Privacy Policy

Your privacy is important, we protect all information you share.

Privacy Policy


Co-Gaming Limited, which is part of the same group as ComeOn!, (”we”) protect your privacy. This privacy policy, together with our general terms and conditions and cookie policy, explains how we handle your personal data, your data protection rights and different choices you have regarding our use of your personal data.

Last updated: 09.03.2021 Version: 2.1

Contents

  • 1. Data controller and data protection officer
  • 2. Categories of information and the purpose of our processing     
    • 2.1. Information you provide      
    • 2.2. Information necessary for you to be able to use our services      
    • 2.3. Information used for marketing
  • 3. Information sharing      
    • 3.1. Sharing your personal data within the group      
    • 3.2. Sharing your personal data with third parties
  • 4. Transfers of personal data outside the EU
  • 5. Miscellaneous      
    • 5.1. Social media      
    • 5.2. Links to other websites      
    • 5.3. Surveys and competitions      
    • 5.4. Testimonials      
    • 5.5. Winner notifications and leaderboards
    • 6. Data retention
  • 7. Security
  • 8. Your rights
  • 9. Notification of privacy policy changes10. Contact details

1. Data controller and data protection officer
Co-Gaming Limited determines the purposes and means of the processing of your personal data and is therefore the data controller in accordance with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“GDPR”).

2. Categories of information and the purpose of our processing
2.1. Information you provide
We may process information that you provide us with to fulfill our legal obligations. This type of processing is necessary for us to comply with the law. The following types of personal data may be processed:
Your personal number;Contact information such as name, date of birth, address, email address, phone number;Official documents such as passport or ID, these may include a photo of you;Communication history, for instance, your communication with our customer service through email or live chat;We may also process anonymized behavioural data and provide it to third party research organizations with the aim of preventing gambling-related issues; andOther information needed for us to comply with our legal obligations.We reserve the right to confirm your personal data without prior notice and without giving any reason. This is due to regulatory obligations that require us to confirm your identity and is done by collecting your personal number through a third party, unless you have provided it yourself. You have the right to oppose such verification.

2.2. Information necessary for you to be able to use our services
We may process information that we need in order to provide you with our services. Our lawful basis for the processing of this personal data is to fulfill our contract with you regarding the delivery of our services. The following types of personal data may be processed:
Username, IP address, browser type, demographic information and geo-location information from your device and/or hardware, referring/exit pages, and operating system;Device ID, installed software, cookies and in-game information;Financial information and billing information such as credit card number, name of credit card holder, expiry date on credit card, billing address, bank name and bank account number; andOther information needed to deliver our services.

2.3. Information used for marketing
We may also process information in order to provide marketing material. Our lawful basis for the processing of this personal data is our legitimate interest in marketing our products and services for the pursuit of our commercial and business objectives. The processing will not take place in a way that violates your personal rights or freedoms.


3. Information sharing
We may share your personal data with other companies that are within the same group as ComeOn!, with companies that provide services to you on our behalf, help us deliver our services and/or help us with our business operations and with other parties in the course of complying with our legal obligations. Furthermore, we may share personal data if we enter any kind of merger, acquisition or business sale, as customers’ personal data generally is included in the sale or transfer. In this case, you will be notified via email and/or through a clear announcement on our website. We have a contractual relationship with all of these companies to ensure that your personal data is always treated as confidential, protected with appropriate security measures and prevents these companies from using your personal data for their own purposes.

3.1. Sharing your personal data within the group
We may share your personal data within the group for the following purposes:
Offer you customer support and respond to your questions and complaints;Crime detection, prevention and prosecution;To fulfill our legal obligations to the licensing and regulatory authorities, as well as to fulfill our obligations in accordance with applicable legislation and relevant authorities in other jurisdictions;In order to establish, exercise or defend our legal rights;When we believe, in good faith, that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or obey an authority request;Enable us to provide help and support for gambling issues and addiction;Provide you with secure access to our online platform and maintenance of our website;Respond to your subject access requests and answer your GDPR related questions;If it has been preceded by your consent, or if we deem it reasonable and necessary. In this case, the lawful basis for the processing is legitimate interest and the processing will not take place in a way that violates your personal rights or freedoms;Evaluating and analyzing marketing strategies and trends and marketing research and training.Administrate offers and promotions; andAdministrate payments and handle payment related queries.

3.2. Sharing your personal data with third parties
We may share your personal data with third parties for the following purposes:
Provide you with products and/or servicesWhen required by law, such as following a court order or similar legal process;To fulfill our legal obligations to the licensing and regulatory authorities, as well as to fulfill our obligations in accordance with applicable legislation and relevant authorities in other jurisdictions;When we believe, in good faith, that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or obey an authority request;In order to establish, exercise or defend our legal rights;To provide you with our services;With external auditors;When we work with third party organizations to identify cases of match-fixing;If it has been preceded by your consent, or if we deem it reasonable and necessary. In this case, the lawful basis for the processing is legitimate interest and the processing will not take place in a way that violates your personal rights or freedoms; andIn some cases, we are legally required to verify your identity with the help of third party vendors with whom we share your personal data and obtain personal data from. We are entitled to form decisions based on the information supplied from these service providers. This sharing of personal data may involve transfers of personal data to countries outside of the EU/EEA. We use Transunion for sanction lists and similar checks. If you would like to know more about how your personal data is processed by Transunion please visit their privacy policy here.

4. Transfers of personal data outside the EU
Your personal data may be disclosed to countries outside the EU/EEA. In these cases, we take all reasonable legal, technical and organizational measures to ensure that the level of protection for your personal data is at the same level as in the EU/EEA. This is done by, among other things, using standard contractual clauses or binding corporate rules. We only enter into contractual relationships with third parties that guarantee a comparable standard of data protection to EU/EEA countries.

5. Miscellaneous
5.1. Social media
If you choose to communicate via social media, the information you provide is linked to your personal social media account. These social media platforms have their own privacy policies, you must contact them directly in order to exercise your rights or request the deletion of communication between you and us on the platform in question.

5.2 Links to other websites
Our service has links to other websites, these websites may have privacy practices that differ from ours. If you submit personal data to any of these sites, your information will be governed by their privacy policy. We encourage you to carefully read the privacy policy on all websites you visit.

5.3. Surveys and competitions
We may periodically offer you the opportunity to participate in competitions or surveys on our website. If you participate, we may, in some cases, ask you for certain personal data. Participation in these surveys or competitions is completely voluntary and it is up to you if you choose to disclose any personal data.

6. Data retention
We store your personal data for as long as we need it to fulfill the purpose of the processing, or for as long as we have to store the data according to the law. When your personal data is no longer needed to fulfill the purpose or when the statutory time has passed, we will delete your personal data. However, we may process personal data for statistical purposes. In these cases, we anonymize the data, which means that the information can no longer be linked to you.

7. Security
We aim to achieve the highest possible level of security and privacy and we take the security of your personal data seriously. For us, it is very important that you feel secure in our processing of your personal data and we take appropriate measures to protect your personal data from unauthorized access or other undue processing. To achieve a high level of security, we apply appropriate organizational, technical and physical measures.

8. Your rights

You have the following rights with respect to the processing of your personal data:

  • Right of access: you can request to know if we are processing personal data relating to you and request a copy thereof.
  • Right to rectification: you can request to have your personal data corrected. The easiest way to do this is to make the necessary changes in the “My Account” section;;
  • Right to object: you can object to our processing of your personal data.
  • Right to restriction of processing: you may, in some cases, request a restriction on the processing of your personal data.
  • Right to withdraw your consent in cases where we process your personal data based on your consent;
  • Right to data portability: you can request that we transfer your personal data to another data controller. You will then receive your personal data in a structured, commonly used and machine-readable format.
  • Right to erasure: you can request that we delete your personal data. Although you have the right to have your personal data deleted, in some cases we cannot delete the data in its entirety, due to legal requirements to retain certain personal data for a specific period.
  • Right to lodge a complaint with a supervisory authority.

9. Notification of privacy policy changes
We may update this privacy policy to reflect changes to our information practices. If we make significant changes that will significantly affect any of your rights, we will notify you or announce this on our website before the changes take effect. However, we encourage you to periodically review this policy for the latest information regarding our privacy practices.

10. Contact details
If you have any questions about this privacy policy or would like to contact us regarding how we process your personal data, please write to us at: Co-Gaming Limited Attn: Data Protection Officer 3rd Floor, Spinola Park, Triq Mikiel Ang Borg St. Julians, SPK1000 Malta.

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