We are always committed to safeguarding your privacy in the best possible way and to maintaining a transparent process regarding the collection and use of your data.
Our privacy policy
As a Malta-based company, we are subject to European data protection regulations, including the European Union’s General Data Protection Regulation.
Our data protection officer
If you have any questions about the way Willwin.gg handles your personal information, if you would like to request access to your data or exercise any of your rights, please do not hesitate to contact our Data Protection Officer by sending an e-mail to contact@willwin.gg.
The data we collect
You can use the Willwin.gg website without having to provide us with any personal data. However, as explained below, certain information will be automatically collected from the device you are using. Of course, if you choose to contact us, we will retain your contact details and the details of your inquiry.
Information extracted from your device
We collect various types of data from the devices you use to access Willwin.gg. This information includes your IP address (a number that uniquely identifies a device on the Internet and is required for it to communicate with websites), hardware model, operating system and version, software, user agent, device data, preferred language, serial number, device motion control data, mobile network information and location data.
We also collect web server log files which may contain information such as access dates and times, features or pages you view, application or web site incidents, and other system activity. In addition, we record the website or third-party service you were using immediately before visiting our site and the URL you visit immediately after leaving our site. Note that our website may make use of Hotjar, a third-party tool that records clicks, mouse movements, page scrolling and any text you enter into site forms. This data helps us to improve our website, detect and correct errors, and optimize functionality. It is also used to generate statistical reports on the use and performance of our site.
Data collected through cookies
Cookies” are small text files stored in your web browser that enable us to recognize your computer when you visit our website. They are essential to ensure the proper functioning and security of certain parts of our website. In addition, we use them to improve the speed, ease of use and personalization of your experience, while helping us to understand how our websites are used. Cookies may also be used to present you with more relevant content or advertising.
Cookies collect some of your personal data when you browse our websites. You can accept or decline some or all types of cookies by adjusting your browser settings. If you continue to use our websites without changing these settings, we will use cookies in accordance with the information below. In order to make an informed decision, it is important to understand why we use different types of cookies and how this may affect your online experience. This section provides an overview of the key points and explains how disabling certain types of cookies may affect your experience on our websites.
Most of the cookies we use are “session cookies”, which are automatically deleted at the end of your browsing session. We also use “persistent cookies” which remain on your hard disk. They enable us to recognize you as a recurring visitor when you return to our website or application. These cookies do not contain any personal information that identifies you directly. Instead, they transmit an identifier to our server, enabling us to associate you with the cookie and personalize the home page to inform you of changes since your last visit.
The categories of cookies we use are as follows
- STRICTLY NECESSARY COOKIES: GUARANTEEING THE OPERATION OF OUR WEBSITES
These cookies are essential to enable you to navigate our websites and access secure sections. They also help us tailor content to your device. If you choose to refuse them, some parts of our site may not function properly or at all.
Examples of the use of strictly necessary cookies :
- Facilitating navigation on our site
- Optimize content display for your device
- Enable content delivery without repeated adjustment of volume and display settings
2. FUNCTIONALITY COOKIES: ACTIVATE WEBSITE FUNCTIONS
These cookies enable our websites to remember your choices, such as your region, and personalize your experience. They help us to offer different content to regular users and new visitors, to connect to social media such as Twitter, or to suggest links to relevant articles based on your consultation.
Without these cookies, you’ll still be able to use the site, but some features may be less accessible, and content may not be as personalized.
Examples of the use of functionality cookies :
- Memorizing survey participation
- Limiting the repeated display of a particular advertisement (also known as “capping”)
3. ANALYTICAL COOKIES: MONITORING THE PERFORMANCE OF OUR WEBSITES
These cookies collect information on the use of our websites, such as the number of visitors, the most popular pages, any error messages, etc.
Examples of the use of analytical cookies :
- Identifying browsing trends
- Help with content maintenance
- Measuring the effectiveness of content and communications
- Improving the operation of our websites
- These cookies do not affect access to the online functionalities of our websites.
4. WEB BEACONS (“WEB BEACONS”)
Our websites and some e-mails contain invisible images known as “web beacons” or “web beacons”. They are used to count the number of page or e-mail consultations, thus helping to evaluate the effectiveness of our marketing. Web beacons remain anonymous and do not collect any personally identifiable information.
5. TARGETING COOKIES: MARKETING AND ADVERTISING
These cookies are used to deliver ads and content tailored to your interests, as well as to control the frequency with which ads are displayed. They also measure the effectiveness of advertising campaigns and help to test and improve our products and services.
Without these cookies, you’ll still be able to use all the features of our websites, but the ads you see won’t be as personalized.
We hope this explanation will help you understand the importance of each category of cookies in your online experience on our websites.
How and why we use your personal data
We use the information we have about you in a variety of ways, which fall into these main categories:
1. PROVIDE THE PRODUCTS OR SERVICES YOU HAVE REQUESTED
We use your data to offer you the products or services you have requested, to respond to your requests and to provide you with quality customer service. To this end, we use technical information about your device, such as operating system, browser version and location, in order to offer you the appropriate version of our website and to ensure its proper functioning and security.
2. MEET OUR LEGAL OBLIGATIONS
We use your data to comply with our legal obligations.
3. MANAGING OUR BUSINESS EFFECTIVELY
We use the information to optimize the management of our company and improve our performance.
4. MARKETING CONSENT
If you have given us your consent, we will use your data for marketing purposes.
We share your information with third parties working in collaboration with us, enabling us to provide you with our products and services, as do most organizations.
Privacy rights: Can I refuse to have my data used in this way?
This first category covers everything that is essential to enable us to offer you the services you use or to which you subscribe. If you prefer not to have your data used in this way, you can choose not to use our website.
MEETING OUR OBLIGATIONS: LEGAL AND REGULATORY REQUIREMENTS
Willwin.gg is required to comply with a range of legal and regulatory requirements. Some of these requirements involve the use of personal information and may stipulate mandatory retention periods for such data.
In addition, we must comply with legal and regulatory requirements relating to other aspects of our business, such as complaints handling or advertising and marketing practices. Some of these regulations also involve the use of your personal information or the definition of retention periods.
PRIVACY RIGHTS: CAN I OBJECT TO THE USE OF MY PERSONAL INFORMATION IN THIS WAY?
This category relates to actions we are legally required to take to provide our products and services in a manner that complies with laws and regulations, while protecting our customers and our business. If you do not wish your data to be used in this way, you can choose not to use our website.
Efficient management of our company
We undertake certain essential actions to maintain the smooth running of our business organization. We have a legitimate interest in carrying out these activities, and where this involves using your personal data, we take care to do so in a way that minimizes any impact on your privacy.
Under European data protection law, you have the right to object to these activities if your right to privacy overrides our legitimate business interest in carrying them out. You always have the option of exercising this right, but it is important to note that the activities in this category are essential to our operation. In other words, if you choose to exercise this right, it generally means that you will have to stop using our website.
We encourage you to read this section carefully and to ensure that you agree before providing us with your personal data.
BUSINESS ANALYSIS
We carry out basic analyses to understand how, when, where and why our customers use our services, as well as to evaluate the performance of our business. This helps us to monitor and plan various aspects, from the effectiveness of our advertising campaigns to ensuring that we have sufficient staff to meet demand during peak hours. In addition, it gives us a clearer picture of our customers, including their demographics (e.g. age, gender, location, etc.) and the products and services they use. This information helps us to develop better features, products and services. All these analyses are carried out in such a way as not to identify our customers individually, which ensures that there is no impact on anyone’s privacy.
PRIVACY RIGHTS: CAN I OBJECT?
Like any company, we need to keep a close eye on how our business is performing and make sure we’re meeting our customers’ needs. However, we do this in a way that does not identify you as an individual, thus preserving your privacy. If you would prefer your data not to be used in this way, you have the option of not using our website.
Enhancing your personal experience
No matter what products or services you use, where you use them or how you interact with us, our goal is to provide you with a quality service while personalizing it for you. We tailor your experience by modifying the layout and content of our sites according to your information, preferences and preferred way of using our services. For example, we show you features you’ve already used or that we think you might enjoy, and we personalize search results to show you more relevant content.
We also look at aggregate data (which does not identify you personally) about the products and features our customers use. Based on this information, we suggest products and features that we think you might like, given that they are popular among other users who share similar interests to you.
RIGHT TO PRIVACY: CAN I OBJECT?
We believe this personalization enhances our website and your user experience. We want to provide you with the best possible customer experience, and using your personal data in this way contributes to this goal without compromising your privacy. If, however, you prefer not to have your data used in this way, you have the option of not using our website.
It is important to note that some aspects of your user experience depend on cookies. If you have enabled cookies in your browser, we personalize certain elements of our site, such as remembering your geographic location. You can control this via your browser settings.
Protecting our business interests
The majority of our users make fair use of our products and services. However, if we become aware of activity or behavior on an account that could harm our business interests, we will investigate.
RIGHT TO PRIVACY: CAN I OBJECT?
As a company, we have a legitimate interest in protecting our business interests from intentional misuse. We are confident that our actions are proportionate to the risks we face and have minimal impact on your privacy. If you would prefer your data not to be used in this way, you have the option of not using our website.
Market research
From time to time, we may ask for your feedback on services you have used or invite you to participate in surveys, questionnaires or discussion groups. We will contact you directly online or by e-mail. Your participation in these surveys is entirely voluntary. When we use a third party to carry out these surveys, we will not disclose any information about you, other than your contact details needed to send you the invitation, unless you have given your explicit consent.
RIGHT TO PRIVACY: CAN I OBJECT TO THIS PRACTICE?
It’s essential for any company to gather feedback from its customers. We take care to limit the number and frequency of solicitations for feedback or studies that we send to an individual. You always have the option of declining to participate in these solicitations, which will not adversely affect your privacy. You cannot refuse to receive these occasional requests, as they are designed to gather information essential to improving our services.
Use of your personal data with your consent: Marketing
Direct marketing
We will only send you offers and information if we have your explicit consent. In this case, we will communicate with you by e-mail, post, SMS or online. Your data will never be shared with third parties. From time to time, we may work with third parties to present you with information about a product or service that we think may be of interest to you. However, in such cases, the communication will come from us only, and we will never disclose your details to a third party without your prior consent.
Maintaining relevance
We aim to improve your betting and gaming experience by informing you about the products, services and features that excite you most. To do this, we tailor the offers and information we send you based on your profile. This means that we look at the information we have about you to personalize the offers we make.
Giving you control
We believe that our customers prefer to receive offers and information that match their interests rather than generic advertising. We therefore personalize all our marketing based on what we know about you. However, data protection legislation gives you the right to object to the use of your personal data to create this personalized profile and predict your interests. You can exercise this right at any time. It is important to note that our marketing approach is designed to provide an optimal online experience while giving you control over personalization. You can choose to unsubscribe from all marketing communications from Willwin.gg, but we will continue to personalize your online experience based on the information we have already collected about you. This means that you will continue to benefit from a more personalized online experience, including:
- Targeted pop-ups informing you about products, services and offers we think you’ll like.
- Offers tailored to your needs, presented as pop-ups or other content on our site.
- Targeted messages on social media such as Facebook or Twitter (which you can easily manage via your privacy settings on each platform), as well as on other websites that support targeted advertising.
We believe this represents the best balance: you can choose not to receive any more marketing via offline channels (mail, e-mail and SMS), while enjoying an enhanced online experience, without giving up any of its benefits. However, if you prefer not to receive personalized messages or offers online, you have the option of not using our website. Please also note the following:
We will continue to recommend products that you may enjoy, but these recommendations will be based on our customers’ general use of our sites and features, not on any personal information about you as an individual.
Some personalized banner ads on our sites are controlled via cookies, so you’ll need to adjust your browser’s cookie settings to disable them.
You may still see our ads on other websites and social media that you visit, but they will not be specifically targeted to you.
Advertising on social media
If you have given your consent to marketing, we may work with social media platforms such as Facebook and Twitter to inform you about our products and services. If you do not wish to see these ads, you can easily disable ad personalization in the privacy settings of each platform.
Even if you have withdrawn your consent to personalized marketing from us, you may occasionally see general advertisements for our products and services on social media. However, these ads are not specifically targeted at you, and you can also control this via the privacy settings on each platform.
Online behavioral advertising
We use cookies placed by third parties to collect personal information about your browsing, which is then aggregated with similar data from other users sharing similar characteristics (such as age, gender, location, etc.). Aggregated data is used to show you online advertisements based on your interests, whether for our own products and services or those of a third party, which is known as online behavioral advertising.
Sharing your information
Third-party casino and sports betting operators
We do not disclose your personal information to casino or sports betting operators. However, when you click on a link from our site to theirs, a cookie is stored, identifying Willwin.gg as the referring site. These third-party casino and sports betting operators then use the personal information you provide in accordance with their own privacy policies. Each casino and sports betting operator has its own privacy policy. It is therefore recommended that you consult their respective privacy policies and ensure that you are comfortable with the use of your personal data before creating an account.
Service providers
We share your personal information with third-party organizations that provide services on our behalf in accordance with this policy. The main functions delegated or shared with third parties are as follows:
- Management and execution of marketing campaigns
- Customer service
- Checking for potential abuse of our products and services
- Web hosting, online content services and data storage
- Contest and offer management
- Data analysis and data cleansing
- Market research and collection or analysis of customer feedback
- IT support
- Audit, legal and compliance services
We carry out checks to ensure that the companies we work with treat your information with the same level of care and protection as we do. These companies, like us, are required to comply with data protection legislation, and additional contractual measures are put in place to reinforce these obligations.
Transfer of personal information outside Europe
Some of the third-party companies with which we collaborate are based or partially operate outside the European Economic Area (EEA). The EEA comprises the EU member states and certain countries that guarantee a level of data protection equivalent to that of Europe.
Where personal information is transferred outside the EEA, we put in place additional legal safeguards, over and above our usual measures and controls, to ensure that your data receives the same level of protection as in Europe. To do this, we use standardized contractual clauses approved by the European Commission and European data protection regulators, although other approved legal mechanisms may be used instead. Where necessary, we also introduce additional contractual measures in accordance with the local legislation of the countries in which we operate, except where this conflicts with the EU General Data Protection Regulation.
Other circumstances in which your personal data may be shared
Apart from the functions listed above, we do not share your personal information with third parties unless we are legally required or authorized to do so. Such circumstances are rare, but may lead us to share information with police authorities, courts or other law enforcement agencies (for example, for tax matters), as well as with sports bodies (in the context of sports integrity), in the countries where we operate.
We will share personal data with our regulators, external legal advisors and debt collection and monitoring agencies where necessary to protect or defend our rights and interests, resolve disputes or enforce our agreements, although these circumstances are also rare.
If the ownership of our business, in whole or in part, undergoes change, reorganization or restructuring, we will transfer your personal information to the new owner or successor company in order to continue to provide the services you wish to receive.
Whenever we share personal information, whatever the circumstances, we always do so with respect for the law and your privacy.
Retention period of your information
We only keep your personal information for as long as is legally justified, which includes providing the services you have requested, complying with our legal and regulatory obligations, resolving disputes and fulfilling our contractual commitments.
The retention period for different types of personal data may vary depending on the reason for collection, the reason for processing and applicable legal requirements. When establishing our data retention and deletion periods, we take into account a number of factors and requirements, including gambling regulations, anti-money laundering provisions, tax rules, payment industry standards, claims processing, the need to prevent or detect breaches or abuse of our services, and audit obligations.
To meet our various obligations and requirements, some of your personal data may be retained for a period of time even after you have ceased to be a customer.
When we no longer need your personal information to meet the above requirements, we dispose of it securely. Where we wish to retain information for analysis purposes, we first anonymize it in accordance with the standards approved by the Dutch Data Protection Authority (Autoriteit Persoonsgegevens, AP), so that it can no longer be associated with an individual. It is important to note that if you decline to receive marketing from us, we will need to retain your details to prevent future marketing activity.
Exercising your privacy rights
We respect your right to control your personal information, and we want to clarify what these rights entail in practice, as well as how you can exercise them.
Right to refuse use for marketing purposes
You have the right to opt-out of direct marketing at any time. You may also object to the use of your information to create a marketing profile. We believe our customers prefer personalized offers and information, but if you wish to object to this personalization, you will need to unsubscribe from direct marketing.
Right to rectify your personal information
You have the right to update your personal data at any time. Keep your contact details up to date and report any inaccuracies to us. If you are unable to correct an error online, please contact us at contact@willwin.gg. We will rectify errors promptly, and if a complex modification is required, we will do so within one month. If we decline your request, we’ll explain why and record a note on your account to indicate your request. If you do not agree, you have the right to lodge a complaint with the privacy authority.
Right to object
The Data Protection Act gives you the right to object to the activities described in the section “Managing our business effectively and efficiently” if you believe that your privacy rights override our legitimate interest. Please read this section carefully before contacting us, and note that exercising this right generally means that you will have to stop using our services. If you do not agree with our decision, you have the right to complain to our privacy regulator.
Right to erasure (or “right to be forgotten”)
According to the Data Protection Act, you have the right to request the deletion of your personal data in the following situations:
- When the courts or regulatory authorities find that we are processing them illegally ;
- When the initial purpose for collecting the data has been achieved, and there is no other legal basis for storing it;
- When you withdraw your consent to personalized marketing and request the deletion of information previously used for this purpose. However, we will retain your details to prevent future marketing;
- When you successfully exercise your right to object to the activities in the “Managing our business effectively and efficiently” section and request the deletion of information used for this purpose. Note that this may mean ceasing to use our website, and we will need to retain your information for a period of time after your account has been closed due to legal or regulatory obligations.
To exercise these rights, please read carefully the sections “How long we keep your information” and “Your right to erasure” before contacting us. If you wish to exercise any of these rights, please contact us at contact@willwin.gg and we will respond to your request within one month. If we accept your request to delete data, we will also inform the third parties to whom the data has been transmitted, if possible. If we refuse your request, we will explain the reason for the refusal, and you will have the right to lodge a complaint with the privacy protection authority.
The right to access your personal data
If you would like a copy of the personal information Willwin.gg holds about you, please make your request here. We invite you to fill in a form which is not compulsory, but which facilitates the processing of your request by providing us with the necessary details. Prior to our response, we will ask you to present valid identification. Once we’ve received this, we’ll get back to you within a month. If your request is complex and may require more time, we will notify you promptly and inform you of the estimated processing time.
We will endeavour to respond to all requests as far as possible. However, there may be situations where local or European data protection legislation requires or permits us to withhold certain information (for example, when disclosing third party or commercially sensitive information) or allows us to apply a small fee. Where appropriate, we will explain the reason for such measures.
Your right to data portability
The right to “data portability” aims to enable consumers to re-use some of their personal information online by making it available in a commonly used, machine-readable format. This type of file can then be shared and used by other organizations. This is a relatively new initiative, and it is not yet possible to transfer data directly between companies in the betting and gaming industry. However, if you wish to exercise this right, please submit your request here, and we will provide you with the following information in CSV (Comma-Separated Values) format:
- The personal and contact information in your online account.
- Any other information you have provided online (please note that this does not include information submitted in paper format).
- Details you have provided online in the context of complaints or requests.
Before responding to your request, we will ask you to present valid identification. Once we have received this document, we will provide you with a reply within one month of receiving your request.
YOUR RIGHT TO LODGE A COMPLAINT WITH THE DATA PROTECTION REGULATORY AUTHORITY
If you believe that your privacy rights have been violated, or if you disagree with a decision we have made regarding your privacy rights, you have the right to file a complaint with the privacy regulator.
For residents of Canada, you can access the privacy regulator via the following link: https://www.priv.gc.ca/fr/
Links to third-party sites
Our websites contain links to third-party websites. These organizations and their websites have their own privacy policies, which may differ from ours. When you visit any of these sites, be sure to review their privacy policies to ensure you are comfortable with them before sharing any personal information with them.
Congratulations!
You’ve read through this comprehensive document. We’ve done our best to make it as simple as possible while complying with legal requirements. If you have any questions, please do not hesitate to contact us by e-mail at contact@willwin.gg.