At Hero Gaming, transparency is very important to us. We appreciate that you are trusting us with your personal information and we want to be transparent about how we use it.
In this Privacy Policy, we describe the privacy practices for our games, applications, software, websites, APIs, products, and services (the “Services”). You will learn about the data we collect, how we use it, the controls we give you over your information, and the measures we take to keep it safe.
If you have any queries about this Privacy Policy or anything it contains, please contact us by e-mail on [email protected].
Specifically, in this Privacy Policy we will cover:
Information We Collect
When you use our Services, we collect the following types of information.
Information You Provide Us
Account Information
Some information is required to create an account on our Services, such as your name, address, social security number, date of birth, your telephone number and country of residency. This is important data for the ‘Know Your Customer’ process as imposed by the anti-money laundering regulations applicable both in Malta and in the UK. This is the only information you have to provide to create an account with us.
In view of the strict legal obligations imposed upon us we also ask for occupation and source of income. There might be situations in which you are also asked to provide documentary evidence to prove that you are only using legitimate funds.
Additional Information
To help improve your experience or enable certain features of the Services, we may collect additional information such as your game play preferences and payment transaction history.
If you contact us or participate in a survey, contest, or promotion, we collect the information you submit such as your name, contact information, and message.
Information from Third-Party Services
If you choose to connect your account on our Services to your account on another service, we may receive information from the other service. This includes any third-party self-exclusion systems that will restrict or prevent your gambling.
Payment Information
In order to receive payments, you must provide certain information for identification and verification, in addition to payment details which identify your transaction. This information is encrypted and sent to your card network, which upon approval sends back a token, which is a set of random digits for engaging in transactions without exposing your card number. For your convenience, we store the last four digits of your card number and your card issuer’s name and contact information.
Information We Receive from Your Use of Our Services
We receive the following information when you use our services.
Location Information
We may also derive your approximate location from your IP address.
Usage Information
When you access or use our Services, we receive usage data. This includes information about your interaction with the Services, for example, when you view or search content, create or log into your account, collect a bonus or play a game.
We also collect data about the devices and computers you use to access the Services, including IP addresses, browser type, language, operating system, the referring web page, pages visited, location, and cookie information.
Cookie Information
Our Websites use “cookies”. A “cookie” is a piece of software, which may be sent to your computer. Cookies enable us to collect information about how our Websites and services are being used and to manage them more efficiently. The information gathered through cookies may include:
Should you wish to reject all, or certain cookies used by our Website, you may modify your Web browser preferences to do so. If, however, you reject all cookies then you might be unable to use some of the services available on our Website. You may also set your browser to notify you when you receive a cookie, giving you the opportunity to choose whether or not you wish to accept it. You should note however that if you do so, this may distort the quality of service and data you receive.
How We Use Information
We use the information we collect for the following purposes.
Provide and Maintain the Services
Using the information we collect, we are able to deliver the Services to you and honour our Terms of Service contract with you. For example, we need to use your information to provide you with your player dashboard, as well as game suggestions, bonuses, and any other relevant marketing promotions.
Improve, Personalise and Develop the Services
We use the information we collect to improve and personalise the Services and to develop new ones. For example, we use the information to troubleshoot and protect against errors; perform data analysis and testing; conduct research and surveys; and develop new features and Services.
When you allow us to collect location information, we use that information to provide and improve features of the Services.
We also use your information to make inferences and show you more relevant content. For example, we may present to you your favorite games at the top of our games content.
Third Party Websites
Our Websites may, from time to time, contain links to both local and/or international third-party Websites after obtaining permission from them. Any such links are not an endorsement by us of any information in such Websites or products and/or services offered through the same. We shall not accept any responsibility whatsoever for the content, use, availability, privacy practices or the content of any such Websites. Please note that upon entering such other Websites, you become subject to the Privacy Policy of these other sites.
No third party is permitted to link any other Website to our Website without obtaining our prior written consent.
How we Communicate with You
We use your information when needed to send you Service notifications and respond to you when you contact us. We also use your information to promote new features or products that we think you would be interested in. You can control marketing communications and most Service notifications contacting our customer support.
Use of E-Mail for Communications
All e-mail messages are routinely scanned for viruses. In the case of e-mails, we may reject, delay or remove content from e-mails which have a nature, content or attachments which may disrupt our systems or because they may pose security issues such as viruses. We may also filter out e-mails which contain certain content on the basis that content is offensive or the e-mail is unwanted or spam. In certain circumstances this may unfortunately result in “innocent” e-mails being affected but we do try and reduce such occurrences.
Please be aware, however, that data sent through the Internet may technically be transmitted across international borders even where sender and receiver of information are located in the same country. Consequently, personal information relating to you may be transmitted via a country having a lower level of data protection than that existing in your country of residence.
How Information Is Shared
For External Processing
We transfer information to our affiliates, service providers, and other partners who process data for us, based on our instructions, and in compliance with this policy and any other appropriate confidentiality and security measures. These partners provide us with services globally, such as information technology, payments, customer service, marketing, data analysis, research, and surveys.
In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a sale of all or any portion of assets or shares, we may share your information with third parties in connection with such transaction for the sole purpose of completing that transaction. If another entity buys us or part of our business, that party will have the right to continue to use your Personal Data, subject to the terms of this Privacy Policy.
Analytics and Advertising Services Provided by Others
We work with partners who provide us with analytics and advertising services. This includes helping us understand how users interact with the Services, serving advertisements on our behalf across the internet, and measuring the performance of those advertisements. These companies may use cookies and similar technologies to collect information about your interactions with the Services and other websites and applications.
We may share non-personal information that is aggregated or de-identified so that it cannot reasonably be used to identify an individual. We may prepare such information for research or statistical purposes.
We do not transfer your personal information to any third parties for marketing purposes or for any other purposes other than listed above.
For Legal Reasons or To Prevent Harm
Without prejudice to anything contained in this Privacy Policy, we are obliged to disclose personal data relating to you to any third party if such disclosures are necessary inter alia for the following purposes:
Our policy is to notify you of a legal process seeking access to your information, such as search warrants, court orders, or subpoenas, unless we are prohibited by law from doing so. In cases where a court order specifies a non-disclosure period, we provide delayed notice after the expiration of the non-disclosure period.
Your Rights to Access and Control Your Personal Data
We provide you with account settings and tools to access and control your personal data, as described below, regardless of where you live.
Accessing and Exporting Data
By logging into your account, you can access much of your personal information, including your dashboard. Using your account settings, you can also download information in a commonly used file format.
Editing and Deleting Data
Your account settings let you change your personal information. For instance, you can edit the profile data you provide or delete your account if you wish.
If you choose to delete your account, please note it may take up to 30 days to delete your transactional data, like the data recorded during your games. This is due to the size and complexity of the systems we use to store data.
We recognise your right to be forgotten, however we have a legal obligation due to Anti-Money Laundering (AML) regulations to retain all personal account data, obtained for customer due diligence purposes, such as your name and address and all documentation gathered during registration and payment processes for a period of 5 years after you close your account. You may also wish to note that this period may be extended by a further 5 years through a specific notification by the competent authorities.
Customising or Restricting your Data Use
We provide you with account settings and tools to control your data use. For example, through your privacy settings, you can limit how your information is visible to other users of the Services; using your notification settings, you can limit the notifications you receive from us.
You have a right to object to the use of your information for direct marketing purposes. Please see your notification settings to control our marketing communications to you about new games and products. Please also review our Cookie Use statement for your options to control how we and our partners use cookies and similar technologies for advertising.
If you need further assistance regarding your rights, please contact our Data Protection Officer via email on [email protected], and we will consider your request in accordance with applicable laws. You also have a right to lodge a complaint with your local data protection authority or with the Malta Data Protection Commissioner, our lead supervisory authority.
Data Retention
We keep your account information, like your name, social security number, and password, for as long as your account is in existence because we need it to operate your account. In some cases, when you give us information for a feature of the Services, we delete the data after it is no longer needed for the feature. We also keep information about you and your use of the Services for as long as necessary for our legitimate business interests, for legal reasons, and to prevent harm, including as described in the How We Use Information and How Information Is Shared sections.
Promoting Safety and Security
We use the information we collect to promote the safety and security of the Services, our users, and other parties. For example, we may use the information to authenticate users, facilitate secure payments, protect against fraud and abuse, respond to a legal request or claim, conduct audits, and enforce our terms and policies.
For personal data subject to the GDPR, we rely on several legal bases to process the data. These include when you have given your consent, which you may withdraw at any time using your account settings and other tools; when the processing is necessary to perform a contract with you, like the Terms of Service; and our legitimate business interests, such as in improving, personalising, and developing the Services, marketing new features or products that may be of interest, and promoting safety and security as described above.
Information Security
We work hard to keep your data safe and make all reasonable efforts to safeguard the confidentiality of all personal information that we process. We regularly review and enhance our technical, physical and managerial procedures to ensure that your personal data is protected. These cover areas such as access control, authentication, audit, monitoring, alarms, data storage and back up and transmission standards. This is to ensure there is no unauthorised access or modifications to data, no improper use or disclosure, or unlawful destruction or accidental loss.
Our security policies, rules and technical measures are dedicated to the protection of the personal information that we have under our control. All our employees and third-party data processors, who have access to and are associated with the processing of personal information, are further obliged to respect the confidentiality of this personal data and are subject to a code of conduct which requires them to adhere to privacy principles.
By its very nature however, the Internet is not a secure medium and data sent via this medium can potentially be subject to unauthorised acts by third parties. No method of transmitting or storing data is completely secure, however if you have a security-related concern, please contact Customer Support.
International Operations and Data Transfers
We operate internationally and transfer information to other countries for the purposes described in this policy.
We rely on multiple legal bases to lawfully transfer personal data around the world. These include your consent, the EU-US and Swiss-US Privacy Shield, and EU Commission approved model contractual clauses, which require certain privacy and security protections. You may obtain copies of the model contractual clauses by contacting us.
Privacy Compliance
Our Privacy Policy is compliant with the Data Protection Act (Chapter 440 of the laws of Malta), any future data protection legislation as may be enacted by the Maltese legislator from time to time, and any other European Union data protection legislation, including but not limited to the General Data Protection Regulation (GDPR).
Changes to This Policy
This Privacy Policy may be modified at any given time, particularly where statutory obligations so require, or the interest of our users’ security so requires. Any such changes will be posted here so that you are always kept informed of how and why we process your personal information.
We will notify you before we make material changes to this policy and give you an opportunity to review the revised policy before deciding if you would like to continue to use the Services.
Who We Are and How to Contact Us
If you have questions, suggestions, or concerns about this policy, or about our use of your information, please contact our support on [email protected]
If you live in the European Economic Area, United Kingdom, or Switzerland, then Hero Gaming, a Maltese company, controls your personal data and provides you with the Services. If you are seeking to exercise any of your statutory rights, please contact our Data Protection Officer at [email protected].
Contact info to Data Controller
Hero Gaming Ltd
Level 0, Spinola Park
Triq Mikiel Ang Borg
St. Julian's SPK1000
Malta
Contact details to Data Protection Officer (DPO): [email protected]
Your personal data is hosted in Malta and backed up on cloud servers within Europe.