Support

Privacy Policy

Last updated 4th April 2022

Version 1.0.

INTRODUCTION

Welcome to the LeoVegas Gaming Plc's (“LeoVegas”, “us” “we” and “our”) privacy policy relating to provision of the Services (e.g. Games) of LeoVegas provided via www.leovegas.com and/or any sub-website and/or associated domains (and/or sub-domains) and any related software applications (“Site”, “Website”).

This Website and the services are being offered by LeoVegas as part of the open and regulated iGaming market conducted and managed by iGaming Ontario (http://www.igamingontario.ca/en). In the course of providing the services (i) LeoVegas collects, uses and discloses personal information on behalf of and as agent to iGaming Ontario; (ii) LeoVegas collects personal information in accordance with the Freedom of Information and Protection of Privacy Act and other applicable privacy laws, and under the authority of Ontario Regulation 722/21 made under the Alcohol and Gaming Commission, and the operating agreement entered into between LeoVegas and iGaming Ontario.

Personal Data under this privacy policy means information about an identifiable individual and includes any information that constitutes personal information within the meaning of applicable privacy laws.

This Privacy Policy is provided in a layered format, so you can click through to the specific areas set out below. In summary, we think that the following information is the most relevant for you:

Purpose of processing: We process your personal data for the purpose of providing you with the services, to allow your access to Website, to comply with our legal obligations such as anti-money laundering and responsible gaming, to detect and prevent fraud and to commercially grow our business (e.g. direct marketing, analyses);

Your rights: You have a number of rights afforded by applicable laws, especially a right to withdraw your consent to certain processing activities, such as the direct marketing of our own goods and services, segmentation, and our loyalty programme. Also, you have a right to request access to all of the personal data that is undergoing processing and a right to erasure of the data that are no longer necessary;

Implications of processing: Processing of personal data will result in provision of services (or denial thereof if certain data is not provided), receiving marketing communication, segmentation with respect to risk categories or bonuses and similar offers.

We however recommend that you read this Privacy Policy in full, with care. For the ease of your orientation, these are the contents of this Privacy Policy:

1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this Privacy Policy
Changes to the privacy policy

2. THE DATA WE COLLECT ABOUT YOU

Personal Data
Data Obtained from You
Data obtained from different sources
Special categories of Personal Data
If you fail to provide Personal Data

3. WHY AND HOW WE USE YOUR PERSONAL DATA

Detailed purposes and legal basis
Direct marketing

4. RETENTION

Criteria used to determine retention periodDetails on our retention periods

5. RECIPIENTS OF YOUR PERSONAL DATA

Authorised disclosures

Group companies/other brands for Responsible Gaming Purposes
Group Companies/other brands for AML purposes
Data sharing for AML and Responsible Gaming Purposes between brands
Corporate restructuring
Service Providers

6. INTERNATIONAL TRANSFERS

7. DATA SECURITY

8. YOUR RIGHTS UNDER DATA PROTECTION LAWS

Right to Deletion/Erasure
Right to withdraw consent
Right to Lodge a complaint
What we may need from you
Time limit to response
Different brands

9. AUTOMATED PROCESSING – PROFILING

Responsible Gaming Profiling
AML profiling
VIP Profiling
Direct Marketing Profiling
Sports Risks Segments Profiling
Games recommendation

10. COOKIES

11. Data Protection Office

12. Contact Details

1. IMPORTANT INFORMATION AND WHO WE ARE

1.1. 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.
n This Privacy Policy stipulates details and conditions of collecting and processing your Personal Data and provides you with information in accordance with openness and transparency principles 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 19 years of age). If a parent or guardian is aware that his or her child under the age of 19 has provided us with personal data, the parent may contact us at the details set out below in the “Contact Details” section to have such personal information deleted.


1.2. 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 changes made to this Privacy Policy (as well as other terms and conditions relevant to the Site). We shall also archive and store previous versions of the Privacy Policy for Your review upon request.

2. THE DATA WE COLLECT ABOUT YOU

2.1. 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.

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

a) Registration Data provided by you when you register and/or open Your Member Account (notably in the terms of the T&Cs) including first name, last name, username or similar identifier, date of birth, applicable (where permitted or required by law), gender, and jurisdiction.
b) Contact Data includes permanent address, email address and telephone numbers.
c) Identification and Verification Data (Anti-Money Laundering/Due Diligence/KYC data) that include your name, surname, permanent address and proof (e.g. utility bill or other documentation showing your address), date of birth, nationality, employment information (i.e. descriptive occupation, business phone number, employer name and address), politically exposed person and head of international organization information, financial status information (e.g. bank statement, source of income and source of wealth, tax information), masked credit card details, proof of e-wallet ownership such as Netller, Skrill, Paypal, Paysafe, government-issued identification number, KYC documentation (e.g. ID card, Power of attorney), country of residence, and citizenship,.
d) Responsible Gambling Data (RG) including name, surname, Postal Code, email, phone number, country, date of birth, territory applicable social insurance number where permitted or required by law, approved transactions (deposits and withdrawals), denied transactions (deposits and withdrawals), Identification and Verification Data, Self-exclusion Data,
e) Self-exclusion Data include data pertaining to you and your self-exclusion such as your Registration and Contact Data and your self-exclusion info such as reason, start and date, utilisation of self-exclusion tools such as exclusions, session limit, loss limit, wager limit, deposit limit, reality check.
f) 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.
g) 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.
h) Log in Data includes internet protocol (IP) address, your logins (first log in last login, last failed login), duration of log ins, 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.
i) 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;
j) Marketing Communications Data includes your preferences in receiving marketing from us (opt in/opt out), as well as your Contact and Registration Data.
k) Other Communication Data provided by you in communication with Us (via recorded calls, chats, emails, or SMS) which may include various data such as your intentions, interests, complaints, preferences, as well as internal communication and notes.
l) Analytics data include various data provided by you or observed 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”.

2.3. Data from different sources

2.3.1. We collect information for AML/CFT purposes on the background of the player, which we source from third party providers (private companies working mostly with public sources but may also include your mobile service provider), such as Bisnode, Transunion, GBG Group, HooYu Ltd and which includes information whether player is politically exposed person or head of an international organization and whether any international and/or financial sanctions have been imposed and/or information on any corporate or property ownership, court judgements and/or insolvency. Moreover, background information is, using so-called OSINT analyses (Open-Source Intelligence) collected from publicly available sources (e.g. Google search, all social media services like Facebook, Twitter, Pinterest, Instagram, LinkedIn as well as other services/sites like pipl.com, https://www.zopla.co.uk/, https://www.glassdoor.com, https://www.gov.uk/government/organisations/companies-house, https://www.ratsit.se/ ). We also share your data with a 3rd party provider Sphonic as part of our electronic ‘’Know your Customer” and identity verification procedure for new sign-ups. Where a manual process is needed, this will be conducted through HooYu Ltd.

2.3.2. To comply with our legal obligations stemming from applicable laws and license conditions, when applicable, we collect Self Exclusion Data also from other licensed gaming operators belonging to the same group of companies as LeoVegas (LeoVegas Mobile Gaming Group). Likewise, for the same purposes, LeoVegas uses Self Exclusion Data collected with respect to any other brands under which LeoVegas operates its licensed gaming business.

2.3.4. 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 other device identification data are sourced and processed by Us utilizing a services of third-party fraud detection software provider.

2.4. Special Categories of Personal Data

We will not ask you for, or 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, You may, at your own discretion, send us such data in communicating with Us.

2.5. IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with Our Services).

3. WHY AND HOW WE USE YOUR PERSONAL DATA

3.1. 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 Games 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 license conditions such as Anti-money laundering and responsible gaming
• For identification and verification proposes
• for direct marketing of LeoVegas goods and services via electronic mail as provided below; and
• for direct marketing via live telephone calls or postal mail as provided below
• for analytics purposes


3.2. Detailed purposes and legal basis

3.2.1 We have set out below, a description of all the possible ways we plan to use your personal data and which legal bases we rely on to do so. 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.

3.2.2. Please note that the below sets out the general information about the Personal Data We process.

3.2.3. The processing of players’ data which is subject to the local and federal laws of the province of Ontario, Canada, is primarily carried out on the basis of Your consent which is acquired from You directly or indirectly, as well as other applicable lawful grounds in the following manner:

• Explicit Consent; we directly ask you for your consent to carry out a processing activity where the processing is carried out voluntarily by (Yourself or on Your own instruction) or through your explicit permission and instructions;
• Implied Consent; in the case where You have been provided an opportunity to opt-out of such processing, We will consider You as having provided Your consent for the processing to take place if you do not choose to opt-out of the processing; and
• Legal Obligations including specific scenarios we are obliged by law to share or process data with 3rd parties, including Government Authorities.

3.2.4. The processing of personal data is carried out for the following purposes:

• To register you as a new player; to identify you and verify you when you access your Account to allow you to participate in in Games
• To allow your participation in the Games
• To process and manage payments transactions
• To manage our relationship with you, to communicate with you, to provide you with access to Games and any ancillary services
• For AML/CTF and due diligence purposes
• To establish and investigate any suspicious behaviour in order to protect our business from any risk and fraud
• Identification and investigation of gaming activity for responsible gaming purposes
• Responsible gaming profiling
• To ensure that self-excluded players with respect to LeoVegas or any other brand/company within the group are duly self-excluded and do not access Our Services (e.g. Games) and to handle and action requests made by the customer relating to the use of the Responsible Gaming Tools through the website
• Direct Marketing of our own goods and services (Games) – incl. bonuses and offers
• Direct Marketing of our own goods and services (Games) –loyalty programme/VIP experience
• Social Media Marketing
• Customer segmentation for the purpose of tailored offers and bonuses sent via direct marketing
• Loyalty program/VIP Experience purposes to (i) offer you attendance to events which would be of interest to you and possible guests, based on previous attendance; (ii) offering bonuses and other gifts which would be of interest to you, based on previous bonuses or gifts you may have benefitted from; (iii) contacting you on your preferred contact channels
• Customer segmentation for the loyalty program purposes and responsible gambling purposes;


• To monitor player activity, detect and prevent fraud and to manage risk exposure
• Commercial business analyses for the creation of standard, periodical as well as ad hoc reports.
• Web Analytics
• Games recommendation

3.3. DIRECT MARKETING

3.3.1. In accordance with the applicable laws and on the basis of Your consent, LeoVegas 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, VIP experience) via, as applicable:

electronic mail (email or SMS), or

• direct messaging via social media, or
• live phone calls, or
• postal mail, or
• push notification (app and/ or desktop)

If you do not wish to receive direct marketing any longer, You may withdraw your consent at any time and free of charge, as applicable, either by:

• clicking the “Unsubscribe” link at the end of an electronic message, or
• contacting us, or
• informing the caller (in the case of phone call), or
• changing your Settings in your profile.

3.3.2. Please note that even if You withdraw your consent to receiving direct marketing ma-terial from, from time to time We may still need to send You certain transactional or account-related communications.

4. RETENTION

4.1. Criteria used to determine retention period: 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.

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 anonymize it.

4.2. Details on our retention periods

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 in-definitely.
• 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 sub-sequent 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 LeoVegas system as per our terms and conditions, therefore as long as we store, for the abovementioned purposes, all of the Personal Data of the player, the player may, following a closure only re-open their existing account, provided the account its 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 from us by contacting us (please refer to our “Contact Details” below).

5. RECIPIENTS OF YOUR PERSONAL DATA

5.1. As LeoVegas’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 LeoVegas.

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 and only permit 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.

5.1.1 Details on the categories of the 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)
• marketing suppliers to perform certain marketing activities on behalf of LeoVegas
• marketing partners to perform certain marketing activities on behalf of LeoVegas
• marketing consultants to provide marketing advice to LeoVegas
• 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
• companies within LeoVegas Mobile Gaming group to provide certain services/support with functions of LeoVegas
• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services
• KYC providers Sphonic and HooYu for the purpose of customer identity verification as part of the sign-up process

5.2. 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 surpassing fraud or other criminal activity, as well as to comply with legal or regulatory obligations and duties, LeoVegas has a right to:

• forward Your Personal Data to the government authorities;
• share any of Your Personal Data to the relevant gambling regulator;
• 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.

5.3. Group companies/other brands for Responsible Gaming Purposes

When applicable, Your Self-Exclusion Data is, for the purpose of compliance with legal obligations, and Our license conditions, shared also with other companies within the same group. Likewise, for the same purposes, LeoVegas shares your Self Exclusion data with other brands under which it operates its gambling activities.

5.4. Group companies/other brands for AML Purposes

When applicable, your Identification and Verification Data in the extend of first name, surname, date of birth and postcode is, for the purpose of compliance with legal obligations, shared between various brands under LeoVegas operates its gambling activities.

5.5. Data sharing for AML and Responsible Gaming Purposes between brands

When applicable, your Identification and Verification Data, Transaction and Usage Data, Registration Data and Contact data are for the purpose of compliance with legal obligations, shared with as well as sourced via various brands under LeoVegas operates its gambling activities.

5.6. Corporate restructuring

Third parties, incl. any companies belonging to the same group of companies as LeoVegas, 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.

5.7 Service Providers

Your personal data may be transferred (or otherwise made available) to third parties that provide services on our behalf. We use service providers to provide services such as hosting the Website and providing advertising and marketing services. Our service providers are only provided with the information they need to perform their designated functions and are not authorized to use or disclose personal information for their own marketing or other purposes. Our service providers may be located in the U.S., Canada or other foreign jurisdictions.

5.8 iGaming Ontario: Due to both Our contractual and legal obligations we may be obliged to provide and disclose personal information pertaining to You to iGaming Ontario that conducts and manages internet gaming in the province of Ontario Canada. iGaming Ontario may also in turn be legally required to further disclose information with other entities.

6. INTERNATIONAL TRANSFERS

Where personal data is transferred or transmitted outside of Canada and/or Ontario, we will ensure that any transfer is subject to an equivalent level of protection either afforded by the jurisdiction to which the personal data will be transferred, or by means of appropriate safeguards including the use of specific contracts which we will apply in relation to the personal data being transferred.

7. 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. Various technical controls ensure data and information are always encrypted using industry standard encryption techniques across the board. 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 to specifically 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 and they are subject to a duty of confidentiality.

In order to protect your account, we strongly recommend that you do not disclose your password to anyone. We will never ask you for your password in any unsolicited communication (such as letters, phone calls or email messages). If you become aware of any unauthorized access to or use of your account, you are required to notify us immediately. For general information for how to help protect your information online, please refer to the resources posted by the Information and Privacy Commissioner of Ontario at https://www.ipc.on.ca/privacy-individuals/ensuring-your-privacy-is-protected/.

We have put in place plans and procedures to deal with any actual or suspected personal data breaches. We will notify you, iGaming Ontario and any applicable regulator of a breach where we are legally required to do so, and we will aid iGaming Ontario and any related authorities in breach management and handling of any results from a breach.

8. YOUR RIGHTS UNDER THE DATA PROTECTION LAWS

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.

The easiest way to obtain this information is to activate “Download my Data” functionality of your profile. 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. If this information is not what you were looking for, you wish to obtain other information, request this information via another channel, the functionality of this feature is not available (e.g for technical reasons), or you do not wish to use it, please contact us at sar@leovegas.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 30 days of receipt of the request, which period may be extended by two months where necessary, taking into account the complexity and number of the requests. We shall inform You of any such extension within 30 days of receipt of the request, together with the reasons for the delay.

Although all reasonable efforts will be made to keep Your Personal Data updated, you are kindly requested to inform Us promptly. 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.

8.1. Right to withdraw consent

In those cases where We process on the basis of Your consent, YOU HAVE THE RIGHT TO WITHDRAW YOUR CONSENT AT ANY TIME.

Should You exercise Your right to withdraw Your consent at any time (by writing to Us at the mailing address or email address set out below) we will delete your information unless there is a statutory or alternative legal requirement to retain it.

When We ask for such Personal Data, You may always decline, however We may not be able to provide You with the use of our services.

8.2 The Right to lodge a Complaint

You also have the right to lodge complaints with the appropriate Privacy Commissioner. 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).

8.3 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.

8.4 TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within 30 days. In situations where your request is particularly complex or you have made a number of requests, we may require more time to respond. In this case, we will send notice of an extension and we will keep you updated.

8.5 DIFFERENT BRANDS

LeoVegas is operating its gaming business also under other brands and trademarks. For the purpose of the exercise of your rights as provided above, and for the purpose of clarity and legibility of our reply, we will initially comply with the requests with respect to data processed under the brand from where the request is originating. Should you wish your requests to be complied with respect to all of the brands with respect to which LeoVegas operates its business, please make sure to flag this in your request.

9. AUTOMATED PROCESSING - PROFILING

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

LeoVegas is on the basis of the applicable laws and license 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 historic data describing behaviour of players, in particular certain Responsible Gaming Data, Transaction and Usage Data, and Other Communication Data (in particular sentiment used in message) LeoVegas has established rules regarding who is likely to suffer from gambling addiction and then take relevant action.
n 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, are not taken automatically without human intervention.

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

LeoVegas is, on the basis of the applicable laws and license 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 are not taken automatically and require human intervention.

9.3. Meaningful information about the logic involved in the automated processing for loyalty/VIP 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 VIP/loyalty program. This model is used on fresh players and depending on their involvement with our services the VIP status is predicted. The result of the model is a prediction as to whether the player will become a VIP. Apart from gender, country and age, we do not make use of personally identifiable information as input in the model. Decisions, on the basis of the prediction, are not taken automatically without human intervention. The process is based on our compliance with legal obligation and with respect to the loyalty offers, on legitimate interest of LeoVegas regarding 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.


9.4. 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 legitimate interest of LeoVegas regarding 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.


9.5. Meaningful information about logic involved in automated processing with respect to Sports Risks Segments

LeoVegas is manually processing your Sports Risks Segments as established by the sportsbook provider – Kambi. The Sports Risk Segments are established by Kambi on the basis of automated profiling performed by Kambi. They use automated processing to suggest a risk profile, however such risk profile is confirmed or amended by Kambi's personnel. In conjunction with provision of its services, Kambi uses automated risk management technology to assess the risk of particular betting activities. If You seek to undertake a bet that falls outside of the parameters associated with your risk profile, the bet is flagged for Kambi’s personnel to review. To safeguard your rights and interests, Kambi allows you to contest any decision that they make about your risk profiling or to object to our use of profiling. To this end, please contact us (LeoVegas). More information on processing activities performed by Kambi please consult Kambi’s privacy notice here: https://www.kambi.com/player-fair-processing-notice

9.6. Meaningful information about logic involved in automated processing with respect to Game recommendation By making use of your Transaction and Usage data, we provide you a list of games that is aligned with your taste. The system determines your affinity towards different games and generalise your preferences to unseen games. Ranking the computed preferences, an ordered list of games is produced and can be served as recommendations.

The games recommendation is produced without human intervention. The process is based on legitimate interest of LeoVegas regarding providing customised, quality experience for the players.

10. COOKIES

Our site uses cookies. A cookie is a tiny element of data that our Website sends to a user’s browser, which may then be stored on the user’s hard drive so that we can recognize the user’s computer or device when they return. You may set your browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from our Website, you may not be able to take advantage of all of the Website features. For further information on what cookies are, which cookies we use, how and why we use cookies, and how you can control which cookies are dropped, please read our Cookies Policy.

11. Data Protection Officer

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.

12. CONTACT DETAILS

Although our goal is to always be as clear and transparent as possible, if you need any clarification on this Privacy Policy, we would be happy to provide you with any such information you may need.

You have the right to file a complaint through our complaints process, which is highlighted in section 22 of the LeoVegas Terms and Conditions which can found here

Our full details are:

General email address: privacy@leovegas.com
DPO email address: dpo@leovegas.com
Postal address: Leovegas, Level 7, The Plaza Business Centre, Bisazza Street, Sliema SLM 1640, Malta

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