Cookies&Privacy Policy on GlitchSpin

This Privacy Policy explains how GlitchSpin and its direct and indirect subsidiaries (collectively referred to as “GlitchSpin”, “we”, “us”, or “our”) handle your personal data.

This Privacy Policy applies to the personal data collected from registered users (“Players”) who have an account on our website and from visitors to our site.

Who We Are

The operator of this website is the data controller responsible for your personal data. We act as the data controller because, in the context of our business relationship with you, we decide how and why your personal data is processed as explained in this notice. Along with our joint data controllers, we maintain ownership and security of the personal data you provide to us.

If you have any questions regarding this notice, including any requests related to your privacy rights and data protection, you may contact our Data Protection Officer by sending an email to [email protected].

What Personal Data We Collect

Data You Provide Directly: we may collect the following personal data from you depending on how you interact with our services:

• Registration Data: To create an account on our website, you need to provide us with personal information, including your email address, date of birth, country, phone number, gender, full name, social security number, postal code, and username. During registration, we will also automatically receive your IP address and location data.
• Due Diligence Data: We collect identity card/driver’s license/passport number, proof of address, social security number, wealth/funding source information, bank details, and financial statements to comply with our obligations related to Know Your Customer (KYC), age and identity verification, anti-money laundering (AML), or other legal requirements.
• Financial Information: We may collect your financial details, including bank ID, CPR number, CPF number, IBAN, and payment system details, to facilitate withdrawals and deposits in your account.

Automatically Collected Personal Data:

• Device Information: We collect information about the device and software you use to access our services, including your IP address, operating system version, and device identifiers.

• Log and Usage Information: To understand how you use our services and improve them, we automatically collect information about your interactions with our services. Our servers log usage data when you interact with our website. This includes activity records such as content views, ad selections, searches, social media shares, session dates and times, pages you view, links to/from any page, and session duration. Some of this data is collected through cookies and similar technologies.

• Location Data: We may collect or infer your general location information when you use our services.

Personal Data We Receive from Others: we may collect your personal data from other sources to provide and personalize our services and/or comply with legal obligations. We may collect data from:

• Publicly available sources such as public and government databases, the internet, social media platforms, online and offline media.
• Commercially available databases and third-party entities, including financial and credit institutions, fraud prevention organizations, and public authorities. These sources help us verify your information and investigate suspicious activities, particularly for fraud prevention and anti-money laundering.

Why We Collect Your Data

We use the personal data we collect to:

• Provide our services to you
• Respond to your inquiries or requests
• Test, research, troubleshoot, and analyze data for the development and improvement of our products and services
• Predict, detect, and manage risks from harmful behaviors, fraud, and illegal activities
• Send marketing content, newsletters, and personalize our marketing to you
• Resolve any disputes that may arise, including investigations by law enforcement or regulatory authorities
• Comply with regulatory and legal obligations
• Maintain the security and functionality of the service, including ensuring the technical availability of the website and protecting our systems and intellectual property from security threats and unauthorized access

Legal Basis for Processing Your Personal Data Under the GDPR and other applicable data protection laws, we process your personal data when we have a lawful basis for doing so. For certain processing activities, more than one lawful basis may apply. Below are some of the lawful bases on which we rely:

• Contractual Necessity: We process your personal data to fulfill or enter into a contract with you. For example, to create and support your account, communicate with you to fulfill our obligations under the Terms and Conditions, etc.

Legal Obligation: Processing your personal data may be necessary to comply with legal obligations. Some of the processing activities we carry out to comply with legal obligations include:

• Verifying your age and identity under our KYC and AML obligations
  • Determining your location and applicable legal requirements using your IP data
  • Managing risks, including preventing problem gambling and promoting responsible gambling
  • Ensuring network and information security
  • Complying with legal processes such as subpoenas, court orders, or other judicial decisions
  • Preventing crimes related to money laundering, terrorism financing, fraud, or claims related to computers
  • Routine reporting activities to satisfy financial, technical, and legal requirements
  • Addressing your requests to exercise your rights under data protection laws

Legitimate Interests: When necessary, we may process your personal data to ensure our legitimate interests, those of a third party, or for commercial reasons, provided that your rights, freedoms, or interests do not override those interests. Examples of such processing activities include:

• Raising legal claims and preparing our defense in judicial/administrative processes
  • Implementing IT security and system security procedures to prevent potential crimes, secure assets, protect intellectual property, and ensure the technical availability and proper functioning of our site and apps
  • Managing our business relationships and improving our products and services
  • Engaging in analytics, data aggregation, and research for the development/improvement of services or marketing purposes
  • Customer segmentation for risk management, detecting harmful behaviors, and ensuring responsible gaming
  • Analyzing your gaming behavior using machine learning algorithms to suggest games and features you may enjoy
  • Detecting and preventing activities that compromise the integrity of our services, such as fraud, the use of unauthorized software or tools, abnormal patterns, or cheating

Consent: With your consent, we may carry out the following activities:

• Sending direct marketing messages via email, SMS, phone calls, website or app notifications
  • Customizing offers and promotional campaigns based on your gaming history and preferences
  • Using data regarding your online behavior to display targeted ads that may interest you
  • Personalizing and evaluating the effectiveness of our marketing to better align with your interests and preferences
  • Managing your participation in competitions, tournaments, rewards, loyalty programs, and promotional events

How We Share Your Personal Data

We may share your personal data with the following categories of recipients:

• Internally with authorized employees, commercial entities within the same company/group, contractors, agents, joint controllers, subsidiaries, and affiliates within our business group or connected to our parent company.
• Payment providers and financial institutions. To facilitate the use of our services, withdrawals, and deposits, we offer a variety of reliable third-party payment providers. We may share the following personal data with them: first name, last name, date of birth, email address, address, postal code, city, country, phone number, username. We may also share your KYC documents with payment providers to help them comply with their legal obligations and anti-money laundering duties.
• Third-party service providers as necessary to provide, manage, and improve our services, including customer support providers, email, SMS, and phone service providers, technology providers, and cloud hosting service providers.
• Marketing partners.
• Fraud prevention organizations.
• Third parties in the event of a corporate transaction or process, such as mergers, financing, acquisitions, bankruptcy, dissolution, transfer, liquidation, or sale of all or part of the business or our assets.
• Game providers.
• Data aggregators or analytics providers for conducting market research, data analysis, and improving services.

How Long Do We Keep Your Data

We will retain your personal data for as long as you maintain an account with us and for the fulfillment of the purposes described in this privacy notice.

Additionally, we may retain your data for longer periods as required by applicable legal obligations, such as anti-money laundering (AML) regulations or other regulatory requirements.

Once your account is closed and there is no longer a legal or business need to retain your data, your personal data will be deleted or anonymized, so it can no longer be linked to you.

Your Rights You have certain rights regarding the personal data we hold about you. These include:

• The right to request access to the personal data we hold about you and obtain information on how we process it.
• The right to correct or rectify any inaccurate or incomplete personal data concerning you.
• The right to delete, erase, or remove your personal data when there is no compelling legal or business reason for its continued processing.
• The right to restrict the processing of your personal data in certain cases.
• The right to request the transfer of your personal data to another party in a structured, commonly used, and machine-readable format.
• The right to object to the processing of your personal data, particularly if we process it for legitimate interests or direct marketing purposes.
• The right to withdraw your consent at any time, without affecting the lawfulness of the prior processing based on your consent.
• The right to lodge a complaint with a supervisory authority. You can do this in the EU member state where you reside, work, or where the alleged infringement occurred. To exercise your rights, please contact our Customer Support at [email protected] or our Data Protection Officer at [email protected].

Cookies and Other Tracking Technologies

We use cookies, tags, pixels, web beacons, and other similar technologies to enhance your experience on our website and apps. When you first visit our website or apps, we will ask for your consent to use non-essential cookies. Essential cookies, which are necessary for the website’s operation, do not require your consent. For more information about the specific cookies we use, their purposes, and how to manage your preferences, please refer to our Cookie Policy.

Data Security We prioritize the security of your personal data and implement robust measures to protect it from