Privacy Policy

Clobet Limited, trading in this Privacy Policy as Clobet Limited (“we”; “us”), is updated to version 1.1 on March 1, 2019, and is committed to protecting and respecting your privacy. This Privacy Policy (“policy”) forms part of and is incorporated by reference into Clobet Limited’s standard Terms and Conditions.

This policy governs the data which we collect from users and other third parties in the course of our business and the way in which we protect and process such information. Please read this policy carefully to understand how we will treat your personal data.

On May 25, 2018, the General Data Protection Regulation (GDPR) came into force. This Regulation (EU2016 / 679) has been drafted by the European Parliament and its objective is to protect personal data regarding the processing of their personal data and the free circulation of such data.

It is important that you read carefully this clause of Protection of Personal Data, which contains information about what personal data we request, and the treatments we will carry out with them, including assignments to third parties.

1. Data Controller

For the purpose of the General Data Protection Regulation (the “GDPR”), which applies on May 25, 2018, and other data protection laws applicable, the data controller is Clobet Limited (Company Registration C90546), having its registered address at 89, St John Street, Valletta VLT1165, Malta.

2. Right to Information

It is important that you read this Privacy Policy carefully since it contains information about what personal data we request you and the treatments we will carry out with them, including transfers of data to third parties.

This Privacy Policy regulates the access and use of the online service hosted under the domain (www.Lottofy.com and all its subdomains) as well as all the contents, services or products that are displayed therein.

Currently, the regulation that regulates the processing and transfer of personal data in the EEC is the General Data Protection Regulation (GDPR). This Regulation (EU 2016/679) which entered into force on May 25, 2018, was drafted by the European Parliament and its objective is to protect individuals with regard to the processing of their personal data and the free movement of personal data. same.

The provisions of the “GDPR” will be transposed directly into data protection act (“DPA”) Chapter 440 of the Laws of Malta. The relevant data protection authority is the Information and Data Protection Commissioner (“IDPC”)

3. What personal data can we collect from you?

Data regarding you and your business is collected, retained and processed subject to and in accordance with the requirements of the GDPR. We may collect personal data, that includes: name, date of birth, job title, contact information including email address and mailing address, telephone number, demographic information such as postcode, preferences and interests, employer details, pay data/information, IP address, other information relevant to customers, offers and/or promotions. We also collect information about your play and the transactions you undertake, including details of payment methods used, details of the games you played and underlying gaming transactions, your log-in and log-out times, and any limits set or exclusions made.

Since you contact with us, either because you request information about our services, or because you access through a promotion and create an account to manage the benefits of that promotion, (for example, an advertising promotion, Google or any other company with which we participate in promotions), or because you want to be our customer or user, we need to process your personal data.

The purpose of the collection and processing of personal data that you provide us, is to be able to identify you as a “user” or “customer”, give you access to Lottofy and provide you with the services we offer besides being able to:

• Manage yourself as a user, manage your purchases, your results, your prizes.

• Offer you communications with news, commercial communications and advertising.

• Offer you information, through the site or through electronic communications, about the Lottofy services.

• For statistical purposes related to Lottofy.

Your personal data, your contact data and any others that you provide us must be true, complete, exact and updated, so any modification of your personal data must be communicated to us.

It is important that you keep your data updated in the cases of email changes, mobile number changes or changes of address, because we can send you communications of your interest that is fully valid and effective if made to the addresses that you have provided.

We inform you that Clobet Limited will use your mobile phone numbers and your email to inform you, on time, about any aspect related to your virtual account at Lottofy, as well as information about your products will be sent to you via the Internet through web correspondence. You being able, however, to revoke this option at any time.

If you have provided us with the personal data of another person, you confirm that he/she consents to the processing of his/her personal data and that you have informed him/her of our identity as a data controller and provided him/her with a copy of our Terms and Conditions and this policy.

4. Limitation of use to minors

The services offered on this website are not accessible to children under 18 years of age. To be a Lottofy user you must meet the following capacity requirements:

• You must be a PHYSICAL PERSON. The registration of legal persons or entities is not authorized.

• You must be OVER 18 YEARS OLD.

• You must have FULL CAPACITY TO ACT.

• In the registration process you must provide your DATA CORRECT, COMPLETE and ACCURATE.

To comply with the above, from Lottofy we request and verify the personal data of all our customers, excluding those customers who do not meet the legal age allowed, are not natural persons, do not have full capacity to act or whose registered data are not correct or complete.

Parents or legal guardians must protect their children from Internet content. For this you can install software on your computer to filter the contents of the Internet according to the age of your children.

If you have any comment or contribution to make to help us improve our service and prevent access to it by untrained people (under 18 or who do not have full capacity to act), please contact our customer service department.

Lottofy makes the greatest efforts to prevent access by unauthorized persons. In the case that we collect personal data from persons under 18, we will delete this information as quickly as possible. However, no system is invulnerable and some children can escape detection. If you know a person under 18 who has registered with Lottofy, please contact our customer service department at +356 27782748.

5. How do we obtain your personal data?

We have obtained your personal data because you have provided it to us directly or we will have accessed it based on your queries, requests or hiring of a service with us. Too for your browsing on our own websites or that we have obtained from the use of mobile devices telecommunications or other equally legitimate channels.

In some cases, and always in the scope of the type of services that we provide you in Lottofy, we may collect personal data about you that may be provided by third parties and obtained from other sources, provided that you have given us your consent for this case and with this finality.

In case you provide data of a second person to participate with you in any service, please make sure that this person gives his consent for us to process your personal data and for our part, we will treat them in the manner indicated in this information. In case you do not formalize your registration as a customer within a maximum period of 3 months, your data will be deleted.

To access the products and services we offer on this website, you can only do so through the system of keys that we provide in the registration process. The data collection operations are carried out only through three access systems:

• Information about the customer's account; You access it once you have completed the registration form through the password system that the system assigns you in the registration process and the verification system of your email and telephone.

• Through the payment of awards form; Your bank details will only be requested when necessary, for example, for the payment of your prizes and will be eliminated once they have been used for the purpose for which you have provided them.

• Profiling or other automated individual decision making. We may conduct automated decision making or profiling to better understand your centre of interests and preferences and adapt our communications to your profile. However, we want you to know that you have certain rights in respect of automated decision making and profiling, where that decision produces a legal effect on you. Please see below the section on “Your rights under the GDPR” for more information about your rights.

6. Why do we treat your personal data?

We use the information collected about you for the following purposes:

• If you sign up as a client or user or if you hire any of our services, we will also need to process the documentation that proves your identity or information about your bank details to pay the amount of your prizes or means of payment so that you can pay for the services you hire

However, you can oppose this treatment at any time by communicating it to Lottofy through the electronic address [email protected], after proof of your identity. In no case we will sell your personal data to third parties.

• Your personal data can be used to offer you information, offers and personalized contents according to your preferences and needs, in the form of commercial communications either through our Web, mobile application, email, telephone contact or other legitimate channels. In the case of telephone marketing, or by email, we can get in touch with you in order to know your level of satisfaction with our services.

• In accordance with the Law in force at any time, if you are our client and you maintain a contractual relationship with us, we are legally authorized to send you commercial communications, via email or other equivalent electronic means such as SMS or push notifications, regarding services similar to those you have contracted with us. In all other cases we will proceed to obtain your express consent. If you do not want us to send you more commercial communications, or that we contact you by phone, or by email, for the purposes detailed above, you can request it through the address [email protected], or through the link enabled to the effect on the communications we send you.

• To comply with our obligations on taxes, tax, accounting, prevention of fraud or money laundering, Financial Intelligence Analysis (FIAU), Malta Gaming Authority (MGA), Malta Financial Services Authority (MFSA) or other law enforcement agencies will also be necessary treat your personal data, identification, contact, or navigation. The purpose of this treatment responds to the need for verification of identity, age, prevention of fraud and money laundering or compliance with tax reporting obligations.

• For any other treatments different from the previous ones, your express and prior consent may be necessary, and in which case we will inform you previously at the precise moment, being able to deny it at that moment, revoke it or later at any moment, although without retroactive character.

• To ensure the products and services you have chosen are delivered to you in the most effective way, and to assist with the performance of our internal contract, accounting and administrative functions.

• To carry out our obligations arising from any contracts entered into between you and us.

7. What is the legal basis for the Treatment of your Personal Data?

Legal basis for data processing and your consent to use of your data:

We can process personal data on various legal bases. For processing operations for which we obtain consent for a specific processing purpose, Article 6(1)(a) of the GDPR is our legal basis. This consent includes your opting in for use of your data as set out in this privacy policy and you can change that consent at any time by contacting us as set out below.

Our legitimate interest to offer you our service is based on Article 6 (1) (b) OF GDPR, which can be:

• Allow the operation of our website / applications through technical cookies and functions: keep our tools (websites / applications / devices) safe and secure and ensure that they work correctly and improve continuously.

• Manage yourself as a client or to be able to offer you the service you hire us.

• Remission by electronic means, other means of equivalent communication, invitations made by another user, customer, to participate in a group, or offers and news of our services.

• Realization of statistics: to help us better understand your needs and expectations, and to improve our services, websites / applications / devices, etc.

Finally, we can base our processing operations on Article 6(1)(f) of the GDPR: this legal basis is used for processing operations which are not covered by the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data

8. How Long will we keep your personal data?

We take appropriate measures to ensure that any information collected from you is kept only for so long as is necessary for the purpose for which such information is used. We will normally keep your data for a period no longer than five (5) years, unless required to hold your data for a longer period for regulatory purposes.

We normally update your personal data within seven (7) working days of any new or updated personal data being provided to us, to ensure that the personal data we hold about you is as accurate as possible.

We protect your data by:

• Offering you a secure transmission method to send us personal or company information.

• Implementing security policies and technical measures to protect data from:

  • Unauthorized access;

  • Improper use or disclosure;

  • Unauthorized modification; and

  • Unlawful destruction or accidental loss.

9. With whom do we share your personal data?

We will share your personal data with other entities outside of us that we describe in this section, since we are interested in offering you the best possible service and being able to work to improve our website.

Mainly, we will share your data with service providers whose activity is necessary to comply with the contractual obligations to perform the service that we have assumed with you.

We will share your data with banking entities with which we work in order to perform the service we offer, with other entities that provide results information services and with Malta Gaming Authority when it is mandatory or requires this information

Additionally, it is necessary that we share your data with other entities outside of Clobet Limited and that we describe below:

We may disclose your personal information to third parties in the following circumstances:

1. If we are under a duty to disclose or share your personal data to comply with any legal obligation.

2. Where we have received your permission for us to do so.

3. To enforce or apply our Terms and Conditions and other agreements.

4. To protect the rights, property or safety of Clobet Limited, our customers or others.

5. Any third party which assists us in providing the Services, including (but not limited to) payment processors, providers of marketing services.

6. Any contractors or other advisers auditing any of our business processes or who have the need to access such information for the purpose of advising us;

7. If we or substantially all of our assets are acquired by a third party, in which case personal data held about our customers will be one of the transferred assets.

8. Any company within the Clobet Limited Group (including to its employees and sub-contractors) which assists us in providing the Services or which otherwise has a need to know such information;

9. In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.

10. Any law enforcement body which may have any reasonable requirement to access your Personal Information;

11. Any potential purchaser of Clobet Limited or any investors in it or in any company within our Group (including in the event of insolvency).

12. If it is required to do so to deliver our services. We sometimes outsource certain functions of our business to service providers: some of these service providers may use cloud-based systems: in that case, your personal data would be hosted on their servers, but under our direction and control.

13. Any regulatory body or authorized entity which may have any reasonable requirement to access your Personal Information.

14. Any third party which assists us in monitoring use of the Services, including the detection and prevention of fraud and collusion in order to comply with any applicable law, regulation, legal process or government request; and

15. Any third party which can assist us in verifying the accuracy of your Personal Information, including financial institutions and credit reference agencies (a record of the search may be retained by such third party), identity verification entities.

If at any time you wish us to stop processing your Personal Information for the above purposes, then you must contact us and we will take the appropriate steps to stop doing so. Please note that this may mean that your Account will be closed. You may contact us by sending an email to [email protected]

10. What data do we obtain through Cookies and what do we treat them for?

The use of Cookies allows us to optimize your browsing by adapting the information and services offered to your interests, to provide you with a better experience whenever you visit our website.

We may collect information about your mobile phone, computer or other device from which you access the website. Such information may include your domain name and IP address, details of your computer operating system and browser, the website you visited prior to visiting our website and unique number identifiers that are automatically generated by our systems when you visit our website.

Before using our website, you will be informed of our Cookies policy. You can find more information about the types of Cookies, establish your preferences and choose if you want to accept them or not while you are on our website, in the "Cookies" section.

Some of this information is retained in “cookie” files on your computer. These files retain useful information that can speed your navigation through frequently visited sites. They can also retain records that track site usage, preferences and passwords.

These cookies can be disabled or deleted by activating the setting on your browser if you do not wish them to be used. However, if you select this setting you may be unable to access certain parts of our website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log in to our website.

11. Electronic communications?

In accordance with the Laws of Malta and within the framework of the new regulation of the GDPR, If you are a registered user, your data can be processed in order to generate user profiles and send you by email, phone, WhatsApp, commercial information and personalized advertising of your own or of third parties, which may be useful, as well as to participate in surveys and satisfaction questionnaires.

In addition, these personal data may be processed to send you information and communications that are necessary to comply with the services that we have committed to you. In this sense, you are the one who can control these communications in your privacy settings in the following way:

• E-mails of novelties in games. The client can activate / deactivate if he wants to receive e-mails for two concepts:

• Receive weekly Jackpots (Monday)

• Receive news of the weekend (Friday)

• E-mails of activity in the virtual account. The customer can activate / deactivate if he wishes to receive e-mails for five concepts:

• Receive notification of purchase.

• Receive notification of available combinations.

• Receive summary of weekly games (Monday)

• Receive notification of results.

When you fill out an electronic Lottofy form, you have the option of giving us your express consent to send a newsletter, news, events and more relevant information. You can also give your consent for the sending of the following electronic communications:

• Newsletter service about news, events, people, opinion articles, promotions and other contents that we consider relevant for the client at Lottofy.

• Mobile alerts services: Communications to your mobile number informing you of promotions related to Lottofy.

12. What rights do you haver when providing your data and how can you exercise them?

Right of access to data/copies of data

Right of access to know what your data is being processed, for what purposes, the origin of the same and if we communicate or have communicated to third parties. To exercise this right, you can contact us through our contact information or in the email [email protected]

Any access request shall be subject to your providing acceptable proof of identification.

If we are processing your personal data, we will provide you with a copy of that personal data.

If you require additional copies, we may charge a reasonable administrative fee.

Right of rectification of errors

Right to change your data when they are incomplete or are inaccurate or have changed;

You should instruct us to correct or update any personal data we hold about you (for instance, if you change your address or your name) by contacting us at [email protected]

Right to deletion/right to be forgotten

Right to suppress / forget, your data if the purpose for which you facilitated them has disappeared, the treatment is not lawful or you revoke your consent and other assumptions provided for in the law. It should be noted that this is not an absolute right, but we may have legal or legitimate reasons to keep them.

Right to restrict processing

Right to request the limitation of processing while verifying the contestation of the accuracy of the same, or understand that the treatment is illegal and you oppose the deletion of the data or that Lottofy no longer needs your data, but you need them for the formulation, exercise or defense of claims, or have opposed the processing of the same for the satisfaction of a legitimate interest while verifying the existence of the aforementioned interest and its prevalence over your data;

Right to withdraw your consent or change your Account information

In certain circumstances, we must have your consent before we contact you. You have the right to withdraw your consent to processing of your personal data at any time by contacting us at [email protected]

You may update, correct, or delete your Account information and preferences at any time by accessing your Account settings page on the website. Please note that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, satisfaction of legal obligations, analytics or where we otherwise reasonably believe that we have a legitimate reason to do so.

Right to data portability

The right to portability to receive your data in a structured electronic format that is commonly used and be able to transmit it to another person in charge. It is only possible to exercise this right with respect to data that you have provided, when the treatment is based on the execution of a contract or your consent and the processing is carried out by automated means.

Right to object to processing

You have the right to object to:

• Processing based on legitimate interests or the performance of a task in the public interest / exercise of official authority (including profile).

• Direct marketing (including profiling).

• Processing for scientific / historical and statistical research purposes.

Rights related to automated decision making and profiling

Right not to be subject to automated individual decisions so that we do not make a decision about you based on the treatment of your personal data that produces legal effects in your personal sphere or affects you in a similar way and as long as the decision is not necessary for entering into, or the performance of, to contract between you and us; You are not based on your explicit consent.

Right to lodge a complaint with a supervisory authority (ies)

Right to file a claim with a control authority; You have the right to complain to the Malta Data Protection Agency, the privacy and data protection practices of Lottofy. Do not hesitate to contact us before submitting a claim to the competent authority.

Right to basic Information

You have the right to obtain clear, transparent and easy to understand information about how we use your personal data and about your rights. We provide this information in this Privacy Policy.

13. Customer consent

To become a Lottofy User you must first create a customer / user account. For this purpose, we will request the following information:

We may collect personal information, including: name, date of birth, job title, contact information, including e-mail address and postal address, telephone number, demographic information such as postal code, preferences and interests, details of the employer, data / payment information, IP address, other information relevant to customers, offers and / or promotions.

These data are marked as "required" in the registration process. By registering, through the use of registration forms, you guarantee that your personal data is accurate, complete, true and proper, and you are responsible for communicating any changes to your data.

In Lottofy we have contracted the services of housing and accommodation to a company located in Malta. In the future we can change the provider of this or another service. By registering as a user / customer, you accept that your data is hosted on servers hosted by this company and you accept that Clobet Limited acts as the person in charge of processing your personal data.

As a customer you have the option of "saving credit card data" and you are giving us your consent to save in our database, your credit / debit card data, for future payments using this means, always with your consent. For this you must choose this option to save data, in your user configuration. Clobet Limited will keep the numbering of your card, the expiration date and your name and surname, with the exception of the CVV2 code of your card.

In the same way as a Customer you can choose the option "save bank account data" and with this you give us your consent to save in our database, the data of your bank account, for future payments using as a means of payment the direct debit. For this you must choose this option to save data, in your user configuration.

14. Links to other websites

Lottofy may contain links to other websites. Obviously, we are not responsible for the actions of third parties outside Lottofy and its privacy practices. We advise you that when you leave Lottofy you remain attentive and read the Privacy Policies and Conditions of Use of each of the Websites that collect personal information. This Privacy Policy only applies to the information we collect.

15. Security Advice

It is advisable to protect your computer

You can take some actions to protect your computer from malicious attacks by hackers who may try to access your computer to access your personal and banking information, or to attack other computers through your computer.

To avoid this, you can install on your computer or keep updated in your case, an antivirus, anti-spyware and even an updated firewall to restrict unauthorized access to your computer.

Be careful when accessing or clicking links included in emails or Web pages, which are not trusted, as they could be false or include malicious software. Avoid accessing your Lottofy account through a computer located in a public place with free access.

Use a secure password

You can use a password that contains 8 characters or more. It is recommended that the password contain letters, numbers and other characters. Avoid the use of dates, names or data that may be known. Avoid communicating your password to third parties and do not use the same password for other websites.

Protect your personal data, passwords, bank details.

From Lottofy we will NEVER ask you to confirm your User Account or confirm your password. Lottofy will NEVER send you an e-mail, SMS, or message on your answering machine requesting your username, password, bank details, card details, etc. In the case that you suspect that the data referring to your Lottofy account may have been obtained by third parties, please contact our Customer Service Department as soon as possible.

At the end of your visit to our Web, and whenever you have accessed as a user, we recommend that you close the session. You can locate the icon to close session in your user panel.

Although from Lottofy we take measures to minimize and prevent these risks, this "Close Session" action will prevent an unauthorized third party from accessing your personal data on our website, or even avoid a possible session theft.

16. Transfers outside the European Economic Area (EEA)

We may transfer your personal data outside the EEA in the unlikely event that we receive a legal request from a foreign law enforcement body. All requests for information we receive from these bodies will be checked before personal data is transferred.

We will only transfer your personal data to countries which are considered as providing an adequate level of legal protection or where alternative arrangements are in place to protect your rights.

We may use remote website server hosts to provide and maintain some aspects of our service and website, which may be based outside the EEA (in “the cloud”).

17. Changes to our Privacy Policy

Any changes in our Privacy Policy in the future will be published on this page and on our website. Please check this page from time to time to make sure you are happy with any changes we make.

If you have any questions or doubts about our privacy policy, or if you wish to request information about our privacy policy, please contact us by email or write to the address on the Contact Us page of the website.

18. Contact

Clobet Limited has appointed a Data Protection Officer (“DPO”) who is responsible for matters relating to privacy and data protection. Clobet Limited’s DPO can be reached by sending an email to [email protected].