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Privacy Policy

Version 1.2, dated 09/12/2022

Side Effect complies with the Personal data Protection Act of Curacao (2013) and other applicable legislation in sphere of and data protection.

Newsletter

When signing up for the newsletter we collect your e-mail address. As per the information available during sign-up this is done with your consent. The e-mail address is obtained via voluntary submission to our system and may be processed for the purposes of sending out press releases and corporate news. The legal basis for this processing is your consent. You can unsubscribe at any time, by using the link available in the newsletters, and your e-mail address will be removed instantly.

Correspondence

When contacting us via e-mail, or via the online form shown on our Websites, we gain your e-mail address, and the information you choose to share about yourself. This personal data is obtained via voluntary submission and processed with your consent, for the purposes of responding to your queries. We may keep correspondence for record-keeping so we are able to continue discussions at a later stage, due to legal obligations should there be situations of dispute, or for when we have a legitimate reason for doing so in accordance with our policies. You can withdraw your consent at any time by contacting us vie e-mail [email protected].

We are committed to protecting the privacy of our clients and we do not sell your data to third parties. We want to provide a safe and secure service where we deal with your personal information. This means information that identifies you personally such as your name, photo or contact details or data that can be linked with such information in order to identify you.

Special categories of personal data

No special categories of personal data are processed by us. We do not process either racial or ethnic origin, political opinions, religious or philosophical beliefs, genetic or biometric data, trade union membership nor data concerning health or sex.

WHAT PERSONAL INFORMATION DO WE COLLECT ABOUT YOU?

We collect and process your information in the following ways

Information you provide us:

  • your name, address and contact details;

  • your date of birth and gender;

  • information about your income, wealth and tax status;

  • your employment;

  • your national insurance number;

  • location data; and

  • any other similar information or information provided by you.

We may ask you for further information occasionally, for example in a Player survey. These requests are voluntary but if you request a product or service that requires further information, you will be required to provide this information before we can provide access to it.

In addition to the above, personal data that we may collect, store and process includes:

  • information that you provide to us by filling in forms on the Websites or any other information you might submit to us via the Websites, email, telephone, Skype and/or Live Chat;

  • record of correspondence, whether via the Websites, email, telephone or other means;

  • details of the transactions you carry out with us, whether via Websites, telephone or other means;

  • details of your visits to the Websites, including traffic data, location data, activity logs and other communication data;

  • information we get from your devices (IP address, cookies, computer model, operating system and its version, serial numbers);

  • your telephone/Skype/Live Chat conversations – either when placing a bet or contacting customer service;

  • information and communications on Websites forums, including chat rooms and message boards, profile comments, in-game challenges and chat messaging with game operators and/or other users; and

  • your responses to marketing campaigns from us.

Information we receive from third parties:

  • either through paid for third-party marketing lists, public sources or through our refer-a-friend scheme;

  • data from Experian on your credit history and score;

  • publically available information such as social media, property ownership, electoral roll, annual returns for companies, industry bodies and insolvency registers and others.

HOW WILL WE USE YOUR PERSONAL DATA?

Side Effect will legally use and process your personal information and other data together with other information, in the following way:

  • as a legal obligation according to the gaming legislation, AML legislation or any other specific law that is relevant to business activity of Side Effect;

  • in our own legitimate interests for commercial and business reasons. Please note that the processing of personal data is necessary and we will perform a relevant balancing test to ensure that such processing is lawful and conducted only for specific and legitimate purposes, e.g. anti-fraud measures, risk management, network security, customer support, service personalization and web analytics;

  • under the terms of the contract Side Effect entered into with you (by your acceptance of our Terms and Conditions) and any third party (by signing relevant documents). However, processing of your personal data is strictly limited to legal requirements stated in the above-mentioned agreements;

  • upon receiving your consent only for the period during which we have your consent to process your personal data and for the purposes you agreed to.

We process your Personal data for the purpose of providing services and also for business-related purposes explained below:

  • processing your bets, including card and online payments;

  • setting up and managing your account, plus verification of your identity;

  • complying with our legal and regulatory duties;

  • complying with risk management procedures and monitoring transactions for the purpose of preventing fraud, irregular betting, money laundering and cheating;

  • identification of system problems and administration of the Websites;

  • involving you in surveys and polls relating to the services we provide;

  • providing you with information about promotional offers and the products and services available.

In addition to the above, we will use your personal data:

  • to provide a requested services or carry out a contract with you

    • to verify your identity;

    • to establish and manage your account;

    • to provide you with products and services;

    • to provide you with information about our products and services;

    • to assess your needs;

    • for internal business purposes and record keeping;

  • where we have your consent

    • if you have provided answers to a Player survey or live chat;

    • for marketing by us (to prospective clients);

  • where we have a legitimate interest

    • to verify your identity;

    • to establish and manage your account;

    • to assess your needs;

    • to enable us to improve our products and services;

    • to develop and market new products and services;

    • to protect our commercial interests;

    • to form a profile;

    • to investigate inquiries or disputes;

    • to provide references about you;

    • to send you surveys;

    • for data analysis such as counting web page visits and cookie tracking to make sure our product and services we provide are relevant;

    • for marketing by us (based on a soft opt-in) including after a short period after your account has closed;

    • for internal business purposes and record keeping;

    • to disclose your data for due diligence in the event of a restructure or acquisition;

  • where we have a legal obligation

    • to verify your identity;

    • to form a profile;

    • to comply with applicable law, court order, other judicial process, or requirements of any applicable regulatory authorities;

    • to provide references about you;

    • for internal business purposes and record keeping.

HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?

We keep your information for the following periods as long as reasonably needed for legal or business purposes.

Clients: 6 years after closure of your account.
Prospective clients: 1 year after submitting details.

We will take care to ensure the privacy of your data during the retention period.

Apart from what is specified above, please note that we may retain your personal data after we have stopped providing services to you, if it is necessary in order to comply with our legal obligations, prevent fraud, meet regulatory requirements, or to resolve disputes.

We may also keep anonymized derivatives of your personal data for business analytical purposes, such as Websites navigation. Rest assure that personal data that we process for any purpose will not be retained longer than what is necessary for that specific purpose.

WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?

We share your personal data with:

  1. The Affiliates of Side Effect

    The term “Affiliates” includes all direct or indirect subsidiary enterprises, joint venture partners, and their related companies. We may share your personal data with our Affiliates for set-up, verification and management of your account, for marketing research and data analysis, to conduct relevant risk management and comply with legal and regulatory obligations.

  2. Third Parties (payment service providers, customer services software providers, marketing agencies and other trusted partners)

    We share your personal information with trusted third parties where we have retained them to provide services that you or our clients have requested, such as Visa and Mastercard to provide payments. These third parties comply with similar and equally stringent undertakings of privacy and confidentiality.

    We share your personal information with third parties who perform functions on our behalf and who also provide services to us, such as professional advisors, IT consultants carrying out testing and development work on our business technology systems, research and mailing houses and function coordinators. These third parties comply with similar and equally stringent undertakings of privacy and confidentiality.

    Where required we share your personal information with third parties to comply with a legal obligation; when we believe in good faith that an applicable law requires it; at the request of governmental authorities conducting an investigation; to verify or enforce our Player Agreement or other applicable policies; to detect and protect against fraud, or any technical or security vulnerabilities; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of third parties, visitors to our Websites, our business or the public.

  3. International data transfers

    Side Effect runs its business activity on the territories pointed in the General Terms except for restricted areas.

    We would like to emphasize that Side Effect makes every effort to ensure the protection of personal data while cooperating with any third parties. In addition, we try to secure your rights and information, by verifying whether the data is processed in accordance with legal requirements.

  4. Credit reference agency notice

    In order to process your application, we will supply your personal information to credit reference agencies (CRAs) and they will give us information about you, such as about your financial history. We do this to assess your creditworthiness and product suitability, check your identity, manage your account, trace and recover debts and prevent criminal activity.

    We will also continue to exchange information about you with CRAs on an ongoing basis, including about your settled accounts and any debts not fully repaid on time. CRAs will share your information with other organizations. Your data will also be linked to the data of your spouse, any joint applicants or other financial associates.

WHAT HAPPENS IF YOU DO NOT PROVIDE US WITH THE INFORMATION WE REQUESTED OR ASK THAT WE STOP PROCESSING YOUR INFORMATION?

If you do not provide us with required personal information or withdraw your consent for the processing of your personal information, where this information is necessary for us to provide services to you, we will not be able to provide these services to you.

DO WE MAKE AUTOMATED DECISIONS CONCERNING YOU?

No, we do not carry out automated decision-making.

DO WE USE COOKIES TO COLLECT PERSONAL DATA ON YOU?

To provide better service to you on our Websites, we use cookies to collect your personal data when you browse. See our cookie policy here for more details.

Protecting your personal data

We uphold state of the art security measures in order to protect your personal data from unauthorized access, unlawful disclosure, destruction or modification, accidental loss, and other misuse. The security mechanism we use are technical, physical and administrative, such as encryption, firewalls, physical access controls and information access controls. Despite our reasonable efforts to safeguard personal data, please note there is always a risk that a third party may unlawfully access our systems or otherwise access personal data. We do not accept liability for protecting personal data disclosed through your internet connection.

While your information is being transferred to the data centers we limit its processing to a strictly necessary extent, in keeping with the procedures aimed at ensuring the network and information security. In addition, the security of any transfer of data is helped by using computer security incident response teams (CSIRTs), computer emergency response teams (CERTs) and other means to ensure a high level of protection. Moreover, data centers use Operational Metrics (traffic data, cryptographically hashed file samples, clickstream information, logged snippets of transmitted content, IP trust scores and other server activity data and all analytic products derived therefrom).

WHAT ARE YOUR RIGHTS?

As a Player, you are entitled you to a range of specific rights with regards to your personal data. Please make sure you examine the following list with due care. In addition, we would like to stress that some rights relate to specific circumstances only.

  1. Right to be informed regarding your personal data

    Side Effect tries to highlight the most crucial issues concerning the security of your personal data to keep you informed. If the policies of Side Effect are in any way changed, we will make updates accordingly.

  2. Right to access

    It is your right to receive information from us regarding whether we are using your personal data. You are also entitled to ask us to clarify which of your personal data we have. In addition, you may request a copy of the personal data which is being processed.

  3. Right to alter incorrect data

    You have a right to change inaccurate personal data in our possession.

  4. Right to have data removed

    You are entitled to erase your personal data in our possession due to specific circumstances. Those would be if the data is no longer necessary for the stated purposes, you withdraw your consent to data processing, your personal data has been unlawfully used, there are no overriding legitimate grounds to process your information and/or your personal data is to be erased for legal reasons. However, please, note that Side Effect is not bound to comply with such a request if processing of your personal data is necessary to exercise the right of freedom of expression and information, comply with a legal obligation in the public interest, exercise official authority and/or establish, exercise or defend legal claims.

  5. Right to restriction of processing

    You have the right to request the suspension of your personal data being processed, for example, if the accuracy of the data is being questioned.

  6. Right to data transfers

    You are entitled to transfer your personal data in our possession to any other data controller. You also have a right to receive a report on your personal data from Side Effect in a structured, commonly used and machine-readable format. While transferring the above-mentioned data to you, Side Effect will take all security measures necessary to ensure your personal data is securely transmitted by using end-to-end encryption or any other strong authentication measures.

  7. Right to object

    You have the right to object to the processing of your personal data. However, where legitimate grounds to use your information outweigh your interests and rights, Side Effect reserves the right to continue such processing.

  8. Right not to be subject to automated decision-making

    You are entitled not to be subjected to automated decision procedure. Side Effect ensures that all important matters relating to your personal data are resolved by our team.

HOW COULD YOU EXERCISE YOUR RIGHTS?

To exercise any of the above-mentioned rights, you must provide us with a special request. Should you wish to make such a request, please, contact us via e-mail [email protected].

Your application should include adequate identification details and appropriate documents to support your request. Side Effect will deal with your concerns within 30 days and reply to you regarding each issue.

If you do not receive a response to your request within the stipulated time period or are not satisfied with our processing of your personal data, you are entitled to apply to your data protection authority.

Consent

By registering on our Websites as a customer of Side Effect and/or using our services, you consent to the processing of your personal data by Side Effect and to the General Terms and Conditions and this Privacy Policy. Please, make sure you understand all your rights and obligations stated here and in the Terms and Conditions.

Further information

Side Effect always aims to make its customers aware of their rights and obligations. Please, make sure you read carefully this Privacy Policy, Terms and Conditions and other information on our website.

We use a 256 bit Secure Sockets Layer (SSL) protocol to ensure the data that is transferred between a client and a server remains private.

If you have any doubts regarding our services or need any additional assistance, do not hesitate to contact us via e-mail [email protected].

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