Privacy Notice

Date: 22nd August 2024

This Privacy Notice sets out the way in which Swintt (‘’we’’ or ‘’us’’), a company incorporated and registered in Malta, collects and processes personal information as underlined in paragraph 2.1 below.

Depending on the context of personal information you provide, Swintt Malta Ltd may be the data controller ("controller") or data processor ("processor") of your personal information under this Notice.

We shall only process your Personal information in accordance with this Privacy Notice.

1. What is the Purpose of this Privacy Policy?

The purpose of this Privacy Notice is to inform you about the methods and purposes for which your personal information is processed, as well as to inform you about the rights you have regarding the processing. By accepting this Privacy Notice, you agree that you understand and accept the use of your Personal information as set out in this Notice. If you do not agree with the terms of this Privacy Notice and/or wish to provide your Personal information please do not use the Website, or otherwise provide us with your Personal information.

By using our website, you acknowledge Swintt will process your Personal information in accordance with this Privacy Notice.

Swintt may periodically make changes to this Privacy Notice, and we will post the modified terms on the Website. Swintt may also inform you personally of any significant changes to this Privacy Notice. You are encouraged to regularly examine this Privacy Notice for up-to-date information on the processing of personal information.

2. What Information Do We Collect from You?

The Personal information that you provide us: For example, when you send us an email or a message on social media with any Personal information that you choose to send. We would process the data for the purposes of contacting you/providing support and information service. The legal basis for this processing is your explicit consent.

The Personal information that you are requested to provide: For example, in the ‘Swintt Client Area’ you will be requested to enter certain details to be able to register your account, this includes name, surname, email and company, we would process the data for the purposes of contacting you/providing support and information service. The legal basis for this processing is your explicit consent.
By means of the ‘Client Area’ - Personal information is required to create an account (name, surname, email address).
When using our services to connect to databases (this also includes third party databases) we may obtain the personal information which you enter to create the account into the Platform. In the case of the Client Area, First Look Games acts as the controller of the above mentioned personal information whilst Swintt acts as a processor.
Swintt’s client area are housed on separate, secure servers of First Look Games, located in the UK. For more information on First Look Games, kindly refer to their privacy policy irstlookgames.com/privacy-policy/.

First Look Games determine the means and purposes of the processing activities which involve your Personal information. The sharing of Personal information via the Client Area is within your control and if you do not want us or First Look Games to obtain your name, surname, email address we kindly advise you not to include these details in the Client Area.

For Marketing purposes by means of the Client Area (Business Partners only): To provide Marketing, Swintt will require your email address for correspondence, updates, marketing news and service news. The legal basis for this processing is your explicit consent and this is collected when signing up to the client area.

By means of the ‘B2B Platform’: Personal information which is depicted on the B2B Platform illustrate the player details. This constitutes the following Personal information: IP address, player country, player jurisdiction, player currency ID which is sent to us by the client i.e (the ‘Operator’)
The Personal information outlined above is processed by Swintt when the data subject plays any of our games via the Operator’s website. In the processing of this Personal information, Swintt acts as a processor and the Operator acts as the controller. If you are a customer of the Operator we kindly ask you to address your queries relating to Data Protection to the relevant Operator as they determine the means and purposes of the processing activities which involve your Personal information.

We may process any of your personal information for the establishment, exercise, or defence of legal claims. We process the data for the purpose of exercising and defending legal claims.

Kindly be informed that we only use your personal information for the purposes of which it has been obtained, as underlined in this privacy notice.

3. Do we collect Information from third parties?

No, we do not use information from any third-party service providers.

4. How Do We Use Your Personal Information?

Your Personal information is processed in accordance with the General Data Protection Regulation (Regulation (EU) 2016/679) and any other applicable data protection laws.

5. Who Do We Share Your Personal Information With?

Generally, no Personal information will be sold or given or shared with any person or corporation other:

any company within the Group which assist Swintt in fulfilling the stated purposes or on a need-to-know basis.

whenever we have a legal obligation to do so, we may also share your personal information with any regulatory body, any authority, any law enforcement.

We may also share your personal information 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.

6. For how long do we keep your Personal information?

All your personal information is not kept longer than is necessary for the stated purposes. For more information kindly send us an email at compliance@swintt.com.

7. Security Measures

Swintt endeavours to maintain strict security measures (which includes physical, technical and administrative safeguards) on the Website and its associated sites, so that no unauthorized disclosure, use, loss and/or alteration of data can be done.

We update and test our security technology on an ongoing basis. We restrict access to your personal information to those employees who need to know that information to provide benefits or services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information.

8. What are your rights?

You have the right to object at any time to the processing of your personal information to direct marketing. When using your right to object, you are required to define the particular situation based on which you are objecting the data processing.

You have the right to withdraw your consent to the processing of your personal information.

You have the right to obtain information of the personal information collected for processing, and a right to obtain a copy of such data in a machine-readable format.

You are also entitled to have any such personal information 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 information for example when you contest the accuracy of the data, when the data is processed unlawfully or when you think that we no longer need to process your data.

You have the right to port your data to another organization.

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

We may update this Privacy Notice from time to time by publishing another updated version on our website. We kindly ask you to check this page occasionally.

9. How to Contact us

COMPANY NAME: Swintt Malta Ltd (C91649)

ADDRESS:

LEVEL 8, THE CENTRE, TIGNE POINT,
SLIEMA
TP0 001
Malta

Data protection officer email address: compliance@swintt.com

10. Filing a complaint with the supervisory authority

You have the right to make a complaint at any time to a supervisory authority.

The Information and Data Protection Commissioner (IDPC) in Malta is the Lead Supervisory Authority:

Floor 2, Airways House
Triq Il-Kbira,
Tas-Sliema SLM 1549,
Malta

Telephone number: +356 2328 7100

Email address: idpc.info@idpc.org.mt