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Introduction

This Privacy Policy, which was last updated on 24/05/2018, sets out the data processing practices carried out by LunaCasino.

Here at LunaCasino we like making things simple and easy for our customers and that includes being clear, transparent and open about what we collect, and how and why we use the data we collect, so this page goes into great detail.

Our Policy explains how we use your personal data, whether you are just visiting, making a deposit or playing one of our games. This policy includes information you may not already know about your data privacy rights, circumstances in which we share and obtain information about you and how we use it to personalize the marketing you receive, so please take time to read all the sections carefully.

If we make any material updates to this Policy, we will inform you.

Please note that all our employees undertake regular training on Information Security and are required to comply with internal policies and procedures whenever they handle your information.

We hope you will find this page helpful, but should you have any concerns or questions, regarding Data Protection, please feel free to contact our Data Protection Officer at dpo@lunacasino.com

Our Privacy Policy Promise

LunaCasino will always value and respect the privacy of each and every one of its customers, which we safeguard through our Privacy Policy. LunaCasino acknowledges the fact that your personal information is your personal information. Your privacy is important both to you and to us and we make the following promise to you:

LunaCasino is committed to protecting your privacy. We believe in using your personal information to make things simpler and better for you. We will always keep your personal information safe. We’ll be clear and open with you about why we collect your personal information and how we use it. Where you have choices or rights, we’ll explain them to you and respect your wishes.

The Types of Information We Collect

We collect two types of data and information from our customers.

“Personal Information”
Personal Information which can be used to identify an individual. The Personal information we collect through our Services includes information which is submitted directly by the you, such as: phone number; full name; e-mail address; home address; date of birth; payment means (e.g. credit card number); and other financial information that we may need in order to provide our Services. We also collect Personal Information from your device (e.g. geolocation data, IP address) and information on your activity on the Services (e.g. pages viewed, online browsing, clicks, actions, etc.).

“Non-personal Information”
The second type of information is un-identified and non-identifiable information pertaining to you which may be made available or gathered via your use of the Services We are not aware of the identity of the user from which the Non-personal Information was collected. Non-personal Information which is being collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time and the domain name of the website from which you linked to the Services; etc.), in order to enhance the functionality of our Services.

If we combine Personal Information with Non-personal Information, the combined information will be treated as Personal Information for as long as it remains combined.

How We Collect Your Information

Collecting Information about you, from you

LunaCasino collects personal information about you whenever you use our services. Some of it you provide directly to us, for example, when you register an account or fund your account. Other information is collected during your interactions with us, such as the bets you place or online chats with our customer services team and through Cookies (Please refer to the dedicated section about Cookie’s for more information on our usage of cookies) Also, if you consent we will also record the telephone calls you make to us. We also collect information about the way you access, view, share, contribute to and communicate with and through our services, for example when you post comments via our social media channels or chat functionalities.

Collecting Information about you, from your device

We collect information from the devices you use when using LunaCasino content, products and services. This includes but is not limited to the following: your IP address (a number that identifies a specific device on the internet and is required for your device to communicate with websites), hardware model, operating system and version number.

Collecting Information about you, from Cookies

We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns and does not identify any individual.

For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on your browser or the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. They help us to improve our site and to deliver a better and more personalised service. Some of the cookies we use are essential for the site to operate. The cookies we use can be grouped into four separate categories and are explained in the section further below set out for Cookies.

Collecting Information about you, from external companies

To help us comply with our legal and regulatory KYC obligations, when you open your account we may cross reference the information you supplied to us with a company called Experian who will reply to us regarding the accuracy of the details provided. We log and save the result they send us. When a customer from Denmark opens an account and on every subsequent login we use the CPR number provided to check certain information (age and status with regards to registration on ROFUS) and we also log and save the result sent to us.

When a customer from the UK opens an account, and on every subsequent login, we consult with GamStop to obtain information from them as to whether we need to restrict access to our services. We log and save the result sent to us.

We use publicly available information (on social media sites and the like) to help verify information provided to us and we log and save the results.

How do we use the information we collect?

We use and share Personal Information in the manners described in this Privacy Policy. The Personal Information will be disclosed to a third party only to the extent required for the specific purpose, as stipulated in this Privacy Policy, and in such cases, we require the relevant third party to agree to process such information in compliance with our Privacy Policy.

The information we collect, which may include “Personal Information”, is used for the following purposes:

• To set up your account and to provide our Services (e.g. send out cash-out checks, process your payments; etc.)
• To identify and authenticate your access to certain features
• To communicate with you and to keep you informed of our latest updates;
• To market our website and products or those of any of our business partners and affiliates.
• To serve you advertisements
• To perform a research or to conduct anonymous analytics in order to improve and customize our Services to your needs and interests;
• To support and troubleshoot our Services and to respond to your queries; and
• To investigate violations and enforce our policies, as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process or respond to a government request.
• To audit certain elements of our business practices

Companies that provide services on our behalf

We share your personal information with external organizations that carry out a range of services on behalf of LunaCasino. We carry out checks to ensure that the companies we work with will give your information the same level of care and protection as we do. Both we and they are obliged to handle your information in accordance with data protection law, and we are also required to put in place contractual measures reinforcing those obligations.

The main functions that are or may be carried out, fully or in part, by third parties are listed below:

• Management and execution of marketing campaigns
• Payment processing and verification
• Anti-fraud and -money laundering checks and ID verification
• Checks to detect unfair use of our products and services
• Web hosting, online content services and data storage
• Management of competitions, contests and offers
• Data analytics and data cleansing
• Market research and collecting or analysing customer feedback
• IT services and support
• Audit-, Legal- & Compliance- related services
• Storing data for regulators to access and view

Sharing information with Experian

If you are not happy for us to pass your Personal Information to Experian, you will not be able to open an account and use our pay-to-play products and services.

For ID verification of our UK and Denmark customers we use tools and services provided by Experian. The data will be passed to Experian, and a search is made using their products to check the validity of the information provided to us. Due to this we are obliged to tell you that:

• i. Experian may check the details customer supplied, against any particulars on any database (public or otherwise) to which Experian has access in order to carry out the relevant verification service,
• ii. A specific (non-credit) footprint is left by Experian, and
• iii. A record of the decision made is available for us to retrieve for auditory purposes.

Sharing information with Licencing Regulators

We need to comply with a range of licencing and regulatory requirements, some of which involve the use of personal and non-personal information.

SAFE (electronic storage service):

In Schleswig-Holstein (utilising your Personal and Non-Personal Information) and Denmark (utilising non-Personal Information) we send your data to a third party controlled ‘SAFE’ where the relevant regulator has full viewable access to it.

Information demands from Regulators:

On a regular basis, in all licensed jurisdictions, we are regulatory required to produce reports containing non-Personal Data. The reports consists of things such as number of self exclusions, number of registrations, number of complaints, number of suspicious transactions reported to authorities.

How long do we keep your information?

We hold your personal information only as long as we have a valid legal reason to do so, which includes providing you with the services you have requested, meeting our legal and regulatory obligations, resolving disputes and enforcing our agreements.

The length of time for which we keep different types of personal information can vary, depending on why we originally obtained them, the reason we process them and the legal requirements that apply to them. When setting our data retention and deletion timescales we take into account a range of factors including applicable regulations and standards relating to gambling and gaming, anti-money laundering, taxation, payment processing and complaint handling, the need to prevent or detect crime or other misuse of our services, and audit requirements. To fulfil our requirements, some of your personal data will need to be retained for a period of time after you cease to be a customer. When we no longer need it to fulfil the above requirements, we delete it securely or anonymize it.

Your Rights

Your Data Subject Rights

You have the following rights in terms of your personal data we hold about you:

• The right to be informed. Transparency in how we are using personal data. Hence, this detailed Privacy Policy.
• The right of access. This enables you to e.g. receive a copy of the personal data we hold about you.
• The right to rectification. Correction/Rectification of the personal data we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected/rectified.
• The right to erasure. This enables you to ask us to erase your personal data [known as the ‘right to be forgotten’] where there is no good reason for us continuing to process it.
• The right to data portability. This gives you the right to receive personal data they have provided to a controller in a structured, commonly used and machine-readable format. It also gives you the right to request that a controller transmits this data directly to another controller.
• The right to restrict processing. This enables you to ask us to restrict the processing of your personal data, i.e. use it only for certain things, if:
  
  • it is not accurate,
  • it has been used unlawfully but you do not wish for us to delete it,
  • it is not relevant any more, but you want us to keep it for use in possible legal claims,
  • You have already asked us to stop using your personal data, but you are waiting us to confirm if we have legitimate grounds to use your data.
• The right to object. This gives you the right to object to the processing of your personal data. For example, if you object to receiving marketing material you can remove consent for us to send it. The right to object only applies in certain circumstances. Whether it applies depends on your purposes for processing and the lawful basis for processing. Individuals have the absolute right to object to the processing of their personal data if it is for direct marketing purposes. Individuals can also object if the processing is for:
  
  • a task carried out in the public interest;
  • the exercise of official authority vested in you; or
  • your legitimate interests (or those of a third party);
  • in relation to automated decision making and profiling.

If you believe your privacy rights have been infringed, or you disagree with a decision we have made about your privacy rights, you have the right to complain to the relevant supervisory authority.

Cookie Section

What are Cookies?

'Cookies' are small text files stored in your web browser that enable us to recognize your computer when you visit our website. Cookies are essential to keep certain parts of our website functioning correctly and securely. We also use them to make things quicker, easier and more personal to you and to help us understand how our website is used. They can also be used to present you with more tailored advertising content.

To do all these things, cookies collect some personal information about you whenever you use our website. You can choose whether to accept or reject some or all types of cookies and control this through your device’s browser settings. We will make you aware of this by showing you our cookie banner when you visit our site. If you then continue to use our website without adjusting your browser settings, we will use cookies as set out in the sections below, so to help you make an informed choice it’s important to know why we use the different types of cookie and what that means for your online experience. This section provides you with a summary of the main points and tells you how switching off the different types of cookie will affect your experience on our website.

They also enable LunaCasino to find out which advertisement brought you to our website, we may use the LunaCasino cookies on your computer. In the event that we do collect such information, you will remain personally unidentifiable and we will not share this information with any unconnected third-party.

The Cookie Categories

The Cookies we use fall into the following categories:

• Strictly Necessary
  This type of cookie allows you to navigate the website and use essential features like secure areas and online registration. These cookies don’t gather any information about you that could be used for marketing or remembering where you’ve been on the internet. These cookies are essential in our being able to guarantee the performance of our website, should you disable them we won’t be able to ensure your security or predict how our website will perform during your visit.
• Performance
  This type of cookie collects information about how you use our website e.g. which pages you visit, and if you experience any errors. The information collected is anonymous and is only used to help us improve how our website works, gauge what interests our users and assess the effectiveness of advertising.
• Functionality
  This type of cookie remembers your preferences for tools found on our website, so you don’t have to re-set them each time you visit. Some of them are managed by third parties. They may for instance determine whether you see the latest or oldest comments made in relation to an article first. They may also help us greet you by name or remember your choice of language or region).
• Targeting/Tracking
  These cookies are used to analyse what advertising might be most relevant to a user of the website based on the areas of the website that the user visits.

Controlling my Cookies

All modern browsers allow you to see what cookies you have, and to clear them individually or in their entirety by changing your cookie settings. Cookie settings are typically found in the 'options' or 'preferences' menu of your browser, otherwise you should use the 'Help' option in your browser for more details. You may also find the links below helpful:

• Cookie settings in Chrome
• Cookie settings in Firefox
• Cookie settings in Internet Explorer
• Cookie settings in Safari

You can block cookies by activating the settings on your browser which allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be to access all or parts of our site. We endeavour to make all parts of our site accessible to everyone but if you block some cookies, particularly Strictly Necessary cookies, your access might be impaired. Unless you have adjusted your browser settings so that it will refuse cookies, our system will issue cookies as soon you visit our site.

Your first visit to our site will generate a pop-up header alerting you to this privacy policy and will re-appear only in the event that you change your cookie settings from time to time.

The Use of Google Analytics

We use Google Analytics for ‘analytical’ purposes such as to keep track of user/customer browsing patterns and to build up a profile for a customised browser experience for you. Google Analytics is a popular web analytics service provided by Google, Inc. Google Analytics uses cookies to help us to analyse how customers use our Website.

Your opt-out choice is applied only to the browser from which you make the choice, so if you use different browsers you will need to opt out in each one. This opt-out is cookie based, so if you delete your cookies, you will no longer be opted out and will need to opt out again. Google Analytics, from which you can control through your browser settings: opt out. https://tools.google.com/dlpage/gaoptout

Marketing

We may use your Personal Information, such as your name, email address, telephone number, etc. ourselves or by using our third-party subcontractors for the purpose of providing you with promotional materials, concerning our Services as well, products, services website and applications which related to:

• (i) our business partners’ and affiliates’; (collectively Marketing Affiliates) which we believe may interest you.
  
  We may also share and disclose Personal Information with our Marketing, Affiliates for the purpose of providing you different marketing offers we or our Marketing Affiliates believe are relevant for you. Our Marketing Affiliates may use this Personal Information for different marketing techniques, such as direct email, SMS and telephone marketing purposes.
  
  Out of respect to your right to privacy we provide you within such marketing materials, and from within our casino software, with means to decline receiving further marketing offers from us or from our Marketing Affiliates.

Security

LunaCasino goes to great lengths to guarantee that your personal and financial information remains 100% secure and confidential. We employ industry standard security protocols (128-bit, SSL data encryption technology) to ensure that all transactions including deposits and withdrawals are carried out in a totally secure manner. This technology protects you from having your information intercepted by anyone other than LunaCasino while it is being transmitted between you and LunaCasino.

Limits of Confidentiality

For legal reasons, LunaCasino may be required under certain circumstances to disclose your personal information. Reasons for this may include:

1. to protect and defend our rights or property;
2. to comply with any legal process served on us. In addition, we reserve the right to disclose your personal information, including player identification, name, physical address, billing address, e-mail and/or phone number, to third parties as we believe necessary or appropriate in connection with any investigation of fraud, intellectual property infringement, piracy or any other unlawful or prohibited activity that might expose us to legal liability.