1. INTRODUCTION

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Thank you for visiting this website. Your privacy is important to Playgon Games Inc and our subsidiaries (together referred to as “Playgon”, “we”, “us” and “our”) and we respect the privacy of everyone who uses our website playgon.com including any subpages and mobile websites and applications (“Website”) and /or plays our online games (“Game(s)”) which are made available through various customers of ours (“Network Operator(s)”). In this document we refer the visitor/user of our Website or a player of our Games “you”.

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We are committed to protecting the privacy of anyone who visits our Website and uses our Games. This privacy policy (“Privacy Policy”) applies to all Playgon companies and sets out how we manage your personal data when you for example visit our Website, play on our Games, or send us an email. “Personal Data” means information about you which can be used, on its own or together with other information, to identify you as a person.
 

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2. WHAT INFORMATION WE COLLECT AND WHY

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• Information You Provide. We collect information that you voluntarily provide when you fill out forms on our Website (like subscription to newsletters and corporate information). The main purpose we collect this information is to manage our relationship with you and to be able to provide you with the requested information. We also keep emails from you and records of correspondence with you for us to be able to contact you and to respond to a question from you.

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• Information you provide to our Network Operators. We collect certain very limited information that you voluntarily provide when you sign up with a Network Provider and use the Games. The information that you provide is needed to operate or manage the Game that you have signed up to participate via one of the Network Operators. In certain jurisdictions it may also be a legal requirement for Playgon to collect such information to lawfully offer and operate the Games.

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• Information collected automatically from your device. We and our third-party service providers may collect information automatically from your device in a variety of ways, including:
   

  • Through your browser or device. Certain information is collected by most browsers or automatically through your device, such as your IP, device type, language and the Internet browser type you are using. We use this information to ensure that our services function properly.
     

  • Through your use of an app. When you download and use one of our apps, we may track and collect app usage data, such as the date and time the app on your device accesses our servers and the information and files that have been downloaded to the app.
     

• Information given by you or Network Operator. If you work for a Network Operator and have access to our customer administration tool we may save your work email, name, job telephone number and job title. The purpose is for us to be able to manage our relationship with the Network Operator you work for and to better support services relating to the Games.
   

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3. HOW WE USE YOUR PERSONAL DATA

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We will only process your Personal Data as described in this Privacy Policy. We use the information that we collect to operate our Website and the Games and to provide the services required by you, to respond to your questions, to fulfil all the regulatory requirements.

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As a few examples, the data held about you is used in the following ways:

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• To administer the Games You play, to keep track of financial obligations during the tournaments within the network of operators;
   

• Providing, maintaining, enhancing and personalizing the operation of the Game and analyzing how customers use the Game and Website;
   

• To know your preferences and to try to ensure that the content on the Website is presented in the most effective manner for you and your computer or mobile device;
   

• To send information about Playgon and newsletters to you. You can opt-out at any time from receiving any corporate related information.

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Also, in some cases we are using your personal information for research purposes, such as: to evaluate customer experience and identify how we can improve our Games, to prioritize our product features and improve product designs.
 

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4. HOW WE SHARE YOUR PERSONAL DATA AND WITH WHOM

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All personal information collected by Playgon is treated as confidential. We disclose entire or part of your data in the following limited circumstances.

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• If we are required by law. We will disclose your Personal Data as required by law and regulation as well as to maintain and protect the gaming licenses of Playgon.
   

• Our Playgon group companies, subsidiaries, employees, and independent contractors. We will disclose Personal Data to our Playgon group companies, subsidiaries, employees, and individuals who are our independent contractors that need to know the information in order to help us provide our services or to process the information on our behalf and also for administrative purposes, billing and tax and all other purposes.
   

• Third party vendors, business partners and advisors, etc. We will share Personal Data with third party vendors, Data Center services providers, business partners, external advisors and consultants, auditors, collaborators or other third parties who need to know information about you in order to provide various services to us or on our behalf, including performing analysis of our products or customer demographics and do market research that help us understand and enhance our Games and services surrounding the operation of the Games. We will only share Personal Data that is necessary for the third party vendor to provide the requested service. These companies will process the provided data under instructions of Playgon and in accordance with relevant data privacy laws.
   

• To protect rights and property. We will share account and personal information with companies, organizations or individuals when we believe in good-faith that access, use, preservation or disclosure of the information is necessary to meet any applicable law, comply with regulation, legal process or enforceable request; to enforce or apply our agreements; to investigate potential violations; to protect against harm to the rights, property or safety of Playgon, our users or the public as required or permitted by law. To the extent we are legally permitted to do so, we will take all reasonable steps to notify you in the event that we are required to provide your personal information to third parties as part of legal process.
   

• With your consent. With your explicit consent or at your direction we may share and disclose information you have authorized us to with third parties.

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We will not sell, rent, share or otherwise disclose Personal Data in any way that is contrary to the commitments made in this Privacy Policy. We will take all reasonable steps to notify you when and what information might go to third parties and you will be able to choose whether to share it or not.
 

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5. HOW LONG WE KEEP YOUR PERSONAL DATA

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We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy and we may keep it after we have stopped providing services to you in order to comply with our legal obligations and to resolve any disputes. For more specific information about data retention terms, please contact us at privacy@playgon.com. We may also keep anonymized derivatives of your data for business analytics purposes where no automated decision making is involved.
 

 

6. WHERE WE TRANSFER YOUR PERSONAL DATA

 

Playgon operates globally and we have employees, third party vendors and business partners both inside and outside of the European Economic Area (“EEA”). Your Personal Data may therefore be transferred to, stored at, and hosted on servers that are outside the EEA. We will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this document when transferring the Personal Data.

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7. HOW WE PROTECT YOUR PERSONAL DATA

 

We have appropriate technical and organizational safeguards to protect your Personal Data against accidental or unlawful destruction or loss, modifications, unauthorized use, disclosure or access, and all other unlawful forms of processing. However, Internet is not a completely secure environment we can’t guarantee that information you transmit via our Website or Games will not be accessed, disclosed, altered or destroyed by breach of any of our safeguards or otherwise. We will of course follow applicable rules and processes for notifying you if this should happen.
 

 

8. CHANGES TO THIS PRIVACY POLICY

 

We will occasionally make changes to this Privacy Policy. If we do, we will inform you by posting the changes on the Website and send you an email or message about the changes. We will also give you the opportunity to consent to these material changes. Changes will be effective upon the posting of the changes and your acceptance of the changes.
 

 

9. HOW TO CONTACT US

 

If you have any questions, complaints or comments about this document or our use of Personal Data contact us by email at privacy@playgon.com.

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10. YOUR RIGHTS

 

You may request, free of charge, information on the scope, origin and recipients of the stored data as well as the purpose of storage. You have the right to ask us to rectify, complete and delete your Personal Data and to port your data to another organization. You have the right to request additional information about the handling of your Personal Data. You also have the right to object to our processing of your data by in some circumstances such as profiling and, where we have asked for consent to process your data, to withdraw this consent. You can also contact a supervisory Data protection authority with the mention that Playgon's Lead Supervisory Authority is the Office of the Information and Data Protection Commissioner in Malta. There are exceptions to these rights, however. For example, access to Personal Data may be denied in some circumstances if making the information available would reveal personal information about another person or if we are legally prevented from disclosing such information. In addition, we may be able to retain data even if you withdraw your consent, where we are obliged by a legal requirement to process your data.

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11. ABOUT PLAYGON GAMES GROUP

 

The Playgon Group of companies work with digital entertainment, providing online gaming solutions to gambling operators. Below is a representative list of the Playgon companies that currently are part of this Privacy Policy.

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The parent company in our group is Playgon Games Inc (publ), a Canadian company with a registered address #1100 - 1199 West Hastings Street, Vancouver, BC, Canada V6E 3T5.

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GDFSI Malta Limited is incorporated in Malta with organization number C 77058 and registered address at Vault 14, Level 2, Valletta Waterfront, Floriana FRN 1914, Malta. GDFSI Malta Limited is responsible for your Personal Data ion for the purposes of the applicable European Union data protection law is and is in charge of the data collected on the Website and the Games.

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This Privacy Policy was last updated on 24 July 2020.

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© 2020 Playgon Games Inc. All rights reserved.