You might have noticed that we like to have fun here at Casumo, but something that we know isn’t fun for you is worrying about your privacy. We know that when you share your personal information with us, you expect us 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.
THE DATA CONTROLLER AND HOW TO CONTACT US
When you register, play and contact Casumo, the data controller is Casumo Services Limited.
Address: The Unicorn Centre
Data Protection Officer: email@example.com
As Casumo is based in Malta, we follow the rules of the General Data Protection Regulation (GDPR). This means that whenever we handle your 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 smallest amount of information that we need and we only ever use it for lawful purposes. We never sell your information to anyone else.
The contract between us
When you register for an account with Casumo you enter into a contract with us, as we explain in our Terms and Conditions. For us to be able to keep up our end of this 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 it to us, then you will not be able to have an account with us and use our services.
We use this information to:
Some of the information we process about you is necessary for us to meet the legal and regulatory obligations that we have as a gambling company. This includes licensing requirements, responsible gaming obligations 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 and app. We do this so that we can better understand the people who use our services and to help us identify where there are problems for users, such as security issues or things going wrong. 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 our services from abuse that could compromise the ability of other users 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, which you can access and change at any time.
SENSITIVE PERSONAL INFORMATION
Casumo will never ask you to provide any sensitive personal information, such as information about your health or 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 or Responsible Gaming Specialists, and these chats and emails are assigned to your account with us. Where you have a health condition that affects your ability to control your gambing behaviour and you choose to provide us with documentation to support this, we will make note that you have a health condition but delete the documentation you provide to us. 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 yourself. 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 addition to this, we also carry out our own searches for information available to us from open sources, such as social media and public registers.
In some circumstances, payment service 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.
We may also receive information about you from national self exclusion registers. We query national registers so we can ensure people who have signed up to self exclude from gambing websites can’t have an account with us. These national registers will let us know if you are signed up with them so we can exclude you from our services.
You may also choose to authorise third parties to share personal information with Casumo. For example, authorising banks and financial institutions to share personal information with us in order to assist with your registration and account verification.
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 smallest amount of your information that we need to. Casumo will never sell your information to any other parties.
The third parties we share information with include:
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 smallest amount of information required in a secure way. We will also proactively 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 or wellbeing. 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, have appropriate legal protection and are carried out securely.
Where personal information is transferred outside of the EEA to a country that the EU has not determined to be adequate, we always implement the EU Commission’s Standard Contractual Clauses between ourselves and the company who is receiving the personal information. This ensures your personal information is protected and safe at all times and that the transfer of the information is lawful. Some of the third parties that we use are based in the US. Where these third parties are signed up with the EU-US Privacy Shield,they are considered by the EU to offer an adequate level of data protection so we do not implement the EU Commission Standard Contractual Clauses.
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.
HOW LONG DO WE KEEP YOUR INFORMATION FOR
Casumo has a number of legal obligations when it comes to retaining your personal information. Depending on the activity on your account, we will keep your personal information for between 5 and 10 years after you close your account with us. If you have self excluded, we will retain your personal information for 75 years after you close your account, to ensure that we are able to maintain your self exclusion from our services. Any health documentation you may have chosen to provide to us will not be retained and will be deleted once it has been reviewed by our Responsible Gambling Specialists.
All closed and self excluded accounts are kept protected until the retention period is over and then the information is securely destroyed.
YOUR RIGHTS AROUND YOUR 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.
Right to Erasure
The right to erasure is not an absolute right. This means that it doesn’t always apply to everyone. In order to have your information deleted, you need to fall into one of a small number of categories. In addition to that there are a number of categories, known as exemptions, where the right to have your information deleted doesn’t apply at all.
Casumo has to comply with our legal obligations under Anti-Money Laundering (AML) laws. Under these laws we are required to keep all information about any business relationship formed with an individual, up to the retention period assigned to the account. Because of this, the right to erasure does not apply, as there is an exemption when a company has to comply with a legal obligation that does not allow for erasure of information.
Although the right to erasure does not apply to players with Casumo, we can close your account with us which will mean that you would no longer hear from Casumo and your account would no longer be active.
WITHDRAWING YOUR CONSENT
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 let you know 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”. If you choose to withdraw your consent to marketing, we will action this straight away and you will no longer receive these messages from us. However, please note that on rare occasions you may still receive a further marketing message from us within 24 hours of unsubscribing while our systems update.
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, such as availability of payment methods.
Anytime you have a telephone call with Casumo, the call will be recorded. This is both when we make a call to you and when you make a call to us. You will always receive a notification at the start of the call so you know that the call is being recorded. We record all of our calls because we have to comply with legal obligations that we have as a gaming company, one of which is to record all contacts we have with our players.
There is not a way to opt out of having a call recorded if you make a call to, or receive a call from Casumo, but you can choose not to proceed with the call. You can also always communicate with us via written means such as email and live chat if you prefer. You will only be contacted with a phone call if you have given us your consent to contact you in this way and you can opt out at any time either through your account settings or by telling us on the call. The exception to this is where you have shared information with us that leads us to believe that there is a risk to your safety. In these circumstances we may try and contact you with a phone call to check on your well-being.
AUTOMATED DECISION MAKING AND PROFILING
We are required to take a number of steps to meet the rules around Anti-Money Laundering (AML), counter terrorism financing, fraud and other illegal activities. In order to do this we employ programmes that monitor player behaviour and alert us to suspicious or fraudulent transactions and activity. Where relevant transactions are flagged we escalate these to the necessary regulators and enforcement bodies and accounts may be blocked.
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 Responsible Gambling Specialists 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 ensure people get the right marketing (e.g. the correct language and offers) and to help us understand how people use the product, develop our marketing approach, and ensure people receive offers they are interested in. We also identify individuals who qualify for our Loyalty scheme.
With our sportsbook product we work with a third party who provides us with a risk management service. Using automated decision making and profiling, your bets and playing activity are assessed to analyse your betting patterns, to create risk profiles about you, to adjust betting limits and to prevent betting where necessary. In some cases, there may be human intervention by the third party or ourselves to review these decisions.
MAKING A COMPLAINT
If you are unhappy with how your information has been handled by Casumo the first thing you can do is raise this 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
CHANGES TO THIS PRIVACY NOTICE
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 originally created and published May 2018
TRANSLATIONS OF THIS PRIVACY NOTICE
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.
PREVIOUS CHANGES TO THIS PRIVACY NOTICE
May 2018 - Consumer privacy notice launched
May 2019 - Annual update: