This Policy applies to data collected, received or used whenever each of Lady Aida‘s website visitors and registered players ("you") uses the Lady Aida website, plays Lady Aida‘s games or otherwise accesses or uses any of our websites, systems or services (collectively, the "Services").
Below we describe what data we collect, from whom we may collect or receive such data, how we may use and disclose such data (and to whom), our data security practices and the rights and choices available to you regarding such data.
We strongly urge you to read this Policy and make sure that you fully understand and agree with it. If you do not agree to this Policy, please discontinue and avoid using our Services.
In order to allow you to register a player account at Lady Aida (as further described below), under applicable gambling regulations we are required to collect certain Personal Data (as such term is explained below). This is necessary to ensure the identity and safety of our players, to facilitate your use of Lady Aida, and to ensure our compliance with all necessary regulations and responsibilities. If you do not wish to provide us with such data, or with any other Personal Data, please simply do not register to Lady Aida or use our Services.
Table of Contents:
- What data do we collect?
- How do we collect such data?
- Why do we collect such data?
- Where do we store your Personal Data?
- With whom may we share your Personal Data?
- Communications from Us
- How do we safeguard your Personal Data?
- The rights and choices available to you regarding your Personal Data
- How long may we keep your Personal Data?
- Contact us
What Data Do We Collect?
The data we collect pertains to either unregistered visitors to our Services, or registered players, and includes the following parameters (which, to the extent it relates to an identified or identifiable individual, shall be deemed as "Personal Data"):
Visitor Data: when someone visits our Services, we might collect certain technical data about them, concerning their visit, their use of our Services, and the source of their visit (such as any of our marketing campaigns or affiliate websites). Such data does not enable us to actually learn the identity of the visitor from whom it was collected, and serves us mostly to better understand and improve on our marketing campaigns and engagements, as well as the overall performance of our Services.
Visitor data mainly consists of technical and aggregated usage data, such as the visitor's IP address,
Geo-location and/or device unique identifier, browsing and ‘click-stream’ activity on the Services,
session heat-maps and scrolls, non-identifying data regarding the visitor’s device, operating system,
internet browser, screen resolution, language and keyboard settings, internet service provider,
referring/exit pages, date/time stamps, and the origin of the visitor's visit to our Services.
In addition, if a visitor contacts us in any way (such as via chat, e-mail or phone), we will collect and record such communications and related data, information and usage logs concerning such visitor (including their identity or contact details, if provided through such communications).
Player Data: in addition to such visitor data, when someone registers to open a player account, they are required to provide us with additional data, namely information concerning their identity, contact and billing details, and in certain cases, additional verification documentation proving and evidencing the same upon our request.
Such information includes the player's account credentials (username and hashed password), full name, date of birth, gender, home address, e-mail, phone number, bank account, credit card and any other payment information, scanned photographic identification documents, financial statements, and additional information and documentation as may be necessary to ensure their eligibility to play at Lady Aida.
Following registration and approval of the player's account, we collect additional data with respect to the player's transactions (deposits and withdrawals), playing activity, communications with us, and self-exclusion requests.
In addition, we may require that you provide us additional data related to your financial status and/or the source of funds used on our site, and in certain cases, additional verification documentation proving and evidencing the same.
How Do We Collect Such Data?
There are two main methods we use:
We collect Personal Data through your use of the Services. In other words, when you are visiting or using our Services, including when you browse our website, register a player account, and play at Lady Aida, we are aware of it and may collect and record such uses, sessions and related data, either independently or with the help of third-party services as detailed in Section 5 below, including through the use of “cookies”, social media channels, and other tracking technologies, as further detailed in Section 6 below.
We collect Personal Data that you provide us voluntarily when you are using the Services. For example, when you register to the Services, make deposits or withdrawals, place bets, communicate with us via chat, e-mail or phone, or personally disclose any information in public areas of the Services. Throughout your relationship with Lady Aida as a player, we may choose to verify the data you have provided through any of the means as described in our Terms and Conditions, including by requesting additional identification data or financial data from you.
Why Do We Collect Such Data?
We collect Personal Data for the following purposes, in accordance with our legitimate interests and/or legal obligations, as applicable, and/or as necessary for the establishment and performance of our contractual engagements with our players:
• To enable you to use our website, to register and set up your account, play at Lady Aida and to
provide you with ongoing customer service and technical support;
• To identify our players and process their requests and transactions;
• To monitor our website performance and further develop, customize and improve the Services and user experience, based on visitors’ and players’ common or personal preferences, experiences and difficulties;
• To contact our visitors and players with general or personalized service-related notices and promotional messages and to facilitate, sponsor and offer certain contests, events and promotions;
• To market and advertise our services;
• To ensure players' eligibility and monitor their performance, preferences and requests;
• To verify financial solvency of players and to conduct affordability checks;
• To conduct Source of Income / Source of Funds / Source of Wealth checks;
• To support and enhance our data security measures, including for the purposes of preventing fraud, irregular betting, money laundering and cheating;
• To protect and support our legitimate interests and those of our affiliates;
• To protect the safety, well-being and interests of visitors, players, GFO, its affiliates and any members of the general public;
• To create aggregated statistical data and other aggregated and/or inferred non-personal data, which we or our business partners may use to provide and improve our respective services; and
• To comply with any applicable laws and regulations, including gambling and anti-money laundering regulations.
Where Do We Store Your Personal Data?
Personal Data collected in accordance with this Policy may be maintained, processed and stored by us and our authorized affiliates and service providers as reasonably necessary for the proper delivery of our Services or as may be required by law. While the data protection laws in these jurisdictions may be different from the laws where you reside, please know that we, our affiliates and service providers that store or process your Personal Data on our behalf are each committed to keep it protected and secured, in accordance with this Policy and industry standards, regardless of any lesser legal requirements that may apply in their jurisdiction.
With Whom May We Share Your Personal Data?
We may share your Personal Data with third parties (or otherwise allow them access to it) only in the following manners and instances:
Third Party Services: We have partnered with a number of selected service providers, whose services and solutions complement, facilitate and enhance our own. These may include hosting, advertising and marketing services, database and server co-location services, data analytics services, identity verification services, data and cyber security services, banks, payment processors, gateways and correspondents, fraud detection and prevention services, insolvency and credit risk assessment services, e-mail and text message distribution and monitoring services, dispute resolution providers, customer support and call center services, session recording, remote access services, and our business, legal and financial advisors (collectively, "Third Party Services").
Such Third Party Services may receive or otherwise have access to your Personal Data, depending on each of their particular roles and purposes in facilitating and enhancing the Services, and may only use it for such purposes. We remain responsible and liable for any Personal Data processing done by Third Party Services on our behalf, except for events outside of our reasonable control.
Governmental/Law Enforcement Agencies and Legal Requests or Duties: We may disclose or otherwise allow access to your Personal Data pursuant to a legal requirement or request, such as a subpoena, search warrant or court order, or in compliance with applicable laws and regulations. Such disclosure or access may occur with or without Policy to you, if we have a good faith belief that we are legally required to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.
Protecting Rights and Safety: We may share your Personal Data with others, with or without Policy to you, if we believe in good faith that this will help protect the rights, property or personal safety of us, any of our players, or any members of the general public.
Subsidiaries and Affiliated Companies: We may share Personal Data
internally within our family of companies, for the purposes described in this Policy. In
addition, should we or any of its affiliates undergo any change in control, including by means
of merger, acquisition or purchase of substantially all of its assets, your Personal Data may be
shared with the parties involved in such event. If we believe that such change in control might
materially affect your Personal Data then stored with us, we will notify you of this event and
the choices you may have via e-mail and/or prominent Policy on our Website or Services.
For the removal of doubt, we may share your Personal Data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so. Additionally, we may transfer, share or otherwise use non-personal data in our sole discretion and without the need for further approval.
We use certain monitoring and tracking technologies, including ones offered by Third Party
Services. These technologies, such as cookies, web beacons, pixels and log files, are used
in order to maintain, provide and improve our Services on an ongoing basis, and in order to
provide a better experience to our visitors and players. For example, these technologies
enable us to keep track of our visitors' and players' preferences and authenticated
sessions, to better secure our Services, and detect abnormal behaviors, to identify
technical issues, and to monitor and improve the overall performance of our Services.
In order for some of these technologies to work properly, a small data file ("cookie") must be downloaded and stored on your device, for purposes of session and user authentication, security, keeping the user's preferences, connection stability, monitoring performance and generally providing and improving our Services.
In order to delete or block any cookies, please refer to the "Help" area on your internet
browser for further instructions, or look for optional third party add-ons offering cookie
management assistance. For example, you can instruct your browser, by changing its options,
to stop accepting cookies or to prompt you before accepting a cookie from the website you
visit. Click “Help” in the toolbar of your browser for instructions. Please note however
that deleting any of our cookies or disabling future cookies or tracking technologies may
prevent you from accessing certain areas or features of our Websites and Solutions, or may
otherwise adversely affect your user experience.
Please note that we do not change our practices in response to a "Do Not Track" signal in the HTTP header from a browser or mobile application.
Communications from Us
Service Messages: We may contact you with important information regarding our Services, or your use thereof. For example, we may notify you (through any of the means available to us) of changes or updates to our Services, transactions performed, payment issues, service maintenance, verification requests, etc. You will not be able to opt-out of receiving such service messages.
Promotional Messages: In addition to communications that are an inherent part of our Services, occasionally we may also use your contact information to contact and notify you about new services and special opportunities or promotions we think you will find valuable. We may contact you through e-mail, phone (including text messages), through the Services, social media channels or any other contact methods available to us, including with the help of our Third Party Services.
Accordingly, we shall be entitled to call you or send you promotional content or messages by e-mail, SMS, direct text messages, web chat, marketing calls, and similar forms of communication.
If you wish not to receive such promotional messages or calls, you may notify us at any time by e-mailing us at [email protected], or by following the "unsubscribe", "change preferences" or "stop" instructions contained in the promotional communications you receive.
How Do We Safeguard Your Personal Data?
We have implemented security measures designed to protect your Personal Data held with us and our Third Party Services, including physical, procedural and electronic measures. Among other things, we offer HTTPS secure access to our Services; we use industry standard SSL/TLS encrypted connections to protect the transmission of data that we believe in good faith to be of a sensitive nature; we use encryption tools to protect such sensitive data stored with us; we regularly monitor our systems for possible vulnerabilities and attacks, and seek new ways and tools for further enhancing the security of our Services and the integrity of the Personal Data that we hold.
Please note however, that regardless of the measures we take and the efforts we make, we cannot and do not guarantee the absolute protection and security of any Personal Data stored with us and/or with any third parties as described in Section 5 above.
If you have any questions regarding the security of our Services, please feel free to contact us at [email protected]
The Rights and Choices Available To You Regarding Your Personal Data
If you wish to exercise your right to access Personal Data, to
request us to make corrections to your Personal Data that you
have stored with us, to object to any form of processing, or
to have such Personal Data deleted or exported in
a portable copy, please send us an e-mail
to [email protected], and we will respond within a reasonable
timeframe and in accordance with applicable laws and regulations.
Please note that due to applicable gambling and tax regulations, we are required to retain certain Personal Data even following a deletion request, for the legally required period.
How Long May We Keep Your Personal Data?
We may retain your Personal Data for as long as your player account is active or as otherwise needed to provide you with our Services or comply with applicable laws and regulations.
We will typically retain your Personal Data even after you deactivate your account or
cease to use our Services, as reasonably necessary to comply with our legal
obligations, to resolve and protect ourselves against disputes regarding any of our
players, to prevent fraud and abuse, to enforce our agreements and/or protect our
When we no longer need your Personal Data for such purposes, we securely delete or destroy it.
We may amend this Policy at any time by posting a revised version on our Services. The revised version will be effective as of the published effective date. If the revised version includes a substantial change, we will provide you with 30 days’ prior Policy via any of the communication means available to us, or by posting Policy of the change on the Services. After this 10-day Policy period, all amendments to this Policy shall be deemed accepted and effective on both you and us. Except if and as stated otherwise, our most current Policy shall apply to all Personal Data described in such Policy.
While our Services may contain links to other websites or services, we are not responsible for such websites’ or services’ privacy practices, and encourage you to be aware when you leave our Services and read the privacy notices of each and every website and service you visit. This Policy does not apply to such linked third-party websites and services.
Our Services are not intended for use by children under the age of 18. We do not knowingly collect Personal Data from minors under the age of 18 and do not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors are not using the Services. In the event that it comes to our knowledge that a minor is using the Services, we will prohibit and block such player from accessing the Services and will make all efforts to promptly delete any Personal Data stored with us with regard to such player.
This Policy was written in English and may be translated by us into other languages for your convenience. If a translated (non-English) version of this Policy conflicts in any way with its English version, the provisions of the English version shall prevail.
please contact us at [email protected]
Our Data Protection Officer may be contacted at [email protected]
If you are not satisfied with the response you receive from our Privacy team or Data Protection Officer, you may escalate concerns to the applicable data protection authority in your jurisdiction.
Effective Date: May 15, 2018