IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY POLICY

This privacy policy aims to give you information on how We collect and process your personal data through or in
conjunction with your use of this website and Our Services.

This Privacy Policy stipulates details and conditions of collecting and processing your Personal Details and
provides you with information in accordance with the transparency principle and requirements under the applicable
data protection laws.

This website is not intended for children and we do not knowingly collect data relating to children (below 18 years
of age).

CONTROLLER

Prize Draw Time Ltd is a legal entity and the controller responsible for your personal data (referred to as “the
Controller”, “We”, “we”, “us” or “our” in this Privacy Policy).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this
privacy notice. If you have any questions about this privacy notice, including any requests to exercise rights
please contact Us or the DPO using the details set out below.

CONTACT DETAILS

Although our goal is to always be as clear and transparent as possible, if you need any clarification on this
Privacy Policy or a specific legal basis. We are relying on to process Your Personal Data for a specific processing
operation. We would be happy to provide you with any such information you may need.

Our full details are:

General email address: support@prizedrawtime.com

Postal address: PrizeDrawTime, PO: 13659, Linlithgow, EH49 9BZ

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

We reserve the right, at Our complete discretion, to change, modify, add and/or remove portions of this Privacy
Policy at any time. You shall be, in advance, informed by Us of any material changes made to this Privacy Policy (as
well as other terms and conditions relevant to the Site).

THE DATA WE COLLECT ABOUT YOU

Personal Data: means any information that identifies You as an individual or that relates to an
identifiable individual.

Whenever it is not possible or feasible for Us to make use of anonymous and/or anonymised data (in a manner that
does not identify any Users of the Site or customers of Our services), We are nevertheless committed to protecting
Your privacy and the security of Your Personal Data at all times.

Data obtained from You: We collect from You, through interaction with You or through Your interaction with
Us or our Services different kinds of personal data about you which we have grouped together as follows:

1. Registration Data provided by you when you register and/or open Your Member Account (notably as specified in our
   T&Cs) including first name, last name, username or similar identifier, date of birth, territory applicable
   social security or similar identification number where permitted or required by law, gender, country.
2. Contact Data includes permanent address, email address and telephone numbers.
3. Identification and Verification Data (Anti-Money Laundering/Due Diligence/KYC data) that include your name,
   surname, permanent address and proof, age, nationality, family members and associates (including their KYC data if
   required), degrees and qualifications, schools/universities attended, employment history and information, media
   involvement, financial status information (e.g. bank statement including through open-banking solutions subject to
   Your authorisation, source of income and source of wealth, tax information), masked credit card details, proof of
   e-wallet ownership such as Netller, Skrill, Paypal, Paysafe, territory applicable personal identification where
   required or permitted by law, KYC documentation (e.g. ID card, Power of attorney).
4. Responsible Gambling Data (RG) including name, surname, postcode, email, phone number, country, date of birth,
   territory applicable social security or similar identification number where permitted or required by law,
   affordability limits (where applicable), approved transactions (deposits and withdrawals), denied transactions
   (deposits and withdrawals), Identification and Verification Data, Self-exclusion Data.
5. Self-exclusion Data include data pertaining to you and your self-exclusion such as your Registration and Contact
   Data and your self-exclusion information such as reason, start and date, utilisation of self- exclusion tools such
   as exclusions, session limit, loss limit, wager limit, deposit limit, reality check.
6. Payments Data includes bank/payment account details, as well as information pertaining to a transaction such as
   currency, location, amount/value, client IP, user ID, token.
7. Transaction and Usage Data generated through your use of our Services (e.g. playing Games) and include payments
   to and from you (deposits, withdrawals, failed deposits and reversed withdrawals) and other details of Services you
   have purchased from Us (such as bets, wagers (real and bonus), wins), date and time of the transactions, account
   balances (bonus and real), bonuses used (conversion and forfeiture), bonuses turnover, bonuses balance, channels
   used, transaction games played, language, country, account balances.
8. Log in Data includes internet protocol (IP) address, your logins (first log in last login, last failed login),
   duration of logins, browser type and version, time zone setting and location, browser plug-in types and versions,
   operating system and platform and other technology on the devices you use to access our Services.
9. Profile Data includes internal notes to your account, interests, preferences, feedback, information about events
   which you have attended; Your preferences as to whether you wish to attend any events, and what type of events you
   prefer; Any bonus/cash back deals, or bonus preference you have been offered or benefitted from; Whether you have
   received any giveaways or, and your preferences regarding what type of gifts you would like to receive; Your
   preferences as to contact channels; information regarding your hobbies and interests;
10. Marketing Communications Data includes your preferences in receiving marketing from us (opt in/opt out), as well
    as your Contact and Registration Data.
11. Other Communication Data generated as part of communications with Us (via recorded calls, chats, emails, or SMS)
    which may include various data such as network communication data, content of the communication including your
    intentions, interests, complaints, preferences, as well as internal communication and notes.
12. Analytics data include various data generated with respect to your use of our Website and Services such as your
    player ID, language, location, browser data, campaigns utilised, channels used, device, payment provider,
    Transaction and Usage data and in case of online acquisition analytics also pages visited, postcards clicked, scroll
    depth. Certain information is collected using cookies and/or similar tracking technology – please see further
    section “Cookies”.

Data from different sources

Profile data (hobbies, interests) as well as public interactions on social media which are related or
relevant to the Controller’s services are also gathered by search or through analysis of publicly available sources
such as Facebook, LinkedIn, Twitter and Instagram, Google search.

In order to prevent and detect fraud and misuse of our systems (e.g. use of VPN), certain Log In Data, such
as; IP address, device model/type, browser information, operating system and device or other identification data are
sourced and processed by Us utilising a services of third-party fraud detection software provider.

To simplify the sign-up procedure a separate process, such as i)Bank ID or similar, ii}_Facebook connect,
iii) Google sign-In, iv) Apple Pay, may be used as a source for identification and verification. If such a process
is used, once the authorisation of access and the necessary information is provided by You upon sign up, personal
data (Registration and Contact Data) will be automatically fed to the players profile from the third-party source to
facilitate your registration. Such data is used as further specified in this Privacy Policy.

Special Categories of Personal Data

We do not collect any Special Categories of Personal Data about you (this includes details about your race or
ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union
membership, information about your health and genetic and biometric data). However, from our experience, we may not
exclude that You, at your own discretion, send us such data in communication with Us.

Please note that although ID cards are processed, images contained therein are not technically processed to allow or
confirm a unique identification match. Therefore, such data is not to be considered biometric data (special category
of data).

WHY AND HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal
data in the following circumstances:

• To allow You to participate in services and to provide ancillary services to You
• To allow You access and use of the Website
• For legal and regulatory reasons, to comply with our legal obligations and licence conditions such as
  Anti-money laundering
• For identification and verification proposes
• To prevent and detect illegal or fraudulent behaviour for purposes that constitute a legitimate interest of
  the Controller regarding direct marketing of its own similar goods and services via electronic mail as
  provided below; and
• for purposes that constitute a legitimate interest of the Controller regarding direct marketing via live
  telephone calls or postal mail as provided below
• for analytics purposes

Detailed purposes and legal basis

We have set out below, in a table format, a description of the possible ways we plan to use your personal
data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are
where appropriate. Note that we may process your personal data for more than one lawful ground depending on the
specific purpose for which we are using your data. Please contact us if you need details about the specific legal
ground we are relying on to process your personal data where more than one ground has been set out in the table
below.

Please note that the below table sets out the general information about the Personal Data We process. Certain
data categories and/or purposes may differ in different jurisdictions and/or brands under which the Controller
provides its services. Please contact us if you need further details about the specific purpose for processing or
data category in your jurisdiction.

DIRECT MARKETING

In accordance with the applicable laws (incl. local regulations) and on the basis of Our legitimate interest
or Your consent, the Controller may, from time to time, inform You about its own similar products or services (incl.
without limitation Own new services and promotions, bonuses and offers, experience), as applicable via:

• electronic mail (incl. email, SMS or instant messaging)
• social media
• live phone calls
• postal mail
• push notification (desktop and/ or app)

When relying on legitimate interest, the Controller will give you the opportunity to oppose such direct marketing
when registering on Our site.

When relying on consent, the consent may be granted by You when registering on Our site. In both cases, if you do
not wish to receive direct marketing any longer, You may opt out, easily, at any time and free of charge, as
applicable, by:

• activating the relevant link at the end of an electronic message
• contacting us through our communication channels
• informing the caller (in the case of phone call)
• changing your Settings in your profile
• changing your Settings on your device, third-party sites or applications (e.g. social media) where the
  receipt of marketing is enabled on such systems.

Please note that even if You object to receiving direct marketing material, from time to time We may still
need to send You important communications from which You cannot opt-out.

From time to time we may conduct surveys or ask customers to rate their experience with us to improve our
service. You can however, decide whether to take part in these surveys, as well as have the right to object from
being contacted for these purposes.

RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for,
including for the purposes of satisfying any legal, accounting, or reporting requirements.

The criteria We use to determine what is ‘necessary’ depends on the nature of the particular personal data in
question. Our normal practice is to determine whether there is/are any specific law(s) (for example licence
requirement, tax or corporate laws) permitting or even obliging Us to keep certain personal data for a period of
time (in which case We will keep the personal data for the maximum period indicated by any such law) and if not,
whether there are any laws and/or contractual provisions that may be invoked against Us by You and/or third parties
and if so, what the prescriptive periods for such actions are. In the latter case, We will keep any relevant
personal data that We may need to defend Ourselves against any claim(s), challenge(s) or other such action(s) by You
and/or third parties.

Where Your personal data is no longer required by Us, We will either securely delete or anonymise the personal data
in question. We will generally retain your personal data for a maximum period of ten years from the closure of your
account. There are some exceptions to this retention period, namely:

• If you are permanently self-excluded from any of our services, we will retain this information indefinitely.
• If you are under investigation or where we have identified possible fraudulent or other criminal activity,
  we may retain your personal data for longer and as required in order to cooperate with the relevant
  authorities.
• If there is a legal dispute, we will retain your personal data for at least the entire duration of the
  dispute and as may be required in order to defend our rights in any subsequent claim or any subsequent
  proceeding arising from the same.

Due to gaming authority restrictions relating to the use of multiple accounts, players are only permitted to create
and use a single account per brand on the Controller’s system (as per our terms and conditions). Therefore as long
as we store, for the above mentioned purposes, all of the Personal Data of the player, the player may, following a
closure, only reopen their existing account, provided the account is eligible for opening.

Further details of retention periods for different aspects of your personal data are available in our retention
policy which you can request by Contacting Us.

Recipients of your Personal data

As the Controller’s business partners, suppliers or service providers are responsible for certain parts of the
overall functioning or operation of the Website, Games and other services, Personal data are processed also by them
for the above-mentioned purposes on behalf of the Controller.

We require all third parties to respect the security of your personal data and to treat it in accordance with the
law. We do not allow our third-party service providers to use your personal data for their own purposes unless this
is permitted or required by law, and only allow them to process your personal data for specified purposes and in
accordance with our instructions, after thorough vetting of these partners and on the basis of strict data
processing agreements as may be necessary.

Details on the categories of recipients of the personal data

• game providers for the purpose of provision of games
• sportsbook provider for the purpose of provision of sportsbook service and risk management purposes
• payment service providers to perform payment transactions (deposit and withdrawals) and for the purposes of
  preventing fraud and enabling compliance with AML obligations
• marketing suppliers including social media platforms and other business partners to perform marketing
  activities, such as: advertising campaigns, optimisation, market analysis and research on behalf of the
  Controller
• marketing consultants to provide marketing advice to the Controller
• service providers that technically enable communication with you (via email, chat, SMS, phone)
• technical suppliers to support functioning of the Website and Our technical systems (both front and back
  end)
• technical administrators of the database to maintain the functioning of the database
• AML providers providing and/or processing certain data for the purposes of compliance with our AML
  obligations
• Services providers regarding or organisation and booking emails, trips and/or delivery of presents and gifts
  with respect to our loyalty programme
• Cloud services providers for provision of cloud-based services such as storage or hosting certain software
• Service providers for the purpose of data analytics and/or business intelligence
• credit rating agencies, fraud detection agencies, anti-money laundering agencies for fraud detection and
  control purposes, in the processing of Your Member Account and associated transactions

– Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal,
insurance and accounting services.

Authorised disclosure:

If You are suspected to have breached our Terms and Conditions or any applicable laws
(for example when we suspect that a crime may have been committed), or for the purpose of preventing, detecting or
suppressing fraud or other criminal activity, or when required for your own protection and vital interests, the
Controller has a right to:

• forward Your Personal Data to the relevant government or public authorities;
• share any of Your Personal Data to the relevant gambling regulator(s) and other relevant bodies such as,
  related associations where this is permitted by law;
• share Your Personal Data with relevant law enforcement and/or crime investigation bodies or organisations
  and assist the same with any type of investigation into Your actions;
• respond to any Court subpoena or order or similar official request for Personal Data.

Group companies/other brands for AML Purposes

When applicable, Your information, such as, Identification and
Verification Data, Transaction and Usage Data, Registration Data and Contact data are for the purpose of compliance
with legal obligations, shared between various brands under which the Controller operates its gambling activities.

Group companies/other brands and third-parties for fraud prevention and establishment, exercise or defence of
legal claims

Your information, including as applicable, Identification and Verification Data, Transaction and Usage
Data, Registration Data, Contact data and Log-in data are for the purpose of preventing, detecting, or suppressing
fraud, shared with as well as sourced via other Group companies/ brands under which the Controller operates its
gambling activities, as well as third-party fraud detection tools and providers. In addition, the Controller may,
subject to its legitimate interests and insofar as permitted by law, share and source information via other Group
companies and third parties for the establishment, exercise or defence of legal claims.

Corporate restructuring

Third parties, incl. any companies belonging to the same group of companies as the
Controller, to whom we may choose to sell, transfer, or merge parts of our business, our assets or operations or as
a result of restructuring. Alternatively, we may seek to acquire other businesses or merge with them. If a change
happens to our business, then the new owners may use your personal data in the same way as set out in this privacy
notice.

INTERNATIONAL TRANSFERS

Some of our suppliers and partners (as listed above) are based outside the United Kingdom (UK) as well as the
European Economic Area (EEA), so their processing of your personal data will involve a transfer of data outside
these territories. Whenever we transfer your personal data, we ensure a similar degree of protection is afforded to
it by ensuring at least one of the following safeguards is implemented:

• transfer your personal data is performed to countries, territories, or subject to arrangements or mechanisms
  that have been deemed to provide an adequate level of protection for personal data both by the UK Government
  and the European Commission.
• Where we use service providers which are not subject to an adequacy mechanism, we will ensure that
  additional safeguards and measures are put in place as required, including by incorporating specific
  contracts approved by the UK Government and the European Commission.

Please Contact us if you want further information on the specific mechanism used by us when transferring your
personal data.

DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used
or accessed in an unauthorised way, altered or disclosed. In order to comply with the applicable data protection
legislation, various technical controls ensure data and information are always encrypted during transit and at rest
using industry standard encryption techniques at all other times. This ensures confidentiality and integrity at all
times. At an organisation level, the handling of all information is governed by our comprehensive Information
Security Policies. This is complemented by an Information Security Awareness Programme designed specifically to
ensure we embrace security best practices whenever it comes to handling information. In addition, we limit access to
your personal data to those employees, agents, contractors and other third parties who have a need-to-know business
requirement. They will only process your personal data on our instructions or subject to a lawful ground, as well as
their duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and
will notify you and any applicable regulator of a breach where we are legally required to do so.

Your Rights Under the Data Protection Laws

Your Right of Access

You may, at any time, with reasonable intervals, request Us to confirm whether or not We are processing personal
data that concerns You and, if We are, you shall have the right to access that personal data and to the following
information:

• what personal data We have,
• why We process them,
• who We disclose them to,
• how long We intend on keeping them for (where possible),
• whether We transfer them abroad and the safeguards We take to protect them,
• what Your rights are,
• how You can make a complaint,
• where We got Your personal data from and whether We have carried out any automated decision-making
  (including profiling) as well as related information.

In order to facilitate the exercise of such right We have developed the “Download my Data”, which is a self-service
feature enabling You to request your data directly by activating this functionality from your profile. Upon
triggering such functionality, You will be provided with a copy of all your transaction data and an exhaustive
summary of all categories of data, their sources and recipients, all processing operations, the purposes thereof and
retention periods applicable. In case this functionality is not supported on any of our brands or otherwise
unavailable, or should you need to obtain additional explanations or information concerning your personal data you
may alternatively send your request to: support@prizedrawtime.com. Upon such request, We shall (without adversely
affecting the rights and freedoms of others including Our own) provide You with such additional information and/or
with a copy of the personal data undergoing processing within one month (or a shorter period if required by law),
from receipt of the request, which period may be extended by another two months where necessary, taking into account
the complexity and number of the requests. We shall inform You of any such extension within the required time frame,
together with the reasons for the delay.

The Right to Rectification

Although all reasonable efforts will be made to keep Your Personal Data updated, you are kindly requested to inform
Us promptly of any changes. With respect to your residential address and phone number, you can notify us of the
change by amending Your profile of any changes to Your Personal Data. If the change pertains to data that cannot be
amended by changing your profile, please contact us. To this end You have the right to ask Us to rectify inaccurate
personal data and to complete incomplete personal data concerning You. We may seek to verify the accuracy of the
data before rectifying it.

The Right to Erasure (The Right to be Forgotten)

You have the right to ask Us to delete Your personal data and We shall comply without undue delay but only where:

• The personal data are no longer necessary for the purposes for which they were collected; or
• You have withdrawn Your consent (in those instances where We process on the basis of Your consent) and We
  have no other legal ground to process Your personal data; or
• You have successfully exercised Your right to object (as explained below); or
• Your personal data have been processed unlawfully; or
• There exists a legal obligation to erase the data to which We are subject; or
• Special circumstances exist in connection with certain children’s rights.

In any case, We shall not be legally bound to comply with Your erasure request if the processing of Your personal
data is necessary:

• for compliance with a legal obligation to which We are subject (including but not limited to Our data
  retention obligations); or
• for the establishment, exercise or defence of legal claims.

There are other legal grounds entitling Us to refuse erasure requests although the two instances above are the most
likely grounds that may be invoked by Us to deny such requests.

You may request the erasure of data by following these steps:

• close your account by using the ‘My Account’ Menu options;
• submit a request to support@smallscreencasinos.com to complete the process..

Following your request, personal data which is still relevant to fulfil our legal obligations or required to defend
our legal rights, will be subject to the retention period of 10 years and as specified in section 4 of this privacy
policy. Any other data will be deleted or anonymised when this is no longer required.

The Right to Data Restriction

You have the right to ask Us to restrict (that is, store but not further process) Your personal data but only where:

• The accuracy of Your personal data is contested (see the right to data rectification above), for a period
  enabling Us to verify the accuracy of the personal data; or
• The processing is unlawful, and You oppose the erasure of Your personal data; or
• We no longer need the personal data for the purposes for which they were collected but You need the personal
  data for the establishment, exercise or defence of legal claims; or
• You exercised Your right to object and verification of Our legitimate grounds to override Your objection is
  pending.

Following Your request for restriction, except for storing Your personal data, We may only process Your personal
data:

• Where We have Your consent; or
• For the establishment, exercise or defence of legal claims; or
• For the protection of the rights of another natural or legal person; or
• For reasons of important public interest.

You may request the restriction by contacting us.

The Right to Data Portability

You have the right to ask Us to provide Your personal data (that You shall have provided to us) to You in a
structured, commonly used, machine-readable format, or (where technically feasible) to have it ‘ported’ directly to
another data controller, provided this does not adversely affect the rights and freedoms of others. This right shall
only apply where:

• The processing is based on Your consent or on the performance of a contract with You; and
• The processing is carried out by automated means.

To a great extent, you may exercise this right by activating “download my data” functionality of your profile. For
any request over and above the data provided or if you would like us to assist you with the actual transfer of such
data to another operator, please contact us. If you are a customer of another gaming operator and would like to have
your data “ported” to Us, please contact us. In this respect please note, that notwithstanding any portability right
utilisation, you will still be expected to provide all Registration and Contact Data due to the requirements of our
customer registration / sign up procedure requirements.

The Right to Object to Certain Processing

In those cases where We process Your personal data for the performance of a task carried out in the public interest
or when processing is necessary for the purposes of the legitimate interests pursued by Us or by a third party (as
indicated in the Table in the clause 3.2 above), You shall have the right to object to processing of Your personal
data by Us.

When Your data is processed for direct marketing purposes, You have the right to object at any time to the
processing of Your personal data, which includes profiling to the extent that it is related to such direct
marketing.

For the avoidance of all doubt, when We process Your personal data when this is necessary for the performance of a
contract, when necessary for compliance with a legal obligation to which We are subject or when processing is
necessary to protect Your vital interests or those of another natural person, this general right to object shall not
subsist.

With respect to Direct marketing of our own goods and services incl. related profiling, You may object to such
processing at any time, by contacting us, or by selecting your preferences on your account Profile.

Right to withdraw consent (when we process your data on the basis of consent)

In those cases where We process Personal Data on the basis of Your consent (which We will never presume but which We
shall have obtained in a clear and manifest manner from You), YOU HAVE THE RIGHT TO WITHDRAW YOUR CONSENT AT ANY
TIME and this, in the same manner as You shall have provided it to Us.

Should You exercise Your right to withdraw Your consent We will determine whether at that stage an alternative legal
basis exists for processing Your Personal Data (for example, on the basis of a legal obligation to which We are
subject) where We would be legally authorised (or even obliged) to process Your Personal Data without needing Your
consent and if so, notify You accordingly.

When We ask for such Personal Data, You may always decline, however should You decline to provide Us with necessary
data that We require to provide requested services, We may not necessarily be able to provide You with such services
(especially if consent is the only legal ground that is available to Us).

Just to clarify, consent is not the only ground that permits Us to process Your Personal Data (As indicated in the
Table in the clause 3.2 above there are various grounds that We rely on when processing Your Personal Data for
specific purposes).

The Right to lodge a Complaint

You also have the right to lodge complaints with the appropriate Data Protection Supervisory Authority. We kindly
ask that You please attempt to resolve any issues You may have with Us first (even though, as stated above, You have
a right to contact the competent authority at any time).

WHAT WE MAY NEED FROM YOU

When exercising your rights by contacting us, we may need to request specific information from you to help us
confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights).
This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month (unless a shorter period is required by law).
Occasionally, it may take us longer than a month if your request is particularly complex or you have made a number
of requests. In this case, we will notify you and keep you updated.

AUTOMATED PROCESSING – PROFILING

Meaningful information about the logic involved in the automated processing for responsible gaming
purposes

The Controller is on the basis of the applicable laws and licence conditions legally obliged to monitor its players
in order to identify people who may be experiencing, or at risk of developing, problems with their gambling, and
interact with them to offer help or support. To this end, and to fulfil this obligation, by using historical data
describing behaviour of players, in particular certain Responsible Gaming Data, Transaction and Usage Data, and
Other Communication Data (in particular, notably sentiment used in messages), the Controller has established rules
regarding who is likely to suffer from gambling addiction and then take relevant action.

Our approach is based on classification trees because they allow for clear interpretation of why players get
classified as potential gambling addicts. Based on data describing unique players, the algorithm provides us with an
estimated probability of gambling addiction. Decisions on the basis of the prediction and which may impact
customers, are not taken automatically without human intervention.

Meaningful information about the logic involved in the automated processing for AML
purposes

The Controller is, on the basis of the applicable laws and licence conditions, legally obliged to monitor its
players in order to identify potentially suspicious activities regarding AML/CFT. Based on data describing the
behaviour of players, in particular Transaction and Usage Data, the algorithm suggests a risk profile. Decisions on
the basis of the prediction and which may impact customers, are not taken automatically and require human
intervention.

Meaningful information about the logic involved in the automated processing for loyalty
segmentation purposes

By making use of the historical data that players generated in their first 2 days, We assess whether You will
qualify for our loyalty program. This model is used on fresh players and depending on their involvement with our
services the loyalty status is predicted. The result of the model is a prediction as to whether the player will
become a loyalty customer. In addition, apart from gender, country and age, we will use affordability criteria and
enhanced due diligence information insofar as permitted or required by law, to determine your eligibility for
loyalty/ High-Value schemes. Decisions on the basis of the prediction and which may impact customers, are not taken
automatically without human intervention. The process is based on our compliance with legal obligation and with
respect to the loyalty offers, the performance of our contract with You as well as the legitimate interest of the
Controller regarding its commitment in providing customised, quality experience and reward loyalty of the players.
You can object to such processing by contacting us or changing your preferences in your account.

Meaningful information about logic involved in automated processing with respect to direct
marketing segments

By making use of Your Transaction and Usage data, certain Registration Data such as gender, country, date of birth
and Your overall interaction with our services, We analyse and establish various segments of the customers. These
segments are then processed manually, in order to ensure that We provide the most appropriate offers and bonuses to
our customers. These decisions are not taken automatically without human intervention. The process is based on the
legitimate interest of the Controller with regard to providing customised, quality experience for the players and
reward loyalty of the players. You can object to such processing by contacting us or changing your preferences in
your account.

Cookies

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cookies, and how you can control which cookies are dropped, please read our Cookies Policy – found in main menu.