Privacy Policy for Users

INTRODUCTION

Virtual Global Digital Services Limited ("the Company", "we", "our" or "us"), offers online free to play game services (collectively, the "Services").

The Company 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:

  • WHAT INFORMATION WE COLLECT?
  • CONDITIONS FOR PROCESSING OF PERSONAL INFORMATION
  • MINORS
  • HOW WE USE THE COLLECTED INFORMATION?
  • MARKETING
  • WITH WHOM WE SHARE INFORMATION?
  • INTERNATIONAL TRANSFER OF INFORMATION
  • THIRD PARTY TRACKING TECHNOLOGIES
  • THIRD PARTY SERVICES
  • RETENTION OF PERSONAL INFORMATION
  • YOUR RIGHTS
  • HOW WE KEEP YOUR INFORMATION SECURED
  • CHANGES TO THE PRIVACY POLICY
  • HOW TO CONTACT US

We encourage you to read the Privacy Policy carefully and use it to make informed decisions. By visiting the Company's websites, mobile apps or other online properties, or by creating an account through our Services, you hereby indicate that you have read and understood this Privacy Policy.


WHAT INFORMATION WE COLLECT?

We collect two types of information from our Users:

  • Personal Information
    The first type of information which we collect 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:
    • Account 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 your first and last name and your email address username and password.
    • Game information: in order for us to provide the Services, we automatically record different information related to your account and use of our Services.
    • 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, such as on the chat feature and in games. This includes information you are willing to share with us for the purpose of improving and developing our relationship with you, as well as for maintaining your stratification from our services (for example, information about your marital status and family, your hobbies and interests, and other information you share with us through surveys).
    • 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 and MAC address), browser fingerprinting, IP address and geo-location data.
    • Telephone calls: We record or monitor telephone calls for customer support, training and/or security purposes.
  • 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:
    • Log-in history and 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.).
    • Device and connection information: we collect information from the particular device you are using, for security and fraud detection and prevention purposes. For example, we may gather information with regard to other software which is running simultaneously with the Software for detecting if you are using software which is associated with fraudulent activity (e.g. robots, malware, etc.) or checking if the connection you are using is via a VPN or proxy.
    • 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.

CONDITIONS FOR PROCESSING PERSONAL INFORMATION

We will process your Personal Information for a variety of reasons, each of which is prescribed by relevant data protection laws.

  • Fulfillment of a contract, compliance with a legal obligation
    It is necessary for us to process your Personal Information where it is necessary for the performance of a contract (such as our agreement with you ("User Agreement") or in order for us to comply with our various legal and/or regulatory responsibilities.
  • Legitimate interests
    We also process your Personal Information where we deem such processing to be in our (or a third party's) legitimate interests and provided always that such processing will not prejudice your interests, rights and freedoms. Examples of us processing in accordance with legitimate interests would include: (i) where we disclose your Personal Information to any one or more of our associate/subsidiary companies following a restructure or for internal administrative purposes; (ii) processing for the purposes of ensuring network and information security, including preventing unauthorized access to our electronic communications network; (iii) safeguarding the integrity of our Services by combatting, reporting and sharing information related to suspicious betting patterns or fraudulent activities; (iv) adhering to regulatory and statutory requirements; (v) devising a tailored reward scheme for players; and (vi) sharing personal information with our advisers and professional services providers (such as auditors) for ensuring our compliance with regulatory requirements and industry best practices.
  • Consent
    Our processing of your Personal Information will primarily be necessary for us to provide you with the Services. However, on certain occasions we may ask for your consent to processing Personal Information. In these instances your Personal Information will be processed in accordance with such consent and you will be able to withdraw this consent in writing at any time.

MINORS

The Services are not designed or directed to persons under the age of 18 with respect to the use of the Services ("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 unless it is needed to comply with any legal or statutory obligation binding upon us. If you have any reason to believe that a minor has shared any information with us, please contact us (our contact details are available under the "HOW TO CONTACT US?" section).

HOW WE USE THE COLLECTED INFORMATION?

We use your Personal Information for the purposes listed below:

  • To set up, manage and update your account;
  • To provide and operate the Services;
  • 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 communicate with you 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 User Agreement as well as enforce our policies and the User Agreement;
  • To investigate and resolve disputes in connection with your use of the Services;
  • To assist us with meeting our regulatory obligations or as required by law or regulation, including for the purpose of ascertaining your source of funds or income, or as required by other governmental authorities, or to comply with a subpoena or similar legal process or respond to a government request; and
  • In addition, we use your Personal Information upon your specific and informed consent, such as for certain marketing and promotional activities.

Where you have not consented (or have withdrawn your consent) to the processing of your Personal Information by us, we may continue to process your Personal Information (a) where processing is required for the performance of the contract (i.e. the User Agreement) between you and us; and/or (b) where processing is necessary for compliance with a legal obligation to which we are subject; (c) where processing is necessary for the purposes of a legitimate interest of the Company (including for security reasons or for marketing purposes).

MARKETING

The Company 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 that we believe may interest you.

You may at any time decline receiving further marketing offers from us by either: following the guidelines available on the marketing communications, (such as selecting the opt-out link inserted in the promotional emails) or by contacting support (our contact details are available under the "HOW TO CONTACT US?" Section). Please note that even if you unsubscribe from our marketing mailing list, we may continue to send you service-related updates and notifications.

Please note: you can control the delivery of certain advertising or social campaigns through the settings offered by the respective third party platforms (e.g. Facebook).

In addition, if you download any of our mobile applications to your device from the Apple AppStore or Google Play, the only way to prevent receipt of notifications is by changing the settings on the device itself.

TARGETED ADVERTISING

We use third-party advertising technology to serve advertisements when you visit the Platform and use the Services. You may opt-out of many third-party ad networks, including those operated by members of the Network Advertising Initiative ("NAI") and the Digital Advertising Alliance ("DAA").

For more information regarding this practice by NAI members and DAA members, and your choices regarding having this information used by these companies, including how to opt-out of third-party ad networks operated by NAI and DAA members, please visit their respective websites: http://www.networkadvertising.org/optout_nonppii.asp and http://www.aboutads.info/choices.

WITH WHOM WE SHARE INFORMATION?

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;
  • Subsidiaries and affiliated companies;
  • Game 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;
  • Auditors, contractors or legal/financial/other advisers of any of the Company’s business processes;
  • Any third parties who investigate, detect or prevent fraudulent or illegal activity or enable us to enforce our policies (e.g. governmental authorities, law enforcement bodies, banks and other investigatory bodies);
  • Governmental and regulatory bodies, in accordance with applicable laws and regulations; and
  • Potential purchasers, successors or investors in the Company, 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 the Company (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 and other service providers;
  • 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.

INTERNATIONAL TRANSFER OF INFORMATION

Since we operate globally, it may be necessary for the provision of Services and to the extent required for the specific purpose, as stipulated in this Privacy Policy to transfer your Personal Information to countries outside the European Economic Area. The data protection and other laws of these countries may not be as comprehensive as those in the European Economic Area.

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 standard contractual clauses approved by the European Commission for data transfer, as available here) or other means (such as ensuring that the European Commission decisions determined that such jurisdictions offer adequate level of protection, as available here).

For more information about the transfer of your personal data outside of the EEA, please contact us (our contact details are available under the "HOW TO CONTACT US?" Section).

THIRD PARTY TRACKING TECHNOLOGIES

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.

We also use a tool called “Google Analytics” to collect information about your use of the Websites. Google Analytics collects information such as how often users access the Websites, what pages they visit when they do so, etc. We use the information we get from Google Analytics only to improve our Websites and services. Google Analytics collects the IP address assigned to you on the date you visit sites, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to the Websites is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

THIRD PARTY SERVICES

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 Company. 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.

RETENTION OF PERSONAL INFORMATION

If you have registered with an account through our Services, the Company will retain your Personal Information during the period your account is active. In addition, the Company will retain your Personal Information for additional periods, as strictly necessary to enable the Company to meet its legal obligations under applicable laws or regulations, as well as to meet the Company's contractual obligations and legitimate interests.

In addition, the Company may retain your Personal Information for longer periods, provided that retaining such information is strictly necessary for the Company’s legitimate interests, such as fraud prevention and record keeping, resolving or exercising claims regarding potential disputes, and where the Company is guided to do so by the applicable supervisory authority.

YOUR RIGHTS

You may contact us at any time by email (our contact details are available under the "HOW TO CONTACT US?" section), and request:

  1. To access or delete any Personal Information relating to you;
  2. 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);
  3. That we will restrict or cease any further use of your Personal Information;
  4. That we will provide the Personal Information you volunteered to us in a machine-readable format;
  5. To object to the processing of your Personal Information (such as for marketing purposes);
  6. To withdraw your consent to our processing activities (provided that such processing activities rely on your consent, and not on a different legal basis);
  7. To not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, except where such processing is necessary for the performance of the contract between you and us, or it is based on your explicit consent, as provided hereunder.

Please note that these rights are not absolute and requests are subject to any applicable legal requirements, including applicable 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.

HOW WE KEEP YOUR INFORMATION SECURED

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.

CHANGES TO THE PRIVACY POLICY

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 fourteen (14) 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.

HOW TO CONTACT US?

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 through one of the companies detailed below, as explained below:


Attn: Data Protection Officer
Suite 601-701 Europort Avenue, Gibraltar
support@888.net


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 lodge a complaint with the applicable data protection supervisory authority.


The Privacy Policy has been drafted in the English language. In the event of any discrepancy between the meanings of any translated versions of the Privacy Policy and the English language version, the meaning of the English language version shall prevail, to the extent permissible by domestic law in the jurisdiction you reside in.



Last updated on April, 2020