Privacy Policy

Version No. 1.0Last Updated on 22nd May 2018

1. Introduction

In line with our Terms and Conditions, a player must register an account with Cyberplay Management Limited in order to be able to avail him/herself of the services provided. During this registration process, the player shall be requested to provide certain personal data. Throughout the lifetime of the relationship between the player and Cyberplay Management Limited, the player shall be requested to provide additional personal data and Cyberplay Management Limited shall infer further personal data about the player.

This Privacy Policy aims to provide the player, being the data subject, with information about his/her personal data and the manner in which it is held and processed by Cyberplay Management Limited.

2. About Cyberplay Management Limited

Cyberplay Management Limited is a company incorporated in Malta, bearing registration number C70489 and having its registered address at 9, Level 2, Britannia House, Old Bakery Street, Valletta, Malta. Should you wish to reach out to us you may send as an email on support@loki.com. For any privacy or data protection queries, the company’s Data Protection Officer can be reached via email on dataprotection@cpm.com.mt.

3. What data do we process about you and why?

The table below outlines the personal data that Cyberplay Management Limited holds about a player (Personal Data); the source from which said data has originated (Source); the purpose for which said data is collected and processed (Purpose of Processing); the basis upon which Cyberplay Management Limited is permitted to process said data for the established purpose (Lawful Basis for Processing). Where legitimate interests are quoted as the lawful basis for processing, an explanation of same is also provided (Legitimate Interests).

Personal Data Source Purpose of Processing Lawful Basis for Processing Legitimate Interest Essential to Provision of Service
Registration Details (name, surname, date of birth, place of birth, residential address, telephone number, email address, IP address, gender) Derived from Data Subject dentification of player; verification of identity and address; prevention and detection of fraud; prevention of money laundering and terrorist funding; ensuring responsible gambling; offering customer support services; effecting payment of withdrawals; providing remote gaming services. Performance of contract, legal obligations, legitimate interest Prevention of fraud Yes
Contact details (email address, telephone number) Derived from Data Subject Engaging in correspondence with player; notifying player of news, updates and information about the services, campaigns and/or bonuses; providing marketing material. Performance of contract & consent - Yes
Identification Documentation (identity card / passport / driving license / utility bill / bank statement / other documentation Derived from Data Subject Identification of player; verification of identity and address; prevention and detection of fraud; prevention of money laundering and terrorist funding; ensuring responsible gambling. Legal obligation - Yes
Player behavior (transactional behavior, geo-location, device information) Inferred from Data Subject Prevention of money laundering and funding of terrorism; prevention of fraud; ensuring responsible gambling; improvement of quality of service; customer recommendations. Legal obligation; legitimate interest; consent Prevention of fraud Partially

4. Who do we share your data with?

Throughout the course of its relationship with the player and thereafter, Cyberplay Management Limited may be required to transfer personal data of the player to third parties. The below table provides information on said transfers, namely: the personal data of the player that is being transferred (Personal Data); the type of third party which shall receive the personal data (Recipient); the purpose for which the third party shall process the data (Purpose of Processing); and the location where the data shall be processed by the third party (Location). In each of these scenarios Cyberplay Management Limited undertakes to bind said recipients to process and use the personal data in line with the provisions of the General Data Protection Regulation and the provisions of Cyberplay Management Limited’s Privacy Policy.

Personal Data Recipient Purpose of Processing Location
Registration Details; Identification Documentation; Financial Transactions; Gaming Transactions; General information about the Player’s account held with Cyberplay Management Limited Regulatory Authorities Compliance matters related to Cyberplay Management Limited’s remote gaming licenses EU
Registration Details; Identification Documentation; Financial Transactions; Gaming Transactions; General information about the Player’s account held with Cyberplay Management Limited Financial Intelligence Authorities Prevention of money laundering and funding of terrorism; general compliance matters related to Cyberplay Management Limited’s business activities insofar as these render Cyberplay Management Limited to be considered an obliged entity under Directive 2015/849 of the European Parliament and of the Council, as this may be amended from time to time EU
Registration Details; Identification Documentation; Financial Transactions; Gaming Transactions; General information about the Player’s account held with Cyberplay Management Limited Enforcement Agencies Investigation of fraud, identity theft and other related and/or similar offences by local and international Police and other enforcement agencies. EU
Registration Details; Identification Documentation; Financial Transactions; Gaming Transactions. Gaming Platform Provider Hosting and storage of data on behalf of Cyberplay Management Limited. EU
Registration Details; Identification Documentation; Financial Transactions; Gaming Transactions. Data Platform Provider Hosting and storage of data on behalf of Cyberplay Management Limited. EU
Registration Details; Identification Documentation. Third Party Tool Providers Provision of customer support tool to Cyberplay Management Limited EU

5. How long do we store your data for?

In line with the principles of data protection, Cyberplay Management Limited undertakes to retain personal data of Players only for as long as is necessary. Therefore, upon completing a process, Cyberplay Management Limited shall delete the data required for that specific process, save in the following cases:

  1. Where the same data is required for other data processes for which a lawful basis for processing exists; and/or
  2. Where the data is required to be retained by the company in line with legal obligations to which it is subject, including but not limited to, legislation and/or regulations relating to remote gaming, responsible gaming, anti-money laundering and counter-terrorist funding, taxation, company and corporate matters. In light of this certain personal data may be retained and used by Cyberplay Management Limited even after the closure of the Player’s Account.

6. What are your rights?

  1. Rights of access and data portability – The Player may obtain a copy of the personal data held by Cyberplay Management Limited about him/her at any time by accessing the My Account section after logging in. In the event that further information should be required, a Subject Access Request may be made via email to the company’s Data Protection Officer. Furthermore, the Player may request that certain categories of his/her data are transferred to third parties by Cyberplay Management Limited.

  2. Right of rectification - In the event that the data held about a Player by Cyberplay Management Limited is inaccurate, incomplete or outdated, you may rectify said data by accessing the My Account section after logging in. Certain verification requirements may apply for the completion of a rectification request.

  3. Right of erasure – The Player may at any time request that Cyberplay Management Limited erases data held about him/her by sending an email to the Data Protection Officer. Cyberplay Management Limited shall ensure that such personal data is, upon request and when not required for purposes outlined in the Data Retention section above, deleted. Players are however advised that with the deletion of their personal data, the quality of their user-experience on the Website may be diminished.

  4. Right to restriction of processing, objection to processing and withdrawal of consent – The Player may at any time request that Cyberplay Management Limited restricts or ceases to conduct certain data processes and Cyberplay Management Limited shall accede to that request, provided that there exist no other lawful basis on which Cyberplay Management Limited is authorized to process said data. Likewise, with respect to any data processes which are conducted by Cyberplay Management Limited on the basis of consent given by the Player, the Player may at any time withdraw said consent by sending an email tothe Data Protection Officer. Provided that the withdrawal of consent shall not affect the lawfulness of any data processing that would have taken place prior to said withdrawal.

  5. Right to lodge a complaint – In the event that the Player is not satisfied with the manner in which Cyberplay Management Limited has handled a request or generally with the manner in which Cyberplay Management Limited handles data protection related issues, the Player has the right to file a complaint to the relevant supervisory authority. Complaints may be filed with the Office of the Information and Data Protection Commissioner in Malta via www.idpc.org.mt.

7. Other Information

Cyberplay Management Limited performs certain automated decisions based on Player behavior for the improvement of the services provided, for instance by providing recommendations of games and other services.