Introduction and contact details
The policy is designed to help you understand what data we collect, why we collect it, and how we use it in connection with you using our services. This is important; we hope you will take time to read it carefully.
Evoke Gaming Ltd is the data controller and thereby responsible for the processing of your personal data carried out by us or on our behalf. If you have any questions regarding the processing, you are welcome to contact our Data Protection Officer: firstname.lastname@example.org.
What personal data do we process?
Personal data is all information that may be associated with you as an individual. We process the following personal data during the customer relationship:
- Name, address, contact details, birth date and gender, customer ID.
- Documentation verifying your identity and address (e.g. ID card (incl. social security number) or similar, utility bills).
- Copy of credit card (excl. CVC code) and bank statement and another person’s credit card and contact details if such person’s credit card is connected to your account.
- Your transaction history (e.g. logins, gaming frequency, deposits, winnings, bonuses and games played, promotions and services you have taken part in – i.e. if you have received, read and acted on an email, sms or ad).
- Your correspondence with customer service (email, phone and/or chat conversations relating to any matters you have registered with our customer service).
- Data collected via social networks/media (provided that you have an open/public account/profile, i.e. not restricted your settings to private).
- Information about the device you are using (e.g. IP address, operating system and mac address).
For what purposes do we process your personal data?
We use the personal data listed above for the purpose of:
- Administrating and managing our customer relationship, i.e. providing our games and services to you.
- Providing various tools in order to enable you to control and monitor your gaming habits, e.g. setting deposit or loss limitations. We also check against self-excluding registers (whether applicable) if you have self-excluded.
- Carrying out operations relevant for your participation in the games or use of our services, e.g. providing our customer service function incl. assisting and following-up on matters discussed with customer service.
- Conducting know your customer investigations (e.g. verifying identity, age, address and if you are a politically exposed person) and other investigations during the customer relationship (e.g. an in case your accumulative withdrawals exceed a certain amount) for the purpose of preventing and mitigating fraud and complying with anti-money laundering legislation and applicable licence requirements (e.g. by verifying source of wealth, creating suspicious activity reports and disclosing such reports to relevant supervisory authorities).
- Sending you marketing material, e.g. information about new services and promotions that we believe you may find of interest based on promotions and services you have taken part in (e.g. if you have received, read and acted on an email, sms or ad).
- Customizing the marketing material and your website experience, e.g. by recommending relevant games/services and presenting you with targeted bonus offers and similar. Such customization is based on gaming history and promotions and services you have taken part in (e.g. if you have received, read and acted on an email, sms or ad).
- Performing statistical analysis in order to improve and develop our current games and services, and develop new and exciting features. When performing such analysis, we will mainly use data in an aggregated form.
- Providing you with service and assistance if you have queries regarding your use of our services.
Legal basis for our processing
Most of our processing performed for the purpose of administrating and managing the customer relationship, is necessary for our performance of the contract we have with you; i.e. the terms and conditions.
We also process your data when it is required by any licence or legislation we are subject to, e.g. anti-money laundering (AML) legislation, which require certain due-diligence procedures to ensure that we are not contributing to money laundering.
When communicating marketing material to you and performing statistical analysis, the processing is based on a balance of interest, which means that we have a legitimate interest of processing the data (i.e. a commercial interest in providing relevant marketing) and we do that in a way that does not interfere with your privacy. We have made our assessment with consideration of our established customer relationship and the fact that we only process a limited amount of data when customizing our offers and marketing activities (e.g. age, gaming frequency, website usage and transaction history).
If we were to perform any processing of data that would require your consent, we will obtain such consent from you in connection with the specific processing activity.
To whom do we disclose the personal data?
Your data may be shared within the Mr Green group for the purpose of developing and improving our games and services. It may also be disclosed to external parties providing services to the Mr Green group, e.g. IT/system support services and gaming providers. It may also be disclosed to third parties assisting in investigations (such as AML investigations) for the purpose of detecting and preventing fraud or other security or technical problems. We may also disclose your data to authorities, if required by law, regulation or administrative decisions.
If we transfer your data to external parties outside of the EU/EEA, we ensure that there is a legal basis for the transfer, e.g. by including the EU Commission’s standard contractual clauses for data transfers (which are available at the EU Commission’s website) in our agreements with the parties accessing personal data.
For how long do we store your personal data?
Due to gaming licence requirements, a majority of your data is stored as long as you are a customer at Evoke Gaming Ltd. In case you want to close your account, all data (such as what segment you belong to or other information generated for marketing purposes) is erased unless it is required by legislation or licence requirements that we retain the data. In that case, such data will be stored as long as required by such legislation and/or licence requirement (e.g. 5 years after the customer relationship has ended according to our Malta licence).
Your rights under applicable data protection legislation
- According to applicable data protection legislation, you are entitled to the following rights in connection with our processing of your personal data:
- Right to access, i.e. a right to receive information about what data we process about you and a copy of the personal data being processed.
- Right to rectification, i.e. a right to have incorrect information corrected.
- Right to erasure, i.e. have your data deleted.
- Right to restriction of processing, i.e. a right to request that our processing is restricted, e.g. if you contest the accuracy of the personal data we are processing.
- Right to data portability, i.e. a right to request that your personal data is being transferred from us to another company.
- Right to object to our processing of your personal data.
- Right to withdraw your consent, a withdrawal will however not affect the lawfulness of processing based on your consent before its withdrawal.
- Right to lodge a complaint with a supervisory authority if you consider that our processing does not comply with the applicable data protection legislation.
- Some of the rights above are only applicable in certain situations (such as request to be forgotten which we may not be able to fulfil as we need to retain certain personal data (e.g. transaction history) due to retention periods set out in licence requirements). In case you would like to exercise any of your rights, please contact us via the contact details above.
This policy may be adjusted from time to time. You will always find the most recent version of this policy on our website. If we make any significant changes to the policy we will notify you of such changes, either by email and/or by adding information about the changes on our website, before any changes come into effect.
Version 1, Updated: 2018-05-25