• PRIVACY
• INFORMATION COLLECTED
• MEANS OF COLLECTING AND PROCESSING DATA
• INFORMATION USE
• CERTAIN EXCLUDED DISCLOSURES
• ACCESS
• COOKIES
• Information placed on your device
• List of Our main cookies
• When do We use cookies?
• During the registration process
• On Our website
• Cookies allow Us to
• How can I refuse or opt out of cookies?
• Cookies
• Flash Cookies
• CONSENT TO USE OF ELECTRONIC SERVICE PROVIDERS
• CONSENT TO SECURITY REVIEW
• CONSENT TO USE OF ANTI-CHEATING SOFTWARE
• SECURITY
• PROTECTION OF CHILDREN
• INTERNATIONAL TRANSFERS
• THIRD-PARTY PRACTICES
• LEGAL DISCLAIMER
• MERGERS AND OTHER EVENTS REQUIRING TRANSFER
• CONSENT TO PRIVACY POLICY

1. PRIVACY

We are committed to protecting Your personal information. We have created this Privacy Policy to let You know what information We collect when You use Our Services, why We collect this information and how We use the collected information.

Please note that this Privacy Policy will be agreed between You and the Group being Entain together with its Group companies as defined in the Terms and Conditions of Use ('GVC','We', 'Us' or 'Our', as appropriate).

We may periodically make changes to this Privacy Policy and will notify You of these changes by posting the modified terms on Our Platforms. We recommend that You revisit this Privacy Policy regularly.

2. INFORMATION COLLECTED

We consider information that may be used to identify an individual, including, but not limited to, first and last name, date of birth, credit card information, home or other physical address, email address, phone number or other contact information to be Personal Information ('Personal Information'). You may be asked to provide Personal Information when You use Our website, register for an account or to use the Services. The Personal Information that We collect may include information such as: contact information (including telephone number), shipping information, billing information, transaction history, website usage preferences, and feedback regarding the Services. This information is held by Us on servers based in Gibraltar and elsewhere from time to time. In addition, when You interact with the Services, Our servers keep an activity log unique to You that collects certain administrative and traffic information including: source IP address, time of access, date of access, web page(s) visited, language use, software crash reports and type of browser used. This information is essential for the provision and quality of the Services. We do not collect Personal Information about You on the Services without Your knowledge.

3. MEANS OF COLLECTING AND PROCESSING DATA

We may automatically collect certain data as discussed above and receive Personal Information about You where You provide such information through the Services or other communications and interactions with Us. We may also receive Personal Information from online vendors and service providers, and from customer lists lawfully acquired from third-party vendors. In addition, We may engage the services of third-party service providers to provide technical support, process Your online transactions and maintain Your Account. We will have access to any information You provide to such vendors, service providers and third-party e-commerce services, and We will use the Personal Information as set out in this Privacy Policy below. This information will only be disclosed to third parties outside the Group in accordance with this Privacy Policy. We take steps to ensure that Our arrangements with third-party service providers and online vendors protect Your privacy.

4. INFORMATION USE

We use the Personal Information We collect from You to deliver Our Services, to provide customer support, to undertake necessary security and identify verification checks, to process any of Your online transactions, to assist Your participation in third-party promotions, meet certain business requirements and for any other purpose related to the operation of the Services. As such, We may share Your Personal Information with Our carefully selected partners (which will include any other parties which such partners have entered into data sharing arrangements with). Your Personal Information may also be used by Us to provide You with: (a) promotional offers and information regarding Our products and services; and (b) promotional offers and information regarding the products and services of Our carefully selected partners, in order to better provide You with a range of products and services and improved customer service. From time-to-time, We may request information from You via surveys or contests. Participation in these surveys or contests is completely voluntary, and, therefore, You have the choice of whether or not to disclose such information. Information requested may include contact information (such as name, correspondence address and telephone number), and demographic information (such as zip or postal code or age). By accepting any contest prize or winnings from Us, You consent to use of Your name and likeness for advertising and promotional purposes without additional compensation, except where prohibited by law. Unless You have elected not to receive promotional information, We may also use Your Personal Information (including Your email address and phone number) to provide You with information regarding Our products, services and promotions, including other gaming products (including online poker, casino, betting, backgammon and bingo services) and products and services from third parties carefully selected by Us.

5. CERTAIN EXCLUDED DISCLOSURES

We may disclose Your Personal Information if required to do so by law, or if We believe in good faith that such action is necessary to: (1) comply with any legal process served on Us, any of Our sites or the Services or in circumstances where We are under a substantially similar legal obligation; (2) protect and defend Our rights or property; or (3) act to protect the personal safety of users of the Services or the public. If, in Our sole determination, You are found to have cheated or attempted to defraud Us, the Group, or any other user of the Services in any way including but not limited to game manipulation or payment fraud, or if We suspect You of fraudulent payment, including use of stolen credit cards, or any other fraudulent activity (including any chargeback or other reversal of a payment) or prohibited transaction (including money laundering), We reserve the right to share this information (together with Your identity) with other online gaming sites, banks, credit card companies, for the purpose of research on the prevention of addiction, data can be made anonymous and passed on to the respective institutions and appropriate agencies.

6. ACCESS

You may 'opt out' of receiving any promotional communications either by choosing to opt out where such option is made available on Our sites or the Services or in an email You receive from Us, or at any time by sending an email, or by writing to Us at Customer Service, Suite 711, Europort Gibraltar, under company number 93313. In addition, You may contact Us at this address if You: 1) want to confirm the accuracy of the Personal Information We have collected about You; 2) would like to update Your Personal Information; and/or 3) have any complaint regarding Our use of Your Personal Information. If requested, We will (a) update any information You have provided to Us, provided that You provide evidence as We may reasonably require for such changes, or (b) mark any information to prohibit future use for marketing purposes. For the avoidance of doubt, nothing in this Privacy Policy shall prevent Us from retaining Your Personal Information where We are required to do so by law.

7. COOKIES

7.1. Information placed on your device

We may store some information on your computer, laptop, tablet or mobile device when you look at our sites, mobile sites or mobile apps. We use cookies, which are small text files that are stored on your computer or equipment when you visit certain online pages that record your preferences. We also use Local Shared Objects or 'flash cookies'. 'Flash cookies' are similar to browser cookies. They allow us to remember things about your visits across our sites but cannot access or use other information on your computer. We do not use flash cookies to remember or use directly identifying personal information about you such as your name or email address. We only use flash cookies across our own sites and no others. We use cookies and flash cookies to track use of Our sites. We also may use cookies and third party cookies to monitor traffic to the site, improve the Services and make it easier and/or more relevant for your use. We use flash cookies and third party cookies to help us to show you advertisements which are relevant to your interests based on your use of Our sites.

7.2. List of the main GVC cookies

You can find more information about the individual cookies we may use and the purposes for which we use them in the table below

1st Party

STRICTLY NECESSARY COOKIES

1st Party

3rd Party Cookies:With a 3rd Party cookie the tracking cookie is set and recorded by a 3rd Party

PERFORMANCE COOKIES

1st Party

FUNCTIONALITY COOKIES

1st Party

3rd Party Cookies:With a 3rd Party cookie the tracking cookie is set and recorded by a 3rd Party

ANALYTICAL COOKIES

3rd Party Cookies:With a 3rd Party cookie the tracking cookie is set and recorded by a 3rd Party

TARGETING & ADVERTISING COOKIES

3rd Party Cookies:With a 3rd Party cookie the tracking cookie is set and recorded by a 3rd Party

7.3. When do We use cookies?

1. 7.3.1. During the registration process
2. These cookies will hold information collected during Your registration and will allow Us to recognise You as a customer and provide You with the services You require. We may also use this data to better understand Your interests while online and to enhance Your visits to Our Platforms.
3. 7.3.2. On Our website
4. For visitors to Our website, We use cookies to collect information. Our servers use two different types of cookies:
5. A 'session-based' cookie: This type of cookie is only allocated to Your computer for the duration of Your visit to Our website. A session-based cookie helps You move around Our website faster and, if You're a registered customer, it allows Us to give You information that is more relevant to You. This cookie automatically expires when You close Your browser.
6. A 'persistent' cookie: This type of cookie will remain on Your computer for a period of time set for each cookie. Flash cookies are also persistent.
7. 'Analytical' cookies allow us to recognise and count the number of visitors and to see how visitors move around the site when they are using it. This helps Us to improve the way our sites works, for example, by ensuring You can what You are looking for easily.

7.4. Cookies allow Us to:

• Better understand Your preferences and offer You more relevant promotional offers.
• Distinguish You from other users of our sites, which help Us to provide You with a good experience when You browse our sites and also allows Us to improve our sites
• Identify Your preferences when customizing content or functionality for You.
• Confirm You are a registered user and save Your log-in details when accessing certain Services on Our website.
• Show you advertisements which are relevant to your interests based on your use of Our sites
• Collect statistics on the use of Our Services.
• We may also use cookies and web beacons to ensure that Our mailing tools are working properly.

7.5.How can I refuse or opt out of cookies?

7.5.1.Cookies

You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but, if You prefer, You can usually modify Your browser setting to decline cookies. The Help menu on the menu bar of most browsers will tell You how to prevent Your browser from accepting new cookies, how to have the browser notify You when You receive a new cookie and how to disable cookies altogether.

7.5.2.Flash cookies

You can modify your Flash Player settings to prevent the use of flash cookies. The Settings Manager of your Flash Player allows you manage your preferences. To disallow flash cookies from all third party content go to the 'Global Storage Settings' panel of the Settings Manager and de-select the check box labelled 'Allow third party flash content to store information on your computer' and close the Settings Manager. Alternatively you can also adjust your settings for specific websites you visit through the 'Website Storage Settings' panel which is also found in the Settings Manager.

If you are using an old version of Flash Player or older web browser, the Settings Manager may not be available to you. We recommend that you ensure that you refresh your Flash Player and browser to the latest available versions.

If You choose to decline cookies, You may not be able to experience all of the interactive features on Our sites.

Alternatively, you can visit http://www.aboutcookies.org/ in order to obtain information on deleting or controlling cookies. Please note that by deleting our cookies or disabling future cookies, you may not be able to access certain areas or features of our sites.

8. CONSENT TO USE OF ELECTRONIC SERVICE PROVIDERS

In order to play real money games on the Services, You will be required to send money to and receive money from Us. We may use third-party electronic payment processors and/or financial institutions ('ESPs') to process such financial transactions. By accepting this Privacy Policy, You expressly consent to Personal Information necessary for the processing of transactions being shared with ESPs, including, where necessary, the transfer of information outside of Your country. We take steps to ensure that Our arrangements with ESPs protect Your privacy.

9. CONSENT TO SECURITY REVIEW

We reserve the right to conduct a security review at any time to validate Your identity, age, the registration data provided by You and to verify Your use of the Services and Your financial transactions for potential breach of Our Terms and Conditions of Use and of applicable law. By accepting Our Terms and Conditions of Use You authorise Us, Our staff, agents and suppliers to use Your Personal Information and to disclose Your Personal Information to third parties for the purposes of validating the information You provide to Us in the course of using the Services, including, where necessary, the transfer of information outside of Your country. Security reviews may include but are not limited to ordering a credit report and/or otherwise verifying the information You provide against third-party databases. In addition, to facilitate these security reviews, You agree to provide such information or documentation as We may request. If You are resident in Germany, due to local laws We require that You read and agree to an additional statement which can be found here.

10. CONSENT TO USE OF ANTI-CHEATING SOFTWARE

Our software package - used to access and use the Services - contains certain features designed to detect use of automated programs that enable artificial (non-human) intelligence to play on Our site. Use of such 'bot' software programs violates Our Terms and Conditions of Use, where We deem it detrimental to other players. By installing Our software and using the Services, You consent to Our software performing the functions described in this section. Our software may perform any or all of the following functions in order to detect the use of illicit automated programs and ensure that We maintain a 'cheat free' environment for all users: (1) scan Your list of active software applications while You are using the Services; (2) scan Your list of active processes while You are using the Services; and (3) scan the files in Your Services and site-related program folders to ensure that only 'non-hacked' versions of Our software are being used. If any of the foregoing processes reveals a suspect application or process, Our software may scan the files associated with the suspect application or process and compile a composite mesh (i.e., a profile that characterizes the files associated with the application or process) to be matched against profiles for known illicit automated programs. Our software will not perform any random search of large portions of Your hard drive, equipment or files, and it will not transmit any information to Us or to any third party other than the information necessary to identify use of illicit automated programs as described above. Our software will not alter any files or information on Your computer or other equipment and will not interfere with the operation of any of Your applications. You may terminate use of Our software at any time by uninstalling Our software package.

11. SECURITY

We understand the importance of information security and the techniques needed to secure information. We store all of the Personal Information We receive directly from You in a password-protected database residing within Our secure network behind active state-of-the-art firewall software. Our Services support SSL Version 3 with 128-bit encryption. We take steps to ensure Our subsidiaries, agents, affiliates and suppliers also employ adequate levels of security.

12. PROTECTION OF CHILDREN

The Services are not intended for or directed at persons under the age of eighteen (18) (or the lawful age in their respective jurisdiction). Any person who provides their information to Us through any part of the Services represents to Us that they are eighteen (18) years of age (or the lawful age in their respective jurisdiction) or older. It is Our policy to uncover attempts by minors to access Our Services which may involve Us having to access and verify Your Personal Information. If We become aware that a minor has attempted to or has submitted personal information via the Services, We will not accept this information and will take steps to remove such information from Our records.

13. INTERNATIONAL TRANSFERS

Personal Information collected on the Services may be stored and processed in any country in which We or Our affiliates, suppliers, ESPs or agents maintain facilities. By using the Services, You expressly consent to any transfer of information outside of Your country (including to third countries that may not have been assessed as having adequate privacy laws). Nevertheless, We take steps to ensure that Our agents, affiliates and suppliers comply with Our standards of privacy regardless of their location.

14. THIRD-PARTY PRACTICES

We cannot ensure the protection of any information or images that You provide to a third-party online site that links to or from the Services or any information collected by any third party administering Our affiliate program (if applicable) or any other program, since these third-party online sites are owned and operated independently of Us. Any information collected by these third parties is not governed by this Privacy Policy but by the privacy policy, if any, of such third party. If You have questions about a third party's information practices, please read its privacy policy. We assume no responsibility or liability whatsoever for the practices, actions or policies of such third parties, and We are not responsible for the content or privacy practices of such online sites.

15. LEGAL DISCLAIMER

The Services operate 'AS-IS' and 'AS-AVAILABLE,' without liability of any kind. We are not responsible for events beyond Our direct control. Because of the complex and constantly changing nature of Our technology and business, We cannot guarantee nor do We represent that there will be error-free performance regarding the privacy of Your Personal Information, and We will not be liable for any indirect, incidental, consequential or punitive damages relating to the use or release of Personal Information.

16. MERGERS AND OTHER EVENTS REQUIRING TRANSFER

If We should ever file for bankruptcy, or become insolvent, or be acquired by a third party, merge with a third party, sell all or part of Our assets, or transfer substantially all or part of Our relevant assets to a third party, We are entitled to share the Personal Information and all other information You have provided through the Services to potential and subsequent business and merger partners. By agreeing to the standard Terms and Conditions of Use, you hereby give your consent to such transfer of this information.

17. CONSENT TO PRIVACY POLICY

By clicking 'Submit' or 'I agree' during the registration process or by Your continued use of the Services following the posting of this Privacy Policy (as applicable), You agree to this Privacy Policy. This is Our entire and exclusive Privacy Policy and it supersedes any earlier version. This Privacy Policy should be read in conjunction with Our Terms and Conditions of Use and any additional applicable terms posted on Our Platforms. We may periodically make changes to this Privacy Policy and will notify You of these changes by posting the modified terms on Our Platforms. We recommend that You revisit this Privacy Policy regularly.

ElectraWorks Limited is registered on the Gibraltar Regulatory Authority Data Protection Register.

Modified/Created 06 June 2016