GANATUPARLEY S.R.L (hereinafter we) is committed to protecting the privacy of any personal information about you that you provide to us or that we collect (hereinafter Personal Information). Personal Information is information that identifies and/or relates to you, including your name, address, date of birth, payment card details, gaming history, account details, and other information we hold about you. We are the controller (also known as data controller) with respect to your Personal Information. Controller is a legal term and means that we are responsible for determining the purposes for which your Personal Information is processed. We ensure that your Personal Information is processed in compliance with the data protection laws and regulations of the countries in which we operate. Therefore, we set out in this Privacy Policy how we use your Personal Information. We may update this Privacy Policy from time to time, so we encourage you to regularly review this Privacy Policy. If we make any material changes to this Privacy Policy, we will notify you that the changes have been made.

• You will be asked to provide us with personal information for the purpose of registering and opening an account with us so that you can operate our website and mobile applications. You are not obliged to provide us with any personal information.
• However, certain personal information is essential for us to provide you with services (such as to enable you to play games on the website), and if you choose not to provide the information we request for these services, you may not be able to obtain certain services.
• We also collect information about the transaction, including details of the payment card used. We may collect personal information through surveys conducted by us or companies we engage for such purposes.
• In addition, we collect information about your use of our website, mobile applications and services. We also collect other information necessary for the processing of your personal information for the purposes described in this Privacy Policy.
• If you provide your name, address or other personal information in public areas of our website, we will also process this personal information.
• We may also collect personal information from third-party service providers, such as fraud prevention companies.
• Finally, we also use cookies that collect certain information, such as the IP address of your device, which constitutes personal information. For more information on cookies, please see the Cookies section below.

In accordance with data protection regulations, we only process your personal information when we have a legitimate interest in doing so. The basis for the processing of your personal information is as follows:

• (i) Where we need to provide you with services under the performance of a contract with you;
• (ii) Where we are required to process your personal information pursuant to a legal or regulatory obligation;
• (iii) Where the processing of your personal information is in the public interest;
• (iv) Where we have your consent;
• (v) Where the processing of your personal information is in our legitimate interests, provided that it is not prejudiced against your rights, freedoms and interests.

Below is a list of the purposes for which we process your personal information and the lawful basis for such processing Purposes:

• Set up and manage your account (including processing deposits and withdrawals)
• To provide our services (including enabling you to play our games)
• To receive and respond to your communications and enquiries
• Necessary for the performance of a contract, where the communications specifically relate to our services. otherwise with your consent or where it is in our legitimate interests
• To inform you about updates to our website, mobile applications and services
• To ensure we meet our regulatory obligations in relation to your use of our services (this may include verifying the accuracy of the information you provide to us and verifying your age, which may involve disclosing your personal information to third parties or supplementing it with information received from third parties (such as credit reference agencies) as necessary to comply with a legal or regulatory obligation
• To comply with our obligations under applicable law (including the Gambling Act, regulations and licensing requirements relating to our gambling licences), as necessary to comply with a legal or regulatory obligation
• To identify and disclose any suspected unlawful, fraudulent or other improper activity (including money laundering) in connection with our website, mobile applications and services, as necessary to comply with a legal or regulatory obligation
• To prevent or detect unlawful activity. and to protect the public from fraud, negligence or other serious misconduct. Necessary to comply with a legal or regulatory obligation or where there are substantial public interests.
• To carry out market research to better understand which products and services you enjoy most.

Where it is in our legitimate interests.

• To analyse how you and other players use our website, mobile applications and services and respond to promotions and advertising, and to identify relevant patterns and business trends, in order to improve our products and services and provide you with the offers and support that are most suitable for you. To build a personal profile of you and to better understand your preferences for products and services.
• To recommend relevant games and other gaming sites.
• To inform you of offers and promotions relating to our services.
• To inform you of offers and promotions relating to our services or other Group services, provided that we have obtained your consent.
• To serve you with advertising via social media, unless you have opted out of receiving such advertising via your social media accounts.
• To support all other purposes necessary for the performance of our contractual obligations or those obligations specifically stated at the time you provided your personal information
• To record calls and live chats with our customer service representatives and for training on improving our customer service, as well as for security and identity verification purposes.
• This is for customer support training: where it is in our legitimate interests, security and customer verification: necessary to comply with a legal or regulatory obligation
• To monitor your gambling patterns and identify any concerns about responsible gambling. This is necessary to comply with a legal or regulatory obligation
• To prevent you from using our websites, mobile applications and services, as requested by you. This is necessary to comply with a legal or regulatory obligation
• To honor any deposit, budget or loss preferences you may have set. This is necessary to comply with legal or regulatory obligations With your consent, to use your name, image, username or location for advertising and marketing

Cookies

• Necessary to operate our website or mobile application (e.g., to interact with the website or mobile application, recall your preferences as you navigate from page to page)
• To analyze your use of our website and monitor website visitors to continually improve our website and services, and to tailor our website to better suit you
• To track your movements around our site to understand how you navigate to and from our website and to effectuate commercial arrangements
• Necessary for legal compliance, including identifying multiple accounts, unauthorized logins and potential fraud. This is necessary to comply with legal or regulatory obligations
• Used for third-party marketing

We may also disclose your personal information to our processors to provide services on our behalf. Such processors will only process your personal information in accordance with this Privacy Policy, and we will enter into contracts with such processors to ensure that your personal information is kept secure. In addition, we may disclose your personal information to third party service providers involved in the operation of the website (such as credit reference agencies, fraud prevention agencies, payment processors, banks, financial institutions and other similar third parties). This processing is necessary for us and our third party service providers to comply with our legal and regulatory obligations (such as verifying identity, monitoring website activity, preventing money laundering, preventing illegal activity on our website and other actions necessary to meet our obligations).

We may also disclose your personal information in the following circumstances:

• If required by applicable law or regulation to a government, regulatory or enforcement agency
• To defend us in connection with legal or/and legal proceedings
• Where we are required to verify your identity, age and the accuracy of your registration details (including disclosure to third parties such as: financial institutions, and third-party referral agencies)
• If we choose to outsource the operation of the website to a third-party service provider, and/or
• To negotiate and carry out a corporate acquisition, divestiture, acquisition, merger, financing, investment, reorganization, sale, transfer, divestiture, disclosure of all or a portion of our business or assets, and other proceedings thereunder

Your personal information will be transferred to third-party data processing entities within the European Union and Asia. We will take reasonable steps to ensure that sufficient measures are in place to keep your personal information secure in accordance with this Privacy Policy.

We have implemented extensive technical and organizational measures to protect your personal information against loss, manipulation and unauthorized access. Security measures include, but are not limited to, digital and physical perimeter protection, asset management, access control, and operational security controls. We will use all reasonable efforts to keep your personal information safe at all times, but you should be aware that security cannot be guaranteed and shall not hold us liable unless your security is compromised due to our negligence.

We may use the services of third-party service providers to provide reliable marketing services. We take steps to ensure that our arrangements with these parties protect your privacy by ensuring that they strictly follow our instructions when processing your personal information.

Users of our website can choose whether and how they would like to receive marketing communications from us. We may use your personal information on our website to provide you with tailored offers. We may sometimes use cookies to understand your usage and online preferences and deliver tailored content to you. Please see above for more information on how cookies are used.

Marketing communications about the website may include the following:

• Information about new games and campaigns available to you on our website.
• Information about prizes and cash prizes from our loyalty programs, campaigns, etc.
• Information about other campaigns on our website.

You can choose to opt out of receiving marketing communications from our website at any time by following the steps below.

• Email marketing: use the unsubscribe link in any email we send you or change your preferences in the campaign settings page in your account.
• SMS marketing: use the unsubscribe code in any SMS we send you or change your preferences in the campaign settings page in your account.
• Telephone marketing: change your preferences in the campaign settings page in your account.
• Push notifications: disable push notifications on your device.

If you unsubscribe from receiving email, SMS and telephone marketing communications, your unsubscribe will take effect within 72 hours of your unsubscribe.

We may use the information you provide to place advertisements and customized information about our game sites on certain third-party social media platforms (hereinafter referred to as Social Media Sites) made available to us through their services, such as Facebook and Twitter. We do not control the operation of these social media sites or how they collect information. We encourage you to read their respective privacy policies to understand how these sites use your personal information.

We may periodically use Facebook advertising services to provide Facebook users with customized content on our Game Site. When you log in to Facebook, the customized content may be posted. To provide this customized content, Facebook may share with us information that you have chosen to make available, in accordance with your Facebook settings. You can learn more about how Facebook uses your information in Facebook Privacy Policy. We may also display customized ads on your Facebook account. If you no longer wish to receive customized ads through Facebook, you can manage your ad preferences through your Facebook account settings and choose what you want to see and don`t want to see. For more information on how to manage your Facebook ad preferences, please click here.

About Cookies: In this Privacy Policy, we use the term cookies to refer to cookies and similar technologies that store information (such as web beacons). A cookie is a simple text file that is stored on your computer or mobile (or other) device by a website server, and only that server can retrieve or read the contents of the cookie. Each cookie is unique to a user web browser. It contains anonymous information, such as a unique identifier, the name of the website, or a number.

Most websites and applications, including our website, use cookies to improve a visitor`s user experience by allowing the website or application to remember you, either for the duration of your visit (session cookies) or when you return (persistent cookies).

Cookies do many different jobs that improve your use of a website or application, such as letting you navigate between pages efficiently, storing your preferences, and improving your experience on the website. Cookies make your interaction with the website faster and easier. If a website or application does not use cookies, you would be considered a new visitor each time you navigate to another page on the website. Some websites, including our site and any mobile or device specific versions and related applications of this website (collectively referred to in the Cookies section as the Website), may also use cookies to target advertising and marketing messages to you, for example, based on your location or browsing habits.

Cookies can be first-party cookies, which are set by the website you are visiting, or third-party cookies, which are set by other websites whose content is posted on the page or application you are visiting. Our Cookies: We use several different cookies to recognise and track activity of each user to improve your experience on the website.

In addition, we use a number of third-party service providers who set cookies on our website to perform the services we provide to you. These services include, but are not limited to, helping to improve your use and experience of the website by tracking website activity and measuring the effectiveness of the website and evaluating the effectiveness of our marketing campaigns.

We and/or third parties may use cookies to collect or receive information from the website and use that information to serve advertisements on other websites.

What to do if you don`t want cookies to be set: Some users find the fact that websites store information on their computer or mobile (or other) device intrusive, especially when this information is stored and even used by third parties without the user`s knowledge. This is generally harmless, but you may not want to see, for example, advertisements targeted to your interests. If you prefer, you can block some or all cookies or delete cookies that have already been set, but you should be aware that if you do this, you may lose functionality of the website. Most online browsers automatically accept cookies, but you can restrict or block them by modifying your browser settings.