1. Introduction
1.1. Raw Entertainment B.V (together with Roobet Group hereafter the “Company”, “we,” “our“), is responsible as ‘controller’ for the protection of privacy and the safeguarding of the partners’ or customers’ personal and financial information pursuant the General Data Protection Regulation (“GDPR”). By executing the registration form and opening an affiliate account with us, you (hereinafter referred to as the “Affiliate”, “you” or ”your”) hereby gives its consent to such collection, processing, storage and use of personal information by the Company as explained below in the policy (the “Policy”).
1.2. This Policy is the property of the Company. The reproduction in whole or in part in any way including the reproduction in summary form, the reissue in a different manner and any changes in the original manual or any translated version is strictly forbidden and is only allowed with the prior written consent of the Company.
1.3. This Policy may be changed from time to time and it is important that you check this Policy for any updates. If the changes effected are considered to be important, we will communicate them to you.
1.4. Please note that this Policy is addressed to Affiliates and potential affiliates onboarded via www.roobetaffiliates.com for the Roobet Affiliate Program (the “Program”). Any personal information we collect will be used in connection with your use and participation in the Program, your contractual relationship or in accordance with our separate policies which are available by contacting us.
2. Roobet Group Of Companies
2.1. This Policy applies to the processing activities of the following data controller entities within the Roobet group of companies (the “Roobet Group”, which are:
a) Raw Entertainment B.V, a company registered in Curacao with company registration number 157205,
b) Raw Entertainment Limited, a company registered in Cyprus with registration number HE 421735,
c) Camann Limited, a company registered in the United Kingdom with registration number 13986362
3. Your Right To Privacy
3.1. You are advised that these rights do not apply in all circumstances due to regulatory requirements. In summary, you are entitled to the rights including but not limited to:
3.2. Right to Information
You have the right to request disclosure of the personal information we hold about you.
3.3. Right of Access
You may request access to your personal data that we collect, process and store, including how and why we process your personal data, and how long we intend to store your personal data as shown in this Policy.
3.4. Right to Rectification
You may request that we rectify any inaccurate or update or complete incomplete personal information that changes from time to time. We will then correct our records and notify any third parties to whom such personal information may have been transmitted.
3.5. Right to Erasure
You may request that we erase your personal information, and we will comply provided your personal data is no longer necessary in relation to the purposes for which we collected or otherwise processed.
3.6. Right to Object (Restriction) of Processing
You may request that we withdraw processing your personal information. The right to object/ restrict of processing may be requested by you in below circumstances:
i) where our use of the data is unlawful, but you do not want us to erase it;
ii) where you want us to establish the data’s accuracy;
iii) where you need us to hold the data although we may no longer require it as you need it to establish, exercise or defend legal claims; or
iv) where you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;
3.7. Right to Data Portability
You have the right to move or transfer your personal information in structured format, using a secure method, and within a month of receiving the request. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information (i.e. not to hard copies) which you initially provided consent for us to use or where we used the information to perform a contract with you.
3.8. Right to Withdraw your Consent (Opt-Out)
You have the right to opt out of marketing and/or gambling communications by clicking on the “unsubscribe” link in the marketing emails you receive from us. Alternatively, you can contact our support team and they will assist you in managing your preferences, regarding the type and the means of communications you want to receive or stop receiving. It shall be noted that you may change these preferences at any time. You further agree that the following may apply:
i) Once you exercise your right to unsubscribe/opt-out, we will refrain from reaching out to you regarding any email alerts, promotions, weekly content, announcements, updates, festive greetings and/or invitations to events;
ii) Any amendments in our Program Terms and Conditions and/or any announcements that may have an impact on your affiliate account with us and/or any other substantial notification will still be communicated to you even if you unsubscribe.
4. Types of Personal Information We Collect
4.1. We collect the necessary information required to open an affiliate account, and to provide the Affiliate with the services they require. We may collect certain personal information including but not limited to:
Categories of personal data
Passport, ID, identification data, images… Last names, names and addresses, passport or ID cards images, job title, mobile number, email address, birth date, criminal records, etc.
Economic and financial information (income, financial situation, tax situation, etc.)
Bank account details, source of funds/ wealth, cryptocurrency wallets and verifications, e-wallets account details, transaction history (withdrawal/ deposits), gambling history, etc.
Technical data
Source IP address, website access information, device used, cookies, languages, location browser etc.
5. HOW WE COLLECT YOUR PERSONAL INFORMATION
5.1. Direct interactions. You provide us with personal information through completion of the registration process, upload or send identity documents, carry out transactions, communicate through instant live-chat, telephone or email.
5.2. Use of automated technologies or interactions. When using our services, your device automatically transmits to us its technical characteristics. Locale is implemented for smooth processing of your personal information to produce the best possible service while using our platforms.
5.3. Use of our web services. We retain data from IP address, cookies files, browser data or operating system used, the date and time of access to the site, and the requested pages addresses allows us to provide you with the optimal operation on our web application, mobile app and/or desktop versions of our application and monitor your behaviour for the purpose of improving the efficiency and usability of our services.
6. HOW WE USE YOUR PERSONAL INFORMATION
6.1. Your personal information may be used as well as disclosed by as us as follows:
a) Payments-, AML-, KYC-, communication-, electronic verification apps and platforms providers which are provided to us by third parties, including but not limited to; Chainanalysis Inc., Shuftipro Ltd., Veriff, SEON Technologies Kft., and other providers with whom we have contractual agreements;
b) Consultants and other service providers who have been contracted to provide us with services such as administrative, online marketing, analytics, and financial, regulatory, compliance, insurance or other services;
c) Customers or other affiliates with whom we have a mutual relationship;
d) Competent authorities, and third-party providers (auditors or contractors or other consultancy firms) where such disclosure is required in order to enforce or apply our Program Terms and Conditions or other relevant agreements;
e) Payment service providers, credit card processors and banks processing your transactions;
f) Companies within the Roobet Group who provide marketing, financial, technical and other services;
g) Any person authorised by you through a limited power of attorney.
6.2. We endeavour to disclose to these third parties only the minimum personal data that is required to perform their contractual obligations to us. Our third-party service providers are not permitted to share or use personal data we make available to them for any other purpose than to provide services to us.
6.3. Our websites or our apps may have links to external third-party websites. Please note, however, that third party websites are not covered by this privacy notice and those sites are not subject to our privacy standards and procedures. Please check with each third party as to their privacy practices and procedures.
6.4. We may process your information in accordance with the principles of lawfulness, fairness, transparency, and always adhering to the intended purpose of data processing, the principle of data minimization, accuracy, limited data storage, data integrity, confidentiality and accountability.
6.5. We record and store personal information in hard copy files, electronic devices (computers, laptops, servers) and other records where we endeavour to protect it from damages, loss, internal or external-fraud, unauthorised access, modification or disclosure.
6.6. The Company may keep your personal data for either five (5) or ten (10) years for legal, regulatory and/or any other obligatory reason. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time.
6.7. Pursuant to the gambling services and anti-money laundering laws, we are required to retain copies and evidence of the actions taken by us in regard to your identity verification, transaction monitoring, gambling history, recorded communications (i.e. chats, emails, calls), complaints handling as well as records that reflect our compliance with regulatory obligations and fulfilment of the Program Terms and Conditions or the Customer Terms of Service with clients. Such evidence must be maintained in accordance with clause 6.6 after termination of our business relationship, or longer retention period upon regulator’s request (if applicable).
7. CONSENT AND ACKNOWLEDGEMENT OF DATA SUBJECT
7.1. We may process your personal data for one or more legal and lawful basis of processing determined by each purpose for which we may require your personal data.
7.2. We are obliged on legal and lawful basis to obtain your consent in connection to the following;
a) to perform our contractual obligations towards you
b) to be compliant with the legal and regulatory requirements
c) to pursue our legitimate interests, (each a “Lawful Basis”).
7.3. Where our use of your personal information does not fall under one of the Lawful Basis, we require your consent. Your free consent shall be required in this event, and you have the right to withdraw your consent at any time by contacting us using the contact details set out in this privacy notice or by withdrawing your consent.
7.4. You agree we may use personal data provided by you through our website or otherwise and personal data provided during our business relationship to communicate with you for marketing and promotional purposes as well as to provide you with announcements and updates of our terms through different channels like include calling you, sending emails, notifications through the Program and SMS notifications including push notifications.
7.5. We have the obligation to collect and store your personal information in accordance with the Ant-money laundry laws and regulation. This information is referred to as Know Your Customer information which is performed through our customer due diligence process of identifying and verifying your personal identity, transactional, financial, and other data.
7.6. We intend to store your personal information in our records for five (5) years or longer if required by law and where it is required of us to do so in relation to the fulfilment of our services.
8. TRANSFER OF PERSONAL INFORMATION OUTSIDE THE EUROPEAN UNION
8.1. We may transfer the client’s personal information and/or data outside the EU/EEA subject to the below conditions, and ensuring appropriate and suitable safeguards based on (a) the Standard Contractual Clauses (“SCC”) as adopted by the European Commission; or (b) the EU has designated a country as providing an adequate level of data protection; (c) through approved model contracts or binding corporate rules; (d) implementing Binding Corporate Rules for Processors or (e) by complying with an approved certification mechanism, e.g. EU-US Privacy Shield (if applicable), as permissible under the limited additional provisions of the GDPR. Some of our third-party providers (processors) may be based outside the European Economic Area (EEA) or European Union (EU); if a firm is located outside EEA/EU in a jurisdiction without adequate level of data protection, the transfer can only be completed if a transfer agreement based the EU Standard Contractual Clauses (including clauses on safeguard data).
9. HOW WE MANAGE YOUR PERSONAL INFORMATION
9.1. Any organisations outside the Roobet Group who handle or collect or process personal information acknowledge the confidentiality of such information, undertake to respect any individual’s right to privacy and comply with all relevant data protection laws and this privacy notice.
9.2. We ensure that personal data protection management conform to the below conditions:
a) enrolment of employees to training programmes regarding personal information to respect the confidentiality of customer information;
b) regularly prompt passwords updates and potential two-factor authentication when accessing our systems;
c) apply data encryption technologies during data transmission across networks or electronic devices;
d) regularly back-ups, deploy firewalls, and virus scanning tools to protect against unauthorised access of our systems;
e) use of shredders to destroy hard copies which contain sensitive data;
f) if applicable, installed CCTVs, and security alarms to protect against unauthorised access to our premises.
10. THIRD-PARTY CONTENT ON OUR WEBSITE AND SECURITY MEASURES
10.1. We may provide links to third-party websites in our website, and such websites are not under our control. We cannot accept responsibility for the conduct of third-parties linked to our website, including without limitation the collection or disclosure of your personal information. Before disclosing your personal information on any other website, we encourage you to read their privacy policy as well as terms and conditions for the use of their website.
10.2. Please note that such information is recorded by a third party and will be governed by the privacy policy of that third party, and those sites are not subject to our privacy standards and procedures.
10.3. In the event of any data breach which poses risk to your personal information, we will notify you within 72 hours of first having become aware of such breach (without undue delay).
10.4. Cookie’s may be enabled to gather, use and manage data from mobile devices through software’s that uses advanced encryption mechanisms. Such information includes the brand, type and hardware token of the mobile device transferred to us during registration of the device in the application and it is used for explicit identification of the applicant or application and the mobile device.
10.5. The Company’s services are not available for persons who are not of a legal age (“Minors”). We disclaim any liability for any unauthorised use by minors of our affiliate services, gambling platform in any manner or another.
11. HOW TO RESOLVE A COMPLAINT
11.1. Your possible privacy concerns are important to us. We are committed to resolving any complaint and to attending to answering general questions about our services or personal information that we collect, store and how it is used. If you are not satisfied with our response to your complaint, you have the right to further submit a complaint.
11.2. We will promptly respond to your requests but depending on the complexity or number of requests we revert to you in less than a month of the receipt of your request and keep you updated.
11.3. You may exercise your right by submitting written complaints or general questions about your personal information by emailing to: support@roobet.com
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Last updated on the 22nd of September 2022
