2. Types and Use of Information We Collect
|Purposes of processing your data||Personal data involved||Possible consequences of refusing to provide personal data||Legal basis for processing your data|
|Your Registration||Personally identifiable data; Contact Details; Tax Data; Social Security Data; Financial Information; Connection Information; Location Information||Registry Failure||Contract Execution|
|Identity verification and contact details||Personally identifiable data; Game Activity; Financial Information; Social Security Data; Connection Information; Location Information||Account suspension/closure; Unable to log in; Withdrawal requests unavailable||Regulatory / Legal Obligations|
|3||Transaction Management||Personally identifiable data; Financial Information||Account suspension/closure; Frozen and/or canceled withdrawal requests||Regulatory / Legal Obligations|
|4||Monitoring and evaluating gaming behavior for crime prevention||Personally identifiable data; Contact Details; Game Activity; Tax Data; Social Security Data; Financial Information||Account suspension/closure; Unable to log in, Withdrawal requests unavailable||Regulatory / Legal Obligations|
|5||Monitoring and evaluating gaming behavior for business development||Personally identifiable data; Game Activity; Financial Information; Social Security Data; Connection Information; Location Information Legitimate Interest (Internal reports and business development)||N / D||Legitimate interest (Internal reporting and business development)|
|6||Game behavior monitoring and evaluation for personalized offers, bonuses and user interface||Personally identifiable data; Game Activity; Financial Information; Social Security Data; Connection Information; Location Information||Inability to receive offers and bonuses. Non-custom gaming experience||Legitimate interest (ideal experience for our customers)|
|7||Informational communications, newsletters and campaigns||Personally identifiable data; Contact Details||Inability to receive newsletters and general marketing campaigns||Consent|
|8||Inquiries, Complaints and Troubleshooting||Personally identifiable data; Contact Details; Game Activity; Connection Information; Location Information; Financial Information||N/D||Legitimate interest (ideal experience for our customers and problem solving)|
|9||Reporting to regulatory/police authorities||Personally identifiable data; Game Activity; Financial Information; Social Security Information; Connection Information; Location Information; Tax Information||Account suspension/closureUnavailability to login||Regulatory / Legal Obligations|
|10||Promotions and offers||Personally identifiable data; Contact Details||Inability to receive relevant promotions and offers||Consent|
|11||Solvency verification, compare information accuracy and third-party verification||Personally identifiable data; Game Activity; Financial Information; Social Security Information; Connection Information; Location Information||Potential restrictions on the use of the website in cases of detection of illegal practices||Legitimate Interest (Guarantee of accuracy and legal nature of the information provided)|
|12||Quality Assurance and Staff Training through Call Recording and/or Presentation of Educational Material||Personally identifiable data; Contact details; Game Activity||Impossibility of customer service/phone callback||Legitimate Interest (ideal experience for our customers and quality assurance of our customer service|
3. Disclosure of Personal Information
We will not sell, distribute, or rent your personal information to third parties in ways that are not explicitly stated in this privacy notice. We may, nevertheless, release your personal information to the following third parties:
3.1 If we sell or acquire any company, assets, or shares, we may disclose your personal information to the potential seller or purchaser of such business, assets, or shares.
3.2 If we are forced to disclose or share your personal data to comply with any legal or regulatory requirement, enforce our Terms and Conditions, or defend our rights, property, or safety, or the rights, property, or safety of our customers or others.
3.3 To work with local authorities to uphold laws and investigate and punish unlawful and fraudulent actions. We reserve the right, at our sole discretion, to disclose any information about you to law enforcement and other government authorities in connection with any investigation of fraud or other criminal activities. These authorities are, in particular:
- Gambling authorities in the countries in which we operate
- Sport governing bodies (e.g. FIFA)
- Anti-Money Laundering / Counter-Terrorism Financing Agencies (AML / CTF)
- Law enforcement agencies in the countries in which we operate
This includes sharing information with other firms and organizations (for example, banks and credit institutions) inside and beyond the EU for the goal of preventing fraud and reducing credit risk. These organizations may use your personal information to investigate and prosecute such violations in line with their policies and procedures.
3.4 Finally, we may disclose some personal information to unaffiliated service providers, agents, or independent contractors that assist us in the maintenance of our website and other administrative services (including but not limited to order processing and fulfillment, customer data, maintaining and analyzing data, sending customer communications on our behalf, and collecting entries, selecting winners, and realizing prizes for contests and other promotions). We make every effort to guarantee that these unaffiliated third parties do not use personal information for any other reason than to deliver the administrative services for which they are accountable. We also engage into agreements with these third parties that compel them to follow the privacy standards required by law in the protection of your personal information, and we only use them for the reasons for which they were given to us. Third parties give information regarding data processing to the public through their websites or other open communication assets.
4. Duration of data maintenance
4.1 In accordance with the Data Minimization and Storage Limitation principles, we only keep customer information for as long as it is required for the original reason for which it was received. Your data will be stored for a minimum of five years after the client relationship ends for all of the reasons listed below. Furthermore, we link the keeping of your information with any variations that may arise from the exercise of your data privacy rights (see section 6). However, owing to probable legal responsibilities, legitimate interest objectives, and so on, certain personal information may be maintained beyond this length of time in some situations. Examples of such causes include:
- Money laundry;
- Player Protection;
- Civil law;
- Criminal law;
- Any other legal issues.
5. Data protection rights
5.1 At any time while we are storing or processing your data, you have the following rights and can submit a request via your personal account:
- Right of access – You have the right to see the personal information we have on file for you.
- Right to correction – you have the right to have erroneous or incomplete information about you corrected. More information may be found in Section 7 of the current policy.
- Right to erasure – you have the right to request that the data we have on file about you be deleted, and we are bound to comply with such a request in certain situations.
- Right to Processing Restriction – You have the right to request that the processing of your personal information be limited, and we are bound to comply with such a request if certain circumstances are met.
- Data portability – you have the right to have the information we have on file about you transferred to another organization.
- Right to object – under certain situations, you have the right to object to certain processing operations.
- Right to withdraw consent – where the legal basis for processing your data is Consent, as described in section 2, you have the right to withdraw your consent at any time via our dedicated consent management portal integrated into your account personal, without affecting the lawfulness of processing based on such consent prior to withdrawal. Such requests to cease receiving commercial messages will be handled within three (3) days of receipt.
5.2 We shall assess your request and react to you on the status and result of the request (application grant, partial application grant, application rejection) as soon as feasible, but no later than one month from the date of submission. If Pin Up app refuses your request regarding the Data Privacy Rights outlined above, we will explain why. You have the right to make a complaint with the appropriate regulatory body directly.
5.3 We retain the right to refuse requests that are excessively repeated, need disproportionate technical effort or have disproportionate technical implications, endanger others’ privacy, or are highly impracticable.
6. Updating Personal Information
6.1 Except in rare circumstances, if you are a registered user of the website, you may examine, amend, or remove some personal information by signing in and utilizing the tools provided to change such information. Certain data, such as date of birth or age, required to verify eligibility, however, cannot be erased.
6.2 You may get a copy of your personal information by logging into your personal account. In order to get such copies, you will be needed to present verification of your identification. You must provide sufficient information to identify yourself as well as any pertinent information to assist us in processing your purchase. If you want to cancel your account, you may do so by contacting Customer Support or via your personal account. We will comply with your requests unless we have a good reason not to.
7.1 The security of your data is very important to PinUp, and we always aim to give all necessary methods to guarantee the security of your personal data, the limitation of unauthorized access, and/or any modifications. To safeguard our customers’ privacy, we use information security procedures that are in line with current best practices. These safeguards comprise technological, procedural, monitoring, and tracking actions aimed at preventing data abuse, illegal access or disclosure, loss, modification, or destruction.
Please visit our dedicated Security page for more information on how we secure your personal data.
8.1 We gather your personal data, such as transactional behavior, gaming activities and practices, cookies, and geolocation information, among other things, in order to offer you with a customized service based on your choices. Profiling enables us to provide a more tailored perspective and a better user experience on our website.
8.2 Profiling activity also enables us to discover and report possible fraudulent conduct and violations of our Terms and Conditions, potential money laundering activities, and responsible gambling behavior to the appropriate authorities, in accordance with our regulatory/legal requirements to do so.
To recap, the profiling activity is deemed required for the following reasons:
- You may get customised offers, emails, and general marketing campaigns, as well as a personalized gaming experience, for marketing purposes.
- Reasons for Responsible Gaming: If your conduct is regarded “at risk,” and you are discovered to be addicted or claim that you are, your account will be cancelled for your own safety in line with our Terms and Conditions.
- Anti-fraud grounds: If you breach our Terms and Conditions (for example, by having two (or more) active accounts on our site), your accounts will be cancelled and your betting actions canceled in line with our Terms and Conditions.
9. Marketing Digital
9.1 We gather your personal data, such as transactional activity, gambling activities and practices, cookies, and information, in order to present you with targeted offers, promotions, and marketing materials. Your use of such services is entirely at your discretion, and your approval was given when you enrolled. You may offer this permission later, or withdraw existing consent for such services, using our dedicated consent management platform, which is linked into your personal account.
10. Internet Protocol (IP) Address
10.1 We collect your IP address and browser information when you visit the website. Your IP address is a unique address that devices on a computer network use to identify and interact with one another. Browser settings may include the browser type, language, and time zone. We gather this information in order to customise your experience and monitor your device in the event of abuse or unlawful acts linked to visits or usage of the service. Furthermore, we may utilize your IP address to determine your location (at the city level).
11.1 When you visit a website, a ‘cookie’ is a little text file that is transferred to your access device and enables the website to acquire certain information from your browser, such as your preferences. Cookies and related technologies are used on this site to manage sessions, deliver customized pages, and tailor adverts and other information to your individual requirements and interests.
11.2 You may enable your browser to prohibit all cookies, including those related to our services, or to notify you when a cookie is being placed by us. However, keep in mind that if cookies are deactivated, many of our services may not operate correctly. We may, for example, forget about your language choices. For advice on how to remove and/or deactivate cookies, see the technical documentation for your browser or mobile device.