Privacy Policy

Winning.io has the legal obligation to keep a copy of your gambling history and to employ measures to detect and identify problem gaming using analytical tools and/or behavior monitoring systems, as well as the legal obligation to take steps to prevent further harm if such an issue was identified. We will also use such data to initiate customer interaction where we have concerns that your behavior may indicate problem gambling.

 Winning.io 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. 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 (see section Rights and Data Subject Requests).

Winning.io 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.

Winning.io might sometimes process your data automatically, with the aim of evaluating certain personal aspects (profiling). We use profiling for the purposes of complying with our anti-money laundering and funding of terrorism obligations. As a rule, we do not make decisions based solely on automated processing (as defined in Article 22 of the GDPR) to establish and implement the business relationship, as there is always an element of human involvement in such decisions. If we use these procedures in individual cases, provided this is allowed by law, we will inform you of this separately.

 Data processing

All the collected data will only be used in accordance to current legislation.

Generally, this would be in the following circumstances:

• When we need to in order to be able to provide you with gaming services in line with the contract we have with you or are about to enter into with you (please see our Terms Conditions);
• Where it is necessary for our legitimate interests and your interests do not override those interests;
• Where we need to comply with an obligation under law including Anti-Money Laundering and Funding of Terrorism Laws, and gaming laws.

We do not generally rely on your consent as a basis for processing your personal data other than in relation to the sending of marketing communications. You are not obliged to give your consent and refusing to give your consent will not lead to any detriment to you. You have the right to withdraw your consent at any time by ticking the opt-out option on your profile. You may also opt-out by contacting our DPO at any time or clicking the ‘unsubscribe’ link in any marketing material sent to you.

 Credit card information processing:

Winning.io does not collect your credit card and financial information, as the payment process is done through our payment gateway providers.

Our payment gateway providers use secure server software (SSL - SSL Certificate enables encryption of sensitive information during online transactions), which is the industry standard and among the best software available today for secure commerce transactions.

We do not have access to any information about the card or your bank account, other than the ones you provide for KYC verification purposes, that Winning.io will only process in order to comply with legal obligations.

 Disclosing your Personal Data

We do not share your personal information with third parties outside WagerCraft Ltd. for marketing purposes. However, there are circumstances when we share your personal data with other companies within WagerCraft Ltd., third-party service providers acting on our behalf, and other third parties to comply with our legal obligations. For example, when we engage in any merger or business sale, customers’ personal information is likely to be included in the transfer. We will inform you before such a transfer of personal data takes place. Even when shared, your personal information will only be used for the purposes outlined in this Privacy Notice.

With Other Companies within WagerCraft Ltd.

We may share the personal data we collect with other companies within WagerCraft Ltd. for the following purposes:

• Providing you with products and services and notifying you about important changes or developments to those products and services.
• Responding to your inquiries and complaints.
• Administering offers, competitions, and promotions.
• Facilitating secure access to online platforms.
• Updating, consolidating, and improving the accuracy of our records.
• Conducting transactional analysis.
• Testing new systems and checking upgrades to existing systems.
• Detecting, preventing, and prosecuting crime, and complying with regulatory requirements.
• Evaluating the effectiveness of marketing, market research, and training.
• Customer modeling, statistical and trend analysis, aimed at developing and improving products and services.

With Third Parties

We may share personal data with third parties in the following circumstances:

• Providing you with products and services and notifying you about important changes or developments to those products and services.
• When ordered to do so by any regulatory body and/or under any legal provision contained in the governing law.
• Instructing and authorizing the Financial Institution with which an Account Holder's account is held to disclose any information as requested by the Regulator concerning an Account Holder's account.
• Establishing, exercising, or defending our legal rights.
• For fraud detection and control purposes, we may transfer your personal data to third parties, including Address Verification System service providers, Sports Governing Bodies, Payment Service Providers, and Financial Institutions. We reserve the right to disclose the Account Holder’s personal data to relevant parties where WagerCraft Ltd. has reasonable grounds to suspect irregularities involving an account (including money laundering).
• With service providers to enable us to provide our Services, such as companies that assist with technology services, data storage and combination, payment processing, or providing relevant online advertising for our products and services.
• With external auditors who conduct independent checks as part of our accreditations.
• To an organization we sell or transfer (or enter into negotiations to sell or transfer) any of our businesses or any of our rights or obligations under any agreement we may have with you. If the transfer or sale goes ahead, the receiving organization can use your personal data in the same way as us.
• To any other successors in title to our business.
• With security communities to ensure network and information security.

Further details on retention periods for different aspects of your personal data are available in our retention policy, which you can request by contacting us.

Data Transfers

We will only transfer your data to the European Union or to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.

In case US processors are used (depending on the services you are using on winning.io), we shall only transfer data to providers based in the US after making sure that all appropriate safeguards have been implemented and that the same protection is afforded / same standards are applied as would be within the EEA. We will only share the data with processors that are registered with Privacy Shield (an agreement between the EU and US allowing for the transfer of personal data from the EU to US, only to providers that are compliant to the European Data Protection standards).

Marketing

WagerCraft Ltd would like to send you information about our services which may be of interest to you. If you have consented to receive marketing, but decide you want to stop receiving the information and withdraw your consent, you have the right to opt out at any time from receiving such marketing material.

You may opt-out from winning.io marketing material at any time as set out below:

1. Email support@winning.io and say that you would like to opt-out;
2. Tick the ‘opt-out’ option on your account information page;
3. Press ‘unsubscribe’ on any marketing material received.

Withdrawing your consent will not lead to any detriment to you or the relationship with winning.io.

Collaboration with Educational Bodies for Safer Gambling

At WagerCraft Ltd., we are committed to promoting safer gambling practices. To support this initiative, we may collaborate with educational institutions and research organizations to study online gambling behaviors. In these instances, we ensure that the data shared is double anonymized, meaning that it is stripped of any personal identifiers that could link it back to individual customers. We do not disclose any identifiable personal data pertaining to our customers under any circumstances. Our goal is to contribute valuable insights into safer gambling practices while upholding the privacy and confidentiality of our users.

 Security of data

Winning.io is committed to ensuring that your information is secure. We have implemented measures and procedures to prevent unauthorized access or disclosure of your information. Likewise, we seek to keep confidential all information you send to us.

This site uses Secure Sockets Layer (SSL) to ensure secure transmission of your personal data. You should be able to see the padlock symbol in the status bar on the top left-hand corner of the browser window. The URL address will also start with https:// depicting a secure webpage. SSL applies encryption between two points such as your PC and the connecting server.

In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any personal data breach and will notify you and the relevant regulator of a breach where we are legally required to do so.

Data Retention

Winning.io will retain your personal data only as long as necessary to achieve the purposes for which it was collected, including satisfying any legal, accounting, or reporting obligations.

The criteria we use to determine the necessity of retaining personal data depends on the nature of the data. Typically, we assess whether any specific EU or national laws (such as those related to licensing, tax, or corporate requirements) mandate the retention of certain personal data for a specified period. If such laws exist, we will retain the data for the maximum period prescribed. In the absence of such laws, we consider whether any legal or contractual obligations could be invoked against us by you or third parties, and if so, we retain the relevant data for the duration necessary to defend against any potential claims or actions.

When your personal data is no longer required, we will either securely delete or anonymize it. Generally, we retain your personal data for a maximum of ten (10) years from the closure of your account, with certain exceptions:

If you are permanently self-excluded from our services, we will retain this information indefinitely.

If you are under investigation or if we suspect fraudulent or criminal activity, we may retain your personal data for a longer period to cooperate with relevant authorities.

If there is a legal dispute, we will retain your personal data for at least the duration of the dispute and as necessary to defend our rights in any subsequent claims or proceedings.

Due to gaming authority restrictions regarding multiple accounts, players are permitted to create and use only a single account per brand on the Controller’s system (as stated in our terms and conditions). Therefore, while we retain all the player's personal data for the aforementioned purposes, a player may reopen their existing account after closure, provided the account is eligible for reopening.

Further details on retention periods for different aspects of your personal data are available in our retention policy, which you can request by contacting us.

Rights & Data Subject Requests

Winning.io, through its employees and collaborators, is committed to help You in every way that it can with understanding your data privacy rights and – if you so choose – help you make use of these rights. They are:

Right to Transparent Information – you have the right to be informed in a clear manner on any personal data pertaining to you that may be processed by us. Such information is being provided to you in this Privacy Policy. If you have any questions or concerns pertaining to your rights, you are always encouraged to contact our Data Protection Officer on dpo@wagercraft.com.

Right of Access to Information – you have the right to request confirmation from us whether personal data relating to you is being processed, why and how it is processed, as well as request access and clarifications about such personal data.

Right to lodge a request, contact our DPO/DPR on the details above. If you would only like to receive information on a specific category of data, please indicate such category e.g. ‘Identity Data’ or ‘Contact Data’.

Right to Rectification – you have the right to request from us the rectification, without delay, of any inaccurate personal data pertaining to you.

You may change your data in the following manner:

• Through your Profile: by accessing the ‘Account Details’ page on the platform;
• By email: by emailing: dpo@wagercraft.com

Please note that your user id. may not be changed.

Right to Be Forgotten; you have the right to request from us the erasure of all personal data pertaining to you without delay, where the data has been processed with your consent as the basis for processing and/or where the processing is no longer lawful.

Winning.io will also remove the information that was modified as per your right of rectification (once the new provided data has been verified).

Please know that when you exercise your right to be forgotten, Winning.io will still keep the information that We are required to keep by the current legislation (as mentioned at 4. Purposes of Collecting and Processing the Information and 11. Data retention).

Right to Restrict Processing; you have the right to request from us the restriction of processing if: processing is unlawful; you are contesting the accuracy of data; the data is no longer required by the controller but you require us to keep it in order to establish, exercise, or defend a legal claim; or if you have previously objected to the processing. Once data is restricted, we cannot process it in any way other than to store it unless: we have your consent; or if it is required for the establishment, exercise, or defence of legal claims; or if it is for the protection of the rights of other persons; or if it is for reasons of important public interest.

Please note that this does not extend to personal data which is inferred or derived by us.

Right to Data Portability; you have the right to receive from us personal data which you have provided to Winning.io and to transmit that data to another controller without hindrance from us, in a commonly used format. This right applies where the data is being processed with your consent, or for the performance of a contract, and when processing is carried out by automated means.

Right to Object; you have the right to object at any time to the processing of personal data pertaining to you where the processing is based: on our legitimate interest; or the performance of a task in the public interest/exercise of official authority; or on direct marketing (including profiling); or on processing for purposes of scientific/historical research and statistics.

You also have the right to object to profiling based on our legitimate interests or on the performance of a task in the public interest/exercise of official authority.

You also have the right to object to automated decision making, including profiling, and therefore to not be subject to a decision which is based solely on automated processing, including profiling, which produces legal effects or significantly affects you.

Right to withdraw consent; you have the right to request Winning.io to stop processing your information for all purposes based on consent (as shown in 4. Purposes of Collecting and Processing the Information).

You may withdraw your consent at any time, and the methods you can do that are:

Email support@winning.io and say that you would like to opt-out

Tick the ‘opt-out’ option found in the communication section of your profile;

Press ‘unsubscribe’ on any marketing material received.

Withdrawing your consent will not lead to any detriment to you or the relationship with winning.io.

Data subjects requirements

When making a request pertaining to your Data Protection rights, Winning.io might need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

Winning.io has a legal obligation to keep your data updated, and for this reason you may be asked about changes to your personal data at various intervals. You may help us in this process by informing us whenever your data has changed (and use your right to rectification). You are entitled to ask us to modify your personal data if you ascertain that the personal data which we hold is not accurate or updated.

Since Winning.io requires your data for the purposes of accepting and carrying out a relationship with you and fulfilling our contractual and legal obligations, should you choose not to provide us with such data, we might not be in a position to enter into a business relationship with you and fulfil the Terms and Conditions applicable between us and our obligations thereunder.

Anti-money laundering obligations require us to verify your identity at certain intervals, for example, by means of your passport and to record your personal details. In order for us to be able to comply with this statutory obligation, we will ask you to provide us with the necessary information and documents and notify us without undue delay of any changes that may arise during the course of the business relationship.

Should you choose not to provide us with such data, we might not be able to enter into or continue our business relationship and fulfil the Terms and Conditions applicable between us and our obligations thereunder as we would be in breach of our anti-money laundering and funding of terrorism obligations.

Reference is made to the Terms and Conditions whereby you have undertaken to provide us with certain personal data, including documentation, and to inform us of any changes to such data. In these circumstances, the provision of personal data is a contractual requirement.

You are never obliged to provide us with any kind of data that will have no other processing legal basis other than your consent (as shown above in the section of "Purposes of Collecting and Processing the Information").

Processing Data Through Consent

The processing of data highlighted above, with the exception of processing for marketing purposes does not require your consent as it relies on legal basis.

We may however also request to process additional personal data on the basis of your consent. You are not obliged to give us your consent. Once you have granted us consent to the processing of personal data for an identified specific purpose, the processing becomes lawful on the basis of such consent. You can withdraw your consent at any time. Withdrawal of consent does not affect the legality of data processed prior to withdrawal.

You can withdraw your consent at any time by: dpo@wagercraft.com

At the time of withdrawal of consent, we may determine that there is another legal ground allowing us to process your data and we shall inform you accordingly.

Privacy Policies of Linked Website and Advertisers

Winning.io may contain reference and linked third party website and advertisers. We are not responsible for the privacy practices or the content of such websites. By clicking on those links you may be directed to those Websites which are not under the control of WagerCraft Ltd. 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.

Surveys/Contests

From time-to-time, we collect information via surveys or for participation of any contests organized by us on winning.io. Participation in these surveys and/or contests is completely voluntary, and any information provided to us will be provided on the basis of your consent. You may choose whether or not to participate and thereby disclose any information about you. There will be no detriment towards you for not participating in such surveys and contests. You may wish, and if so have the right to revoke such consent at any time.

By agreeing to participate in the survey, you agree to provide us with any such required information.

Survey information will be used only for purposes of improving the use and customer satisfaction of winning.io.

Contact Us

If you are unhappy with the way in which we have processed your personal data, or have any questions regarding anything related to this privacy policy, you may contact our Data Protection Officer on dpo@wagercraft.com

You also have a right to lodge a complaint with the Office of the Information and Data Protection Commissioner, or other supervisory authority of your habitual residence, place of work or place of alleged infringement, and the right to seek an effective judicial remedy before courts.

Changes to Privacy Policy

We retain the right to change our Privacy Policy at any time in case update is needed. Any new change shall apply from the date we publish them.

Any further updates will be listed on this web page, so please check back periodically.

The Privacy Policy has been drafted in the English language. In the event of any discrepancy between the meanings of any translated versions of the Privacy Policy and the English language version, the meaning of the English language version shall prevail, to the extent permissible by domestic law in the jurisdiction you reside in.

Last updated on June, 2024