The introduction

 

This Privacy Policy (hereinafter the “Policy”) governs the processing of your personal data (hereinafter shall be also referred to as “data”) when you visit or use the website https://jackpotter.com/ (hereinafter the “Website”) or communicate with the Website's administration via available contact details.

Information about us

 

The Website is owned and operated by Bravo Entertainment Ltd, the company incorporated in the Belize, with its registered number 000047535, with its registered address Sea Urchin Street, San Pedro Town, Ambergris Caye, Belize. Bravo Entertainment Ltd shall hereinafter be referred to as the "Company", "We", "Us", "Our".

If you have any questions regarding this Privacy Policy, you can contact our Data Protection Officer at privacy@jackpotter.com.

What data we process

 

Contact data. When you communicate with us via the interface of the Website or via available contact details, you provide us with the following data:

• Your contact details: it may be your postal address/email address/phone number;
• Your name;
• All the information you provide us during our communication;

•Additionally, we record the history of your communication with us, which includes the record of audio calls with us (for example, when you communicate via audio with our Support team etc.)

Account data. When you create an account on the Website, you provide us, in addition to your Contact data, with the following:

• Your name;
• Your gender;
• Your birth date;
• The information about coupons you have activated;
• Your username (if applicable);
• Your Telegram/Whatsapp account;
• Additional data (if applicable).

Additionally, if you have excluded your account from gambling for a specific time period or have blocked your account permanently, we will also have this information recorded.

Newsletter consent data. We collect the data on whether have you consented to receive our Newsletter.

Referral data. We collect the data about your referral (referral user or the referral affiliate).

Bets data. These data include information about bets you have made and on what outcomes, games you have played and the total amount of winnings and losses and similar information.

Verification data. During the Verification process you will be required to provide us with the following data:

• A copy or a photo of your identification document;
• A photo of your payment instrument or other evidence that you are a holder of a payment instrument used or intended to be used for making transactions;
• A photo of you;
• A photo of you bearing your identification document and payment card;
• Your address confirmation. It may be a utility bill, telephone bill or other documents which, in accordance with your jurisdiction's legal and regulatory requirements, shall be enough to confirm your address;
• A confirmation of the source of your wealth and your funds (in some situations);
• The record of your video calls/audio-calls with the Website`s administration (if Verification is made via audio/video call);
• When performing Verification, we check some users of the Website in state registers, databases of politically exposed persons and other reliable sources and collect additional data from them.

Payment data. The Website uses SSL encryption that ensures the confidentiality of your information in the transmission of data. The payment operations are carried out entirely through the secure server of the payment gateway. However, we may store your deposit and withdrawal history.

Loyalty Program data. For the frequenters of the Website, we created our Loyalty Program. It means that we create data about the participation of the user within this Program. These data include:

• Your points earned;
• Your level;
• Cashback amount;
• Other data which may be processed within the Loyalty Program.

Bonus data. We process the data about your use of the bonuses within the Bonus Program. These data include, but not limited to:

• Information about the bonuses you have used;
• Your Bonus balance.

Automatically collected data. When you use the Website some data are collected automatically. These data are received from your web browser and then analysed by us. These data include the following:

• The total time you spend on the Website;
• What internal links were clicked (based on the URL of the next pageview);
• Your IP address and user agent string (which browser is being used, what version, and on which operating system).

Cookies data. Cookies may collect data that fall within the definition of “personal data”. To find more information about the use of cookies, please, follow cookie policy.

 

Here’s a simplified version of the text with clearer structure and styling:

Purpose | Data | Legal Basis

 

1. Administer and protect the Website

• Data: Automatically collected data, Cookies data
• Legal Basis: Legitimate interests of the Company (Article 6(1)(f) GDPR) – To protect the Website from cyberattacks and diagnose server issues.

2. Create your account and provide Services

• Data: Contact data, Account data, Bets data, Payment data
• Legal Basis: Performance of the contract (Article 6(1)(b) GDPR) – Necessary for account creation and service provision.

3. Conduct Verification

• Data: Any data concerning you
• Legal Basis:
• Legal obligation (Article 6(1)(c) GDPR) – Compliance with anti-money laundering and child protection laws.
• Legitimate interests (Article 6(1)(f) GDPR) – Prevention of fraud and cheating.
• Performance of the contract (Article 6(1)(b) GDPR) – Compliance with Terms and Conditions.

4. Comply with legal requests from authorities

• Data: Any data concerning you
• Legal Basis: Legal obligation (Article 6(1)(c) GDPR) – Compliance with legal requests.

5. Contact you

• Data: Contact data and other necessary data
• Legal Basis:
• Legitimate interests (Article 6(1)(f) GDPR) – Communication about the Website or general inquiries.
• Performance of the contract (Article 6(1)(b) GDPR) – Communication related to account use or service issues.

6. Comply with your data subject rights and other requests

• Data: Any data concerning you
• Legal Basis: Legal obligation (Article 6(1)(c) GDPR) – Compliance with your rights and legal requests.

7. Facilitate self-exclusion

• Data: Verification data, Account data, Contact data, Payment data
• Legal Basis: Performance of the contract (Article 6(1)(b) GDPR) – To process self-exclusion requests.

8. Send you newsletters

• Data: Newsletter consent data, Contact data
• Legal Basis: Your consent (Article 6(1)(a) GDPR).

9. Improve Website functionality

• Data: Automatically collected data, Cookies data
• Legal Basis: Legitimate interests of the Company (Article 6(1)(f) GDPR) – Website and service enhancement.

10. Provide a tailored Website experience

• Data: Automatically collected data, Cookies data
• Legal Basis: Legitimate interests of the Company (Article 6(1)(f) GDPR) – To ensure the Website functions properly.

11. Prevent violation of Terms, cheating, and fraud

• Data: Any data concerning you
• Legal Basis: Legitimate interests of the Company (Article 6(1)(f) GDPR) – To prevent misuse and maintain integrity.

12. Calculate commissions for referrers

• Data: Account data, Contact data, Bets data, Payment data
• Legal Basis: Legitimate interests of the Company (Article 6(1)(f) GDPR) – To calculate and pay commission.

13. Establish, exercise, and defend legal claims

• Data: Any data concerning you
• Legal Basis: Legitimate interests of the Company (Article 6(1)(f) GDPR) – Protection of legal rights in disputes.

14. Facilitate payments on the Website

• Data: Payment data
• Legal Basis: Performance of the contract (Article 6(1)(b) GDPR) – To process payments and provide services.

15. Calculate Website balance (real and bonus)

• Data: Payment data, Bonus data, Loyalty program data, Bets data
• Legal Basis: Performance of the contract (Article 6(1)(b) GDPR) – To calculate and maintain balance.

16. Calculate cashback

• Data: Payment data, Bonus data, Loyalty program data, Bets data
• Legal Basis: Performance of the contract (Article 6(1)(b) GDPR) – To calculate and provide cashback.

17. Provide VIP support

• Data: Payment data, Bonus data, Loyalty program data, Bets data
• Legal Basis: Legitimate interests of the Company (Article 6(1)(f) GDPR) – To offer VIP support for qualifying users.

18. Provide Loyalty Program

• Data: Payment data, Bonus data, Loyalty program data, Bets data
• Legal Basis: Performance of the contract (Article 6(1)(b) GDPR) – To provide loyalty rewards.

 

Our subcontractors, affiliated companies and other entities. The Website and Services provided via the Website are maintained and provided by a large number of people who may be employed either by the Company or by any of our affiliated companies, subcontractors, and other establishments. This means that your data may be shared with them. Please note that all these transfers are secured by proper data transfer agreements which oblige these recipients to process your data in accordance with this Policy and with the data protection legislation to which the Company is subject. We engage service providers for the following services:

• Hosting the Website and data;
• Marketing services;
• IT services and security services;
• Customer support software service providers;
• Payment service providers;
• KYC, anti-fraud, and anti-money laundering services;
• Games providers;
• Audit, legal and compliance services.

Data centre(s) which make the Website available. The Website and the Services provided via the Website are placed on the Server which belongs to the third party. From this follows that your data will be shared with them. Please note that your data are stored only in encrypted form, which makes it impossible to decrypt your data without decryption keys.

Financial institutions: banks, payment services providers, payment systems/gateways and other similar entities. Your transactions for the Services provided via the Website are processed by the third-party financial institution(s). This means that your data will be shared with them to process your transactions and perform their legal and regulatory obligations.

Сourier companies. If you win any physical winning(s) or prize(s), your data will be shared with a courier company that will be engaged in the process of delivery of a winning or a prize to you.

Accreditation bodies, auditors. When the Company passes an independent audit, the data concerning you may be shared with the auditor. All these bodies or auditors are legally obliged to handle your data in accordance with this Policy and applicable legislation.

Analytics. We use data analytics services to measure and understand our audience, tailor our marketing services, improve Website experience. This includes Google Analytics, Metrika and Hotjar.

Google Analytics. The Website uses Google Analytics, a web analytics service. It is operated by Google LLC., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google Analytics uses previously mentioned "cookies". The information generated by the cookie about your use of the Website is usually transmitted to a Google server in the USA and stored there. Google Analytics Opt-out Browser Add-on provides visitors and users with the ability to prevent their data from being collected and used by Google Analytics. To install Google Analytics Opt-out Browser Add-on, follow this link: https://tools.google.com/dlpage/gaoptout?hl=en.

Cloudflare, Inc. The Company uses the services, provided by Cloudflare, Inc. 101 Townsend St, San Francisco, CA 94107 USA. Сloudflare provides web optimization and security services that the Company uses to improve and protect the Website, including a reverse proxy, pass-through security service. Cloudflare may collect the log data from the visitors of the Website. Additionally, the Company deployed Cloudflare`s cookie file for security purposes (see Cookies Policy to find out more). To find out more about the processing of the data by Cloudflare, please follow https://www.cloudflare.com/privacypolicy.

Hotjar. Hotjar (registered place of business: Hotjar Ltd, Level 2 St Julians Business Centre, 3, Elia Zammit Street St Julians STJ 1000, Malta) is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, etc.) and this enables us to maintain, and improve our Website. Hotjar uses cookies and other technologies to collect data on our users’ behaviour and their devices (in particular a device’s IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our Website). Hotjar stores this information in a pseudonymized user profile. If you want to opt-out from the processing of the data concerning you by Hotjar, please, follow Hotjar`s Opt-out Webpage via the link https://www.hotjar.com/legal/compliance/opt-out.

How long we will store your data

 

For the data of our users who possess an account on the Website: 6 (six) years starting from the date you closed your account on the Website and our contract with you is terminated.

Your data subject`s rights

Under applicable data protection legislation, you have the rights which you can exercise either by a) sending a request to us to our registered address; or b) sending a request to our email address privacy@jackpotter.com; or c) via the interface of the Website (for some functions).

Please note, that these rights are applicable with some restrictions:

• If we are not sure about the identity of the requestor, we will verify the identity of a user/visitor who requests for the implementation of any of the rights before the implementation;
• We may restrict the rights specified below or deny in implementation of any of the rights if this restriction or denial is grounded on the legislation to which the Company is subject or if we can deny implementation of your request under applicable legislation. In this case, we will specify the reason for the denial in the reply to your request;
• Information contained in this section is just an informational description of the rights under the GDPR and has no legal effect. If you want to find more about each right, please refer to Articles 15-22 of the GDPR.

Your rights are the following:

The right to withdraw consent. If you previously consented (under Article 6(1)(a) of the GDPR) to the processing of your data, you have the right to withdraw this consent at any time. It means that we will stop the processing of the personal data for the processing of which the consent was required starting from the date of the withdrawal. The withdrawal of consent shall not affect the lawfulness of the processing based on consent before its withdrawal.

The right of access. You have the right to obtain from us the confirmation as to whether or not the data concerning you are being processed, and, if we indeed process your personal data, to receive a copy of the personal data undergoing processing.

The right to rectification. You have the right to obtain from us the rectification of inaccurate personal data concerning you.

The right to erasure (or the right "to be forgotten"). You have the right to obtain from us the erasure (removal) of your personal data. Upon your request, your personal data shall be removed. This right shall be applied if:

• your personal data are no longer needed for the purposes for which these data were collected;
• you have withdrawn your consent (if you have provided this consent) and there are no other legal bases for further processing;
• we do not need to keep your personal data for the purposes of compliance with the applicable legislation;
• the data are processed unlawfully;
• there are no any restrictions of this right by the applicable legislation;
• in other cases when the erasure (removal) is required by the applicable law.

The right to object to processing. You have the right to object, on grounds relating to your particular situation, to processing of your personal data if the grounds of this processing were necessary for the purposes of the legitimate interests pursued by the Company or by a third party (Article 6(1)(f) of the GDPR). Additionally, you have the right to object to the processing of your personal data for direct marketing purposes (if applicable).

The right to restriction of the processing. You have the right to obtain from us restriction of processing, in case if one of the following applies:

• you contested to the accuracy of the personal data, for a period enabling the Сompany to verify the accuracy of the personal data;
• processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
• we no longer need the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims;
• you have objected to processing on the basis of your right to object pending to verification whether your legitimate grounds override those of the Company.

The right to data portability. You have the right to receive from us the data which were collected from you, in a structured, machine-readable format and have the right to transmit those data to another controller (in a plain language, to another company). This right applies only to processing which:

• Was carried out by automated means;
• Is based on Articles 6(1)(a) and 9(2)(a) of the GDPR (consent) or is based on Article 6(1)(b) of the GDPR: processing which was carried out under the contract between you and us.

The right to lodge a complaint with the supervisory authority

You can always contact us for any issue concerning the processing of your data, including complaints. If you have queries or concerns, please contact us at privacy@jackpotter.com and we will respond.

If you are unhappy with our response to your query or if you are not satisfied with how we manage your personal data, you always have the right to lodge a complaint with a supervisory authority, in particular in the country of your habitual residence, place of work or of an alleged infringement. We kindly ask that you please attempt to resolve any issues you may have with us first (even though, as stated above, you have a right to contact the competent regulator at any time).

International data transfers

 

Our Company does business globally, which means that your data may be transferred to the so-called “third countries” within the meaning of the GDPR. We rely on the following methods for transfers of personal data to “third countries”:

• We transfer personal data to a third country when the European Commission has decided that such third country ensures an adequate level of protection. You can see more details on the European Commission official website;
• Where we use service providers which are not subject to an adequacy mechanism, we will ensure that additional safeguards and measures are put in place as required, including by incorporating specific contracts approved by the European Commission. For more information, please see the European Commission official website.

If you want further information on the specific mechanism used by us when transferring your personal data to “third countries”, please contact us.

Processing of children`s data

 

The Website is not intended for users under the age of 18 or under the age required to participate in gambling in the place of the residence (jurisdiction) of the particular user ("Legal Age"). If you are a parent or a legal guardian and have found that your child uses our Website, please contact us via any available means of communication and we will apply appropriate measures.

Third-party websites

 

This Website may contain links to Websites owned by third parties. For example, links/hyperlinks to third-party websites (hereinafter " third-party websites"). You follow those links/hyperlinks at your own risk. The Company bears no liability for the content of any of those Websites and bears no responsibility for anything that can happen as a result of your visit to those third-party`s websites. The Company recommends you to visit "Privacy Policy" or "Data Policy" or another privacy document on any of these Websites before submitting any data concerning you to the latter.

Changes to this Policy

 

The Company may change this Policy. In case of any changes, the Company will post a revised Policy before these changes will come into force. The Company will notify registered users about the changes to this Policy by sending an e-mail notification. Continued use of the Website by you shall be interpreted as you have read and understood the revised Policy.

Languages of this Policy

 

This Policy was made in the English language. Please note that other language versions of this Policy are made for convenience. In case of inconsistency between the language versions of this Policy, the English version shall prevail.