Privacy Policy

Last updated: 12.10.2024

 

GENERAL

Personal data provided by players, in our capacity as controllers of data, are subject to legal processing under regulations on gambling, with a view to enabling them to take part in games and to offer ancillary services. This privacy policy explains how personal data is collected from players, for what purpose, and how it is used.

The Winspirits website ("Casino", "Website", “Company”, "We", "Us", "Our") is owned and operated by Hollycorn N.V., a company registered and established according to the laws of Curaçao, with registration number. 144359 and registered address at Scharlooweg 39, Willemstad, Curaçao, Hollycorn N.V. is licensed and regulated by the Curaçao Gaming Control Board under license no. OGL/2023/176/0095.

By registering for a Player Account through the Website you confirm that you agree to this Privacy Policy. If you do not agree to any of the terms of this Privacy Policy and do not want to provide us with the personal information we request, then you should not use this website.

Please note that this is an agreement between you and the Company. We may occasionally make changes to this Policy. While we do our best to advise you of changes, it is your responsibility to review this Privacy Policy regularly. Your continued use of the Website and/or its services following the posting of changes to this Privacy Policy will constitute your consent to the changes.

Personal Information, which we may request to use and process, shall include but is not limited to:

  • Any of the information that you provide to us when filling in the forms on our account registration pages, as well as any other data that you further submit via the Website or email, such as, first and last name, date of birth, email address, phone number;
  • Correspondence made with us through the Website, email, web chat or otherwise;
  • All Player Account transaction history, whether this takes place via the Website(s) or via other means of communication;
  • Information related to logins into the Website, including traffic data, GeoIP location data, browser/device data, weblogs, activity logs and other traffic information recorded in our system;
  • Documents and proofs reasonably requested by Us in order to verify Your account, to process deposits or withdrawals and to perform anti-fraud checks (on Our own initiative or as required by applicable legislation) - such proofs may include passport scans, payment slips, bank statements etc. f) Survey participations or any other customer assessments which we may carry out from time to time.
We process Personal Data collected from you to provide our services. In particular, we will be using your personal data for the following purposes:

  • To process your bets and transactions - this includes relevant uses of credit card and online payment systems;
  • Providing you with gaming and other ancillary services that you seek from our Website;
  • We process the Personal Information collected from you for the purpose of providing our Services. Specifically, we will use your information for the following purposes:
  • Processing your bets and transactions. This includes your use of credit card and online payment systems;
  • The provision to you of gaming and other ancillary services that you request from the Website;
  • Rendering customer support, such as assistance with setting up and managing your account; d) Identification and carrying out necessary verification checks;
  • Informing the registered players about our promotional offers, or giving information about promotional material from our selected Business Partners, Associates and Affiliates only if players have specifically consented to receive marketing material;
  • Complying with legal responsibilities, including complying with anti-money laundering (AML) and combating the financing of terrorism (CFT) laws;
  • Transaction monitoring and investigation for fraud prevention, terms abuse, money laundering and other illegal or irregular gaming activities;
  • Analyze customer trends by the market study assessments. Participating in such surveys is not compulsory, and you always have the right to decide not to participate; i) Data aggregation research and statistical analysis.

We may use your Personal Information, including your email address and phone number to send you marketing communications about our products, services and promotions if you have opted not to receive promotional materials unless. This can also include information about products and services from some of our business partners such as casino game providers.

You can at any time opt out of this, when you no longer want to receive such marketing and advertising material whether through your Player Account settings or by contacting our customer support at [email protected].

Also, by participating in any contest and/or accepting any contest prize/winning from us, you hereby allow us to use your name and/or nickname for advertising and promotional purposes without further compensation, except where prohibited by law.

We will not collect any Personal Information about you except with your knowledge. We may automatically collect certain data about you, where you would have provided such information through the use of our services and through your interactions with us.

We may also collect legally certain Personal Information from online vendors and service providers, such as fraud prevention companies. Furthermore, we reserve the right to hire third-party contractors to provide technical support in order to process your online transactions and source gaming content.

Please note that we may have access to information that you provide when you access such vendors, service providers and third-party e-commerce services. Rest assured that we will use and protect accordingly any Personal Information so obtained, as provided in this Policy. Any information you provide shall be disclosed only to third parties outside the Company in accordance with this Privacy Policy. We shall take any necessary steps, when required, to assure our agreements with third-party service providers will always protect your private information.

We may also share information you have provided us with other entities within our group of companies, and with our business partners. These companies include, but are not limited to, our parent companies, their parent companies, all subsidiaries of these respective companies, as well as other companies with whom we carry out business and hold necessary agreements. Data processing of your information may be undertaken by the Company or by another entity in our group of companies, which may use a third party to fulfill such data processing needs.

The Company's Data Protection Officer, Money Laundering Officer, the employees in the Payments & Anti-Fraud analysts department, the Customer Support agents, the employees in the Customer Retention team, the VIP player managers, and other selected employees will also be provided with your Personal Information to carry out their duties and give support to you.

Our employees with access or associated with the processing of the player's personal information have signed confidentiality agreements to respect the confidential nature of the player's information, pursuant to applicable gaming, data protection, and privacy laws.

Where necessary, we may transfer your personal data to a country outside the EU, EFTA regions, or EEA to provide you with our services or to engage service providers and data processors. However, we need to safeguard your personal data during these transfers in accordance with the General Data Protection Regulation requirements.

This transfer may be necessary in order to provide you with our services such as:

  • Processing your bets and transactions in general;
  • Providing you with gaming and other ancillary services that you seek from our Website;
  • Carrying out the identification and necessary verification checks;

Accordingly, in order to guarantee an adequate level of protection for your personal data when it is transferred to third countries, we use appropriate safeguards, including those approved by the European Commission's standard contractual clauses for data protection. We also will take all steps reasonably necessary to ensure that your information and data are treated securely and in accordance with this Privacy Policy and all applicable data protection laws. By using the services and accessing the website, you hereby consent to such possible transferring of your personal data to third countries and to such application of measures. If you have further questions or concerns on such transfers, you are always free to address us.

Under the Terms and Conditions, both of us-you and the Casino-have the option to consider your Player Account closed at any time. After your account is closed, we will continue to hold information about you for such a period as may be necessary in law. Such information shall only be disclosed upon a request by the relevant authorities, within the framework of an investigation into alleged financial and fiscal record violations, fraud, money laundering, or other illegal activities.

We may also retain anonymized derivatives of your data in order to enhance our content and marketing communications where no automated decision-making is involved.

You hereby acknowledge that due to anti-money laundering legislation in those jurisdictions of the European Union where we are licensed to operate, we are, by law obliged to retain players' personal data provided at registration and all information transferred during the operative life of a Player Account for a period of at least five years from the date of the last player transaction or account closure. As such, requests for erasure prior to the lapse of this period cannot be entertained.

With this, we solemnly confirm that when it comes to the collection and processing of your Personal Information for the purposes of managing your Player Account, strict legal provisions concerning the protection of personal data bind us.

Accordingly, we strive to safeguard your personal data and ensure it is kept by us in confidence, to the best business practices and in conformance with applicable law. We are dedicated to offering the Players secure services and, unless otherwise authorized or required by law, take reasonable precautions against unauthorized access, use, alteration, destruction, and disclosure of your information.

The player account can be accessed only by using the player's unique ID and password. You may also enable two-factor authentication as extra security against any unauthorized use of your account. It is your responsibility to keep your logging information confidential and to make sure that it cannot be accessed by another person.

Data protection legislation affords you, the data subject, certain rights in particular circumstances. The law allows for:

  • Request access to your personal data - that is, you have a right to request, free of charge, a copy of the personal data we hold about you;
  • Request rectification of your personal data: This means that if any personal data we hold about you is incomplete or incorrect, you have a right to have this corrected. Bear in mind, however, that we may require you to provide evidence and documentation-such as your ID documentation or proof of address-to support your request. It can be declined due to our legal obligations.
  • Request the erasure of your personal data: You may request the erasure of your personal data, where it is no longer required for its originally intended purpose or legally justified basis.
  • You object to the processing of your personal data in circumstances where we're relying on our legitimate interests (or those of a third party) to process your data and feel our processing of your data in this way impacts your fundamental rights and freedoms.
  • Request the restriction of the processing of your personal data – You may request for us to temporarily suspend the processing of your personal data in one of the following scenarios: (a) where you want us to establish the accuracy of the data, (b) where our use of the data is unlawful but you do not want for us to delete it, (c) where you need us to retain your data even when we no longer need it in order for you to establish, exercise, or defend legal claims, or (d) where you have objected the use of your data but we need to verify whether we have overriding legitimate grounds to use it;
  • Request data portability: This means you may request us to provide you with certain data we process about you so you may transfer it to another controller. • Withdraw your consent at any time where we rely on your consent to process the data • 'Opting out or withdrawing your consent will not affect the lawfulness of the processing carried out by us up until the time you withdraw your consent. Withdrawing your consent means that going forward, you no longer wish for us to process your data in such a manner.
We have appointed a data protection officer ("DPO") who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, please contact the DPO at [email protected] Further, under Article 77 of the GDPR, you have the right to lodge a complaint pertaining to your data processing with a supervisory authority, especially in the Member State where you reside or work, or where the alleged infringement occurred.
Cookies allow us to know the performance of our content marketing. These cookies are provided by our partners so that we can upscale visits to this website and registrations of new players coming from advertising. We do not disclose personal data about you with affiliated partners except regarding site visit data directly collected by such Advertising Cookies. However, site visit information may occasionally be combined with other personal data gathered from other sources. If this happens, the latter external processing of that data is subject to the privacy notices and policies of these third-party providers.

By the nature of the technical structure of the casino Website, the cookies that we place can be divided into 3 main groups:.

  1. Cookies stored by a back-end application
  2. Cookies persisted by a front-end application
  3. Third-party cookies
In addition to the above, we use a number of third-party service providers that also set cookies on this website, in order to deliver the service they are providing to us. Such services include but are not limited to, helping us to improve your experience by tracking your activity on the Website, measuring the effectiveness of the Website and the effectiveness of our marketing campaigns.

How to Control Cookies

Most Internet browsers automatically accept cookies. However, you can usually modify your browser settings to decline some or all cookies, or to notify you when a cookie is set. Additionally, you may delete cookies that have already been set. We recommend that you do not block or delete your cookies as this may restrict your use of our Website.

You can manage your cookie usage through your browser settings. The Help function within your selected browser will provide the information you need.

You can read more about cookies on the website https://www.aboutcookies.org/
Some browsers provide helpful guides to cookies:

Chrome: https://support.google.com/chrome/bin/answer.py?hl=en&answer=95647&p=cpn_cookies

Firefox: http://support.mozilla.org/en-US/kb/Cookies Internet Explorer: http://support.microsoft.com/kb/278835

Safari 5 for Mac: http://docs.info.apple.com/article.html?path=Safari/5.0/en/9277.html

Opera: http://help.opera.com/Linux/10.50/en/cookies.html

Microsoft Edge: https://support.microsoft.com/en-us/microsoft-edge/delete-cookies-in-microsoft-edge-63947406-40ac-c3b8-57b9-2a946a29ae09