Version 1.0. Latest update - 16.08.2024

1. Purpose

1.1 At Techwise, we value our customers and take pride in providing you the most exciting entertainment services available in the gambling industry today. The Company obtains certain personally identifiable information about you, to facilitate our relationship and offer you the best possible gambling experience.

The purpose of this Privacy Policy is to explain our practices and policies for collecting, using and sharing information and Cookies collected from or about you. We have adopted additional policies and procedures described in our Terms and Conditions. This Privacy Policy applies equally whether you are accessing the website via a personal computer, a mobile device or any other technology or device. For the purposes of the Policy, the data controller is Techwise Limited (‘Techwise’) with registered address at 19-21 Circular Road, Douglas, Isle of Man, IM1 1AF, with company registration number 020819V.

Purposes of processing your data => Personal data involved => Possible consequences of failure to provide the personal data => Legal basis for processing your data:

1. Your Registration => Personal Identifiers, Contact Details, Tax Identifiers, Social Security Identifiers, Financial Information, Connection Information, Location Information => Failed registration => Contract Performance

2. Identity and Contact Details Verification => Personal Identifiers, Gambling Activity, Financial Information, Social Security Information, Connection Information, Localisation Information => Account suspension/ closure, Unavailability to login, Withdrawal request unavailable => Regulatory/ Legal Obligation

3. Transactions Management => Personal identifiers, Financial Information => Account suspension/ closure, Withdrawal request freezing and/ or cancellation => Regulatory/ Legal Obligation

4. Monitoring & Assessing gambling Behaviour for Crime Prevention => Personal Identifiers, Contact Details, Gambling Activity, Tax Identifiers, Social Security Identifiers, Financial Information => Account suspension/ closure, Unavailability to login, Withdrawal request unavailable => Regulatory/ Legal Obligation

5. Monitoring & Assessing gambling Behaviour and communications for Responsible Gaming purposes => Personal Identifiers, Gambling Activity, Financial Information, Social Security Information, Connection Information => Account suspension/ closure, Unavailability to login => Regulatory/ Legal Obligation

6. Monitoring & Assessing gambling Behaviour for Business Development => Personal Identifiers, Gambling Activity, Financial Information, Social Security Information, Connection Information, Localisation Information => N/A => Legitimate Interest (Internal Reporting & Business Development)

7. Monitoring & Assessing gambling Behaviour for Personalised Offers, Bonuses and User Interface => Personal Identifiers, Gambling Activity, Financial Information, Social Security Information, Connection Information, Localisation Information => Unavailability of receiving offers and bonuses. Not customised gambling experience. => Consent

8. Informative Communications, Newsletters and Campaigns => Personal Identifiers, Contact Details => Unavailability of receiving newsletters and general marketing campaigns => Consent

9. Inquiries, Complaints & Troubleshooting => Personal Identifiers, Contact Details, Gambling Activity, Connection Information, Localisation Information, Financial Information => N/A => Legitimate Interest (Optimal experience for our customers and troubleshooting of issues)

10. Reporting to Regulatory/ Law enforcement Authorities => Personal Identifiers, Gambling Activity, Financial Information, Social Security Information, Connection Information, Localisation Information, Tax Identifiers => Account suspension/ closure, Unavailability to login => Regulatory/ Legal Obligation

11. Promotions and offers => Personal Identifiers, Contact Details => Unavailability of the relevant promotion, offer, etc. => Consent

12. Creditworthiness and solvency checks, compare information for accuracy, and verify it with third parties => Personal Identifiers, Gambling Activity, Financial Information, Social Security Information, Connection Information, Localisation Information => Potential restrictions web site usage in cases of detection of malpractices => Legitimate Interest (Assurance of accuracy and legal nature of the information provided)

13. Quality assurance and Staff training through call recording and/or educational material presentation => Personal Identifiers, Contact Details, Gambling Activity => Unavailability of Callback/ Phone Customer Service => Legitimate Interest (Optimal experience for our customers and quality assurance of our customer service)

We will not sell, disclose, or rent your personal information to any third party/entities in ways different from what is disclosed in this privacy notice. However, we may disclose your personal information to third parties under the following circumstances:

3.1 In the event that we sell or buy any business, assets or shares, we may disclose your personal data to the prospective seller or buyer of such business, assets or shares.

3.2 In compliance to any legal or regulatory obligation, in order to enforce or apply our terms and conditions, or to protect our rights, property, or safety, or those of our customers or others.

3.3 In order to cooperate with law enforcement agencies to enforce laws, as well as investigate and prosecute unlawful activities such as frauds and scams. We maintain the right to disclose any information about you to law enforcement and other government officials as we, in our sole discretion, believe necessary or appropriate, in connection with any investigation of fraud, scam or other activity that is illegal.

In particular, these authorities are:

- Gambling Authorities in countries we operate

- Sport Governing bodies

- Anti-Money Laundering / Counter Terrorism Financing (AML/CTF) agencies

- Law enforcement bodies at the countries we operate

This includes exchanging information with other companies and organisations (e.g. banks, credit institutions) within or outside EU for the purposes of fraud protection and credit risk reduction. These entities may then use your personal information to investigate and act on any such breaches in accordance with their procedures.

3.4 Finally, we may disclose certain personal information to unaffiliated third-party service providers, agents or independent contractors who help us maintain our website and provide other administrative services to us (including, but not limited to, order processing and fulfillment, providing customer service, maintaining and analyzing data, sending customer communications on our behalf, and entry collection, winner selection and prize fulfillment for contests, and other promotions). We seek to ensure that these unaffiliated third parties will not use the personal information for any other purpose than to provide the administrative services for which they are responsible. We also enter into contracts with these third parties that compel them to meet the privacy standards required by law in handling your personal information, and use the information only for the purposes for which it was conveyed to them. Third parties provide the public with details on the process of data through their websites or any other available communication assets.

Aiming to achieve the purposes described under section 2 of the current policy, the following third parties, located in the European Union, may receive your data:

- Payment providers

- AML/CTF and anti-fraud services

- Platform Providers

- Services providers

3.5 We will not disclose your personal information with any third parties outside of the European Union in countries, where there is no adequate data protection regime. However, in the event that such a data transfer occurs, we will take all reasonable steps possible to ensure that your data is treated as securely as it is within the EU/EEA and in accordance with this Privacy Policy and the applicable legislation. Additionally, we will update the current Privacy Policy in order to reflect the cross-border data transfer and the relevant safeguards for your privacy.

4.1 It is our policy to only retain customer information for as long as is necessary for the purpose for which it was originally obtained, in alignment with the Data Minimisation and Storage Limitation principles. For all purposes below, your data will be retained for a minimum of a five-year period, after the termination of the customer relationship. Additionally, we align the retention of your information with potential differentiations arising from the exercising of your data privacy rights (please refer to section 6). However, in some cases, some personal information may be retained beyond that time period due to potential legal obligations, legitimate interest purposes, etc. Such reasons would be issues related to:

- Money laundering

- Taxation

- Players Protection

- Civil Law

- Penal Law

- Any other legal issues

5.1 At any point while we are maintaining or processing your data, you have the following rights and can submit a relevant request via your personal account:

- Right of access – you have the right to access the personal data that we hold about you

- Right of rectification – you have the right to correct data that we hold about you that is inaccurate or incomplete. Further analysed in section 7 of the current policy

- Right to erasure – you can ask for the data we hold about you to be erased from our records and we are obliged to satisfy such request in certain circumstances

- Right to restriction on processing – you have the right to request to restrict the processing of your personal information and we are obliged to satisfy such request when certain conditions apply

- Right to data portability – you have the right to have the data we hold about you transferred to another organisation

- Right to object – you have the right to object to particular processing activities, under certain conditions

- Right to withdraw consent – where the legal basis for processing your data as set out in section 2 is ‘Consent’, you have the right to withdraw your consent at any time through our dedicated consent management portal integrated in your personal account, without affecting the lawfulness of processing based on such consent before the withdrawal. Such requests to stop receiving commercial communications would be satisfied in no case later than four (4) days from receipt of the request.

5.2 We will assess your request and reply to you regarding the progress and outcome of the request (granting of request, partial granting of request, rejection of request), as soon as possible and in any case in no longer than one month of the request’s submission. In the event that Techwise refuses your request regarding the aforementioned Data Privacy Rights, we will provide you with a reason as to why. You have the right to lodge a complaint directly with the Regulatory authority and the DPO (via the means described in paragraph 13 of the current policy).

5.3 We reserve the right to reject requests that are unreasonably repetitive, require disproportionate technical efforts or have disproportionate technical consequences, risk the privacy of others, or would be extremely impractical.

6.1 Except for exceptional circumstances, you may review, update or delete certain personal information by, if you are a registered user of the website, logging on and using the tools provided to edit such information. However, certain data that are necessary to check eligibility, such as date of birth or age, cannot be deleted.

6.2 You can obtain a copy of your personal information through your personal account. For your protection, you will be required to provide proof of your identity to obtain such copies. You should include adequate information to identify yourself and other relevant information that will reasonably assist us in fulfilling your request. If you would like to close your account, you can also contact Customer Services. If you would like to close your account, this could be done through your personal account. We will comply with such requests unless we have a legitimate ground to not delete the data.

7.1 Protecting your data is of utmost importance for Techwise and in this regard, we constantly strive to provide all possible means of assuring your personal data’s safekeeping, the restriction of unauthorised access and / or potential alterations. Such means include information security measures consistent with current best practices to protect our customers’ privacy. These measures include technical, procedural, monitoring and tracking steps intended to safeguard data from misuse, unauthorised access or disclosure, loss, alteration or destruction.

8.1 We collect your personal data including transactional behaviour, gambling activity and practices, cookies and geolocation information, amongst others, in order to provide you with customised and tailored to your preferences, views and services. The profiling activity allows us to present you with a personalised view and experience on our website.

8.2 The profiling activity also allows us to detect and report potential fraudulent behaviour and violation of our Terms and Conditions potential money laundering practices and responsible gambling behaviour, in line with our regulatory/ legal obligations of reporting such incidents to the relevant authorities.

To summarise the aforementioned, the profiling activity is deemed necessary for the following purposes:

- Marketing reasons: You can receive customised offers, newsletters and general marketing campaigns, as well as customised gambling experience.

- Responsible gambling reasons: If your gambling behaviour is deemed as “at risk” and you are considered to be addicted or you state that you are, your account will be closed for your own protection, according to our Terms and Conditions.

- Anti-Fraud reasons: If you are found to violate our Terms and Conditions (e.g. by having two (or more) active accounts at our website) your account(s) will be closed and your betting activity will be cancelled, according to our Terms and Conditions.

- AML/CTF reasons: If, according to your profiling, your activity is deemed suspicious in terms of Money Laundering then, your activity will be reported at the relevant Law enforcement bodies at the countries we operate, according to our Terms and Conditions.

9.1 Additionally, and in order to provide you personalised offers, promotions and marketing material, we collect your personal data, including transactional behaviour, gambling activity and practices, cookies and geolocation information, among others. Usage of such services is at your sole discretion and the consent provided upon your registration. You can provide your consent at a later time or revoke an existing consent for such services, through our dedicated consent management portal integrated in your personal account.

10.1 When you visit the Website, we register your device's IP address and browser settings. Your IP address is a unique address that devices use in order to identify and communicate with each other on a computer network. Browser settings can include the type of browser you use, browser language, and time zone. We collect this information so that we can personalise your experience and trace your device in cases of misuse or unlawful actions in connection with visits to or use of the service. Furthermore, we may use the IP address to approximate your location (at city level).

11.1 Cookies are small text files, mainly consisting of letters and numbers, that are stored on users’ devices and saved by their browser when they visit a Website. Our Website uses cookies and similar technologies (e.g., pixel tags, web beacons, clear GIFs, and JavaScript) to recognize our users’ web browser, analyze trends and make Our Website more user-friendly, efficient and secure.

In this Cookie Policy, we will refer to cookies and similar technologies simply as “Cookies.”

You may find further information about Cookies, including information about how to manage and delete them at www.allaboutcookies.org.

Session/Persistent cookies. Session Cookies are one-off and get automatically deleted at the end of users’ visit, while persistent Cookies remain stored on users’ devices for a predefined period of time after the end of their visiting sessions, enabling us to identify the users’ browser upon next visit as well as measuring the effectiveness of advertising efforts.

Third party cookies. These Cookies are placed by a third party on users’ devices, providing information about users’ browsing actions and patterns (e.g., visits to website, pages visited, links and advertisements clicked). These Cookies may determine whether certain third party services are being used, identify users’ interests, retarget advertisements and serve advertisements that are relevant to the website’s users. It has to be noted that these cookies adhere solely to the 3rd party’s Cookie Policies for the management of personal data and Our Website does not take any responsibility.

Essential or Required Cookies. These Cookies are used for providing users with any requested features or services. Disabling Essential Cookies may make certain features and services unavailable.

Functionality Cookies These Cookies are used to identify our users’ selections and settings, maintain our users’ preferences over time and recognize users when they return to Our Website, assist us in personalizing our content and remember certain user preferences (e.g., name, language or region).

Performance/Analytical Cookies These Cookies help us understand how visitors use our Website, collecting information about the number of visitors, pages visited and visits’ duration. These Cookies help us to measure the performance of our promotional campaigns and their optimisation for the best experience of our users.

Retargeting/Advertising Cookies These Cookies collect data on our users’ online activity and identify interests so that we can provide relevant advertising.

Any user may decide whether or not to accept Cookies. Users may set their browser so that they only allow cookies in individual cases, excluding the acceptance of cookies for all or certain cases and activate the automatic deletion of cookies when closing the browser. By having these settings, a user can still have full access to Our Website, however preferences have to be manually adjusted at each visit and some functionalities may not work optimally.

12.1 We strive to constantly review and update our privacy policy in order to address potential legislative and regulatory requirements, while providing optimal protection of your privacy. Any updates will be communicated to you via the current web page.

13.1 If at any time you believe that we have not adhered to the provisions set out within this Privacy Policy or for any other Data Privacy related matter, please contact us through email at [email protected].