Privacy Policy
Version 1.1 - Last updated the 25th of February 2021
1. Introduction
Infiton Limited (the “Company”) is a company incorporated in Malta, bearing registration number C-80823 and having its registered address at 206, Wisely House, Old Bakery Street, Valletta, Malta. This Privacy Policy is intended to provide you with information on the personal data that is collected about you, and the manners in which and the purposes for which it shall be processed.
By accepting this Privacy Policy, you confirm that you understand and accept the use of your personal information as set out herein. If you do not agree with the terms of this Privacy Policy, please do not use the website or otherwise provide us with your personal information.
2. What data do we process about you and why?
The table below outlines the personal data that Infiton Limited holds about a player (Personal Data); the source from which said data has originated (Source); the purpose for which said data is collected and processed (Purpose of Processing); the basis upon which Infiton Limited is permitted to process said data for the established purpose (Lawful Basis for Processing). Where legitimate interests are quoted as the lawful basis for processing, an explanation of same is also provided (Legitimate Interests).
| Personal Data | Source | Purpose of Processing | Lawful Basis for Processing | Legitimate Interest | Essential to Provision of Service |
|---|---|---|---|---|---|
| Registration Details (name, surname, CPR number, date of birth, place of birth, residential address, telephone number, email address, IP address, gender) | Derived from Data Subject | Identification of player; verification of identity and address; prevention and detection of fraud; prevention of money laundering and terrorist funding; ensuring responsible gambling; offering customer support services; effecting payment of withdrawals; providing remote gaming services. | Performance of contract, legal obligations, legitimate interest | Prevention of fraud | Yes |
| Contact details (email address, telephone number) | Derived from Data Subject | Engaging in correspondence with player; notifying player of news, updates and information about the services, campaigns and/or bonuses of our brands; providing marketing material. | Performance of contract & consent | - | Yes |
| Identification Documentation (identity card / passport / driving license / utility bill / bank statement / other documentation) | Derived from Data Subject | Identification of player; verification of identity and address; prevention and detection of fraud; prevention of money laundering and terrorist funding; ensuring responsible gambling. | Legal obligation & Legitimate interest | Prevention of fraud | Yes |
| Player behaviour (transactional and gaming behaviour, geo-location, device information) | Derived from Data Subject | Prevention of money laundering and funding of terrorism; prevention of fraud; ensuring responsible gambling; improvement of quality of service; customer recommendations. | Legal obligation; legitimate interest; consent | Prevention of fraud | Partially |
3. Who do we share your data with?
Throughout the course of its relationship with the player and thereafter, Infiton Limited may be required to transfer personal data of the player to third parties. The below table provides information on said transfers, namely: the personal data of the player that is being transferred (Personal Data); the type of third party which shall receive the personal data (Recipient); the purpose for which the third party shall process the data (Purpose of Processing); and the location where the data shall be processed by the third party (Location). In each of these scenarios Infiton Limited undertakes to bind said recipients to process and use the personal data in line with the provisions of the General Data Protection Regulation and the provisions of Infiton Limited’s Privacy Policy.
| Personal Data | Recipient | Purpose of Processing | Location |
|---|---|---|---|
| Registration Details; Identification Documentation; Financial Transactions; Gaming Transactions; General information about the Player’s account held with Infiton Limited | Regulatory Authorities | Compliance matters related to Infiton Limited’s remote gaming licenses | Within the EU |
| Registration Details; Identification Documentation; Financial Transactions; Gaming Transactions; General information about the Player’s account held with Infiton Limited | Financial Intelligence Authorities | Prevention of money laundering and funding of terrorism; general compliance matters related to Infiton Limited’s business activities insofar as these render Infiton Limited to be considered an obliged entity under Directive 2015/849 of the European Parliament and of the Council (AML Directive), as this may be amended from time to time | Within the EU |
| Registration Details; Identification Documentation; Financial Transactions; Gaming Transactions; General information about the Player’s account held with Infiton Limited | Enforcement Agencies | Investigation of fraud, identity theft and other related and/or similar offences by local and international Police and other enforcement agencies. | Within the EU |
| Registration Details; Identification Documentation; Financial Transactions; Gaming Transactions. | Gaming Platform Providers | Hosting and storage of data on behalf of Infiton Limited. | Within the EU |
| Registration Details; Identification Documentation. | Data Verification Providers | Prevention of money laundering and funding of terrorism; general compliance matters related to Infiton Limited’s business activities insofar as these render Infiton Limited to be considered an obliged entity under Directive 2015/849 of the European Parliament and of the Council (AML Directive), as this may be amended from time to time. | Within the EU |
| Registration Details; Identification Documentation. | Third Party Tool Providers | Provision of customer support tool to Infiton Limited | Within the EU |
4.How long do we store your data for?
In line with the principles of data protection, Infiton Limited undertakes to retain personal data of players only for as long as is necessary. Therefore, upon completing a process, Infiton Limited shall delete the data required for that specific process, save in the following cases:
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Where the same data is required for other data processes for which a lawful basis for processing exists; and/or
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Where the data is required to be retained by the company in line with legal obligations to which it is subject, including but not limited to, legislation and/or regulations relating to remote gaming, responsible gaming, anti-money laundering and counter-terrorist funding, taxation, company and corporate matters. In light of this, certain personal data may be retained and used by Infiton Limited even after the closure of the player’s account.
5. What are your rights?
(i) Rights of access and data portability – The player may obtain a copy of the personal data held by Infiton Limited about him/her at any time by accessing the My Account section after logging in. In the event that further information should be required, a Subject Access Request may be made via email to the company’s Data Protection Officer at [email protected] Furthermore, the Player may request that certain categories of his/her data are transferred to third parties by Infiton Limited.
(ii) Right of rectification - In the event that the data held about a player by Infiton Limited is inaccurate, incomplete or outdated, you may rectify said data by accessing the My Account section after logging in. Certain verification requirements may apply for the completion of a rectification request. Please bear in mind that in line with the provisions of the company’s terms and conditions, it is also your obligation to ensure that all your data provided to Infiton Limited is retained up-to-date and accurate.
(iii) Right of erasure – The Player may at any time request that Infiton Limited erases data held about him/her by sending an email to the Data Protection Officer on [email protected]. Infiton Limited shall ensure that such personal data is, upon request and when not required for purposes outlined in the Data Retention section above, deleted. Players are however advised that with the deletion of their personal data, the quality of their user-experience on the Website may be diminished. This right is further subject to mandatory retention periods under EU/local laws. Therefore, there may be instances where the company will not be in a position to delete your data owing to certain legal obligations.
(iv) Right to restriction of processing, objection to processing and withdrawal of consent – The player may at any time request that Infiton Limited restricts or ceases to conduct certain data processes and Infiton Limited shall accede to that request, provided that there exists no other lawful basis on which Infiton Limited is authorized or required to process said data. Likewise, with respect to any data processes which are conducted by Infiton Limited on the basis of consent given by the player, the player may at any time withdraw said consent by sending an email to the Data Protection Officer on [email protected]. Please bear in mind that the withdrawal of consent shall not affect the lawfulness of any data processing that would have taken place prior to said withdrawal.
(v) Right to lodge a complaint – In the event that the player is not satisfied with the manner in which Infiton Limited has handled a request or generally with the manner in which Infiton Limited handles data protection related issues, the player has the right to file a complaint to the relevant supervisory authority. Complaints may be filed with the Office of the Information and Data Protection Commissioner in Malta via www.idpc.org.mt or from your country’s data protection regulator.
6. Security
Cerberus Technology Limited ensures that the information collected is in line with this Privacy Policy and highest data protection standards. After logging in all information sent to and from the Casino999 website is encrypted using 128-bit Secure Socket Layer (SSL) technology.
7. Other Information
Infiton Limited performs certain automated decisions based on player behaviour for the improvement of the services provided, for instance by providing recommendations of games and other services.
For any specific questions about your personal data, please contact our Data Protection Officer directly by email ([email protected]).
