1. What is a Cookie Policy?
This Cookie Policy describes how we and our partners (third-party service providers, advertising, and marketing partners) use cookies and similar technologies to recognise you when you visit our Website. It explains what these technologies are and why we use them, as well as your rights to control our use of them.
For information about how we collect, use, and keep your data secure, you may read our Privacy Notice.
2. What are Cookies?
Cookies are small pieces of files that are placed on your computer, mobile device, or tablet (all referred to as the “Device”) which you use to access our Website, or mobile app. They allow your browser to remember information about your browsing history and preferences, help us to facilitate and make your interaction faster and easier, as well as provide reporting information. Similar to cookies, we also use other tracking technologies, like web beacons, tracking pixels, digital fingerprints, which in many instances are reliant on cookies to function properly, and so declining cookies will impair their functioning (all together referred as “Cookies”). For example, web beacons, which are used for similar purposes are small graphic images embedded in web pages, which may be used to count the number of visitors to the Website, to monitor how users navigate the Website, and to count content views.
We leverage advertising partners, hosting platforms and demand-side platforms to provide and facilitate the use of these technologies.
3. Why do we use Cookies?
● Authentication. We use Cookies to distinguish you from other users of our Website, to verify your account and determine when you’re logged in so that we can make it easier for you to access our Services and show you the appropriate experience and features. For example, we use Cookies to keep you logged in and to navigate between Website pages.
● Security, Website and Services integrity. We use Cookies to help us keep your account, data and the Services safe and secure, to protect you from fraud, to identify and impose additional security measures when someone may be attempting to access your account without authorisation, to identify the browsers used by malicious actors and to prevent cyber-security attacks. For example, a unique identifier for your browser that, amongst other things, helps us identify trusted browsers where you have logged in before.
● Advertising, recommendations, insights and measurement. We use Cookies to help us identify your preferences and making sure the content and data you see are personalized and correct, to show ads and to make recommendations to people who may be interested in our products and/or services, to help measure the performance of our ad campaigns, access to Website and use of our Services by the same person in different browsers and Devices. Please, note that we do not aim to target minors, or people who are under the permitted age in specific jurisdiction to use Services. For example, Cookies may help us to understand and provide more relevant content and develop features that are likely to be interesting to our customers. We use Cookies during your visit to the website. These Cookies will store the information gathered during your visit, allowing us to identify you as a visitor and provide the services you desire. We might make use of this information to improve your experiences on our Platforms and understand your online preferences better.
● Website features and Services. We use Cookies to enable the functionality that helps us provide our Services, to provide you with the content relevant to your location. For example, to see the Website in your preferred language or to show the games played or the sports selections on the basis of your previous gaming activity with us.
● Performance. We use Cookies to run the functionality of the Website optimally by tracking your activity, to provide you with the best experience possible. For instance, to route traffic between servers and understand how quickly our Website loads for different people.
● Analytics and research. We use Cookies to better understand how people access our Website, and use our Services, so that we can improve them. Like, to analyse which products people find as the most engaging, and to identify features that could be improved.
● Third-party websites and apps. Our business partners may also choose to share information with us from Cookies set in their own websites’ domains, which you are visiting. Unlike Cookies that are set on our own domains, these Cookies aren’t accessible by us, but they serve the same purposes of content personalization, performance measurement, analytics and safer experience.
4. What type of Cookies do we use?
“First-party Cookies” are Cookies set by our Website.
“Third-party Cookies” are Cookies set by parties, other than by us, which is the Website. These Cookies enable third-party features or functionality to be provided on or through the Website (like, advertising, interactive content and analytics).
Both First-party Cookies and Third-party Cookies may be divided into the following categories:
● “Strictly Necessary Cookies” are required for technical reasons in order for the Website to operate, and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these Cookies, but some parts of the site will not then work. These Cookies do not store any personally identifiable information.
● “Functional Cookies” enable the Website to provide enhanced functionality and personalisation. They may be set by us or by our third party service providers. Although these Cookies are non-essential, without their acceptance of some or all of our Services, Website may not function properly.
● “Performance Cookies” allow us to count visits and traffic sources so we can measure and improve the performance of our Website. They help us to know which pages are the most and the least popular and see visitors’ activity across the Website. These Cookies collect aggregated data, which is anonymized. If you do not allow these Cookies we will not know when you have visited our site, and will not be able to monitor its performance.
● “Targeting Cookies” may be set through our Website by our advertising partners. They may be used by those companies to build a profile of your interests, to make advertising messages more relevant to you and show you relevant adverts on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device. Targeting Cookies include Social networking Cookies, which are used both for advertising and to enable you to share pages and content of our Website that you find interesting through third parties social platforms. If you do not allow these Cookies, you will experience less personalised advertising.
● “Analytics Cookies”, including but not limited to Cookies served by Google Analytics, which help to collect limited data directly from your browsers to enable us to better understand your use of the Website, or how effective are our marketing campaigns, including making use of the demographics and interests reports services provided by Google Analytics, helping us customise our Website for you. Further information on how Google collects and uses this data is available on Google’s website at: https://www.google.com/policies/privacy/partners/. You can opt-out of all Google supported analytics within the Services by visiting https://tools.google.com/dlpage/gaoptout.
5. How to manage your Cookie preferences?
Both when you visit our Website for the first time and afterwards, you have the right to decide whether to accept or reject Cookies fully or partially, except Strictly Necessary Cookies, which are essential to access the Website. When managing your choices, please mind that “opt-in” means accepting Cookies and “opt-out” means rejecting Cookies. At any time you can set or amend your web browser controls to accept or refuse Cookies.
We understand the value of your personal information and the need to handle it carefully. Therefore, we would never sell it to anyone or grant unauthorized access to your personal data.
Please, be mindful when managing your cookie preferences. Rejection of Cookies fully or partially (except Strictly Necessary Cookies which may not be rejected) may limit your access to some functionality and areas of our Website. Therefore, to enjoy the full performance and the best user experience on our Website acceptance of all the Cookies is recommended.
You can manage your Cookie preferences by activating the appropriate setting on your Device, or in your Web-browser, as follows:
Google Chrome
Firefox
Safari
Opera
Microsoft Edge
You can choose not to receive interest-based advertising from us in your current browser by going to optout.aboutads.info or www.networkadvertising.org/choices . On your mobile device, you can enable the “Limit Ad Tracking” setting on your iOS phone or the “Opt out of Ads Personalization” setting on your Android phone. You can also opt out of Google Analytics by installing Google’s opt-out browser add-on and opt out of interest-based Google ads using Google’s Ads Settings.
6. How to delete Cookies?
If you do not wish to accept Cookies connected with your use of our website, you may delete, block, and disable Cookies from your Web-browser.
We advise that you erase any Cookies that have been saved on your Web-browser if you do not want to continue to receive relevant targeted advertising. You may choose to block advertising or content based on Targeted Cookies by visiting http://www.youronlinechoices.com.
Alternatively, you can visit www.aboutcookies.org in order to obtain information on deleting or controlling Cookies.
7. How to contact us and get aware of any updates to this Cookie Policy?
We may regularly update this Cookie Policy on our Website. These updates take effect immediately. Check the date at the top of the Cookie Policy for the latest version. By continuing accessing our Website after the updates have been introduced you accept the revised Cookie Policy.
If you have questions or complaints about this Cookie Policy you may contact our Data Protection Officer by sending an email to privacy@coolbet.com or privacy@gan.com. We will get back to your request as soon as possible, but no later than within 30 days of sending us the request.
1. What is a Privacy Notice?
Coolbet’s (“we”, “our”, “ours”) mission is to give our customers (“you”) a unique player experience through innovation, top-class products, transparency and customer care. Please read this Privacy Notice carefully so that you understand what information we collect and retain about you, how it is being used and for what purpose, with whom it may be shared, and how you may exercise your rights and choices with respect to our processing of your Personal Data. This Privacy Notice also describes the measures we take to safeguard your Personal Data and how you may contact us if you have any questions about our privacy practices.
In this Privacy Notice and our Cookie Policy, we outline various choices available to you regarding the Processing of your Personal Data, which includes
“Personal Data” means any information about you that identifies you or makes you identifiable directly or indirectly through means that can reasonably be used.
“Processing” of your Personal Data includes any operation or set of operations which is performed regarding your Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction of your Personal Data.
2. Who Collects and Manages Your Personal Data?
Polar Limited (registry code: C 87805; license number: MGA/B2C/681/2019; address: Regent House, Office 21, Bisazza Street, Sliema SLM1640, Malta; e-mail: privacy@coolbet.com) will be the controller (the “Controller”) of your Personal Data provided to, collected by or for, or Processed in connection with our Services. This means that we decide why and how your Personal Data is used when you use our Services. We determine the purposes for using your data, such as improving our services, and the methods by which we process it, always ensuring your privacy and data protection rights are respected.
3. How to contact us?
If you have any questions about this Privacy Notice or concerns about how we manage your Personal Data, please contact our Data Protection Officer by e-mail at privacy@coolbet.com. We will endeavour to answer your questions and advise you of any steps taken to address the issues raised by you.
4. How and why will we Process your Personal Data?
We are an online gaming company, which offers services, including, but not limited to Sportsbook, Casino and Poker.
This Privacy Notice applies to our Coolbet branded website https://coolbet.co/ (“Website”), which is owned by third-party providers, but offers Services, which are rendered by Coolbet (“Services”). As a Visitor of our Website or User of our Services, the collection, use and sharing of your Personal Data are subject to this Privacy Notice and Cookie Policy, including their respective updates. If you disagree with how we handle Personal Data as described in this Privacy Notice, please refrain from using our Website or using our Services.
As a company that highly values our customers’ trust, we adhere to the principles of transparency, fairness, and lawfulness. We only process your Personal Data when we have a legal basis for it and to the extent that is necessary for a particular purpose. If you want to get acquainted yourself with all the terms, definitions and legislative requirements concerning your privacy and the Processing of your Personal Data, you can consult the Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data of the European Parliament and of the Council of 27 April 2016 (“GDPR”) and Personal Information Protection and Electronic Documents Act of Canada (“PIPEDA”).
How we use your Personal Data depends on the Services you choose, preferences expressed through the Cookie banner, and other legal bases that allow us to process your Personal Data. Our goal is to deliver the best user experience to you. We may process your Personal Data, with the help of automated systems where necessary, to personalise and improve your experience using our Services, and to maintain and offer exciting features.
5. What are the legal bases and purposes of your Personal Data Processing?
In compliance with the GDPR and other applicable data protection laws, we process your Personal Data only when there is a legal basis to do so.
Legitimate interest: Article 6(1)(f) of GDPR
We may use your Personal Data for our legitimate interests or those of a third party, provided these interests do not infringe on your rights, freedoms, or interests. This means we carefully consider and balance any potential impact on you against our interests before Processing your Personal Data. For example, we may Process your Personal Data for the purposes of analytics, research and Service development to provide You and others with a better, more intuitive and personalized experience, to drive loyalty, growth and engagement with our Services.
You have the right to object to processing based on our legitimate interest, and you can do this by contacting us by e-mail at privacy@coolbet.com. However, there are instances where our legitimate reasons for processing your Personal Data may override your rights, in which case we will continue with the processing as necessary.
Your consent: Article 6(a) of GDPR
You can voluntarily give your consent (opt-in) for receiving our newsletter by filling in your name, email and phone number when registering on the Website. You can withdraw your consent at any time by contacting us via e-mail at privacy@coolbet.com.
● For communications. We may contact you about marketing, surveys, analytics, and reminders through email, SMS, phone calls, or Website messages unless you opt-out.
● For Marketing and Advertising. If you’ve opted into receiving our newsletter we shall send you tailored marketing communications and news about our Services, which may be both free-to-play and for money, related to other Coolbet-branded websites. We may analyse the effectiveness of different past marketing campaigns about you to deliver even more personalised offerings and suggestions. When You opt-in to receive email then it has to be clearly understood that we use both analytical and automated tools to Process your Personal Data. However, our Processing activities do not involve profiling or automated decision-making that could have legal or similarly significant effects on you.
6. What Personal Data do we Process and how do we collect it?
Registration data
To use our free-to-play Services you use our Register form, where you provide us with your Personal Data, including your name, email address and mobile phone number and subscribe to receive promotions from Coolbet or its associated partners (campaigns, services and offers) via email. The legal basis for processing this data is your consent obtained through the sign-up process.
Service Use
We Process Personal Data related to your usage of our Services, which includes, but is not limited to:
● Logs, your Device and Location. Our servers automatically log usage data when you interact with our Website or Services. This includes actions like viewing content, clicking on ads, performing searches, installing or updating our apps, and sharing our services on social media or elsewhere on the Internet. We process information such as the URLs you visit, your Internet Protocol (IP) address, timestamps, details about your device (including type and operating system), and your location based on your phone settings. This data helps us to understand and improve user interactions with our services.
● Cookies and Other Technologies. As further described in our Cookie Policy, we use cookies, tags, cookies, pixels, web beacons and similar technologies on our Website to recognize you and/or your device(s). Cookies are small text files placed by the Website and stored on your device. When you visit our Website for the first time, we seek your consent to use cookies, except for those strictly necessary for the Website’s operation. For detailed information about the cookies we use, their purposes, and how you can manage your cookie preferences, please refer to our Cookie Policy. You can control cookies through Your browser settings and other tools. You can also opt-out from our use of cookies and similar technologies that track Your behaviour on the sites of others for third-party advertising.
● Analytics Data. We process analytics data to have a better understanding of how you use the Website and our Services. The legal basis is our legitimate interest in learning how to offer better Services and user experience to you.
7. With Whom We May Share Your Personal Data?
We may share your Personal Data with the following recipients:
Internally with authorised employees, contractors, consultants, agents, affiliates, and subsidiary companies within our business group or linked to our parent company for professional purposes. Access is strictly limited to those who need it to perform their duties.
In the event of a change in control or sale, merger, joint venture, or preparation for these events, any acquiring entity or partner will have the right to continue processing your Personal Data as outlined in this Privacy Notice.
Authorities and other public and private entities may be needed to comply with our legal obligations.
Third-party providers, as necessary to deliver, manage, and improve our Services. We carefully select these providers to ensure they comply with applicable laws, protect your data, implement necessary security measures, and delete your data from their servers upon our request. Specifically, we may transfer your Personal Data to the following third-party providers:
● Email Provider(s). We share your email address and the User ID with our email provider for automation of our email processes, for analytics, marketing or advertising.
● SMS Provider(s). We share your mobile phone number with the SMS provider(s), that we engage in cases when you have opted-in to receive marketing and/or advertising communications.
● Google Analytics and other providers for analytics. Upon your consent, your Personal Data may be shared to provide us with insights and analytics to create reports and statistics on your performance.
● Other Service Providers. In case we use other service providers to help us provide our Services and perform our legal obligations (e.g., maintenance, analytics, analysis, marketing and development). Such Service Providers will have access to your Personal Data as reasonably necessary to perform these tasks on our behalf and are obliged not to disclose or use your Personal Data for other purposes.
8. Do We Transfer Your Personal Data Outside the EU/EEA Region?
We never sell your Personal Data, nor do we publish it publicly on the Internet or elsewhere. As our partners and providers operate globally it may be necessary to transfer and store your Personal Data outside the country from which you access our Services, including outside the EU/EEA. For example, your Personal Data may be Processed and stored by companies operating outside the EU/EEA who are our affiliates or provide us with certain services, like cloud storage, or hosting of the Website on computer servers. We take all reasonable measures to ensure that your Personal Data remains safe when transferred and stored.
In case your Personal Data is transferred outside of the EEA, we will only transfer your Personal Data if:
● the country to which the Personal Data will be transferred has been granted a European Commission adequacy decision, confirming that such third country provides adequate protection for your Personal Data; or
● upon your explicit consent; or
● transfer under legal justifications, supported by strong safeguards like EU standard contractual clauses or binding corporate rules approved by an EU authority.
9. What Security Measures Do We Take to Safeguard Your Personal Data?
While no data transmission or storage can be guaranteed to be secure, we have taken appropriate technical and organizational security measures to help protect your Personal Data and to prevent it from being accidentally lost, used, altered, disclosed, destroyed, or accessed without authorisation. These measures include policies, confidentiality agreements with third parties, secure development practices, due diligence of service providers, and products and services that may be used.
We have implemented security standards to safeguard and protect your Personal Data and we regularly monitor our systems for possible vulnerabilities and attacks, including penetration testing, educating our employees by trained professionals and using all proportionate security measures for our network and infrastructure. Also, we have put in place procedures to deal with any suspected Personal Data breaches and will notify you and any applicable regulator of a breach where we are legally required to do so. We use cryptography to ensure the confidentiality, authenticity and/or integrity of your Personal Data at rest and data in motion.
Please take into account that we cannot guarantee the absolute security of your Personal Data and there is no guarantee that it may not be accessed, disclosed, altered or destroyed by breach of any of our physical, technical or managerial safeguards.
10. How Long Do We Keep Your Personal Data?
We will retain your Personal Data for as long as necessary to fulfil the purposes we collected it for. Once your consent is withdrawn, we will promptly delete your email address from our records, unless we are legally required to retain it for a longer period.
11. What rights regarding your Personal Data do you have?
You have the right to access your Personal Data, the right to correct, update or request the deletion of your Personal Data, the right to restrict the processing of your Personal Data, the right to object to the processing of Personal Data, the right to data portability and the right not to be subject to automated decision-making (with no human intervention), including profiling.
Moreover, you have the right to file a complaint to the Maltese Office of the Information and Data Protection Commissioner: idpc.info@idpc.org.mt, phone +356 2328 7100.
To exercise your rights, submit a request with your ID or digital signature, specifying the right, date, and contact information. We will consider your request in accordance with Applicable Laws. Please contact us at privacy@coolbet.com for help. We shall respond within 30 days, free of charge. Exercising one right does not affect your ability to exercise others.
12. Updates to this Privacy Notice
We may regularly update this notice on our Website. These updates take effect immediately. Check the date at the top of the notice for the latest version. For major changes affecting how we handle your Personal Data, we will provide notice through our Services, or by other means, to allow You to review the changes before they become effective.
You acknowledge that your continued use of our Services and/or visiting of our Website after we publish or send a notice about our revised Privacy Notice means that you accept such change and that the collection, use and sharing of your Personal Data is subject to the updated Privacy Notice.
