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Privacy Policy
Version 1.0
December 2019

Swintt Malta LTD hereinafter also referred to as “the Operator”, “the Data Controller” or “We”.

The purpose of this Privacy Policy is to provide you with clear information on the processing of your personal information through our Website under the General Data Protection Regulation (GDPR) (EU 2016/679). This Privacy Policy describes how we use your personal data. By accepting this Privacy Policy, you agree that you understand and accept the use of your personal information as set out in this policy. 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.

We may periodically make changes to this Privacy Policy and will notify you of these changes by posting the modified Policy on the Website. We may also inform you personally of any significant changes to this Privacy Policy. You are encouraged to regularly examine this Privacy Policy for up-to-date information on the processing of your Data.

Why we process your Player Data

Whenever we process your personal data, we do so on the basis of a lawful “justification” (or legal basis) for processing. In the majority of cases, the processing of your personal data will be justified on one of the following bases:

” Fulfilment of services. To enable us to perform the services to you – to carry out our contractual obligations relating to you, to manage our relationship with you which will also include notifying you about changes to our service and changes to our terms or policies.

Legal basis: It is necessary for us to process your information to perform our obligations in accordance with any contract that we may have with you.

” Support services. To enable us to respond to your requests in accordance with the content of your request.

Legal basis: It is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best client service we can to you or others.

” Marketing communications. To provide news and information services including e-mail briefings and newsletters.

Legal basis: Your explicit consent. We will only send you marketing communications where you have consented and expressed a preference to receive such marketing communications, where it is appropriate and relevant to our business relationship with you, or where we have other lawful right to do so. Users can always easily withdraw their consent from receiving e-newsletters and commercial communications in the following ways:

– By clicking on the ‘unsubscribe’ link in any of such email;

– By contacting us via hello@swintt.com

” User insight and analysis. To collect insights into how you interact with our services so that we can personalise our communications with you and maintain and improve our websites and services.

Legal basis: Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information in such a way to ensure that we deliver our Website and online services to you and our other clients effectively. Where lawfully required, we may also process your personal information in accordance with your consent to the processing.

” Compliance with legal obligations. To comply with legal and regulatory obligations to which we are a subject.

Legal basis: It is our legal obligation to do so.

How we collect Player Data

We will collect various types of personal data about you for the purposes described in this Privacy Policy, including:

” Direct interactions: You may give us your personal data by filling-in forms or by corresponding with us directly or by post, phone, email, Website or otherwise.

” Automated interactions: As you interact with our Website, we may automatically collect some data as described herein.

” Personal data that may be contained in communications you send to us.

You are under no obligation to provide any such information. Providing your personal data to us is necessary for our communication with you and for receiving Newsletter (if you choose to subscribe to receiving it). Disclosure of personal data is obligatory only if such disclosure is required by law.

You are under no obligation to provide us with data we need for the provision of requested services, however if you fail to provide these data we will not be able to execute services you requested.

Data retention

We do not keep your personal data for any longer than is necessary to fulfil the purpose for which we collected it, or to comply with any legal, regulatory or reporting obligations or to assert or defend against legal claims.

In some circumstances, certain personal data can be removed on your request. Also, note that due to technical limitations, the data may not be removed instantly. Please contact us for further information.

Who we share your Personal Data with

Generally, no Personal Data will be sold or given or shared with any person or corporation other than with the a 3rd Party Provider that is only used to process our data.

We may also share your personal data with other third parties in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our shares and/or assets or other corporate change.

Some of the parties we share your personal data with may be located outside the European Union or the European Economic Area. Whenever we transfer your data outside the European Union or the European Economic Area, we do so in accordance with the applicable legislation. As a license requirement we store the gaming data under the license granted by the Government of Malta on a server located in Malta. We use appropriate safeguards to ensure that sufficient level of data protection is maintained. Such safeguards may include e.g. the use of model contractual clauses adopted by the EU Commission.

Security Measures

We place great importance on the security of all personal data associated with our users. We have adopted security measures to protect personal data against accidental or unlawful destruction, accidental loss, alteration, unauthorized disclosure or access. For the best possible protection of your personal data outside the limits of our control, your device should be protected (such as by updated antivirus systems) and your internet service provider should take appropriate measures for the security of network data transmission (such as, for example, firewalls and anti-spam filtering).

While we take reasonable steps to protect your personal data, we cannot guarantee that the personal data you disclose to us will be 100% secure, nor that any data breach will not occur.

You accept the inherent security implications of dealing on-line over the Internet and will not hold Swintt or their processors responsible for any data breach unless it is due to our negligence.

Cookies

Cookies are small files of Data which are stored on your computer. On your first visit to the Website a piece of Personal Data called a cookie will be sent to your browser for the purpose of tracking your navigation patterns. You can disable cookies by changing your browser settings. However, please note that the functionality of our website will be impaired.

Other linked websites

Where there is a link from the Website to another relevant site, this Privacy Policy will not apply once you leave this site.

Your rights

Where the legal basis for processing your personal information is your consent, you have the right to withdraw that consent at any time. You can exercise this right by contacting us on: hello@swintt.com, by clicking on the “unsubscribe” button on our marketing emails or by choosing a similar opt-out option that we may provide for you to exercise your right to object to the processing of your personal data.

Your other rights

You have the right to obtain information of the personal data collected for processing, and a right to obtain a copy of such data. You are also entitled to have any such personal data that is inaccurate, outdated, unnecessary or contrary to the purposes of data processing corrected or erased.

You are also entitled to have us restrict the processing of your personal data for example when you are waiting for our response to your access or erasure request.

You have the right to receive the personal data concerning you, which you have provided to us, in a machine-readable format, and have the right to transmit those data to another controller.

If you suspect that we do not follow the applicable data protection regulations, you have the right to lodge a complaint with competent data protection authority.

You can easily withdraw your consent and modify the channels used for promotional messages at any by contacting us.

We may update this policy from time to time, so please review it frequently.

The Data Controller’s contact details:

Swintt Malta LTD (company no. C 91649)
Forth Mansions, Seafront Ix-Xatt Ta’Xbiex,
Ta’Xbiex, TXT1026