Privacy Notice

Version 1.1, valid from 2021-10-28

Controller This policy describes our processing of personal data. SuprIsle Ltd. is the controller and responsible for the personal data being processed. This policy is applicable to us and any of our affiliates.

The following entities process personal data as part of the SuprNation Group (“SuprNation”):

SuprPlay Ltd.
SuprPay Ltd
SuprMedia Ltd
SuprIsle Ltd
SuprIsle Services Ltd

For the avoidance of doubt SuprPay Ltd (company number C-75650 and registered in Malta), may handle payments on behalf of Controller SuprIsle Ltd.

What information do we collect and why?

We mainly collect your information to offer you our online casino services. We also have certain legal requirements to collect information about you, such as documents for verifying your identity in connections to withdrawals or deposits. With this, we also need to save certain information about you for a number of years due to legal requirements, as for example bookkeeping. In addition, we process some of your information to send you promotions and offers in relation to our casino services that we think you are interested in, but you can of course choose to opt out of such marketing whenever you want to.

Information that you provide

This is information that you provide us when filling out forms on our websites or otherwise providing us your personal data, for example:

When you create an account: Name, gender, address, email, telephone number, date of birth, and information about your preferred currency.
When you are contacting us: Communications with customer support and service requests.
When you are making deposits or withdrawals: Payment methods (such as credit/debit cards), ”Know your Customer“ information (such as driver's license, bank account details, etc.)

Information that we collect about you

This is information that we collect about you without you yourself providing it to us, as

Activity on our websites (as what games you play, what transactions you have made, if you participate in competitions, what marketing you have seen etc.)
Information from third-parties for being able to fulfil our legal requirements (such as detecting fraud or money-laundering or in aid of responsible gambling measures).
Information about criminal records.

Why and how long we process your information

For us to be able to offer you our services, or later being able to follow up on customer support requests, we need to process your personal data. Below is described the overall purposes, on which basis we process your personal data and how long we store such data.

Purpose of processing	Legal basis for processing	How long do we save the information?
Your account on our website	Necessary for performance of contract	Until you choose to delete your profile
Marketing and advertising	Legitimate Interest (with soft opt-in)	1 year from consent or 1 year from opt out / end of relationship
Verifying your identity and performing security checks	Legal obligation	5 years, unless obliged to do so for an alternative (longer period) per court order as case may be
Responsible Gaming	Legal obligation	5 years
Permanent Exclusion	Legitimate interest	Indefinite
Fraud detection, anti-money laundering or other criminal activity	Legal obligation	Up to 5 years
Bookkeeping of transactions	Legal obligation	9 years from the transaction
Defence of legal claims brought by regulatory authority	Legitimate Interest	2 years unless obliged to do so for an alternative (longer) period per court order as the case may be

Withdrawing consent

Any consent to processing can be recalled at any time. Processed data based on consent will be removed unless there is another legal basis requiring us to continue processing such data. Withdrawal of consent is easiest done by changing your preferences in your profile or by contacting us.

Marketing and advertising

We may share information with advertising partners to send promotional messages to you or to show you customized content. We do this to be able to show you offers based on an evaluation of your interests and profile; and to understand how you interact with advertising. Please refer to the section on how we process information on our web site below, for information about cookies and other technologies that we and third parties use on our web site.

Profiling for direct marketing

When you visit our website, we use your activity on the site and your personal data (as age, gender and country of residence) to improve the selection of the games and offers that you see. We offer many different games and we would like to help you see what we think are the most relevant for you. We use the same principle when marketing though other channels, such as Facebook or the use of advertising banners. You have the right to object to this profiling and we must obtain your consent to use these technologies (which you can withdraw at any time), but we will still advertise on third party platforms like Facebook and Google, so you will still see our advertising, but it will not be customized according to what we think is the most interesting for you. You can read more about these technologies and how we use them in our Web Site Privacy Notice, here.

Who we share your information with

Service providers and others

We engage third parties to provide us with services (such as mail service providers, marketing providers or different payment providers). We always ensure that they maintain at least as much data protection for your data as we do.

Casino game providers

We use a number of different casino game providers, which are integrated to our websites. When playing these games, the service providers can access and process some of your personal data (such as your first name, last name, username, country, language, currency, IP address, contact details (phone or email) and your gender). You will be able to see the specific game provider when starting a specific game. You can find a list of current game providers below:

NetEnt
MicroGaming
Evolution Gaming
Play 'N GO
Yggdrasil
NYX Gaming
Quickspin
Scientific Games
Relax Gaming
No Limit City
Push Gaming
Big Time Gaming
Pragmatic Play
Thunderkick
Elk Studios
Blueprint
GIG Games
iSoftbet
Red Tiger Gaming

Payment solution service providers

We use a number of payments solution service providers. These payments solution providers will process a number of personal data, such as “Know your customer” and transactions history. The specific provider for handling of deposits or withdrawals is shown when making a withdrawal or deposit. We use the following payment providers and/or payment methods for deposits and withdrawals:

Citadel
Entercash
EPS
Euteller
GiroPay
iDebit
InstaDebit
MasterCard
Neteller
Paysafecard
Skrill
Sofort
Trustly
Visa
Zimpler
Bank ID
Swish
EcoPayz
Interac Online
Interac e-Transfer

Marketing service providers

We use a number of different service providers for marketing, Search Engine Optimisation and affiliation. Listed below are providers used for direct marketing purposes.

Link Mobility (text message service provider)
Adform (digital marketing platform)
Sendgrid (email services)
Facebook (marketing)

Fraud detection and anti-money laundering service providers

We use the following service providers for making sure that we follow the legal requirements in connection to gambling (such as fraud detection or anti-money laundering).

Sift (fraud screening)
Kount (fraud screening)
Emailage (email verification service)
Verifiera (service used in fraud and anti-money laundering related cases)
Aristotle (anti-money laundering related services including data checks and age checks, PEP and sanction screenings)
Risk Screen (fraud and anti-money laundering related services)
Public sources including government registries, databases (including Ratsit) and social media sites (including Facebook, LinkedIn etc.)

Customer service and support service providers

Providers used with regard to customer service and support

Olark (customer support chat solutions)
Groove (email ticketing solution)
OpEx (customer service provider)
Live Agent (outgoing calls)

Other service providers

Google (mail services, cloud hosting, analytics)
Slack (company communications)
Dropbox (cloud storage)
IGC, Gaming Innovation group (operator platform provider)
Regily (customer registration process)
SignZec/Credit Kudos (affordability checks)
Hooyu Investigate via 192.com (affordability checks)

Transfers to third countries

Some of our service providers are located in countries outside of the Isle of Man. The service providers that we use, located outside of the Isle of Man, have either adhered to the “EU-US Privacy Shield Framework” or have another legal safeguard in place. Further information can be provided to you by emailing dpo@suprnation.com

Your rights

Since we process your personal data, it is important that you know what rights you have as a customer. Below you'll find information about what rights you have and how they relate to the information that we process.

Right of access. You are entitled to request a copy of the personal data we have stored about you, and you are entitled to receive it free of charge. You can send a request for access to your information by email to dpo@suprnation.com
Right to rectification. If we have incorrect or incomplete information about you then you are entitled to request that we correct it at any time.
Right to erasure. If we process your personal data with your consent, and you choose to withdraw your consent, you have the right to request that that information be deleted.
Right to object. When we process your information on the basis of legitimate interest; or we process your information to create a profile for the purpose of determining your interests; you have the right to object to this processing. If you object to such processing, we must either show compelling legitimate reasons that overrides the reasons you stated, or stop the processing of your data.
Right to lodge complaints with the supervisory authority. If you are not satisfied with how we treat your personal data, we hope you tell us so that we can better manage your trust. Regardless, you always have the right to file a complaint at the competent supervisory authority. For more information about the Isle of Man Supervisory Authority, please visit their web site at https://www.inforights.im
Right to Data Portability. You have the right to move your data from SuprIsle and/or SuprNation to another organization of your choice or to download your data. Please email dpo@suprnation.com if you wish to exercise this right.

Security of your information

We put your personal integrity in first place and we are working actively so that your personal data is processed with utmost care. We take the measures that are needed to make sure that your personal data is handled safely and in accordance with this Notice and the General Data Protection Regulation and other applicable laws.

Children

Our services are not directed at any one under 18 years of age. We do not consciously collect personal data from people under the age of 18. If you are a parent of a child and become aware that your child has provided personal information to us, please contact us so that you may request to exercise your right of access, rectification, erasure, and / or objection.

How we process information on our web site

When you visit our web site we use certain technologies which allow us to process information about you and how you use our web site. Some of this information is to enable you to our offered games or to allow you to view the web sites in different languages. These types of technologies are considered as strictly necessary for us to be able to provide the service you have requested. Other technologies such as tools which allow us to see how you interact with our web site are not considered as strictly necessary to deliver the service you have requested and as such we must obtain your consent for us to use these technologies. Often these other technologies are referred to as cookies but other technologies such as local storage; transparent pixels or “web beacons”; javascript files which can send information from your device or computer, back to our servers; and information about your device; are also used. You can find more information about these specific technologies in our Web Site Privacy Notice, here.

Contact details

SuprIsle Ltd, a company incorporated in the Isle of Man, registered address at 1st Floor, Millennium House, Victoria Road, Douglas, IM2 4Rw, Isle of Man, with company registration number 018069V, is the personal data controller responsible for the processing of your personal data. If you would like to exercise any of your data subject access and other rights or have any other questions relating to this notice; or our activities, please contact our customer service through chat or email on the website, or contact our Data Protection Officer directly using the following email address: dpo@suprnation.com

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