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Privacy Policy

Welcome to the Privacy Policy of the online casino “SlotsMillion” owned by Alea Ltd For more information regarding the processing of your data, please, read the following section:

1. who is the data controller?

IdentityAlea Ltd
AddressVella Falzon Home Building, Level 2, Valley Road, MSD9022. Malta.
E-mail [email protected]
Telephone+356 277 803 91
Data Protection Officer (DPO) [email protected]

2. which are the purposes and the legal basis for processing your personal data?

Your personal data shall be processed for the following purposes:

WHICH IS THE PURPOSE?WHICH IS THE LEAGL BASIS?
1. To provide you our services consisting on the offer and enjoyment of different games through any URL owned or licensed by Alea Ltd.Processing is necessary for the performance of a contractual relationship to which you are a party or regarding prior steps to entering into a contract (Article 6.1.b) GDPR).
2. To sign you up as a new user/player, manage your player account and, if necessary, block it and/or cancel it.Processing is necessary for the performance of a contractual relationship to which you are a party (Article 6.1.b) GDPR).
3. To check you’re accessing the services from a country in which we’re available to offer them. This verification is carried out using your IP address.Processing is necessary for the performance of a contractual relationship to which you are a party or regarding prior steps to entering into a contract (Article 6.1.b) GDPR). Also, for complying with our legal obligations (Article 6.1.c) GDPR).
4. Verify the accuracy of the personal data you provide us (e.g., your age, identity document, bank details, etc.), including the disclosure of such data to third party providers in order to assist us with such verification.Processing is necessary for the performance of a contractual relationship to which you are a party (Article 6.1.b) GDPR). Also, for complying with our legal obligations (Article 6.1.c) GDPR).
5. Manage and process payment transactions.Processing is necessary for the performance of a contractual relationship to which you are a party (Article 6.1.b) GDPR).
6. Whenever you have a contractual relationship with us, and in order to offer you a close and quality service, we may contact you and communicate information regarding the status of services, incidents, remind you of certain updates regarding your information or personal data, information about services, among others. These communications will be made by any automated means or not (email, SMS, MMS, Internet, telephone, instant messaging services, etc. ...).Processing is necessary for the performance of a contractual relationship to which you are a party (Article 6.1.b) GDPR). Also, the processing is necessary for the purposes of pursuing our legitimate interest, which is offering to our clients the best possible services, being necessary to inform them regarding certain aspects in order to provide them with proper care and assistance (Article 6.1.f) GDPR). We always watch that our interests don’t override your interests or fundamental rights and freedoms.
7. Assist, manage and answer your possible requests, comments and/or queries. Said attention will be carried out by automated means or not (e-mail, SMS, telephone, instant messaging services, etc.).Processing can be done because of your consent when sending your requests, comments and/or queries (Article 6.1.a) GDPR); and/or is necessary for the performance of a contractual relationship to which you are a party or regarding prior steps to entering into a contract (Article 6.1.b) GDPR).
8. To record telephone calls made and keep records of the SMS and e-mails we send, in order to know and improve the service offered, ensure quality, train our staff and also for security reasons in order to identify people in future communications and in case of legal conflict.Processing is necessary for the purposes of pursuing our legitimate interest, which is offering to our clients the best possible services, being necessary to inform them regarding certain aspects in order to provide them with proper care and assistance (Article 6.1.f) GDPR). We always watch that our interests don’t override your interests or fundamental rights and freedoms.
9. The information will be processed in order to comply with our legal obligations, possible court and other authorities’ decisions. Whenever we have suspicions or indications of an action that may constitute a risk, fraud and/or illicit/criminal offence, we will communicate your personal data to different authorities (including, but not limited to, addiction authorities, money laundering prevention authorities, tax authorities, regulatory authorities, among others).Processing is necessary for compliance with our legal obligations (Article 6.1.c) GDPR).
10. Investigate, control and communicate, where appropriate, the players/user’s activity in order to detect and prevent money laundering, financing of terrorism, fraud and/or illegal/criminal action.Processing is necessary for compliance with our legal obligations (Article 6.1.c) GDPR). Processing is necessary for the purposes of pursuing our legitimate interest to detect and prevent fraud in our services (Article 6.1.f) GDPR).
11. To the extent permitted by law, and provided you have not objected, we will use your information to send you promotional communications about our services, primarily bonuses, that may be of interest to you. These communications will be made by any automated means or not (email, SMS, MMS, fax, internet, telephone, instant messaging services, etc.).

In order to send personalized offers and bonuses we carry out a segmentation of the players/users.
Processing can be done when you consent during registration on our services to receive promotional communications (Article 6.1.a) GDPR). In those legislations where consent is not necessary, the legal basis will be our legitimate interest (art. 6.1.f) GDPR), provided that you haven’t objected.

Segmentation is based on our legitimate interest in promoting our services, improving players/users’ experience, and offering communications that are of interest for them.
12. We will process your information in order to carry out analyses and statistical reports anonymously in order to know how our services work, with the aim of improving their development and personalization.Processing is necessary for the purposes of pursuing our legitimate interest, which consists of managing and improving our products and services in order to offer a quality service and grow as a business (Article 6.1.f) GDPR). We always watch that our interests don’t override your interests or fundamental rights and freedoms.
13. Ensure that self-excluded players/users exclude themselves properly, and cannot access our services.Processing is necessary for compliance with our legal obligations (Article 6.1.c) GDPR).
14. To monitor and study the players/users gambling activities in order to identify those persons who may be experiencing, or at risk of developing, problems with gambling, and to interact with them in order to offer them help or support for this purpose, in compliance with our obligations regarding responsible gambling. This implies profiling, for more information see section 5.Processing is necessary for compliance with our legal obligations (Article 6.1.c) GDPR).
15. To monitor and study the players/users economic-financial behavior during their gaming in order to detect and identify any type of unusual behavior, in compliance with our obligations regarding anti money laundering and fraud. This implies profiling, for more information see section 5.Processing is necessary for compliance with our legal obligations (Article 6.1.c) GDPR).
16. To keep track of players/users who are considered addicts for the purpose of responsible gambling.Processing is necessary for compliance with our legal obligations (Article 6.1.c) GDPR).
17. Your information will be processed to ensure the security of our services, avoiding and detecting possible security incidents, fraud and other crimes.Processing is necessary for the purposes of pursuing our legitimate interest, which is to ensure security on our services (Article 6.1.f) GDPR). We always watch that our interests don’t override your interests or fundamental rights and freedoms.

3. how long do we store your data?

Alea Ltd shall process your personal data for the period necessary to comply with the purposes set out in this Privacy Policy, as well as to keep your personal information in compliance with the provision of the applicable law and regulations, especially in relation to the legal statute of limitations, and for the exercise or defense of claims.

Our criteria for doing so are determined by (a) the purpose of the data collected and the fulfillment of that purpose (e.g. as long as our relationship is maintained); (b) the reasons why the data is collected (e.g. in the event of consent, you may withdraw it at any time); and (c) retention periods required by contractual and regulatory requirements (e.g. statues of limitations required under money laundering and terrorist financing regulations).

Please note that, in some cases, we may retain your data for the time necessary to exercise or defend claims, requirements, liabilities and legal and/or contractual obligations arising from the processing, always being dully blocked.

4. who could be the recipients of your data?

Your personal data will not be disclosed to third parties without your express consent. However, depending on the purposes for which the personal information is collected, such information may be accessed, without distinction, by the following persons:

  • Employees and/or collaborators authorized by Alea Ltd, always subject to the applicable data protection regulations;

  • Whenever we suspect that you have breached our Terms and Conditions or any applicable regulations, or in order to prevent, detect or anticipate fraud and possible breaches of any applicable regulations, Alea Ltd shall disclose your data to the various competent governmental authorities, online gaming regulatory authorities, gaming commissions, law enforcement agencies, relevant criminal investigation bodies, money laundering and terrorist financing prevention authorities, among others.

  • In the event that there is a subpoena, summons or court order, or similar official request, we will disclose your data to those entities and/or authorities whose subpoena, summons, request or order we must comply with.

  • Third party service providers that process information as data processors (e.g., professional advisors, fraud detection agencies, anti-money laundering agencies for fraud detection and control purposes, among others). We’ve entered into the relevant data processing agreement as required by personal data protection regulations.

Whenever your data is transferred from a country in the European Economic Area (EEA) to a country outside the EEA, we ensure that we or our suppliers have an adequate personal data protection level. To this end, we use and/or contract data processors who will process your personal data using recognized data protection safeguards. For example, under the EU-U.S. Privacy Shield Framework, or where applicable, under standard contractual clauses approved by the European Commission for the transfer of personal data.

5. profiling

Alea Ltd considers essential to protect its players/users, promote responsible gaming policies and spread good gaming practices, repairing and avoiding, as far as possible, the negative effects of it.

Consequently, and always in accordance with the principles of responsible gaming, Alea Ltd studies the players/users’ gaming activities to identify those persons who may be experiencing or at risk of developing problems with our services, and to interact with them to offer them help or support in order to fulfill our responsible gaming obligations.

To this end, Alea Ltd has established rules on who may suffer from gambling addiction and take appropriate measures by using historical data on player/user behavior, deposit and withdrawal data, together with other data (e.g. certain communications made to the Customer Service Department).

These rules are studied using an algorithm that gives us an estimated probability of gambling addiction. This study and identification imply creating different players/users’ profiles. However, decisions based on this study are not based solely on automated processing, without human intervention. In other words, the final decision as to whether the player/user is at risk to be addicted or not will never be automatic, always involving human intervention.

Creating such profiles is necessary to fulfill our obligations and responsibilities according to the principles of responsible gaming.

Also, in compliance with anti-money laundering regulation, Alea Ltd shall monitor and observe the players economic-financial behavior during their gaming, including in-payment and pay-out, in order to detect and identify any type of unusual behavior. To this end, Alea Ltd has established some automatic notifications. These notifications are based on an algorithm, but the decisions are not based solely on automated processing, without human intervention. The final decision whether there is an unusual behavior always involves human intervention.

6. what are your rights when you provide us your data?

If we process your personal data, you’ve the following rights:

  • Right to request access to personal data: you may ask Alea Ltd if it is processing your data, and if it is, you may have access to the same.

  • Right to request the rectification of your data in case they are inaccurate or to request data to be completed if they are incomplete.

7. updates

We will only use your personal data as set out in this Privacy Policy which is in force at the time, we collect your information. If any revision or update is done that affects the processing of your personal data, we will inform you.

8. additional information

Updated data: It is essential that the personal information we hold about you is up to date at all times in order to comply with our legal and regulatory obligations. In this sense, you can update your personal data in the Account Settings (Personal Details) section of your Member account or by sending us an email to [email protected] .

Minors: Our services are aimed exclusively at adults. Therefore, we do not knowingly collect information from minors. If parents or legal guardians believe that their children have submitted us personal data, please contact us by sending us an e-mail to [email protected]

Special categories of personal data: Alea Ltd does not collect or process data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic or biometric data, data concerning a natural person’s sex life or sexual orientation. However, we may deal with information regarding your health, specifically in relation to gambling patterns or a possible addiction. In this regard, when you inform us about this information, or we receive it from a third party, we will only process it for the purpose of protecting your vital interests and in compliance with responsible gambling.

Links: Alea Ltd website could contain links to other web pages which we considered useful and informative to you. Keep in mind that we are not liable for the privacy and data processing of other web pages. We recommend that you read the privacy and data processing policies of any other web pages that you may connect to from our website or that you may otherwise visit. Please, bear in mind that this Privacy Policy is applicable solely to the information that is gathered and/or processed by Alea Ltd.

Contact us: If at any time you believe that we have not complied with the provisions set forth in this Privacy Policy, please let us know by sending an email to [email protected] If you want to inform about a problem regarding the privacy of your data or have any questions regarding this Privacy Policy, do not hesitate and contact us by the email address above. We will be happy to help you.

Last Updated: 20th November 2019