PRIVACY POLICY

Privacy Policy 

GENERAL

XXL Services N.V., is the Company incorporated under the laws of Curacao, with company number 150358 and registered office Abraham de Veerstraat 9, Curacao. When You access and/or use the Website or the Services, this Privacy Policy shall apply to any such use (hereinafter referred to as the ‘LionSpin’, ‘we’, ‘our’, ‘us’).

This Privacy Policy explains what personal data we collect from players, for what reason we collect it and how we utilize it. By using our website (https://www.lionspin.com) (hereinafter referred to as the ‘Website’), you accept this Privacy Policy.

Any translation of this Privacy Policy into any other language is made only for our customer’s convenience and is not modifying the terms of this Privacy Policy. If there is a conflict between the English and any other version in a language other than English of this Privacy Policy, the English version shall prevail.

The services offered on the Website are operated by XXL Sevices N.V. which is licensed and regulated by Gaming Services Provider N.V. – holder of Mater License #365/JAZ. XXL Services N.V. holds a sublicense with #GLH-OCCHKTW0703302020 as of 30th day of March 2020.

Please note that this Privacy Policy constitutes as an agreement between you and LionSpin.

PURPOSES OF THE DATA PROCESSING

We are required to maintain certain personal data about individuals for the purposes of satisfying our operational and legal obligations. We recognize the importance of correct and lawful treatment of personal data as it helps to maintain confidence in our organization and to ensure efficient and successful outcomes when using this data. Your personal data may consist of data kept on paper, computer or other electronic media.

We only use personal information as appropriate to provide you with a high quality of service and security.

We use and share personal data in next manners:

• To open and maintain your account and to provide our services (e.g. send out cash-out checks, transactions processing and etc.);
• To identify and verify according to KYC ("Know Your Customer") procedures in order to provide you access to some parts and features of our service;
• To promote our Website and services;
• To serve you advertisements when you use our services;
• To perform a research or to conduct analytics in order to improve and customize our Services to your needs and interests;
• To provide you a responsible gaming instrument;
• To support, maintain, troubleshoot and improve the quality of our Website and services
• To research and analyze about your use of the services;
• To perform research, technical diagnostics or analyze of our Website and services;
• To inform you about new products, services or promotions that may be of interest to you;
• To respond to your questions and requests in order to exercise your rights;
• To prevent fraudulent or any other illegal activity;
• To comply with all legal and regulatory requirements, including money laundering legislation or other legislations;
• To investigate illegal activity and breaches of our policies, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process or respond to a government request.

PRINCIPLES OF THE DATA PROCESSING

All personal data is:

• Fairly and lawfully processed;
• Processed for a lawful specified purpose;
• Adequate, relevant and not excessive;
• Not kept for longer than necessary;
• Accurate;
• Processed in accordance with the individual’s (data subject’s) rights;
• Secure;
• Not transferred to other countries without adequate protection.

WHAT DATA WE COLLECT

We may collect and process the following personal data about you:

1. Approximate geo-location, details of your visits to our Website (including, but not limited to, traffic data, location data, weblogs and other communication data, and the resources that you access), your web requests, browser type, browser language, web pages you visit before or after visiting our Website, URLs, platform type, click numbers, landing pages, viewed pages and the order of those pages and time spent on pages.

2. Any up-to-date personal data, that you provide to us by filling forms on our Website, including forms for registering and opening account with LionSpin, in emails, by calls and other information that may identify you or contains any personal or sensitive information (including your full name, gender, date of birth, phone number, e-mail address or mailing address, and IP address). We will ask you to provide some personal information to us if you want to use our services. This also includes:

• Payment and other financial information: all transaction history on your account, your payment information, that we may need in order to provide our services to you (including credit or debit card number, bank account and etc.);
• All information when you communicate with us through our support team or via email, Website and through any online platform (e.g. our Facebook page) or share additional information about yourself or about others. We may also ask you (a) for information when you report a problem with the Website and (b) to complete surveys that we use for research purposes, although you do not have to respond to them;
• Information from device, used by you: geolocation data, IP address and other online identifiers (i.e. online data collected from your devices, applications and protocols which leave traces which may be used to identify you).

You have choices about the data we collect. When you are asked to provide personal data, you may decline. You also entitled to have the LionSpin erase your personal data, cease further dissemination of the data and potentially have third parties halt processing of the data. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. However, if you choose not to provide data that is necessary to provide a service or feature or to withdraw the data that is still relevant to original purposes of processing, you may not be able to use that service or feature.

The data we collect depends on the context of your interactions with LionSpin, the choices you make, including your privacy settings, and the service and features you use.

HOW WE COLLECT YOUR DATA

We may use to collect personal data by using next methods:

1. By using services: when you are using our services, we may collect some personal data connected with services usage, without dependence on how you use services: independently or through the help of third-party services;

2. When you visit or access our Website or when you interact or engage with our services, we may use (and authorize third parties to use) web beacons, cookies, pixel tags, scripts, tags and other technologies. We use such technologies in order to automatically collect information about you and your online behavior, as well as your device (for example your computer or mobile device), in order to enhance your navigation on our Website, improve our Website’s performance and customize your experience on our Website. We also use this information to collect statistics about the usage of our Website, perform analytics, deliver content which is tailored to your interests and administer services to our players, advertisers, publishers, customers and partners. We also allow third parties to collect information about you. This information is anonymized and cannot identify you and is used for marketing and ad-targeting purposes. To learn more please visit our Cookie Policy.

REASONS WE SHARE PERSONAL DATA

We share your personal data with your consent or as necessary to provide any service you have requested. We also share data with LionSpin affiliates and subsidiaries, subcontractors and other third-party service providers, auditors or advisers of any of LionSpin's business processes and our service providers in order to provide our services to you. We may also forge partnerships and alliances, which may include joint marketing agreements, with other companies who offer high-quality products and services that might be of value to our customers. In order to ensure that these products and services meet your needs and are delivered in a manner that is useful and relevant, we may share some information with partners, affiliates and alliances.

We may share data with third person and authorities if this is required by law, in respond to legal process, to protect our clients, to maintain the security of our services and to protect the rights or property of LionSpin.

We do not sell, rent, lease or otherwise disclose your personal information to any third party for any reason, except as described below.

We may share Personal Information for the purposes listed above, as well as for the following purposes:

• To provide you with our services;
• For security reasons and so that we can audit and statistically track usage, audit our affiliates, and calculate payments to third parties;
• To assist us with our business operations (e.g. to process transactions; authenticate your access to account; to audit our operations, etc.);
• To store your personal data on our behalf;
• For advertising purposes, to use and share information we have about you, including information collected through our technologies, indicated in “How we collect your personal data” section with our partners (in various jurisdictions around the world).

We may use your personal data (such as your name, email address, telephone number, etc.) ourselves or by using our third-party subcontractors for marketing goals, what includes: providing you with promotional materials, concerning our services, as well as products, services, websites and applications. You may unsubscribe and discontinue receiving marketing offers by contacting our support team at [email protected].

We reserve the right to disclose your personal information to third parties when required to do so by law to regulatory, law enforcement or other government authorities if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to:

Comply with any applicable law, regulation, legal process or governmental request;
• Enforce our policies, including investigations of potential breaches thereof;
• Investigate, detect, prevent, or take action regarding any suspected fraud or security issues, or to prevent harm to the rights, property or safety our customers or any third party illegal activities or other wrongdoing;
• Protect LionSpin’s rights or property;
• To establish or exercise our rights to defend against legal claims; or
• For the purpose of collaborating with law enforcement agencies and/or in case we find it necessary in order to enforce intellectual property or other legal rights.

We may disclose your information as necessary to regulators, upon request for disclosures. Such information includes (but is not limited to):

• Details of customers breached our Terms and Conditions (including customers under 18 (eighteen) years of age);
• Self-excluded customers;
• Customers, who breached our Responsible Gaming Policy;
• Customers, engaging in suspicious transactions or suspected to be engaging in money laundering, fraud or any other illegal activity;
• Customers, which being suspected, attempting or doing to modify our products or services (or attempting to, or being suspected of, so doing); and
• Customers, who register a dispute with the applicable regulator.

All third parties with which we share personal information are required to protect personal data in a manner similar to the way we protect personal information.

RESTRICTION OF RESPONSIBILITY

If at any time you choose to purchase a product or service offered by another company, any personal information you share with that company will no longer be controlled under our Privacy Policy. We are not responsible for the privacy policies or the content of sites we link to and have no control of the use or protection of information provided by you or collected by those sites. Whenever you elect to link to a co-branded website or to a linked website, you may be asked to provide registration or other information. Please note that the information you are providing is going to a third party, and you should familiarize yourself with the privacy policy provided by that third party.

ACCESS TO PERSONAL DATA

All customers who are the subject of personal data held by us are entitled to:

• Ask what information we hold about them and why;
• Ask how to gain access to it;
• Be informed how to keep it up to date;
• Have inaccurate personal data corrected or removed;
• To receive the personal data concerning them, which they have previously provided;
• Prevent us from processing information or request that it is stopped if the processing of such data is likely to cause substantial, unwarranted damage or distress to the individual or anyone else, etc.;
• Require us to ensure that no decision which significantly affects an individual is solely based on an automated process for the purposes of evaluating matters relating to him/her, such as conduct or performance;
• Be informed what we are doing to comply with our obligations under the applicable data protection laws.

If you cannot access certain information and personal data collected by LionSpin, you can always contact us by ways, indicated in ‘Contact Us’ section. We will respond to requests to access or delete your personal data within 30 (thirty) calendar days.

SECURITY OF THE PERSONAL DATA

We maintain strict security standards and procedures with a view to preventing unauthorized access to your data by anyone, including our staff. We use 128 SSL bit encryption to protect confidential personal data that is transmitted online. We also take measures to protect your personal data offline. Only our employees will have access to particular information on ‘need to know’ basis in order to perform their work duties. The computers and servers in which we store your personal data are kept in a highly secure environment.

LionSpin takes reasonable steps to keep your personal data safe. However, we are not responsible for actions of such persons, who gain unauthorized access or abuse our services, and we make no warranty, express or implied, that we will prevent such access.

WHERE PERSONAL DATA IS STORUES AND PROCESSED

Personal data collected by LionSpin may be stored and processed in your region or in any other country where LionSpin or its affiliates, subsidiaries or service providers maintain facilities. Typically, the primary storage location is in the European Union, with a backup to the data centers in another regions. The storage location(s) are chosen in order to operate efficiently, to improve performance, and to create redundancies in order to protect the data in the event of an outage or other problem. We take steps to ensure that the data we collect under this privacy statement is processed according to the provisions of this statement and the requirements of applicable law wherever the data is located.

We may transfer personal data from the European Economic Area to other countries, some of which have not been determined by the European Commission to have an adequate level of data protection. When we do, we use a variety of legal mechanisms, including contracts, to help ensure your rights and protections travel with your data.

RETENTION OF THE PERSONAL DATA

LionSpin retains personal data for as long as necessary to provide the services, or for other essential purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements. Because these needs can vary for different data types in the context of different products, actual retention periods can vary significantly. The criteria used to determine the retention periods include, for instance:

• The period of data processing needed to provide the services. This includes such things as maintaining and improving the performance of those services, keeping our systems secure, and maintaining appropriate business and financial records. This is the general rule that establishes the baseline for most data retention periods;
• The data subject's consent for a longer retention period. If so, we will retain data in accordance with the consent;
• LionSpin is subject to a legal, contractual, or similar obligation to retain the data. Mandatory data retention laws can be applied in the applicable jurisdiction, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of litigation.

CONTACT US

If you have a privacy concern, complaint or a question, please contact us (a) via our contact form, (b) by contacting our support team at [email protected] or (c) via live chat. We will respond within 30 (thirty) calendar days.

Unless otherwise stated, XXL Services N.V. is a data controller for personal data we collect through the services subject to this statement.

COOKIE POLICY

INTRODUCTION

XXL Services N.V. (hereinafter referred to as the ‘LionSpin’, ‘we’ or ‘us’ or ‘our’) may use cookies, web beacons, tracking pixels, and other tracking technologies when you visit our website www.lionspin.com (hereinafter referred to as the ‘Website’) to help customize the Website and improve your experience.

We reserve the right to make changes to this Cookie Policy at any time and for any reason. Any changes or modifications will be effective immediately upon posting the updated Cookie Policy on the Website, and you waive the right to receive specific notice of each such change or modification.

Any translation of this Cookie Policy into any other language is made only for our customer’s convenience and is not modifying the terms of this Cookie Policy. If there is a conflict between the English and any other version in a language other than English of this Cookie Policy, the English version shall prevail.

You are encouraged to periodically review this Cookie Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Cookie Policy by your continued use of the Website after the date such revised Cookie Policy is posted.

The Website uses cookies to assist the functionality of the Website. Information on deleting or controlling cookies is available at www.aboutcookies.org. Please note that by deleting our cookies or disabling future cookies may not be able to access certain areas or features of the Website.

USE OF COOKIES

A “cookie” is a string of information which assigns you a unique identifier that we store on your computer. Your browser then provides that unique identifier to use each time you submit a query to the Website. We use cookies on the Website to, among other things, keep track of services you have used, record registration information, record your user preferences, keep you logged into the Website, facilitate purchase procedures, and track the pages you visit. Cookies help us understand how the Website is being used and improve your user experience.

TYPES OF COOKIES

The following types of cookies may be used when you visit the Website:

• Advertising Cookies. Advertising cookies are placed on your computer by advertisers and ad servers in order to display advertisements that are most likely to be of interest to you. These cookies allow advertisers and ad servers to gather information about your visits to the Website and other websites, alternate the ads sent to a specific computer, and track how often an ad has been viewed and by whom. We need to record this so that we can appropriately pay our affiliates. We use this information to measure the effectiveness of our marketing and to improve the overall relevance of the advertising we buy including, where possible, to make advertising more relevant to you. Without these cookies, you will be able to use and enjoy all the features of our Website but the ads you see will not be tailored to your preferences. These cookies are linked to a computer and do not gather any personal information about you.
• Analytics Cookies. Analytics cookies monitor how users reached the Website, and how they interact with and move around once on the Website. These cookies let us know what features on the Website are working the best and what features on the Website can be improved.
• Personalization Cookies. Personalization cookies are used to recognize repeat visitors to the Website. We use these cookies to record your browsing history, the pages you have visited and your settings and preferences (such as preferred language, sort types, media settings), each time you visit the Website. They are also used to improve users’ experience by, for example, stopping users from being shown the same message twice.
• Session Management Cookies. Session Management Cookies are essential to enable use of the Website, they manage session information and enable users to navigate through the Website.
• Security Cookies. Security cookies help identify and prevent security risks. We use these cookies to authenticate users, protect user data from unauthorized parties and to stop fraudulent use of the Website.
• Third-Party Cookies. Third-party cookies may be placed on your computer when you visit the Website by companies that run certain services we offer. These cookies allow the third parties to gather and track certain information about you. These cookies can be manually disabled in your browser.

Where links are provided on the Website to third party websites it is important to remember that those websites will have their own cookies and privacy policies which will govern any information you may submit. If you decide to use any linked third party websites please read their cookies and privacy policies before doing so.

CONTROL OF COOKIES

Most browsers are set to accept cookies by default. However, you can remove or reject cookies in your browser’s privacy settings. Please be aware that such action could affect the availability and functionality of the Website.

For more information on how to control cookies, check your browser or device’s settings for how you can control or reject cookies.

OTHER TRACKING TECHNOLOGIES

In addition to cookies, we may use web beacons, pixel tags, and other tracking technologies on the Website to help customize the Website and improve your experience. A “web beacon” or “pixel tag” is tiny object or image embedded in a web page or email. They are used to track the number of users who have visited particular pages and viewed emails, and acquire other statistical data. They collect only a limited set of data, such as a cookie number, time and date of page or email view, and a description of the page or email on which they reside. Web beacons and pixel tags cannot be declined. However, you can limit their use by controlling the cookies that interact with them.

PRIVACY POLICY

For more information about how we use information collected by cookies and other tracking technologies, please refer to our Privacy Policy posted on the Website. This Cookie Policy is part of and is incorporated into our Privacy Policy. By using the Website, you agree to be bound by this Cookie Policy and our Privacy Policy.

CONTACT US

If you have questions or comments about this Cookie Policy, please contact us (a) via our contact form on the Website, (b) by contacting our support team at [email protected]. We will respond within 30 calendar days.