What is data processing?
As an example, take the account registration process in our App: you are required to provide your date of birth, which we collect and use to verify if your age is above the minimum age required in order to be allowed to use our services. This means that we process your date of birth, which represents personal data.
While we do so, we make sure to observe all legal requirements concerning data protection, including but not limited to the EU General Data Protection Regulation (“GDPR”), the Austrian Data Protection Act and, where applicable, the California Consumer Privacy Act of 2018 (“CCPA”).
What personal data do we process?
To provide our services through the App, we must process your personal data. The types of personal data we collect depend on your activities and how you use our services, and are as follows:
Data you provide while creating an account or in connection with the account, which includes, but is not limited to:
- Name and surname;
- E-mail address;
- Home address;
- Phone number;
- Date of birth;
App activity data, which includes, but is not limited to:
- Device information;
- Source and destination data;
- Username, player ID, account username and password, gaming transactions;
- Online payments data;
- Data disclosed to our Customer Service so we can provide and improve our support (including through e-mails and phone calls).
- The above activity data corresponding to guest users is processed in anonymous mode.
Data provided by third parties who receive your data when you visit or use their services, and they already have your permission to share your data with us because we demand our partners have lawful rights to collect, use and share your data before providing it to us. We include here, for example, social media and, where applicable, different mobile applications.
Please note that you are not legally required to make your personal data available to us. Nevertheless, in order to be able to register an account through our App, you have to provide all the information marked as mandatory. Without this information, we are not able to enter into a contractual relationship with you, which means you are not able to benefit from our services.
Why do we process your personal data?
Our main purpose for processing your personal data is to provide our services to you. More precisely, to fulfil this purpose, we have to process personal data in order to:
- Make our App functional and useful to you, including for setting up and using your account.
- Make sure your personal data is accurate, first for your own protection, but also for age verification, preventing fraud, cheating, reducing business risks and protecting the integrity of our games. For this, a certain degree of semi-automatic profiling might be used, based on your registration and gambling activity data.
- Fulfil the App Terms and Conditions.
- Process online payments with third-party payment providers and/or financial institutions.
- Provide the best customer support to you.
- Protect your safety and public safety, privacy and security, as well as, if necessary, protect, enforce, or defend our legal rights, privacy, safety or property, or for business risk management purposes.
- Improve the security, services and features of our App. This might entail providing partially customised services, features and recommendations, conducting research and surveys, asking for your optional feedback, and providing internal trainings.
- Conduct and complete any potential organisational business changes, such as mergers, transfers or sale of assets. In a case of selling all or part of the business or assets, or if we are involved in a merger or transfer, we might disclose and transfer your personal data to the other parties involved in the business transactions. Should such case arise, you will be duly and timely informed.
- Optionally, and only with your specific consent: to provide customised marketing communications fitting your interests and expectations, and/or direct marketing communications that have a generic nature or are partially based on your gambling journey, and/or can be customized, via: e-mail, instant messages, and (where applicable) chats, SMS and telephone or social media.
We keep all data processing as simple and limited as possible, and take it upon us not to use your personal data for anything other than the purposes specified above. In case the data is processed for other purposes and/or by other parties, you will be informed.
On what legal grounds do we process your personal data?
Our legal basis for processing your personal data is highly dependent on the purpose of the processing activity, and may vary depending on the service you are using.
In general, we process your personal data on the following legal grounds:
- Fulfilling our contractual obligations to you. We process your personal data to fulfil our obligations described in our Terms and Conditions, as processing your data is necessary for the performance of our App. Otherwise, we wouldn’t be able to provide our services, and you wouldn’t be able to enjoy the entertainment experience in our App.
- Our legitimate interests. We process your personal data based on our legitimate interests, which include business risk management and the protection of the integrity of our products. In processing data based on legitimate interest, we commit to implementing all appropriate measures to protect your rights related to your personal data, and to ensuring the balance between our interest and your rights in such a way that your data is processed within the strictly necessary limits.
- Your consent. We process your personal data only if we have your consent for the specific processing activities where consent is needed. Without your consent, we will be stopped from further processing your personal data based on this particular legal ground, but this will not affect the lawfulness of processing based on your consent before consent was withdrawn. Without your consent, we will not provide generic and/or customized marketing communications.
How do we process your personal data?
We process your personal data with partially or fully automated electronic means, and protect it with adequate security measures, established and maintained according to the highest international standards for data security. The activities that may cause significant legal effects, such as decisions based on profiling, always involve a human intervention and/or final decision.
Do we share your personal data?
We only share your personal data with third parties when this is required to perform the services we are obliged to provide you with, when you have given us your consent for the sharing of your personal data, or when we are obliged to for legal reasons, by court order, or at the request of another official authority.
In other words, the data can be shared in compliance with these limits:
- With our employees who are responsible for the processing and safekeeping of the data, and whose employment relationship with us is bound by a confidentiality obligation.
- With our parent company, our sister companies and other third-party providers, who help us provide our services according to our Terms and Conditions, such as, but not limited to, payment services providers, marketing services providers and legal services providers.
Third parties’ access to your personal data is limited to the information necessary to perform their function on our behalf or as required by law. The sharing of data is subject to confidentiality and sufficient safeguards regarding the lawful and secure processing of your personal data by our partners.
Is your personal data transferred abroad?
Data is transferred with no restrictions within the European Economic Area (the “EEA”). We shall not transfer your personal data to countries outside the EEA unless appropriate safeguards for the protection of your data are in place, following the high standards for data protection established by the GDPR.
Having in mind some of the highest standards for data protection worldwide, the European Union, through the European Commission, recognizes certain non-EEA states as providing an adequate level of data protection. We, too, deem these countries safe for data to be transferred to, in justified cases.
For transfers of data to countries whose safeguards for data protection are not considered adequate by the European Commission, we take it upon ourselves to put in place appropriate safeguards to protect the data in compliance with data protection regulations, by concluding our contractual relationships with our partners in such a way that they guarantee an acceptable level of protection for the data we transfer to them.
Under these conditions, the personal data you provide to us may be processed outside of the EEA to deliver some of the App services, as follows:
- Some data may be processed in the USA, depending on the payment provider chosen by you, and the activities undertaken by the payment provider. More information on how payment providers process your personal data is available in their respective Privacy Policies.
How long do we keep your personal data?
We seek not to keep your personal data for longer than it is necessary for fulfilling our contractual obligations to you, or for legitimate organizational purposes. The period for which we keep and/or use your data depends on aspects like the nature of the data, the reasons why it is collected and processed, and relevant legal or operational retention needs.
The following periods and criteria will apply, unless a different period is required or permitted by law, or we have reasonable belief that a different period is necessary:
What are your rights regarding the personal data you provide to us?
You have legal rights available to you with regard to data access, rectification, erasure, restriction of processing and objection to processing, as well as the right to data portability, amongst others. In addition, you can withdraw any consent you may have given to data processing at any time, and have the right to lodge a complaint with a supervisory authority.
Your rights regarding the personal data you provide to us are detailed below, and can be exercised through our Customer Service, at support@DiamondCashSlots.com.
Right of Access
You can request to receive clear and transparent access to information regarding the way we process your personal data. Some of this information is already provided in your account.
Right to Rectification
We try to keep your personal data accurate and up to date. You have the right to demand that we correct any of your personal data that is incorrect, and/or complete any personal data that is incomplete.
Right to Erasure
We will, on your request, delete the personal data belonging to you, which we process. However, please keep in mind that this may result in the termination of the services we provide to you, meaning that it is possible that you will not able to enjoy the entertainment experience in our App anymore.
Right to Restriction of Processing
In certain cases and for grounded reasons, you can demand that restrictions be placed on the processing of your personal data, which would permanently or temporarily limit our possibility to use your personal data, without having to delete it. However, please keep in mind that in such cases, we might not be able to continue providing our services in their entirety.
Right to Data Portability
Upon your request, we will provide an electronic copy of the personal data you provided to us at registration. To the extent that is technically feasible, we may transfer this copy to a different service provider.
Right to Object
In certain circumstances, such as when we process your personal data for direct marketing purposes, you have the right to object at any time. In other words, when the processing of your personal data is based on your consent, you can withdraw the consent you have given us at any time. This right can be exercised through specific means, such as opt-out mechanisms or un-subscriptions.
Right to Lodge a Complaint
You have the right to submit an official complaint to the supervisory authority dealing with data protection issues in your country, or to the Austrian Data Protection Authority (Datenschutz Behörde).
For British citizens, the supervisory authority dealing with data protection is the Information Commissioner’s Office and can be contacted here.
How can you exercise your rights regarding the personal data you provide to us?
All of your rights regarding the personal data you provide to us, with the exception of the right to lodge a complaint, can be exercised under normal circumstances free of charge, by sending a written request to our Customer Service at support@DiamondCashSlots.com.
We will do our best to respond to your requests as quickly as possible, but it may happen that other legal obligations or third-party rights and processes slow down the process. Depending on the nature of the request, you will receive an answer from us within a one-month term, which can be extended by two further months due to complexity or the number of requests we are dealing with at a certain time.
Please note that for justified reasons, we are entitled to deny your request, or to charge a reasonable fee if it is manifestly repetitive, unfounded or excessive.
Is your personal data secure with us?
We take security very seriously and are committed to observing the highest standards for the security of your personal data. We seek to implement and maintain our policies and processes in accordance with the most trusted international requirements for data security, and make sure that these are followed by all of our employees and collaborators, so as to prevent unauthorized or unlawful processing, accidental loss, destruction and damage. By doing this, we don’t eliminate all risks, but we do limit them significantly, decreasing the likelihood of data breaches. However, in the unlikely event of a data breach, not only do we seek to timely assess the incident and mitigate the impact, but also make sure to let you know if the data breach affects your personal data significantly.
Diamond Cash Slots may contain links to partner networks or third party websites/apps. If you follow a link to any of these websites/apps, note that they process your personal data beyond our control, according to their own privacy policies and terms. We advise you to check such policies and terms before accepting and submitting any information to them.
What personal information do we collect?
We are transparent about collecting your personal information, as required by the CCPA. What does this mean? It means that if we buy, rent, gather, obtain, receive or access in any way any kind of information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly to you or your household, you will know.
The categories of personal information we collect and the source where we obtain this personal information are described in the table below. In accordance with the CCPA, these categories of personal information do not include publicly available information or, in other words, information that is lawfully made available from federal, state or local government records.
Category of personal information
App activity data
(for example: alias, unique personal identifier, online identifier, IP address, device or WiFi location)
Personal information as defined in Cal. Civ. Code 1798.80(e)
(for example: name)
(for example: records of personal property, products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies)
Third parties such as but not limited to Google Analytics, Google Firebase, Adjust, Optimove.
Internet or other electronic network activity information
(for example: browsing history, search history, and information regarding your interaction with our App)
(for example: IP address)
(for example: this category includes such data as a result of your interaction with the device in order to play the game)
|Inferences drawn from the above||
Why do we collect your personal information?
We collect the personal data you provide to us in accordance with the CCPA and for the following reasons:
- To create your player account and allow you to enjoy the games in our App.
- To make our games and services available to you, in accordance with our Terms and Conditions.
- To improve and optimize our games and your entertainment experience in our App.
- To enable you to communicate with other players.
- To protect the safety and security of our games, App and company in general (for example, for debugging, auditing and testing).
- For research and development, including game and feature development, improvement, optimization and refinement.
- To protect our rights and property in connection with our games, as well as to comply with our legal obligations, resolve any disputes we may have with you or other players, and to enforce our agreements with third parties.
- To prevent fraud and/or potentially illegal activities, and to enforce our Terms and Conditions.
- For player services and support, in order to ensure a high quality standard for our products and to solve your inquiries.
- To provide you with in-game updates and notifications, new games and promotional offers that we think might be of interest to you.
- To manage and deliver customized advertising and marketing (for example, for user acquisition and direct marketing communications).
- To organize promotional activities or events sponsored or managed by us or our partners.
Do we share your personal information?
What are your rights regarding the personal information you provide to us, in accordance with the CCPA?
You have legal rights granted to you by the CCPA with regard to access to the personal information we collect, to the deletion of your personal information, to the opposition to the sale of your personal information, as well as non-discrimination due to the exercise of your rights under the CCPA, amongst others.
Your rights regarding the personal information you provide to us are detailed below and can be exercised by making a Verified Request via our App or via our Customer Service at support@DiamondCashSlots.com. More information about how you can make such a request can be found in the “How do I make a Verified Request?” section below.
Right to Know
You have the right to request that we provide information about the personal information we collect, use, disclose and sell, and/or have done so during the past twelve months. You may also request that we provide you with an electronic copy of the following:
- The categories of personal information we collect and process.
- The categories of sources where we obtained your personal information.
- Our business or commercial purpose for processing your personal information.
- The categories of third parties with whom we share your personal information.
Please note that we can only provide you with this information if you send us a Verified Request, as explained in the “How do I make a Verified Request?” section below.
Right to Erasure (Right to be Forgotten)
You have the right to request that we delete the personal information that we have collected from you or with respect to you, subject to certain exceptions.
Once we receive and confirm your Verified Request in accordance with the “How do I make a Verified Request?” section below, we will delete your personal information and request that our service providers do the same unless a lawful exception applies.
Please note that we can only delete your personal information if you send us a Verified Request.
Right to Opt Out of the Sale of Your Personal Information
Right to Non-discrimination due to the Exercise of Your CCPA Rights
We believe in transparency and fairness, and take it upon ourselves to ensure that your rights according to the CCPA are not only theoretically granted, but also enforced. You are free and encouraged to exercise any of your rights as granted by the CCPA, and we will do our best to comply. Rest assured, exercising your rights will have no negative impact on your entertainment experience on Diamond Cash Slots. However, note that an erasure request leads to closure of your account.
You also have the right to designate an authorized agent to make a request and exercise your rights under the CCPA on your behalf. In order to be authorized to act on your behalf, your authorized agent will need to make a Verified Request as described in the “How do I make a Verified Request?” section below and provide us with written permission that proves they are entitled to act on your behalf.
How do I make a Verified Request?
In order to exercise your rights under the CCPA, you need to submit a Verified Request. There are two ways to send us a Verified Request:
- Via the Diamond Cash Slots App. This automatically passes on your Player ID to us and helps us verify your identity. Please mention “CCPA” in your request, so it is easier for us to understand your request.
- Via email to support@DiamondCashSlots.com. Our teams and/or Data Protection Officer shall address any request with the due attention. When you send us such a request, please include your Player ID and reference “CCPA”, so it is easier for us to understand your request.
In order for us to handle your request as soon as possible, please take into consideration the following:
- It is important that you include sufficient information to help us understand what you would like us to provide to you. For example, if you want us to delete your data, please tell us that. If you want to request a copy of your data, please tell us that.
- We may need to verify your identity before processing any request. We will try to limit the additional personal information that we collect in order to process your request.
- We may decline a request to exercise your rights under CCPA, particularly if we are unable to verify your identity, or if you make such a request more than twice within twelve months.
- We are entitled to charge you a reasonable fee if your requests are manifestly unfounded, excessive or repetitive.
We will do our best to respond to your request as quickly as possible, but it may happen that other legal obligations or third-party rights and processes slow down the process. Depending on the nature of the request, you will receive an answer from us within a 45-day term, which can be extended by 45 or 90 additional days due to complexity or the number of requests we are dealing with at a certain time.
If you are using an authorized agent, the authorized agent will need to personally submit a request, along with proof of the authorization.
Additional important information
Diamond Cash Slots is intended for those aged 18 or older for entertainment purposes only. We do not knowingly collect personal information from children under the age of 18. Children under the age of 18 should not use our App at any time. If we learn that a person under the age of 18 has provided personal information, we will take reasonable steps to delete such information as soon as possible.
We, Funstage GmbH, registered in Austria under number 258215d, assume the role of data controller responsible for the processing of your personal data through the Diamond Cash Slots App. In other words, we are the legal entity who determines why and how your personal data is processed in order for you be able to enjoy the full entertainment experience in our App.
British citizens who use our App may also contact us through our UK GDPR representative Greentube UK Limited, located at Canalside House, Floors 2 & 3, 6 Canal Street, Nottingham, NG7 7EX, United Kingdom, or via email at email@example.com.