Privacy Policy
SCOPE
This Privacy Policy (the “Policy”) explains how the Company collects, uses, stores, processes, and otherwise handles the information and Personal Data that you provide to us or that we obtain in connection with your use of our services. It also describes how such information is used to manage and maintain our relationship with you.
This Policy applies to the websites, applications, products, and services operated by the Company that refer or link to this Privacy Policy and that are not governed by a separate privacy notice.
The purpose of this Policy is to provide you with clear information about the categories of data we collect, why such information is collected, how it is processed, the parties with whom it may be shared, and the rights available to you in relation to the collection, processing, storage, and disclosure of your Personal Data.
Throughout this Policy, references to the “Company”, “we”, “us”, or “our” refer to the relevant Data Controller.
By using goldenroo-casinos.com, you acknowledge that your Personal Data may be processed in accordance with the practices described in this Policy. If you do not agree with the terms of this Privacy Policy, you should discontinue use of the Website and refrain from providing your Personal Information to us.
All processing of Personal Data carried out by the Company under this Privacy Policy shall be performed in accordance with:
- The National Ordinance on the Protection of Personal Data (“DPA”), together with any applicable subsidiary legislation issued under it, as amended from time to time;
- Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 concerning the protection of natural persons with regard to the processing of Personal Data and the free movement of such data, repealing Directive 95/46/EC (“General Data Protection Regulation” or “GDPR”).
For the purposes of this Policy, the DPA and GDPR are collectively referred to as the “Data Protection Laws”.
The Company determines the purposes and methods by which Personal Data are processed and therefore acts as the Data Controller under the applicable Data Protection Laws.
DEFINITIONS
Data Controller
A “Data Controller” means a natural or legal person, public authority, agency, or other organization that, either alone or jointly with others, determines the purposes and means of processing Personal Data. Where those purposes and means are established by Union or Member State law, the relevant Data Controller or the criteria for its appointment may also be determined by such law.
Data Processor
A “Data Processor” means any natural or legal person, public authority, agency, or other organization that processes Personal Data on behalf of a Data Controller.
Personal Data
“Personal Data” means any information relating to an identified or identifiable natural person and includes information that may directly or indirectly identify an individual who is considered a data subject.
SECURITY
The Company implements appropriate technical and organizational measures intended to protect Personal Data.
Secure Internet communication protocols, including TLS 1.2, are used to help protect information transmitted through our systems. Personal Data transmitted over the Internet is encrypted during transmission. The Company also stores Personal Data electronically using encrypted storage systems as an additional security measure.
Our services use site identification and security technologies that allow browsers to verify the identity of our systems before personally identifiable information is transmitted. Secure servers and firewall technologies are also used to help protect information against unauthorized access.
PERSONAL DATA PROTECTION
Personal Data held by the Company is protected through security procedures, systems, and measures designed to meet applicable industry standards.
Our commitment to protecting Personal Data includes both the implementation of appropriate security measures and compliance with the applicable legal requirements.
The Company will only process Personal Data where there is a valid and legitimate reason to do so and where such processing is based on one or more lawful grounds recognized under the GDPR or other applicable Data Protection Laws.
PROCESSING ON THE BASIS OF OUR LEGITIMATE INTERESTS
A legitimate interest may exist where the Company has a valid business or commercial reason for processing Personal Data.
Where processing is based on legitimate interests, we will take appropriate measures to protect your Personal Data and seek to ensure that our processing activities do not unfairly prejudice your interests, rights, or freedoms.
When the Company relies on legitimate interests as the legal basis for processing your Personal Data, we may provide information explaining the nature of those interests and make available appropriate means through which you may raise questions or objections regarding such processing.
The Company may not be required to discontinue processing where our legitimate grounds for continuing the processing override your right to object.
For example, we may need to process certain Personal Data in order to comply with anti-money laundering requirements or other binding legal and regulatory obligations. This may also include processing necessary for compliance with applicable Curaçao legal requirements where doing so is necessary for the lawful operation of our services.
PROCESSING ON THE BASIS OF YOUR CONSENT
Consent is not the only lawful basis that may allow or require us to process your Personal Data.
We generally rely on consent where another appropriate legal basis, such as compliance with a legal obligation, contractual necessity, or legitimate interests, does not apply or where we elect to obtain your consent.
Where your Personal Data is processed on the basis of consent, you have the right to withdraw that consent at any time using the same or a similarly accessible method through which it was originally provided.
If you withdraw your consent, we will assess whether another lawful basis exists that permits or requires us to continue processing the relevant Personal Data.
Where such a basis exists, we may continue processing and will inform you where appropriate.
Withdrawal of consent does not affect the lawfulness of any processing carried out before your consent was withdrawn.
DATA RETENTION POLICY
All Personal Data retained by the Company will be protected using appropriate measures and used only for purposes compatible with applicable Data Protection Laws and other applicable legal requirements.
We retain Personal Data only for as long as reasonably necessary for the purpose for which the information was originally collected or for another lawful and compatible purpose.
The period for which Personal Data is retained depends on the type of information involved, the purposes for which it is processed, and the nature and duration of our relationship with you.
When determining the appropriate retention period, we may consider applicable legal requirements, including tax, accounting, corporate, financial, regulatory, and other obligations that may permit or require us to retain particular categories of Personal Data.
For example, information regarded as transactional data may be required to be retained for a minimum period of five (5) years.
We may also consider applicable contractual or legal limitation periods where claims may be brought against the Company by you or a third party. Where necessary, relevant Personal Data may be retained for the period required to establish, exercise, or defend against such claims or other legal actions.
Where Personal Data is no longer required for the purposes for which it was retained, we may securely delete or anonymize the relevant information.
Failure to provide certain Personal Data may prevent the Company from complying with its legal or regulatory obligations, performing contractual obligations, or providing services necessary for the proper administration and maintenance of your account.
Accordingly, if required Personal Data is not provided, we may be unable to provide some or all of the products or services requested by you.
PERSONAL DATA WE COLLECT, THE PURPOSE & LEGAL BASIS OF SUCH DATA PROCESSING
The following categories describe the types of Personal Data that may be processed by the Company, the purposes for which they may be processed, and the corresponding legal grounds.
The same category of Personal Data may be processed for more than one purpose and may therefore be processed on the basis of different legal grounds.
CATEGORIES OF PERSONAL DATA
1.1 Contact Data
Contact information may include your first and last name, residential or mailing address, postal code, telephone or mobile number, email address, and documents confirming your residential address, such as a recent utility bill.
1.2 Identity Data
Identity information may include your first and last name, residential address, date of birth, identity card or passport details, photograph, gender, occupation, marital or family status, and hobbies.
1.3 Activity Data
Activity information may include your Website login records, account activity, transactions performed through our services, bets placed, winnings, bonuses received, deposits, payments and withdrawals, analytics information, relevant browsing activity, preferred games or betting categories, time spent on pages, clicks, actions, cookie-related information, and communications with customer support through telephone, email, LiveChat, or other available channels.
Such information may also include whether you have self-excluded from our services.
1.4 Technical Data
Technical information may include traffic information, GeoIP location data, browser information, and information relating to the computer, mobile device, network, or other technology used to access our services.
1.5 Financial Data
Financial information may include your selected currency, credit or debit card information, banking details, other payment-related information, and information relating to the source of funds.
1.6 Data Used for Marketing and Educational Purposes
This category may include your name, surname, mailing address, telephone or mobile number, email address, evidence of marketing consent where required, evidence of objections to marketing communications, Website-related information, IP address, online identifiers, and other information generated by your browser.
PURPOSE OF DATA PROCESSING
2.1 Account Creation and Identity Verification
We may process Personal Data in order to create a record in our systems, register you as a customer, verify your identity, and help prevent fraud, impersonation, or unauthorized use of your Personal Data by third parties.
2.2 Protection of Financial and Personal Information
We may process information in order to provide additional protection for your financial information, payment card information, and other Personal Data.
2.3 Responsible Gaming Support
Personal Data may be processed to provide appropriate assistance and protection in connection with gambling-related problems and responsible gaming measures.
2.4 Provision and Administration of Services
We process Personal Data in order to manage and monitor our ongoing relationship with you and to provide sports betting, casino games, account management, and customer support services.
2.5 Newsletters and Communications
Personal Data may be processed to subscribe you to newsletters, campaigns, promotional communications, or mailing lists where permitted.
2.6 Customer Experience and Support
We may process information in order to respond to requests concerning your account or profile, personalize your experience, promote a responsible gaming environment, and maintain appropriate records of previous questions, complaints, requests, or communications so that we can improve our services.
2.7 Transaction Monitoring
We may monitor deposits and withdrawals and process related information in order to detect or prevent unauthorized, fraudulent, or unlawful use of accounts or payment methods.
2.8 Marketing and Educational Materials
Where legally permitted, we may use Personal Data to provide marketing information that you have requested or that we are otherwise authorized to send.
We may also provide educational information, notifications regarding upcoming events, and other material that may be relevant to the services provided to you.
LEGAL BASIS FOR DATA PROCESSING
Depending on the circumstances, the Company may process Personal Data on one or more of the following legal grounds:
3.1 Contractual Necessity
Processing may be necessary for the performance of a contract between you and the Company or to take steps at your request before entering into a contract.
3.2 Legitimate Interests
Processing may be based on the Company’s legitimate interests, including maintaining accurate internal records, responding to information requests, improving our services, and developing gaming and betting experiences for users.
3.3 Gambling Licence Requirements
Certain Personal Data may be processed where required by the conditions or obligations applicable to the Company’s gambling licence.
3.4 Anti-Money Laundering and KYC Requirements
Processing may be necessary in order to comply with anti-money laundering obligations, Know Your Customer requirements, and related financial crime prevention measures.
3.5 Consent
Where required, Personal Data may be processed on the basis of your consent, including certain forms of direct marketing.
3.6 Responsible Gaming Requirements
Certain processing may be carried out in accordance with applicable responsible gaming obligations and procedures.
The Company may also obtain Personal Data from publicly available sources, including publicly accessible websites, company registers, and broadcast media, provided that such collection is reasonable and does not unlawfully interfere with your rights and freedoms.
Certain information may also be processed for the purposes of account profiling.
For the purposes of this Policy, profiling may include automated processing of Personal Data used in connection with anti-money laundering requirements, fraud prevention, or the identification of potentially suspicious activity. Examples may include identifying potential tax evasion concerns or unusual betting patterns.
Certain information, such as IP addresses or Politically Exposed Person (“PEP”) checks, may be verified automatically.
However, where such checks are performed, the final determination is made by appropriately authorized members of our staff.
Your email address may also be verified, and you may receive a confirmation message requiring you to verify that the email address belongs to you.
DATA PROCESSING ON THE BASIS OF YOUR CONSENT
For clarity, in circumstances where the Company cannot or elects not to rely on another available legal basis, such as legitimate interests or a legal obligation, we may process your Personal Data on the basis of your consent.
Where we rely on consent, we will not assume that consent has been provided. Consent will be obtained through a clear and appropriate process.
YOU HAVE THE RIGHT TO WITHDRAW YOUR CONSENT AT ANY TIME.
You may withdraw consent using the same or an equivalent method through which it was initially provided.
If you withdraw your consent, we will determine whether another lawful basis exists that permits or requires us to continue processing the relevant Personal Data.
For example, we may be legally required to retain or process certain information even after consent has been withdrawn.
Where appropriate, we will inform you if processing continues on another lawful basis.
You may decline to provide Personal Data that we request. However, where such information is necessary to provide a particular product or service, we may be unable to provide that product or service without the required information.
This may be particularly relevant where consent is the only lawful basis available for the intended processing.
For avoidance of doubt, consent is only one of several legal grounds that may allow the Company to process Personal Data. Other applicable grounds are described elsewhere in this Privacy Policy.
COOKIES
When you visit our Website, certain categories of Personal Data may be collected automatically through cookies and similar technologies.
When you use the Website, cookies may be stored on your computer, mobile device, or browser.
Cookies and similar technologies generally operate by assigning a unique identifier to your browser or device. Such identifiers are used in connection with our services and help us recognize preferences and improve your experience.
We may use these technologies to personalize the Website, including your preferred language and currency, and to provide content that is more relevant to your interests.
After you enter your email address and password during an active session, certain information may be retained for the duration of that session so that you are not required to enter the same information repeatedly.
Where you specifically agree, such functionality may also be extended to future automatic logins.
Most browsers accept cookies automatically by default.
You may manage or restrict cookies and similar technologies through the settings available within your browser or mobile device.
We aim to provide users with appropriate choices regarding privacy and information sharing.
We do not currently recognize or respond to browser-generated “Do Not Track” signals because universally accepted standards, implementations, and technical solutions for such signals have not been fully established across the Internet industry.
Additional information about Do Not Track signals may be available at allaboutdnt.com.
Please note that disabling or refusing cookies may prevent certain features of the Website from operating correctly or being available to you.
We may also use your IP address for identification and security purposes, Website administration, and diagnosing technical issues affecting our systems or servers.
OTHER PURPOSES
Where permitted under applicable law and supported by our legitimate interests, we may use and retain Personal Data for loss prevention purposes and to protect our rights, privacy, security, property, or those of other individuals or organizations.
AUTHORIZED DISCLOSURES OF PERSONAL DATA TO THIRD PARTIES
Subject to the terms of this Privacy Policy, Personal Data relating to you may be disclosed to authorized third parties or competent authorities located within or outside the European Union or European Economic Area where such disclosure is permitted or required under applicable Data Protection Laws or other legislation.
Authorized recipients may include entities within the Company, law enforcement agencies, accounting or audit firms, regulators, supervisory authorities, digital marketing service providers, and other appropriate organizations.
We may also share relevant Personal Data with organizations that introduced you to our services, third parties that you have asked or authorized us to share information with, or other organizations where disclosure is reasonably necessary to provide products or services requested by you.
The specific information disclosed will depend on the relevant products or services used by you and the purpose of the disclosure.
Where Personal Data must be transferred outside the EEA, we will seek to ensure that appropriate safeguards are implemented as required by applicable Data Protection Laws.
We may also disclose Personal Data to affiliated or subsidiary companies, business partners, or successors to our business where such disclosure is legally permitted.
Additional information concerning transfers outside the EEA is provided below.
Your Personal Data will not be provided to third parties for their own independent marketing purposes unless you have provided appropriate consent.
SHARING OF PERSONAL DATA WITH OTHER CATEGORIES OF RECIPIENTS
Where appropriate and in accordance with applicable Data Protection Laws, relevant Personal Data may be disclosed to employees and other personnel of the Company, entities within the Company’s organization, affiliated organizations, subcontractors, and service providers.
Such disclosures may occur where necessary to meet legal obligations, provide services, maintain functionality of the Website, or fulfill another purpose described in this Privacy Policy.
Personal Data will only be shared where reasonably necessary to provide the services requested by you or where another lawful basis permits or requires disclosure.
Any authorized disclosure will be performed in accordance with applicable Data Protection Laws.
Service providers acting as Data Processors are required to comply with contractual obligations governing confidentiality and protection of Personal Data.
Where applicable, such processors are also required to ensure that their personnel are subject to appropriate confidentiality obligations.
Our processors are additionally required to comply with other relevant legal obligations, including those applicable under Article 28 of the GDPR.
Your Personal Data will not be shared with third parties for their own marketing activities unless you have provided your consent.
INTERNET COMMUNICATIONS
Information transmitted over the Internet may pass across international borders, including situations where both the sender and recipient are located in the same country.
Subject to applicable law, the Company cannot accept responsibility for acts or omissions by you or third parties concerning Personal Data before such information is received by us.
This includes situations where Personal Data is transferred to us through countries that provide a different or lower level of data protection than that available within the European Union or through third-party technologies or platforms such as WhatsApp, Skype, Dropbox, or similar services.
We do not accept responsibility or liability for the security of information while it is in transit across the Internet except where such responsibility is expressly imposed on us by applicable Curaçao law.
ACCURACY OF YOUR PERSONAL DATA
We take reasonable measures to keep the Personal Data held about you accurate and, where necessary, up to date.
You may request information concerning the Personal Data we hold about you by contacting us using the details provided in this Policy.
If you identify information that is inaccurate or incomplete, you may request that it be corrected or completed.
Further information regarding your rights under applicable Data Protection Laws is provided below.
LINKS TO THIRD-PARTY SITES
Our Website may contain clearly identifiable links to websites operated by third parties.
The Company is not responsible for, and does not necessarily endorse, the content, services, privacy policies, security practices, or Personal Data processing activities of third-party websites.
We recommend reviewing the applicable privacy policy of any external website before providing Personal Data or using its services.
DATA TRANSFER OUTSIDE OF THE EEA
Protecting your Personal Data is a priority for the Company.
We implement appropriate technical and organizational measures intended to protect and secure the information collected through our services.
Personal Data is stored using secure infrastructure maintained by reputable service providers.
Your Personal Data is primarily stored and processed within the European Economic Area.
However, as described elsewhere in this Policy, certain Personal Data may be disclosed to third parties, and some of those parties may access, store, or process information outside the EEA.
Personal Data may also be accessed and processed outside the EEA by employees, representatives, agents, service providers, or other persons acting on our behalf.
Whenever Personal Data is transferred outside the EEA, we will seek to ensure that appropriate safeguards are implemented and that enforceable rights and effective legal remedies remain available to you as required by applicable law.
Such safeguards may include Standard Contractual Clauses or other legally recognized transfer mechanisms.
You may request further information about applicable safeguards by contacting us through LiveChat or by email at [email protected].
Where third-party processors handle Personal Data on our behalf, we will require them contractually to maintain appropriate security standards and to provide a level of Personal Data protection consistent with applicable legal requirements.
By accepting this Policy, you acknowledge and, where required, consent to transfers of your Personal Data outside the EEA in accordance with the practices described above.
DATA SUBJECT RIGHTS
The Company will seek to provide reasonable assistance where you choose to exercise rights available to you in relation to your Personal Data.
In some cases, we may need to verify your identity before processing a request in order to protect your information from unauthorized access or disclosure.
Right of Access
You have the right to request confirmation as to whether Personal Data relating to you is being processed.
Where applicable, you may also request access to the relevant Personal Data and information concerning:
- The Personal Data we hold about you;
- The purposes for which the information is processed;
- The persons or organizations to whom the information is disclosed;
- The period for which we expect to retain the information, where this can be determined;
- Whether Personal Data is transferred internationally and the safeguards used for such transfers;
- The rights available to you under applicable law;
- How you may submit a complaint;
- The source from which your Personal Data was obtained, where applicable;
- Whether automated decision-making or profiling has been carried out and relevant information concerning such processing.
Right to Rectification
You have the right to request that inaccurate Personal Data concerning you be corrected.
You may also request that incomplete Personal Data be completed where appropriate.
Right of Erasure — “Right to Be Forgotten”
You may have the right to request deletion of your Personal Data.
Where applicable, we will process such requests without undue delay where:
- The Personal Data is no longer required for the purposes for which it was originally collected or processed;
- You withdraw your consent where consent was the legal basis for processing and no alternative legal ground applies;
- You successfully exercise your right to object to the relevant processing;
- Your Personal Data has been processed unlawfully;
- Deletion is required in order for the Company to comply with a legal obligation;
- Applicable legal requirements concerning certain rights of children require deletion.
The Company may not be required to comply with an erasure request where continued processing or retention of the relevant Personal Data is necessary in order to comply with a legal obligation applicable to us.
Right to Restriction of Processing
You may have the right to request that processing of your Personal Data be restricted.
This right may apply where:
- You contest the accuracy of the Personal Data, for a period sufficient to allow us to verify its accuracy;
- Processing is unlawful but you prefer restriction of processing instead of deletion;
- The Company no longer requires the Personal Data for its original processing purposes, but you require the information for the establishment, exercise, or defense of legal claims;
- You have exercised your right to object and an assessment of whether our legitimate grounds override your objection remains pending.
Where processing has been restricted, the relevant Personal Data may generally only be processed:
- With your consent;
- For the establishment, exercise, or defense of legal claims;
- Where otherwise permitted or required under applicable law;
- For the protection of the rights of another natural or legal person;
- For reasons of important public interest.
Right to Data Portability
Where applicable, you have the right to request Personal Data that you previously provided to us.
Such information may be supplied in a structured, commonly used, and machine-readable format.
Where technically feasible and legally permitted, you may also request that such information be transmitted directly to another Data Controller, provided that doing so does not adversely affect the rights and freedoms of other persons.
The right to data portability generally applies where:
- Processing is based on your consent or on the performance of a contract with you; and
- Processing is carried out by automated means.
Right to Withdraw Your Consent
Where Personal Data is processed on the basis of your consent, you have the right to withdraw that consent at any time.
Further details are provided in the DATA PROCESSING ON THE BASIS OF YOUR CONSENT section above.
Right to Object to Data Processing
In certain circumstances, you may have the right to object to the processing of your Personal Data.
This may apply where:
- Processing is necessary for the performance of a task carried out in the public interest;
- Processing is based on legitimate interests pursued by the Company or a third party.
Where you submit a valid objection, processing based on legitimate interests may cease unless the Data Controller can demonstrate compelling legitimate grounds for continuing the processing that override your interests, rights, and freedoms, or where the processing is required for the establishment, exercise, or defense of legal claims.
Where your Personal Data is processed for direct marketing purposes, you have the right to object to such processing at any time.
In circumstances not covered by the applicable legal grounds described above, a general right to object may not apply.
Right to Lodge a Complaint
As a data subject, you may lodge a complaint with an appropriate Data Protection Supervisory Authority if you believe that your rights concerning Personal Data have been infringed.
Without limiting this right, we encourage you to contact us first so that we may have an opportunity to address and resolve your concerns.
Please note that the existence of the rights described in this Policy does not necessarily mean that every request must be accepted.
Where permitted under applicable law and where appropriate grounds exist, the Company may decline a request.
Any such refusal does not prevent you from submitting a complaint to the appropriate Data Protection Supervisory Authority.
OUR CONTACT INFORMATION
If you have questions, comments, or concerns regarding this Privacy Policy, the handling of your Personal Data, or the exercise of your data protection rights, you may contact us.
Our customer support team may also assist you with relevant privacy-related requests.
The Company’s Data Protection Officer may be contacted through LiveChat or by email.
Email: [email protected]
Website: goldenroo-casinos.com