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Privacy Policy

By participating in our site, you are accepting the following policies:

The Company (as specified in the terms and conditions) offers gaming services (hereinafter, the "Services") through its own brands (each of them a "Own brand") and trademarks of third parties, known as "Generic brands". From here on we will refer to the owner of the generic brand and its corporate partners as "Generic Brand".

The members of the Group (as described below) and the generic Brand (if applicable) (jointly "us" or "our"), are aware that users ("you" or "user") importance to the way we have to collect, use and protect your information, and we value your trust. For this reason, a very important part of our relationship, the user, is to protect their information and to be transparent in everything we do.

We have created this Privacy Policy to inform you about how we manage, collect and use your information while using our Services. In this Privacy Policy you will learn more about the following aspects:

• The group
• The type of information we collect
• How we use the information we collect and for what purpose
• Cookies and pixels
• Data exchange
• Retention and choice of users
• How we keep your information safe
• Advertising
• Marketing
• Access, update and correction of your information
• How to contact us

We recommend that you carefully read our Privacy Policy to be well informed when making decisions.

About the Group

The group of companies that form TOWER (hereinafter, the "Group") has its head office in Curacao and the Company (where applicable) is part of that Group. The Group offers its Services through the following applications and platforms (together with the "Platforms"):

• Internet websites;
• Downloadable applications and software ("Software"), such as native applications distributed through mobile application stores and downloadable desktop software for PC and Mac;
• Non-downloadable online applications (eg flash applications, HTML5, etc.);
• Facebook applications; Y
• Generic brands.

Information collected

We can collect the following information about you:

• Personal information

What is "Personal Information"?

Personal information is individually identifiable information, that is, information that identifies an individual or that identifies an individual with relative ease. We collect the information, either independently or through the help of third-party service providers, as detailed below.

o Types of personal information that we collect directly from you or about you

Registration details: When you open an account and register to use the Services, you must provide a series of personal details, such as the following: first and last name, email address, full name and sex, birth data, physical address , identification number, telephone number, etc.

Payment information: So that you can enjoy all the functions of our Services (eg placing bets, making purchases, participating in tournaments, etc.), we may ask you to provide your payment information, such as your payment number. credit card or your bank account details.

Voluntary information: We also collect information that you provide to us on a voluntary basis. For example, when you reply to our communications, you communicate with us through email or share additional information about yourself by using our Services, such as the chat function and games.

Device information: We may collect information and specific connection details related to your device, software or hardware that may identify you, such as the following: unique identifiers of the device (such as, for example, unique user identifier, MAC address), fingerprint of the device browser, IP address and geolocation data.

Social networks: When you register through a social network account (such as your Facebook account) to use the Services, or connect your player account with that account, we obtain access to your basic information provided on the network social, such as name, date of birth, profile photo and friend list, as well as basic information that you have publicly shared in that account. Also, when using the Services you can "Invite a friend" through the social network to use the Services. In the event that that person accepts your invitation, we can access your personal information, which may include: name, email, phone number and date of birth. We will use the Personal Information for the purpose stated in this document and we will only share this information with third parties following the instructions in this Privacy Policy.

Information we collect from third parties: We may collect personal information that you have provided to third-party service providers, such as p. ex. information from credit agencies about your credit history and other financial information relevant to the provision of the Services, as well as information collected to verify your identity and prevent fraudulent or illegal activities.

Non-personal information

What is "Non-personal information"?

Non-personal information is non-identifiable information that, when taken in isolation, does not allow you to identify yourself or contact you. As such, we do not know the identity of the user from whom the non-personal information is collected. We use this information for different purposes, such as p. ex. advertising, improvement of Services, fraud prevention and analysis of the web. We may collect such information, either independently or through the help of our third-party service providers and the generic Brand (where applicable).

o Types of non-personal information that we collect directly from you or about you:

  • Technical information: To improve the functionality of the Services and to offer you a better user experience, we collect technical information transmitted by your device, which includes specific information about the software or hardware (eg the type of browser and operating system used your device, language preference, access time and domain name of the website from which you have accessed the Services, etc.).
  • Game information: We collect your game information, which includes, among other data, your deposits, bets, bonuses, duration of the game session and higher scores. We may also share and publish such information through any of our Platforms.
  • Device and connection information: If you download the Software on your device, we may collect information from the particular device you are using, for security reasons and to detect and prevent fraud. For example, we may collect information related to another software that is running concurrently with the Software to check if you are using software associated with fraudulent activities (eg robots, malware, etc.) or to check if you are using a connection by via VPN or proxy.
  • Analysis information: We collect information about your use of the Services, which includes the use of applications, log files, user activity (eg visited pages, visit time on specific pages, online searches, clicks, actions, etc.), time stamps, alerts, etc. This information is collected, among other things, to solve problems and errors, as well as to conduct research and analysis on your use of the Services.
  • Anonymous information: We may anonymously or disidentify the information collected by the Services or through other sources, in such a way that it is not possible to use the isolated information to identify the user personally. The use and disclosure of that additional disidentified information is not subject to any restriction in accordance with this Privacy Policy and we may share it with third parties without limit and for any purpose, such as p. ex. for advertising or marketing purposes.

Combination of data: In the event that we combine personal information with non-personal or anonymous information, we will treat such combined information as personal information as long as it is held together.

Cookies and pixels

We and our partners (third-party service providers, advertising and marketing partners, etc.) may use cookies and pixels, including cases in which you visit our website or access our Services.

• Cookies

A "cookie" is a small piece of information that a website assigns to your device while you are browsing the site. Cookies are very useful and can be used for different purposes.These purposes include: allowing you to navigate between pages of the website efficiently, automatically activate some specific functions, remember your preferences and make the interaction between you and the Services faster and easier. Cookies are also used to ensure that the ads you see are relevant to you and your interests, as well as to collect statistical data about your use of the Services.

Cookies can not damage your device since they are not executable and can not be used to install malware. They are more like a personal file with your basic information, which is checked and updated each time you visit a website.

We may use the following types of cookies:

  • "Session cookies", which are stored temporarily during a browsing session to allow normal use of the system and are deleted from your device once the browser is closed;
  • "Permanent cookies", which are stored on your computer for a specific time and are not deleted when you close the browser. We use these cookies when we need to know your identity for future visits, store your preferences for the next login and to improve the user experience in relation to the Services and the website, as well as to show different announcements and marketing messages to the users. existing users;Y
  • "Third party cookies", which are introduced by other websites or services and which execute content and advertisements on the page you are visiting, such as p. ex. by third party analysis companies or advertisers that control and analyze your access to the web.
  • "Flash cookies", which are saved during game sessions to provide a better and faster gaming experience.

• Pixels

We also do pixel-based tracking to see visits or events on the Platform and the impressions of the ads. This information is also used for remarketing purposes and to track the conversions used to optimize our marketing activities. We may share such information (which is non-personal information) with our advertising and marketing partners. See below the specific information related to our advertising and marketing practices.

By accessing our Services and making use of them, you show your consent to the use of cookies and pixels on your device in accordance with this Privacy Policy.

You can delete cookies by following the instructions of your device preferences; However, if you decide to disable cookies, it is possible that some features of the Service may not work properly and that your online experience may be limited. Additionally and for legitimate security reasons, we may deny you access to specific contents of our website if you do not accept the installation of a cookie or similar device.

How we use the information we collect

We use and share personal information as described in this Privacy Policy. In addition to the purposes mentioned above, the information we collect, which may include your Personal Information, is used for the following purposes:

• To create and update your account;
• To offer you the Services through any of the Platforms;
• To communicate with you and keep you informed about our latest updates and special offers;
• To market our websites, products and services. (see below "Marketing");
• To show you ads;
• To perform analyzes that improve and customize the Services according to your needs and interests;
• For the support and resolution of problems of our Services and to answer your questions;
• To offer you a responsible gaming environment;
• To send you notifications about updates to our software or Services;
• To process any of your information requests;
• To identify and authenticate your access to certain functions of the Services;
• To detect and prevent fraudulent and illegal activities or any other type of activity that could endanger or negatively affect the integrity of the Services;
• To investigate breaches of our policies and the User Agreement, as well as to enforce our policies and the User Agreement;
• To investigate and resolve disputes related to your use of our Services; Y
• as required by law, regulatory authorities or other governmental authority, to obey a subpoena or similar legal process or respond to a government request.

Exchange of data

We do not rent, sell or share your personal information with third parties, except as set forth in this Privacy Policy. We will share your personal information with a third party only to the extent necessary for a particular purpose, as stipulated in this Privacy Policy, and in that case we will require you to agree to process such information in accordance with this Privacy Policy.

We may share your personal information with any of the following recipients:

• The generic Brand;
• Any service provider that the generic Brand contracts as a substitute to control the website or any application of the "generic brand" (if applicable)
• Companies within the Group and other affiliated companies;
• Subcontractors and third-party service providers, as well as their subcontractors, which may include, for example, payment processors and data verifiers, among others;
• Any third party that provides services related to the operation or promotion of the own Brand that corresponds or with the website and application of the "generic brand" (if applicable)
• Any third party that organizes tournaments or events offline on behalf of any of the companies of the Group or jointly with any of them;
• Auditors, contractors or advisors of any of the processes of the Group's businesses;
• Any third party that investigates, detects or prevents illegal or fraudulent activities (eg government authorities, police, banks and other research organizations); Y
• potential buyers or investors of any of the companies of the Group or of the generic Brand (if applicable) or the "generic brand" (if applicable).
In addition to the purposes listed in this Privacy Policy, we may share personal information with these recipients for any of the following purposes:
• Store this information on our behalf through the use of IT service providers, for example;
• Process this information to assist us in our business operations (eg to process payments and deposits, authenticate your access, audit our operations, detect and prevent illegal or fraudulent activities, etc.);
• Conduct research, analysis or technical diagnostics and
• Communicate promotional and informational materials in accordance with our marketing policy (see below "Marketing").

We may also share your information with third parties whenever we believe, in good faith, that the disclosure of such information is necessary to protect our rights or legal claims, protect your safety or the safety of others, and to investigate or prevent any fraud. , for security reasons or to help us in any other related technical problem.

We may also share with third parties non-personal information or information that we have made anonymous with advertising purposes (see below specific information related to our advertising and marketing practices, in "Advertising").

Collection of third-party information

Please note that this Privacy Policy does not apply to third-party websites, services or applications, even if they are accessible, downloadable or even distributed through the Services. We recommend that, before providing your personal information to third parties, always and carefully review their privacy conditions.

You assume in a conscious and voluntary way all the risks of using websites, services or applications of third parties. You agree that we do not have any responsibility in relation to these third party sites and the use you make of them.

Retention and choice of users

At any time you can request the modification and update of your personal information by sending an email to [email protected] You can also request that we correct errors related to your personal information (except in those cases where it is necessary for the information to be kept in its original format according to any regulation and law that may apply).

We will keep your information for as long as the purposes described in this Privacy Policy require (see above, in "How we use the information collected").

In addition, we may rectify, fill in or delete incomplete or inaccurate information at any time and at our sole discretion.

Data security

We are very concerned when implementing and maintaining security in the Services and in your information. We have established adequate physical and technological security measures to prevent unauthorized access, maintain data security and correctly use the online information we collect. These measures vary according to the level of confidentiality of the information we collect and store.

We use industry-standard controls and processes to ensure the security of our users' information, such as:

• Secure network topology, which includes intrusion prevention and firewall systems;
• Encrypted communication;
• Access control and authentication;
• External and internal audit tests, etc.

Although we take reasonable measures to safeguard your information, we can not be held responsible for the acts of those who obtain unauthorized access or abuse of the Services, and we do not guarantee explicitly, implicitly or in any other way that we will prevent such access.

Data transfer

Since we operate globally, we may need to transfer your personal information to other jurisdictions. The data protection laws and other laws of these countries may not be as exhaustive as those of Curacao; In this case we will take the necessary measures to ensure that your information enjoys a similar level of protection. You hereby consent to the transfer of your personal information to countries that are in other jurisdictions.

If you feel that your privacy has not been treated in accordance with our policy or that someone has attempted to abuse the Services or act inappropriately, please contact us directly via email [email protected]

Advertising

We use third-party advertising technology to send notices to users who visit the Platforms and use the Services. This technology uses non-personal information in relation to your use of the Services to offer you advertising (eg through third-party cookies in your web browser). We may also use our third parties and share non-personal information with them to help us evaluate the success of our advertising campaigns and contribute to the "retargeting" process of our users.

You can voluntarily leave many of the third party ad networks, including those operated by members of the Network Advertising Initiative ("NAI") and the Digital Advertising Alliance ("DAA"). For more information about the practices of NAI and DAA members and about options related to the information that these associations use (including how to voluntarily leave third-party networks operated by members of the NAI and the DAA) ), visit their respective websites (in English): http://www.networkadvertising.org/optout_nonppii.asp and http://www.aboutads.info/choices.

Marketing

Both the Group and the generic Brand may use your personal information, such as your name, postal address, email address, telephone number, etc., directly or through third party subcontractors, in order to provide you with promotional material about the Services. , as well as products, services, websites and applications related to: (i) other companies of the Group; (ii) the generic Brand; or (iii) the business partners and affiliates of the Group (collectively, the "Marketing Affiliates"), which we believe may be of interest to you.

We may also share and disclose personal information to our Marketing Affiliates in order to offer you different marketing offers that we or our Marketing Affiliates consider relevant to you. Our marketing Affiliates will be able to use this personal information for different marketing techniques, such as direct email, postal mail, SMS and telephone advertising.

At any time you can indicate that you do not want to continue receiving our marketing offers or those of our business and marketing partners by contacting us through [email protected] Please note that we can continue to send you updates and notifications related to our services although You have unsubscribed from our marketing mailing list.

By downloading, installing or accessing our Accepted Services, you are aware that we may share your personal information with our business and marketing partners for advertising purposes.

Corporate transaction

We may share information, including your personal information, in the event of a corporate transaction (eg the sale of a significant part of our business, merger, reorganization, bankruptcy, consolidation or sale of assets or transfer) in relation to with any company in the Group or in relation to the generic Brand (if applicable) or "generic brand".

If any of the named events occurs, the acquiring company or one that receives the transfer will assume the rights and obligations described in this Privacy Policy.

Minors

Our Services are not designed for minors under 18 years of age or below the minimum age to give legal consent in the use of our Services according to their jurisdiction (whichever is greater is considered "Majority of Age"). If you do not have the Majority of age, you should not download or use our Services or provide us with your personal information.

We reserve the right to access and collect any personal information collected. In the event that we notice that a user who has not reached the age of majority has shared any type of information, we will discard this information. If you have reason to believe that a minor has shared your information, please contact us through [email protected]

Updates or changes to the Privacy Policy

We may revise this Privacy Policy periodically, including without limitation as a result of regulatory and legal changes, security reasons and changes to our Services, and the most current version will always be posted on this website. We encourage you to consult the Privacy Policy regularly to keep up to date with possible changes.

By continuing to use our Services after notification of such changes on the website, you are stating that you know and accept those changes in the Privacy Policy and that you agree to its terms.

How to get in touch with us

If you have any general questions about the Services or the information we collect and how we use it, please contact us through [email protected]

Last update on January 3, 2018