Privacy policy

The introduction

This Privacy Policy (hereinafter the “Policy”) governs the processing of your personal data (hereinafter shall be also referred to as “data”) when you visit or use the website https://gigaspinplay.com/ (hereinafter the “Website”). In this Policy you can also find the information about the following:

• What data concerning you are collected when you use or visit the Website;
• For what purposes and under what legal bases these data are collected;
• How long these data will be retained;
• How can you exercise your data subject`s rights;
• Contact details of the supervisory authority to which you can address your complaints if you suppose that your data subject`s rights are violated;
• Other information in the frame of the processing of your data.

When this Policy applies?

This Policy applies in the following cases:

• When you use the Website;
• Communicate with us via available contact details.

Information about us

The Website is owned and operated by two data controllers: Beriston Limited, a company registered in the Republic of Cyprus, with its address: Prodromou, 75 Oneworld Parkview House, 3rd floor, Flat/Office 304, Nicosia, Cyprus, 2063; Registration number: HE 385830. All gambling services are licensed by Inextro B.V., (License No. 1668/JAZ). Address: Dr. M.J. Hugenholtzweg Z/N Heelsumstraat, E-Commerce Park Vredenberg, Curacao, Registration number: 146616, which is a parent company of Beriston Limited. These two legal entities are joint controllers as defined by Article 26 of the Regulation (EU) 2016/679 ("GDPR"), hereinafter shall be referred as the “Company”, “We”, “Us”, “Our”. You can contact us for any issue, including the data processing, by e-mail [email protected].

What data do we collect?

Contact data. When you communicate with us via the interface of the Website or via available contact details, you provide us with the following data:

• Your contact details: it may be your postal address/email address/phone number;
• Your name;
• All the information you provide us during our communication;
• Additionally, we record the history of your communication with us.

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

• Your name;
• Your gender;
• Your birth date;
• The information about coupons you have activated;
• Your username (if applicable);
• Your Skype account.

Additionally, if you have excluded your account from gambling for a specific time period or have blocked your account permanently, we will also have this information recorded.

Newsletter consent data. We collect the data on whether have you consented to receive our newsletter.

Referral data. We collect the data about your referral (referral user or the referral affiliate).

Bets data: information about bets you have made and on what outcomes, games you have played, and the total amount of winnings and losses and similar information.

Verification data. During the Verification process you shall 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 that you are a holder of a payment instrument used or intended to be used for making payments via the Website;
• A photo of you;
• A photo of you bearing your identification document and payment card;
• Your address confirmation. It may be a utility bill, telephone bill or other documents which, in accordance with your jurisdiction's legal and regulatory requirements, shall be enough to confirm your address;
• A photo of you holding a paper with the requested information written by hand (your e-mail used when registering an account, the date of photo request and confirmation code);
• The Confirmation of the source of your wealth and your funds (for so-called "Politically Exposed Persons");
• The record of your video calls/audio-calls with the Website`s administration (if applicable);

When performing Verification, we check some users of the Website in state registers, databases of politically exposed persons, and other reliable sources and collect additional data from them.

Payment data. The Company does not directly process your payments: they are processed by third-party payment providers. This means that we receive your Payment data from these payment providers. These include the following data:

• The information about your payment card or payment instrument (first six and last four digits and a name of the cardholder - first three letters of the name and last three letters of a surname or, in some cases, first three letters of the surname and last three letters of the name);
• Information about your transactions and the data which are necessary to identify transactions.

Automatically collected data. When you use the Website some data are collected automatically. They are collected with the use of Analytics providers and include Google Analytics, Hotjar, and Yandex Metrika (please read more about these Analytics providers in section “Recipients of your data”). The data collected with the use of these Analytics providers include the following data:

• The total time you spend on the Website;
• The time you spend on each page and in what order those pages were visited;
• What internal links were clicked (based on the URL of the next pageview);
• Your IP address and user agent string (which browser is being used, what version, and on which operating system);
• Your geographic location, your device`s screen size, language installed on your device, whether flash or java is installed, the referring site, installed time zone.

• Cookies data. Cookies may collect data that fall within the definition of “personal data”. To find more information about the use of cookies, please, follow the cookie policy.

Purposes and legal bases for the processing

Recipients of your data

Our employees, subcontractors, affiliated companies, and other establishments. The Website and Services provided via the Website are maintained and provided by a large number of people who may be employed either by the Company or by any of our affiliated companies, subcontractors, and other establishments. This means that your data may be shared with them. Please note that all these transfers are secured by proper data transfer agreements which oblige these recipients to process your data in accordance with this Policy and with the data protection legislation to which the Company is subject.

Cloud provider(s) which make the Website available. The Website and the Services provided via the Website are placed on the Server which belongs to the third party. From this follows that your data will be shared with them. Please note that your data will be transferred only in encrypted form, which makes impossible to decrypt your data without decryption keys.

Financial institutions: banks, payment services providers, payment systems, and other similar entities. Your transactions for the Services provided via the Website are processed by the third-party financial institution(s). This means that your data will be shared with them to process your transactions and perform their legal and regulatory obligations.

Сourier companies. If you win any physical winning(s) or prize(s), your data will be shared with a courier company which will be engaged in the process of delivery of a winning or a prize to you.

Accreditation bodies, auditors. When the Company passes an independent audit, the data concerning you may be shared with them. All these bodies or auditors are legally obliged to handle your data in accordance with this Policy and applicable legislation.

Analytics. This includes Google Analytics, Yandex Metrika, and Hotjar.

Google Analytics. The Website uses Google Analytics, a web analytics service. It is operated by Google LLC., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google Analytics uses previously mentioned "cookies". The information generated by the cookie about your use of the Website is usually transmitted to a Google server in the USA and stored there. Google Analytics Opt-out Browser Add-on provides visitors and users with the ability to prevent their data from being collected and used by Google Analytics. To install Google Analytics Opt-out Browser Add-on, follow this link: https://tools.google.com/dlpage/gaoptout?hl=en.

Cloudflare, Inc. The Company uses the services, provided by Cloudflare, Inc. 101 Townsend St, San Francisco, CA 94107 USA. Сloudflare provides web optimization and security services that the Company uses to improve and protect the Website, including a reverse proxy, pass-through security service. Cloudflare may collect the log data from the visitors of the Website. Additionally, the Company deployed a Cloudflare`s cookie file for security purposes (see Cookies Policy to find out more). To find out more about the processing of the data by Cloudflare, please follow https://www.cloudflare.com/privacypolicy/.

How long will we store your data?

Cookies Data shall be stored in accordance with Cookies Policy.

Automatically collected data of the visitors of the Website who do not have an account on the Website or who are not logged-in into his/her account on the Website shall be stored up to 26 (twenty-six) months starting from the date of the last visit to the Website.

For other data of the users who possess an account on the website: up to 6 (six) years starting from the date you closed your account on the Website and terminated your contract with the Company. This period is based on a) the legal obligation of the Company under Anti-Money Laundering legislation which requires to store Verification data, Contact data, Bets data, and payment data for a period of 5 (five) years; and b) the purposes of the establishment, exercise or defence of legal claims as allowed by Article 7(1) of Limitation of Legal Proceedings act (Law 66 (I)2012) of the Republic of Cyprus.

Your data subject`s rights

Under applicable data protection legislation, you have the rights which you can exercise either by a) sending a request to us to our registered address; or b) sending a request to our email address [email protected]; or c) via the interface of the Website (for some functions).

Please note, that these rights are applicable with some restrictions:

• If we are not sure about the identity of the requestor, we will verify the identity of a user/visitor who requests for the implementation of any of the rights before the implementation;
• We may restrict the rights specified below or deny in implementation of any of the rights if this restriction or denial is grounded on the legislation to which the Company is subject or if we can deny implementation of your request under applicable legislation. In this case, we will specify the reason for the denial in the reply to your request.

Your rights are the following:

The right to withdraw consent. If you previously consented (under Article 6(1)(a) of the GDPR) to the processing of your data, you have the right to withdraw this consent at any time. It means that we will stop the processing of the personal data for the processing of which the consent was required starting from the date of the withdrawal. The withdrawal of consent shall not affect the lawfulness of the processing based on consent before its withdrawal.

The right of access. You have the right to obtain from us the confirmation as to whether or not the data concerning you are being processed, and, if we indeed process your personal data, to receive a copy of the personal data undergoing processing.

The right to rectification. You have the right to obtain from us the rectification of inaccurate personal data concerning you.

The right to erasure (or the right "to be forgotten"). You have the right to obtain from us the erasure (removal) of your personal data. Upon your request, your personal data shall be removed. This right shall be applied if:

• your personal data are no longer needed for the purposes for which these data were collected;
• you have withdrawn your consent (if you have provided this consent) and there are no other legal bases for further processing;
• we do not need to keep your personal data for the purposes of compliance with the applicable legislation;
• the data are processed unlawfully;
• there are no any restrictions of this right by the applicable legislation;
• in other cases when the erasure (removal) is required by the applicable law.

The right to object to processing. You have the right to object, on grounds relating to your particular situation, to processing of your personal data if the grounds of this processing were necessary for the purposes of the legitimate interests pursued by the Company or by the third party (Article 6(1)(f) of the GDPR). Additionally, you have the right to object to the processing of your personal data for direct marketing purposes (if applicable).

The right to restriction of the processing. You have the right to obtain from us restriction of processing, in case if one of the following applies:

• you contested to the accuracy of the personal data, for a period enabling the Сompany to verify the accuracy of the personal data;
• processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
• we no longer need the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims;
• you have objected to processing on the basis of your right to object pending to verification whether your legitimate grounds override those of the Company.

The right to data portability. You have the right to receive from us the data which were collected from you, in a structured, machine-readable format and have the right to transmit those data to another controller (in a plain language, to 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.

The right to lodge a complaint with the supervisory authority.

You can always contact us for any issue concerning the processing of your data, including complaints. Nevertheless, if you suppose that your rights under applicable data protection legislation have been violated, you can lodge a complaint either:

• With the Commissioner for Personal Data Protection of the Republic of Cyprus (jurisdiction of our incorporation). The Website of the Commissioner http://www.dataprotection.gov.cy/; or
• With the data protection authority of the country of your habitual residence. You can find the list of all EU Data Protection Authorities on the Website of the European Data Protection Board https://edpb.europa.eu/about-edpb/board/members_en.

International data transfers

Our Company does business globally, which means that your data may be transferred to the so-called “third countries” within the meaning of the GDPR. Below you can the information about the following:

• The list of transfers;
• The existence or absence of an adequacy decision by the European Commission (to find out more about adequacy decision, please, follow https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en);
• In case of absence of an adequacy decision: appropriate safeguards applied; if you want to obtain a copy of the document(s) which ensures appropriate safeguards for a particular transfer between the Company and another recipient, please, send a request to us via e-mail [email protected].

Processing of children`s data

The Website is not intended for users under the age of 18 years or under the age required to participate in gambling in the place of the residence (jurisdiction) of the particular user ("Legal Age"). If you are a parent or a legal guardian and have found that your child uses our Website, please contact us via any available means of communication, and we will apply appropriate measures.

Third-party websites

This Website may contain links to the Websites owned by third parties. For example, links/hyperlinks to third-party`s websites (hereinafter "third-party`s websites"). You follow those links/hyperlinks at your own risk. The Company bears no liability for the content of any of those Websites and bears no responsibility for anything that can happen as a result of your visit to those third-party`s websites. The Company recommends you to visit "Privacy Policy" or "Data Policy" or another privacy document on any of the third-party`s Websites before submitting any data concerning you to the latter.

Changes to this Policy

The Company may change this Policy. In case of any changes, the Company will post revised Policy 7 days before these changes will come into force. The Company will notify registered users about the changes to this Policy by sending an e-mail notification. Continued use of the Website by you shall be interpreted as you have read, understood, and have no objections to the revised Policy.

Cookies Policy

This Website uses cookies. A cookie is a small file of letters and numbers that we put on your electronic device. These cookies allow us to distinguish you from other users of the website, which helps us to provide you with a good experience when you browse our website and also allows us to improve the Website. Below you can find the cookies used on this Website and the purposes for their use. 

DATE: October 2021