Effective from: 01.06.2018
Last updated: 13 September, 2024
Personal Data means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements;
Controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law; Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
Recipient means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing;
Third party means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data;
Consent of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;
Personal data breach means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed;
Group of undertakings means a controlling undertaking and its controlled undertakings;
Supervisory authority means an independent public authority which is established by a Member State pursuant to Article 51 GDPR;
This notice together with the General Terms and Conditions available on the site sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By registering a Player Account with the Website you confirm your acceptance of this Privacy Policy. Please be advised that if you do not accept the terms outlined in this Privacy Policy and choose not to provide the necessary personal information, your access to certain features and services offered on this website may be limited.
Please note that this Privacy Policy constitutes an agreement between you and the Company. It is important to note that this Privacy Policy may be periodically updated and revised. While we will make reasonable efforts to inform you of any significant changes, we recommend that you review this Privacy Policy regularly to stay informed of our current practices regarding the collection, use, and protection of your personal information. Your continued use of the Website and/or its services will constitute your acceptance of the Privacy Policy.
www.rtp-casino.io values your integrity and privacy immensely and is committed to managing all your personal data in a transparent, fair and lawful manner. This privacy policy (together with the Terms & Conditions and the Cookie Policy) sets out the basis upon which www.rtp-casino.io collects, stores, and uses your personal data when you visit our website, as well as what your rights are, and how the law protects those rights according to the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation)
This website is solely intended for persons over the age of 18, and we do not knowingly collect data relating to persons under such age. If it becomes apparent to us that we have collected personal data relating to persons under the age of 18, due to reasons relating to abuse of our website, we do our best to ensure that such data is handled in accordance with applicable law.
The website www.rtp-casino.io ("Casino", "Website", “Company”, "We", "Us", "Our") is owned and operated by Hollycorn N.V., a company registered and established under the laws of Curaçao, with registration number 144359 and registered address at Heelsumstraat 51 E-Commerce Park, Curaçao. Hollycorn N.V. is licensed and regulated by the Curaçao Gaming Control Board (license no. OGL/2023/176/0095).
As a data controller, we have a legal obligation under gambling regulations to process personal data from players in order to allow them to participate in games and provide them with ancillary services.
When we mention “Company”, “Group”, “we”, “us” or “our” in this privacy notice, we are referring to the Hollycorn N.V.
We take your privacy seriously. For this reason we have appointed a data protection officer (“DPO”) whose responsibility is to oversee that the company is compliant with its legal obligations in respect of the processing of your personal data, and who is your contact point for any questions relating to this Privacy Policy. Should you have any queries about this policy, including any request to exercise your legal rights, and complaints about violation of your rights please contact our DPO using email [email protected].
You may always contact us in regards to this Policy should you wish to:
To fulfill your requests in accordance with this privacy policy, you can use the following means of communication:
Please note that in some cases emails may end up in spam or may not reach the addressee at all for technical reasons.
If your request is not answered within 10 days we strongly recommend you to contact us again for clarification using alternative methods of communication.
We respect and value your privacy. You can always contact the Data Protection Officer via [email protected] in cases where
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
During the course of delivering services to you, we are also working closely with third party data processors, joint or/and independent data controllers (including, for example, business partners, sub-contractors in technical, payment and delivery services as well as for delivery of marketing information (such as CRM Tool Providers, Email Marketing Partners, SMS Providers, Direct Mail Distributors and Outbound Call providers,) advertising networks and affiliate networks, analytics providers, due diligence intelligence companies, search information providers, credit reference agencies). This category includes information we receive from our Publishers, Advertisers and other Partners that we work with to help us deliver ads and personalized content to you and recognize you across browsers and devices. This may include pseudonymous advertiser identifiers that some Advertisers or other third-party ad platforms choose to share with us. Data processors process personal data according to our written instructions and their activities will be limited to those that are needed from them to assist us deliver the service to you.
Personal data means any information about an individual from which that person can be identified directly or indirectly. It does not include data where the identity has been removed (anonymous data).
The personal data collected and processed on you can be grouped into the following categories:
Identity Data includes first name, middle name, last name, email, username or similar identifier, date of birth, gender.
Contact Data includes residential address, email address, telephone numbers and other available means of communication.
Financial Data includes details of your salary and wealth, details of the sources of funds used to deposit with us, as well as bank account, payment card or payment account details, including information contained within any bank statements, scans of documents, confirming your income and similar documentation collected for KYC Purposes.
Transaction Data includes details about deposits and withdrawals, wagering and other details of games you have played on our sites.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Usage Data includes information about how you use our website, products and services, online identifier to login (email), password (encrypted), games played, login and logout times, duration of play, bonuses and promotions claimed, responsible gaming information, limits and history and AML classification.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Special Categories of Personal Data. In the event that you provide us with such information yourself and In fulfillment of our legal obligations, we must also collect some Special Categories of Personal Data about you such as
Information you give to us:
Information we collect about you:
Information we receive from other sources:
We will combine this information with information you give to us and information we collect about you. We will use this information and combined information for the purposes set out above (depending on the types of information we receive). Other sources include third party service providers of age verification tools, identity or address verification services, regulators or entities that keep central databases of problem gamblers, providers of PEP and Sanction searches, and other similar providers who we may contract with from time to time. We may also receive information about you collected from the other sites operated by the Group which helps us deliver a better service to you or to keep away bonus abusers, problem gamblers from our services.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. In regards to processing personal data based on a legal obligation, we refer to the provisions of the Anti-Money Laundering Directive (EU) 2015/849 of the European Parliament and the Council, and the Malta Gaming Act (Cap 583).
Data collected |
How do we collect your data? |
Purpose for collection |
Legal basis for processing data |
Identification data – this includes full name, username of choice, date of birth, gender |
Requested upon registration |
(1) Customer identification and creation of unique customer profile (2) Customer verification for Anti-Money Laundering (“ AML”) purposes (3) Identification of customer when contact is made |
(1) Performance of contract (2) Legal obligation (3) Performance of contract |
Contact details – this includes email address, home address, mobile phone number, skype or any other available mean of communication |
Requested upon registration and/or KYC procedure |
(1) Customer identification and creation of unique customer profile (2) Contacting customers for support purposes (3) Dissemination of marketing material of the brand (4) Dissemination of marketing material of another Group brands (5)Verification of player identity |
(1) Performance of contract (2) Performance of contract (3) Legitimate interest (4) Consent (5) Legal obligation |
Data required for verification purposes – this includes your identification documents, proof of address, and possibly source of funds, source of wealth. |
Must be uploaded on player profile upon request; may be requested either through pop up on website or via email. |
(1) Verification of player identity (2) Required in order for us to comply with AML law |
(1) Legal obligation (2) Legal obligation |
Financial data – this would include the financial details relating to your deposit and withdrawal methods of your choice, therefore your bank details, payment card details, or all relevant details relating to the chosen payment methods. |
Collected upon deposit or withdrawal of funds into the player account. Could also be collected where we have queries via email / chat / calls |
(1) Required to provide you with the service (i.e. to deposit funds into player account) (2) Required for Know-Your-Customer (“KYC”) checks (source of funds) (3) Required for cybercrime checks (4) To ensure a closed-loop policy |
(1) Performance of contract (2) Legal obligation (3) Legitimate interest (4) Legal obligation |
Transaction data – this includes details relating to payments made to and by you; |
Automatically generated when deposits and withdrawals are made |
(1) Required to provide you with the service (2) Required to comply with AML law and gaming licence requirements (3) Required to track your activity for social responsibility measures |
(1) Performance of contract (2) Legal obligation (3) Legal obligation |
Gaming data – this includes details relating to the games you play on our website (i.e. your gaming activity) |
Automatically generated with gaming activity |
(1) Required to provide you with the service (2) Required to comply with remote gaming law |
(1) Performance of contract (2) Legal obligation |
Data relating to your communications with us (via email, live chat, phone call) |
Email correspondence and live chat when contact is made, phone calls may be recorded for record-keeping requirements |
(1) Required to provide you with the service (for customer queries, communicating necessary issues) (2) May be used to manage risks, obtain professional advice, or to establish and defend our legal claims, whether in court or in an out-of-court procedure |
(1) Performance of contract (2) Legitimate interest |
Profile data - Data relating to your gaming habits and your preferences |
Automatically generated with game play, or using cookies to log preferences |
(1) May be used in aggregated and anonymised form to improve service (2) May be used for a more personalised user experience (3) Segmentation for AML and social responsibility measures (4) Targeted marketing |
(1) Legitimate interest. Data in anonymised form is not personal data after that. (2) Consent (3) Legal obligation (4) Consent |
Responsible Gaming Data |
Self-assessment test |
(1) Responsible gaming profiling (2) Identification and investigation of gaming activity for responsible gaming purposes |
(1) Legal obligation (2) Legitimate interest |
Technical data - this may include your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, operating system and platform. Usage data – includes data relating to how you use our website |
Cookie data |
(1) Location data / IP used to ensure customer is not from a restricted or high-risk country (2) Location data / IP address also used to ensure that they do not use proxies or VPNs, to ensure that they do not abuse bonuses or defraud by application fraud (3) All other data (including location and IP) is used to improve website functionality, troubleshoot technical issues, create more products for different platforms |
(1) Legal Obligation (2) Legitimate interest (3) Legitimate interest |
My RTP data – May include your hit rate, total number of spins, overall RTP on your account, your own RTP compared to the games’ RTPs, biggest win on specific games and bet placed to achieve that win |
Automatically generated with gameplay |
(1) To ensure we are in line with all the relevant requirements regarding the RTP of our services. |
(1) Legal Obligation |
Cookie data – please see our Cookie Policy for further information on how and for which purposes we collect your cookies. |
Due to the nature of our service, in order to process your data as explained above of this Privacy Policy, we may need to share your personal data with a number of trusted third parties. These third parties include:
Our employees who have access to, or are associated with the processing of the player’s personal information, have signed confidentiality agreements (NDA) to respect the confidential nature of the player’s information.
- Game providers – sometimes our game providers would require access to select data attributes (such as username and IP address, for instance), in order to provide us with the games you play on our website. To check their privacy notice please visit the relevant website of Game provider;
When you play casino games developed by NetEnt, NetEnt’s Privacy Policy also applies. This policy can be found here.
- Payments providers and related service providers – similarly, we may share some of your personal data with the payment providers you use to make and receive payments on our website. To check their privacy notice please visit the relevant website of Payment provider you’ve used;
If the Website needs to share data with its payment processors to facilitate payment transactions in accordance with their privacy policies. (In particular, most banking card transactions are processed by Trustly whose privacy policy applies to such transactions. Transactions may also be processed by Bambora or Paysafe );
We always ensure that any third party having access to your personal data is bound to respect the security of your personal data, and to process it in a lawful manner at all times and in compliance with our Privacy Policy and strict codes of conduct. We do not allow any third-party service providers to use your personal data for their own purposes. Processing by such third parties (also known as “Data Processors”) is solely carried out for specific purposes and in accordance with our instructions as Data Controller and on our behalf, and such third parties may only use your personal data to the extent to which we ourselves are entitled. Furthermore, in all cases, we strive to ensure that we do not share more data than is necessary to be shared for the service providers to carry out the processing activities in accordance with our instructions.
It may be necessary for us or our service providers to transfer your personal data to countries outside of the European Union (EU), the European Free Trade Association (EFTA) regions, and the European Economic Area (EEA) in order to provide you with our services or engage with service providers and data processors. However, In accordance with the General Data Protection Regulation (GDPR), we are obliged to ensuring the protection of your personal data during these transfers.
This transfer may be necessary in order to provide you with our services such as:
a) Processing your bets and payment transactions; b) Providing you with gaming and other ancillary services that you seek from our Website; c) Identifying and performing the necessary verification checks;
To guarantee an appropriate level of protection for your personal data during transfers to third countries, we implement appropriate safeguards such as European Commission’s standard contractual clauses for data protection. We also take all necessary measures to ensure that your information and data is treated securely and in accordance with this Privacy Policy and all applicable data protection laws.
By using our services and accessing our website, you accept possible transfer of your personal data to third countries and the implementation of these safeguards. If you have any questions or concerns regarding these transfers, please do not hesitate to reach out to us.
We shall only retain your personal data for as long as necessary in view of the purposes for which they were collected. Such purposes could include the satisfaction of any legal, accounting, or reporting requirements.
When determining the appropriate retention period applicable to your data, we take several factors into consideration, such as the purposes for which we collect and process such data, the applicable laws and/or regulatory requirements imposed on us, the nature and sensitivity of the personal data, and the potential risks surrounding the unauthorised use or disclosure of such data.
As stated under our Terms and Conditions both, you and the Casino can decide to have your Player Account closed at any time. Following closure of your account, we will retain your personal data on record for as long as required by law. This data shall only be used should it be required by competent authorities in cases of enquiries regarding financial and fiscal records, fraud, money laundering or investigations into any other illegal activity.
We may also keep anonymized derivatives of your data to improve our content and marketing communications where no automated decision making is involved.
You are to note that due to anti-money laundering regulations in licensed gaming jurisdictions in the European Union, we are obliged to retain personal data of players submitted during registration and any data passed on during the operative period of a Player Account for a minimum of five years from last player transaction or account closure. Therefore, requests for erasure prior to the lapse of this period cannot be entertained.
Data protection law gives you, as a data subject, certain rights in certain circumstances. In accordance with law, you have a right to:
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.
In establishing and carrying out our business relationship, we generally do not make use of fully automated decision making. If we use this procedure in individual cases, we shall inform you of this separately, provided it is a legal requirement.
We hereby acknowledge that in collecting and processing your Personal Information for the purposes of managing your Player Account, we are bound by strict legal provisions on the protection of personal data.
Consequently, we endeavor to protect your personal information and respect your privacy in accordance with best business practices, applicable regulations and state of the art. Being committed to providing secure services to players, we will take all reasonable precautions to ensure that all the data that you have submitted to us remains safe.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthoriяed way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.
Player Accounts can only be accessed with the player’s unique ID and password. You may also set up two-factor authentication (2FA) as additional protection from unauthorized use of your account. You are responsible for keeping your login information confidential and making sure it cannot be accessed by another person.