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Your privacy is very important to GammonSpace Ltd, registered office at Ewropa Business Centre, Level 3 – 701, Dun Karm Street, Birkirkara BKR 9034, Malta, Registration no. C 91360, established and governed by the laws of Malta (referred to herein as “GSL”, “we” or us”), the owner and operator of the website located at www.gammonspace.com (the “Site”). We are committed to maintaining the confidentiality of the personal information collected by us in order to allow you to enjoy playing backgammon online at the Site, by safeguarding it utilizing the best in class software and hardware architecture, techniques, methods and procedures. We will comply with the terms of the applicable personal data protection legislation when processing your personal information.

We respect and value the privacy of everyone who visits our Site and will only collect and use personal data in ways that are described here, and in a manner that is consistent with our obligations and your rights under the law.

Consent to Privacy Policy

By using the Service, you agree to the terms of this Privacy Policy. We reserve the right to amend this Privacy Policy and changes will come into effect immediately upon such change being notified on the Site. Your continued use of the Service constitutes your agreement to this Privacy Policy and any amendments. Our Terms of Service take precedence over any conflicting provision of this Privacy Policy. Unless otherwise defined herein, capitalised terms shall have the meaning given to them in our Terms of Service.

The purpose of this Privacy Policy is to enable you to understand how we collect, store, use and safeguard your personal information and for you to understand your rights in relation to that information.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is deemed to occur upon your first use of our Site. If you do not accept and agree with this Privacy Policy, you must stop using our Site immediately.

What information is collected and for what purpose

As part of the Site account opening process and to allow us to provide services to you, we will ask you to provide us with the following personal information:

  1. name and surname
  2. permanent address
  3. residential address
  4. identity document
  5. bank account
  6. telephone number
  7. e-mail address
  8. username and password to your GSL User Account.

In addition to the above, when you use the Service we may collect the following information:

  1. information on your activity on the Site and use of the Service
  2. utility bill
  3. information held on Devices (defined below) or systems that you use

You also have to certify that you are at least 18 years old or older in jurisdictions in which the minimum age for use of the Service is greater than 18.

For the purposes of using the Service via Mobile Software, you will be required to consent to the use of location-based services (LBS) by us to detect your geographic location. We may also use your information to verify your credentials from third parties including identification verification agencies for the purposes of us providing services to you.

We, members of our Group companies, our affiliates and third parties providing services on our behalf will use your personal information for these purposes:

  • to provide Services to you;
  • to enhance the Services that we provide to you;
  • identification and vetting purposes;
  • statistical analysis and research;
  • research and development;
  • marketing, market research and customer profiling;
  • data analysis; and
  • to comply with licensing and regulatory requirements, including anti-money laundering obligations

Our use of your personal data will always have a lawful basis, either because it is necessary for our performance of a contract based on which we provide Service to you, because you have consented to our use of your personal data (e.g. by subscribing to receiving marketing communication), or because it is in our legitimate interests.

We may disclose your personal information:

  1. if required to do so by law or by regulatory authority;
  2. if we believe in good faith that such action is necessary:
    1. to comply with any law or comply with legal process served on us;
    2. to protect and defend our rights or property;
    3. to any regulatory body or licensing body or authority;
    4. to third parties who provide services to us or on our behalf;
    5. to any third party that purchases us or our business or any part of us or our business;
  3. with your consent;
  4. for the purposes of disaster recovery; or
  5. as set out in Section 5 below.

With your consent or where permitted by law, we may use your data for marketing purposes which may include contacting you by email or telephone with information, news and offers on services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the applicable personal data protection legislation. If you are a current GSL User, we may use the email address or telephone number you provided us to send marketing communications about similar GSL products or services, unless you opt-out of receiving them by following the instructions included in each newsletter. In other cases, especially when informing you about new services, events or User support, we will ask you to agree with sending GSL marketing information and GSL services, actions and promotional campaigns.

You may be subject to profiling based on your history of use of our Services, the consequences of such activity may include offer of specific Services to you.

Your personal information may be processed by us, other members or our Group companies, our affiliates, our agents and third parties providing services to us in any country of the world. 

We will only use your name in publicity materials with your consent.

The name you register with us must be your own name. In addition, it is very important that you complete the account details with valid information, since it will be used for the aforementioned purposes. You are required to advise us of any relevant changes to your personal information.

Users are able to change account details by selecting an account option in the downloaded software.

Your personal information will be processed for 10 years upon your termination of use of our Service or longer if required by law , or for as long as we have your permission to keep it if the processing is based on your consent and there is no other legal ground for processing of your personal data.

Confidentiality

GSL undertakes substantial efforts to protect the confidentiality of the identity, preferences and other information it has collected about individual Users and will not knowingly allow access to this information to anyone outside GSL, other than to the User or as described in this Privacy Policy. GSL has made a substantial investment in its server, database, backup, firewall and encryption technologies to protect the information collected by GSL. These technologies are deployed as part of state of the art security architecture.

You should also do your part in protecting your information. Your Login Credentials are confidential and you are obliged to keep your Login Credentials secret and confidential at all times and to take all efforts to protect their secrecy and confidentiality.

Limits of Confidentiality

Legally Required Disclosures: Due to the legal, regulatory and security environment in which we operate, GSL may be required, under certain circumstances, to disclose personally identifiable information about our Users and we may not be permitted to inform you that we have done so. GSL will use reasonable endeavours to limit such disclosure to the following: where GSL believes in good faith that it is required to do so in response to a subpoena, warrant or other legal process; or where reasonably necessary to identify, contact or bring legal action against persons or entities to preserve and/or enforce GSL' rights. Further, we can disclose your User identification, name, street address, city, state, post code, country, phone number, e-mail, and company information to third party agents of GSL or official government bodies as we, in our sole discretion, believe necessary or appropriate in connection with an investigation of fraud, intellectual property infringement, piracy or other unlawful activity or activity that may expose us to legal liability.

Who receives your information?

In addition to legally required disclosures as explained in this Privacy Policy, we may disclose your personal information to our employees, employees of other companies in our Group companies, our agents and to third party service providers who use your personal information to provide services to us in respect of you being a User with GSL.

We may combine your personal information collected from your use of the Service in accordance with this Privacy Policy with other information collected from you using other services operated by GSL or any other member of the Group companies as well as all products which are related or ancillary to the Services, including mobile and social networking services. We will treat this combined information in accordance with, and will use it for, the purposes set out in this Privacy Policy.

All recipients of your personal information shall be bound by applicable data protection laws to keep your personal information private at no less a level than that by which we are bound.

Your rights in relation to your information

In accordance with the applicable personal data protection legislation, you are entitled to:

  1. request us to have access to personal data and their possible correction or deletion,
  2. at any time to request information regarding the processing of personal data in the legal scope,
  3. object to processing or to demand restrictions on the processing of personal data,
  4. not be the subject of any decision based solely on automated processing, including profiling, which would have legal effects for or would have a significant impact on you.

If you have any cause for complaint about our use of your personal data, please contact us using the details provided in section 8 and we will do our best to solve the problem for you. If we are unable to help, you also have the right to submit a complaint with the data protection authority in the country of your residence.

Cookies

Cookies are text-only strings of information that are downloaded to your personal desktop, laptop computer or mobile device (each a “Device”) when you visit a website. They are then sent back to the originating website on each subsequent visit, or to another website that recognises those cookies.

Cookies are very useful and are used for many different purposes. These include allowing you to navigate between pages efficiently, remembering your preferences, and generally improving user experience. Sometimes cookies are used to help ensure that adverts you see online are relevant to you and your interests. We use cookies in order to track referrals to our websites, to remember your preferences, and to generate anonymised statistical data, which we use to improve the user experience on our sites. We also use cookies to measure the effectiveness of our advertising campaigns, to limit the number of times you see an advertisement, to remember that you have visited a website, and to provide advertisements that are more relevant to your interests.

Detailed information about cookies and how we use them on the Site may be found in our Cookie Policy, which also describes how you can turn off cookies or control which cookies are set on your Device (see in particular the section headed ‘How to manage your cookie settings’).

Who are we and how to contact us regarding personal data protection matters

GammonSpace Ltd

Ewropa Business Centre, Level 3 – 701, Dun Karm Street, Birkirkara BKR 9034, Malta

Our Data Protection Officer is available for you and can be contacted by email at gammonspace@gammonspace.com or by post at Ewropa Business Centre, Level 3 – 701, Dun Karm Street, Birkirkara BKR 9034, Malta