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Privacy Policy

Effective Date: (13th January, 2025)

Shufflers.io ("Company," "we," "us," or "our") is committed to protecting and respecting your privacy. This Privacy Policy outlines how we collect, use, store, and protect your personal data when you use our website, tablet, or mobile applications (collectively, the "Platform") and our services or products (the "Services").

By accessing or using our Platform and Services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with any part of this policy, please discontinue your use of the Platform and Services immediately.

1. Scope of this Privacy Policy

This Privacy Policy applies to personal data that we collect from you when you use our Platform and Services, interact with us, or otherwise engage with us. It also covers personal data that we may receive from third parties.

2. Types of Personal Data We Collect

We may collect and process the following categories of personal data:

2.1. Information You Provide Directly

Identity Data: First name, last name, date of birth, and gender.
Contact Data: Email address, postal address, telephone number.
Account Data: Username, password, and other registration details.
Financial Data: Payment card details, bank account information.
Verification Documents: Copies of identification documents (e.g., passport, driver's license) for age and identity verification.
Communication Data: Records of your correspondence with us, including emails and chat logs.

2.2. Information Collected Automatically

Technical Data: IP address, browser type and version, time zone setting, operating system, and platform.
Usage Data: Information about how you use our Platform and Services, such as page views, clicks, and navigation paths.
Location Data: Geographical location based on your IP address.

2.3. Information from Third Parties

Third-Party Bookmakers & Casinos: Transaction details, betting history, and account information when you interact with Third-Party Bookmakers through our Platform.
Publicly Available Sources: Data from public records or social media platforms when you interact with us through those services.
Service Providers: Verification results from identity verification and anti-fraud service providers.

3. How We Collect Your Personal Data

We collect personal data using the following methods:

Direct Interactions: When you register an account, fill out forms, or communicate with us.
Automated Technologies: Through the use of cookies, server logs, and other similar technologies as you interact with our Platform.
Third-Party Sources: From Third-Party Bookmakers, service providers, and publicly available sources.

4. Purpose and Legal Basis for Processing

We process your personal data for the following purposes and under the following legal bases as permitted by the General Data Protection Regulation (GDPR) and the Data Protection Act 2018:

4.1. Providing Services

Purpose: To register you as a user, facilitate betting transactions, and provide our Services.
Legal Basis: Performance of a contract with you (Article 6(1)(b) GDPR).

4.2. Identity Verification and Security

Purpose: To verify your identity and age, prevent fraudulent activities, and ensure the security of our Platform.
Legal Basis: Compliance with legal obligations (Article 6(1)(c) GDPR) and legitimate interests (Article 6(1)(f) GDPR).

4.3. Customer Support

Purpose: To respond to your inquiries, complaints, and provide customer support.
Legal Basis: Performance of a contract with you (Article 6(1)(b) GDPR) and legitimate interests (Article 6(1)(f) GDPR).

4.4. Marketing Communications

Purpose: To send you promotional offers, updates, and newsletters.
Legal Basis: Your consent (Article 6(1)(a) GDPR) or legitimate interests (Article 6(1)(f) GDPR) where applicable.

4.5. Analytics and Improvement

Purpose: To analyze usage of our Platform, improve our Services, and develop new features.
Legal Basis: Legitimate interests (Article 6(1)(f) GDPR).

4.6. Legal Compliance

Purpose: To comply with legal and regulatory requirements, such as anti-money laundering laws.
Legal Basis: Compliance with legal obligations (Article 6(1)(c) GDPR).

4.7. Protecting Our Interests

Purpose: To enforce our Terms & Conditions, protect our rights, privacy, safety, or property, and that of our users.
Legal Basis: Legitimate interests (Article 6(1)(f) GDPR).

5. Cookies and Similar Technologies

We use cookies and similar technologies to enhance your experience on our Platform. For detailed information, please refer to our Cookie Policy.

5.1. Types of Cookies Used

Essential Cookies: Necessary for the functioning of the Platform.
Analytical/Performance Cookies: Allow us to recognize and count visitors and see how users move around the Platform.
Functionality Cookies: Used to recognize you when you return to our Platform.
Targeting Cookies: Record your visit to our Platform, pages visited, and links followed.

5.2. Consent

We obtain your explicit consent before placing non-essential cookies on your device.

You can manage your cookie preferences through our Platform settings or your browser settings.

6. Disclosure of Personal Data

We may share your personal data with the following parties:

6.1. Third-Party Bookmakers & Casinos

For the purpose of facilitating betting transactions and account management.

Note: Each Third-Party Bookmaker is a separate data controller, and their use of your data is governed by their privacy policies.

6.2. Service Providers

Companies that provide services on our behalf, such as payment processing, identity verification, IT support, and marketing services.

We ensure that these providers process your data securely and in accordance with applicable laws.

6.3. Legal and Regulatory Authorities

Law enforcement agencies, regulators, or other authorities if required by law or to protect our rights.

6.4. Business Transfers

In the event of a merger, acquisition, or sale of all or a portion of our assets, your personal data may be transferred to the successor organization.

7. International Data Transfers

Your personal data may be transferred to and processed in countries outside the European Economic Area (EEA) that have different data protection laws.

7.1. Adequacy Decisions

Transfers to countries that the European Commission has deemed to provide an adequate level of data protection.

7.2. Standard Contractual Clauses

For transfers to countries without an adequacy decision, we use Standard Contractual Clauses approved by the European Commission.

7.3. Additional Safeguards

We implement additional measures to ensure your data is protected, such as encryption and strict access controls.

8. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including:

Account Information: For the duration of your account's active status and as required by law.
Legal Obligations: To comply with regulatory requirements, such as anti-money laundering laws.
Dispute Resolution: As necessary to resolve disputes or enforce our agreements.

9. Your Rights

Under the GDPR, you have the following rights regarding your personal data:

9.1. Right to Access

Request confirmation of whether we process your personal data and access to the personal data we hold about you.

9.2. Right to Rectification

Request correction of inaccurate or incomplete personal data.

9.3. Right to Erasure

Request deletion of your personal data when it is no longer necessary, or if processing is unlawful.

9.4. Right to Restrict Processing

Request that we limit the processing of your personal data under certain circumstances.

9.5. Right to Data Portability

Receive your personal data in a structured, commonly used, and machine-readable format and transmit it to another controller.

9.6. Right to Object

Object to the processing of your personal data based on legitimate interests or for direct marketing purposes.

9.7. Right to Withdraw Consent

Withdraw your consent at any time when processing is based on your consent.

9.8. Right to Lodge a Complaint

Lodge a complaint with the Data Protection Commission (DPC) if you believe your rights have been violated.

To exercise your rights, please contact us as specified in Section 18.

10. Security Measures

We take the security of your personal data seriously and implement appropriate technical and organizational measures to protect it against unauthorized access, alteration, disclosure, or destruction.

10.1. Measures Implemented

Encryption: Data encryption in transit and at rest.
Access Controls: Strict access controls and authentication processes.
Regular Audits: Periodic security assessments and audits.
Staff Training: Employee training on data protection and security practices.

10.2. Your Responsibilities

Account Security: Keep your account credentials confidential and notify us immediately of any unauthorized use.
Secure Devices: Ensure that the devices you use to access our Platform are secure.

11. Third-Party Links

Our Platform may contain links to third-party websites or services not operated by us. This Privacy Policy does not apply to those third-party sites.

11.1. Responsibility

We are not responsible for the privacy practices of third-party websites.

We recommend reviewing the privacy policies of any third-party sites you visit.

12. Children's Privacy

Our Services are not intended for individuals under the age of 21

12.1. Age Restriction

We do not knowingly collect personal data from individuals under 21.

If we become aware that we have collected personal data from someone under 21, we will take steps to delete such information.

13. International Users

If you are accessing our Platform from outside Ireland, please be aware that your personal data may be transferred to, stored, and processed in Ireland and other countries.

14. Automated Decision-Making and Profiling

We may use automated decision-making processes, including profiling, for purposes such as fraud prevention and compliance with legal obligations.

14.1. Your Rights

You have the right not to be subject to decisions based solely on automated processing that significantly affect you.

You may request human intervention or express your point of view by contacting us as specified in Section 18.

15. Marketing Communications

15.1. Consent

We will obtain your explicit consent before sending you marketing communications.

You can choose your marketing preferences during registration or by adjusting your account settings.

15.2. Opting Out

You may opt out of marketing communications at any time by:

Clicking the "unsubscribe" link in promotional emails.
Adjusting your account settings.
Contacting us as specified in Section 18.

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal obligations.

16.1. Notification of Changes

We will notify you of significant changes by posting a notice on our Platform or contacting you directly via email.

16.2. Effective Date

The effective date of the current Privacy Policy is stated at the top of this document.

17. Data Protection Commission

If you believe that we have infringed your data protection rights, you have the right to lodge a complaint with the Data Protection Commission (DPC).

18. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or your personal data, including requests to exercise your rights under GDPR or to contact our Data Protection Officer (DPO), please use our contact form.

19. Conclusion

Your privacy is important to us, and we are committed to safeguarding your personal data. We encourage you to review this Privacy Policy regularly to stay informed about how we are protecting your information.

By continuing to use our Platform and Services, you acknowledge that you have read and understood this Privacy Policy and agree to its terms.

Please note: This Privacy Policy should be read in conjunction with our Terms & Conditions and Cookie Policy.

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