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ASPIRE GLOBAL INTERNATIONAL LTD LIMITED
Last revised: 22/12/2020
PRIVACY POLICY
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INTRODUCTION
Aspire Global International LTDAspire Global Limited, which includes all of the entities specified below under “The Group” section,
including its affiliates (collectively, the
(“ Company”) offers online gambling services (collectively, the Services via:
The Group 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 will read about:
We encourage you to read the Privacy Policy carefully and use it to make informed decisions.
By visiting the Group’s websites, mobile apps or other online properties, or by creating an account
through our Services, you hereby agree to the Privacy Policy.
INTRODUCTION
THE GROUP
WHAT INFORMATION WE COLLECT? We collect two types of information from our Users:
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:
MINORS The Services are not designed or directed to persons under the age of 18 or persons under the age of legal consent with respect to the use of the Services of any jurisdiction, whichever is higher (“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. If you have any reason to believe that a minor has shared any information with us, please contact us at Contact Us CONDITIONS FOR PROCESSING OF PERSONAL INFORMATION We will process your Personal Information for a variety of reasons, each of which is prescribed by relevant data protection laws. HOW WE USE THE COLLECTED INFORMATION? We use your Personal Information for the purposes listed below: MARKETING The Group 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 which relate to: (i) other companies within the Group; (ii) White Label Brands; or (iii) Group's business partners and affiliates (collectively: “Marketing Affiliates", which we believe may interest you. We may also share and disclose Personal Information with our Marketing Affiliates for the purpose of providing you different marketing offers, which we, or our Marketing Affiliates, believe are relevant for you, where we have a legitimate interest to do so or where we obtained your consent.. Our Marketing Affiliates may use this Personal Information for different marketing techniques, such as direct email, post, SMS and telephone marketing purposes. You may at any time decline receiving further marketing offers from us or from our business partners and marketing affiliates by contacting us at to Contact Us . Please note that even if you unsubscribe from our marketing mailing list, we may continue to send you service-related updates and notifications. We will occasionally send you push notifications concerning the Services and products, services, websites and applications which relate to us, as well as to keep you informed of the latest improvements, features and other developments related to the Service. You may opt-out of receiving these types of communications by turning off push notifications at the device level at any time. 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: TRANSFER OF INFORMATION Since we operate globally, it may be necessary to transfer your Personal Information to countries outside the European Union. The data protection and other laws of these countries may not be as comprehensive as those in the European Union. 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 contractual clauses approved by the relevant regulators for data transfer) or other means (such as ensuring that the jurisdiction imposes adequate safeguards for data protection). 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. 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 Group. 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 Group will retain your Personal Information during the period your account is active. In addition, the Group will retain your Personal Data for additional periods, to enable the Group to meet its legal obligations under applicable laws or regulations, such as the applicable gambling regulations, Know-Your-Customer and Anti-Money Laundering regulations. In addition, the Group may retain your Personal Information for longer periods, provided that retaining such information is necessary for the Group’s legitimate interests, such as fraud prevention and record keeping. YOUR RIGHTS You may contact us at any time Contact Us and request:
Please note that these rights are not absolute and requests are subject to any applicable legal requirements, including gambling regulations and other 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:
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 e-mail address that you volunteered. Such substantial changes will take effect seven (7) 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 v Contact Us or by sending a letter to:
Attn: Data Protection Officer 135, High street, Sliema SLM 1549, Malta DPO@aspireglobal.com The Platforms are operated by: COOKIE POLICY Revised at: May 3rd 2018 When you visit or access our websites or applications operated by us, or when you interact or engage with our content ( "Services"), we use (and authorize third parties to use) web beacons, cookies, pixel tags, scripts, tags, API 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), 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.
What are cookies?
Cookies are small text files (composed only of letters and numbers) that a web server places on your computer or mobile device when you visit a webpage. When used, the cookie can help make our Services more user-friendly, for example by remembering your language preferences and settings. You can find more information about cookies at all about cookies Cookies are widely used in order to make websites work in an efficient way. The use of cookies allows you to navigate between pages efficiently. Cookies remember your preferences, and make the interaction between you and the Services smoother and more efficient. Cookies are also used to help ensure that the advertisements you see online are relevant to you and your interests. Storing Tracking Technologies We store Tracking Technologies when you visit or access our Services (for example when you are visiting our websites) – these are called "First Party Tracking Technologies". In addition, Tracking Technologies are stored by other third parties (for example our analytics service providers, business partners and advertisers) who run content on our Services – these are called "Third Party Tracking Technologies". Both types of Tracking Technologies may be stored either for the duration of your visit on our Services or for repeat visits. Storing Tracking Technologies There are five main types of Tracking Technologies:
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 Group. 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 Group will retain your Personal Information during the period your account is active. In addition, the Group will retain your Personal Data for additional periods, to enable the Group to meet its legal obligations under applicable laws or regulations, such as the applicable gambling regulations, Know-Your-Customer and Anti-Money Laundering regulations. In addition, the Group may retain your Personal Information for longer periods, provided that retaining such information is necessary for the Group’s legitimate interests, such as fraud prevention and record keeping. YOUR RIGHTS You may contact Contact Us us at any time by email (at: support@tradacasino.com, and request:
Please note that these rights are not absolute and requests are subject to any applicable legal requirements, including gambling regulations and other 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:
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 e-mail address that you volunteered. Such substantial changes will take effect seven (7) 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 Contact Us or by sending a letter to:
Attn: Data Protection Officer 135, High street, Sliema SLM 1549, Malta DPO@aspireglobal.com The Platforms are operated by: COOKIE POLICY Revised at: May 3rd 2018 How to manage your cookie settings Please note that we do not recognize or respond to automated browser signals regarding Tracking Technologies, including "Do Not Track" requests. However, there are various ways in which you can manage and control your cookie settings. Please remember that, by deleting or blocking cookies, some of the features of the Services may not work properly or as effectively.
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