PRIVACY POLICY

1. Who are we and how can you get in touch with us?

This website is operated by SAPHIRIX SOLUTIONS SRL, registered under number 3-102-933997 and located in PROVINCIA 01 SAN JOSE, CANTON 15 MONTES DE OCA, DISTRITO UNO DE SAN PEDRO, LOS YOSES, AVENIDAS OCHO Y DIEZ, CALLE TREINTA Y NUEVE, SEGUNDA OFICINA A MANO DERECHA, LY CENTER. In this instrument the SAPHIRIX SOLUTIONS SRL is referred as ‘we’, ‘us’ and ‘our’.

As the organization determining how and why your personal data is processed, we act as the Data Controller under GDPR.

We’ve appointed a Data Protection Officer (DPO) to oversee our data practices. If you have questions or wish to exercise your rights, you can contact the DPO directly at [email protected].

You can also contact us via Customer Support email - [email protected] - or reach us via chat service on our website.

2. Categories of processed personal data, purposes and legal grounds for processing

We collect only the data that’s necessary for delivering our services and maintaining a safe and compliant platform. The data we gather depends on your interactions with us and may include:

• Identification and contact information: full name, username, date of birth, nationality, gender, residential address, phone number, email, and official identification documents;
• Financial information: payment card or bank account data, source of funds/wealth documentation, and financial verification records;
• Transaction details: deposit and withdrawal history;
• Gameplay activity: logs of games played, bets placed, bonuses used, timestamps, and any responsible gaming actions taken;
• Technical and device data: IP address, browser type, device model, operating system, location, and related diagnostic or usage info;
• Communication and preferences: records of communications with support, feedback, and your marketing choices;
• Other info: anything else you voluntarily provide when interacting with us.

We collect this data directly from you during registration, gameplay, communication with our team, and when verifying your account. We also receive data from trusted third-party partners such as payment processors, identity verification services, fraud prevention databases, and affiliate networks.

We process your personal data for the following purposes:

1. To create and manage your account;
2. To meet legal obligations (KYC, AML, responsible gaming);
3. To process financial transactions securely;
4. To prevent fraud and protect platform integrity;
5. To run AI-Assisted customer communication services;
6. To improve user experience and system performance;
7. To send marketing communications.

We only use your data where we have a valid legal reason. These include:

• Contractual necessity. When processing is required to deliver the services you request (for instance, account access, payments);
• Legal obligation. When we must comply with legal requirements such as anti-money laundering or gambling regulations;
• Legitimate interests. For operating our business responsibly, preventing fraud, protecting users, conducting analytics, provide AI-Assisted customer communications, and, if applicable, sending you relevant offers or updates;
• Consent. When we ask for your permission - for marketing messages, if applicable, or optional features. You may withdraw this consent at any time.

3. Data retention

We retain your personal information only for as long as necessary to meet legal, regulatory, or operational requirements. This may include maintaining records for tax purposes, dispute resolution, and compliance with AML regulations - typically for at least five years after your account is closed.

4. Your rights

You have a number of rights under data protection laws. These include the right to:

1. Access your personal data;
2. Correct inaccurate or incomplete data;
3. Request deletion of your data, subject to legal retention requirements;
4. Restrict processing in certain situations;
5. Transfer your data to another provider (data portability);
6. Object to processing based on legitimate interest or for marketing;
7. Withdraw consent at any time, where applicable;
8. File a complaint with your local data protection authority.

If you wish to exercise any of these rights, please contact [email protected] or our support services. We may need to verify your identity before acting on your request.

5. Data sharing and security of your personal data

To provide our services and comply with regulations, we may share your personal information with:

• Game content providers;
• Payment gateway services;
• Marketing and affiliate partners;
• Legal and regulatory bodies;
• External consultants (e.g., legal counsel, auditors, notaries etc.);
• Identity verification and compliance solution providers and communication service providers etc.;
• Conversational AI processors, such as Anthropic, OpenAI, Gemini, to enable and optimize our customer communication experience;
• Potential successors in the event of a merger or acquisition.

Such sharing is governed by appropriate contractual safeguards to ensure that your information is used only for legitimate purposes and is protected in accordance with data protection laws.

We take data protection seriously and have put strong technical and organizational safeguards in place to prevent unauthorized access, loss, or misuse of personal information. These include:

• Access controls: physical access to facilities, buildings, or rooms where personal data is processed is strictly restricted. Our systems are hosted in secure data centers that comply with high industry standards for both physical and digital security. Only authorized personnel have access to personal data;
• System access controls: all systems that process personal data are protected by authentication measures, including password protection. Each user is assigned a unique ID to ensure secure and traceable access;
• Data access controls: access to data files and programs is granted strictly on a “need-to-know” basis. Measures are in place to prevent unauthorized installation or use of hardware and software. We also maintain procedures to ensure that data no longer required is securely and permanently deleted;
• Organizational measures: we have established technical and organizational safeguards to prevent the unintentional combination or mishandling of personal data. This includes appointing a Data Protection Officer (DPO) and providing regular training to staff on data protection and information security practices.

6. International data transfers

Some of our partners and service providers may be located outside your country. When we transfer your data internationally, we ensure it is protected by adequate safeguards - such as jurisdictions with approved adequacy decisions or Standard Contractual Clauses approved by the European Commission.

7. Automated decision making

We do not make decisions based solely on automated processing that have a legal or similarly significant impact on you. If this changes, we’ll inform you clearly in advance.

8. Policy updates

We encourage you to review this Privacy Policy from time to time, as we may make updates to reflect changes in law, technology, or our services. We’ll take every effort to notify you.