Privacy Policy

This Policy describes what kind of Personal Data does the Company collect about natural persons, how does it collect it, use it, share it with third parties, secure it, process it etc.

In this Policy, and reference to “Personal Data” is to any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or in combination with additional information that We have or that We have access to.

In this policy, wherever We refer to the “processing” of Personal Data, We refer to any operation or set of operations which is performed on Personal Data, including the collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

The Company:

The Company is the data controller in respect of the Personal Data about you.

The data protection officer of the Company and the means to communicate with the data protection officer are:

Data Protection Officer, Progressplay Limited

E-mail: dataprotection@progressplay.com

We collect Personal Data about you whenever you use Our products and services, use the Website, Our service channels and/or contact Us. In some instances, you will actively provide Us with the Personal Data, and in other instances We will collect the Personal Data about you from examining and analyzing your use of Our products and services and/or Our service channels.

You are not obligated to provide Us with any Personal Data about you. However, in some instances, not providing such Personal Data will prevent Us from providing you with the products or services you request Us to provide you. Please see below a detailed description of such instances:

A legal obligation of the Company: there are certain legal obligations that require the Company to collect certain Personal Data as a precondition to providing products and services. In these instances, while you are not obligated to provide the Personal Data about you, if you will not provide the Company with such Personal Data, We will not be able to provide you with such products and services.

By way of example, We are required to collect your physical address and country of residence under our regulatory requirements as holders of online gambling licenses. While you are not obligated to provide Us with such information, if you will not provide it to Us, We will not be able to register you as a customer and provide you with Our products and services.

A contractual obligation of the Company: in some instances, the Company is contractually obligated to provide Personal Data about you. In these instances, while you are not obligated to provide the Personal Data about you, if you will not provide the Company with such Personal Data, We will not be able to provide you with the products and services to which the contractual obligation applies.

By way of example, if you do not provide Us with your credit card details, We will not be able to execute your withdrawal request via such credit card.

Providing Personal Data for the purpose of contracting with you: in some instances, providing Personal Data about you is a precondition to executing a contract between yourself and the Company. In these instances, while you are not obligated to provide the Personal Data about you, if you will not provide the Company with such Personal Data, We will not be able to contract with you and therefore will not be able to provide you with Our products and services

By way of example, in order to provide you with certain operational messages, relating to the products and services We provide, We will require to receive your email address.

Personal Data We collect upon registration: email address, first name, last name, gender, date of birth, physical address, city of residence, country of residence, zip code, phone number, mobile phone number, currency of account, language of account, publicly available data from the world wide web and social networks.

Personal Data We collect upon each logging in into your account: IP address, device info, operating system info, browser info, screen resolution, flash version, current and previous webpages browsed, date and time of login, location data.

Personal Data We collect during your use of Our products and services: your deposits, wagers, bonuses, game session (including date, time and duration), winnings and losses.

Personal Data We collect via Our support: passport / ID / driving license number and photo, utility bill.

Personal Data We collect upon receiving a deposit of funds and upon a withdrawal request: bank account details, e-wallet details, credit card details and photo, source of funds details, phone bill, bank statement.

Personal Data We receive from you: any Personal Data you provide to Us on your own free will when contacting Us, including via customer support, chat, social networks or in any other manner, including complaints, requests and comments. Our customer support representatives may record and/or document in writing your calls.

The Company processes your Personal Data for one or more of the purposes outlined in this section and according to the appropriate legal basis.

The Company shall not process Personal Data about you unless there is a legal basis for such processing. The legal bases according to which the Company may process Personal Data about you are as follows:

1. Your consent that the Company will process Personal Data about you for one or more specific purposes. By way of example, for the purpose of sending you marketing materials.

   Where the legal basis for the processing of the Personal Data about you is consent, you may at any time to withdraw your consent for the purposes for which you provided your consent by sending a notice free of charge to the following email address customersupport@instantgamesupport.com, or by changing your settings in your account.

   Where you withdraw your consent for the processing of Personal Data about you, We might not be able to provide you with some or all of the products and services you requested or in the form intended to be provided to you, and you will have no claim in respect of that.

2. Processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract. By way of example, for registering you as an account holder, or for allowing you to withdraw funds from your account.
3. Processing is necessary for compliance with a legal obligation to which the Company is subject. By way of example, on account of Our licensing obligations as holders of online gambling licenses.
4. Processing is necessary for the purposes of the legitimate interests pursued by the Company or by a third party. By way of example, for the purpose of improving our products and services, or for the exercise or defense of legal claims.

Whenever the processing of Personal Data about you is necessary for the purpose of the legitimate interests pursued by the Company or by a third party, the processing is conditional upon such interests not overridden by your interests or fundamental rights and freedoms which require protection of Personal Data about you. At any time, you may approach Us by sending a notice to the following email address customersupport@instantgamesupport.com in order to receive information concerning the review performed by Us in order to reach the conclusion that We may process the Personal Data about you on account of such processing being necessary for the purposes of the legitimate interests pursued by the Company or by a third party.

The following list outlines the purposes for which We may process Personal Data about you and the legal basis for any such processing:

	Purpose	Legal Basis
1	In order to register you as a customer Upon your request to register with the Company and open an account, We will process your Personal Data in order to allow Us to perform such requests.	Processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract. Processing is necessary for compliance with a legal obligation to which the Company is subject.
2	In order to allow Us to provide you with Our products and services Whenever you request to use Our products and services, specifically to make use of a bonus, place a wager, deposit and withdraw funds from your account, We will process the Personal Information required for Us to perform such requests.	Processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract. Processing is necessary for compliance with a legal obligation to which the Company is subject.
3	In order to contact you for the purpose of operational requirements In some circumstances, We will contact you in order to update you in respect of certain operational matter; for instance, where We will be required to cease to provide Our products and services in certain jurisdictions, or where a certain aspect of Our products and services is changing. In these circumstances, We will need to use Personal Data about you accordingly.	Processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract. Processing is necessary for compliance with a legal obligation to which the Company is subject.
4	In order to respond to your queries, requests and/or complaints, and to provide you with customer support services Processing of Personal Data about you is required in order to respond to queries you have concerning products and services of the Company used by you, and in general to provide you with customer support services. In other circumstances, We will need to process Personal Data about you in order to fulfill any self-exclusion (or similar) requests made by you.	Processing is necessary for the purpose of the legitimate interests pursued by the Company or by a third party. Processing is necessary for compliance with a legal obligation to which the Company is subject.
5	In order to collect money in connection with products and services purchased by you	Processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract.
6	In order to provide you with tailor made marketing materials and offers In order to enhance and improve your user experience and the use of Our products and services, and in order to offer you with additional and new offers, products and services, We process Personal Data about you in order to adjust the materials presented to you according to your preferences, behavior, characteristics and interests. For this purpose, We use Personal Data automated analysis techniques, including profiling.	Processing is necessary for the purpose of the legitimate interests pursued by the Company or by a third party.
7	In order to comply with any legal obligations or judicial or administrative orders We process Personal Data about you in order to comply with Our various legal obligations, which include, inter alia, preventing customers from certain jurisdictions to use Our products and services due to a legal prohibition or to prevent minors from using Our products and services.	Processing is necessary for compliance with a legal obligation to which the Company is subject.
8	In order to improve the products and services We offer, as well as to offer new ones We may use Personal Data about you in order to improve the products and services We offer, as well for the purpose of offering new ones; such processing will include, inter alia, an analysis of previous uses by you of Our products and services, any comments and complaints received in respect of Our products and services, as well as any errors and malfunctions.	Processing is necessary for the purpose of the legitimate interests pursued by the Company or by a third party.
9	In order to prevent fraud, abusive use of Our products and services and to prevent money laundering	Processing is necessary for the purpose of the legitimate interests pursued by the Company or by a third party. Processing is necessary for compliance with a legal obligation to which the Company is subject.
10	In order to send you marketing materials Inasmuch as you agree to receive marketing materials from Us, We will send you, via the means of communication you consented to, marketing materials relating to Our products and services, whether in existence now or in the future, whether similar to Our current products and services and whether different ones, and/or products and services of third parties. It is hereby clarified that you may withdraw your consent at any time, by sending an email free of charge with the title “unsubscribe” to the following email address: customersupport@instantgamesupport.com or by clicking the unsubscribe option in any marketing material sent to you. Please note that you will be requested to choose from which means of communication (one, some or all) do you wish to unsubscribe. It is hereby clarified that unsubscribing will not cause the deletion of your contact details, but to cease receiving marketing materials – unless you re-request to receive them, subject to any legal obligation of Ours.	Your consent
11	In order to analyze the effectiveness of any marketing and advertising campaigns and activities of the Company	Processing is necessary for the purpose of the legitimate interests pursued by the Company or by a third party.
12	In order to perform and maintain various activities supporting the offering and provision of Our products and services Such activities include back office functions, business development activities, strategic decision making, oversight mechanisms etc.	Processing is necessary for the purpose of the legitimate interests pursued by the Company or by a third party.
13	In order to perform analysis, including statistical analysis We use various analytical measures (including statistical ones) in order to make decisions in various issues, including improving existing products and services and introducing and developing new ones.	Processing is necessary for the purpose of the legitimate interests pursued by the Company or by a third party.
14	In order to protect Our and third parties’ interests, rights and assets, including initiation or exercise or defense of legal claims We may process Personal Data about you in order to protect the interests, rights and Assets of Ours and of third parties, according to any law, regulation and agreement, including any of Our terms and conditions and policies.	Processing is necessary for the purpose of the legitimate interests pursued by the Company or by a third party.

Where the processing of Personal Data about you is necessary for the purpose of the legitimate interests pursued by the Company or by a third party, you have the right to object to such processing for this purpose by sending a notice to the following email address customersupport@instantgamesupport.com, unless We demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.

The Company provides its customers with offers that are tailored for them specifically, in order to enhance and improve your user experience and the use of Our products and services, and in order to offer you with additional and new offers, products and services, including products and services of third parties. This is done following the processing of Personal Data about you, in order to adjust the materials presented to you, on the basis of their preferences, behavior, characteristics and interests. For this purpose, We use Personal Data automated analysis techniques that provide Us with analysis and conclusions concerning you in various aspects, including profiling.

By way of example, such analysis and conclusions may be used by Us in order to offer you products and services which We think may be of more interest to you; for instance, on the basis of your playing patterns, your address and age, the time and day of the week in which you prefer to use Our products and services etc.

Similar analysis and conclusions are used to the extent that you agreed to receive marketing materials from Us, as such materials are tailored to offer you products and services which We think may be of more interest to you.

Where Personal Data about you is processed for direct marketing purposes, you shall have the right to object at any time to such processing for this purpose, including profiling to the extent that it is related to such direct marketing, by sending a notice to the following email address customersupport@instantgamesupport.com, in which case We shall cease to process Personal Data about you for such direct marketing purposes.

In addition, you may withdraw your consent from receiving marketing materials at any time, by sending an email free of charge with the title “unsubscribe” to the following email address: customersupport@instantgamesupport.com

The Company shares Personal Data with companies within the group of companies of which the Company is a part, for the purpose of supporting the activities of the Company and the offering of the Company’s products and services.

The Company may also share Personal Data about you with third parties that provide Us with the following services:

1. KYC and AML services, aimed to ensure that We comply with all of Our legal, regulatory and licensing obligations and requirements.
2. Payment services, such as payment service providers, payment processors and banks.
3. Services in connection with responsible gambling matters; e.g., where We wish to ensure that the scope of wagering of a person is compatible with his wealth.
4. Storage and hosting providers, including cloud computing services.
5. Fraud prevention and chargeback investigation.
6. IP address information.
7. Analysis of user experience.
8. Support.
9. Marketing (including our white label partners and their contractors).
10. Dispatch of materials, including marketing materials, via various means of communications, such as emails, SMS, regular (snail) mail, push notifications and other electronic messages.
11. CRM data management.
12. Call enters.
13. Game providers.
14. Digital signing.
15. Accounting and legal services.
16. Research, analytical, technical and diagnostic services.

The Company may share Personal Data about you with governmental, local, official, regulatory, licensing and gambling authorities, as well as where such disclosure is required to protect Our and third parties’ interests, rights and assets, including initiation or exercise or defense of legal claims.

In addition, We may disclose Personal Data about you to potential purchasers or investors of, or lenders to, the Company and/or any company within the group of companies of which the Company is a part, or in the event of any similar transaction (including the sale of assets of the Company and/or of any company within the group of companies of which the Company is a part), and/or in connection with any merger, reorganization, consolidation or bankruptcy of the Company and/or any company within the group of companies of which the Company is a part.

You are entitled to the following rights in respect of the Personal Data about you. The exercise of such rights will be via sending an email requesting to exercise your right to the following email address: customersupport@instantgamesupport.com

Right of access

You have the right to receive from the Company confirmation as to whether or not Personal Data about you is being processed, and, where that is the case, access to the Personal Data and the following information: (1) the purposes of the processing; (2) the categories of Personal Data concerned; (3) the recipients or categories of recipient to whom the Personal Data have been or will be disclosed, in particular recipients in third countries outside the European Economic Area (EEA) or international organisations; (4) where possible, the envisaged period for which the Personal Data will be stored, or, if not possible, the criteria used to determine that period; (5) the existence of the right to request from the Company rectification or erasure of Personal Data or restriction of processing of Personal Data about you or to object to such processing; (6) the right to lodge a complaint with a supervisory authority; (7) where the Personal Data is not collected from you, any available information as to its source; (8) the existence of profiling; and (9) where personal data is transferred to a third country outside the EEA or to an international organisation, the appropriate safeguards relating to the transfer.

The Company shall provide a copy of the Personal Data undergoing processing and may charge a reasonable fee for any further copies requested by you where you make the request by electronic means, and unless otherwise requested by you, the information shall be provided in a commonly used electronic form.

The right to obtain a copy of the Personal Data shall not adversely affect the rights and freedoms of others, and therefore if the request will harm the rights and freedoms of others, the Company may not fulfill your request or do so in a limited manner.

Right to rectification

You have the right to obtain from the Company the rectification of inaccurate Personal Data about you. Taking into account the purposes of the processing, you have the right to have incomplete Personal Data completed, including by means of providing a supplementary statement.

Right to erasure

You have the right to obtain from the Company the erasure of Personal Data about you where one of the following grounds applies: (a) the Personal Data is no longer necessary in relation to the purpose for which it was collected or otherwise processed; (b) you withdraw your consent on which the processing is based and there is no other legal ground for the processing; (c) you object at any time, on grounds relating to your particular situation, to processing of Personal Data about you which is based on the legitimate interests pursued by Us or by a third party, and there are no overriding legitimate grounds for the processing; (d) you object to the processing of Personal Data about you for direct marketing purposes; (e) the Personal Data has been unlawfully processed; (f) the Personal Data about you has to be erased for compliance with a legal obligation in European Union or Member State law to which the Company is subject.

This right is not applicable to the extent that the processing is necessary: (a) for compliance with a legal obligation which requires processing by European Union or Member State law to which the Company is subject; or (b) for the establishment, exercise or defense of legal claims.

Right of restriction of processing

You have the right to obtain from the Company restriction of processing of Personal Data about you where one of the following applies: (a) the accuracy of the Personal Data is contested by you, for a period enabling the Company to verify the accuracy of the Personal Data about you; (b) the processing is unlawful and you oppose the erasure of the Personal Data about you and request the restriction of its use instead; (c) the Company no longer needs the Personal Data about you for the purposes of the processing, but it is required by you for the establishment, exercise or defense of legal claims; (d) where the processing of Personal Data about you is necessary for the purpose of the legitimate interests pursued by the Company or by a third party, unless We demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims; (e) where Personal Data about you is processed for direct marketing purposes, including profiling the extent that it is related to such direct marketing.

Where processing of Personal Data about you has been restricted following your request, such Personal Data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or of a Member State.

Right to data portability

You have the right to receive the Personal Data about you, which you have provided to the Company, in a structured, commonly used and machine-readable format and have the right to transmit such Personal Data to another controller, where: (a) the processing is based on your consent or on a contract to which you are a party; and (b) the processing is carried out by automated means.

In exercising your right to data portability, you have the right to have the Personal Data about you transmitted directly from the Company to another controller, where technically feasible. The exercise of your right to data portability is without prejudice to your and the Company’s rights under your right to erasure. In addition, the right to data portability shall not adversely affect the rights and freedoms of others.

Right to object

You have the right to object, on grounds relating to your particular situation, at any time to processing of Personal Data about you which is based on the legitimate interests pursued by the Company or by a third party, including profiling based on such legitimate interests. We shall no longer process the Personal Data about you unless We demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.

You have the right to object at any time to the processing of Personal Data about you for direct marketing purposes, which includes profiling to the extent that it is related to such direct marketing.

Right to withdraw consent

You may withdraw your consent provided to Us for the purpose of processing Personal Data about you at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

Right to lodge a complaint with a supervisory authority

You have the right to lodge a complaint with a supervisory authority which is established by a Member State in order to protect the fundamental rights and freedoms of natural persons in relation to processing of personal data within the European Union.

Your rights in respect of Personal Data about you as outlined in this section 11 may be restricted by European Union or Member State law to which the Company is subject to.

We shall provide you with the information requested according to your rights outlined in this section 11 without undue delay and in any event within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. We shall inform you of any such extension within one month of receipt of the request, together with the reasons for the delay.

The information requested according to your rights outlined in this section 11 shall be provided free of charge, unless stated otherwise in this section 11. Where requests are manifestly unfounded or excessive, in particular because of their repetitive character, We may either: (a) charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested; or (b) refuse to act on the request.

The Company may require you to provide additional information necessary to confirm your identity in order to fulfill your request according to your rights outlined in this section 11, where We have reasonable doubts concerning the identity of the natural person making the request.

General

When you visit or access the Website and/or use Our products and services, a cookie file (which is a small text file) is installed on the device via which you visit or access the Website and/or use Our products and services. The cookies allow Us to collect information about you and your behavior, in order to improve your user experience, to remember your preferences and settings, to customize and offer you with products and services that may interest you. Cookies are also used collect statistics about your usage of Our products and services and perform analytics.

Some of the cookies We use are session cookies, which are downloaded temporarily to your device and last until you close your web browser, while others are persistent cookies which last on your device after you cease browsing the Website and are used to help the Website remember you as a returning visitor when you return to the Website.

Types of cookies

The cookies We use have classified according to their functionality, as follows:

Type of cookie	Purpose	Additional Information
Strictly Necessary Cookies	These cookies are strictly necessary to enable you to navigate the Website and use features you have requested. They are used to provide you with Our content, products and services that you have requested. Such cookies are essential to help your device download or stream information so that you can navigate around the Website, use its features and allow you to return to pages you have previously visited.	These cookies collect Personal Data about you, such as user name, last login date and identify you as being logged in to the Website. These cookies are deleted when you close your web browser (session cookies)
Functionality Cookies	These cookies are used to recognize you when you return to the Website and allow Us to remember your choices and preferences (such as language) in order to allow Us to provide you with improved and customized features.	These cookies collect Personal Data about you, such as your language preference, the games you play and marketing preferences. These cookies survive the closing of your web browser, and last until their applicable expiry time.
Performance Cookies	These cookies are used to provide aggregated statistics in respect of the performance of the Website and to test and improve such performance, in order to provide better user experience; in addition, they allow Us to carry out analytical functions on the Website.	These cookies collect anonymised data which is not relating to an identified or identifiable natural person. These cookies are valid for varying periods; some are deleted once you close your browser, while others have an indefinite validity period.
Third Party Marketing / Targeting Cookies	These cookies are used to deliver ads and marketing communications, and to make the Website displayed, in a manner which is more relevant you, based on your interests and actions; they are also used to measure the effectiveness of an advertising campaign. These cookies record your visit to the Website, the pages you have visited and the products and services you used.	Some of these cookies are provided and used by third parties. These cookies are valid for varying periods; some are deleted once you close your browser, while others have an indefinite validity period.

Blocking and removal of cookies

You can change your browser settings in order to block and delete some or all cookies. Please see below links to instructions as to how to do this in respect of some of the most popular web browsers:

• Firefox ကို
• Internet Explorer
• Google Chrome
• Safari

Please note, however, that if you do so, some or all of the Website’s features and functionalities might not perform as intended.

The Company shall retain Personal Data about you for as long as is required to fulfill the purposes of the processing of the Personal Data as outlined in this Policy, or for a longer period as required according to the legislation, regulation, policies and orders that apply to Us.

In general, We will hold Personal Data about you for a minimum period of five years after the termination of your account with Us.

In order to ensure that Personal Data about you is not retained for longer than is required, We periodically review Personal Data retained by Us in order to examine whether any Personal Data can be erased.

Personal Data about you may be transferred to a third country (i.e., jurisdictions outside the EU Member States, Iceland, Norway and Liechtenstein) or to international organisations. In such circumstances, the Company shall take appropriate safeguards aimed to ensure the protection of Personal Data about you and provide that enforceable data subject rights and effective legal remedies for data subjects are available.

These safeguards and protection will be available if any of the following are met:

1. The transfer is to a third country or an international organization which the EU Commission decided that they provide an adequate level of protection to the Personal Data that is transferred to them pursuant to Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (" GDPR");
2. The transfer is according to legally binding and enforceable instrument between public authorities or bodies pursuant to Article 46(2)(a) of the GDPR; or
3. The transfer is in accordance with standard data protection clauses adopted by the EU Commission pursuant to Article 46(2)(c) of the GDPR; the clauses adopted by the EU Commission can be viewed at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en

You may request the Company to be provided with details concerning the safeguards employed by it to protect the Personal Data about you which is transferred to a third country or an international organization, by sending an email to the following address:

We implement appropriate technical and organisational measures to ensure an appropriate level of security to Personal Data taking into account the risks that are presented by processing, in particular from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to Personal Data transmitted, stored or otherwise processed.

We may be required, due to legal or other obligations outside Our control, to transfer Personal Data about you to third parties, such as public authorities. In such circumstances, We have limited control over the level of protection provided to the Personal Data about you by such third parties.

Any transfer of Personal Data via the internet cannot be fully secured. Therefore, the Company cannot ensure the protection of Personal Data about you when transferred via the internet to the Website operated by the Company.

The Website may provide links to websites and/or applications of third parties. The Company does not control such websites and applications, nor the collection and/or processing of Personal Data about you by such websites and applications, and We are not responsible for such websites and applications, nor to their privacy and data protection policies and activities. This Policy does not apply to any actions taken via such websites and/or applications.

Wherever you access such third parties' websites and/or applications, We recommend that you carefully review their privacy policies prior to using such websites and/or applications and prior to disclosing any Personal Data by you.

We may amend, from time to time, the terms of this Policy. Whenever We amend this Policy, We will notify such amendments by publishing the updated Policy on the Website. In addition, when We make significant amendments of this Policy, We will strive to inform you about such amendments via means of communication which We believe are reasonably appropriate to inform you of such amendments and by publishing a notice about such amendments on the Website. Unless stated otherwise, all amendments will enter into force upon publishing the updated Policy on the Website.