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Privacy Policy

Last revised: July, 22nd, 2022

INTRODUCTION

Aspire Global International LTD, which includes all of the entities specified below under “The Group” section, including its affiliates (collectively, the (“Company”) offers online gambling services (collectively, the Services via:

  • Its own in-house brands (each, an “In-House Brand”; together with the Company: “Group”, “we”, “our” or “us”), and
  • MrLuck as third party brands and their respective affiliates (each, “White Label Brand”).

The Group is deeply committed to safeguard the privacy expectations of its users (“User(s)”, “you” or “your”). Accordingly, we have put in place this Privacy Policy, which outlines our data protection practices, including how we collect, use, disclose and protect your Personal Information, as well as your rights with respect to your Personal Information.

In this Privacy Policy you will read about:

  1. THE GROUP
  2. WHAT INFORMATION WE COLLECT?
  3. MINORS
  4. CONDITIONS FOR PROCESSING OF PERSONAL INFORMATION
  5. HOW WE USE THE COLLECTED INFORMATION?
  6. MARKETING
  7. WITH WHOM WE SHARE INFORMATION?
  8. INTERNATIONAL TRANSFER OF INFORMATION
  9. THIRD PARTY TRACKING TECHNOLOGIES
  10. THIRD PARTY SERVICES
  11. RETENTION OF PERSONAL INFORMATION
  12. YOUR RIGHTS
  13. HOW WE KEEP YOUR INFORMATION SECURED
  14. CHANGES TO THE PRIVACY POLICY
  15. HOW TO CONTACT US
  16. COOKIE POLICY

We encourage you to read the Casino MrLuck Privacy Policy carefully and use it to make informed decisions. By visiting the Group’s websites, mobile apps or other online properties, or by creating an account through our Services, you hereby agree to the Privacy Policy.

THE GROUP

The Group provides the Services through the following applications and platforms (collectively “Platforms”):

  • Internet websites;
  • Downloadable applications and software (“Software”), such as native applications which are distributed through mobile application stores and PC and Mac desktop software which can be downloaded to your computer;
  • Non-downloadable online applications (e.g. flash applications, HTML5 applications, etc.);
  • Facebook applications; and
  • White Label Brands.

WHAT INFORMATION WE COLLECT?

We collect two types of information from our Users:

1. Personal Information

The first type of information is information that identifies or may reasonably identify an individual reasonable effort (“Personal Information”). Personal Information which is being gathered may consist of the following:

  • Registration details: When you open an account and register to use the Services, you will be asked to provide us certain details about yourself, such as: first and last name, email address, gender, birth data, physical address, ID number, phone number, occupation, etc.
  • Governmental-issued ID: In certain instances, you will be required to provide a copy of a governmental-issued ID, for identity verification process. Please note that this information is required for certain features of our Services.
  • Payment information: In order for you to enjoy all of the functions of the Services (e.g. place bets, perform purchases, play in tournaments, etc.), payment information will be collected from you, such as your debit card number and bank account details.
  • Voluntary information: We also collect information which you provide us voluntarily. For example, when you respond to communications from us, communicate with us via email or share additional information about yourself through your use of the Services, such as on the chat feature and in games.
  • Device information: We collect specific types of connection details and information with regard to your device, software or hardware that may identify you, such as: device’s unique identifiers (e.g. UDID, IMEI, MAC address), browser fingerprinting, IP address and geo-location data.
  • Telephone calls: We record or monitor telephone calls for customer support, training and/or security purposes.
  • Social networks: When you register through your social network account (such as your Facebook account), to use the Services or connect your player account with such account, we will have access to basic information from your social network account, such as your name, birthdate, profile picture and friends’ list, as well as information you made publicly available on such account.
  • In addition, when using the Services, you may be able via your social network to “Invite a Friend” to use the Services. Should the person accept your invitation, we may obtain Personal Information from him/her such as: name, email address, phone number and date of birth.
  • Feedback, reviews and testimonials: We also collect and display personal testimonials, reviews and feedback of satisfied Users on the Services in addition to other endorsements. With your consent, we may post your testimonial along with your name, on the Services.
  • Information we collect from third parties: We collect Personal Information from third party service providers, such as information about your credit history from credit agencies and other financial information which is relevant to the provision of the Services, as well as information which is gathered in order to verify your identity and prevent fraudulent or illegal activity.

2. Non-personal information

The second type of information is un-identified and non-identifiable information pertaining to a User(s), which may be made available or gathered via the User’s use of the Services (“Non-Personal Information”).

Non-Personal Information which is being collected consists of technical information and aggregated usage information, and may contain, among other things, the User’s operating system, type of browser, screen resolution, browser and keyboard language, the User’s ‘click-stream’ and activities on the Services, the period of time the User visited the Services and related time stamps, etc.

For avoidance of doubt, any Non-personal Information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection or linkage exists.

Types of Non-personal Information we collect from or about you:

  • Technical information: In order to enhance the functionality of the Services and to provide you with a better user experience, we collect technical information transmitted by your device, including certain software and hardware information.
  • Gameplay information: We record game play information including, amongst other things, your deposits, bets, bonuses, game session duration and your high scores.
  • Device and connection information: If you download the Software to your device, we may collect information from the particular device you are using, for security and fraud detection and prevention purposes.
  • Analytics information: We collect information about your use of the Services, such as applications’ usage, log files, user activity, time stamps, alerts, etc.
  • Anonymous information: We may anonymize or de-identify the information collected by the Services so that the information cannot, on its own, personally identify you.

MINORS

The Services are not designed or directed to persons under the age of 18 or persons under the age of legal consent with respect to the use of the Services of any jurisdiction, whichever is higher (“Legally of Age”). If you are not Legally of Age, you should not download or use the Services nor provide any Personal Information to us.

We reserve the right to access and verify any Personal Information collected from you. In the event that we become aware that a user who is not Legally of Age has shared any information, we may discard such information.

CONDITIONS FOR PROCESSING OF PERSONAL INFORMATION

We will process your Personal Information for a variety of reasons, each of which is prescribed by relevant data protection laws.

  • Fulfillment of a contract, compliance with a legal obligation: It is necessary for us to process your Personal Information where it is necessary for the performance of a contract or in order for us to comply with our various legal and/or regulatory responsibilities.
  • Legitimate interests: We also process your Personal Information where we deem such processing to be in our (or a third party’s) legitimate interests, such as for internal administrative purposes, ensuring network security, and combatting fraudulent activities.
  • Consent: On certain occasions we may ask for your consent to processing Personal Information. You will be able to withdraw this consent in writing at any time.
  • Special Categories of Personal Data: Our processing may involve special categories of personal data, such as racial or ethnic origin (as defined under Article 9 of the GDPR), where necessary for the prevention of unlawful acts or safeguarding economic well-being.

HOW WE USE THE COLLECTED INFORMATION?

We use your Personal Information for the purposes listed below:

  • To set up, manage and update your account;
  • To provide and operate the Services (such as for betting and payment processing);
  • To communicate with you and keep you informed of updates;
  • To market our Services and serve behavioral advertisements;
  • To promote our Services by displaying Users’ testimonials;
  • To conduct analytics, statistical and research purposes;
  • For Customer Relationship Management and troubleshooting;
  • To provide you with a responsible gaming environment;
  • To identify and authenticate your access;
  • To detect and prevent fraudulent and illegal activity;
  • As required by law or regulation (such as KYC and AML requirements).

MARKETING

The Group will use your Personal Information (name, address, email, etc.) to provide you with promotional materials concerning the Services, White Label Brands, or Group business partners. We believe these may interest you.

You may at any time decline receiving further marketing offers by contacting us. Please note that even if you unsubscribe, we may continue to send you service-related updates and notifications.

WITH WHOM WE SHARE INFORMATION?

We do not rent, sell, or share your Personal Information with third parties (“Recipients”) except as described in this Privacy Policy. Recipients include:

  • White Label Brands and their service providers;
  • Companies within the Group and affiliated companies;
  • Subcontractors and third-party service providers (cloud computing, identity verification, etc.);
  • Credit reporting agencies;
  • Payment service providers, processors, and banks.

INTERNATIONAL TRANSFER OF INFORMATION

Since we operate globally, it may be necessary to transfer your Personal Information to countries outside the European Union. The data protection and other laws of these countries may not be as comprehensive as those in the European Union.

We use best efforts to ensure that your Personal Information is protected in accordance with our Privacy Policy, through contractual means (such as by using the standard contractual clauses approved by the relevant European Commission for data transfer) or other means (such as ensuring that the jurisdiction imposes adequate safeguards for data protection).

THIRD PARTY TRACKING TECHNOLOGIES

When you visit or access our Services (for example when you visit our websites), we use (and authorize third parties to use) web beacons, cookies, pixel tags, scripts, tags and other technologies (“Tracking Technologies”).

The Tracking Technologies allow us to automatically collect information about you and your online behavior, as well as your device (for example your computer or mobile device), in order to enhance your navigation on our Services, improve our Services’ performance and customize your experience on our Services.

THIRD PARTY SERVICES

While using the Services you may encounter links to third party websites, services or applications. Please keep in mind that this Privacy Policy does not apply to any third party websites, services or applications, even if they are accessible, downloadable, or otherwise distributed through the Services.

We are not responsible for the privacy practices or the content of such third parties. Please be advised that such third party websites, services or applications may collect Personal Information from you. Accordingly, we encourage you to read the privacy policies of each and every third party website, service or application you choose to use.

RETENTION OF PERSONAL INFORMATION

If you have registered with an account through our Services, the Group will retain your Personal Information during the period your account is active. In addition, the Group will retain your Personal Information for additional periods, as necessary to enable the Group to meet its legal obligations under applicable laws or regulations, such as the applicable gambling regulations, KYC and AML regulations.

In addition, the Group may retain your Personal Information for longer periods, provided that retaining such information is necessary for the Group’s legitimate interests, such as fraud prevention and record keeping.

YOUR RIGHTS

You may contact us at any time by email and request:

  • To access or delete any Personal Information relating to you;
  • To change or update any Personal Information relating to you (for example, if you believe that your Personal Information is incorrect, you may ask to have it corrected or removed);
  • That we will restrict or cease any further use of your Personal Information;
  • That we will provide the Personal Information you volunteered to us in a machine-readable format.

Please note that these rights are not absolute and requests are subject to any applicable legal requirements, including gambling regulations and other legal and ethical reporting or document retention obligations.

HOW WE KEEP YOUR INFORMATION SECURED

We take great care in implementing and maintaining the security of the Services and your information. We have put in place appropriate physical and technological safeguards to help prevent unauthorized access, to maintain data security, and to use correctly the information we collect online.

These safeguards vary based on the sensitivity of the information that we collect and store. We employ industry standard procedures and controls to ensure the safety of our Users’ information, such as: secure network topology, which includes intrusion prevention and Firewall systems; encrypted communication; authentication and Access Control; and external and internal audit tests.

CHANGES TO THE PRIVACY POLICY

We reserve the right to change this Privacy Policy at any time, so please re-visit this page frequently. We will provide notice of substantial changes of this Privacy Policy on the Services and/or we will send you an email regarding such changes to the applicable email address that you provided to us. All changes to this Privacy Policy are effective as of the stated “Last revised” date, and your continued use of the Services after the Last revised date will constitute acceptance of, and agreement to be bound by, those changes.

HOW TO CONTACT US

If you have any general questions about the Services or the information that we collect about you and how we use it, please contact us via our customer support channels.

COOKIE POLICY

When you visit or access our Services, we use cookies to distinguish you from other users. This helps us to provide you with a good experience when you browse our Services and also allows us to improve our Services. For more detailed information on the cookies we use and the purposes for which we use them, please refer to our full Cookie Policy.

Cookies are used for ads personalisation, provide social media features, and analyze our traffic. With your consent, we may also share information about your use of our app with our social media, advertising, and analytics partners.