right to change this Privacy Policy at any time, so please re-visit this page
frequently. We will provide notice of substantial changes of this Privacy Policy on the App
and/or we will send you an e-mail regarding such changes to the applicable e-mail address
that
you provided to us. Such substantial changes will take effect no less than fourteen (14)
days
after such notice was provided. Otherwise, all other changes to this Privacy Policy are
effective as of the stated "Last Revised" date, and your continued use of the Services after
the
Last Revised date will constitute acceptance of, and agreement to be bound by, those
changes.
HOW TO CONTACT US
If you have any questions or suggestions about our Terms and Conditions, do not hesitate to contact us at work@zopte.com.
We will make an effort to reply within a reasonable timeframe. Please feel free to reach out to us at any time. If you are unsatisfied with our response, you can lodge a complaint with the applicable data protection supervisory authority.
Last updated on October 21, 2020