PRIVACY NOTICE
1. Introduction and our contact information
1.1. Our websites (hereinafter “Website”) are designed for fun and games, and Viral (hereinafter also referred to as “the Operator”, “the Data Controller” ”We”, ”Our”or “Us”) highly values and respects the privacy of the players and online visitors on its Websites. This Privacy Notice (hereinafter “Notice”) is created in order for you to enjoy your gaming without having to worry about your data. We are committed to following the privacy principles set out in the General Data Protection Regulation "GDPR".
1.2. We collect and process your personal data only in the way we have informed you in this Privacy Notice and in accordance with the General Data Protection Regulation (2016/679) and applicable national legislation. Our aim is to respect your rights as a data subject and keep our data and the processes as accurate and transparent as possible.
1.3. You should read this Notice before using our Website. If you use or register via the Website, you accept this Notice. If you do not accept this Notice, please do not use the Website.
2. Personal data controller
2.1 For the personal data processing purposes defined in Section 3 of this Notice, the controller of your personal data is:
Viral Interactive Limited, a company duly incorporated under the laws of Malta, corporate registration number C66828.
Contact Information
UK Correspondent Address
Horeca Building, 3rd Floor,
Triq I-Imgarr, Xewkija, Malta, XWK 9012
compliance(at)viral-interactive.com
Contact phone number: +441274003201
Goodwille Ltd
24 Old Queen Street
LONDON
SW1H9HP
2.2. Contact our DPO
In all cases, you can send the data protection queries in order to obtain information on the processing of your personal data. The contact references of our Data Protection Officer: dpo@luck.com
2. Definitions
We aim to be as clear as possible. That’s why we have collected some terms that have a significant meaning and defined them here for you. As this Notice is a part of our Terms and Conditions, the definitions provided in the Terms and Conditions also apply to this Notice. When you notice a term used with a capital letter, it is one of the terms defined below:
"Automated Decision Making" is the process of making a decision by automated means without human involvement.
"Contract" is the agreement established between you and the Operator, once you register as a Player to the Operator’s Websites
"Cookie" is a tiny datafile that is saved on your computer, tablet or mobile phone.
"Data Controller" is the gaming license holder which determines the purposes and means of the processing of personal data. Defined in section 1.
"Duty of Care" is the duty of the Operator to protect the social and health aspects of its players in gambling operations, avoiding excessive gambling and providing help when and where necessary.
"GDPR" is the General Data Protection Regulation of the European Union [(EU) 2016/679] and Data Protection Act [UK2018/12]
"Notice" is this Privacy Notice
"Operator" is the company that holds the Gambling Licenses and runs the gaming websites.
"Player" is an individual registered as a real money player, holding a Player Account and having the nature of a data subject
"Player Account" is the designated account linked to a Player and established under registration, including Player Data
"Player Data" is any and all personal data connecting to the Player and processed by the Operator, further defined in section 4
"Processing" is any action or set of actions performed upon personal data such as collection, recording, organising, structuring, storing, adapting or altering, retrieving, consulting, using, disclosing by transmission, disseminating or making available, combining, restricting, erasing or destroying it.
"Profiling" is the procedure including any form of automated processing of personal data which may involve a series of statistical deductions. For example, gathering information about an individual (or group of individuals) from different sources and evaluating their characteristics or behaviour patterns in order to place them into a certain category or group to analyse and/or make predictions.
"Terms and Conditions" are the terms and conditions of Viral Interactive Ltd., found here.
"Website" is any and all the websites that operate under Viral Interactive Ltd.’s gaming licences.
3. Why do we collect and process
We need to collect and process your personal information, Player Data, in order to provide our services to you.
We aim for fairness and transparency in our actions concerning data and this Privacy Notice is one example of it. We want you to be informed about what data we collect and for what reasons, and also how it is processed and stored after collection.
The collecting and processing of your Player Data is solely based on lawful purposes. The purposes are introduced further in this chapter.
3.1. The contract between yourself and us
When you register and create a Player Account for our services, you enter into a Contract with us. Our part of the Contract is to provide you with access to the Services, and for that, We need to process your Player Data.
Some of the Player Data is mandatory, and if you decide not to provide this information to us, you will not be able to register a Player Account and use the Services.
This information is processed for purposes like:
Creating and managing your player profile and Player Account Protecting your Player Account and Data Processing your payment transactions and game transactions Providing Customer Support Avoiding multiple Player Accounts
3.2. Legal Obligations
As a gambling company, we have certain special legal and regulatory obligations that affect the data we need to process about our players. These obligations include, for example, regulation concerning Anti-Money Laundering (AML), responsible gaming, and the requirements set out by the license-granting authorities.
This information is processed for purposes like:
Age verification Source of Wealth / Funds verification Due Diligence checks Identity verification Self-Exclusion registers consulting Problem gambling detecting Detecting and blocking duplicate Player Accounts Detecting and blocking individuals from jurisdictions that prohibit gambling Monitoring and investigating transactions and game play to prevent and detect fraud, money laundering, problematic gambling patterns and other irregular gaming activities
3.3. Legitimate interest
It is in our legitimate interest to provide you with the best gaming experience and to protect our Services from abuse. For a better understanding of people who use our Services and to help us identify possible issues in usage, we process a small amount of information about everyone that uses our Websites.
The data is processed in a way and scale that is necessary to fulfil our legitimate interest but minimising the impact on your privacy in order to provide you with a secure, joyful and problem-free player experience and for us to be able to protect our Services from abuse.
The processing carried out based on Legitimate Interest are the following:
Avoidance of Fraud & Risk Assessment, besides the required assessment by Anti Money Laudering regulation, We also carry out risk assessment in order to determine our terms of service. Network Security, to ensure that non excluded but opted-out players do not receive marketing communications. Personalisation and web-analytics, to keep our marketing strategy up to date and personalise the gaming experience. Non-invasive profiling for direct marketing, for clusters of information without identifiable traits to ensure better marketing communication. Customer support logs, information can be used to manage disputes with players, to direct player's to responsible gaming staff and to improve the overall player experience.
It is our understanding that the processing of your data to achieve our legitimate interests listed above does not harm your rights and freedoms as a data subject. If you wish to obtain more detailed information on how this decision was made ("balancing test"), please contact our Data Protection Officer.
3.4. Consent
When you register with our website you are asked to give us your consent to send you relevant offers and marketing campaigns via email and/or SMS. We can only bring these promotions to you if you have given your active consent (opt-in) to this communication. You can always modify your consent on your player profile, withdrawing your consent at any time so that we stop sending you the marketing-related material or opting in to start receiving them.
4. Where and what do we collect and process
The majority of the Player Data is provided to us by yourself. There might also be some instances that we need to obtain some additional information about you from other sources.
To follow through with our legal obligations, including Anti Money Laudering and duty of care, we have to carry out due diligence to verify your identity, including your age. We might also have to ask about your source of funds. We always choose respected external companies to help us carry out these checks. In addition to this, we may also carry out additional searches on information available in open sources, like public registers and social media.
Besides using our own self-exclusion registry database, We also verify information with national registries in order to prevent self-excluded persons from registering and using our services.
Payment service providers that we are in business with may provide us with small amounts of information when carrying out your transactions, in order for us to connect the transactions to your Player Account.
FROM DETAILS RETENTION PERIOD (CALCULATED FROM THE DATE OF ACCOUNT CLOSURE) You Personal information: When you register to the Website, you are requested to submit your personal information: - your name; - date of birth; - email address; - address -phone number National Identification Number: if you use your bankID to register or login to our websites, those details will be securely stored as well. Financial Information: When you choose to make a deposit or withdrawal you are requested to submit your financial information (account and debit or credit card details). Your financial information is collected through a secure server (SSL) upon your registration as a real money player. Identification Documentation: The Operator may request additional documents through your Player Account in order to verify your identity, such as a copy of your: - ID; - passport; - driving license; - credit card; or - proof of address; Correspondence: Records of correspondence between you and us, whether via the Website, email, telephone or other means. AML/KYC Information: For possible Anti-Money Laundering and Know Your Customer purposes we might need supporting documentation to confirm your source of funds. 5 years Your device Device Information: Specific types of connection details with regards to your device are collected, such as device unique identifiers, IP Address and geo-locational data. This is needed in order to ensure that you are not playing in a restricted country. A country is restricted if the gambling in that specific country is prohibited by legislation or requires a local gaming license, which the Operator does not hold. 5 years External Sources To investigate possibly risky activities and to help us to comply with our legal and regulatory obligations, we need to from time to time rely on external sources to verify information. To prevent fraudulent or criminal activity, we may also collect the Player’s financial information from other online gaming sites, banks, credit card companies and other fraud prevention agencies. 5 years
Cookies
We use Cookies on our Websites and collect information through them. To learn more about Cookies on our Websites, please see our Cookies Policy.
5. Sensitive personal data
We do not collect or ask you to provide us with sensitive personal data as a part of your Player Data. Sensitive personal data could for example be; data revealing your ethnic origin; sexuality; or health-related data. If you at some point decide to disclose such data to us, for example while communicating with our Support or Responsible Gaming personnel, these discussions are linked and assigned to your Player Account. If you provide us documentation concerning your health condition that might affect your ability to keep control on your gambling behaviour, this documentation will be erased from our System but the information will be added to your Player Account. If our Responsible Gaming agents conclude that the information you have disclosed with us might affect your ability to play responsibly, we might close your account to comply with our Duty of Care policy, which means that you might not be able to reopen your account and use our Services.
6. Sharing of Data
In order for you to enjoy the website, We need to share some of your Player Data. This happens when, for example, you make a deposit or use our customer service: the necessary part of your Player Data is shared with the payment provider and helpdesk to help us provide you with the services of our gaming sites.
We, as a licensed operator, are also subject to regulations that might require data collection or sharing. As an example, to prevent fraudulent activity, we may share Player Data with other online gaming sites (cross-referencing), banks, credit card companies and other fraud prevention agencies. Whenever we have a legal obligation to do so, we may also share your Player Data with authorities.
We also share your Player Data or parts thereof with service providers in connection with identity verification, marketing, game and payment transactions, national exclusion database, customer support, risk & fraud, safer gambling, and data storage.
Part of our operation is done via Brand Partnerships. This means that We operate the Casino but the Brand is not owned by Us. In those cases, the Brand Partners are also data controllers, together with us.
Brand Partners have access to your Player Data, including your payment transactions. The Brand Partner will use your Player Data in order to provide you with promotions (if you consent to it!) and to comply with legal obligations.
In the U.K. we use the service of GB Group plc to verify your identity data in order to secure that we comply with the requirements of the anti-money-laundering and safer gambling regulation. For their privacy policy please visit: https://www.gbgplc.com/en/legal-and-regulatory/privacy-policy/
Here you can check our Partners, who are co-controllers of your data with Us:
SITE BRAND PARTNER LOCATION www.Luck.com/uk GB Group plc U.K.
Some of the parties we share your personal data with may be located outside the United Kingdom, European Union or the European Economic Area. Whenever we transfer your personal data outside the United Kingdom, European Union or the European Economic Area, we do so in accordance with the applicable legislation. We use appropriate safeguards to ensure that a sufficient level of data protection is maintained. Such safeguards may include the use of model contractual clauses adopted by the EU Commission or be based onan adequacy decision from the European Commission, confirming that the third country provides adequate protection for your personal data.
We share the minimum amount of data required with service providers.
You can find a comprehensive list of who we share your data with here.
7. Automated Decision Making and Profiling
We use automated decision making and profiling in only a few scenarios: for Responsible Gaming measures, to comply with Anti-Money Laundering legislation, to prevent Risk & Fraud and to tailor promotional materials to you (if you consented for marketing communications).
You can check below how these automated decisions are made and how we might profile your player data.
7.1. ANTI-MONEY LAUNDERING / RISK & FRAUD
As an Operator, we are obligated to follow the regulation for Anti Money Laundering and Countering the Financing of Terrorism and Fraud. This is mainly done by a Source of Funds/Wealth Check (SOF/SOW).
We will get a notification in case you reach the established deposit/withdrawals threshold. You may be asked to provide us with additional documents and your player data may be checked against databases to verify the information provided.
This system is in place in order to keep our service safe and compliant. We are also keeping our player data safe by performing additional risk prevention steps. This is a feature that includes real-time identification of each player, authenticating and authorizing their presence in our websites. The process also ensures that you have sufficient funds available to play games in our platform.
7.2. SAFER GAMBLING
To help us make a decision regarding your affordability, data is collected from a major credit bureau TransUnion.
The information we receive is in form of a credit score which allows us to assess your affordability and set a limit accordingly.
7.3. PROMOTIONS AND MARKETING MATERIAL
We use a feature in our system called "Engagement Manager", it combines smart player segmentation with campaign automation and real-time analytics. We use the Engagement Manager to set up graphical dashboards fed by real-time data to analyse results and improve future campaigns, player segments, triggers and bonus offerings.
8. Security Measures
We have implemented technical, organizational and physical safeguards for the protection of your personal data against unauthorized use, changes, access or disclosure. Our security measures also ensure that your data is not accidental or illegally destroyed.
We endeavour to maintain strict security measures on the Website and associated sites, so that no unauthorized use, loss and/or alteration of data can be done to Player and Player Account Data. Only authorised individuals with special access rights have access to your Data.
Financial information like credit or debit card data will not be stored in the Website, and all credit and debit card transactions are stored for the purpose of processing the payments by a certified payment service provider of your choice.
The Player Account can only be accessed with a unique username and password. The password will be stored in the Website only in encrypted form.
All personnel are subject to confidentiality clauses in addition to the obligation to follow our internal code of conduct, information security policy and data protection policy.
In the event of a data breach that might cause harm to you, we will inform you and the relevant data protection authorities as soon as reasonably possible but no later than 72 hours of our discovery of the breach.
If you require any further information, please contact our data protection officer at dpo@luck.com
9. Player’s rights
9.1. RIGHT TO ACCESS PERSONAL DATA
You can easily access and view the personal data you’ve provided us, as well as your gaming and payment transactions by logging into your player’s account and printing it out from your profile page.
However, if you cannot log in or have any difficulties accessing your data, you can also reach out to us and we will help you out. You can send an email to dpo@luck.com with a Subject Access Request ("SAR") below.
You can simply fill in the form, send it to us and we will take it from there! We will process your query within 30 days of confirming your identity.
Note that in some cases the 30 day period can be extended by 60 days, depending on the complexity of your player data. We will always inform you beforehand if that is the case.
Please let us know if you encounter any trouble accessing your data on your profile or filling in the form.
You can download the request form under this link.
Please fill out the form and sign it by hand. You can send the filled-out form to us via dpo@luck.com or via our support chat.
9.2. RIGHT TO RECTIFY YOUR PERSONAL DATA
You have the right to have any inaccurate personal data corrected. This means that you can fix any mistakes, typos and other inaccuracies in your player data or change some personal details that might not be current anymore.
Do let us know the changes in your personal data (new address, phone number, etc.) so we can keep your records up to date. You can do so via support@viral-interactive.com.
Note that some additional documents may be asked to confirm the veracity of the information.
9.3. RIGHT TO ERASE YOUR PERSONAL DATA
The right of erasure, commonly known as "the right to be forgotten" grants you the possibility to request that your data is erased and free from further processing.
This right can only be used when the data meets the following criteria:
i. The personal data is no longer necessary for the purpose for which it was collected or processed;
ii. Withdrawal of consent (without other legal grounds for processing);
iii. Data was unlawfully processed;
iv. Personal data has to be erased to comply with a legal obligation of the controller;
Please note that data pertaining to self-excluded players, to prevent fraudulent players from re-registering, data maintained in relation to sports betting integrity and to comply with AML regulations cannot be the object of a right of an erasure request, but its processing will be limited to these purposes only.
9.4. RIGHT TO OBJECT TO PERSONAL DATA PROCESSING
There are a few instances where you have the right to object to having your personal data processed by Us. This can be done regarding the processing based on a legitimate interest (see item 3.3. above) and to direct marketing (including profiling related to marketing activities).
You can exercise your right to object to personal data processing by sending an e-mail to dpo@luck.com .
Note that we reserve the right to close your account with us should you object to a legitimate interest that would make offering the gaming services impossible.
9.5. RIGHT TO DATA PORTABILITY
One of the new features brought by the GDPR is the right to data portability. In the gaming industry this means that you can ask us to forward your data to another operator. However, this right is limited to personal data processed by automated means and that the legal basis for processing is consent. We may also forward your data concerning self-exclusion and limits upon your request.
If you wish to have your data forward to another operator, please contact our DPO at dpo@luck.com .
10. Data Retention
In order for us to fulfill the requirements of our licenses and to comply with anti money laundering regulation, we need to store your data for the duration of your relationship with us.
We retain your personal data for a period of 5 (five) years from the day you close your account with us.
The five year period is the minimum period necessary for us to fulfill the purposes outlined in this Privacy Notice, to resolve disputes, enforce our Terms and Conditions, and comply with technical and legal requirements and constraints related to the security, integrity and operation of the Website and our service.
Please note that if you choose to self-exclude permanently from our services, we will retain a minimum amount of data in order to maintain our self-excluded database updated.
11. Complaints
We are committed to keeping your data safe and running the website smoothly. However, if you are not satisfied with how your information has been handled by Viral you can always reach out to our Support Team with your concerns.
If you are unhappy with the outcome of your interaction with our Customer Support Team, either via e-mail or live chat, you can always ask for the matter to be revised by our Data Protection Officer.
The DPO will then launch an investigation to verify whether your information has been handled appropriately and in line with this Notice and our legal obligations.
You will be contacted by the DPO with the result of such an investigation.
If after raising your complaint with the DPO you are dissatisfied with the resolution to your complaint you can make a formal complaint to our lead supervisory authority, the Maltese Data Protection Commissioner:
Office of the Information and Data Protection Commissioner
Level 2, Airways house - High Street
Sliema, SLM 1549 - Malta
(+356) 2328 7100
idpc.info[at]idpc.org.mt
Or, for players from the U.K.:
Information Commissioner’s Office
https://ico.org.uk/
0303 123 1113
12. Translations
Viral's company language is English. We have our websites translated into different languages for your convenience. However, if there are any conflicts between the translated version and the English one, the English one will prevail.
13. Third-party websites
Our Websites may contain links to other websites. Please review the privacy statements of any such other websites to understand their own information practices.
14. Amendments to this Privacy Notice.
To keep up with changing legislation, best practice and changes in how we collect and process personal data, we may update and amend this Notice from time to time and in case of significant changes which could affect you, you will be asked to approve the policy again when accessing our Website and services. If you do not accept the terms of the updated Notice, you are not able to use our Website and services.
This Notice is valid from the date indicated in its header.
15. Old versions and Changes Made
VERSION
MODIFICATION
1.4 - June 2022
Updated
1.3 - October 2020
Updated
1.2 - March 2020
Updated Player's rights and access form
1.0 - May 2018
First version of the Notice is published
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