Background Circle Background Circle

Overview

Trustx Gaming, a subsidiary of Trustx Gaming (Nasdaq: GAMB) (“GAMB”), is the owner of the websites operated by and on behalf of the Group.

The terms “Trustx Gaming”, “we”, “us”, or “our” refer collectively to GAMB, and its current and future subsidiaries (“Group Members”).

Trustx Gaming Media Limited has licensed the operation of certain Trustx Gaming’s websites in certain geographic locations to other Group Members, including:

(a) all Trustx Gaming websites operating in the United States to Trustx Gaming America Inc., a GAMB subsidiary;

(b) certain Trustx Gaming websites operating in the area of the United States to Roto Sports, Inc., a GAMB subsidiary, under a sub-license from Trustx Gaming America; and

(c) certain Trustx Gaming websites operating worldwide (excluding the United States), to NDC Media Limited, a GAMB subsidiary.

This Privacy and Cookies Policy (“Policy”) describes the practices of Trustx Gaming Media Limited, including the Group Members involved in the operation of the Trustx Gaming’s websites in different geographic locations and the rights and choices available to individuals regarding personal data.

Purpose Of This Policy

Trustx Gaming respects your privacy and is committed to protecting your personal data. Personal data means any information that relates to an identifiable individual. It does not include data where the ability to identify an individual has been removed (anonymous data).

This Policy describes the rights and choices regarding your personal data. It is important that you read the Policy carefully. If you have any questions about this Policy, including any requests to exercise your legal rights, please contact us using the details set out below.

We may alter this Policy as needed for certain services of Trustx Gaming and to abide by local laws or regulations around the world, such as by providing supplemental information in certain countries. This Privacy Notice does not apply to Trustx Gaming’s processing of the personal data of its personnel, such as employees and contractors.

We also provide important additional information in paragraph 8 that is solely applicable to individuals located within the Member States of the European Union, countries in the European Economic Area, the United Kingdom, and Switzerland (collectively, “Europe” or “European”) and for individuals located in the State of California, United States:

  • European users should read the important information provided below about transfer of personal data outside of Europe.
  • California residents should read the important information provided below regarding our handling of the personal data.

Our websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect, use or otherwise handle data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave any of our websites, we encourage you to read the privacy policy of every website you visit.

The Personal Data We Collect

We collect personal data about individuals from various sources described below. Where applicable, we indicate whether and why individuals must provide us with personal data, as well as the consequences of failing to do so. We may collect, use, store and transfer different kinds of personal data about you (“Personal Data”) which we have grouped as follows:

Personal Information” includes any information from which you can be personally identified, including your name, surname, email address, telephone number or mobile number.

Profile Data” includes a username, password and a profile image that an individual may establish and upload on one of our websites or mobile applications, along with any other information that an individual enters into their account profile;

Financial account data” includes payment card details or bank account details;

Recruitment Process Data” includes the CV and any covering letter of a job applicant and notes taken for the duration of your recruitment process relating to a job application and interview of a job applicant; Other information supplied by a job applicant, such as professional credentials and skills, educational and work history, and other information of the type included on a CV or covering letter;

Technical Data” includes internet protocol (IP) address, browser type and version, time zone setting and location, operating system and platform, and other technology on the devices you use to access our websites;

Usage Data” includes information about how you use our websites.

We also may collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.

We do not collect any information about your race, ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data. However, if you are applying for a job with us, we will collect information about criminal convictions and offences.

We automatically collect Technical Data and Usage Data. If you are using a mobile device, we collect data that identifies your mobile device, device-specific settings and characteristics, app crashes and other system activity.

Collection Of Personal Data

We may use different methods to collect data from and about you including the following:

  1. Via direct interactions. You may give us your Personal Information and Recruitment Process Data by: a) filling in any a job application form on our Career Page b) providing an email address to register with our websites and/or receive our newsletter, or c) providing your contact details via our registration and/or newsletters form.
  2. Automated technologies. As you interact with our websites, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this data by using cookies, server logs and other similar technologies.
  3. Third parties or publicly available sources. We may partner with third parties (such as content providers and analytics companies including Google Analytics, OptInMonster, Hotjar, and Convert.com) to help us improve the services of our website, including to provide you with relevant and interesting content and to conduct analytics and measurement to understand how our services are used. These companies may collect information from you automatically in connection with your visit.

Generally, our websites can be accessed and used without registration and without having to provide us any Personal Data (Personal Information, Profile Data, and/or Recruitment Process Data). You may opt in to receive information about promotions, bonuses, bets, tips and strategy by subscribing to our mailing list by providing your email address. You may any time opt out from receiving such communications by writing to us or clicking the “unsubscribe” button in any of our emails to you. In case you contact us, whether by email, through contact forms, or in other writings, we may keep a copy of that correspondence. We will not share your Personal Data with third parties for marketing purposes unless you have provided us with your express consent to do so.

Use Of Personal Data

We may use your Personal Data for the purposes of:

Providing our services, which may include:

  • Operating, evaluating, maintaining, improving, and providing the features and functionality of our services;
  • Fulfilling a payment transaction initiated by you;
  • Communicating with you regarding your account with us, if you have one, including by sending you service-related emails or messages (e.g., messages regarding account verification, changes or updates to the functionality of our services, technical and security notices and alerts, and support messages)
  • Personalizing the manner in which we provide our services;
  • Administering and protecting our business; and
  • Providing support and maintenance for our services, including responding to your service-related requests, questions, and feedback.

For research and development

We use the information we collect for our own research and development purposes, which include:

  • Developing or improving our services; and
  • Developing and creating analytics and related reporting.

Marketing

We may use your Personal Data to form a view on what services we think you may want or need or what may be of interest to you.

We may contact you with marketing communications using the Personal Data you have provided to us if you have actively expressed your interest in availing of our services or have availed of our services and, in any case, you have not opted out of receiving that marketing, to the extent permitted by applicable law.

You can ask us to stop sending you marketing messages at any time by contacting us using the details below or clicking on the opt-out link included in each marketing message.

Should you choose to opt out of receiving our marketing messages, we will continue to conduct our other relevant activities using your Personal Data, including sending non-marketing messages.

Managing our recruiting and processing employment applications

We process Personal Data, such as information submitted to us in a job application, to facilitate our recruitment activities and process employment applications, such as by evaluating a job candidate for an employment activity, and monitoring recruitment statistics.

Complying with law

We use your Personal Data as we believe necessary and appropriate to comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.

Compliance, fraud prevention and safety

We use your Personal Data as we believe necessary or appropriate to (a) enforce the terms and conditions that govern our services; (b) protect our rights, privacy, safety or property, and/or that of you or others; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

With your consent

In some jurisdictions, applicable law may require us to request your consent to use your Personal Data in certain contexts, such as when we would like to send you certain marketing messages. If we request your consent to use your Personal Data, you have the right to withdraw your consent any time in the manner indicated when we requested the consent or by contacting us. If you have consented to receive marketing communications from our third-party partners, you may withdraw your consent by contacting those partners directly.

To create anonymous data

We may create anonymous data from your Personal Data and other individuals whose Personal Data we collect. We make Personal Data into anonymous data by excluding information that makes the data personally identifiable to you and use that anonymous data for our lawful business purposes.

To Whom Do We Provide Personal Data

We may have to share your data to the following parties:

Group Members

We may disclose your Personal Data to other Group Members for purposes consistent with this Policy.

Service providers

We may employ third parties to administer and provide services on our behalf (such as third parties that provide customer support, third parties that we engage to host, manage, maintain, and develop our websites, mobile applications, and IT systems, and third parties that help us process payments). These third parties may use your information only as directed by us and in a manner consistent with this Policy. These third parties are prohibited from using or disclosing your information for any other purpose.

Participants in the transaction processing chain

We may share your Personal Data with companies in the transaction processing chain in connection with processing a payment transaction, such as merchants, banks or other card issuers, card associations, debit network operators and their members.

Professional advisors

We may disclose your Personal Data to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary, in the course of the professional services that they render to us.

Compliance with Laws and Law Enforcement; Protection and Safety

Trustx Gaming may disclose information about you to government or law enforcement officials or private parties as required by law, and disclose and use such information as we believe necessary or appropriate to (a) comply with applicable laws and lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; (b) enforce the terms and conditions that govern our services; (c) protect our rights, privacy, safety or property, and/or that of you or others; and (d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

Data Security And Data Retention

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. In addition, we limit access to your Personal Data to those employees, agents, contractors, subsidiaries, affiliates and other third parties who have a business need to know. They will only process your Personal Data on our instructions, and they are subject to a duty of confidentiality. We have put in place commercially reasonable procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We will process and store the relevant Personal Data for as long as it is necessary or required in order to fulfil our legal, contractual, or statutory obligations and/or for the establishment, exercise or defence of legal claims.

Your Rights And Choices

In this section, we describe the rights and choices available to all users. Users who are located in Europe may read additional information about their rights in paragraph 8 below.

Marketing communications

You can ask us to stop sending you marketing messages at any time by contacting us or clicking on the opt-out link included in each marketing message. You may continue to receive service-related and other non-marketing messages.

Choosing not to provide your Personal Data

Where we request Personal Data directly from you, you do not have to provide it to us. If you decide not to provide the requested information, in some circumstances we may be unable to provide services to you. For example, we may be unable to process your transaction.

Accessing, modifying or deleting your information

In some jurisdictions, applicable law may provide a right for individuals to access, modify, or delete their Personal Data in some. You may contact Trustx Gaming directly to request access to, modify or delete your information. We may not be able to provide access to, modify, or delete your information in all circumstances.

Complaints

If you have a complaint about our handling of your Personal Data, you may contact our data protection officer using the contact information below. We request that a complaint be made in writing. Please provide details about your concern or complaint so that we can investigate it. We will determine whether to take action in response to your complaint, which, if we do so, may include conducting internal discussions with relevant business representatives. We may contact you for additional details or clarification about your concern or complaint. We will contact you to inform you of our response to your complaint. You also may have a right to file a complaint with a national or local regulatory agency.