The following is Appendix I to the general Terms and Conditions and covers our privacy policy:
I. General
Thank you for visiting our website and for your interest in our company. Senator Group is committed to user privacy. This Privacy Policy provides details on whether your personal information is collected, processed and used and how this is done. Personal information refers to information concerning the personal or material circumstances of an identified or identifiable individual. This includes a person's name, address, telephone number and date of birth.
As this information is subject to special protection, we shall only collect it when technically required. The following describes which information is collected during your visit to our website and how it will be used.
When accepting our Privacy Policy by ticking the respective box during the registration process or continuing to use our services after publication of this Privacy Policy, you agree to the terms of this Privacy Policy and consent to the use of your personal information.
Your personal information will be treated as strictly confidential. Our data protection practices comply with all applicable data protection legislation, particularly Chapter 440 of the Malta Data Protection Act. We shall collect, process and retain your personal information for the processing and settlement of your visit and any related enquiries in the context of our product offering. We also use your data for advertising purposes. You can opt out of behavioural advertising by modifying your personal settings.
This Privacy Policy may be subject to modification from time to time, notably in the event of changes to legislation, the introduction of new laws or revision or expansion of our offering. Any changes will be published on our website. We therefore recommend that you check the Privacy Policy regularly.
II. Special website features
Our website offers various features through which we collect, process and retain your personal information. We explain how this information is used below:
Contact form:
The information collected through our contact form will only be used to process enquiries we receive through it.
III. Newsletter:
If you are a registered user and have not objected to receiving our newsletter, or e.g., have consented to receipt of the newsletter on a special promotion, we will use your e-mail address to send you our newsletter featuring information on all our services. It is possible to cancel the newsletter at any time by clicking the unsubscribe link in the newsletter or by changing your personal settings.
IV. Data transfer / Retention / Conditions of use
We only share personal information with third parties if required to do so by our contractual obligations, for contract processing or to prevent fraud. Personal information is not shared with third parties for any purpose other than stipulated in this Privacy Policy. Information is not transferred to third parties for advertising purposes.
Your data may be processed by group-wide computer networks or by Senator Group's contractual partners. If you provide us with personal information with your explicit consent, this data will be used for the purpose for which consent was requested and for which you granted it. We shall only retain your personal information for the length of time necessary for the intended purpose of data collection or for as long as legally required.
We reserve the right to carry out security checks at any time to validate your identity, age and registration data, and to check your use of services and your financial transactions for a possible breach of our General Terms and Conditions and applicable legislation. To facilitate such security checks, you also agree to provide us with all information and documents that we may request. By agreeing to our General Terms and Conditions and our Privacy Policy, you authorise us and our employees, representatives and suppliers to use your personal information and share it with a third party, if we consider it necessary, in order to check the information, you provided when using our services. Each time you access this website or individual files on the website, we collect, process and retain the following data: IP address, your operating system/terminal settings, website from which file was accessed, name of file, date and time of retrieval, volume of data transmitted, notification of whether data retrieval was successful (so-called web log). This access data is used solely in aggregate form for the ongoing improvement of our website and for statistical purposes.
We use active JavaScript contents from external providers on our website. When you access our site, these external providers may receive personal information relating to your visit to our website. You can prevent this by installing a JavaScript blocker such as the browser plugin 'NoScript' (www.noscript.net) or by disabling JavaScript in your browser. However, please note that if you do so, you may not be able to use the full functionality of the websites you visit. We use the following plugins and active script contents from third-party providers on this website:
Google-Analytics:
This website uses Google Analytics, a web analytics service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (hereinafter referred to as Google). Google Analytics uses various techniques, including so-called 'cookies', which are text files placed on your computer to help the website analyse how users use the site. The information obtained by Google Analytics about your use of the website will be transmitted to and stored by Google on servers which may be operated outside member states of the European Union as well outside states party to the Agreement on the European Economic Area. In case of activation of IP anonymisation within the Google Analytics tracking code for this website, Google will anonymise your IP address before transmission. This website uses a Google Analytics tracking code, to which the operator “gat._anonymizelp();” is added to enable anonymised collection of IP addresses (so-called IP masking). Google will use this information on behalf of the website operator for the purpose of evaluating your use of the website, compiling reports on website activity and for providing other services relating to website activity and internet usage to the website operator. Google Analytics will not associate your IP address with any other data held by Google. You may refuse the use of Google cookies by selecting the appropriate settings on your browser. However, please note that if you do so, you may not be able to use the full functionality of this website. You can prevent Google’s collection and use of data relating to your use of the website (incl. your IP address) by downloading and installing the browser plug-in available at https://tools.google.com/dlpage/gaoptout/. Further information concerning the terms and conditions of use and data privacy can be found at http://www.google.com/analytics/learn/privacy.html.
Google APIs:
Google APIs provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043 (hereinafter referred to as Google) are used on our website. These are program interfaces provided by Google. The information generated, such as the IP address, may be transmitted to Google. You can prevent collection and transmission of personal data (particularly your IP address) and use of this information by deactivating JavaScript in your browser or by installing a tool such as 'NoScript'.
Use of cookies and web beacons
We use cookies and web beacons in our digital offerings and newsletter to make our website more attractive to visitors and to enable the use of certain functions. So-called 'cookies' are small text files, which your browser can place on your computer. The process of placing a cookie file is also known as 'setting a cookie'. You can modify your browser settings to notify you when a cookie is set, to accept them on a case-by-case basis, or to generally accept or generally reject cookies. Cookies may be used for different purposes, e.g., to recognise that your PC has already been connected to a website (permanent cookies) or to save the last pages viewed (session cookies). We use cookies to offer enhanced user comfort. We recommend that you accept the cookies that we set on this website to get the best out of its functions.
V. How and why we use your personal information
We use your personal information in a range of ways that fall into the following categories:
• To provide you with the products or services you have requested;
• To meet our legal or regulatory obligations;
• To monitor our website performance; and
• To provide you with marketing information
Your rights over your personal information differ according to which category and lawful basis these fall into. This section provides more information about each category, the rights it gives you, and how to exercise these rights. These rights are in bold following each category.
Providing our products and services
We use your personal information to enable you to use our websites, to set up your account, participate in the online casino and to provide you with customer service assistance.
Legal and Regulatory Requirements
Senator Group will use your identification document and/or proof of address to check your details in order for us to protect our users from fraudulent behaviour and to promote responsible gambling.
We may conduct a security review at any time to validate the registration data provided by you and to verify your use of the services and for potential breach of our Terms and Conditions and of applicable law.
We are required to carry out these activities to provide our products and services legally, responsibly, and in line with the requirements stipulated by regulators. We cannot provide you with our services without carrying out these activities, if you don’t want your information used in this way, your option is to not use our services and close your account.
Marketing
If you have given us your consent to do so, we will send you offers and promotions via email, SMS or online. We do not share your information with third parties for them to use for their own marketing.
You have the right to withdraw consent or update your marketing preferences at any time.
Your Rights
Your rights to rectification
If you believe the personal information, we hold on to you is incorrect, you have the right for this to be rectified. For any information that cannot be updated through My Details, please contact our support.
Your right to request a copy of your personal information
If you would like a copy of the personal information we hold about you, you should request it through live chat or by emailing and we will provide you with a form to complete. The form is not compulsory but helps us to provide you with the information you are looking for in a timely manner. To ensure the security of your personal information, we will ask you for valid proof of identity and once we’ve received it, we will provide our response within one month. If your request is unusually complex and likely to take longer than a month, we will let you know as soon as we can and tell you how long we think it will take, such request may also incur an administration cost.
Your right to complain to the regulator
If you believe your privacy rights have been infringed, or you disagree with a decision we have made about your privacy rights, you have the right to complain to your local Supervisory Authority or the place in which the infringement took place.
Your right of erasure
You can request us to erase your personal data where there is no compelling reason to continue processing. This right only applies in certain circumstances, it is not a guaranteed or absolute right.
The right to erasure does not apply if processing is necessary for one of the following reasons: to exercise the right of freedom of expression and information; to comply with a legal obligation; for the performance of a task carried out in the public interest or in the exercise of official authority; for archiving purposes in the public interest, scientific research historical research or statistical purposes where erasure is likely to render impossible or seriously impair the achievement of that processing; or for the establishment, exercise or defence of legal claims.
VI. Disclosure to Third Parties
We may disclose your Personal Data to third parties:
• if we are under a duty to disclose or share your personal information in order to comply with any legal or regulatory obligation;
• in order to enforce or apply the terms of this policy or any other agreements;
• for the purpose of research on the prevention of addiction (this data will be made anonymous)
• to protect the rights, property or safety of us, our customers or others; and
• where we have received your permission for us to do so.
VII. Data Storage
Security
We understand the importance of security and the techniques needed to secure information. We store all the Personal Information we receive directly from you in an encrypted and password protected database residing within our secure network behind active state-of-the-art firewall software. We also take measures to ensure our subsidiaries, agents, affiliates and suppliers employ adequate security measures. For security of transactions, we use the Secure Sockets Layer (SSL) protocol, which encrypts any personal information you enter registration forms on the Application. The encryption process protects your information, by scrambling it before it is sent to us from your computer.
Retention
We retain personal information for as long as we reasonably require it for legal or business purposes. In determining data retention periods, Senator Group takes into consideration local laws, contractual obligations, and the expectations and requirements of our customers. When we no longer need your personal information, we securely delete or destroy it.
Third-Party Practices
We cannot ensure the protection of any information that you provide to a third-party online site that links to or from the services or any information collected by any third party administering our affiliate program (if applicable) or any other program, since these third-party online sites are owned and operated independently from us. Any information collected by these third parties is governed by the privacy policy, if any, of such third party.
Our web site may contain links to other web sites, which are outside our control and are not covered by this Privacy Policy. If you access other sites using the links provided, the operators of these sites may collect information from you which will be used by them in accordance with their privacy policy, which may differ from ours. We are not responsible solely the operators of these websites shall be responsible for their functionality or possible errors on the linked sites.
VIII. Data security and data privacy, communication by email
Technical and organisational measures are used to protect your personal information from access by third parties during its collection, processing and retention. This level of protection cannot, however, be extended to communication by email and we recommend that you send all confidential information by normal post.
Disclaimer
The Services operate ‘AS-IS’ and ‘AS-AVAILABLE’ without liability of any kind. We are not responsible for events beyond our direct control. Due to the complex and ever-changing nature of our technology and business, we cannot guarantee, nor do we claim that there will be error-free performance regarding the privacy of your Personal Information, and we will not be liable for any indirect, incidental, consequential or punitive damages relating to the use or release of said Personal Information.