We are committed to protecting our Customers' privacy and we will only collect and process any personal information about you in accordance with this Policy. If you do not agree with the terms of this Policy please do not use the Website or otherwise provide us with your personal information.
1. Data Controller
The Controller of your personal data is Glimmer Limited, Level 3 Portomaso Business Center, STJ4011, St. Julians, Malta. Telephone Number: 00356 - 21383777; email : email@example.com.
Certain sections of the Website and certain services and products (hereinafter “Games”) are operated in conjunction with our third-party Providers. When you access, as registered user, such sections of the Website, or play such games, certain non-personal data, such as the device you are using to access the Website, your browser, your operating system and certain personal data such as your UserID or your Country, are collected and processed by such Providers. In respect of these data, third-party Providers are Data Controllers in accordance with the applicable legislation and therefore, you may refer to their own privacy policies, which apply in these instances.
2. Grounds and Purposes of Processing
As Operator of the Website and as a Company engaged in the highly regulated gaming field, we need to collect and process information about you to manage your relationship with us and therefore to process your bets, including card and on-line payments, to set-up, open and manage your account, to build up personal profiles, to respond to your queries, to provide you with information and updates about promotional offers and our products and services, where you consented to. Additionally, we need to keep and process your data to comply with our legal and regulatory obligations; to pursue our legitimate business interests such as the detection and prevention of fraud, abuses and irregular betting and the protection of our legal position in the event of disputes and / or legal proceedings.
We only collect and process only data and information that you, voluntarily, also following a request, provide to us or which derivate or we otherwise are able to obtain from them.
Where we intended to process it for one or more lawful purposes other than which it was collected, we will provide you with information on such purposes and any other relevant details. In the event that any further purpose requires your consent, we will refrain from the processing until we have explicitly obtained it.
3. Categories of Personal Data we process
In order to open a gaming account with Portomasolive and access our range Games you will be required to provide us with a number of personal information, such as your full name, your date and place of birth, your nationality, your address, your contact and payment details (the “Registration Data”). As part of the registration you will be requested to choose a username and a password, which will be treated in accordance with this Policy.
We are required by law to identify our Customers and we need certain information to manage your relationship with Portomasolive and therefore to collect and archive the Registration Data. If you do not provide this data we may be unable to comply with our obligations and to provide you with our services and products.
Once you opened your account with Portomasolive, in order to fully access all the functionalities of the Website, you may be required to provide us with additional personal information to verify your Registration Data. Such additional information may include, but is not limited to: documentation relating to your residential address or photographic evidence of your identity (the “Validation Data”)
We are required by law to verify the identity of our Customers and we only process your Validation Data to fulfil our legal and regulatory obligations. If you do not provide this data we may be unable to comply with our obligations and we may restrict your account functionalities, suspend or, in certain instances, even close your account.
-Account and Website Usage
Whenever you access any of the Games available on the Website, make a deposit or request a withdrawal, contact our Customer Service for assistance or even for a complaint, we may collect certain information, either personal or not personal, relating to your gaming sessions and, in general, to your usage of such products and services. (the “Account Data”).
Account Data may include, but are not limited to information about how and when you visit the Website, what sections you click on and what device your use; information about the IP address used to access the Website; details of your use of the Games, such as information about when you start a Game or your playing patterns; information we collect through Cookies (as per section below); records of your correspondence with us.
Cookies are small pieces of data sent from a website and stored on the user's hard drive by the user's web browser while the user is browsing. We may use them to improve the Website and to provide a better and more personalised services. Some cookies allows the Website to automatically recognise you and your settings (for example, language or currency), other cookies may be essential for the Website to operate.
If you want to delete any cookies already stored on your computer or stop the cookies that keep track of your browsing patterns on the Website you can do so by deleting your existing cookies and/or altering your browser's privacy settings to block cookies (the process you follow will differ from browser to browser). If you would like more information on how to do this please visit the website cookiesandyou.com .
Deleting our cookies or disabling our future cookies may restrict or prevent you from accessing certain areas or features of the Website.
5. Data Security and Disclosure
We will take all reasonable steps to ensure that your information is kept secure and protected to the highest possible standards. We have appropriate, adequate and effective technical and physical safeguards as well as highly trained personnel to protect your personal information against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.
We are a very structured and articulated Group and therefore we may share your personal data between the parent Companies of the Group when it is necessary to better manage your relationship with us, to comply with our legal and regulatory requirements or to facilitate the exercise of your rights as data subject.
For the purposes of preventing fraud and money laundering and for data verification purposes, we may use a third party company , CREDITINFO MALTA LTD , a Maltese company with registered address at 199, EUCHARISTIC CONGRESS ROAD, MOSTA MST 9036, MALTA,who will record any searches on your file. We may also make enquiries of, and disclose certain details, for example, of how you conduct your account, to such agencies, security organisations and any other relevant third parties for fraud and money laundering prevention.
For the purposes of processing transactions, such as deposits to and /or withdrawal from your account we may use third-party payment service providers which will need to collect and process certain information such as your name, your bank or payment details. The processor of all the transactions on portomasolive is being handle by Apco Limited, a Maltese company with registered address at Nineteen Twenty Three, Valletta Road Marsa, MRS 3000, Malta.
For the purposes of responding to your queries involving technical issues relating to your account with us, we may use third-party providers which will need to access to certain information such as your Registration Data in order to resolve the issues. Our IT Partner and processor of your data for this purposes is Gamologist Limited, a Maltese company with registered address at 114/3 The strand, GZR1027, Gzira.
Where your information is processed on our behalf by any of the aforementioned third parties, we protect your personal data by putting in place contractual clauses and undertakings aimed to ensure that the relevant third-party has in place a level of protection at least as appropriate and adequate as ours.
In respect of your data we process to comply with our legal and regulatory obligations, we might be required to disclose your information to Regulatory bodies and Organisations, such as the Malta Gaming Authority, the Financial Intelligence Analysis Unit and other competent public Authorities.
We will not release your personal information to any third party nor will we transfer it to any third-Country or international organizations.
6. Retention Period
As a general principle, we keep your personal data stored only for the time that is strictly necessary to the processing for the purposes stated in this Policy in relation to the different categories of data or, where you consented to the processing, until you wish to withdraw your consent.
Nevertheless, in some cases we are legally required to retain personal data for a given period of time or for longer periods. In this respect, Registration, Validation and Account data, will be retained, in accordance with this Policy, for up to 5 years after the closure of your account.
7. Your Rights
In relation to the different categories of personal data we collect and process in terms of this Policy, of any of your personal data collected and processed by us in accordance with this Policy, you, as data subject, have a number of rights.
With reference to all the categories of data, you have the right, at any time, to:
- Access your personal data and periodically obtain a free of charge copy of them;
- Rectify your personal data;
- Request the restriction of processing your personal data.
With reference to data we process to pursuit our legitimate interests as stated above, at any time you have the right to:
- Oppose to the processing where you deem that the pursuit of our legitimate business interests is overridden by your rights as data subject;
Additionally you may request information on the assessment we conducted to balance our legitimate interest with your rights and freedom as data subject.
Where you have given your consent to processing, in addition to the right stated above, at any time you have the right to:
- Withdraw the consent to processing without affecting the lawfulness of the processing based on consent before withdrawal;
- Request the erasure of your personal data.
In order to exercise your rights you might be asked to provide us with a form of identification.
You may obtain further information on how to exercise your rights or to request access to or rectification or erasure of your data or to oppose to the processing by sending an email at: firstname.lastname@example.org.
If, at any time, you deem that the processing of your personal data is not being conducted in compliance with this Policy or with any applicable law, you may lodge a complaint with your local Supervising Authority or with the Information and Data Protection Commissioner:
Information and Data Protection Officer, Floor 2, Airways House, Triq Il-Kbira, Sliema. Tel. 00356-23287100; email: email@example.com.
8. Changes to this Policy
9. Right to Data Portability
You have the right to receive personal information you provide to us, in a ‘commonly used machine-readable format’. This allows you to obtain and reuse your information for your own purposes across different services. For example, if you decide to switch to a different provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability. This is not a general right however, and only arises when the processing of your information is:
- based on your consent or where it is necessary for the performance of a contract, and
- when the information is processed by solely by automated means