If you do have any question with regards to the way we process your data, feel free to contact our Data Protection Officer at firstname.lastname@example.org
This website is not intended for children and we do not knowingly collect data relating to children.
You have the right to make a complaint at any time to the Office of the Commissioner for Personal Data Protection, accessed here: http://www.dataprotection.gov.cy/dataprotection/dataprotection.nsf/home_el/home_el?opendocument
We would, however, appreciate the chance to deal with your concerns before you approach the Office of the Commissioner for Personal Data Protection so please contact us in the first instance.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Due to our regulatory requirements we will collect information about criminal convictions and offences as part of our PEP and sanction procedures, however, this information will not be passed to third parties unless required by law.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with gambling services). In this case, we may have to close your account you have with us but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
(a)analytics providers such as Google based outside the EU;
(b)search information providers based inside the EU such as:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
You have the right to withdraw consent to marketing at any time by:
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer and choose whether to give explicit consent or not to receiving free bonuses and exclusive offer news from Fairdos Online Services Limited.||(a) Identity |
(c) Marketing and Communications
|Performance of a contract with you; Processing and disclosure of your Personal Information for the purposes of sending relevant marketing material, promotions and prizes to you.|
|To process and deliver your transactions including: |
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
|(a) Identity |
(d) Transaction (e) Marketing and Communications
|(a) Performance of a contract with you |
(b) Necessary for our legitimate interests (to recover debts due to us)
(b) Asking you to leave a review or take a survey
|(a) Identity |
(d) Marketing and Communications
|(a) Performance of a contract with you |
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)
|To enable you to partake in a prize draw, promotion, competition or complete a survey||(a) Identity |
(e) Marketing and Communications
|(a) Performance of a contract with you |
(b) Necessary for our legitimate interests (to study how customers use our services, to develop them and grow our business)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity |
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)|
(b) Necessary to comply with a legal obligation
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity |
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, services, marketing, customer relationships and experiences and Responsible Gambling requirements||(a) Identity |
|Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy and to ensure we comply with our Social and Responsibility Requirements)|
|To make suggestions and recommendations to you about our new games, promotions and depositing methods that may be of interest to you||(a) Identity |
|Necessary for our legitimate interests (to develop our services and grow our business)|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not agreed to receive that marketing.
Where you have agreed to receive such communications, Fairdos Online Services Limited may use contact you for marketing purposes by SMS, email or phone. These marketing messages will provide you with various information about our new games, promotions and other services.
We may also send push notifications to your mobile device in order to provide game updates, account communications, promotions or other relevant messages.
We will get your express opt-in consent before we share your personal data with any company outside the Fairdos Online Services Limited group of companies for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by Contacting us at any time.
CHANGES AND UPDATES TO THIS POLICY
Last update: 17/01/2019
WHAT IS A “COOKIE”?
There are two main types of cookies used on website across the internet:
Within the above types of cookies, there are several kind of cookies as listed below:
The cookies that are used on our websites do not collect any personally identifiable information from the website usage. The technical data that is collected is used for analytical purposes. This data helps us understand how we can enhance the browsing experience by providing more suitable content to the users of the website.
All of the following cookies are currently in use on the website:
|Cookie Name||Purpose||Persistent or Session|
|ANON||This cookie is associated with Bing. This specific cookie is used for site analytics and advertising purposes.||Expires after 6 months|
|MUID||This cookie is associated with Bing. This specific cookie is used f or site analytics and advertising purposes.||Expires after 1 year|
|MUIDB||This cookie is associated with Bing. This specific cookie is used f or site analytics and advertising purposes.||Expires after 1 years|
|NAP||This cookie is associated with Bing. This specific cookie is used for site analytics and advertising purposes||Expires after 6 months|
|1P_JAR||This cookie is related to Google Analytics and it is used for analytics purposes||Expires after 1 month|
|NID||This cookie is used to remember user preferences in regards to the use of the website. This cookie is associated with Google Analytics||Expires after 6 months|
|Datr||This cookie is related to Facebook, its purposes is to understand what web session accessed the social media network||Expires after 2 years|
|Fr||This cookie is related to Facebook, its purposes is to allocate an encrypted browser ID and Facebook ID for advertisement purposes||Expires after 3 months|
|sb||This cookie is related to Facebook, its purposes is to improve friends suggestion with the social network platform||Expires after 2 years|
|OTZ||This cookie is associated with Google Analytics. It collects anonymous information with regards to the way this website is used. This data is then used for analytical purposes||Expires after 1 month|
|__cfduid||This cookie is related to Cloudflare (website cyber security solutions provider)||Expires after 1 year|
|_ga||Performance cookie used for website analytics. This cookie is associated with Google Universal Analytics||Expires after 2 years|
|_gat||Performance cookie used for website analytics. This cookie is associated with Google Universal Analytics||Expires at the end of the session|
|_gid||Performance cookie used for website analytics. This cookie is associated with Google Universal Analytics||Expires after 24 hours|
|vid||This cookie is a first party cookie. It allows us to keep track of the logged in entity using the website||Expires after 1 year|
|PREF||This cookie is set by Youtube. The purpose of this cookie is to keep track of user preferences and serve up related content within an embedded video player||Expires after 8 months|
|VISITOR_INFO1_LIVE||This cookie is set by Youtube. The purpose of this cookie is to measure the bandwidth available on the user’s browser to determine what version of the youtube player is used||Expires after 6 months|
WHAT INFORMATION IS GATHERED?
The data gathered revolves around the way the users interact with the website during their visit. This includes: what pages and sections of the website are visited, what links are being clicked on, how many users are currently logged in, whether or not content is being shared on social media. As mentioned previously, this data is purely technical and it does not allow us to identify an individual.
CONSENT FOR COOKIES
Any strictly necessary cookies that are in use on this website will not give the ability to opt-out. If you wish to opt-out of third party cookies, please refer to the following section. A pop up banner will appear on your first visit to this website to inform you about cookies and prompt you whether or not you agree. If you do not agree with cookies, please refer to the following sections.
HOW TO OPT OUT?
To opt out of Google Analytics cookies, visit the following link. All the information required to opt out of Google Analytics are detailed: http://tools.google.com/dlpage/gaoptout
HOW TO DELETE THE COOKIES THAT ARE STORED ON YOUR MACHINE?
If you want to delete the cookies that are already on your computer, please refer to the instructions for your file management software to locate the file or directory that stores cookies. You can also access them through your internet browser.
ADDITIONAL INFORMATION ABOUT COOKIES
Please refer to the following page for general information about cookies and guidance on how to delete cookies that are stored on your machine: https://www.aboutcookies.org/
Please refer to the following page for more information about Google Analytics: https://www.google.com/analytics/#?modal_active=none
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
Where required by law, your personal information may also be disclosed to an applicable governmental, regulatory or enforcement authority. Additionally, in circumstances where we deem it appropriate, your personal information may be disclosed to any regulatory authority which has issued any company within the with a gambling operator licence.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We share your personal data within the Fairdos Online Services Limited Group. This may involve transferring some of your data outside the European Economic Area (EEA). has offices located in Romania (EEA) and in Taiwan (outside the EEA).
Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we will ensure personal data has a similar degree of protection that it would have in Europe.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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.
All data on our secure websites is encrypted using Transport Layer Security (TLS) technology. Where we have given you (or where you have chosen) a password which enables you to access your account, you are responsible for keeping this password confidential.
Any data which contains personal information which identifies you will be encrypted at all times whilst in transit over the internet. TLS is a special protocol that automatically encrypts any information sent by you on our secure pages. Our server then reads the information using a private key. This means that your information, be it debit or credit card information or any other personal details, is turned into code that can only be decoded with the private key or password.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law to maintain our compliance with AML regulations we are required to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for a period of at least five years after the relationship with the customer has ended. The date the relationship with the customer ends is the last date on which they visit or use our services.
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Should you wish to make a Subject Access Request you should contact us in writing at:
Subject Access Request c/o Legal Department, Achilleos, 21 Flat/Office B, Agios Dometios 2370, Nicosia, Cyprus
Or via email at: email@example.com
You should include adequate information to identify yourself and such other relevant information that will reasonably assist us in fulfilling your request.
However, a request can be refused if it is ‘manifestly unfounded or excessive’. An example of a request that may be excessive is one that merely repeats the substance of previous requests. We must notify you in writing, and without undue delay, if your request has been refused and this will contain the reasons for refusal.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to 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. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.