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Your Privacy Matters
Coolbet.co’s mission is to give our customers a unique player experience through innovation, top class products, transparency and customer care. Central to this mission is our commitment to be transparent about the data we collect about you, how it is being used and with whom it is shared.
This Privacy Policy applies when you use our Services (described below).
We offer you choices about the data we collect, use and share as described in this Privacy Policy, Cookie Policy and under My Account settings page.
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Introduction
Our registered users (“Customers”) share their personal identities and other personally identifiable information in order to take part in our Services (enlisted below).
We use the term “Designated Countries” to refer to countries in the European Union (EU), European Economic Area (EEA) and Canada.
Services
This Privacy Policy applies to Coolbet.co.
We are a free to play gaming website, which offers services including but not limited to Sportsbook competitions, free to play Casino games and other free to play competitions. Among other actions and uses, Customers use our Services for, playing games, browse our website, request rewards, receive rewards, connect to social media and for many more. Our Privacy Policy applies to any Customer or Visitor to our Services.
Data Controllers and Contracting Parties
If you reside in the “Designated Countries” or outside of the “Designated Countries” – Staycool OÜ (Estonia), will be the controller of your personal data provided to, or collected by or for, or processed in connection with our Services.
As a Visitor or Customer of our Services, the collection, use and sharing of your personal data is subject to this Privacy Policy (which includes our Cookie Policy and other documents referenced in this Privacy Policy) and updates.
Change
Coolbet.co (“we” or “us”) can modify this Privacy Policy, and if we make material changes to it, we will provide notice through our Services, or by other means, to provide you the opportunity to review the changes before they become effective. If you object to any changes, you may close your account by contacting support@coolbet.co or dataprotection@coolbet.co.
You acknowledge that your continued use of our Services after we publish or send a notice about our changes to this Privacy Policy means that the collection, use and sharing of your personal data is subject to the updated Privacy Policy.
1. Data We Collect
1.1 Data You Provide To Us
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Registration
To create an account you need to provide data including your email address, password, first name, username and a confirmation about your legal age. Upon registering, we will automatically receive your IP location, time and date of registration.
1. Data We Collect
1.1 Data You Provide To Us
Registration
To create an account you need to provide data including your email address, password, first name, username and a confirmation about your legal age. Upon registering, we will automatically receive your IP location, time and date of registration.
1.2 Service Use
We log usage data when you visit or otherwise use our Services, including our websites, applications and platform technology, such as when you view or click on content or ads (on or off our sites and applications), perform a search, install or update one of our mobile apps, share predictions or anything else from our Services on social media. We use log-ins, cookies, device information and internet protocol (“IP”) addresses to identify you and log your use.
1.3 Cookies and Other Technology
As further described in our Cookie Policy, we use cookies and similar technologies (ad tags and device identifiers) to recognize you and/or your device(s) on, off and across different Services and devices. You can control cookies through your browser settings and other tools. You can also opt-out from our use of cookies and similar technologies that track your behavior on the sites of others for third party advertising.
1.4 Your Device and Location
When you visit or leave our Services (including our plugins or cookies or similar technology on the sites of others), we receive the URL of both the site you came from and the one you go to next. We also get information about your IP address, proxy server, operating system, web browser and add-ons, device identifier and features, and/or ISP or your mobile carrier. If you use our Services from a mobile device, that device will send us data about your location based on your phone settings. We will ask you to opt-in before we use GPS or other tools to identify your precise location.
2.How We Use Your Data
How we use your personal data will depend on which Services you use, how you use those Services and the choices you make in your settings. We use the data that we have about you to provide and personalize, including with the help of automated systems, our Services (including ads) so that they can be more relevant and useful to you and others.
2.1 Services
We use your data to authorize access to our Services.
We will use data about you (such as your profile, clicks in any of our services, transactions, account settings and all other interactions in relation to any of our Services) to offer you a better experience and personalized product offering.
Furthermore, we allow you to use various social media services and you are in full control to manage this type of communication. Please see on how to control your Facebook posts and news feed from here. Also please visit our Cookie Policy page for further information.
2.2 Communications
We will contact you through, email, direct mail, on site messages via our online website and mobile application among other ways through our Services. We will send you messages about the availability of our Services, security or other service related topics. We will also send you messages about our marketing campaigns related to our services, in case you won a reward, reminders and suggestions. You may change your communication preferences at any time from here. Please be aware that you cannot opt-out of receiving service messages from us, including but not limited to security and legal notices.
2.3 Advertising
We target (and measure the performance of) ads to our Customers (logged in ; logged out), Visitors and others both on and off our Services directly or through a variety of partners using the following data whether separately or combined:
* Data from advertising technologies on an off our Services, like pixels, ad tags, cookies and device identifiers;
* Member-provided information
* Data from your use of our Services (e.g search history, content that you read or click on, page visits, clicking on an ad, emails that you open, marketing campaigns that you react to and other data).
Please visit the Cookie Policy page in order to review and or, to opt-out of our cookies.
2.4 Marketing
We use information that you have provided to us and based on the consent that you have provided, to deliver personalized and relevant marketing information. We may analyze the effectiveness of different past marketing campaigns about you in order to deliver even more personalised offerings and suggestions. When you opt-in to receive email or direct mail, then it has to be clearly understood that you accept de-personalized profiling and automated decision making. Meaning, we use aggregated data that is not personally identifiable, in order to know which sports, games or emails you may like and we use both analytical and automated tools in order to process this data. Based on this processing and profiling, we deliver the relevant content or product offering to you, via your preferred communication method.
2.5 Developing Services and Research
Service development
We use data to conduct research and planning for further development of our Services in order to provide you and others with a better, more intuitive and personalized experience, to drive loyalty, growth and engagement with our Services.
Surveys
From time to time we conduct surveys and questionnaire related to experience with our Services or the development of new Services. You may opt-out of survey invitations by opting out of email communication from here.
2.6 Customer Support
We use data (which can include your communications) to investigate, respond to and resolve complaints and Service issues. We also use the data to measure customer satisfaction.
2.7 Aggregate Insights
We use your data to produce, use and analyze aggregated insights that do not identify you. For instance we may use your data to generate statistics, calculate transactional information, track page visits or clicks or to classify you anonymously based on a combination of attributes and data metrics.
2.8 Security and Investigations
We use your data (including your communications) if we think its necessary for security purposes or to investigate/prevent possible fraud or other violations of our Terms & Conditions, Privacy Policy and/or in regards to any other of our Services rules.
2.9 Processes
Coolbet.co will never sell Your data. Only authorized personnel can have access to Your data which is controlled via permission levels. Moreover Coolbet.co only processes and keeps the data for a limited period of time where possible, while taking into account all the measures set out in the General Data Protection Regulation.
We process data for the:
Customer identification & due diligence, Customer support & quality assurance, Fraud detection & prevention, Customer relations & communication, Advertising activities, Operational management.
These processes have the following purpose and description:
– For identification, authentication and authorization for Coolbet.co services.
– For services, security and customer access management.
– To manage customer relationship, customer information and contact history.
– Providing support to the customer as well as managing service and marketing campaigns.
– To perform analysis, reporting, profiling about the customer for Coolbet.co activities, such as: for games, services and fraud prevention.
– Preventing and detecting misuse, illegal activities, non compliance with our terms and conditions or privacy policy. Ensuring the legality and security of all Coolbet.co customers.
– To perform macro analysis, statistical analysis, granular and detailed segmentation, forecasting, and research based on customer information. Also, to analyze customer survey results.
– To manage customer and marketing communications, product development and service offerings as well as business development and automated decision making.
– Profiling for internal risk management reasons, including but not limited to profiling based on competition participation history, activity on the platform, product preference, reward winnings or usage, customer location and other personal data.
– Moreover we differentiate customers based on the specific application platform which they use.
The categories of personal data we use during processes
We use the following data in these processing activities:
– Game Activity
– Login history
– General Personal Information
– Profiling Information
– Chat transcripts
– Email copies and Email verification
3. How We Share Information
3.1 Our Services
Profile
Your profile is always protected within our Services as we never publish your personal information anywhere publicly on the web or any other public place for that matter. We might share some of your personal data with other service providers based on a legitimate interest or based on a lawful basis.
Internally we have carefully organized so that only a selected personnel has access to your personal data in order to fulfill their designated professional duties and we make sure that your data is always handled with care.
Third Parties We Use
According to Article 14 of the General Data Protection Regulation, StayCool OÜ hereby enlists all third parties we use in order to perform tasks or processes to meet necessary operational activities:
Email Provider: We use a third party email provider for automating our email process and to be more analytical. When it comes to personally identifiable data, then we only share your email address and Coolbet.co User ID with them. We have made sure that our email provider is GDPR compliant and is a safe and trustworthy third party service to use. Your data will be deleted upon our request from their servers. In order not to receive any email from us, this can be controlled under your preferences from here. Coolbet.co uses this service in order to perform its internal marketing objectives, reach our customers with the relevant message, offer or product updates.
Casino Providers:
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– When you play casino slots developed by NetEnt, NetEnt’s privacy policy also applies. It can be found here.
– When you play casino slots developed by Microgaming(Quickfire), Microgaming (Quickfire) privacy policy also applies. It can be found here and here
– When you play casino games developed by Yggdrasil, then Yggdrasil’s privacy policy also applies. It can be found here.
– When you play casino games developed by Evolution, then Evolution’s privacy policy also applies. It can be found here.
– When you play, You have the right to access personal data held by the Operator about You. You also have the right to demand termination of processing of personal data and correction, closure and deletion of personal data unless exercising such right is restricted by law.
Customer support: We use several providers in order to service our customers requests. We made sure that these providers all fall under the Privacy Shield framework. By contacting our support team you acknowledge that the communication will be shared with these 3rd parties. This is necessary under the contract with Coolbet.co, in order to use our Services.
Using Social Media
We allow you to share content related to you and our services on various social media platforms (e.g Facebook). We want to emphasize that you control where you want to post or share this content and that it is under your control to keep or delete this content under your social media providers settings. Moreover, you should be aware that anything that is posted on social media platforms, can be redistributed or re-shared by any one.
3.2 Service Providers
We use others to help us provide our Services (e.g., maintenance, analysis, audit, payments, fraud detection, marketing and development). They will have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes. We take great care in the selection of the providers that we choose to work with and make sure that they are committed to protecting your data at all times.
3.3 Legal Disclosures
It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you, (3) investigate and defend ourselves against any third-party claims or allegations, (4) protect the security or integrity of our Service (such as by sharing with companies facing similar threats); or (5) exercise or protect the rights and safety of Coolbet.co, our Members, personnel, or others. We attempt to notify Members about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.
3.5 Change in Control or Sale
We can also share your personal data as part of a sale, merger or change in control, or in preparation for any of these events. Any other entity which buys us or part of our business will have the right to continue to use your data, but only in the manner set out in this Privacy Policy unless you agree otherwise.
4. Your Choices and Obligations
4.1 Data Retention
We retain your personal data while your account is active with us or, as long as and in the extent as required by the law or where we find the legitimate interest or need for it. This includes data you or others provided to us and data generated or inferred from your use of our Services. Even if you have not used our Services for years, then we keep your data, until you or we, decide to close your account. Also, we have set internal guidelines in order ask you about whether you would like to close your account with us, after a longer period of inactivity. Furthermore, regardless of the closure of your account, we may retain and keep data which is necessary as by the law or critical from our perspective, but while maintaining a clear and eventual set timeline that clearly states, for how long the data is being kept. Based on our legitimate interest and internal risk management, we may hold your personal details for up to 10 years.
Below we have described our data retention procedure:
Coolbet.co will retain data about you in the following way: based on legitimate interest, legal requirement, based on the contract with us and by consent. Please read more about the legal basis for processing from section 5.3
4.2 Rights to Access and Control Your Personal Data
We provide options to choose what kind of communication you want to receive from us or if any at all. Moreover, we provide the ability for you to change or edit some of your data to the extent that is either allowed by the respective laws that apply to us or by the internal policy that we have set out in this Privacy Policy and by what is required for us to fulfill our Service obligations.
For all other requests you can always contact us in writing on support@coolbet.co and we will respond to any enquiries as soon as possible, but no later than within 30 calendar days from receiving your request.
We will consider your request in accordance with applicable laws.
If you reside in any of the designated countries, then (Staycool OÜ) will be the controller of your personal data provided to, or collected by or processed in connection with our Services. In that regards, you have the right to file a complaint with the Estonian Data Protection Inspectorate: info@aki.ee, phone: +372 5620 2341 or +372 627 4135.
4.3 Account Closure
If you choose to close your Coolbet.co account, your personal data will be removed from any of our communication channels and we make sure that you will not be part of any further processing or profiling from that moment on within 72 hours.
We retain your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, based on legitimate interest, resolve disputes, maintain security, prevent fraud and abuse, enforce our Terms and Conditions, Privacy Policy or any other Services related policy and agreement, or fulfill your request to “unsubscribe” from further messages from us. We will retain de-personalized information after your account has been closed. The de-personalized information cannot be restored or decrypted. In addition we may keep data about you on the basis of legitimate interest or from the requirement by the law.
Personal data will be depersonalized after 5 years from the moment you closed your account or from the moment you became inactive. The data cannot be deleted as it is required for us to comply with the gaming act as well as the anti money laundering & counter terrorism financing act, where we have obligations related to customer due diligence, fraud prevention, legitimate interest and responsible gaming. Furthermore, the data cannot be deleted for operational reasons such as: sportsbook prediction game management, fraud detection & prevention, and customers segmentation/communication.
5. Other Important Information
5.1 Security
Coolbet.co implements security standards to safeguard and protect your data. We regularly monitor our systems for possible vulnerabilities and attacks, including an annual penetration testing, educating our employees by trained professionals and using all proportionate security measures for our network and infrastructure.
However, we cannot warrant the security of any information that you send us. There is no guarantee that data may not be accessed, disclosed, altered or destroyed by breach of any of our physical, technical or managerial safeguards.
5.2 Cross-Border Data Transfers
We only process your data within the European Union (EU) or European Economic Area (EEA) or when some data is transferred outside of the EU or EEA, we make sure the geographical area is acceptable by the European Union (EU), European Economic Area (EEA) standards and is officially under the Privacy Shield Framework.
5.3 Lawful Bases for Processing
We will only collect and process personal data about you where we have a lawful basis. Lawful basis includes consent (where you have given us consent), contract (where processing is necessary and required for the performance of a contract with you for the Coolbet.co services that you have requested or expect us to deliver to you) and based on the “legitimate interests”.
We may process your personal data for the purposes of our legitimate interests or for the legitimate interests of third parties (e.g. email or direct mail service provider), provided that such processing shall not outweigh your rights and freedoms. For example, we may process your personal data to:
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1. Protect you, us, or others from threats (such as security threats or fraud)
2. Comply with laws that apply to us
3. Enable or administer our business, such as for quality control, consolidated reporting, segmentation for product offering and customer service
4. Manage corporate transactions, such as mergers or acquisitions
5. Understand and improve our business or customer relationships in general
6. Personalize our offers and the experience you have on our site
Here is how we define the following:
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Legitimate Interest: This includes various internal routines which are essential for us to run our day to day operations and ensure compliance with our terms & conditions.
Legal requirement: In order to comply with our gaming license obligations set forth in the Estonian Gaming Act, and the Anti Money Laundering & Counter Terrorism Financing Act.
Contract: This includes the use of various 3rd party providers which are essential for us to provide you with our core services. This includes but is not limited to casino providers, customer support providers, service notifications.
Consent: We have identified activities which fall under a separate category and for these we will always ask for Your explicit consent, prior to processing. These are the following: direct mail, electronic email.
*All of the above mentioned categories may be updated on an ongoing basis.
Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object. If you have any questions about the lawful basis upon which we collect and use your personal data, please contact our Customer Support by writing an email to support@coolbet.co or to our Data Protection Officer via dataprotection@coolbet.co
5.4 Logs
Servers that host Coolbet.co website(s) and applications, may store logs or requests that you make to the server (the web address which you open, the browser that you use and device, IP address, timestamp). These kinds of logs and data will only be used for technical purposes – in order to ensure the behavior which meets the security standards and to investigate potential security incidents.
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Coolbet.co collects and stores this kinds of data only because Coolbet.co has the legitimate interest to make sure that the website is technically available and secure.
5.5 Contact Information
If you have questions or complaints regarding this Policy, please contact our DPO (Data Protection Officer) at dataprotection@coolbet.co or by writing to our customer support, support@coolbet.co
You can also reach us by physical mail at the following address:
Staycool OÜ
Paldiski maantee 29, 10612 Tallinn, Estonia.
(V.1.1 DATED 01 September , 2019)