PRIVACY STATEMENT
This website and its subsidiaries are committed to respecting and protecting the confidentiality of users' personal data. The paragraphs below outline the protection and use of the data provided by the users of this website.
We recommend that every user carefully reads and understands the privacy policy described below before making use of our offered services.
1. Identity and contact details of the controller
The controller for Hotwin.be is:
ANTWERP GAMING CLUB NV, with its registered office at 1853 Grimbergen, Romeinsesteenweg 592, a company duly incorporated in Belgium, under company registration number 0462.255.082. ANTWERP GAMING CLUB NV holds a B licence under Belgian law for the operation of offline games of chance in a Class II establishment and an additional B+ licence under Belgian law for the operation of games of chance via information society tools.
The user can contact the controller if he wishes to retrieve more information. The controller is hereinafter also referred to as the operator.
2. Definition of a privacy policy
A privacy policy is a website’s way of informing its users about how they ensure the protection of privacy on their domain while processing data. Most websites use cookies and trackers that process personal data from their users.
3. Collection of personal data
Definition of Personal data
Personal data is any kind of information that can identify a living individual, either directly or indirectly. Personal data includes names, e-mails, addresses, location data, and online identifiers such as IP addresses, unique IDs, searches, and browser history.
All personal data provided is stored on the operator's platform and remains strictly personal and confidential. The sensitive information is stored in encrypted form.
The categories of personal data stored are:
Personal identification, such as name, address, date of birth, place of birth, gender, and phone number;
Electronic identification, such as username, email, browser type, and IP address;
Identity card or passport number/national number;
Financial identification and transactions.
All of this data is provided by the user, except for the data received from business partners and other organizations, such as specialist companies providing verification services, credit reference agencies, and fraud prevention agencies.
Personal data collected may include so-called “special categories of data”, such as data revealing health (responsible gambling related).
In case of personal data modification, users are requested to update their account information or to contact the support team with notice of the change in their account information, so that correct personal details are always available.
4. Purpose of the collection of personal data
The processing of the user’s personal data is done confidentially and in compliance with national and international legislation.
Collecting personal data is essential for the provision of the services and products offered. Different bases are relied on for the processing of personal data.
4.1. Under the contract
The terms and conditions which the user is required to accept at registration set out the terms of the contract.
to provide gaming and betting services, activities, or online content, to provide the user with information about them, and to deal with their requests and inquiries;
for “service administration purposes”, such as password resets, service messages, or updates to our policies.
to process user transactions.
4.2. Under legitimate interests
To personalize the user experience. The gaming history of the user can be used to personalize promotional offers and recommend content. The user can unsubscribe from any personalized marketing offers, which require his consent, at any time;
To improve our products and services;
To be able to communicate with the user.
4.3. Under legal obligation
In order to comply with mandatory legal obligations to which the operator is subject under EU or local laws.
to verify if the user is allowed access in accordance with the operator's license conditions;
crime detection, prevention, and prosecution;
to verify the user his identity and establish the source of funding in any transaction;
to carry out appropriate anti-fraud checks. This will however not affect the user his credit rating;
to assess and manage any potential risks.
4.4. Under your consent
for marketing purposes and for the provision of the offered services, the user his username is reproduced on the website, as well as that of its partners, when the user wins a tournament, winnings, a prize, and/or bet, but only if the user has previously agreed to make his username for this purpose. The user can change this consent online at any time.
to send the user relevant offers and news about the products and services in a number of ways including by email, SMS, post, social media targeted advertising, but only if the user has previously agreed to receive these marketing communications. The user can change his marketing choices online at any time.
5. Recipients of personal data
The user his collected personal data will be processed confidentially by the personnel of the website. Certain of the user's personal data can be transferred to third parties, but only in the following cases:
We collaborate with service providers, representatives, and subcontractors to ensure support for the internal operations of our website and to help us with the management of the various functions, programs and offers available on the site. These third parties and their employees can also come in contact with the users' personal data when they provide us with their services. All of these third parties are obligated to constantly apply the same level of security to your personal data as the website does and, if necessary, they are bound by an agreement that requires them to maintain the confidentiality and security of the users' personal data and to only process these data according to the specific instructions.
Personal information may be disclosed under a fraud investigation or if it has been requested from a government department due to legal processes and regulations (such as the Belgian Gaming Commission or police department).
In order to protect client information, the website uses the most cutting-edge systems on the market. All information, whether it comes from registration or from financial transactions, is transferred to the website's server using secure encryption technology and a Firewall.
The website and its software are provided with the latest protection technology as well as the means of preventing information leakage from malicious use.
6. Preservation of personal data
The operator sees to the adequate, relevant, and non-excessive collection of personal data, taking into account the purpose of the processing as indicated in this declaration. The user's personal data will not be kept for longer than is necessary to achieve the purpose of processing unless data retention is imposed by a law, decree, or order. Typically this means the user's relevant personal data will be stored for a period of ten years after he ceases being a customer, beginning at the date the user account is closed. There are several reasons why the operator retains the user's information, these include:
to comply with legal obligations under EU/local laws (for example, anti-money laundering regulations, or licensing regulations);
to establish or defend legal claims (for example negligence claims) which could be made against the operator.
7. User rights concerning personal information
The user has the right to access, amend and erase the personal information that the website holds, the right to object to the processing of this data, the right to withdraw consent, and the right to data portability. The user also has the right to lodge a complaint to the supervisory authority if he/she is concerned with how their personal data is processed. In addition, the user has certain rights relating to automated decision-making and ‘profiling’. Further information and advice about the user's rights can be obtained from the organization responsible for the processing of the personal data mentioned above or from the country’s data protection regulator.
Data Protection Authority
Rue de la Presse 35, 1000 Brussels Tel. +32 2 274 48 00 Fax +32 2 274 48 35 e-mail: commission@privacycommission.be Website: https://www.dataprotectionauthority.be
7.1. Right to access and rectify personal data
The user has the right to request a copy of the personal data stored, known as a data subject access request. The user also has the right to request to update incorrect information. These requests are free of charge. To exercise this right, the user must send a written request, signed and dated, to the organization responsible for the processing mentioned above and include proof of your identity by means of a copy of your identity card. A copy of your personal data will be sent to you at the latest 45 days after receipt of your request, when relevant by electronic means.
7.2. Right to erase personal data
In some circumstances, the user can ask the operator to erase personal data (‘the right to be forgotten). This includes when:
the information is no longer necessary in relation to the purpose for which it was collected;
if the user previously gave consent to the use of his information but decides to withdraw it and the operator cannot justify another legal ground for using it;
the information is processed based on the operator's legitimate interests and cannot demonstrate overriding legitimate grounds to continue the processing of the information;
The operator doesn’t have lawful ground under data protection law to process your information;
the data needs to be erased to comply with a legal requirement.
This right is subject to mandatory retention periods under EU and local laws.
7.3. Right to restrict processing
The user has the right to ask the operator to restrict (‘block’ or ‘suppress’) the processing of his personal information. When processing is restricted, the operator can still store the information, but will not use it further. The operator keeps lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in the future. This right is available to you when:
the user disputes the accuracy of the personal information (while the operator verifies matters);
the processing is unlawful, and the user objects to the erasure of the information and request that the operator restricts processing instead;
The operator no longer needs the data, but the user requires it to establish, exercise or defend a legal claim; and
The operator processes the user’s information for their legitimate business interests but the user objects while the operator verifies the grounds for continued processing.
7.4. Right to data portability
The user has the right to receive personal information he provided in a ‘commonly used machine-readable format. This allows the user to obtain and reuse his information for his own purposes across different services. For example, if the user decides to switch to a different provider, this enables him to move, copy or transfer his information easily between the operator's 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.
7.5. Right to object
Based on the user’s particular situation, the user can object to the processing of his personal information, that is:
based on our legitimate business interests (including profiling);
done for research and statistical purposes.
The user also has the right to object to the use of his personal information for direct marketing purposes (including profiling).
7.6. Right to withdraw consent
When the operator relies on the user’s consent as the basis to process their personal information – such as for marketing communications (see section 3.4) – the user has the right to withdraw his consent at any time. The operator always strives to make it easy for the user to withdraw consent by choosing an “unsubscribe” option in every communication. If the user finds this isn’t the case, then he can get in touch with the operator who will try to fix things ASAP.
7.7. Rights related to automated decision making, including profiling
The operator uses systems to make automated decisions based on the user's personal information. This helps to make quick, fair, efficient, and correct decisions based on what the operator knows. These automated decisions can affect the products, services, or features offered, or the ability to use our services.
The automated decision-making is used in the following situations:
tailoring products and services – similar customers are placed in groups (segments) to study and learn about their preferences and needs, and offer them a more tailored experience;
detecting fraud -the operator uses the user's personal information to help decide and detect if the user account may be being used for fraud or money laundering. If there is a risk of fraud, the user account can be blocked or suspended;
opening a user account - when the user opens an account, Starcasino checks that the product or service is relevant for the user, based on what is known. The operator also checks that the user meets the conditions needed to open the account. This includes checking age, residency or nationality;
to offer complimentary promotional offers to the user when his recent gaming history can be classified as a bad gaming experience.
Data protection law seeks to safeguard individuals against harm that may arise from decision-making - including profiling - that takes place without human intervention. The user has the right not to be subject to a decision - including profiling - when it is based on the automated processing of his personal information and it has a legal effect or a similarly significant effect on him.
Please note that the right does not apply when the processing is:
necessary for entering into or for the performance of a contract with the user; or
when it is authorized by law; or
when it is based on the user's explicit consent.
8. Cookies
The operator has the right to use cookies to provide the appropriate customer service to its clients. The website uses cookies for the following purposes:
to identify the visitor’s preferred language;
to authenticate the user;
for analysis of website traffic.
Be aware that it is not possible to use the website without cookies. For additional information about the website's cookie usage, please read the cookie policy.