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icon1.Introduction
icon2. Information about us
icon3. What data we process
icon4. Purposes and Legal Bases for Data Processing
icon5. Recipients of Your Data
icon6. Data Retention Duration
icon7. Your Data Subject's Rights
icon8. The Right to Lodge a Complaint with the Supervisory Authority
icon9. International Data Transfers
icon10. Processing of Children's Data
icon11. Third-Party Websites
icon12. Changes to this Policy
icon13. Languages of this Policy
icon14. Contact us

Privacy Policy

1.Introduction

This Privacy Policy (hereinafter the “Policy”) outlines the processing of your personal data (referred to as “data”) when you visit or use the website http://primewin.com (hereinafter the “Website”) or communicate with the Website's administration through available contact details.

2.Information about us

The Website is owned by controller PrimeWin N.V., a company registered and established under the laws of Curaçao, with registration number 165439 and registered address at Zuikertuintjeweg Z/N (Zuikertuin Tower) Curaçao, and its wholly-owned subsidiary, PrimeByte Solutions Ltd, registered in Cyprus with registration number HE455186 and registered address 6 Othonos, Strovolos, 2008, Nicosia, Cyprus. PrimeWin N.V. is licensed and regulated by Gaming Services Provider N.V. (license no. 365/JAZ), (hereinafter be referred to as the "Company," "We," "Us," or "Our.")      

You can contact us for any issues related to data processing via email at [email protected].  

3.What data we process

Contact Data. When you communicate with us via the Website's interface or using the provided contact details, you provide us with the following data:

  • Your contact details, which may include your postal address, email address, and phone number.
  • Your name.
  • All information you provide during our communication.
  • Additionally, we record the history of your communication with us, including audio call records (e.g., when communicating via audio with our Support team).

Account Data. When you create an account on the Website, you provide us, in addition to your Contact Data, with the following:

  • Your name.
  • Your gender.
  • Your birth date.
  • Information about activated coupons.
  • Your username (if applicable).
  • Your Skype account.
  • Additional data, if applicable.
  • If you have excluded your account from gambling for a specific time period or blocked your account permanently, we will also have this information recorded.

Newsletter Consent Data. We collect data on whether you have consented to receive our Newsletter.    

Referral Data. We collect data about your referral, whether it's a referral user or a referral affiliate.    

Bets Data. These data encompass information about the bets you have placed, the outcomes of those bets, games you have played, and details on total winnings and losses, among other relevant information.    

Verification Data. During the Verification process, you will be required to provide us with the following data:

  • A copy or a photo of your identification document.
  • A photo of your payment instrument or other evidence confirming your status as the holder of a payment instrument used or intended for transactions.
  • A photo of yourself.
  • A photo of you holding your identification document and payment card.
  • Confirmation of your address, which may include a utility bill, telephone bill, or other documents satisfying legal and regulatory requirements in your jurisdiction.
  • Confirmation of the source of your wealth and funds (in certain situations).
  • The record of your video calls/audio calls with the Website's administration (if Verification is conducted via audio/video call).
  • During Verification, we cross-check certain users against state registers, politically exposed persons databases, and other reliable sources, collecting additional data as needed.

Payment Data. The Website utilizes SSL encryption to guarantee the confidentiality of your information during data transmission. All payment operations are conducted exclusively through the secure server of the payment gateway. While we prioritize security, we may store your deposit and withdrawal history, along with limited payment information such as the last four digits of your credit card, bank issuer, etc.    

Loyalty Program Data. For frequent users of the Website, our Loyalty Program is designed to enhance user experience. The data generated within this program include:

  • Points earned.
  • User level.
  • Cashback amount.
  • Other relevant data processed within the Loyalty Program.    
     

Bonus Data. We process data related to your use of bonuses within the Bonus Program, including but not limited to:

  • Information about the bonuses you have utilized.
  • Your Bonus balance.

Automatically Collected Data. When you use the Website, certain data are automatically collected. These data, obtained from your web browser, are then analyzed by us and include:

  • Total time spent on the Website.
  • Internal links clicked (based on the URL of the next pageview).
  • Your IP address and user agent string (indicating the browser, version, and operating system in use).

Cookies Data. Cookies may collect data falling within the definition of "personal data." For more information about cookie usage, please refer to the cookie policy.

4.Purposes and Legal Bases for Data Processing

As part of our business operations, we collect, use, store, and transfer various types of personal data about you only when there is a lawful basis for such use. The most common lawful bases employed by us are:    

Consent. In specific instances, we may process your personal data solely upon obtaining your explicit consent.    

Execution of a Contract. To provide you with our services in adherence to the contractual terms between you and us, we necessitate the use of your personal data.    

Adherence to Legal Obligations.The nature of the services we provide compels us to gather and store specific data about you in conformity with the laws governing our operations.    

Legitimate Interests. On occasion, we leverage our legitimate interests to process your data, such as enhancing our services. However, we exercise this right only when such interests do not supersede your rights, interests, or fundamental freedoms.    

The subsequent table outlines the potential applications of your personal data and identifies the legal bases the Webpage employs to ensure lawful data processing:

PurposeType of dataLegal basis for processing

Administer and protect the Website:

  • To protect the Website from any cyberattacks (including, but not limited to DdoS attacks); 
  • To diagnose any problems with the Website or the server which makes the Website available.
  • Automatically collected data; 
  • Cookies data.
Legitimate interests of the Company in accordance with Article 6(1)(f) of the Regulation 2016/679 (hereinafter the “GDPR”). Administration and protection of the Website and the Server which makes the Website available are the legitimate interests of the Company
To create your account and provide you with the Services available on the Website. Without these data, we are incapable of creating your account on the Website and providing you with our Services.
  • Contact data;
  • Account data;
  • Bets data;
  • Payment data.
Performance of the contract in accordance with Article 6(1)(b) of the GDPR. These data are essential to open your account and without these data, we would not be able to conclude a contract with you and open your account on the Website.
To conduct Verification. We conduct Verification for the purposes of:    
a) compliance with applicable anti-money laundering and counter-terrorist financing legislation: from this follows that provision of Verification data is required by the law. Without these data, we would be incapable of complying with our legal obligation under the legislation mentioned above;    
b) prevention of fraud, cheating and violation of the Terms and Conditions of the Website. In some cases, we conduct additional verification (for example, via videocall) in order to prevent violation of our Terms and Conditions (which are a contract between you and us), cheating and fraud. From this follows that additional verification is the procedure required by the contract between you and us;    
c) prevention of the use of the Website by children. Without Verification, we would not be able to create your account (in some cases) or allow the continuation of operation of your account.
  • Any data concerning you we possess.
When Verification is conducted for the purposes of compliance with money laundering and counterterrorist financing legislation and prevention of the use of the Website by children: compliance with the legal obligation to which the Company is subject under Article 6(1)(c) of the GDPR;     
When Verification is conducted for the purposes of prevention of fraud and cheating: Legitimate interests of the Company in accordance with Article 6(1)(f) of the GDPR. Prevention of fraudulent activity and cheating is the legitimate interests of the Company;     
When Verification is conducted for the purposes of prevention of violation of the Terms and Conditions of the Website: performance of the contract to which you are party in accordance with Article 6(1)(b) of the GDPR. Our Terms and Conditions are the contract between you and the Company and your failure to pass the verification will be in breach of this document.
To comply with the requests from governmental authorities, courts and other similar bodies.
  • Any data concerning you we possess.
Compliance with the legal obligation to which the Company is subject under Article 6(1)(c) of the GDPR.
To contact you.     
We may contact you for various purposes:     
a) When you contact us via the interface of the Website or via contact details available on the Website and ask a question about our Website, the Company etc.;     
b) When you use the Website, you communicate with the Support Team and other staff of the Company who may be engaged in provision to you our Services, or solving of your problem(s) connected with your use of the Website;     
c) Additionally, we can use your contact data to communicate with you about changes in our Website, products, services, and documents/rules which affect you.
  • Contact data and any other data which we have about you (if required by the purpose of communication.
If you do not have an account on the Website and communicate with us about the general issues: Legitimate interests of the Company in accordance with Article 6(1)(f) of the GDPR. Communication with the general public is the legitimate interest of the Company;     
When we communicate with you in the course of your use of the Website, your account or our Services: performance of the contract to which you are party in accordance with Article 6(1)(b) of the GDPR. Without these communications, we would not be able to provide you with some functions of the Website and/or solve your problems that can arise during your use of the Website.
To comply with your data subject`s requests and other legal requests from you.
  • Any data concerning you we possess.
Compliance with the legal obligation to which the Company is subject under Article 6(1)(c) of the GDPR.
To exercise your self-exclusion. If you have decided to conduct self exclusion (to block or restrict your account for a specific time period or block your account permanently), we will use your data to conduct this self-exclusion
  • Verification data; 
  • Account data; 
  • Contact data; 
  • Payment data;
Performance of the contract to which you are party in accordance with Article 6(1)(b) of the GDPR.
To send you our Newsletter.
  • Newsletter consent data; 
  • Contact data.

 

Your consent given in accordance with article 6(1)(a) of the GDPR.
To improve the Website and its functionality:     
a) Testing new functions and features on the Website;     
b) Research and analysis.
  • Automatically collected data; 
  • Cookies data.

 

Legitimate interests of the Company in accordance with Article 6(1)(f) of the GDPR. Improvement and enhancement of the Website and the Services which are provided via the Website are the legitimate interests of the Company.
Provide you with the Website and with the Website tailored for your device and the settings installed on your device. Without Automatically Collected data and Cookies data, the Website may not work and/or may not work correctly. For example, if you disable cookies you will not be able to log in to the Website and we will not be able to remember your website choices (for example, the language of the Website).
  • Automatically collected data; 
  • Cookies data.
Legitimate interests of the Company in accordance with Article 6(1)(f) of the GDPR. Provision of the Website to its users is the legitimate interest of the Company.
To prevent violation(s) of our Terms and Conditions, cheating, collusion, use of the Website in bad faith and other similar activity.
  • Any data concerning you we possess.
Legitimate interests of the Company in accordance with Article 6(1)(f) of the GDPR. Prevention of violation(s) of our Terms and Conditions, cheating, collusion, use of the Website in bad faith and other similar activity are the legitimate interests of the Company.
To calculate commission to the referrer who has directed you to the Website.
  • Account data; 
  • Contact data;
  • Bets data;
  • Payment data.
Legitimate interests of the Company in accordance with Article 6(1)(f) of the GDPR. Calculation of the commission to the referrers is the legitimate interest of the Company.
To establish, exercise and defence legal claims. We may use your data in order to protect our legal interests in courts disputes, legal disputes etc.
  • Any data concerning you we possess.
Legitimate interests of the Company in accordance with Article 6(1)(f) of the GDPR. The establishment, exercise and defence of legal claims is the legitimate interest of the Company.
To facilitate your payments via the Website. Without your Payment data we will not be able to process your payment and, subsequently, provide you with the Services of the Website.
  • Payment data.
Performance of the contract to which you are party in accordance with Article 6(1)(b) of the GDPR.
To calculate your Website balance (both real and bonus).
  • Payment data;
  • Bonus data; 
  • Loyalty program data;
  • Bets data.
Performance of the contract to which you are party in accordance with Article 6(1)(b) of the GDPR.
To calculate your cashback.
  • Payment data;
  • Bonus data; 
  • Loyalty program data;
  • Bets data.
Performance of the contract to which you are party in accordance with Article 6(1)(b) of the GDPR.
To provide VIP support for some users. 
  • Payment data;
  • Bonus data; 
  • Loyalty program data;
  • Bets data.
Legitimate interests of the Company in accordance with Article 6(1)(f) of the GDPR. VIP support for some users is the legitimate interest of the Company.
To provide you with our Loyalty Program.
  • Payment data;
  • Bonus data; 
  • Loyalty program data;
  • Bets data.
Performance of the contract to which you are party in accordance with Article 6(1)(b) of the GDPR.

5. Recipients of Your Data

Your data may be shared with various entities, including our subcontractors, affiliated companies, and other establishments involved in maintaining and providing the Website and its services. The individuals employed by the Company or its affiliated companies, subcontractors, and other entities may have access to your data.    

It's essential to note that these data transfers are safeguarded by appropriate data transfer agreements. These agreements obligate recipients to process your data in compliance with this Policy and the applicable data protection legislation governing the Company.    

We enlist service providers for the following services:

  • Hosting the Website and data; 
  • Marketing services; 
  • IT services and security services; 
  • Customer support software service providers; 
  • Payment service providers; 
  • KYC, anti-fraud, and anti-money laundering services; 
  • Games providers; 
  • Audit, legal and compliance services.

Data Centre(s). The Website and its services are hosted on servers owned by a third party. Consequently, your data will be shared with these data centers. It's important to note that your data is stored exclusively in encrypted form, ensuring that it cannot be decrypted without the appropriate keys.   

Financial Institutions. Transactions for the services provided via the Website are processed by third-party financial institutions, including banks, payment services providers, and payment systems/gateways. Your data will be shared with them to facilitate transaction processing and fulfill their legal and regulatory obligations.   

Courier Companies. In the event of winning physical prizes, your data will be shared with courier companies responsible for delivering the winnings or prizes to you.   

Accreditation Bodies and Auditors. When the Company undergoes an independent audit, data related to you may be shared with accreditation bodies and auditors. These entities are legally obligated to handle your data in accordance with this Policy and applicable legislation.   

Analytics. We utilize data analytics services, including Google Analytics and Hotjar, to measure and understand our audience, tailor marketing services, and enhance the Website experience.   

Google Analytics. The Website uses Google Analytics, a web analytics service provided by Google LLC. Information generated by cookies about your Website usage is transmitted to and stored on Google servers in the USA. The Google Analytics Opt-out Browser Add-on allows users to prevent their data from being collected and used by Google Analytics. To install the add-on, visit: [Google Analytics Opt-out Browser Add-on](https://tools.google.com/dlpage/gaoptout?hl=en).

6.Data Retention Duration

For users with an account on the Website, we will store your data for a period of 6 (six) years from the date of closing your account and termination of our contract with you. Additional details regarding the retention of your personal data can be found in our FAQ section on data retention.

7.Your Data Subject's Rights

In accordance with applicable data protection legislation, you have rights that can be exercised by:   

a) Sending a request to our registered address.   
b) Sending a request to our email address: [email protected]   
c) Utilizing the interface of the Website (for certain functions).   

For further information on your rights and how to exercise them, please refer to our FAQ section or contact us via the provided channels.   

Please note that these rights are subject to certain restrictions:

  • Verification of Identity. We may verify the identity of a user/visitor before implementing any of the rights.
  • Restrictions or Denials. We reserve the right to restrict or deny the implementation of any rights based on applicable legislation. If a restriction or denial occurs, we will specify the reason in response to your request.

Your Rights Include:   
Right to Withdraw Consent. You can withdraw your consent to the processing of your data at any time. Withdrawal does not affect prior lawful processing.   

Right of Access. Obtain confirmation of data processing and receive a copy of the processed personal data.   

Right to Rectification. Obtain rectification of inaccurate personal data.   

Right to Erasure (Right "to be Forgotten"). Request the erasure of personal data under specific circumstances.   

Right to Object to Processing. Object to processing based on legitimate interests or for direct marketing purposes.   

Right to Restriction of Processing. Obtain restriction of processing under specific circumstances.   

The Right to Data Portability. You have the right to receive the data collected from you in a structured, machine-readable format and the right to transmit this data to another controller, which in simpler terms means another company. This right applies only to processing which: 

  • Was carried out by automated means; 
  • Is based on Articles 6(1)(a) and 9(2)(a) of the GDPR (consent) or is based on Article 6(1)(b) of the GDPR: processing which was carried out under the contract between you and us.

8.The Right to Lodge a Complaint with the Supervisory Authority

You have the option to contact us regarding any concerns or complaints about the processing of your data. If you have questions or issues, please reach out to us at [email protected], and we will respond promptly.   

If you are dissatisfied with our response or our handling of your personal data, you retain the right to lodge a complaint with a supervisory authority. This is particularly relevant in the country of your habitual residence, place of work, or where an alleged infringement has occurred. We encourage you to attempt resolution with us first before contacting the regulatory authority.

9.International Data Transfers

As our company operates globally, your data may be transferred to "third countries" under GDPR. We ensure such transfers through:

  • The European Commission's decision of adequate protection in the destination country.
  • When using service providers not subject to adequacy mechanisms, we implement additional safeguards, such as specific contracts approved by the European Commission.

For more details on the mechanism used for your data transfer, please contact us.

10.Processing of Children's Data

We hereby acknowledge that in collecting and processing your Personal Information for the purposes of managing your Player Account, we are bound by strict legal provisions on the protection of personal data.

Consequently, we endeavour to protect your personal information and respect your privacy in accordance with best business practices and applicable regulations. Being committed to providing secure services to players, and we will take all reasonable precautions to ensure that all the data that you have submitted to us remains safe.

Player Accounts can only be accessed with the player’s unique ID and password. You may also set up two-factor authentication (2FA) as additional protection from unauthorised use of your account. You are responsible for keeping your login information confidential and making sure it cannot be accessed by another person.

11.Third-Party Websites

The Website may include links to third-party websites. Visiting these links is at your own risk, and we hold no liability for the content or consequences of third-party websites. Before submitting any data, we recommend reviewing the privacy policies of these third-party websites.

12.Changes to this Policy

The Company reserves the right to modify this Policy. In case of changes, a revised Policy will be posted before taking effect, and registered users will be notified via email. Continued use of the Website implies understanding and acceptance of the updated Policy.

13.Languages of this Policy

This Policy was created in English, with other language versions provided for convenience. In case of discrepancies, the English version prevails.

14.Contact us

If you have questions or issues, please reach out to us at [email protected], and we will respond promptly.

Last updated: 23.04.2024
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PrimeWin N.V., Zuikertuintjeweg Z/N (Zuikertuin Tower), Curaçao
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License Copyright © 2024 www.primewin.com is owned and operated by PrimeWin N.V., a company registered and established under the laws of Curaçao, with registration number 165439 and registered address at Zuikertuintjeweg Z/N (Zuikertuin Tower) Curaçao, and its wholly-owned subsidiary, PrimeByte Solutions Ltd, registered in Cyprus with registration number HE455186 and registered address 6 Othonos, Strovolos, 2008, Nicosia, Cyprus.PrimeWin N.V. is licensed and regulated by Gaming Services Provider N.V. (license no. 365/JAZ).