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Version: 1.0

Last modified: May 09, 2021

1. KNOW YOUR CUSTOMER (KYC) POLICY

1.1. KYC – Know Your Customer

A Know Your Customer (“KYC”) process is a process of identity verification by which we make sure that you are who you say you are – and not someone pretending to be you. This policy tells you how we perform KYC checks when you use our website (https://spin.city/) including any mobile or a device-specific version of the website and any related applications (“Website”).

1.2. Why we ask you to verify your identity

As a regulated company, we are required by law and license conditions to verify our customers. This is necessary to ensure that our services are not misused. KYC helps us in protecting our business from money laundering, terrorism financing, and other illegal activities. Identify verification makes your account on the Website (“Member Account”) safer.

If we need you to verify your identity, we will ask for you to provide personal identification documents. A verification request will be communicated to you via a notification on the Website and/or by email.

1.3. Documents we require from you

The identification documents we request from you may vary on the basis of the payment method. We typically ask for documents, such as but not limited to:

Proof of identity: a copy of a valid ID document (passport or national identity card) and a selfie of you holding an ID document;

Proof of payment method (a bank or card statement, a photo of the credit/debit card, etc.).

You will find the exact documents you need to provide in the verification request.

1.4. Photo requirements of your documents

Please make sure your documents are in acceptable condition:

A clearly legible photo of an original document;

Your personal data must match the details on your Member Account;

All corners of the document must be visible;

Screenshots, scanned copies, and black and white photocopies are not acceptable.

1.5. How to submit documents

If we have requested documents from you, we will have sent a link to you on your Member Account and to your email address. Clicking that link will allow you to upload images/photos of your documents.

Please do not email us with your documents.

1.6. Verification failed/completed or more information required

Once all documents are uploaded, they are waiting until we review them.

Your satisfaction is our first priority so we review your documents as soon as possible. The following outcomes are possible:

Verification completed: all documents are successfully verified;

Verification failed or more information required: some of the documents you have sent us do not meet our requirements, and another document or more information is needed.

Please note that your withdrawal transaction will not be processed until your identity is fully verified. We reserve the right to block access to or close your Member Account until verification has been completed.

1.7. How to check your verification status

You are always able to check the status of your verification process on your Member Account. Changes in the status of your verification process will be also communicated to you via a notification on the Website and/or by email.


2. PRIVACY & MANAGEMENT OF PERSONAL DATA (“PRIVACY NOTICE”)

We respect your privacy and are committed to protecting your Personal Data when you use the Website.

For the ease of your orientation, these are the contents of this Privacy Notice:

Our contact details

Our role in the processing of Personal Data

How we collect your Personal Data

How we use your Personal Data

When we share your Personal Data with others

How we transfer Personal Data outside the United Kingdom and European Economic Area

Your data protection rights

How to complain

How we secure your Personal Data

How we store your Personal Data

Cookies

What happens when you visit other websites?

Modifications to this Privacy Notice

Definitions and legal references

2.1. Our contact details

Name: Faro Entertainment N.V. Any references in this document to “we”, “us” or “our” are references to Faro Entertainment N.V. only.

Address: Kaya Richard J. Beaujon Z/N, Curacao, P.O. Box 6248

E-mail: [email protected]

EU Representative:

Name: Faro Entertainment Europe Limited

Address: 35, Room 1A, Salvu Psaila Street Birkirkara BKR 9072 Malta

2.2. Our role in the processing of Personal Data

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When we process your Personal Data, we act as a Data Controller of Personal Data. We are committed to processing your Personal Data as described in this Privacy Notice.

2.3. How we collect your Personal Data

Personal Data you give to us:

Account data: Information that you provide by creating a Member Account (for example, full name, date of birth, home address, phone number, email address, password).

ID Documents: Copy of a government-issued ID, bank statement, utility bill, or another document uploaded by you.

Contact data: When you create an account or otherwise contact us, you provide us with an email address, telephone number, and content of the communication. Please note that we retain a history of communication with you.

Payment data: While providing Services, we collect your payment details or other documents confirming payments.

Additional information collected:

Gaming data: When you use our Services, we record information related to your accounts such as your balances, bets, bonuses, and winnings.

Login data: We may collect data about your computer, including IP address, OS, information about your browser, etc.

Usage data: We may collect information about how you use the Website, pages visited, time spent, links clicked, features used, etc.

What happens if you don’t give us your data

You are under no obligation to provide us with your Personal Data. However, some Personal Data is necessary so that we can supply you with the Services you have purchased or requested, and authenticate you so that we know it is you and not someone else. For example, if you do not provide us with your email address, we will not be able to create an account for you.

2.4. How we use your Personal Data

We use your Personal Data for the following purposes:

Providing Services

This includes using Personal Data in order to:

Create and manage your Member Account;

Provide access to Services;

Process and manage payment transactions.

We rely on the fulfillment of a contract and legitimate interests (for example, ensuring account functionality, processing of payments) as the lawful basis for the processing of your Personal Data.

Customer support

We process Personal Data to support you, including to:

Answer any issue that has arisen, respond to any of your comments;

Improve our support processes.

We rely on a legitimate interest basis (for example, to solve issues and any problems) for collecting, storing, and processing this information.

Responsible gambling

As responsible gambling operator, we need to process personal information to ensure you gamble responsibly.

We use the data described above as necessary to comply with our legal obligations and as necessary for our (or others’) legitimate interests.

Legal and regulatory obligations

We use personal data as required by license conditions and relevant legislation. This includes:

Identifying and verifying customers;

Prevention, detection, and investigation of crimes or other illegal activities;

Minimization of the risk of fraud.

We process such kind of personal information to comply with our legal obligations. When this information is processed for protecting our business from illegal activity, we rely on legitimate interest.

Safety and security

We use Personal Data to help maintain the safety, security, and integrity of the Website. This includes:

Ensuring confidentiality, integrity, and availability of the Website;

Preventing unauthorized access to our information systems;

Ensuring our Website functions correctly and identifying any technical issues.

We have a legitimate interest in maintaining personal information for safety and security purposes. We also use your data for compliance with legal obligations.

Marketing

We may use the data we collect to market our Services, in particular to:

Notify you of news and updates related to our business;

Carry out promotions (bonuses, loyalty programs, VIP management).

We have a legitimate interest in processing Personal Data for marketing purposes.

Improvement

We may use the data we collect for testing, research, analysis, development, and improving user experience.

We have a legitimate interest in understanding how you use the Website.

2.5. When we share your Personal Data with others

Service providers and business partners:

Web hosting providers: To store and transfer our content and data;

Providers of games: To provide you with access to high-quality virtual slot machines; 

Payment service providers: To process payment transactions;

Marketing partners: To send service and marketing messages;

Consultants, lawyers, accountants, and other professional service providers: To receive professional advice from them.

Other disclosures

In addition to the disclosures for the purposes identified above, we may disclose your Personal Data to third parties:

To comply with legal obligations and respond to requests from government agencies;

To address disputes, claims, or to establish, exercise, and protect our rights.

2.6. How we transfer Personal Data outside the United Kingdom and European Economic Area

Information we collect about you could be processed in countries outside the United Kingdom and/or European Economic Area. We rely on the following methods for transfers of Personal Data outside the United Kingdom and/or European Economic Area:

Adequacy: We may transfer Personal Data to a third country when such a third country has received a finding of “adequacy” from the relevant regulator(s);

Appropriate safeguards: We are providing appropriate safeguards by entering binding, standard data protection clauses adopted by the relevant regulator(s) and enforceable by data subjects in the United Kingdom and/or European Economic Area;

Derogations: Depending on the circumstance, we also collect and transfer Personal Data based on certain derogations such as explicit consent of the data subject, performance of a contract involving the data subject, important public interest reasons, establishment, exercise, or defense of legal claims.

2.7. Your data protection rights

If you live in the United Kingdom or European Economic Area, you have certain data protection rights. You can learn more about these rights below:

Right of access: You have the right to ask us for copies of your Personal Data;

Right to rectification: You have the right to ask us to rectify Personal Data you think is inaccurate. You also have the right to ask us to complete Personal Data you think is incomplete;

Right to erasure (right to “be forgotten”): You have the right to have all of your Personal Data erased when you stop using the Services and close your account;

Right to restriction of processing: You have the right to ask us to restrict the processing of your Personal Data in certain circumstances;

Right to object to processing: You have the right to object to the processing of your Personal Data in certain circumstances;

Right to data portability: You have the right to ask that we transfer the Personal Data you gave us to another organization, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you. Please contact our customer support manager if you wish to make a request.

You can also exercise your rights by contacting us at [email protected]

2.8. How to complain

In many countries, you have a right to lodge a complaint with the appropriate data protection authority if you are unhappy with how we process your Personal Data.

If you have questions, concerns, or complaints, please try to contact us at [email protected]

2.9. How we secure your Personal Data

To help protect the privacy of Personal Data, we maintain physical, technical, and administrative safeguards. We update and test our security technology on an ongoing basis. We restrict access to your Personal Data to those employees and vendors who need to know that information to provide Services to you.

2.10. How we store your Personal Data

We will not keep your Personal Data for longer than required. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the Personal Data, the purposes for which we process your Personal Data, and what the law requires us to do.

2.11. Cookies

We may collect data about your computer, including IP address, OS, and type of browser you use. It helps us with system administration and reporting aggregate data to our advertisers. 

You can set your browser not to accept cookies. Nonetheless, in different cases, some of the features on our Website may not function as a result.

2.12. What happens when you visit other websites?

The Website may contain links to other websites. Please note, if you follow a link to any of these websites, it is advisable to keep in mind that these websites have their own privacy notices or privacy policies. This Privacy Notice does not cover how those organizations process Personal Data. Consequently, we do not accept any responsibility or liability for these policies.

2.13. Modifications to this Privacy Notice

We keep our Privacy Notice under regular review to make sure it is up to date and accurate. We recommend that you revisit and read this Privacy Notice regularly to ensure that you are up-to-date with the current terms.

2.14. Definitions and legal references

Data Controller means the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.

Data Processor means the natural or legal person, public authority, agency, or other body which processes Personal Data on behalf of the Data Controller and according to its instructions.

European Economic Area consists of the member states of the European Union and three additional countries, namely Iceland, Liechtenstein, and Norway.

Personal Data means any information that directly, indirectly, or in connection with other information allows for the identification of a natural person.