Privacy Policy
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General
Seven23 Ltd, as the Data Controller for the collection and processing of data on its website www.casinofive.com, is strictly committed to the protection of players' personal data, according to applicable legislation, including the EU - General Data Protection Regulation. This Privacy Policy Statement describes how Seven23 Ltd processes personal data and notifies players on their related rights.
Personal data means any information relating to an identified or identifiable natural person.
Processing of data means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Personal data will solely be processed by Seven23 Ltd in case the player has given consent to such processing, the processing is necessary for the provision of the offered services, the processing is performed to fulfil mandatory legal requirements applying to Seven23 Ltd, or the processing is required for the pursuit of the legitimate interests of Seven23 Ltd, third parties or the public, when such legitimate interest is not overridden by the particular player's fundamental rights.
By accepting this Privacy Policy Statement, the player expresses its consent to the collection and processing of its personal data as described in this Privacy Policy Statement.
To provide our services, and for the purpose of preventing illegitimate use of our services, we carry out profiling of our players and their activities using automated processes. However, any decisions taken based on these profiles and information are taken by natural persons. No automated decision-making processes will be implemented.
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Inquiries & Data Protection Officer
For any privacy issues, for inquiries and/or for further information on Seven23 Ltd's data processing activities, please contact the Data Protection Officer at:
Seven23 Ltd
DPO
10, Manoel Street
Castries
Saint Lucia
[email protected] -
How Seven23 Ltd processes personal data
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Legitimate Interests
Except for the fulfilment of mandatory legal requirements or when the player has consented in such processing, Seven23 Ltd processes personal data solely for the pursuit of its legitimate interests or for the pursuit of the legitimate interests of third parties or the public.
As a general rule and not anticipating the results of a proportionality assessment to be performed when appropriate, Seven23 Ltd's legitimate interests for the collection and processing of personal data may be:
- the enabling, optimisation and improvement of the services offered by Seven23 Ltd,
- the detection of abuse of the websites operated and/or the services provided by Seven23 Ltd,
- the identification and solution of dysfunctions on the Websites of Seven23 Ltd,
- the enforcement of contractual agreements and/or legal duties, and
- the promotion of the services offered.
The legitimate interest for the processing of data will be declared in the relevant section of this Privacy Policy Statement.
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Principles for the processing of personal data
Seven23 Ltd processes personal data solely according to the principles laid down in art. 5 (1) a. to f. of the EU General Data Protection. These principles are:
- Lawfulness, fairness and transparency: personal data will solely be processed in a lawful, fair and transparent manner;
- Limitation of purpose: personal data will solely be processed for the specified, explicit and legitimate purposes these data was collected and not further, when such processing is incompatible with the purpose of collection;
- Minimization: personal data will solely be processed in an adequate, relevant and limited extent in relation to the purpose of processing;
- Accuracy: personal data will be processed in an accurate manner and kept up-to-date where necessary;
- Storage Limitation: personal data will not be kept longer than necessary for the purpose for which the data will initially collected; and
- Integrity and confidentiality: personal data will solely be processed in a reasonably secure manner and utilising appropriate organisational and technical measures, in order to protect these data against accidental or malicious loss, destruction or damage.
Moreover, in accordance with the relevant Data Protection legislation, Seven23 Ltd informs players or potential players that when an account is opened, the player's personal data may be processed for anti-money laundering purposes.
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Collection and processing of data within the offers of Seven23 Ltd
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when visiting the website
During the visit of the websites of Seven23 Ltd, the gaming system, by automated means, may collect information generated by the browsers of the visitors of the websites and may store them in logfiles on a temporary basis. This may include, but is not limited to:
- the IP address of the accessing computer,
- date and time of accessing,
- the operating system accessing, and
- the browser deployed by the visitor.
The logfiles may contain IP addresses allowing to identify a particular player.
Legitimate interest for such collection are:
- the enabling, optimisation and improvement of the services offered by Seven23 Ltd,
- the detection of abuse of the websites operated and/or the services provided by Seven23 Ltd, and
- the identification and solution of dysfunctions on the Websites of Seven23 Ltd.
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when registering with Seven23 Ltd
Seven23 Ltd is legally required to collect players' personal data at registration stage. This may include, but is not limited to
- first name and last name,
- gender,
- residential address,
- date of birth,
- nationality, and
- email address.
Players may be required to submit further documentation for the purposes of identity verification, security assessments and regulatory required checks. Seven23 Ltd may also collect information from third party databases for such purpose.
Player are required to keep up-to-date their personal details at any time.
Failing to provide the mandatory information to be collected by Seven23 Ltdor maintaining up to date personal details with Seven23 Ltd can result into the account closure.
Legitimate interest for such collection are:
- the enabling, optimisation and improvement of the services offered by Seven23 Ltd,
- the detection of abuse of the websites operated and/or the services provided by Seven23 Ltd,
- the enforcement of contractual agreements and/or legal duties, and
- the promotion of the services offered.
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for the purpose of processing payments
Seven23 Ltd offers the facility to process payments in favour of the offers provided to its players. Depending on the payment method chosen by a particular player, and, if applicable, further criteria, the personal information required may vary.
These data will be transmitted to third party payment providers in order to process a particular payment request.
Legitimate interests for such processing are:
- the enabling, optimisation and improvement of the services offered by Seven23 Ltd,
- the detection of abuse of the websites operated and/or the services provided by Seven23 Ltd, and
- the enforcement of contractual agreements and/or legal duties.
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for the purpose of creating player profiles
Seven23 Ltd processes information that is collected by cookies, logfiles, clear gifs, and/or by third parties' support in order to create player profiles. A profile contains information on individual players including preferences concerning the activities of the player. Profiles are also used to design the player's experience on the websites individually and to provide specific marketing information.
Legitimate interest for such collection are:
- the enabling, optimisation and improvement of the services offered by Seven23 Ltd, and
- the promotion of the services offered.
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via logfiles
Seven23 Ltd uses logfiles on its websites. These may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp and the number of clicks to analyze trends for administration of the website, to track a particular players' movements on the website, and to gather comprehensive demographic information. IP addresses are related to the provision of web-based services with personally identifiable information.
Legitimate interest for such collection are:
- the enabling, optimisation and improvement of the services offered by Seven23 Ltd, and
- the enforcement of contractual agreements and/or legal duties.
- player communication
Seven23 Ltd may store communication with players with the customer support and further.
Legitimate interest for such collection are:
- the enabling, optimisation and improvement of the services offered by Seven23 Ltd, and
- the enforcement of contractual agreements and/or legal duties.
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for the purposes of marketing activities
Depending on the account settings set by a particular player, its personal data may be used for marketing activities across various channels including mail, email, electronic/instant messaging, and further.
The consent in the use of the player's personal data for marketing activities may be cancelled or restricted by the player at any time. Such request may be submitted to the customer support team of Seven23 Ltd via [email protected] or via the player account settings.
Legitimate interest for such collection are:
- the enabling, optimisation and improvement of the services offered by Seven23 Ltd, and
- the promotion of the services offered.
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for other purposes
In exceptional cases, it may become necessary for Seven23 Ltd to process personal data for other purposes. However, the conditions set out in section A. above apply to any case; no processing will take place unless the said conditions of section A. above are met.
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third party content and tracking software
Seven23 Ltd uses tracking software and website analytics tools on its websites, allows the use of social media plugins and single sign-on technology, and may provide third party content on its websites.
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Tracking-Software
Seven23 Ltd uses tracking software for the purpose of evaluating the user's preferences and therefore to improve the offers of Seven23 Ltd.
Tracking software collects user data such as IP address, accessing website, advertisement preferences and further marketing information.
The following tracking software are integrated to the websites of Seven23 Ltd:
Legitimate interest for such collection are:
- the enabling, optimisation and improvement of the services offered by Seven23 Ltd.
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Website analytics
Seven23 Ltd uses website analytics tools for the purpose of understanding the player's behaviour on the Seven23 Ltd websites and optimise the services provided by Seven23 Ltd.
Website analytics tools collect data by using cookies and IP address tracking for that purpose.
The following website analytics tools are integrated to the websites of Seven23 Ltd:
Legitimate interest for such collection are:
- the enabling, optimisation and improvement of the services offered by Seven23 Ltd
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Social media plugins
Seven23 Ltd uses social media plugins for the purpose of enabling the player to interact between social media and the Seven23 Ltd websites and therefore share the gaming experience with others.
Social media plugins allow the user to login to both social media and Seven23 Ltd account and to link content provided by Seven23 Ltd to the player's social media profile.
Social media plugins collect user data such as IP address, login data, accessing website and cookie data.
The following social media plugins are integrated to the websites of Seven23 Ltd:
Legitimate interest for such collection are:
- the enabling, optimisation and improvement of the services offered by Seven23 Ltd.
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Single sign-On
Seven23 Ltd uses single sign-on technology for the purpose of facilitating the player's access to the Seven23 Ltd websites and allowing interaction between the player's chosen service provider or social media profile and the Seven23 Ltd websites.
Single sign-on tools collect user data such as IP address, login data and cookie data.
The following single sign-on tools are integrated to the websites of Seven23 Ltd:
Legitimate interest for such collection are:
- the enabling, optimisation and improvement of the services offered by Seven23 Ltd.
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Third party games providers
Within the offers of Seven23 Ltd, games provided by third party game providers may be deployed.
In the event of games being provided via the game provider websites and therefore beyond Seven23 Ltd's framework of privacy regulations, Seven23 Ltd cannot acquire warranty for data collected via the third-party websites.
A list of the third-party game providers offering games on the websites of Seven23 Ltd can be found in subsection 4.e. below.
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via cookies
Seven23 Ltd uses cookies. Cookies are small files that are automatically created by the user's browser and are stored locally (on the accessing laptop, tablet, smartphone, etc.) when visiting the websites of Seven23 Ltd.
For more information about the use of cookies on the websites of Seven23 Ltd, please refer to our Cookie Policy.
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Sharing and disclosure of personal data
Seven23 Ltd will, in no event, transfer data to states outside of the European Economic Area provided unless the recipient guaranties a standard of data protection comparable to European standards (e.g., by agreeing to approved contractual clauses, binding corporate rules or further measures applied and accepted to ensure that the recipients of personal data obtain an appropriate level of data protection and privacy at any time).
Seven23 Ltd shares data within the framework of the EU - General Data Protection Regulation:
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with services providers
Under the circumstances set out in subsection 4. above, Seven23 Ltd may make use of third party companies to process players' personal data. In such event, the sharing of personal data collected by Seven23 Ltd may be necessary.
Seven23 Ltd requires any service provider to act with a reasonably high level of diligence and care, imposes contractual obligations to treat any data shared accordingly, to any service provider and ensures that data shared will solely be utilised for the purpose of collection and to the extent necessary to fulfil the respective task.
Legitimate interest for such transmission are:
- the enabling, optimisation and improvement of the services offered by Seven23 Ltd,
- the detection of abuse of the websites operated and/or the services provided by Seven23 Ltd,
- the enforcement of contractual agreements and/or legal duties, and
- the promotion of the services offered.
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for measures of KYC, AML and fraud prevention
For the purpose of a players' identity verification, to carry out security checks, to assess a players' compliance with the applicable Terms and Conditions and legal obligations including the prevention of money laundering, the financing of terrorism and the protection of minors, player data may be matched against third party databases.
Upon any indication of transactions and/or activities that may give rise to suspicions of criminal activities, Seven23 Ltd will report to the relevant parties in charge (e.g., police, private associations aiming at the prevention of criminal and fraudulent activities in games of chance).
With the acceptance of the applicable Terms and Conditions and this Privacy Policy Statement, the player grants its explicit consent to these procedures including the matching of data provided against databases of third parties.
The sharing of players' data may also be necessary to protect the players and the operation of Seven23 Ltd from crime and to comply with legal obligations.
There may be circumstances in which Seven23 Ltd may be obliged to forward the Player Personal Information to any relevant regulatory authority.
Legitimate interest for such transmission are:
- the enabling, optimisation and improvement of the services offered by Seven23 Ltd,
- the detection of abuse of the websites operated and/or the services provided by Seven23 Ltd,
- the enforcement of contractual agreements and/or legal duties, and
- the promotion of the services offered.
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for other purposes
It may be necessary share personal data for additional purposes. However, Seven23 Ltd solely discloses personal data in case and to the extent that one or more conditions set out in this Privacy Policy Statement and according to the general rules declared in section A. above are met.
Legitimate interest for such transmission are:
- the enabling, optimisation and improvement of the services offered by Seven23 Ltd,
- the detection of abuse of the websites operated and/or the services provided by Seven23 Ltd,
- the enforcement of contractual agreements and/or legal duties, and
- the promotion of the services offered.
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of anonymised data
Notwithstanding Seven23 Ltd's commitment to the protection of personal data, Seven23 Ltd reserves the right to publish gaming data (e.g., game results), the player's first name, the initial of the surname and the player's country of residence on the websites of Seven23 Ltd, as long as the player remains, directly and indirectly, unidentifiable by the publication of these information.
Such publication is performed in order to promote the services offered.
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third party games providers
Within the offers of Seven23 Ltd, games provided by third party game providers may be deployed.
In the event of games being provided via the game provider websites and therefore not within Seven23 Ltd's framework of privacy regulations, Seven23 Ltd cannot acquire warranty for data collected via the third-party websites.
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Retention
Personal data is kept by Seven23 Ltd for the term of the contractual relationship. Whenever a player closes its player account with Seven23 Ltd, the personal data stored in the gaming system will remain stored for the minimum length of time required to comply with the purposes set out in this Privacy Policy Statement and relevant legal requirements. Personal Data may also be stored for a longer term in case it cannot a deletion is not possible for technical and/or legal reasons.
As a general rule, personal data will be stored for a minimum term of five years after termination of the business relationship in question, while transaction data will be stored for a term of ten years upon termination of the business relationship in question.
Storage terms in particular may vary, depending of the circumstances of the certain case.
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Data Security
All data will be processed by automated means. Seven23 Ltd takes all adequate technical and organisational efforts to protect players' data from access by unauthorised persons and to prevent accidental or unlawful processing, disclosure, destruction, loss, alteration or damage.
Additionally, payment information will be encrypted when being processed.
Sensitive information is protected online by SSL encryption. Furthermore, Seven23 Ltd takes any reasonable effort to ensure the protection of players' data in all other areas.
Only authorised personnel of Seven23 Ltd or of third-party companies contractually bound to Seven23 Ltd and to the compliance with the principles of data protection and the terms of this Privacy Policy Statement, obtain access to the players' information.
Seven23 Ltd monitors the trustworthiness and reliability of all personnel and service providers. At regular intervals, any employee will be trained on the applicable security and data protection standards. Relevant servers are located in a secure environment.
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Data encryption
In order to protect the players' personal data when communicating with the web browser, Seven23 Ltd uses encryption technology of its trusted certification partner company. In addition, online transactions are shielded by the security system of a worldwide-accredited partner.
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Other technical security measures
In addition, all player data will be protected from unauthorised or damage access by firewall and intrusion prevention systems.
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Rights of the player regarding its personal data
The player, at any time, has the right to
- request access to its personal data,
- request correction of its personal data,
- withdraw the consent to the processing of its personal data (e.g., for marketing activities),
- request erasure of its personal data,
- receive its persona data upon request in a structured, commonly used and machine-readable format (data portability),
- request the restriction of processing its personal data, and
- to object to the processing of personal data.
Some of these rights may only apply under certain circumstances as set forth in data protection legislation including the General Data Protection Regulation.
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Inquiries
For inquiries or complaints regarding the handling and collection of data on the websites of Seven23 Ltd, please contact [email protected] or the relevant data protection authority.
Complaints
Complaints in relation to how Seven23 Ltd handles the player’s Personal Details can be raised by sending an email to [email protected]
The Player has also the right to loge such complaints to the relevant supervisory authority.
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Changes and amendments to this Privacy Policy Statements
This Privacy Policy Statement may be subject to change from time to time, of which players will be informed without undue delay and upon their next login to the player account with Seven23 Ltd at the latest.
