Privacy Policy
Useful information for online players.
General
As data controller, we are required by gambling law to process players’ personal data in order to allow them to participate in games and to provide them with additional services. This Privacy Policy explains what personal data we collect from players, why we collect it, and how we use it.
The website www.arlekincasino.com (“Casino”, “Website”, “Company”, “We”, “Us”, “Our”) is owned and operated by Dama N.V., a company registered and established under the laws of Curaçao, with registration number 152125 and registered address at Julianaplein 36, Willemstad, Curaçao. Dama N.V. is licensed and regulated by Antillephone N.V. (license no. 8048/JAZ2020-013).
If you have any other questions regarding this Privacy Policy or protection of your data, please feel free to contact our Data Protection Officer at [email protected].
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. While we will do our best to notify you of such changes, we recommend that you revisit this Privacy Policy regularly. Your continued use of the Website and/or its services will constitute your consent to the Privacy Policy.
Information We Collect
The Personal Information which we may request to use and process shall include, without limitation:
- Any of the information that you provide to us when filling in the forms on our account registration pages, 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);
- Correspondence made with us via the Website, email, web chat or through other means of communication;
- All Player Account transaction history, whether this takes place via the Website(s) or via other means of communication;
- Website logins and their details, including traffic data, GeoIP location data, browser/device data, weblogs, activity logs and other traffic information recorded in our system;
- 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.
- Survey participations or any other customer assessments that we may carry out from time to time.
How We Use Your Information
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:
- Processing your bets and transactions. This includes your use of credit card and online payment systems;
- Providing you with gaming and other ancillary services that you seek from our Website;
- Rendering customer support, such as assistance with setting up and managing your account;
- Identifying and performing the necessary verification checks;
- 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);
- Complying with legal responsibilities, including complying with anti-money laundering (AML) and combating the financing of terrorism (CFT) laws;
- Monitoring and investigating transactions for the purposes of preventing fraud, terms abuse, money laundering and other illegal or irregular gaming activities;
- Analysing customer trends through market study assessments (participation in surveys is not obligatory and you can always choose not to take part);
- Conducting research and statistical analysis of aggregated data.
Marketing Communication
Unless you choose not to receive promotional material, we may use your personal information, including your e-mail address and telephone number, to send you marketing messages about products, services and promotions. This may include information about the products and services of our business partners, such as casino game suppliers.
Whenever you decide to stop receiving such marketing and promotional materials, you can opt out in your player account settings or by contacting our support team at [email protected].
In addition, please note that by accepting any contest prize or winnings from us, you consent to the use of your name and/or pseudonym for advertising and promotional purposes without additional compensation, except where prohibited by law.
Obtaining Personal Information
We will not collect personal information about you without your knowledge. However, we may automatically collect certain information about you if you would provide such information when you use our services and when you interact with us.
We may also lawfully obtain certain personal information from online merchants and service providers, such as fraud prevention companies. In addition, we reserve the right to use third-party service providers to provide technical support to process your online transactions and source game content.
Please understand that we may be given 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 protect any personal information obtained in this manner as set forth in this Policy. Any information you provide will only be disclosed to third parties outside of the Company in accordance with this Privacy Policy, and we will take all necessary steps to ensure that our agreements with third party service providers protect your personal information at all times.
Data Recipients
We may share the information you have provided to us with other entities in our group of companies and our business partners. These companies include our parent companies, their parent companies and all subsidiaries of these respective companies, as well as other companies with which we do business and have necessary agreements. The processing of your information may be handled by the Company or another entity within our group of companies, which may use a third party to fulfill such processing needs.
Company employees, in particular the Data Protection Officer, the Anti-Money Laundering Officer, Payment and Fraud Analysts, Help Desk Agents, Members of the Customer Retention Team, VIP Player Managers, and other selected employees, must also have access to your personal information in order to perform their duties and assist you.
Our employees who have access to or are associated with the processing of player personal information have signed confidentiality agreements to respect the privacy of player information in accordance with applicable gaming, data protection and privacy laws.
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). Thus, by browsing the Website and communicating with us electronically, you acknowledge and agree to our (or our suppliers or subcontractors’) processing of your data in those countries. We will always make every effort to ensure that your information and data is treated securely and in accordance with this Privacy Policy.
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 to do so 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 is 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:
- Where we are required to do so by law;
- 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 Paysafe whose privacy policy applies to such transactions);
- 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;
- 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;
- If our marketing service providers require the data to carry out their tasks;
- To any other third party with the player’s prior consent to do so.
We use third-party data processors to process limited personal data on our behalf. Such service providers maintain the Website, especially with respect to website hosting and operation, marketing, analytics, website enhancements and sending email newsletters. We will ensure that the transfer of Personal Data to the recipient complies with applicable Data Protection Laws and that the processor is subject to the same obligations as we are subject to under the relevant Service 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. If data is collected in this way, its processing is governed by the privacy policies of the relevant social media platforms.
In addition to the above, we may also disclose personal information if we acquire any new businesses. If the Company undergoes any change in its structure, such as a merger, acquisition by another company or partial takeover, it is most likely that our customers’ personal information will be included in the sale or transfer. In accordance with our Policy, we will inform our players by email before interfering with such a transfer of personal information.
Please note that our content may contain links to third-party websites to provide related links. We are not responsible for such external content, which may contain separate privacy policies and data processing disclosures.
Data Retention
As stated in our Terms and Conditions, you and the Casino may decide to close your player account at any time. Once we have closed your account, we will retain your personal data on record for as long as we are required by law to do so. The data will only be used when required by the competent authorities in connection with requests related to financial and tax reporting, fraud, money laundering or investigations into any other illegal activities.
We can also store anonymous derivatives of your data to improve our content and marketing communications when automated decision-making is not required.
Please note that due to anti-money laundering regulations in licensed gaming jurisdictions in the European Union, we are required to retain personal player data provided at the time of registration, and any data transferred during the player account period, for a minimum of five years from the last player transaction or account closure. Therefore, deletion requests prior to the expiration of this period cannot be considered.
Security of Your Data
We hereby acknowledge that we are bound by strict legal provisions for the collection and processing of your Personal Information for the purposes of managing your Player Account.
Consequently, we are committed to protecting your personal information and respecting your privacy in accordance with best business practices and applicable regulations. In striving to provide a secure player experience, we will take all reasonable precautions to ensure that all data you provide to us remains secure.
Right to withdraw consent. Where we rely on your consent to process personal data, you have the right to withdraw your consent at any time.
Player accounts can only be accessed using a unique player ID and password. You can also set up two-factor authentication (2FA) as additional protection against unauthorized use of your account. It is your responsibility to keep your registration information confidential and ensure that it cannot be accessed by another person.
Contacting Us
You may always contact us in regards to this Policy should you wish to:
- Confirm the accuracy of the personal information we have collected about you;
- Enquire about our use of your personal information;
- Prohibit future use of your data for direct marketing purposes;
- Update or rectify any information that you have provided us (in such cases you shall provide any evidence we may reasonably require to effect such changes). Note it is illegal to provide us with false information about you and it is your responsibility to ensure that we are always updated with your correct data.
We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, please contact the DPO at [email protected].
In addition, as per Article 77 of the GDPR, you have the right lodge a complaint related to your data processing to a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of an alleged infringement.
Cookie Policy
When you visit the Website, our system automatically collects information about your visit, such as your browser, IP address and referring website. This collection may be done in conjunction with our platform providers and partners. We may receive general demographic or usage data about visitors to our Website from them. We do not automatically use the information collected to identify you personally without obtaining additional consent.
We use cookies and similar tracking tools to collect the information in question. Cookies are small text files that are stored on your computer or equipment when you visit our Web pages. Some cookies are necessary for the operation of the Website; others enhance your website and help us provide better services to you. Below are the types of cookies we use and their purposes.
Required cookies: provide navigation and basic website functions, such as access to sections for Website members.
Functionality cookies: allow us to analyze your use of the website and your choices on the website (such as your session key, language or region) so that we can store these settings and offer you a more personalized experience.
Advertising cookies: allow us to measure how effective our content marketing is. These cookies are provided by our affiliates to track website visits and new registrations due to advertising. We do not share your personal information (such as your name or email address) with affiliate partners, except for site visit data collected directly by these advertising cookies. However, your website visit data may be linked to other personal information collected by ISPs from other sources. The latter external processing of data is governed by the privacy notices and policies of these third-party providers.
In addition to the above, we use a number of third party service providers who also set cookies on this Website to provide the services they provide to us. These services include, but are not limited to, helping us improve your experience by tracking your activity on the Website, measuring the effectiveness of the Website and the effectiveness of our marketing campaigns.
Most online browsers automatically accept cookies. If you wish, you can block some or all cookies or delete cookies that are already set by changing your browser settings. However, we recommend that you do not block or delete cookies, as this may limit your use of our website.
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