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Privacy & Management of Personal Data

Scope and Application

This Privacy and Personal Data Management Policy (the “Policy”) explains how Rkgg processes Personal Data collected from users in connection with the Services offered by Rkgg. It applies to the Websites, applications, games, betting and other services provided by Rkgg that link to this Policy, regardless of access method or device.

Definitions

  • Data Controller: the natural or legal person who determines the purposes and means of processing Personal Data. For the purposes of this Policy, Rkgg acts as the Data Controller.
  • Data Processor: a natural or legal person or entity that processes Personal Data on behalf of the Data Controller.
  • Personal Data: any information relating to an identified or identifiable natural person.
  • Processing: any operation or set of operations performed on Personal Data, whether by manual or automated means.
  • Profiling: any form of automated processing of Personal Data used to assess or predict aspects concerning a person.
  • Data Subject: the individual to whom Personal Data relates.

Data Controller and Contact

Rkgg is the Data Controller for Personal Data processed under this Policy. The Data Protection Officer can be contacted at privacy@rkgg or by mail at: Privacy Office, Rkgg, 1 Innovation Way, Gaming District, Country. You may lodge a complaint with the competent supervisory authority as provided by applicable law.

Security and Data Protection Principles

Rkgg implements appropriate technical and organizational measures to safeguard Personal Data. In transit, Personal Data is protected with TLS 1.2 or equivalent. At rest, Personal Data is stored on encrypted drives. Access to systems is controlled, and firewalls and intrusion detection measures are maintained. We verify user identity before exchanging Personal Data and maintain audit logs where required to support security and compliance.

Processing on the Basis of Legitimate Interests

Where Processing is not required by contract or by law, Rkgg may rely on legitimate interests to maintain accurate customer records, provide and improve Services, and detect and prevent fraudulent activity. We will balance these interests against your privacy rights and provide a mechanism to raise questions or objections. AML compliance and adherence to applicable Curacao law are treated as legitimate interests to operate lawfully.

Processing on the Basis of Consent

Consent is used where no other lawful ground applies or where required by law for direct marketing or other purposes. You may withdraw consent at any time using the same method by which it was provided. Withdrawal does not affect Processing conducted prior to withdrawal, and we will determine whether any other lawful basis applies and notify you if so.

Categories of Personal Data Collected

  • Contact data (name, address, phone number, email).
  • Identity data (date of birth, government identifiers, photographs).
  • Activity data (login activity, bets, winnings, deposits/withdrawals, analytics, page views, cookies, communications with support).
  • Technical data (IP address, device identifiers, browser and OS information).
  • Financial data (payment method, banking information, source of funds).
  • Marketing and education data (opt-in status, marketing preferences, consent records).

Purposes of Processing and Legal Basis

  • Set up and verify a user account; prevent impersonation. Legal basis: Contractual Necessity; AML/KYC obligations.
  • Provide security for payment and personal data; prevent fraud. Legal basis: Contractual Necessity; Legitimate Interests.
  • Manage the ongoing relationship and deliver Services, including customer care. Legal basis: Contractual Necessity; Legitimate Interests.
  • Direct marketing and educational content (where permitted or with consent). Legal basis: Consent or Legitimate Interests as applicable.
  • Profiling for fraud detection and AML compliance; no automated decisions with legal effect, with human review where required. Legal basis: Legitimate Interests; AML obligations.
  • Responsible gaming monitoring and risk assessment. Legal basis: Legitimate Interests and regulatory obligations where applicable.

Data Retention

Rkgg retains Personal Data only for as long as necessary to fulfill the purposes described herein and to comply with applicable laws and regulations. Transactional data (bets, deposits, withdrawals) are retained for a minimum of five (5) years from the date of the last transaction. When data are no longer required, they are securely deleted or anonymized in a manner that prevents reconstruction.

Cookies and Tracking Technologies

We use cookies and related technologies to collect information automatically during your use of the Services. Cookies are categorized as strictly necessary, performance, analytics, functionality, and advertising. We obtain consent for non-essential cookies where required by law and provide mechanisms to manage or disable cookies through in-service controls or browser settings.

Recipients of Personal Data

We may disclose Personal Data to service providers performing processing on our behalf (for IT, payments, customer support, analytics, and security), to regulators when required by law, and within corporate groups for service delivery. Recipients must process Personal Data in accordance with this Policy and applicable law, and safeguards must be in place for cross-border transfers where applicable.

Profiling and Automated Decision Making

Rkgg may employ profiling and automated processing to detect patterns, assess risk, and verify identity in compliance with AML directives. No decision with legal or similarly significant effect is made solely by automated means; human involvement remains a component of such decisions.

Your Rights as a Data Subject

You have rights to access, rectify, erase, restrict, or object to Processing; data portability where applicable; withdraw consent where required; and lodge a complaint with the competent supervisory authority. We will respond in a timely fashion and within the time limits set by applicable law.

Exercising Your Rights

To exercise rights, submit a request to the Privacy Office using the contact details above. Identity verification and any information necessary to locate the Personal Data in question may be required. We will acknowledge receipt and provide information on actions taken and expected timelines.

Changes to this Policy

Rkgg may update this Policy to reflect changes in law or our processing activities. Material changes will be published on our site and, where required, notified to you in a timely manner.