Introduction
10CRIC, which includes all of the entities specified below under
“The Group” section, including its affiliates (collectively, the
"Company"), offers online gambling services, such as casino, and
sports gambling, and operates the affiliate marketing program in
respect of same (collectively, the “Services”) via its own
in-house brands (each, an "In-House Brand"; together with the
Company: “Group”, "we", "our" or "us"). The Group is deeply
committed to safeguard the privacy expectations of its users
(“User(s)”, “you” or “your”). Accordingly, we have put in place
this Privacy Policy, which outlines our data protection practices,
including how we collect, use, disclose and protect your Personal
Information, as well as your rights with respect to your Personal
Information.
In this Privacy Policy, you can learn about:
We encourage you to read the Privacy Policy carefully and use it
to make informed decisions. By visiting the Group’s websites,
mobile apps or other online properties, or by creating an account
through our Services, you hereby agree to the Privacy Policy.
The Group provides the Services through the following
applications and platforms (collectively the “
Platforms”):
- This internet website;
- The Income Access Affiliate Platform;
-
Downloadable applications and software ("Software"), such as
native applications which are distributed through mobile
application stores and PC and Mac desktop software which can
be downloaded to your computer;
-
Non-downloadable online applications (e.g. flash applications,
HTML5 applications, etc.); and
We collect two types of information from our Users:
-
Personal Information
The first type of information is information that identifies
or may reasonably identify an individual reasonable effort (“
Personal Information”). Personal Information
which is being gathered may consist of the following:
-
Registration details: When you open an
account and register to use the Services, you will be
asked to provide us certain details about yourself, such
as: first and last name, email address, gender, birth
data, physical address, ID number, phone number,
occupation, etc. In addition, we may collect certain
information as required under various Know KYC and
Anti-Money Laundering regulatory requirements, such as
your source of funds.
-
Governmental-issued ID: In certain
instances, you will be required to provide a copy of a
governmental-issued ID, for identity verification process.
Please note that this information is required for certain
features of our Services.
-
Transaction information: in order for us to provide the
Services, we automatically record different information
related to your account and use of our Services,
including with respect to your transactions, referrals,
and balances, as applicable.
-
Payment information: In order for you to
enjoy all of the functions of the Services, payment
information will be collected from you, such as your
currency, credit card number and bank account details.
-
Voluntary information: We also collect
information which you provide us voluntarily. For example,
when you respond to communications from us, communicate
with us via email or share additional information about
yourself through your use of the Services.
-
Device information: We collect specific
types of connection details and information with regard to
your device, software or hardware that may identify you,
such as: device’s unique identifiers (e.g. UDID, IMEI, MAC
address), browser fingerprinting, IP address and
geo-location data.
-
Telephone calls: We may record or monitor
telephone calls for affiliate support, for training and/or
security purposes.
-
Information we collect from third parties: We collect Personal
Information from third party
service providers, such as information about your credit
history from credit agencies and other financial
information which is relevant to the provision of the
Services, as well as information which is gathered in
order to verify your identity and prevent fraudulent or
illegal activity.
-
Non-personal information
The second type of information is un-identified and
non-identifiable information pertaining to a User(s), which
may be made available or gathered via the User’s use of the
Services (“Non-Personal Information”).
Non-Personal Information which is being collected consists of
technical information and aggregated usage information, and
may contain, among other things, the User’s operating system,
type of browser, screen resolution, browser and keyboard
language, the User’s ‘click-stream’ and activities on the
Services, the period of time the User visited the Services and
related time stamps, etc.
For avoidance of doubt, any Non-personal Information
connected or linked to any Personal Information shall be
deemed as Personal Information as long as such connection or
linkage exists.
Types of Non-personal Information we collect from or about
you:
-
Technical information: In order to
enhance the functionality of the Services and to provide
you with a better user experience, we collect technical
information transmitted by your device, including certain
software and hardware information (e.g. the type of
browser and operating system your device uses, language
preference, access time and the domain name of the website
from which you linked to the Services; etc.).
-
Transaction information: We record
financial transaction information including, amongst other
things, commissions, payouts etc. and share and publish
such information through any of our Platforms.
-
Analytics information: We collect
information about your use of the Services, such as
applications' usage, log files, user activity (e.g. pages
viewed, the amount of time spent on particular pages,
online browsing, clicks, actions, etc.), time stamps,
alerts, etc. This information is collected for amongst
other things troubleshooting errors and bugs as well as
for research and analytics purposes about your use of the
Services.
-
Anonymous information: We may anonymize
or de-identify the information collected by the Services
or via other means so that the information cannot, on its
own, personally identify you. Our use and disclosure of
such aggregated or de-identified information is not
subject to any restrictions under this Privacy Policy, and
we may disclose it to others without limitation and for
any purpose, such as for advertising or marketing
purposes.
The Services are not designed or directed to persons under the
age of 18 or persons under the age of legal consent with respect
to the use of the Services of any jurisdiction, whichever is
higher (“Legally of Age”). If you are not Legally of Age, you
should not download or use the Services nor provide any Personal
Information to us.
We reserve the right to access and verify any Personal
Information collected from you. In the event that we become
aware that a user who is not Legally of Age has shared any
information, we may discard such information. If you have any
reason to believe that a minor has shared any information with
us, please contact 10CRIC Affiliate Support at
[email protected].
We use your Personal Information for the purposes listed below:
- To set up, manage and update your account;
-
To provide and operate the Services (such as for payment
processing);
-
To communicate with you and to keep you informed of our latest
updates to our Services and special offers;
-
To market our Services (see more below under “Marketing”), as
well as to serve you advertisements, including behavioral
advertising;
-
To conduct analytics, statistical and research purposes, in
order to improve and customize the Services to your needs and
interests (such as by compiling aggregated reports about the
usage of certain features of our Services);
-
For Customer Relationship Management purposes, and to support
and troubleshoot the Services and to respond to your queries;
-
To enable us to further develop, customize and improve the
Services based on Users’ common preferences and uses;
-
To provide you with a responsible affiliate marketing
environment;
-
To communicate with your and to process any of your requests
to exercise your User Rights;
-
To identify and authenticate your access to certain features
of the Services;
-
To detect and prevent fraudulent and illegal activity or any
other type of activity that may jeopardize or negatively
affect the integrity of the Services, including by identifying
risks associated with your activity on our Services;
-
To investigate violations of our policies and 10CRIC Affiliate
Terms and Conditions as well as enforce our policies and the
10CRIC Affiliate Terms and Conditions;
-
To investigate and resolve disputes in connection with your
use of the Services; and
-
As required by law or regulation (such as Know Your Customer
("KYC") and Anti-Money Laundering regulatory requirements), or
as required by other governmental authorities, or to comply
with a subpoena or similar legal process or respond to a
government request.
The Group will use your Personal Information, such as your name,
home address, email address, telephone number etc., ourselves or
by using our third party subcontractors for the purpose of
providing you with promotional materials, concerning the
Services as well as products, services, websites and
applications which relate to: (i) other companies within the
Group; (ii) or (ii) the Group's business partners and affiliates
(collectively: “Marketing Affiliates”), which we believe may
interest you.
We may also share and disclose Personal Information with our
Marketing Affiliates for the purpose of providing you different
marketing offers, which we, or our Marketing Affiliates, believe
are relevant for you. Our Marketing Affiliates may use this
Personal Information for different marketing techniques, such as
direct email, post, SMS and telephone marketing purposes.
You may at any time decline receiving further marketing offers
from us or from Marketing Affiliates by contacting 10CRIC
Affiliate Support at:
[email protected], or by unsubscribing from
receiving marketing materials by
following the guidelines available on the marketing
communications (such as clicking on an “unsubscribe” button).
Please note that even if you unsubscribe from our marketing
mailing list, we may continue to send you service-related
updates and notifications.
We do not rent, sell, or share your Personal Information with
third parties (“Recipients”) except as described in this Privacy
Policy. The Personal Information will be disclosed to Recipients
only to the extent required for the specific purpose, as
stipulated in this Privacy Policy.
We share Personal Information with any of the following
recipients:
-
Any replacement service provider that we engage with to
operate the Platforms;
-
Companies within the Group and other affiliated companies;
- Gaming providers;
-
Subcontractors and third party service providers, as well as
their subcontractors, which by way of example include (but is
not limited to) cloud computing companies, marketing
affiliates, identity verification and fraud prevention
services, and other data verifiers;
- Credit reporting agencies;
-
Payment service providers, payment processors and banks;
-
Any third parties who provides services in relation to the
operation or promotion of the applicable Group’s brands;
-
Any third parties who organize offline events or tournaments
on behalf of or in conjunction with any companies within the
Group;
-
Hotels and flight companies (such as in the context of offline
events and promotions);
-
Auditors, contractors or legal/financial/other advisers of any
of the Group’s business processes;
-
Any third parties who investigate, detect or prevent
fraudulent or illegal activity (e.g. governmental authorities,
police, banks and other investigatory organizations);
-
Licensing authorities, governmental and regulatory bodies, in
accordance with applicable laws and regulations; and
-
Potential purchasers, successors or investors in any of the
companies within the Group, or in the event of a corporate
transaction (e.g. sale of a substantial part of our business,
merger, reorganization, bankruptcy, consolidation or asset
sale of an asset or transfer in the operation thereof) in
relation to any company within the Group (in such event, the
acquiring company or transferee will assume the rights and
obligations as described in this Privacy Policy).
In addition to the purposes listed in this Privacy Policy, we
share Personal Information with those Recipients for any of the
following purposes:
-
Storing such information on our behalf, for example by using
cloud computing service providers;
-
Processing such information to assist us with our business
operations (e.g. to process payments and your deposits;
authenticate your access; auditing our operations; detect and
prevent fraudulent or illegal activity; etc.);
-
Performing research, technical diagnostics or analytics;
-
Communicating targeted advertising, as well as promotional and
informational materials, in accordance with our marketing
policy (see above, in the section titled "Marketing"); and
-
Whenever we believe in good faith that disclosure is necessary
to protect our rights or legal claims, enforce our policies
(including our User Agreement and Privacy Policy), protect
your safety or the safety of others, as well as to investigate
or prevent any fraud, for security reasons or to help us with
any other related technical issue.
Since we operate globally, it may be necessary to transfer your
Personal Information to countries outside the European Union.
The data protection and other laws of these countries may not be
as comprehensive as those in the European Union.
We use best efforts to ensure that your Personal Information is
protected in accordance with our privacy policy, through
contractual means (such as by using the contractual clauses
approved by the relevant regulators for data transfer) or other
means (such as ensuring that the jurisdiction imposes adequate
safeguards for data protection).
If you feel that your privacy was treated not in accordance with
our policy, or if any person attempted to abuse the Services or
acted in an inappropriate manner, please contact us directly at
Customer Service.
When you visit or access our Services (for example when you
visit our websites), we use (and authorize third parties to use)
web beacons, cookies, pixels, scripts, tags and other
technologies ("Tracking Technologies").
The Tracking Technologies allow us to automatically collect
information about you and your online behavior, as well as your
device (for example your computer or mobile device), for
different purposes, such as in order to enhance your navigation
on our Services, improve our Services’ performance and customize
your experience on our Services. We also use this information to
collect statistics about the usage of our Services, perform
analytics, deliver content which is tailored to your interests
and administer services to our Users, advertisers, publishers,
customers and partners.
We also allow third parties to collect information about you
through Tracking Technologies. To learn more please see our
Cookie Policy below.
While using the Services you may encounter links to third party
websites, services or applications. Please keep in mind that
this Privacy Policy does not apply to any third party websites,
services or applications, even if they are accessible,
downloadable, or otherwise distributed through the Services.
Please be advised that such third party websites, services or
applications are independent from the Group. We assume no
responsibility or liability whatsoever with regard to privacy
matters or any other legal matter with respect to such third
party websites and/or services. We encourage you to carefully
read the privacy policies and the terms of use of such third
party websites and/or services, as their terms, not ours, will
apply to any of your interactions with such third parties.
You should always review their privacy practices carefully
before providing Personal Information to such third parties.
You are knowingly and voluntarily assuming all risks of using
any third-party websites, services or applications. You agree
that we shall have no liability whatsoever with respect to such
third party sites and your usage of them.
If you have registered with an account through our Services, the
Group will retain your Personal Information during the period
your account is active. In addition, the Group will retain your
Personal Data for additional periods, to enable the Group to
meet its legal obligations under applicable laws or regulations,
such as the applicable gambling regulations, Know-Your-Customer
and Anti-Money Laundering regulations.
In addition, the Group may retain your Personal Information for
longer periods, provided that retaining such information is
necessary for the Group’s legitimate interests, such as fraud
prevention and record keeping.
You may contact us at any time by email at:
[email protected], and request:
-
To access or delete any Personal Information relating to you;
-
To change or update any Personal Information relating to you
(for example, if you believe that your Personal Information is
incorrect, you may ask to have it corrected or deleted). Note
that you may also request that we will correct errors with
regard to your Personal Information (except in cases where the
information is required to be kept in its original format
under any applicable laws and regulations);
-
That we will restrict or cease any further use of your
Personal Information;
-
That we will provide the Personal Information you volunteered
to us in a machine-readable format.
Please note that these rights are not absolute and requests are
subject to any applicable legal requirements, including gambling
regulations and other legal and ethical reporting or document
retention obligations. We may also rectify, replenish or remove
incomplete or inaccurate information, at any time and at our own
discretion, in accordance with our internal policies.
We take great care in implementing and maintaining the security
of the Services and your information. We have put in place
appropriate physical and technological safeguards to help
prevent unauthorized access, to maintain data security, and to
use correctly the information we collect online. These
safeguards vary based on the sensitivity of the information that
we collect and store.
We employ industry standard procedures and controls to ensure
the safety of our users’ information, such as:
-
Secure network topology, which includes intrusion prevention
and Firewall systems;
- Encrypted communication;
- Authentication and Access Control;
- External and Internal audit tests; etc.
Although we take reasonable steps to safeguard information, we
cannot be responsible for the acts of those who gain
unauthorized access or abuse the Services, and we make no
warranty, express, implied or otherwise, that we will prevent
such access.
We reserve the right to change this Privacy Policy at any time,
so please re-visit this page frequently. We will provide notice
of substantial changes of this Privacy Policy on the Services
and/or we will send you an e-mail regarding such changes to the
applicable e-mail address that you provided to us. Such
substantial changes will take effect seven (7) days after such
notice was provided on any of the above mentioned methods.
Otherwise, all other changes to this Privacy Policy are
effective as of the stated “Last Revised” date, and your
continued use of the Services after the Last Revised date will
constitute acceptance of, and agreement to be bound by, those
changes.
We use cookies in order to provide you with a high-quality and
personalised experience.
A cookie is a small text file that is stored on your computer,
laptop or mobile device when you visit a website or use
applications. Cookies may be used for many different purposes
such as remembering your preferences, following your use of our
website and improving your user experience.
We use three different types of cookies:
Essential Cookies- These cookies are necessary for the website
to function properly or to provide a service which you request.
These cookies are usually only set in response to your actions,
such as in the case of auto form filling or logging in. Your
browser can be set to block these cookies but the website will
not perform properly if you decide to do so.
Functionality Cookies - These cookies help to provide you with a
more personalised user experience and are used by us and select
third parties whose services feature on our pages. Blocking
these cookies will disable these services and may affect your
Website experience.
Performance Cookies - These cookies collect information about
how you use a website or application and assist us in improving
the performance of our website. Blocking these cookies means
that we cannot work effectively to improve the usability of our
website.
Cookies may be stored either for the duration of your visit to
the website or for repeat visits:
Session Cookies - These cookies allows us to link your actions
during a browser session. A browser session starts when you open
the browser window and finishes when you close it. Session
cookies are created temporarily and are deleted once the browser
window is closed.
Persistent Cookies - These cookies remains on your device for a
set period of time specified in the cookie and activated each
time you visit the website that created that particular cookie.
You may modify your browser so that it will not accept cookies.
Please see the "Help" section of your browser for instructions.
If you have any general questions about the Services or the
information that we collect about you and how we use it, please
contact us via email at:
[email protected].
We will make an effort to reply within a reasonable timeframe.
Please feel free to reach out to us at any time. If you are
unsatisfied with our response, you can reach out to the
applicable data protection supervisory authority.