Privacy Policy

Privacy Policy, version February 21st 2022

1. INTRODUCTION

One Casino Limited (“One Casino”, the “Company”, “OCL”, “we”, “our”) is committed to maintaining the highest standards of data privacy, confidentiality and information security. Protecting the confidentiality and integrity of information and of personal data is taken seriously at all times.

We process data in compliance with the requirements laid down by all applicable data protection legislation, including but not limited to the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and the Data Protection Act, Chapter 586 of the laws of Malta, and by the Data Protection Commissioner of Malta. In this Privacy Policy (the “Policy”), we will explain what personal data we collect and for which purposes. We recommend that you read it carefully.

The following definitions shall have the same meaning as those contained in the GDPR: “Data Subject”, “Data Controller, “Data Processor”, “Personal Data”, “Process” or “Processing”.

One Casino values the privacy of its customers and takes appropriate care in processing and protecting personal data. This Policy sets out how we deal with the player’s (“you”, “your”, “User”) Personal Data, in our capacity as Data Controller. If you have any queries about this Policy or anything it contains, please contact our Data Protection Officer (DPO) by e-mail on dpo-officer@onecasino.com.

This Policy must be read in conjunction with our Player Terms and Conditions https://www.onecasino.com/termsandconditions and any other relevant document referred to by One Casino as issued and amended from time to time.

By using this website you agree with and consent to this Policy.

2. PURPOSE AND SCOPE

The purpose of this Policy is to establish the important information pertaining to the collection, processing,storage and retention of your personal details as well as establishes rules and controls to ensure compliance withapplicable data protection and privacy laws in line with the provisions of the GDPR that is applicable to One Casino. This Policy sets out how One Casino processes personal data it collects and holds about individuals lawfully and in a manner that is fair to the data subject.

3. PRIVACY PRINCIPLES

As One Casino is based in Malta, we follow the rules of the GDPR. This means that whenever we handle your personal data, we always follow the GDPR principles:

• Lawfulness, fairness and transparency:
• We identify valid grounds for collecting and using personal data. We use personal data in a waythat is fair. We do not mislead the data subject and always be clear, open and honest with individuals from the start on how the personal data shall be used.
• Purpose limitation:
• One Casino is clear about what the purposes for processing information are from the start of the relationship.
• Data minimisation:
• Ensuring that the personal data we are processing is sufficient to properly fulfil our purpose as well as has a rational link to that purpose. We do not hold data that we do not need for that purpose.
• Accuracy:
• All reasonable steps are taken to ensure that personal data we hold is not incorrect or misleading. In the event that we discover that personal data is incorrect or misleading, we take the appropriate steps to correct and / or erase it as soon as possible.
• Storage limitation:
• One Casino has established retention periods in a separate Data Retention Policy, which outlines the duration of data retention ensuring that no data is kept long than required.
• Integrity and confidentiality:
• We ensure that we have the appropriate security measures in place to protect the personal data we hold on individuals.
• Accountability:
• One Casino has the appropriate measures and records in place to be able to demonstrate our compliance.

4. PERSONAL DATA

Data Collection at Registration

Certain features of our services require you to register beforehand. When you register for an account with One Casino you enter into a contract with us, as we explain in our Terms and Conditions. For us to be able to perform this contract and provide you with access to our services, we need to collect and process some personal information about you. We will always make it clear which information is mandatory and which information you can decide not to give us if you don’t want to. If there are pieces of information that are mandatory and you don’t want to provide it to us, then you will not be able to have an account with us and use our services. We will only ever ask you for the smallest amount of information that we need and we only ever use it for lawful purposes. We never sell your information to anyone else.

To register on our website, we require the following data:

• Username
• Password
• Date of birth
• Address and place of residence
• Gender
• Name and surname
• Email address
• Phone number

If these required fields are not filled in, you will not be able to create an account. Besides this information requested upon registration, we collect the following data:

• IP addresses
• Your gaming history
• Your financial transaction history
• Your used Devices
• Your sign up time
• Your payment history
• Your withdrawal history
• Your bank details
• Your limits set
• Your self exclusions
• Your communication with customer support
• Your bonuses
• Your login times
• Your used browsers
• Phone numbers used for payments
• Skrill usernames
• Neteller ID’s

For the verification of your account, we require copies of:

• Identification (ID card/passport)
• Proof of address (Recent utility bill)

Documents required for the verification of your account might be processed via a Third Party.
For a small group of users, we also require a copy of:

• Proof of finance (Recent bank/credit card statement)

We collect these copies and store them in a safe and secure manner.

We use this information to:

• Help you create, operate and manage your personal profile, allowing you to access our games and services;
• Carry out age and identity verification checks.
• Verify source of wealth.
• Carry out due diligence checks.

Manage loyalty points and reward schemes;

• Protection of your personal profile and account;
• Process your bets and transactions, including your use of credit/debit cards and online payment systems;
• Provide customer support and service updates;
• Analyse user trends and improve the services we provide;
• Manage registration of duplicate accounts and individuals from jurisdictions where gambling is prohibited.
• Monitor and investigate transactions and game play in order to prevent and detect fraud, money laundering, problem gambling and other irregular gaming activities.
• Consult self-exclusion registers and manage problem gambling.

After your registration we will retain your username and the personal data you provided. This is so that you do not have to re-enter it every time you visit our website, to contact you in connection with the execution of the agreement, regarding withdrawals or deposits and to provide an overview of the services we have delivered to you.

Data Source

The majority of the information that we have about you is the information you provide to us yourself. However, sometimes we also get information about you from other sources. There are specific reasons for this. As part of our legal obligations, including those concerning Anti Money-Laundering (AML) and Combating the Financing of Terrorism (CFT), we are required to carry out due diligence checks with established identity verification service providers that confirm your identity, including your age. In some circumstances we may also need to verify your source of wealth. We work with reputable external companies to carry out these checks and they provide a report which contains information about you and your background. In addition to this, we also carry out our own legitimate searches for information available to us from open sources, such as social media and public registers.

In some circumstances, payment service providers may supply us with a small amount of personal information when they carry out a transaction for you so that we can connect transactions to you as a player.

We may also receive information about you from national self-exclusion registers. We query national registers so we can ensure people who have signed up to self-exclude from gambling websites can’t have an account with us. These national registers will let us know if you are signed up with them so we can exclude you from our services.

You may also choose to authorise third parties to share personal information with One Casino. For example, authorising banks and financial institutions to share personal information with us in order to assist with your registration and account verification.

Legal Obligations

Some of the information we process about you is necessary for us to meet the legal and regulatory obligations that we have as a licenced gambling company. This includes licensing requirements, responsible gaming obligations and AML Regulations, such as:

1. To maintain our AML and player protection obligations, including via risk assessment exercises;
2. To prevent fraud;
3. When you do not want to receive our marketing communication, but your account is not self-excluded;
4. To ensure you are always protected by our network security systems;
5. To personalize your gaming experience (in line with the relevant Commercial Communication Legislation);
6. To improve your customer experience. For example, to identify software issues and analyse your feedback, customer logs are stored.

Data Sharing with Third Parties

There are some circumstances where we need to share your information with recipients who are outside of One Casino in order to provide our services. When we carry out any sharing with third parties we always ensure that there is an appropriate contract in place, that the information being shared is transferred in a secure way and that we only share the smallest amount of your information that we need to. One Casino will never sell your information to any other parties.

The third parties we share information with include:

• Payment service providers
• Corporate services providers
• Auditors
• Legal counsel
• Analytics services
• Identity verification and AML related service providers
• Website performance and security system providers
• Marketing and advertising companies
• Communications platform providers
• Social media platforms
• Game providers
• National self-exclusion registers
• Banks, payment card and financial services providers
• Other companies within the One Casino group or same ownership structure.

We may receive a request to disclose information about you with law enforcement, regulators and supervisory authorities. We will always ensure that the organisation requesting the information has a legal basis to do so and will only share the smallest amount of information required in a secure way. We will also proactively share your personal information with law enforcement, regulators and supervisory authorities where we believe a criminal act has been or may be committed.

There may be times when you share information with us that leads us to believe that there is a risk to your life or wellbeing. Where this is the case, we will share your details with local authorities in your area so that they can check on your wellbeing and ensure your safety.

International Transfers

Wherever possible, One Casino keeps your information within the European Economic Area (EEA). However in some circumstances your information may have to leave the EEA, such as when we work with non-EEA third parties. One Casino always makes sure that any transfers outside of the EEA are carried out in line with the law, have appropriate legal protection and are carried out securely.

Where personal information is transferred outside of the EEA to a country that the EU has not determined to be adequate, we always implement the EU Commission’s Standard Contractual Clauses between ourselves and the entity that is receiving the personal information. This ensures your personal information is protected and safe at all times and that the transfer of the information is lawful. Some of the third parties that we use are based in the US. Where these third parties are signed up with the EU-US Privacy Shield, they are considered by the EU to offer an adequate level of data protection so we do not implement the EU Commission Standard Contractual Clauses.

A small number of people that work for One Casino are located outside of the EEA. We require them to work in line with all of our internal policies and procedures, and they also have the EU Commission’s Standard Contractual Clauses added to their employment contracts to ensure that your information is protected and safe at all times and that the transfer of the information is lawful.

Data Retention

One Casino has a number of legal obligations when it comes to retaining your personal information. Depending on the activity on your account, we will keep your personal information for between 5 and 10 years after you close your account with us. Any health documentation you may have chosen to provide to us will not be retained and will be deleted once it has been reviewed by our Responsible Gambling key function and DPO.

All closed and self-excluded accounts are kept protected until the retention period is over and then the information is securely destroyed.

Your rights regarding your personal information

As a user, you have certain rights regarding your data or personal information. These rights include the right to access your data, to rectify your data, to delete your data and to restrict it, as well as to transfer your data. These rights are explained below.

(i) Right to access and to change your data

We would like you to be aware of the personal data being processed and for you to be able to verify this processing. This is why you have the right to obtain a confirmation that data about you is being processed. By that you also have the right to receive a copy of your personal data that is being processed.

If you have the impression your personal information is collected wrongly, you have the right to change this data. When you wish to adjust your data, please contact our Data Protection Officer via dpo-officer@onecasino.com.

(ii) Right to object to the processing of your data

When there are actions we undertake that you do not fully agree with, you have the right to object to these. You have the right to object to the following actions:

• Processing based on legitimate interests pursued by us or the performance of a task carried out by us in the public interest;
• Processing with the purpose of scientific or statistical research.

Objecting to activities that are associated with direct marketing, such as profiling, is also your right. When you object to this, you will not receive any future offers of which we think are interesting for you.

(iii) Right to withdraw your consent

Where we have your consent (which we collect as part of the registration process), One Casino will contact you about news, promotions, such as our newsletter, and bonuses. We will only ever contact you for these reasons if we have your prior consent to do so.

However, when you do not like to have your data processed anymore for this (for example when you do not want to receive our newsletter anymore) you have the right to withdraw your consent

You have full control over whether and how we get in touch (including the channels that we contact you on) through the settings in your account, which you can access and change at any time.

Withdrawing your consent can also be done by clicking the ‘unsubscribe’ button we have in all of our marketing related communication you receive by email. If your findings result there is no unsubscribe button visible in the communication sent to you, please contact our Data Protection Officer on dpo-officer@onecasino.com.

If you choose to withdraw your consent to marketing, we will action this straight away and you will no longer receive these messages from us. However, please note that on rare occasions you may still receive a further marketing message from us within 24 hours of unsubscribing while our systems update.

You should be aware that even if you do not consent to marketing messages, you may still receive the occasional service email from One Casino. These messages are so that we can inform you of changes to Terms and Conditions and this Policy, as well as anything else that may impact the service, we are able to provide to you, such as availability of payment methods.

(iv) Right to be forgotten (right to erasure)

The right to delete your data (also known as ‘the right to be forgotten’) is applicable to you when you would like to request having your own personal data deleted and free from processing in the future. The right to delete exists in the following situations:

1. When the personal data is no longer necessary for the purpose it was collected or processed for;
2. You withdraw consent and there is no other legal ground for the processing;
3. When you object to the processing and there are no overriding legitimate grounds;
4. If the personal data was processed in a way that is not in accordance with laws;
5. If the personal data has to be removed to comply with a legal obligation.

The right to erasure is not an absolute right. This means that it doesn’t always apply to everyone. In order to have your information deleted, you need to fall into one of a small number of categories. In addition to that, there are a number of categories, known as exemptions, where the right to have your information deleted doesn’t apply at all.

One Casino has to comply with its legal obligations under AML laws. Under these laws we are required to keep all information about any business relationship formed with an individual, up to the retention period assigned to the account. The right to delete your data is therefore subject to a retention period of five years.

Although the right to erasure does not apply to all players with One Casino, we can close your account with us which will mean that you would no longer hear from One Casino and your account would no longer be active.

If you would like your data deleted, please contact us by visiting https://www.onecasino.com/contact or by contacting our DPO on dpo-officer@onecasino.com

(v) Right to data portability

With this right, we will transfer your information to you in a transparent way that makes it easy (a machine-readable format) to transfer it to other organizations. You are also entitled to request us to transfer your concerned information to the other organization directly. The right to data portability applies in the following situations:

1. Personal data which is processed by automated means (which means no paper records);
2. Personal data which you provided us with;
3. Only when you have given consent to processing the personal data.

If you would like to exercise any of these rights, you should email our DPO on dpo-officer@onecasino.com from your registered email address and provide:

• Your name
• Contact details
• Your username
• Full details of your request

In some circumstances we may request that you provide us with ID so that we can verify your identity. If this is needed we will let you know and explain the ID that we require. Some of these rights only apply in certain circumstances, so if we are unable to action your request we will explain to you why.

5. SENSITIVE PERSONAL INFORMATION

One Casino will never ask you to provide any sensitive personal information, such as information about your health or race or ethnic origin. There may be times when you may choose to disclose information like this to us, such as when you are speaking with our Responsible Gaming key person or DPO, and these chats and emails are assigned to your account with us. Where you have a health condition that affects your ability to control your gambling behaviour and you choose to provide us with documentation to support this, we will make note that you have a health condition but delete the documentation you provide to us. Where you disclose a health condition which we feel may impact your ability to make rational decisions around your gameplay, we may take the decision to block you from our services for your own safety.

6. PAYMENTS

One Casino provides safe and secure payment options. All of our payments are carried out using a safe and secure SSL connection. We only support reputable online payments providers.

7. SOCIAL MEDIA

Our website features social media buttons. These buttons are used by the providers of these services to collect your personal data. We refer you to the cookie policies and privacy and policies of these providers, which are subject to change.

8. SECURITY

We take security measures to reduce misuse of and unauthorized access to personal data. We keep statistics on our website, but these are kept anonymous at all times.

9. THIRD-PARTY WEBSITES

This Policy is not applicable to third-party websites that may be connected to this website through hyperlinks. We cannot guarantee that these third parties will handle your personal data in a secure and careful manner. We recommend you to read these websites’ privacy statements before making use of their services.

10. COMPLAINTS

When the way we processed your personal data raises certain dissatisfaction on your part, there is a possibility for you to file a complaint. File a complaint by contacting our DPO on dpo-officer@onecasino.com and they will investigate your case. When our answer does not sufficiently satisfy you, you are entitled to submit your complaint to the Office of the Information and Data Protection Commissioner of Malta.

Making a Complaint in relation to your Personal Data

If you are unhappy with how your information has been handled by One Casino the first thing you can do is raise your query by emailing our DPO to try and resolve it.

You can do this by sending an email to dpo-officer@onecasino.com and detailing:

• Your name
• Your contact details
• Your username
• Full details of the complaint that you have

The DPO will then look into your complaint and investigate whether your information has been handled appropriately and in line with this Policy, our legal obligations and our internal policies and procedures. The DPO will then contact you regarding the outcome of the investigation and any steps that have been taken as a result.

10. COOKIES

One Casino processes a small amount of information about anyone who visits our website. We do this so that we can better understand the people who use our services and to help us identify where there are problems for users, such as security issues or things going wrong. We do this by using technical programmes. When we process information in this way it is necessary for the legitimate interests of One Casino to ensure that we provide an enjoyable, secure and smooth customer journey and that we protect our services from abuse that could compromise the ability of other users to use the service.

Cookies are a standard method of registering user preferences when people use websites, to ensure a better and more personalised experience. These preferences are stored in a file on your computer's hard disk drive. For example, a cookie would contain your preferred country of residence so we do not have to ask you this question each time you visit.

Our website uses both persistent and session cookies. Persistent cookies are cookies that stay on your computer permanently until you “manually“ delete them. Session cookies delete themselves automatically when you leave a website and go to another one or shut down your browser.

We use cookies on our website to recognize a computer when a User uses and returns to this website, to improve the user’s experience of this website, to personalise this website for Users, to enable the use of an account or wallet in this website, to track Users while navigating through this website, to analyse the use of this website, to prevent fraud, and other illegal activity in this website and to maintain and improve security of this website.

11. CALL RECORDING

Anytime you have a telephone call with One Casino, the call will be recorded. This is both when we make a call to you and when you make a call to us. You will always receive a notification at the start of the call so you know that the call is being recorded. We record all of our calls to comply with the legal obligations that we have as a gaming company, one of which is to record all contacts we have with our players.

There is not a way to opt out of having a call recorded if you make a call to, or receive a call from One Casino, but you can choose not to proceed with the call. You can also always communicate with us via written means such as email and live chat if you prefer. You will only be contacted with a phone call if you have given us your consent to contact you in this way and you can opt out at any time either through your account settings or by telling us on the call. The exception to this is where you have shared information with us that leads us to believe that there is a risk to your safety. In these circumstances we may try and contact you with a phone call to check on your well-being.

12. AUTOMATED DECISION MAKING AND PROFILING

We are required to take a number of steps to meet the rules around (AML, CFT, fraud and other illegal activities. In order to do this we have policies and procedures that monitor player behaviour and alert us of suspicious or fraudulent transactions and activity. Where relevant transactions are flagged we escalate these to the necessary regulators and enforcement bodies, and accounts may be blocked.

As part of our license, we also have obligations around responsible gaming. To ensure our compliance, we employ a system which flags any gambling patterns or behaviours exhibited by a player that could indicate problem gambling. When the system flags a player, one of our Responsible Gambling key function reviews the account and where necessary will contact the player for a discussion on their game play and provide information and advice.

We also use segmentation to split our players into groups based on their gaming behaviour. We do this to ensure people get the right marketing (e.g. the correct language and offers) and to help us understand how people use the product, develop our marketing approach, and ensure people receive offers they are interested in.

13. CHANGES TO THIS POLICY

We will review and update this Policy anytime there is a significant change to how we are using personal information and at least annually.

If we make any changes to this Policy we will summarise these changes below. We may also contact you to notify you of any significant changes if we think this is necessary.

14. INSPECTION AND MODIFICATION OF YOUR DATA

You can always contact us if you have any questions regarding this Policy or wish to review, modify or delete your personal data. Our contact details are available at: https://www.onecasino.com/contact