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Personal data, or personal information, means any information about an individual from which that person can be identified, directly or indirectly.
It does not include data where the identity has been removed anonymous data. We may collect personal data from you because of a legal reason or because you have consented us to do so for a specific purpose.
We may collect, use, store and transfer different categories of personal data about you, which we have grouped together as follows:.
Registration Data includes first and last name, username or similar identifier, date of birth, territory applicable social security number where permitted or required by law, gender, country.
ID card, passport, utility bill, any other document as may be specified in sectoral implementing procedures issued by the relevant regulator authorities.
Responsible Gambling Data RG including name, surname, Zip Code, email, phone number, country, date of birth, territory applicable social security number where permitted or required by law , approved transactions deposits and withdrawals , denied transactions deposits and withdrawals , Identification and Verification Data, Self-exclusion Data.
Self-exclusion Data includes data pertaining to you and your self-exclusion such as your Registration and Contact Data and your self-exclusion details such as reason, start and date, utilisation of self- exclusion tools such as exclusions, session limit, loss limit, wager limit, deposit limit, reality check.
Transaction and Usage Data includes details generated through your use of our Services e. Log in Data includes internet protocol IP address, your logins first log in last login, last failed login , duration of log ins, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Services.
Other Communication Data provided by you in communication with us via recorded calls, chats, emails, or SMS which may include various data such as your intentions, interests, complaints, preferences, as well as internal communication and notes.
Analytics Data include various data provided by your observed with respect to your use of our Website and Services such as your player ID, language, location, browser data, campaigns utilised, channels used, device, payment provider, Transaction and Usage data and in case of online acquisition analytics also pages visited, postcards clicked, scroll depth.
We do not collect any Special Categories of Personal Data about you this includes details about your race or ethnicity, religious or philosophical beliefs, sex life or sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.
However, there may be times when you may voluntarily choose to disclose information like this to us, such as when you are speaking with our Ambassadors or Responsible Gaming Specialists, and these chats and emails are assigned to your account with us.
Where you have a health condition that affects your ability to control your gambling behaviour and you choose to provide us with documentation to support this, we will make note that you have a health condition but delete the documentation you provide to us.
Where you disclose a health condition which we feel may impact your ability to make rational decisions around your gameplay, we may take the decision to block you from our Services for your own safety.
Direct interactions - you may give us your Registration, Contact, Identity and Verification, Marketing and Communications and Financial Data by filling in forms or by corresponding with us by phone, email or otherwise when you engage with us to provide you with our Services.
Third parties and publicly available sources - We may combine the information we collect from you with information that we receive about you from other sources, such as public databases, providers of demographic information and other third parties.
Due to regulatory requirements we collect know your customer KYC information from specialised third parties. Automated technologies or interactions - We and our third-party service providers may collect information automatically from your device in a variety of ways, including:.
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you for example, to provide you with information related to your query.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email, text message or by post.
You have the right to withdraw consent to marketing at any time by either unsubscribing from our mailing list or by contacting our DPO.
We have set out below, in a table format, a description of all the ways we use your personal data, and which of the legal bases we rely on to do so.
We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.
We may use your personal data, such as your email address and telephone number, ourselves or by using our third party subcontractors for the purpose of providing you with promotional materials including news and bonuses , concerning our Services as well as products, services and promotions which relate to other companies within the Casumo Group, which we believe may interest you.
We will use your personal data for the purpose of providing you with promotional materials solely where we have a legitimate interest in doing so, or where we have obtained your affirmative consent.
When relying on legitimate interest, Dunder will give you the opportunity to oppose to such direct marketing when registering on our Site.
In both cases, if you do not wish to receive direct marketing any longer, you may opt out, easily, at any time, either by:. In case of social media marketing, you can control the delivery of certain advertising or social campaigns through the settings offered by the respective third-party platforms e.
In addition, if you download our mobile application to your device from the Apple AppStore or Google Play, the only way to prevent receipt of notifications is by changing the settings on the device itself.
We also use this information to collect statistics about the usage of our Services, perform analytics, deliver content which is tailored to your interests and administer services to our users and players.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact our DPO.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We require all third parties that are acting as processers to Dunder to respect the security of your personal data and to treat it in accordance with the law.
We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Where required by law, your personal information may be disclosed to an applicable governmental, regulatory, sporting or enforcement authority.
Those bodies may then use your personal information to investigate and act on any such breaches in accordance with their procedures.
The data protection and other laws of these countries may not be as comprehensive as those in the EEA. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.
They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available in our Data Retention Policy which you can request from us by contacting our DPO.
Where your personal data is no longer required by us, we will either securely delete or anonymise the personal data in question. Under certain circumstances, you have rights under data protection laws in relation to your personal data.
You have right to:. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction tof the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it.
You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing see below , where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest or those of a third party and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
You also have the right to object where we are processing your personal data for direct marketing purposes.
In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. Request the transfer of your personal data to you or to a third party.
We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data or to exercise any of your other rights.
This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests.
In this case, we will notify you and keep you updated. We would, however, appreciate the chance to deal with your concerns before you approach the IDPC so please contact us in the first instance.
Dunder is on the basis of the applicable laws and license conditions legally obliged to monitor its players in order to identify people who may be experiencing, or at risk of developing, problems with their gambling, and interact with them to offer help or support.
To this end, and to fulfil this obligation, by using historic data describing behaviour of players, in particular certain Responsible Gaming Data, Transaction and Usage Data, and Other Communication Data in particular notably sentiment used in message.
Dunder has established rules regarding who is likely to suffer from gambling addiction and then take relevant action. Decisions, on the basis of the prediction, are not taken automatically without human intervention.
Based on data describing the behaviour of players, in particular Transaction and Usage Data, the algorithm suggests a risk profile.
Decisions, on the basis of the prediction, are not taken automatically and require human intervention. These segments are then processed manually, in order to ensure that we provide the most appropriate offers and bonuses to our players.
These decisions are not taken automatically without human intervention. The process is based on legitimate interest of Dunder regarding providing customised and quality experience for the players.
You can object to such processing by contacting us or changing your preferences in your account. It is important that the personal data we hold about you is accurate and current.
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