You might have noticed that we like to have fun here at Casumo, but one thing we take really seriously is your privacy. We know that when you share your personal information with us, we need to keep it secure and use it fairly and lawfully. To help you understand how we do this, we’ve put together this privacy notice so you’re clear about what happens to your personal information when you engage with Casumo and our services.
When you register, play and contact Casumo, the data controller is Casumo Services Limited.
Address: The Unicorn Centre, Triq Il-Uqija, Swieqi, SWQ 2335, Malta
Data Protection Officer: email@example.com
As Casumo is based in Malta, we are subject to the General Data Protection Regulation (GDPR). This means that whenever we process personal data, we always follow the GDPR principles:
We need to process your personal information in order to provide you with our services. We will only ever ask you for the minimum amount of information that we need and we only ever use it for lawful purposes.
When you register for an account with Casumo you enter into a contract with us, as set out in our Terms and Conditions. For us to be able to keep up our end of the contract and provide you with access to our services we need to process some personal information about you. We will always make it clear which information is mandatory and which information you can decide not to give us if you don’t want to. If there are pieces of information that are mandatory and you don’t want to provide to us, then you will not be able to hold an account with us and use our services. We use your information to:
Some of the information we process about you is also necessary for us to comply with the legal and regulatory obligations that we have as a gaming company, such as licensing requirements, responsible gaming and Anti Money Laundering (AML) Regulations. This information is processed in order to:
Casumo processes a small amount of information about anyone who visits our website. We do this so that we can better understand the individuals who visit our websites and to help us identify where there are problems, security issues or things going wrong for visitors to the site. We do this by using technical programmes and functionality cookies. When we process information in this way it is necessary for the legitimate interests of Casumo to ensure that we provide an enjoyable, secure and smooth customer journey and that we protect the product from abuse that could compromise other users ability to use the service.
To make your time at Casumo fun and social, the Casumo website has a live panel that displays information about players who have logged in, what they are playing and amounts they have won on a game in real time. Players also have a player card which shows other players the games you have played, trophies and bonuses you have earned and your involvement in Reel Races. Your inclusion in this is based on your consent and you can control whether this information is made public to other players through your settings, which can be changed at any time.
Where we have your consent, Casumo will contact you about news, promotions and bonuses. We will only ever contact you for these reasons if we have your prior consent to do so. You have full control over whether and how we get in touch through the settings in your account. You can access and change these settings at any time.
Casumo will never ask you to provide any sensitive personal information, such as information about your health, or your race or ethnic origin. There may be times when you may choose to disclose information like this to us, such as when you are speaking with our Ambassadors. Any chats or emails are assigned to your account with us, and where you disclose a health condition which we feel may impact your ability to make rational decisions around your gameplay, we may take the decision to block you from our services for your own safety.
The majority of the information that we have about you is the information you provide to us yourselves. However sometimes we also get information about you from other sources.
Under our AML obligations, we are required to carry out due diligence checks that confirm information about you. In some circumstances we may also need to verify your source of wealth. We work with reputable external companies who work with the gaming industry to carry out these checks and they provide a report which contains information about you and your background.
In some circumstances, payment services providers may supply us with a small amount of personal information when they carry out a transaction for you so that we can connect transactions to you as a player.
There are some circumstances where we need to share your information with recipients who are outside of Casumo in order to provide our services. When we carry out any sharing with third parties we always ensure that there is an appropriate contract in place, that the information being shared is transferred in a secure way and that we only share the minimal amount of your information that we need to. Casumo will never sell your information to any other parties.
The third parties we work with include:
Occasionally we may receive a request to disclose information about you with law enforcement, regulators and supervisory authorities. We will always ensure that the organisation requesting the information has a legal basis to do so and will only share the minimum amount of information required in a secure way. We will also share your personal information with law enforcement, regulators and supervisory authorities where we believe a criminal act has been or may be committed.
There may be times when you share information with us that leads us to believe that there is a risk to your life. Where this is the case, we will share your details with local authorities in your area so that they can check on your wellbeing and ensure your safety.
Wherever possible, Casumo keeps your information within the European Economic Area (EEA). However in some circumstances your information may have to leave the EEA, such as when we work with third parties. Casumo always makes sure that any transfers outside of Europe are carried out in line with the law and are made securely.
Some of the third parties that we use for storage and communications are based in the US. These third parties are signed up with the EU-US Privacy Shield and are considered to offer an adequate level of data protection. Where these companies are not signed up to Privacy Shield, Casumo includes the EU Commission’s Standard Contractual Clauses in our contract with them to ensure your information is protected and safe at all times and that the transfer of the information is lawful.
A small number of people that work for Casumo are located outside of the EEA. We require them to work in line with all of our internal policies and procedures, and they also have the EU Commission’s Standard Contractual Clauses added to their employment contracts to ensure that your information is protected and safe at all times and that the transfer of the information is lawful.
To meet our legal obligations around fraud, taxation and anti money laundering, Casumo will need to keep your account information for up to 10 years after you close your account. When you close your account with us, the account is marked as “closed” and the information kept securely until the retention period is over. We then securely destroy this information.
You have a number of rights that you can exercise when it comes to your information. These rights include:
If you would like to exercise any of these rights, you should email our Ambassadors at firstname.lastname@example.org from your registered email address and provide:
In some circumstances we may request that you provide us with ID so that we can verify your identity. If this is needed we will let you know and explain the ID that we require. Some of these rights only apply in certain circumstances, so if we are unable to action your request we will explain to you why.
Where we rely on your consent to process your information you always have the option to withdraw this consent at any time.
We rely on your consent to include you in the live panel on the website that displays information about players and their real time game play and wins, as well as to make your player card visible to other players on the platform. The live panel and player card is only visible to other players who are registered with Casumo. You can control whether this information is made visible through your settings when you are logged into your account and this can be changed at any time.
We also rely on your consent to keep in touch with you to tell you about Casumo news, bonuses and promotions. We only ever send marketing messages to you if you have given us your consent to receive these messages. We collect this consent as part of the registration process, but you can control the channels that we contact you on and whether we contact you at all through your settings when you are logged into your account. These settings can be accessed and changed at any time. In any message that we send you there will also be a way for you to unsubscribe or “opt-out”.
You should be aware that even if you do not consent to marketing messages, you may still receive the occasional service email from Casumo. These messages are so that we can inform you of changes to Terms and Conditions and this privacy notice, as well as anything else that may impact the service we are able to provide to you.
We are required to take a number of steps to meet the rules around Anti-Money Laundering (AML) Counter Terrorist Financing and fraud. In order to do this we employ programmes that monitor player behaviour and alert us to suspicious or fraudulent transactions. Where relevant transactions are flagged we escalate these to the necessary regulators and enforcement bodies.
As part of our license, we also have obligations around responsible gaming. In order to do this, we employ a system which flags any gambling patterns or behaviours exhibited by a player that could indicate problem gambling. When the system flags a player, one of our Ambassadors reviews the account and where necessary will reach out to the player for a discussion on their game play and provide information and advice.
We also use segmentation to split our players into groups based on their gaming behaviour. We do this to help us understand how people use the product and to help us develop our marketing approach, including bonuses and promotions.
If you are unhappy with how your information has been handled by Casumo the first thing you can do is raise this with with our Ambassadors either through live chat or by emailing email@example.com to try and resolve it.
If you are unable to resolve your complaint with the Ambassadors, the next step is for you to make a complaint to our Data Protection Officer (DPO). You can do this by sending an email to firstname.lastname@example.org and detailing:
The DPO will then look into your complaint and investigate whether your information has been handled appropriately and in line with this privacy notice, our legal obligations and our internal policies and procedures. The DPO will then contact you regarding the outcome of the investigation and any steps that have been taken as a result.
If after raising your complaint with the DPO you are unhappy with the resolution to your complaint you can make a complaint to our lead supervisory authority, the Maltese Data Protection Commissioner:
Office of the Information and Data Protection Commissioner
Level 2, Airways house
(+356) 2328 7100
We will review and update this privacy notice anytime there is a significant change to how we are using personal information and at least annually.
If we make any changes to the privacy notice we will summarise these changes below. We may also contact you to notify you of any significant changes if we think this is necessary.
This privacy notice was created and published May 2018.
We have translated our privacy notice from English into the official languages of the countries that we provide our services to. We have done this to ensure that all of our customers are clear about how Casumo uses personal information.
If there are any conflicts or inconsistencies between the translated versions of this privacy notice, the English version will prevail.
May 2018 - Consumer privacy notice launched