This privacy policy describes how Crowd Entertainment Limited handles the information and data you share with us, in order to allow you to optimally use the gambling services provided through the website www.winboss.ro (“Platform”). Your personal data provided through the Platform, via the registration form available, as well as through any other means, or held by us from publicly accessible sources, will be processed in the manner and for the purposes established by this Privacy Policy.

The collection and processing of your personal data is carried out in accordance with applicable national data protection legislation, as well as with 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 and repealing Directive 95/46/EC (General Data Protection Regulation).

By accepting this Privacy Policy, you confirm that you have read, understood, and agreed with the way the Operator uses your personal data, as described below.

This Privacy Policy is periodically updated; each time we make a change, we will display it on our website https://winboss.ro/info/privacy-policy

Last update: 01.07.2022

The controller of your personal data is Crowd Entertainment Ltd., a company incorporated under the laws of Malta, with registration number C97517, having its registered office at 2 Spinola Road, St. Julians STJ 3014, Malta, hereinafter referred to as the “Operator” or “we.”

If you have specific questions about your personal information or how we use it, please contact us at: support@casino.winboss.ro.

The categories and amount of personal data we collect vary depending on the activities in relation to which the data is collected and include the following data obtained from you:

1. For the purpose of registration and participation in our gambling services, we will process the following categories of personal data: name, surname, personal identification number, age, date and place of birth, gender, address, postal code, email address, and phone number, payment methods used, citizenship, information about bets placed, betting tickets and winnings, in-game activity, financial transactions, activity on the platform. In order to participate in gambling, based on your choice, prior registration on our site is mandatory. Your personal data will be processed throughout the contractual relationship, i.e., while accessing gambling services.

We will also process any additional information you provide through the use of our services, such as forum, chat, comment section, or as a response to competitions, tests, and surveys. Your interactions with our support team (e.g., chat, phone conversations, emails) will also be processed.

1. For the purpose of complying with obligations established by special gambling legislation, as well as by the Anti-Money Laundering Act, and for the prevention and combating of terrorism financing, Accounting Law, and/or Fiscal Code, we will process the following categories of personal data: name, surname, personal identification number, age, date of birth, gender, address, citizenship, email address and phone number, financial data, payment method details, bets and stakes, as well as results of fraud prevention, abuse, and money laundering checks (including video recordings of identity validation and, where applicable, device information such as IP address, device identifiers, device type, screen resolution, operating system, and browser type, insofar as such data constitutes personal data under applicable law), interactions with the support team in any form. The processing is based on compliance with applicable legal obligations. Personal data will be processed for the period specified in the special legislation, but no longer than 10 years from the start of processing for each individual case.

2. According to Law no. 506/2004 regarding the processing of personal data and the protection of privacy in the electronic communications sector, you may be contacted by phone or email for the promotion of our services and products, even without prior consent. In all situations, you have the right to refuse at any time to receive such marketing communications. Your electronic data will be processed for the duration of the contractual relationship, except where you withdraw from it.

3. For distributing commercial communications regarding our services available on www.winboss.ro and yojicasino.ro, we may process the following personal data: name, surname, personal identification number, date of birth, gender, permanent address and postal code, citizenship, email address, phone number, transaction and gaming history, IP address, cookies, browsing data and gaming preferences, your voice and conversation recording when contacting us, as well as any other data. We will rely on our legitimate interest to keep you updated about products/services that may be of interest to you. We will design marketing campaigns so as to avoid excessive contact. If you do not want to be contacted, you may object to receiving such communications.

4. To personalize your experience (profiling), we may use your gaming history to offer personalized recommendations and products. For this purpose, we will process your personal data such as: name, surname, personal identification number, date of birth, gender, address and postal code, citizenship, email, phone number, transaction and gaming history, IP address, cookies, browsing data and behavioral data, as well as any other data. This processing is based on consent given during the registration process. Your data will be processed for the duration of the consent provided.

5. For ensuring the functionality of the Platform, we use cookies to ensure its proper operation, improve your user experience, and ensure the services are relevant for you. Personal data will be processed and stored for the period necessary to ensure the Platform’s functionality.

6. We also process and store your personal data (name, surname, phone number, email, bank account) for the purpose of potential complaints and claims. This processing is based on our legitimate interest or that of a third party. Data will be processed as long as necessary for this purpose, but not longer than 2 years from the date of registering each complaint or claim.

7. Additionally, we process:
 a) details of your participation in surveys, promotions, and communications through our services, including social media;
 b) device data used to access and use our services, e.g., mobile network information, location data, IP address, browser type, hardware model, operating system and version, software, and unique identification code;
 c) visited pages, viewed content, clicked links and buttons, URLs accessed before and after using our Services (see the “Cookie Policy” below);
 d) your responses to marketing campaigns, whether from us or third parties (e.g., when you open/click such emails);
 e) your social media profile details (name, surname, profile picture, and other information you provide us) when you connect or contact us via social media accounts.
   

We also collect personal data not provided directly by you, such as:

• In the case of winnings, we will calculate tax amounts withheld and transferred to tax authorities, which also represent personal data processed by us.
• Data regarding your use of the Platform, obtained through tracking technologies, such as cookies. These data include IP address and, where registered, registration details, as well as pages viewed, duration, and browsing path on the site.

We collect personal information when you interact with us and use our services. This information is provided by you directly, when you first register, as well as when you use our products or contact us. Sometimes, third parties or publicly available sources provide us with information about you.

We disclose your personal data to persons authorized by the Operator to process personal data (i.e., entities we contract to carry out various personal data processing operations on our behalf).

Also, if the law requires us or we have a legal basis to do so, we may disclose your personal data to third entities acting as controllers (entities processing data for their own purposes) or, as the case may be, entities acting as joint controllers with us (where we jointly determine the purposes and/or means of data processing).

Categories of recipients of your personal data (processors, independent controllers, joint controllers – as the case may be) include:

1. Third parties that provide us with technical, administrative, or marketing support, such as:

• companies that provide services for sending mass SMS and mass emails
• software providers offering us necessary programs for our activity
• payment institutions for the transfer or withdrawal of your winnings


1. Other companies in the group assisting us and providing services in the course of our daily activities: these activities include services in the bet approval process, marketing services, internal administrative purposes, analytics, archiving, and other secondary activities related to the gambling industry.

Also, based on legal obligations, we may share personal data with payment institutions, government authorities, competent public authorities, external consultants, and other parties with confidentiality obligations.

The Operator ensures that only a limited number of employees have access to your personal data. Our employees are required to keep your personal data confidential and comply with the measures taken to protect it. They may process personal data only based on the instructions received.

Based on your consent, in cases where your personal data is transferred to any other third party for which you have consented or requested us to do so.

At any time, you have the following rights with respect to your personal data processed by us. Please note that, apart from your right to object to the use of your information for direct marketing (and profiling for direct marketing purposes), the other rights are not absolute where other laws apply.

• Right to be informed: you have the right to be provided with information about the identity of the data controller, the reasons for processing your personal data, and other relevant details necessary for fair and transparent processing.
• Right of access: you have the right to request details about your personal information and a copy of such information.
• Right to rectification: you have the right to have inaccurate information about you corrected or removed from our database without undue delay.
• Right to erasure (“right to be forgotten”): you have the right to have certain personal data about you erased from our records.
• Right to restrict processing: you have the right to request that we use your personal data only for restricted purposes.
• Right to data portability: you have the right to request that we transfer the personal information you provided to us or to another party in a machine-readable format.
• Right to object: in certain circumstances, you have the right to object to the Operator processing your personal data. Depending on the situation, if we have legitimate interests for processing that override your interests, rights, and freedoms, or if we need the data for establishing, exercising, or defending legal claims, we may continue processing your data for such purposes.

If your data is processed for marketing purposes/related purposes based on legitimate interest, you can object at any time. In such cases, we will immediately cease processing your data.

• Rights related to automated decision-making: you have the right not to be subject to a decision based solely on automated processing that produces legal effects concerning you or significantly affects you, except where necessary for a contract with you, authorized by law, or based on your consent.

To exercise any of the above rights, you can send a request to: support@casino.winboss.ro. Your request will be reviewed and answered within one month of receipt, in accordance with the General Data Protection Regulation. If we receive a large number of requests or particularly complex ones, the term may be extended by up to two additional months. In some cases provided by data protection law (e.g., excessive requests), we may refuse to act on your request.

Where your personal data is processed based on your consent, you have the right to withdraw your consent at any time, without affecting the legality of processing carried out based on your consent before withdrawal.

You also have the right to file a complaint with the competent data protection authority, in our case, the Information and Data Protection Commissioner’s Office (https://idpc.org.mt/raise-a-concern/) or your national data protection authority.

We will retain your information as long as necessary to fulfill the purposes described above and to meet our legal obligations.

If we process your personal data based on your consent, such personal data will be processed only for the duration of your consent, which you may withdraw or restrict at any time. If you do so, we will stop processing the personal data for which you withdrew your consent.

Our site may include social media options, such as Facebook, Twitter, Instagram buttons. These options may collect certain information about visitors to our site, such as IP address or browsing history, and may place cookies in visitors’ browsers. Note that the processing of collected data is governed by the policies adopted by the social media operators, and therefore, this privacy notice does not apply.

This privacy policy may be updated periodically to reflect changes in how we work or how our activity is regulated. Any changes we may make to the Privacy Policy in the future will be available in this Section. We recommend that you review this Privacy Policy each time you provide us with personal information.

You may decide at any time not to provide us with the requested personal data. However, if you refuse to share personal data when requested, we may not be able to fulfill our contractual obligations where collection and processing of such data is a legal obligation (e.g., if you refuse to provide your personal identification number, we cannot pay your gambling winnings). You may also be ineligible to participate in certain activities or events if you do not provide the minimum requested information (e.g., if you refuse to share contact data, you cannot participate in a promotional activity since we could not contact you to grant winnings).

Your refusal to share personal data to access certain services may also limit the services and special offers we can provide to you. For example, if you do not agree to receive our newsletter, you will not receive any newsletters. We will not process your personal data if you only wish to visit our website and learn more about our services and products.

We will transfer your personal data outside the European Economic Area only if:

(i) You have given your explicit consent;

(ii) It is necessary to establish or perform a contract you have concluded with us, or to comply with a legal obligation.

If we transfer your personal data outside the EEA, within the Operator’s group or to our business partners, we will take steps to ensure that they are protected to the same standards as within the EEA, based on:

(i) the recipient country being recognized by the European Commission as offering the same level of protection as the EEA (more information available on the European Commission’s website);

(ii) using contracts requiring the recipient to protect your personal data at the same standards as in the EEA;

(iii) for transfers to the United States, the recipient is registered in the Privacy Shield, a framework ensuring that personal data is protected to a level approved by the European Union. More details are available on the European Commission’s website.

In some cases, we may be legally required to disclose your personal data to a third party and have limited control over how that third party protects your data.

We understand that online security and data protection are vital for all our customers, so it is important for us to ensure trust in the security of personal data before a user registers an account. We are actively engaged in using security measures to protect information from unauthorized access and to prevent processing, disclosure, destruction, loss, modification, and accidental or unlawful damage.

Our technological security solutions are advanced and managed by a mature framework. Our approach focuses on risk prevention. To support this, we adopt robust procedures and technologies to reduce the impact of potential incidents.

Since the security of some parts of Internet communications cannot be fully guaranteed, we cannot guarantee complete security of information you disclose over the internet. You accept the implications regarding Internet security by using it, and the Operator will not accept any liability for direct, consequential, incidental, indirect, punitive, or other damages resulting from such events.

The Operator’s services and products are not intended for children (persons under 18). The Operator does not collect personal data from minors. You must be over 18 years old to use the Platform’s services and products and to communicate with us.

By registering for our events and contacting us, you confirm that you are at least 18 years old and have the full capacity to conclude, comply with, and be legally responsible for any of our terms and conditions and this Privacy Policy.

Cookies are text files stored in your web browser. They allow us to identify you each time you access our website. Cookies collect certain personal information when you use the site to improve your online experience.

We use different types of cookies:

• Strictly necessary: these cookies allow you to navigate the website and allow us to provide you with the content you request. If you opt out of these cookies, you will not be able to access core features of our sites, such as placing bets or accessing your player account. These cookies are valid until you close your browser, after which they are deleted.

  Examples:

  • cookies that position content on your device or screen so you can navigate our site;

  • cookies that keep you logged in each time you visit, without having to log in again;

  • cookies remembering and updating selections during a live session until placed.
• Functionality: these cookies recognize you when you log in and remember your choices, so we can improve and personalize your experience, e.g., resetting passwords. You may still use our site if you opt out, but some functions (like staying logged in) will be harder to use. These expire after a maximum of 2 years but can be deleted earlier.

  Examples:

  • cookies that remember your preferences and settings;

  • cookies that display “related links” depending on what you search.
• Performance/analytics: these cookies collect information about how visitors use the site and its performance. To improve our site performance, these cookies collect information without identifying you. Some may be used by third parties, but they will not identify you. You may opt out and still use the site without compromising its features. Validity may vary but can be deleted anytime.

  Examples:

  • cookies to know how many times a page was visited;

  • cookies providing statistics on site usage;

  • cookies measuring content and ad effectiveness;

  • cookies improving user experience.
• Third-party marketing/targeting: these cookies allow us to provide you with relevant ads and content. They track visits to our site and limit ad frequency while measuring campaign effectiveness. Third-party cookies may collect browsing activity data. No personal data is collected since cookies are stored anonymously. If disabled, you may still use our site, but ads will not be tailored to your interests.

  Examples:

  • cookies collecting browser usage information for targeted ads;

  • cookies providing personalized marketing content;

  • search retargeting cookies displaying our ads on third-party sites based on your browsing activity.

You can modify cookie settings anytime via the “options” or “preferences” menu in your browser, or through the browser’s “Help” option for more details.

*** In case of any discrepancies, the terms and conditions in Romanian language shall prevail.