Privacy Police

INTRODUCTION

Pollytrading (“We”) are committed to protecting and respecting Your privacy, which includes any personal information that You may choose to provide us (“Personal Information”). This policy (together with Our Terms and Conditions and Cookie Policy) describes how Pollytrading collects and uses Your personal information. It also describes Your rights and the choices available to You regarding Our use of Your personal information and how You can access and update this information. If You have questions or complaints regarding Our privacy policy or practices, please contact Our Data Protection Officer at dpo@pollytrading.com.

Personal information is that information which relates to an identified or identifiable user, and can include information such as name and surname, residential address and copies of passports. Where Pollytrading collects and determines the means of processing of Your personal information, it will act as data controller.

Pollytrading adheres to and complies with the General Data Protection Regulation and other relevant European and national regulations, legal notices and similar instruments that may be in force from time to time.

ACCEPTANCE OF THIS PRIVACY POLICY

By providing Your information to us by registering with us or accessing the website via a computer, mobile phone or other handheld internet enabled device or any other device, You confirm Your acceptance of Our Privacy Policy and authorise us, Our staff, subsidiaries, and suppliers to process Your personal data.

Please read this policy carefully so as to ensure that You understand Our values, views and practices regarding the capture, retention, processing, use and transfer where applicable of Your information.

CATEGORIES OF INFORMATION AND PURPOSE OF PROCESSING

We may collect the following personal information from You to comply with Our legal obligations (including but limited to gaming and anti-money laundering regulation):

• Contact Information such as name, surname, date of birth, residential address, email address, phone number;
• Official documents such as passport or identity document which includes a photograph of Yourself;
• Responsible gaming limits; and
• Correspondence information such as a record of Your communication with Our Customer Support Team via email and live chat.

We may also process anonymised behavioural information and provide such to third party research organisations in order to prevent gambling-related issues.

In addition, We may collect the following information from You to provide to You with Our Service:

• Username, Internet Protocol (IP) address, browser type, demographic and geo-location information from Your device and/or hardware, referring/exit pages, and operating system;
• Device ID, installed software, browser cookies and in-game information;
• Financial and Billing Information such as credit card number, name and surname of credit card holder, expiry date of credit card, billing address, name of bank and bank account number; and
• Information related to Your subscription to Our Mailing List such as name, surname and email address.

We also collect, process and retain Your personal information where We deem that We have a legitimate interest to do so for the pursuit of Our commercial and business objectives, and if such processing does not prejudice Your right to privacy, including situations such as:

• when We provide You with marketing updates, newsletters and bonus information,
• when We update and carry out maintenance on the Service and for troubleshooting,
• when We prevent and investigate fraud and other misuses.

Should You require any further information regarding processing of Your personal information based on legitimate interest, please contact Our DPO at dpo@pollytrading.com.

INFORMATION SHARING

We share Your personal information with companies that provide services to help Us deliver the Services requested by You and help Us with Our business activities such as but not limited to card and payment processing, customer service, marketing, data storage providers and business intelligence. We have a contractual relationship with all these companies which ensures that Your personal information which is shared, is strictly processed as necessary to provide these services to Us.

We may also disclose your personal information as follows:

• As required by law such as to comply with a subpoena, or similar legal process;
• To comply with Our legal and regulatory duties and responsibilities towards the relevant licensing and regulatory authorities as well as all duties and responsibilities owed under any other applicable legislation and to any other applicable regulators in other jurisdictions;
• When We believe, in good faith, that disclosure is necessary to protect Our rights, protect Your safety or the safety of others, investigate fraud, or respond to a government request;
• If We are involved in a merger, acquisition, or sale of all or a portion of assets, in which case, You will be notified via email and/or a prominent notice on Our Service of any change in ownership or uses of Your personal information, as well as any choices You may have regarding Your personal information;
• When We collaborate with third party organizations in order to identify instances of match-fixing; and
• To any other third party with Your prior consent to do so.

In certain instances, We are also legally obliged to verify Your identity through the use of third party service providers with which We share personal information and obtain personal information from. We are entitled to form decisions based on the information supplied from these service providers. The above sharing of personal information may involve transfers of personal information to third countries outside of the EU/EEA.

Transfers of personal data outside the EU

We operate in multiple jurisdictions, some of which are located in Countries different from the one where You reside. The information that We collect from You or that you provide to Us may be transferred to and stored at a destination outside Your country for the processing of Your payment details and the provision of support services. We will take all reasonable steps to ensure that Your data is treated securely and in accordance with this Privacy Policy. By providing Us with Your personal information You agree that We may transfer, store and process Your information outside Your country. Where We share Your personal information with third parties located outside of the EU/EEA, We ensure that Our contractual relationship with such third party contains adequate safeguards in respect of Your personal information. We only enter into contractual relationships with third parties who guarantee a comparable standard of data protection to EU/EEA countries.

If You choose to communicate through social media platforms, the information You provide is tied to Your personal social media account. You will need to contact the social media platform directly in order to exercise any of Your rights or request removal of communications between You and Us on the platform in question.

COOKIES

We use cookies to help the site work properly and to improve Your user experience. We may use cookies, for example, to keep track of Your preferences, activity and which website You were routed from. Cookies are also used to collect general usage and volume statistical information that does not include personal information.

THIRD PARTY COOKIES

We make use of active JavaScript contents from third party providers such as FeatureSpace Limited and Google Analytics on Our Service which may therefore access Your personal information when You access Our Service. This might constitute a transfer of Your personal information to countries which are not situated in the EU/EEA area. You can avoid this by disabling JavaScript in Your personal browser. However, if You do so, the functionality of Our Service may be severely impaired and You might not be able to access Our Service. In these cases, We exclude any liability arising from third party content on Our Service.

LINKS TO OTHER WEBSITES

Our Service includes links to other websites whose services You might use, and privacy practices may differ from those of Pollytrading. If You submit personal information to any of those sites, Your information will be governed by the third party privacy policies. We encourage You to carefully read the privacy policy of any website which You visit. We assume no responsibility or liability whatsoever for the practices, actions or policies of such third parties.

SURVEYS OR CONTESTS

From time-to-time We may provide You with the opportunity to participate in contests or surveys on Our site. If You participate, We will request certain personally identifiable information from You. Participation in these surveys or contests is completely voluntary and You therefore have a choice whether or not to disclose this information.

We will retain Your information for as long as Your account is active, but also after closure, howsoever occurring, in accordance with Our data retention policy and in accordance with the respective laws and regulations. The criteria used to set the respective retention periods for the different kinds of personal information which We collect and process depend on the respective retention periods stipulated under various laws and regulations, including anti-money laundering laws.

If You wish to cancel Your account or request that We no longer use Your information to provide You with the Service, please contact Us at dpo@pollytrading.com. Cancelling Your account and/or requesting data erasure does not always mean that We are legally allowed to do so. Following closure, We will retain and use Your personal information as necessary to comply with Our legal obligations, resolve disputes, and enforce Our agreements.

The security of Your personal information is important to Us. We follow generally accepted industry standards to protect the personal information submitted to Us, both during transmission and once We receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, We cannot guarantee its absolute security. The transmission of all information collected on Our Service is encrypted using secure socket layer technology (SSL). Pollytrading complies with Payment Card Industry (PCI) Data Security Standards.

YOUR RIGHTS

You have the following rights with respect to the personal information that We hold about You:

• If You would like to know what personal data We hold about You, please contact us on dpo@pollytrading.com; The right to update incomplete personal information.
• The right to withdraw Your consent where We process Your personal information based on Your consent and the right to object to processing;
• The right to object to direct marketing, which can be done by opting-out of direct marketing either unsubscribing via email or by emailing us with a request to dpo@pollytrading.com. You also have the right to object to any profiling to the extent that it relates to direct marketing only;
• The right to lodge a complaint with the Malta Information and Data Protection Commissioner should You feel that Your rights under the General Data Protection Regulation (Regulation (EU) 2016/679) have been breached – You also have the right to lodge a complaint with the respective supervisory authority of the Member State of Your habitual residence, place of work or place of an alleged infringement;
• The right to transmit Your personal information to another data controller. Your personal information will be provided to You in a structured, commonly used and machine-readable format.
• Although You have the right for Your data to be erased, in some cases We may not be able to remove it entirely.

NOTIFICATION OF PRIVACY POLICY CHANGES

We may update this privacy policy to reflect changes to Our information practices. If We make any material changes which significantly affect any of Your rights, We will notify You by email (sent to the e-mail address specified in Your account) or by means of a notice on Our Service prior to the change becoming effective. We encourage You, however, to periodically review this policy for the latest information on Our privacy practices. If You have questions about this Privacy Policy or want to contact Us regarding how We handle Your personal information, please send an email to Our Data Protection Officer dpo@pollytrading.com.