CLICKJACKPOT - PRIVACY POLICY

[Last updated: 24th of August, 2018]

At, ClickJackpot, our aim is to provide you with a fun and entertaining gambling experience, but we take your security and privacy just as seriously.

For your peace of mind, you can find our complete Privacy Policy below.

This Privacy Policy applies to ClickJackpot Services including playclickjackpot.com and clickjackpot.eu, as well as to all ClickJackpot Group’s other brands, websites, products or services.

The aim of this policy is to give you better understanding of:

- What personal information we collect
- Why we collect it and how we use it
- How this information is shared
- The rights you have to your personal data
- Other privacy and security information

Please note, you should read this notice in conjunction with our Terms and Conditions.

References to “we” “our” and “ClickJackpot” all refer to the ClickJackpot Group and the relevant Data Controller.

Data Controller:
The data controller for ClickJackpot is Sapphire Solutions OÜ, Harju maakond, Tallinn, Kesklinna linnaosa, Liivalaia tn 33, 10118, Estonia.

Your Personal Information:
To register an account with us, you will need to provide some personal information. Examples of this may include, but are not limited to; your name, email address, home address, telephone number, date of birth and debit/credit card data. It is our primary concern that this data is kept safe and secure at all times, and our methods of ensuring this are covered within this policy page. When we receive your registration information, your details will be processed, giving you access to our online gambling services, full customer support, and deposit and withdrawal options.

Additionally, as you start to enjoy using our Services, in order for us to provide you the gambling services contracted for, or to comply with a legal obligation, or in our or your legitimate interest, we will collect other types of information including: IP address and browser type; device information; your betting, gaming, payments and other account transactions; chat transcripts, email correspondence and occasionally phone calls are recorded for training purposes; social media details and other information derived from publicly available sources and third party sources – as discussed below. We will also use the personal data we collect to personalise our offering to you and as part of our risk management services, in furtherance of our legitimate interests.

We'll also use some of this information to tell you about our latest and/or personalised offers and promotions, and notify you of any changes to our website or policies.

Sharing and Processing your Personal Information:
We may share your information with any other companies within our Group, which is defined as “internal” sharing – ie it never leaves the ClickJackpot infrastructure.

An example of this is in the case of a self-exclusion, where it is necessary to apply this across all brands and products operated by the ClickJackpot Group. In such cases, the relevant data would need to be processed internally to ClickJackpot Group companies that operate other brands or websites.

In order to provide you with the full gambling services you signed up to enjoy, your personal data will also be shared with essential third-party service-providers, such as platform providers, game providers, payment-facilitation processors, financial institutions, auditors and contractors.

This sharing & processing may also be required in order to comply with a particular legal or regulatory obligation, for example in relation to our legal obligation to properly identify and verify our customers, we may use 3rd party electronic database providers who allow us to verify customer information. This type of processing also applies in relation to our compliance with Anti-Money Laundering or Responsible Gambling requirements, as well as crime prevention, detection or investigation of a crime or fraud. This processing also includes referrals to regulatory or sporting integrity bodies.

Your information will not be disclosed to government institutions or authorities unless:

• We have your written consent OR,
• We are required to respond to subpoenas, court orders or legal processes

Marketing Communications:
Where we have the appropriate consent or lawful basis and subject to your preferences, some of your personal details will be processed by our 3rd party marketing partners in order to allow us to communicate with all our customers either by phone or email or push notifications (if you downloaded the app). This may include Email & SMS sending platform providers, prize or gift suppliers, etc.

The intention of these communications is to send you marketing material which we hope will be of interest to you – about our promotions, new games, offers, prizes, events, etc. You will not receive marketing from third parties outside the ClickJackpot Group.

Consent for this processing can be removed, in whole or in part, at any time, by contacting customer support and letting us know what type of marketing communications you are happy – or not – to receive. You can also update your consent via your wallet dashboard.

All our marketing communications, whether by email or by SMS, will include instructions on how to opt out of receiving this specific type of marketing communication. Please contact us directly using the above details, if you wish to remove your consent for marketing activities completely and your personal details will be promptly removed from all of our marketing processes. Please allow up to 48 hours following on from your request for this to be fully carried out.

We will not share your personal data with unrelated third parties to market their products to you without your prior written consent.

Your Personal Data Rights:
Under the General Data Protection Regulation that came into force on the 25th May 2018, you have a number of rights to your personal data, which are detailed here:

• Right to Access personal data: You have a right to request a copy of the personal information that we hold about you. Please visit the Contact Us page to get in touch should you wish to make such a request. In your contact please give as much information as possible to identify yourself with, to assist us in gathering the information.
• Right to Erasure: You can request us to erase your personal data where there is no lawful basis requiring us to continue processing this personal data. This right only applies in certain circumstances given that legal obligations include data retention periods.
• Right to Rectification of Personal data: You can request that we correct any personal data that we are processing about you which is incorrect.
• Right to be informed: Where the application of a personal data right has impacted on your personal data, you have the right to be informed.
• Right to data portability: Similar to the right to access personal data, this right allows you to obtain your personal data in an electronic format that would enable you to transfer that personal data to another organisation, should it be relevant.
• Right to restrict / object to processing of personal data: in certain circumstances you have the right to object or restrict the processing of your personal data, where this is processing is based on consent or our legitimate interest. However, despite your objections or wish to restrict processing, where there are compelling legitimate grounds or legal obligations, we would be required to continue said processing.
• Rights relating to automated decision making and profiling: you have the right to not be subject to a decision which is based only on automated processing – ie without human involvement – where that decision has a legal impact or otherwise significantly affects you. We confirm that we do not make automated decisions of this nature.
• As referred to above, you also have the general right to withdraw the consent you have given us to process your personal data (in respect of our marketing activities) and where this processing is based on what we deem to be our legitimate interest.

Cookies:
We collect browser and cookie information when you first navigate to our websites. We use cookies to personalise your experience and for ease of your access. Some cookies will remember your username and password, or to remember your language preferences, etc. Cookies also then record other pages visited and content viewed before and after you use our services.

Security:
We take the security of your data and personal information very seriously, and have a number of measures in place to keep you protected.

Robust security policies, rules, and technical measures have been implemented to safeguard all of your account information. All employees, data-processors and third parties contracted by playclickjackpot.com are legally required to abide by a confidentiality agreement.

In addition, we use a firewall and RSA 128-bit encryption technology to help ensure that your details are always safe and secure.

Retention:
We retain all customer personal data and records for at least a period of 5 years post-account closure, in compliance with regulatory requirements and guidelines. We engage in periodic deletion of customer records where the account has been closed for more than 5 years. Should a current customer request a right to erasure, this would only be possible 5 years after the right to erasure request. Even after this period has elapsed, we would need to retain certain information under legal obligation (for example, in relation to responsible gambling and self-exclusion). We will take all necessary steps to ensure that the privacy of your information is maintained for the periods of retention.

Data protection outside the European Union:
Your personal information may be processed in any country where we or our affiliates, suppliers, subsidiaries or other companies within our Group operate. By submitting your personal information to us, you consent to the use of that information as set out in this Privacy Policy.

The data protection, privacy and other laws of countries outside the European Union countries may not be as comprehensive as those of European Union-member countries. In these instances, we will take steps to ensure that a similar level of protection is given to your information as is afforded the data of players within the European Union.

Anti Money Laundering Obligations:
Please note that we are legally obliged to comply with European and International Anti Money Laundering laws and regulations. These obligations require us to carry out certain tasks including but not limited to: screening for Politically Exposed Persons (‘PEPs'), Sanction List screening, monitoring of account activity to guard against potential money laundering risks, reporting of suspicious activity to the relevant financial crime authorities, etc. It also means that we are required to retain all customer records for a minimum of 5 years after the relationship between the customer and us has ended. This information is retained securely and confidentially at all times and we use industry standard practices in information security. Please contact Customer Support for more details.

Our Customer Support team are available between 9-17 during normal business days to answer any queries you may have regarding data protection and our privacy policy, or to withdraw your consent you’re your personal data being used by us to send you marketing communications. Please note that you can withdraw your consent also using your wallet dashboard. You can send your contact request to our Customer Support team 24/7