1. Introduction
At www.playmojo.com (“We,” “Us,” “Our,” or the “Website”), safeguarding your personal information is a core commitment.
This Privacy Policy (“Policy”) explains how we, along with our affiliated entities, collect, use, share, and protect your personal data in alignment with applicable data protection laws, including the General Data Protection Regulation (GDPR) and Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA).
This Policy applies to all interactions you have with us, whether through our website or related services we provide.
2. Age Restrictions
Please bear in mind that our services are strictly intended for individuals 18 years of age or older. We do not knowingly collect data from minors. Should we discover that data from an underage individual has been collected, we will take immediate steps to delete it in accordance with applicable legislation.
3. Who We Are
The Website is owned and operated by Aveazure SRL, a company incorporated under the laws of Costa Rica, with registration number 3-102-848946 and registered address at Ofident, Oficina 3, 200 mts norte y 50 mts este del Centro Cultural Norteamericano, Barrio Dent, San José, Costa Rica. We operate under License number 940 issued on May 3, 2023 by the Kahnawake Gaming Commission.
As the operator of this platform, Aveazure SRL is the Data Controller responsible for determining the purposes and methods of processing your personal information.
We have appointed a Data Protection Officer (DPO). If you have questions or wish to exercise your legal rights under data protection laws, you may contact the DPO at [email protected].
4. Contact Us
If you have questions or concerns about this Policy or how your data is handled, you can contact our Data Protection Officer at [email protected].
For general support, please reach out to our Customer Service Team via support email or chat on the website.
5. Categories of Processed Data, Processing Purposes and Legal Basis for processing
We collect and process personal data to provide our services, comply with legal requirements, and ensure a safe gaming environment. Each category of data is collected for specific purposes and processed under a certain legal basis.
1) Identity Data
What data we collect: Full name, username, date of birth, gender, nationality, government-issued identification (e.g., ID card or passport).
Purpose: To verify your identity, comply with regulatory requirements, and ensure account security.
Legal Basis: Performance of a contract and compliance with legal obligations (e.g., KYC and AML).
2) Contact Details
What data we collect: Residential address, documents confirming proof of address, email address, phone number, and other communication channels you use.
Purpose: To communicate with you, verify your address, send notifications, and ensure the delivery of account-related and promotional information.
Legal Basis: Performance of a contract and, for marketing communications, your consent or our legitimate interest.
3) Financial Data
What data we collect: Bank account numbers, payment card details, documents confirming the source of funds or wealth (e.g., income statements or bank records).
Purpose: To process deposits and withdrawals, detect fraudulent activity, and comply with financial regulations.
Legal Basis: Performance of a contract and compliance with legal obligations (such as AML).
4) Transaction Data
What data we collect: Records of deposits, withdrawals, used bonuses, and other payment-related activity on your account.
Purpose: To maintain accurate financial records and detect misuse or fraud.
Legal Basis: Performance of a contract and compliance with legal obligations (such as AML).
5) Gaming Data
What data we collect: Details about the games you play, your gameplay activity (including wagering and session times), bonus history, and usage of responsible gaming options.
Purpose: To personalize your gaming experience, monitor for responsible gaming.
Legal Basis: Legitimate interest and compliance with legal obligations.
6) Technical Data
What data we collect: IP address, geolocation data, browser type and version, time zone settings, device type, operating system, and other technical identifiers used to access our platform.
Purpose: To secure the platform, detect unauthorized access, improve service performance, and analyze usage trends.
Legal Basis: Legitimate interest in maintaining security and optimizing platform performance.
7) Marketing and Related Communication Data
What data we collect: Marketing preferences, opt-in status, communication history, and engagement with promotional materials.
Purpose: To provide you with relevant offers, updates, and personalized content, based on your preferences.
Legal Basis: Your consent and/or our legitimate interest in offering relevant services.
8) Communication Data
What data we collect: Any additional information you voluntarily share with us through customer support or other communications.
Purpose: To provide Customer Support.
Legal Basis: Legitimate interest.
6. Where We Get Your Data
We gather your data directly from you or from other sources to ensure functionality and regulatory compliance:
- Verification providers
- Financial institutions (AML/PEP, Sanctions searches)
- Regulatory and gaming safety databases
- Business partners and analytics providers
7. Data Retention
We retain your data only as long as necessary for its intended purpose or as required by law.
Under anti-money laundering regulations, we must retain personal data for a minimum of 5 years following the closure of your account. We are unable to process data deletion requests that conflict with legal retention obligations.
8. Data Sharing
We may share your personal information with the following categories of recipients:
- Game Providers: Game providers like NetEnt may access select personal data to deliver games and support.
- Payment Providers: Payment service providers are given access to the necessary data to process deposits, withdrawals, and other transactions.
- Marketing Partners: If you have given consent, your contact details may be shared with third-party marketing partners for promotional purposes.
- Governmental and Regulatory Authorities: We may share your data with authorities for compliance with legal obligations, including AML requirements.
- AML & Fraud Verification Tools: Third-party suppliers used for fraud prevention and verification purposes.
- Client communication software: We use a third-party software to help us communicate with you. This software enables us to send you emails and chat with you on live chat whenever you have queries.
- Business consultants, lawyers, advisors, notaries who we may engage from time to time to manage risks, obtain professional advice, or to establish and defend our legal claims, whether in court or in an out-of-court procedure.
All third-party data processors are bound by contractual agreements to ensure your personal data is handled lawfully, securely, and solely for the intended purpose.
9. International Data Transfers
When personal data is transferred outside the European Economic Area (EEA) or Canada, we ensure it is protected through:
- Standard Contractual Clauses (SCCs)
- Transfers to jurisdictions recognized by the European Commission or the Office of the Privacy Commissioner of Canada as providing adequate protection
10. Your Rights
Data protection law gives you, as a data subject, certain rights in certain circumstances. In accordance with law, you have a right to:
- Request access to your personal data - This means that you have a right to request, free of charge, a copy of the personal data we hold about you;
- Request the correction of your personal data– This means that if any personal data we hold about you is incomplete or incorrect, you have a right to have this corrected. Keep in mind, however, that we may need you to provide evidence and documentation (such as your ID documentation or proof of address) to support your request. It can be declined due to our legal obligations
- Request the erasure of your personal data- This means that you may request the erasure of your personal data where we no longer have a legal basis to continue processing it or retaining it. Please be aware that this right is not absolute – meaning that we are not able to satisfy your request where we are obliged under a legal obligation to retain the data or where we have reason that the retention of data is necessary for us to defend ourselves in a legal dispute;
- Object to the processing of your personal data where we rely on our legitimate interests (or those of a third party) to process your data, and you feel that our processing of your data in such a manner impacts your fundamental rights and freedoms. However, in some cases, we may be able to demonstrate that we have a compelling, legitimate ground to process your data, which may override your rights and freedoms. You may submit your objections to the processing of your personal data on the grounds of the above-mentioned legitimate company interests by contacting our DPO;
- Request the restriction of the processing of your personal data – You may ask us to temporarily suspend the processing of your personal data in one of the following scenarios: (a) where you want us to establish the accuracy of the data, (b) where our use of the data is unlawful but you do not wish for us to delete it, (c) where you need us to retain your data even when we no longer need it in order for you to establish, exercise, or defend legal claims, or (d) where you have objected the use of your data but we need to verify whether we have to override legitimate grounds to use it – This means you may request us to provide you with certain data we process about you so you may transfer it to another controller. This right only applies to data acquired through automated means, which you initially provided consent for us to use, or where we used the data to perform our obligations under a contract with you;
- Request the transfer of your personal data (i.e. data portability) – This means you may request us to provide you with certain data we process about you so you may transfer it to another controller. This right only applies to data acquired through automated means, which you initially provided consent for us to use, or where we used the data to perform our obligations under a contract with you;
- Withdraw your consent at any time when we rely on your consent to process the data. You may withdraw your consent at any time through the account profile settings on the website;
- Lodge a complaint with a supervisory authority
In order to exercise your rights, as explained above, we may need to request specific information about you to help us verify your identity. This is a security measure to ensure that we are certain that the person to whom we disclose your personal data is really you.
We will do our utmost to respond to all legitimate requests within a one-month timeframe from the submission of a request. If your request is particularly complex, or if you have made multiple requests in a certain time period, it may take us a little longer. In such a case, we will notify you of this extension.
11. Automated Decision-Making
We do not make decisions solely based on automated processing that would produce legal effects or significantly affect you. All actions are checked by humans. If this changes, we will inform you and, where applicable, provide safeguards and options to contest such decisions.
12. Security Measures
We implement a range of physical, electronic, and organizational controls to protect your personal information. These include:
- Physical Access Control: We take stringent measures to prevent unauthorized physical access to locations where personal data is processed. All systems are hosted within secure data centers that comply with recognized industry standards for both physical and cybersecurity. Only authorized individuals are granted entry or access to personal data.
- System Access Control: Systems that handle personal data are protected through secure authentication protocols, including password protection. Every user is assigned a unique ID to ensure traceable and secure system access.
- Data Access Control: Access to data and software is granted strictly on a need-to-know basis. Controls are implemented to block unauthorized use or installation of hardware and software. We also maintain secure procedures for the permanent deletion of data that is no longer necessary.
- Organizational Safeguards: We apply robust technical and organizational safeguards to prevent accidental data mingling or breaches. A designated Data Protection Officer (DPO) oversees compliance, and all employees receive training in data privacy and information security best practices.
13. Updates to This Policy
This Privacy Policy may be revised periodically to reflect legal or technological changes. We will notify you of material updates where required by law. The most recent version is always available on our website.
