Version 5.0
16 April 2025
1. INTRODUCTION
Forseti Services Limited, which hereafter will also be referred to as the "Operator", " Controller", or "We", is a company incorporated in Malta. This privacy notice describes how We collect, use, share and any other processing activity applicable to the players and visitors that visit our website.
We values and respects the privacy of our players and visitors and we are committed to maintain the confidence and security of our players and visitors’ Personal Data.
2. THE PURPOSE
The purpose of this privacy notice is to inform you of the methods and purposes of how we process your Personal Data (or hereinafter also referred to as ‘’Data’’) whilst using the Website and to inform you of your rights when it comes to the processing of this Data.
By agreeing to this privacy notice, you confirm that you understand and agree to the use of your Data as set out in this privacy notice. If you do not agree to the terms of this privacy notice, please do not use the website or share your Data with us. This privacy notice should be read together with our terms and conditions.
We may periodically make changes to this privacy notice and will inform you of these changes by posting the modified terms on the Website. We may also inform you personally about important changes in this privacy notice when required. You are encouraged to regularly visit this privacy notice to stay up to date on information regarding the processing of your Data..
3. WHAT TYPE OF PERSONAL DATA DO WE COLLECT?
3.1 The Data you provide us. We collect your Data primarily from the registration form when you register as a player on our website.
The Data we collect via the registration form includes:
a) First name
b) Middle name (optional)
c) Surname
d) Date of Birth
e) Email address
f) Telephone or mobile number
g) Occupation
h) Industry
i) Job title
j) Biometric data, Photographic identification and proof of address for due diligence checks
k) If you attest that you are a Politically Exposed Person (“PEP”) the Head of an International Organization (“HIO”), or a family member or a close associate of a PEP or HIO, as those terms are defined in the Terms and Conditions, you will be required to provide additional information such as your source of funds, your source of wealth.
l) Banking and Financial details and any supplementary documents required by law to establish the source of funds.
m) Residential address.
3.2 Through the use of our services, we may collect the following personal information:
a) Records of correspondence (this can be via email, telephone, mobile or other means of communication).
b) Documents you provide.
c) Any information you provide via the Website or email.
d) Information about the transactions you carry out on the Website.
e) Information about your visits to the Website traffic data, location data.
f) Information about any devices you may have used to access our Services (define this)
g) Information about how you, interact with our website.
h) To prevent fraudulent or criminal activity, we may also collect the player’s financial information from other online gaming sites, banks, credit card companies and other fraud prevention agencies.
i) From which location you are accessing the service.
3.3 The Information we receive from third parties.
a) The information that is collected from you may be combined with other information we receive from third party sources such as public data bases.
b) We may use third party data about you, from
Facebook feeds to provide more effective personalization.
Google used by Google Analytics to collect data on the number of times you have visited the website as well as the date of the first and last visit. It is used to understand how you, the visitor navigates around the website.
Microsoft is used for internal analysis. It collects behavioural data from multiple websites, in order to present more relevant advertising. This allows the website to limit the number of times the same advertisement is shown, it collects track FTDs and registrations for campaigns, ads and keywords in Microsoft Ads interface.
c) Data received from our business partners.
4. WHY DO WE PROCESS YOUR DATA?
a) It allows us to identify you.
b) It is essential for providing you with the services and products that you want.
c) It is used to personalize and improve your experience when you are using our services.
d) To comply with the law.
e) To contact you with important information.
5. WHERE DO WE STORE YOUR DATA?
We store all game data on a server in the European Union.
We store your Data for a period necessary for us to fulfil the purposes set out in this privacy notice unless a longer storage period is required or permitted by law.
Generally, your Data is stored for at least the entire duration of our relationship, and as required by the licensing authority. Accordingly, your Data will be stored for at least five years after the closure of your account (if applicable) or the last contact with us from you. Where it is no longer necessary for us to process your Personal Data, we will delete it.
6. WHO DO WE SHARE YOUR DATA WITH?
6.1 Sharing your personal data with our group companies.
We will share your Personal Data with the companies forming part of our (i.e the Controller’s) group of entities.
We share your Personal Data within our group of companies for the following purposes:
1. To fulfil our legal obligations to the licensing and regulatory authorities, in addition to fulfilling our obligations under applicable laws and relevant authorities in other jurisdiction. This includes the sharing of your identification and verification data, transaction and usage data, registration data, contact data and self exclusion data are for the purpose of compliance with licensing, regulatory and legal requirements.
2. To enable us so we can provide help and support in relation to gambling problems and addictions
3. To respond to any of your data protection requests
4. To manage payouts and process payment related requests
5. To administer offers and promotions
6.To establish, exercise and defend our legal rights.
7. To investigate, prevent and prosecute offences
8.To provide you with customer support assistance
9.To defend your rights, your safety, the safety of others and to investigate fraud and any related government/regulatory request
10. To provide offers and promotions. In this case, we share your Personal Data with our sister company, Glitnor Marketing Limited which will process your data to provide you with promotions.
11. To provide secure access to our platform and for the maintenance our website.
When you consent to receive marketing, you agree to receive promotional communications from Forseti Services Limited and our subsidiary Glitnor Services Limited, which is licensed by the Malta Gambling Authority. You can withdraw your consent at any time by contacting customer support or by using the unsubscribe link in our emails.
6.2 Sharing your personal data with our service providers.
We may share your Personal data with processors who provide services on our behalf. These processors will only handle your Personal data in accordance with this Privacy Notice, and we have and we will continue to have contractual agreements in place to ensure your data is handled in line with the applicable Data Protection Laws.
In order for us to comply with applicable legal and regulatory obligations which include combatting of money laundering, checking your identity, protecting our Website from illegal use and monitoring your behaviour on our Website and any other activity which is necessary for us to meet our obligations.
We may also disclose your Personal data to third parties that provide services to us in connection with the operation of our Website, this includes, credit reference agencies, payment service providers, banks, financial institutions, and similar third parties.
6.3 We share your Personal Data with third parties in the following circumstances:
a) With service providers that provide services on our behalf. This includes companies that provide the following services.
- Process payments
- Advertising
- Technology
- Data storing
- Security
- Analytics
b) With external auditors to carry out the required independent checks.
c) When we are ordered to do so by any legal provision or regulatory authority.
d) To establish, exercise or defend our legal rights.
f) Whenever we have a legal obligation to do so, we may also share your personal data with authorities.
g) In connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our shares and/or assets or other corporate change.
Some of the parties we share your Data with may be located outside the EU and the European Economic Area. When we transfer your data outside the EU or the European Economic Area. Any data transferred outside the EU and European Economic Area, will be transferred in accordance with the General Data Protection Regulation (GDPR) and any other applicable laws and guidelines.
We use appropriate safeguards to ensure that the necessary level of data protection is maintained.
7. MARKETING
We will keep your marketing preferences on record for the duration of our data retention period, unless you choose to update them. If you close your account and your preference is still set to opt in, we may continue sending you marketing communications. To stop receiving these, please update your marketing preferences.
8. SECURITY MEASURES
We have implemented technical and organisational measures to protect your Data from loss, manipulation and unauthorised access. Security measures include, but are not limited to, digital and physical perimeter protection, asset management, access control and operational security controls. While we will use all reasonable endeavours to keep your Data safe and secure at all times, you should note that security can never be guaranteed, and we may not be liable to you unless your security is compromised due to our negligence.
9. Cookies
Cookies are small text files that are stored on your computer by your browser. They are used for many things, such as remembering if you have visited the site before, to access your account - or to help us find out how many new site visitors we get each month. They contain information about the use of your computer. Cookies cannot harm your computer and do not contain viruses.
9.1 How do we use your cookies?
The Operator uses cookies to improve your experience on this website. We want to inform you about a few things about our cookies:
· Functional cookies: used because they are important for the website to function properly.
· Analytical cookies: to help us understand which content is most useful to our visitors. We track website traffic patterns to identify popular website content and potential website issues.
· Marketing cookies: we use these cookies for advertising purposes.
· Security: These cookies allow us to secure access to your account.
· Preference: These cookies are used to store your preferences.
9.2 Third Party Cookies
Social sharing and other services we offer are operated by other companies. These companies may drop cookies on your computer when you use them on our website or if you are already logged in to them. See their specific cookie notice for more information.
The third parties we work with are Facebook, Google Ads, Bing Ads and My Affiliates.
9.3 Advertising
By accepting the cookie notice, you allow us to store third-party cookies for tracking purposes using an external service. This can be used to target you when you use online services such as Facebook, Twitter or Bing ads.
9.4 Your choices regarding cookies
You can choose to have your computer warn you every time a cookie is set, or you can choose to turn off all cookies; you can do this through your browser settings. Each browser is slightly different, so look at your browser's 'Help Menu' to learn the correct way to change your cookies. If you turn off cookies, you will not have access to many functions that make your experience more efficient and some of our services will not work correctly. Blocking or removing cookies from the website will prevent you from using the website, as it significantly degrades the functionality of the website.
9.5 Other Affiliated Websites
Where there is a link from the website to another relevant page, this privacy notice will cease to apply when you leave the site.
9.6 Your right to object to the processing of Personal Data.
You have the right to object at any time to the processing of your Data for direct marketing.
To the extent that the processing of your Personal Data is based on our or a third party's legitimate interest, you have the right to object to the processing for reasons relating to your particular situation. .
You have the right to object at any time to the processing of your Data. By doing so, you are instructing us to close your account, which will prevent you from accessing your account. We will store your data for as long as the licensing authorities require.
You can exercise your right to object to data processing by contacting our customer service.
10.0 WHAT ARE YOUR RIGHTS?
· Right of Access. You have the right to obtain information about the Personal Data collected for processing, and the right to obtain a copy of such data
· Right to Rectify. You have the right to ask us to rectify inaccurate Personal Data and to complete incomplete Personal Data concerning you. We may seek to verify the accuracy of the data before rectifying it.
· Right to Erasure. You have the right to ask us to delete the Personal Data and we shall comply without undue delay provided that we have no legal ground to process your Personal Data. We will not be legally bound to comply with the erasure, if the processing is necessary for compliance with a legal obligation to which we are subject or for the establishment, exercise or defence of legal claims.
· Right to Data Restriction. You are also entitled to us restricting the processing of your Personal Data when you e.g. awaiting our response to your access or deletion request.
· Right to Data Portability. You have the right to ask us to provide your Personal Data (which you shall have provided to us) to you in a structured, commonly used, machine-readable format, or (where technically feasible) to have it 'ported' directly to another data controller, provided this does not adversely affect the rights and freedoms of others. This right shall only apply where:
The processing is based on Your consent or on the performance of a contract with You; and
The processing is carried out by automated means.
· Right to Object to Certain Processing. If we process your Personal Data for our legitimate interests—or those of a third party, you have the right to object to such processing.
Additionally, if your data is processed for direct marketing purposes, you may object at any time, including to any profiling related to such marketing.
However, to clarify, this general right to object does not apply when we process your Personal Data to fulfill a contract, comply with a legal obligation, or protect your vital interests or those of another individual.
· Right to withdraw your Consent. When we process your data on the basis of consent, you have the right to withdraw your consent at any time. To withdraw you consent please contact our Customer Service or our Data Protection Officer (‘’DPO’’) via [email protected]
· Right to lodge a Complaint. You also have the right to file complaints with the relevant Data Protection Supervisory Authority. As our primary EU establishment is in Malta, our Lead Supervisory Authority is the Maltese Information and Data Protection Commissioner (IDPC). While you may contact the competent authority at any time, we kindly ask that you first attempt to resolve any concerns directly with us.
When you contact us to exercise your rights, we may need to request specific information to verify your identity and confirm your right to access your personal data (or exercise any other rights). This security measure helps prevent unauthorized disclosure of your Data. Additionally, we may reach out for further details regarding your request to expedite our response.
Our contact details:
FORSETI SERVICES LIMITED (company no. C 101070)
Level 8, The Centre, Tigne Point, Sliema TPO0001, Malta
If you wish to exercise your rights or if you have further questions regarding how we process your Data, please contact our DPO by sending an email to [email protected]