1.1. Privacy Policy

Before consenting to the Processing of Your Personal Data or providing Your Personal Data through any form on our Website, we kindly ask You to review this Privacy Policy carefully. This will ensure that You fully understand the Terms and Conditions under which we operate. This Privacy Policy is applicable to Your use of our Services, as outlined in our Terms and Conditions.

This Privacy Policy details when, where, and why we collect and process Personal Data from the Users of the Website, how we use this Data, the circumstances under which we may share it with others, Your rights regarding Your Personal Data, and the measures we take to protect it.

1.2. Definitions

The following definitions are used in this Privacy Policy:

“Consent of the Data Subject/User” refers to any voluntary, specific, informed, and clear expression of the Data Subject/User’s wishes, given through a statement or clear affirmative action, indicating their agreement to the processing of their Personal Data.

“Data Subject” refers to any identified or identifiable natural person as the User of the Website whose Personal Data is being processed by the Data Controller.

“Data Controller” refers to us as the Company that collects, uses, transfers and processes Your Personal Data.

“Personal Data” refers to any personal information about You that, alone or combined with other information, enables the Data Controller to identify You as an individual.

“Processing of the Personal Data” refers to any action taken with Your Personal Data, whether automated or manual, including collection, recording, organization, structuring, storage, modification, retrieval, consultation, use, sharing, transmission, dissemination, alignment, restriction, deletion, or
Other terms, including but not limited to “User”, “Website” and “Company”, shall have the meanings assigned to them in our Terms and Conditions, unless otherwise defined herein.
This Privacy Policy together with the Terms and Conditions, forms an integral part of our Terms of Use, which You have accepted upon registering Your Player’s Account or will accept before completing Your registration on our Website. We strongly recommend that You read our Terms of Use carefully before registering Your Player’s Account and using our Services.

1.3. General

This Privacy Policy sets out and describes the way in which We collect and process Your Personal Data, which You provide, or You are requested to provide to us in connection with using our Website and Services.

We respect Your privacy and are committed to protecting Your Personal Data and processing it in accordance with the applicable laws, including:

Constitution of the Republic of Comoros of 2018.

The Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 and Directive (EU) 2016/680 of the European Parliament and of the Council of 27 April 2016 (General Data Protection Regulation) (“GDPR”).

By registering and clicking “I agree” on the Website, You have agreed to be bound by this Privacy Policy, which forms part of the Terms of Use as indicated in the Terms and Conditions.

1.4. What Personal Data We Collect

We mainly collect Your Personal Data to provide You with our Services and to comply with regulatory requirements. We are required by law to collect specific information from You, including documents for verifying Your identity in connection with Your use of our Services. As a result, we must retain certain information about You for several years to comply with our legal obligations. Additionally, we may process some of Your Personal Data to send You promotions and offers related to our Services that we believe may be of interest to You. However, You can opt out of such marketing communications at any time if You wish.

Personal Data that we request or may request from You in the frame of the provision of the Services:

• Name;
• Date of Birth;
• Email Address;
• Telephone Number;
• Country of Citizenship;
• Country of Residence;
• ID/Passport Number.

Additional Data that we may collect and process during Your activity on our Website:

• Type of Access Device You use, Your Access Device unique identifier, serial number or Access Device ID.
• IP address of Your Access Device, Your operating system and browser type.
• Information related to Your usage, product interactions, performance, diagnostics, crash data, search and browsing history, and location data from the devices You have purchased or use to access our Services.
• Anti-fraud data (e.g., detection of VPN/proxy usage, multi-accounting monitoring/geolocation).
• Details about how You use our Services (identify Your activity on our Website), such as to differentiate You from other users, remember Your preferences (for example do you place bets or participate in games, what marketing You are interested in or subscribed to, etc.), and enhance Your experience. This information also helps us improve our Services.

Additionally, we may request that You provide other documents or information as specified in Section 6 of our Terms and Conditions.

1.5. How We Use Your Personal Data

We may process Your Personal Data for the following purposes:

• To verify Your identity for Your registration on the Website (that You can create Your Player’s Account) in relation to Your access to the Services.
• To provide You with the information, products, offers regarding our Services as well as to send You marketing and promotional materials.
• To deliver, improve, and develop our Services.
• To communicate with You, including to offer You targeted advertisements and Services (such as if You participate in a contest or promotion, where Your Personal Data may be used to manage those programs).
• To process Your transactions (for example withdrawals and deposits).
• For system administration and internal operations, including troubleshooting, testing, statistical analysis, surveys, data analysis, research, and audits.
• To authenticate Your access to our Website and Services and to differentiate You from other Users.
• To monitor Your use of our Website and Services, improving User experience and ensuring content is displayed optimally for You and Your Access Device.
• To conduct marketing analysis, enabling us to assess trends and the effectiveness of our advertising and marketing efforts (this may include using Your Personal Data to evaluate, analyse, or predict aspects like Your preferences, financial situation, interests, or location).
• To provide Customer support and maintain a high level of Customer Services.
• To personalize Your Services and communications, where available and chosen by You.
• To promote safety and security by monitoring for fraud, investigating suspicious or potentially illegal activities, or enforcing our Terms of Use.
• To ensure the safety and security of our Website and Services.
• To comply with applicable laws and regulations.

1.6. With Whom We May Share Your Information

We may share Your Personal Data with:

• Advertising partners to deliver promotional messages or display personalized content to You as well as for the purposes of research, evaluation, and analysis. This allows us to present offers tailored to Your interests as well as to understand how You engage with advertisements and how can we improve our Services for You.
• Service providers and other our contractors. We engage third parties to provide us with services (such as mail service providers, cloud hosting and storage, analytics, marketing service providers (affiliates) different payment providers, other professional service provider).
• Fraud detection and anti-money laundering service providers. We also work with service providers to ensure compliance with legal requirements related to gambling, including fraud detection and anti-money laundering measures.

Additionally, we may utilize open-source information, such as public records, government registries, databases, and social media platforms (including Facebook, LinkedIn, etc.), as permitted or required by law.

We always ensure that our service providers and other contractors provide at least the same level of protection for Your Personal Data as we do.

1.7. Direct Marketing and Opt-Out

From time to time, we may use Your Personal Data to notify You about our Services or new products, or promotional activities that we believe may be of interest or benefit to You. This may be done through email, sms or phone.

Additionally, we may reach out to You regarding the management and administration of Your Player’s Account. These communications can occur through any of the contact methods You provided during registration. Please note that these account-related communications do not affect Your opt-in or opt-out preferences for direct marketing notifications.

If You no longer wish to receive marketing or promotional materials from us whether in general or in a specific format, You can withdraw Your consent at any time, such as by clicking the “unsubscribe” link at the bottom of our marketing emails or by contacting our support team via email to: [email protected].

1.8. Legal Basis for Processing Your Personal Information

We will only handle Your Personal Data when there is a legitimate legal basis to do so. The appropriate legal basis depends on the specific reasons for which Your Personal Data is collected and used. Typically, the legal grounds will include:

• Consent: When You agree to provide Your Personal Data in the frame of accessing the Website and using the Services, as well to receive marketing communications from us. Based on Your consent we process Your Personal Data.
• Legitimate Business Interests: We may process Your Personal Data to understand our customers, promote our Services, and operate our business effectively, as long as this is done in a way that does not disproportionately affect Your privacy or rights. For instance, we may rely on this basis to:
  • conduct market research to gain insights about our customers;
  • send You promotional emails, SMS, or push notifications about our Services, special offers, and new products (provided You have not opted out);
  • improve our Website’s usability and customer experience.
• Legitimate Interest: We may process Your information to maintain the security of our Services, prevent fraud, and ensure compliance with our Terms and Conditions. This includes:
  • verifying account authenticity;
  • preventing multi-accounting, bonus abuse, identity theft, and other fraudulent activities;
  • detecting VPN/proxy usage and other security risks;
  • ensuring compliance with responsible gaming measures.
• Contractual Obligations: When processing Your Personal Data is necessary to fulfil the Agreement with You or to take steps before entering into Agreement.
• Legal Obligations: We may be required to process Your Personal Data in order to comply with applicable regulations, anti-money laundering (AML) laws, and requirements related to the responsible use of our Services. This includes:
  • retaining KYC documents for identity verification;
  • monitoring transactions for suspicious activities;
  • reporting to regulatory authorities where required by law.

1.9. Fraud Prevention and Security

We are committed to ensuring the security of the provision of our Service and preventing fraudulent activities, including but not limited to:

• Multi-accounting;
• Bonus abuse;
• Identity theft;
• Unauthorized access;
• Money laundering.

To detect, prevent, and mitigate fraudulent activities, we process and monitor the following types of Personal Data:

• IP address and geolocation – to identify suspicious login attempts, VPN/proxy usage, and unauthorized account access.
• Device ID and browser fingerprinting – to detect duplicate accounts and prevent unauthorized account sharing.
• Behavioral data – to identify suspicious gaming patterns and prevent collusion.
• Payment and withdrawal history – to prevent financial fraud and ensure AML compliance.

This Data processing is based on our Legitimate Interest (as stated above in clause 1.8.) to maintain the integrity of our Services and comply with regulatory obligations where applicable. If we detect fraudulent activity, we reserve the right to suspend or terminate accounts, restrict Your access to the Services, and report violations to relevant authorities.

1.10. Your Rights

Since we handle Your Personal Data, it’s essential that You are aware of Your rights as the Customer.

Below, we outline Your rights and how they pertain to the Data we process.

• Right of Access: You have the right to request a copy of the Personal Data we hold about You, which will be provided free of charge.
• Right to Rectification: If the information we have about You is inaccurate or incomplete, You have the right to ask us to correct it at any time.
• Right to Withdraw Consent: If we are processing Your Personal Data based on Your consent, You have the right to withdraw that consent at any time. Once consent is withdrawn, any data processed under that basis will be deleted, unless another legal reason requires us to continue processing it.
• Right to Erasure: If we process Your Personal Data based on Your consent and You later withdraw Your given consent, You have the right to request the deletion of Your Data (except for information that we are required to retain by legal or regulatory obligations).
• Right to Object: If we process Your Personal Data based on Legitimate Interests or use Your Personal Data to create a profile to determine Your interests, You have the right to object. If You do, we must either demonstrate compelling legitimate grounds that override Your reasons or stop processing Your Personal Data.
• Right to Data Restriction: You have the right to request that we restrict the processing of Your Personal Data under specific conditions, meaning we can store it but not process it further. This right applies in the following situations:
  • You dispute the accuracy of Your Personal Data (refer to the right to data rectification above) and we need time to verify its accuracy;
  • The processing is unlawful, and You prefer to restrict the use of Your data rather than have it erased;
  • We no longer require the Data for the original purposes, but You need it to establish, exercise, or defend legal claims;
  • You have exercised Your right to object to processing, and we are verifying whether our legitimate grounds override Your objection.
    You have exercised Your right to object to processing, and we are verifying whether our legitimate grounds override Your objection.
  After You request a restriction on processing Your Personal Data, we may only process it under the following conditions:
  • If we have your consent;
  • To establish, exercise, or defend legal claims;
  • To protect the rights of another individual or legal entity;
  • For reasons of significant public interest;
  • Due to our Legitimate Interest and Legal Obligations.
• Right to Lodge Complaints with the Supervisory Authority: If You are dissatisfied with how we handle Your Personal Data, we encourage You to inform us so we can address Your concerns. However, You also have the right to file a complaint with the relevant supervisory authority (at Your place of residence or to the Gaming Board of Anjouan).
  If You wish to exercise any of the above mentioned rights, You may contact us at [email protected].

1.11. Transfers to Third Countries

All information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to other countries, which may have different data protection laws. The service providers that we use, have either adhered to the GDPR or other data protection laws applicable to their activity. We endeavour to safeguard Your information consistent with the requirements of applicable laws.

1.12. Security of Personal Data

You acknowledge that data transmission over the Internet can never be entirely secure. Therefore, we cannot guarantee the absolute security of any information You transmit. Any Personal Data You send to us is done at Your own risk. However, once Your Data is received, we will take reasonable measures to protect Your Personal Data from misuse, loss, unauthorized access, modification, or disclosure. This includes utilizing password-protected systems, databases, and Secure Socket Layer (SSL) technology. By using our Services or providing us with Personal Data, You consent to receiving electronic communications from us regarding security, privacy, and administrative matters related to Your use of the Services.

Always remember to log out of Your Player’s Account when You have finished using the Website and Services, especially if You share a computer with someone else. You are responsible for the security of the Access Devices You use to access the Website.

Ultimately, maintaining the confidentiality of Your username, password, and account information is Your responsibility. Please exercise caution when using the Internet and our Website.

1.13. Special Category of Personal Data

We do not collect any Special Categories of Personal Data about You, such as details about Your race or ethnicity, religious or philosophical beliefs, sexual life, sexual orientation, political opinions, trade union membership, health information, or genetic and biometric data. However, based on our experience, we recognize that You may voluntarily provide such data during communication with us at Your discretion.

Please note that although we process Your personal documents, such as passports or ID cards, the images contained in them are not technically processed in a way that would enable us to identify any of the aforementioned data. Therefore, such documents are not to be considered special category of data.

1.14. Children

Our Services are not intended for individuals under the age of 18 or the Relevant Age (as prescribed in our Terms and Conditions). We do not consciously collect Personal Data from people under the age of 18.

We are dedicated to preventing children from accessing our Services and do not accept their information for account registration. However, it is ultimately the responsibility of parents and guardians to supervise their children's online activities, including the use of internet filtering software where appropriate.

1.15. Third-Party Websites and Services

Our Website, Services and other products, may contain links to or allow access to third-party websites, products, and services. When You click on these links, You are leaving our Website and are subject to the privacy policies of those third parties. We are not responsible for the privacy practices, information, or content provided by these external websites and services. This Privacy Policy applies only to Personal Data collected directly by us through our Website and Services. We encourage You to review the privacy policies of any third-party websites You visit.

1.16. Cookies

Whenever You access the Website, we collect log information and place cookies on Your Access Device to track Your activity on the Website. You can choose to opt out of cookies, except for those that are essential for the Website’s functionality. If You are a registered User, we may collect and process cookie identifiers as well as the Data You provide during registration.

Also, when You use our Services, we monitor and analyse web traffic and track Your behaviour on the Website. We may collect information such as Your IP address, proxy server, operating system, web browser, mobile carrier, and location based on Your Access Device settings. This data helps us conduct market research and enhance the quality of our Services. Additionally, we use cookies to understand and remember Your preferences for future visits.
Users have the option to be notified by their browsers whenever a cookie is sent and can also disable cookies through their browser settings. However, please be aware that disabling cookies may affect or limit certain features and functions on our Website.

You can check additional information about cookie usage on the Website in our Terms and Conditions.

1.17. How Long Do We Store Your Information?

The duration for which we store Your Personal Data depends on regulatory and operational requirements. Typically, we assess whether specific laws or regulations mandate or allow us to retain Personal Data for a certain period. If no such laws apply, we take steps to ensure that the Personal Data is retained for only as long as it is necessary for the purpose for which it was collected. When Your Personal Data is no longer required, we will securely delete or anonymize it. However, there are exceptions:

• Permanent Self-Exclusion: If You are permanently excluded from our Services, we will retain Your Personal Data indefinitely to prevent Your further participation.
• Investigations or Fraud: If You are under investigation or we suspect fraudulent or criminal activity, we may keep Your Personal Data for a longer period to cooperate with legal authorities.
• Legal Disputes: In the event of a legal dispute, we will retain Your Personal Data for the duration of the dispute and as needed to defend our rights in any related proceedings.
• Account Deletion: If You request account deletion, we will securely delete or anonymize Your Data, unless We are required to retain it by law.

1.18. Updates

We may periodically review, update, and modify this Privacy Policy. The latest version will be published on our Website, and changes will take effect upon posting. We recommend that You regularly review this Privacy Policy to stay informed about its terms. By continuing to use the Website and Services after changes are published, You accept those changes. This Privacy Policy does not apply to websites linked to our Website, which are beyond our control.

1.19. Contact Details

While we strive to be as clear and transparent as possible, if You need any clarification about this Privacy Policy, please feel free to reach out. We are happy to provide You with any additional information You may need. Please contact us by email to [email protected] or by the Website customer support chat function.