Version: 11-2022
Last update: 02.11.2022
1. GENERAL
The scope of this privacy policy is to help you know your rights.
As a data controller, we have a legal obligation under gambling regulations to process personal data from players in order to allow them to participate in games and provide them with ancillary services. This Privacy Policy explains what personal data we collect from players, why we collect it and how we use it.
The website www.casinotogether.com ("Casino", "Website", “Company”, "We", "Us", "Our") is owned and operated by Tsokel N.V., a company registered and established under the laws of Curaçao, with registration number 152125 and registered address at Abraham de Veerstraat 9, Willemstad, Curaçao. Tsokel N.V. is licensed and regulated by the Government of Curacao (license 365/JAZ).
If you have any other questions regarding this Privacy Policy or protection of your data, or if you are unhappy with the way in which we have processed your personal data, please feel free to contact our Data Protection Officer at dpo@casinotogether.com
By registering a Player Account with the Website you confirm your consent with this Privacy Policy. If you do not agree with the terms of this Privacy Policy and do not wish to provide us with the personal information we require, please do not use this website.
Please note that this Privacy Policy constitutes an agreement between you and the Company. We may periodically make modifications to this Policy. You will be required to agree to such changes by reconfirming your acceptance of this Privacy Policy when attempting to access the Website. While we will do our best to notify you of such changes, we recommend that you revisit this Privacy Policy regularly.
Any new change shall apply from the date we publish them.
Your continued use of the Website and/or its services will constitute your consent to the Privacy Policy.
This Privacy and Cookie Policy is incorporated into and forms part of CasinoTogether Terms and Conditions.
Please keep in mind that CasinoTogether is only open for Adult players (18+). We will use the data and documents you will provide in order to verify your age. Keep in mind that any use of any games or services shown on CasinoTogether is forbidden for anyone who is under 18 years old.
All references to “Player”, “end user”, “you”, “yours” and/or “your”, in this Privacy Policy refers to any user which accesses and plays on CasinoTogether.
Any reference to “Games” or “Game” in this Privacy Policy refers to the gaming products offered on CasinoTogether.
“The data controller” is a person, company, or other body that determines the purpose and means of personal data processing (this can be determined alone, or jointly with another person/company/body)
“Data processor” is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
“Personal Data” are any information which are related to an identified or identifiable natural person
“GDPR” or “the Regulation” – General Data Protection Regulation (2016/679)
Any presentation of this Privacy Policy in a language other than in English is a mere translation, provided for convenience only, and the English language version of Our Privacy Policy will always take precedence.
The Personal Information which we may request to use and process shall include, without limitation:
a) Any of the information that you provide to us when filling in the forms on our account registration pages, entering any competition or promotion, communicating with our Customer Support team and/or when you report a problem with Our Website, as well as any other data that you further submit via the Website or email (e.g. first and last name, date of birth, email address, phone number);
b) Correspondence made with us via the Website, email, web chat or through other means of communication;
c) All Player Account transaction history, whether this takes place via the Website(s) or via other means of communication;
d) Website logins and their details, including traffic data, GeoIP location data, browser/device data, weblogs, activity logs, time of access, date of access, games played, session times, play limits set, language, software crash report and other traffic information recorded in our system;
e) Documents and proofs reasonably requested by us to verify your account, to process deposits or withdrawals and to conduct 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 that we may carry out from time to time. Any information provided to us will be provided based on your consent. You may wish to revoke your consent at any time. By agreeing to participate in the survey, you agree to provide us with any such required information.
We will also keep account balance information (total, real and bonus balance, bonuses, reserved bets, maximum balance, deposits, withdrawals, average deposit and bonus, income) as well as game analytics (free rounds, recently played games, favourite provider, most played, biggest win)
You have the right to set limits on your account, in order for us to help you in this process we will process your decision in regards to the self-imposed such limits (deposit limits) – what we call “limit data”; you also have the right to self-exclude yourself or freeze the account for a set period of time (please know that you will not be able to access your account until the self-exclusion period has passed).
We will request and process Know Your Customer (KYC) information in line with our legal requirements and our Terms & Conditions mentioned on the website. These are requested on a case to case basis, they include but are not limited to : Bank statements, Valid ID, Utility bill, PEP status, Source of wealth or source of funds.
In order to provide you with the best gaming experience, we will collect and use technical data, including but not limited to: IP address (the address used to connect your computer to the internet) and device, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; Information about your visit including the full Uniform Resource Locators (URL), games you played and duration of each game and page, page interaction information (“Usage Data”); Information received from cookies including details of your visits to this site for traffic overview, games you played, duration on each game and in general your behaviour on the website. This information is collected in line with our cookies policy (“Cookie Data”) and your preferences as expressed in the cookie banner on our website.
We will not collect or process any kind of sensitive data, including but not limited to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union memberships, health data, data concerning an individual’s sex life or sexual orientation;
Public sources data that is publicly available information from Third Parties or Publicly Available Sources, usually via Google searches, when required for us to use it to be in line with our legal requirements.
The collection, storage, use and disclosure of your personal data, including Personal Information, is undertaken pursuant to any and all applicable laws, and industry best practice generally.
We process the Personal Information we collect from you in order to deliver our services. In particular, we will use your data for the following purposes:
a) Processing your bets and transactions. This includes your use of credit card and online payment systems;
b) Providing you with gaming and other ancillary services that you seek from our Website;
c) Rendering customer support, such as assistance with setting up and managing your account;
d) Identifying and performing the necessary verification checks;
e) Providing registered players with information about our promotional offers, or providing promotional information from our selected business partners, associates and affiliates (only if players specifically consented to receiving such marketing material);
f) Complying with legal responsibilities, including complying with anti-money laundering (AML) and combating the financing of terrorism (CFT) laws (Your personal data will be processed automatically with the aim of evaluating certain personal aspects : profiling) ;
g) Monitoring and investigating transactions for the purposes of preventing fraud, terms abuse, money laundering and other illegal or irregular gaming activities;
h) Analysing customer trends through market study assessments (participation in surveys is not obligatory and you can always choose not to take part, there will be no detriment towards you for not participating in such survey and contests). Survey information will be used only for purposes of improving the use and customer satisfaction of the Site;
i) Conducting research and statistical analysis of aggregated data.
Registering you as a user to create your account.
Performing our obligations arising from the Terms and Conditions including contacting you where contact is necessary to perform our obligations towards you.
Our legitimate interest to see how customers use our products in order to develop them and to grow our business and form our marketing strategy and to deliver relevant website content and advertisements to users.
Our legitimate interests to use data analytics to improve our website, products and services, customer relationships and marketing strategy and to define types of customers for our products, to keep our website updated and relevant, and to develop our business.
Notifying you of changes to this Privacy Policy in line with our obligations under GDPR.
Complying with our legal obligations under gaming laws for the allowance of the setting of player limits and processing of data to ensure that player and website do not exceed set limits.
Complying with our legal obligations under gaming laws for the allowance of the setting of self-exclusions and processing of data to ensure that player and website abide by such exclusions.
Complying with our legal obligations under anti-money laundering and gaming laws to verify your identity and establish source of wealth, source of funds and politically exposed person status.
CasinoTogether will also use and study your Usage Data, Technical Data and Account Data to target marketing activities for persons of the same age as you, if marketing consent is provided. This activity includes the processing of your age. We consider this to be in our legitimate interests to develop our products, form our marketing strategy, deliver website content and advertisement to users, to keep our website updated and relevant and overall to provide a better customer experience to our players. You have a right to object to such processing
We will further process your IP address in order to confirm your location, in line with our verification requirements under anti-money laundering laws, and to ensure that you do not have multiple accounts on our website in line with our obligations under gaming laws.
Please know that CasinoTogether is using payment gateway providers, so no credit card or bank account information (other than the one you provide us for KYC verification purposes, and that CasinoTogether will process in order to comply with legal obligations) will be processed on our side.
Carry out Our obligations pursuant to any contracts entered into between you and Us and to provide you with the information, products and services that you request from Us;
Provide you, or permit selected third parties to provide you, with information about goods or services We feel may interest you;
Notify you about changes to Our service;
and to ensure that content from Our Website is presented in the most effective manner for you and for your computer/device.
4. MARKETING COMMUNICATION
Unless you have elected not to receive promotional materials, we may use your Personal Information, including your email address and phone number, to send you marketing communications regarding products, services and promotions. This may include information about products and services from our business partners, such as casino game providers.
We will usually inform you (before collecting your data) if We intend to use your data for such purposes or if We intend to disclose your information to any third party for such purposes.
Whenever you decide to stop receiving such marketing and advertising material, you may opt out of this in your Player Account settings or by contacting our customer support at support@casinotogether.com.
Withdrawal of consent does not affect the lawfulness of the processing of any data which was carried out by Us, or on Our behalf, prior to Your consent being withdrawn.
Additionally, note that by accepting any contest prize or winnings from us, you consent to the use of your name and/or nickname for advertising and promotional purposes without additional compensation, except where prohibited by law.
We shall not collect any Personal Information about you without your knowledge. We may, however, 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 lawfully receive certain Personal Information from online vendors and service providers, such as fraud prevention companies. In addition, we retain the right to engage the services of third-party providers to render technical support, so as to process your online transactions and source gaming content.
Please understand that we may be granted access to any information you may provide to such vendors, service providers and third-party e-commerce services. Rest assured that we will use and safeguard any Personal Information so obtained, as set out in this Policy. Any information that you provide will only be disclosed to third parties outside the Company in accordance with this Privacy Policy, and we shall take any necessary steps to ensure that our agreements with third-party service providers always protect your private information.
6. DATA RECIPIENTS
We may pass information that you have given us to other entities within our group of companies and to our business partners. These companies include our parent companies, their parent companies and all of the 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.
Employees of the Company, more specifically Data Protection Officer, Money Laundering Officer, Payments & Anti-Fraud analysts, Customer Support agents, Customer Retention team members, VIP player managers as well as other selected employees, shall also have access to your Personal Information for the purpose of executing their duties and providing you with assistance.
The data that We collect from you will be transferred to, and stored in locations other than the jurisdiction/territory in which you reside, and will be processed by individuals who work for Us or for one of Our suppliers.
Our employees who have access to, or are 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.
External service providers and third-party vendors. We shall only disclose the personal data which is necessary for such third parties to deliver the required service. These include: MaxMind (provides IP intelligence to locate visitors and show them relevant content and ads, perform analytics, enforce digital rights and efficiently route internet traffic); Customer.io (email newsletter platform); Payment IQ (payment getaway provider); Professional advisors including lawyers, compliance officers, auditors and insurers;
In order to provide you with an efficient service, we and/or our service providers might require transferring your personal data from one country to another in the European Union (EU) and European Free Trade Association (EFTA) regions and also to some data processors that may be based outside of the European Economic Area (EEA). Therefore, by browsing the Website and communicating electronically with us, you acknowledge and agree to our (or our suppliers or sub-contractors) processing of your data in these countries. We shall always use our best efforts to ensure that your information and data is treated securely and in accordance with this Privacy Policy.
If processors from outside the EU countries are used, CasinoTogether will make sure that all data processors used are audited and found to be compliant to the European Data Protection standards.
Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others.
Analytics and search engine providers that assist Us in the improvement and optimisation of Our Website; and credit or reference agencies for the purpose of verification of your personal information where this is a condition of Us entering into a contract, or maintaining a relationship, with you.
7. RELEASING DATA TO THIRD PARTIES
We do not sell or rent your personal data to third parties.
We may disclose your personal information if required by law, regulation, or other legal subpoena or warrant. We may also disclose your personal information to a regulatory or law enforcement agency if we believe it to be necessary to protect the legitimate interests of the Company, its customers or any third party.
Personal data will only be disclosed to third parties in the following cases:
a) Where we are required to do so by law;
b) If the Website needs to share data with its payment processors to facilitate payment transactions in accordance with their privacy policies. (In particular, most banking card transactions are processed by Wirecard Bank AG whose privacy policy applies to such transactions);
c) To comply with our legal and regulatory duties and responsibilities to the relevant licensing and regulatory authorities as well as all duties and responsibilities owed under any other applicable legislation and to any other applicable regulators in other jurisdictions;
d) When the Company believes that disclosure is necessary to protect the Company’s or the player’s safety, or the safety of others, investigate fraud, or respond to a government request;
e) If our marketing service providers require the data to carry out their tasks;
f) To any other third party with the player’s prior consent to do so.
A legitimate interest for the purposes of litigation or asserting and defending our legal rights and interests or if we are required to disclose the information in response to legal process (for example, a court order, search warrant or subpoena).
If we have been instructed by you to do so.
If we believe that CasinoTogether and its content is being used in the commission of a crime, including to report such criminal activity or to exchange information with other companies and organizations for the purposes of fraud or money-laundering protection
Where you are disputing payments or losses charged on your account, we shall disclose your KYC Data, Bank Account Data, Usage and Account Data to your bank to settle the dispute.
We use third-party data processors to process limited personal data on our behalf. Such service providers support the Website, especially relating to hosting and operating the websites, marketing, analytics, improving the websites, and sending email newsletters. We shall ensure that the transfer of the Personal Data to the recipient is compliant with applicable Data Protection Legislation and that the same obligations are imposed on the processor as is imposed on us under the respective Services Agreement.
Our websites may also include social media features (e.g. “share” or “like” buttons). Such features are provided by third-party social media platforms such as Facebook. Where data is collected this way, its processing is governed by the privacy policy of the respective social media platforms.
In addition to the above, we may also release personal data if we file for bankruptcy, or become insolvent, or acquire any new businesses. Should the Company undergo any changes to its structure such as a merger, acquisition by another company or a partial acquisition, it is most likely that our customers’ personal data will be included within the sale or transfer. We will, as part of our Policy, inform our players by email prior to affecting such transfer of personal data.
Please note our content may link to third party websites to provide relevant references. We are not responsible for such external content, which may contain separate privacy policies and data processing disclosures. Please check these policies before you submit any personal data to these websites.
By clicking on those links you may be directed to those Websites which are not under the control of Tsokel N.V. and will need to comply with those respective third party privacy policies. If you have any questions about how these other Websites use your information, you should review their policies and contact them directly.
8. DATA RETENTION
CasinoTogether is committed to respecting the purpose limitation, data minimisation and storage limitation principles as defined under GDPR.
As stated under our Terms and Conditions both, you and the Casino can decide to have your Player Account closed at any time. Following closure of your account, we will retain your personal data on record for as long as required by law. This data shall only be used should it be required by competent authorities in cases of enquiries regarding financial and fiscal records, fraud, money laundering or investigations into any other illegal activity.
We may also keep anonymized derivatives of your data to improve our content and marketing communications where no automated decision making is involved.
You are to note that due to anti-money laundering regulations in licensed gaming jurisdictions in the European Union, we are obliged to retain personal data of players submitted during registration and any data passed on during the operative period of a Player Account for a minimum of five years from last player transaction or account closure. Therefore, requests for erasure prior to the lapse of this period cannot be entertained.
