PRIVACY NOTICE

Scope

This Privacy Notice (hereafter referred to as the “notice”) explains how FunID (“us”, “we”, “our”) handles your personal data.

This Privacy Notice applies to the personal data collected from registered users (“Player(s)”) who have an account on our mobile application, website and visitors to our website.

Who We Are

We are the data controller of your personal data because in the context of our business relationship with you, we decide how and why it is processed in the ways explained in this notice.

If you have any questions about this notice including any requests about exercising your privacy and data protection rights, you can contact our Data Protection Officer by sending an email to dpo@funid.com.

What Personal Data Do We Collect?

Data you provide to us directly

We may collect the following personal data from you depending on how you interact with our services:

• Registration Data: To create an account on our mobile application or website, you need to provide us with your personal data, including your email address, date of birth, country, phone number, gender, full name, social security number, zip code, and username. Upon registering, we will automatically receive your IP address and location data.
• Due Diligence Data: We collect your identity card number/driving license/passport number, proof of address, social security number, source of wealth/funds, bank ID, and financial statement/details to comply with our due diligence and Know Your Customer (KYC) obligations, for age and identity verification purposes for Anti-Money Laundering purposes and/or to comply with our license or other legal requirements.
• Financial Information: We may collect your financial information, including Bank ID, CPR number, CPF number, IBAN, and payment system details, to facilitate withdrawals and deposits to your account. Additionally, this information may be used for Know Your Customer (KYC) and Anti-Money Laundering (AML) compliance purposes.

Personal Data We Collect Automatically

• Device Information: We receive information about the device and software you use to access our services, including Internet protocol (IP) address, operating system version, and device identifiers.
• Logs and Usage Information: To help us understand how you use our services, and to help us improve them, we automatically receive information about your interactions with our services. Our servers automatically log usage data when you interact with our website. This information includes records of your activities like viewing content, clicking ads, performing searches, and sharing our services on social media on our website, date and time of your sessions, the pages you view, links to/from any page, and time spent in a session. We gather some of the data through cookies and similar technologies.
• Location Information: We may collect or infer your general location information when you use our services.

Personal Data That We Receive From Others

We may collect your personal data from other sources to provide and personalize our services to you and/or to comply with legal obligations. We may gather data from:

• Publicly available sources such as public and government databases, internet, social media platforms, online and printed media, and so on.
• Commercially available databases and third-party entities, including financial and credit institutions, fraud prevention agencies, and public authorities. These sources help us in verifying your information and investigating suspicious activities, especially for fraud prevention and anti-money laundering purposes.
• Inferences. We may infer additional personal data based on the personal data described above. For example, we may infer your interests and game preferences based on the web pages you view and the games you play.
• Personal data you have made public, such as information available on social media platforms, linked accounts (e.g., Facebook or Google), and other publicly accessible digital platforms.

Why Do We Collect Your Data?

We use the personal data we collect to:

• Provide you with our services
• Respond to your questions or requests
• Test, research, troubleshoot, and analyze data to develop and improve our products and services
• Prevent, detect, and manage risk against harmful behavior, fraud, and illegal activities
• Send you marketing content, newsletters, and personalize our marketing to you
• Resolve disputes that may arise, including investigations by law enforcement or regulatory bodies
• Fulfill regulatory and legal obligations
• Maintain the security and functionality of the service, including ensuring technical availability of the website, protecting our systems and intellectual property from security threats and unauthorized access

What Are Our Lawful Basis for Processing Your Personal Data?

In compliance with the GDPR and other applicable data protection laws, we process your personal data when we have a legal basis to do so. For some processing, more than one lawful basis may be relevant. Here are some lawful bases that we rely on:

Conclusion and Performance of a Contract

We process personal data in order to fulfill or enter into a contract with you. For example, to create and support your account with us, to communicate with you to fulfill our obligations under the Terms and Conditions, and so on.

Legal Obligation

Processing your personal data may be necessary to comply with legal obligations. Some of the processing activities we may engage in to comply with legal obligations include:

• Verifying your age and identity as part of our KYC and AML obligations
• Determining your location and applicable legal requirements using your IP data
• Managing risks, including preventing problem gambling and promoting responsible gambling
• Ensuring network and information security
• Complying with legal processes like search warrants, subpoenas, or court orders
• Preventing crimes related to money laundering, terrorist financing, fraud, or computer claims
• Regular reporting activities to meet economic, financial, technical, and legal requirements
• Dealing with requests from you to exercise your rights under data protection laws

Legitimate Interest

When necessary, we may process your personal data to safeguard our legitimate interest, a third party, or a commercial reason provided your rights, freedoms, or interests do not outweigh those interests. Examples of such processing activities include:

• Initiating legal claims and preparing our defense in litigation/administrative procedures
• Undertaking IT and system security procedures to prevent potential crime, asset security, intellectual property protection, and ensure technical availability and proper functioning of our website and applications
• Managing our business relationship and enhancing our products and services
• Engaging in analytics, data aggregation, and research for service development/improvement and/or marketing purposes
• Customer segmentation to manage risks, identify potential harmful behaviors, and ensure responsible gaming
• Analyzing your gaming behaviors using machine learning algorithms to recommend games and features you might enjoy
• Detecting and preventing activities that compromise the integrity of our services, such as fraud, use of unauthorized software or tools, abnormal patterns, or cheating

Consent

With your consent, we may engage in the following activities:

• Send direct marketing messages via email, SMS, phone calls, website or app notifications
• Customize offers and promotions based on your gaming history and preferences
• Use data about your online behavior to display targeted advertisements that might interest you
• Personalize and assess the effectiveness of our marketing to better align with your interests and preferences
• Administer your participation in competitions, tournaments, rewards, loyalty schemes, and promotional events

How We Share Your Personal Data

We may share your personal data with the following categories of recipients:

• Internally with authorized employees, brands within the same entity/operator, contractors, agents, affiliates, and subsidiary companies within our business group or linked to our parent company.
• The brands and entities that provide the games you choose on our mobile application and/or website. These entities use your personal data to deliver their services, fulfill regulatory obligations, and for marketing purposes.
• Payment providers and financial institutions. For the use of our services, withdrawals, and deposits, we offer a variety of trusted third-party payment providers. We may share the following personal data with them: first name, last name, date of birth, email, address, zip, city, country, phone number, alias. We may also share your KYC documents with the payment providers in order for them to comply with their legal and AML obligations.
• Third-party service providers, as necessary to deliver, manage, and improve our services including but not limited to customer support service providers, email delivery, SMS and voice call providers, technology providers, and cloud hosting service providers.
• Marketing partners.
• Fraud prevention agencies.
• Third parties in the event of/connection to a corporate transaction or proceeding such as a merger, financing, acquisition, bankruptcy, dissolution, transfer, divestiture, or sale of all or a portion of our business or assets.
• Game providers.
• Data aggregators or analytics providers for the purpose of conducting market research, data analysis, and improving service offerings.
• Law enforcement agencies, regulatory, and licensing authorities.

How Long We Keep Your Data

We will retain your personal data only for the duration that you maintain an account with us and to fulfill the purposes outlined in this privacy notice.

Additionally, we may keep your data for a longer period as required by applicable legal obligations, such as anti-money laundering (AML) regulations or other regulatory requirements.

Once your account is closed and there is no longer a legal or business need to retain your data, your personal data will be either deleted or anonymized so that it can no longer be associated with you.

Your Rights

You have certain rights regarding the personal data we hold about you. They include:

• Right to request access to the personal data we hold about you and obtain information about how we process it.
• Right to rectify or correct any inaccurate or incomplete personal data about you.
• Right to erase, delete, or remove your personal data when there is no compelling legal or business reason for its continued processing.
• Right to restrict the processing of your personal data in certain circumstances.
• Right to request the transfer of your personal data to another party in a structured, commonly-used, and machine-readable format.
• Right to object to the processing of your personal data, particularly if we are processing it on grounds of legitimate interests or for direct marketing purposes.
• Right to withdraw your consent at any time, without affecting the lawfulness of previous processing based on your consent.
• Right to lodge a complaint with a supervisory authority. You may do so in your EU member state of residence, place of work, or the place the alleged infringement occurred.

To exercise your rights, kindly contact our Customer Support at support@funid.com or our Data Protection Officer at dpo@funid.com.

Cookies and Other Tracking Technologies

We use cookies, tags, pixels, web beacons, and other similar technologies to enhance your experience on our website and applications. Upon your first visit to our website or applications, we will ask for your consent to use non-essential cookies. Strictly necessary cookies, which are required for the operation of the website, do not require your consent. For more information on the specific cookies we use, their purposes, and how to manage your preferences, please refer to our Cookie Notice.

Data Security

We prioritize the security of your personal data and implement robust measures to protect it from unauthorized access, loss, theft, and misuse. Our security strategy includes a combination of administrative, technical, and physical safeguards designed to protect your data against unauthorized disclosure, alteration, and destruction. Even though we use advanced security measures to protect your data, no system is completely safe from security breaches. The Internet, by its nature, cannot ensure complete security of data transmission or storage. While we strive to protect your personal information, we cannot guarantee its absolute security. However, we will continuously assess and improve our security practices to enhance the protection of your data.

Transfer Of Data Outside EU/EEA

We may process your personal data in countries outside of the EU/EEA. When we transfer your personal data to our affiliates or third parties, we ensure that appropriate safeguards have been put in place before such transfer to ensure your personal data is afforded a high standard of protection. This includes transferring personal data only to countries recognized by the European Commission as providing adequate protection, employing Standard Contractual Clauses approved by the European Commission, or implementing other legally recognized safeguards.

Change in Ownership or Control

In the event of a sale, merger, or any other change in ownership or control of our company, your personal data may be disclosed as part of the transaction or during the preparation for such an event. The new owner or controlling entity will be permitted to use your personal data, but only in accordance with the terms outlined in this Privacy Notice, unless you provide explicit consent for different use.

How To Contact Us

If you have any questions about this privacy notice or our data collection practices, kindly contact us by sending an email to support@funid.com or dpo@funid.com.

Updates To This Notice

We may need to update, modify, or amend our Privacy Notice as our technology evolves and as required by law. It is your responsibility to review the amended Privacy Notice from time to time. The Privacy Notice will apply from the effective date provided on our website.

Effective Date: July 2024

Cookie Notice

Introduction

This Cookie Notice builds on our Privacy Notice by explaining how we use cookies and similar technologies to manage and deliver our online services and electronic communications to you. We will explain what these technologies are, why we use them, and how you can control our use of them.

In some cases, these cookies and technologies might collect personal data, or information that becomes personal data when combined with other information we have. To understand more about how we handle your personal data, please refer to our Privacy Notice.

What are Cookies and Tracking Technologies?

Our website and applications use cookies - small files downloaded to your device that help us and our third-party partners gather information about your interactions with our websites, email communications, and other online services to improve your experience. We and our third-party partners and providers may also use other similar technologies, such as web beacons, pixels, embedded scripts, location-identifying technologies, and logging technology (collectively called “cookies”).

Our Use of Cookies

We, along with our partners, use cookies to gather information about how you interact with our websites, mobile application, emails, and other online services. This helps us improve your experience and understand how people use our services.

The Kind of Information We Collect Automatically

The kind of information we collect automatically includes:

• Details about your device and software (operating system, browser type).
• When you visit and how you use our services (pages viewed, time spent).
• We may track email opens and clicks to see if you received and interacted with our emails with your consent.
• We may also use analytics tools to see usage trends and understand our user base.
• Information about your location may also be collected based on your IP address.

Types

• Essential Cookies: These are crucial for basic functions like security and navigation. Turning them off will affect how our website works. We use these because it's in our legitimate interest to provide and maintain our website and services.
• Functional Cookies: These remember your choices (such as language, region) to personalize your experience. The legal basis for these is our legitimate interests in providing and maintaining our services.
• Performance Cookies: These help us recognize and count visitors, and understand how you navigate our services. This helps improve our services by ensuring you can easily find what you need. We will only use these cookies with your consent.
• Targeting Cookies: These cookies record your visit to our website, the pages you visited, and the links you followed, and are used to track visitors. We will ask for your consent to use these cookies. You are free to deny this consent.

Sources

• First-Party Cookies: These cookies are created by our website and can only be accessed by us. They are typically used to remember your preferences (language, location) and improve your experience on our services.
• Third-Party Cookies: These cookies are placed on your device by other companies (third-party partners) whose services we integrate into our website. These cookies are used for various purposes, such as analytics, advertising, and social media integration.

Duration

• Session Cookies: These cookies are temporary and are automatically deleted when you close your browser.
• Persistent Cookies: These cookies remain on your device for a predetermined period of time (set by the cookie itself or by us) even after you close your browser.

Why We Use Cookies

We use cookies for various reasons, which can be broken down as follows:

• Set you apart from other users on our sites, ensuring you have a great browsing experience and helping us enhance our sites.
• Gain a better understanding of your preferences to display advertisements that match your interests based on your activity on our sites.
• Collect data on how our Services are used to improve our offerings.
• Improve site security by preventing fraud and abuse.
• Identify your preferences and track your activity to ensure the site functions smoothly and the content you see is personalized and accurate.
• Keep track of your language choice, browsing activity, browser type, device, and favorite products to present relevant content to you.
• Deliver the right information based on how you accessed the site, whether through a search engine or an affiliate network.

Managing Your Cookie and Advertising Preferences

You have choices when it comes to cookies and their use for advertising! Here's how you can manage them:

Browser Settings

Most browsers allow you to adjust your cookie settings in several ways, including:

• Get alerts when a cookie is sent, letting you decide to accept or reject it.
• Remove cookies already stored on your device.
• Set your browser to automatically reject all cookies.

Please note that disabling cookies may negatively affect the functionality of this and other websites you visit, potentially leading to reduced functionality and features of our website. You can limit interest-based ads displayed on your current browser by visiting optout.aboutads.info or networkadvertising.org/choices.

Mobile Devices

You can enable the "Limit Ad Tracking" setting on iOS or the "Opt out of Ads Personalization" setting on Android.

Email Settings

You can also configure your email settings to prevent the automatic downloading of images, which can contain technologies that inform us if you have accessed our email and performed certain actions with it.

Google Analytics & Ads

Opt out of Google Analytics by installing their browser add-on and manage interest-based Google ads through their Ads Settings.

Interest-Based Advertising

Block ads based on your browsing habits by visiting www.youronlinechoices.com.

Depending on your device and operating system, you might not be able to delete or block all cookies. Additionally, if you wish to reject cookies across all browsers and devices, you will need to adjust the settings on each browser and device you use.

Learn More About Online Advertising

Here are some resources to understand how advertisers use cookies and your choices:

• Digital Advertising Alliance (General Information)
• European Interactive Digital Advertising Alliance (EU-Specific Information)
• www.aboutcookies.org (Information on Deleting or Controlling Cookies)

Contact Us

If you have any questions or complaints about our use of cookies or this Cookie Notice, you may contact our Data Protection Officer by sending an email to dpo@funid.com.