Version 1.0, dated 21 May 2019
When visiting noaccountcasino.com ("Website"), Paf Multibrand Ltd, company registration number C 75805 with its registered address at The Bastions Office No. 2, Triq Emvin Cremona, Floriana FRN 1281, Malta ("Paf Multibrand", "we", "us", "our") may collect and process personal data ("Personal Data") about you ("user", "customer", "you", "your").
This privacy notice ("Privacy Notice") sets out which Personal Data Paf Multibrand collects from the users of the Website, and for which purposes the Personal Data is processed.
Throughout this Privacy Notice, the term "processing" is used to cover all activities involving your Personal Data, including collecting, handling, storing, sharing, accessing, using, transferring and disposing of information.
"Applicable Data Protection Laws" includes, in particular, the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (the "GDPR").
WHAT PERSONAL DATA DO WE COLLECT
Personal Data refers to information which can directly or indirectly identify an individual. It also includes special categories of data, which is considered as more sensitive information. Personal Data which Paf Multibrand collects and processes includes the following categories:
Registration and identification data include details provided by you in order to register and/or open an account on our Website. These include first name, last name, residential address, username or similar identifier, date of birth, gender, country, occupation, employment status, personal identification (PID) number (for Swedish customers), and information contained in other identification documents such as passports, identity cards and driving licenses.
Contact data includes residential address, email address and telephone number.
Financial data include payment method account details, financial status information, salary details, source of funds and source of wealth, and other information contained in bank statements, source of income/payslips and similar documentation.
Transaction/payments data includes deposit and withdrawal amounts, as well as the currency, location, username or similar identifier, wagering and games played.
Technical/log-in data includes internet protocol (IP) address, log in information, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Website.
Usage and analytics data include information on how you use our Website, products and services; such as the username or similar identifier, language, location, browser data, device used, payment provider, games played, duration of play, and promotions claimed.
Marketing and Communications data includes information with regards to your preferences in receiving marketing material from us; as well as other various information which is provided by you in your communication to us.
Special categories of data include information about any political or government positions held, criminal convictions and offences, and details of any problem gambling behaviour for responsible gaming matters.
FROM WHERE DO WE COLLECT PERSONAL DATA
INFORMATION COLLECTED FROM YOU
We collect Personal Data directly from you when you register an account on our Website, when you interact with us, and when you use our services. This includes information about your visit to our Website, as detailed in Clause 2 above, and information you voluntarily shared with us or made public.
INFORMATION COLLECTED FROM THIRD PARTIES
Paf Multibrand works with different third-party data processors when providing its services to customers. These include, for example, business partners, due diligence and KYC service providers, and payment service providers.
For Swedish players, we collect Personal Data during the registration process via the bank identification process. When you are registering with the personal identification number (PID), and are successfully verified, certain Personal Data will be automatically populated in your customer profile. This refers to the first name, last name, registered address and email address.
We use the Personal Data collected about you in accordance with applicable laws and only for specified purposes. When using personal data to serve our or a third party's legitimate interest, we will always balance your rights and interests in the protection of your personal data against our rights and interests or those of the third party.
PERSONALIZE AND ANALYSE OUR INTERACTIONS WITH YOU
When you visit our Website, we will collect and process your Personal Data in order to better understand you as a user and to personalize our interactions with you, for example, to show you products and services we think you may like, to manage our risk, and in order to carry out customer profiling segmentation and analysis. We will also collect and process your Personal Data in order to identify usage trends, and for the purpose of statistical analysis.
The legal basis for the above processing of your Personal Data is that the processing is necessary in order to fulfil our legitimate interest to better understand you as a user, and to personalise our interactions with you to show you relevant products and services, as per article 6.1 (f) of the GDPR.
PROVIDE YOU WITH INFORMATION SUCH AS NEWSLETTERS AND PRESS RELEASES
If you have opted in to receive or subscribed to our newsletters, press releases and similar information about Paf Multibrand and its business and services, or order such information on a one-time basis, we process your Personal Data for the purposes of providing you with the requested subscription or information, in accordance with the article 6.1 (a) of the GDPR (you have given consent to the processing of your personal data for one or more specific purposes).
ANSWER YOUR QUESTIONS AND HANDLE FEEDBACK IN GENERAL
Our Website provides functionality for the user to communicate with us, to ask questions and give feedback regarding our services and business. Where you use such functionality, Paf Multibrand will process your Personal Data for the purpose of answering your questions and handling your feedback sent to us.
The legal basis for the above processing of your Personal Data is that the processing is necessary in order to fulfil our legitimate interest to answer questions and handle feedback from you, as per article 6.1 (f) of the GDPR.
MANAGE COMPLAINTS RELATING TO OUR SERVICES AND PRODUCTS
Our Website allows you to send us your complaints relating to our services and products. Where you provide us with a complaint, Paf Multibrand will processes your Personal Data for the purpose of investigating, managing and replying to your complaint.
The legal basis for the above processing of your Personal Data is that the processing is necessary in order tocomply with a legal obligation to investigate, manage, and reply to your complaint, as per article 6.1 © of the GDPR, as well as for the performance of contract with you in accordance with the Website's Terms & Conditions, as per article 6.1 (b) of the GDPR.
REGISTRATION OF PERSONAL USER ACCOUNTS AND PROVIDING GAMING SERVICES
Our Website allows users to register a personal user account, accessible via unique log-in credentials. If you create a user account, Paf Multibrand will process your personal data for the purpose of creating and managing your personal user account, and providing you with access to your account, including the provision of games, and the processing of deposits and withdrawals.
The legal basis for the above processing of your Personal Data is that the processing is necessary for the performance of contract with you in accordance with the Website's Terms & Conditions, as per article 6.1 (b) of the GDPR.
COMPLY WITH LEGAL OBLIGATIONS
Paf Multibrand processes Personal Data in order to comply with its legal obligations, such as your eligibility to be our customer, crime prevention, identity and source of wealth verification, responsible gaming and compliance with the tax and anti-money laundering laws.
The legal basis for the above processing of your Personal Data is that the processing is necessary in order to comply with our legal obligations, as per article 6.1 © of the GDPR.
ESTABLISH, EXERCISE AND DEFEND LEGAL CLAIMS
Paf Multibrand may process your Personal Data for the purpose of ensuring compliance with our Terms and Conditions; and establishing, exercising and defending legal claims in the unlikely event of a dispute.
The legal basis for the above processing of your personal data is that the processing is necessary in order to fulfil our legitimate interest to establish, exercise and defend legal claims, as per article 6.1 (f) of the GDPR.
FOR HOW LONG DO WE KEEP YOUR PERSONAL DATA (DATA RETENTION)
DISCLOSURE AND TRANSFER OF PERSONAL DATA
Paf Multibrand may share Personal Data with the companies within the Paf Multibrand group.
We may also disclose Personal Data to external parties, such as vendors and service providers processing Personal Data under the instructions of Paf Multibrand. If we transfer your Personal Data out of the EEA, we ensure that a similar degree of protection is afforded to it by contractual arrangements or by transferring Personal Data only to countries that provide an adequate level of protection for personal data as determined by the European Commission. Please contact us if you want further information regarding the transfer of your personal data outside the EEA.
RIGHT TO RECTIFICATION
Paf Multibrand takes steps in accordance with Applicable Data Protection Laws to keep your Personal Data accurate, complete and up-to-date. If you identify that any Personal Data related to you is inadequate, incomplete or incorrect, you are entitled to have the Personal Data corrected. We reserve the right to verify the accuracy of the new data you provide to us.
RIGHT OF ACCESS
You may request us to confirm whether or not we are processing your Personal Data. You can access most Personal Data we hold about you by logging in to your account. Any additional information regarding the processing of your Personal Data can be requested by contacting us on email@example.com.
RIGHT TO OBJECT
You have the right to object to the processing of your personal data for direct marketing purposes. If you have opted in to receive email newsletters from us, each email will include an easily accessible opt-out function where you may unsubscribe from further direct marketing communications.
You also have the right to object to personalized marketing. This is done on our site for data use.
RIGHT OF ERASURE
You have the right to request Paf Multibrand to delete your Personal Data under certain circumstances, such as when your Personal Data is no longer required for the purposes for which it was originally collected. There may be legal obligations, such as Anti-Money Laundering laws, which may prohibit us from deleting all or any information held about you immediately at the time of the request. However, we will process your request whenever any applicable data retention period expires and if we are not legally obliged to retain such data.
RIGHT TO RESTRICT PROCESSING
You may ask us to restrict the processing of your Personal Data to only comprise the storage of your Personal Data under certain circumstances and as such, we will not use your Personal Data further. You have such right when the processing is unlawful, but you do not want your Personal Data erased; when we no longer require your Personal Data, but you request it to defend a legal claim; and when you want us to establish the accuracy of your Personal Data.
RIGHT TO WITHDRAW CONSENT
You have the right to withdraw your consent to the processing of your Personal Data at any time to the extent that the processing is based on your consent. As also stated in section 7.3, you can easily withdraw your consent from direct marketing received from us by using the unsubscribe option which is found in every communication.
You can retract your approval for personalized marketing at any time. This is done on our site for data use.
RIGHT TO DATA PORTABILITY
You have the right to request to receive a machine-readable copy of your Personal Data which was processed on the basis of your consent or on the basis that the processing is necessary in order to perform an agreement with you. Our Terms and Conditions, which you have accepted at registration, set out the terms of the contract and the services we will provide. You will receive your Personal Data in a structured and commonly used format. This right refers to Personal Data which has been provided to Paf Multibrand by you (data portability) and allows you to ask for the information to be transferred to another data controller (where possible).
COMPLAINTS TO THE SUPERVISORY AUTHORITY
You always have the right to lodge complaints pertaining to the processing of your Personal Data by Paf Multibrand to the competent data protection authority, if so, provided under Applicable Data Protection Laws. Our main data protection authority is the Office of the Information and Data Protection Commissioner (IDPC).
We have implemented appropriate technical, physical and organisational measures to protect your Personal Data against unauthorised or accidental destruction; alteration or disclosure; misuse; damage; theft or accidental loss; or unauthorised access. This is complemented by internal policies and ensuring that our employees are properly trained on Data Protection and Information Security.
COOKIES – WHY DO WE COLLECT AND PROCESS YOUR PERSONAL DATA
If you have any questions or concerns regarding the processing of your Personal Data or wish to exercise any of your rights, please contact Paf Multibrand using the contact details set forth below.
You can contact our Data Protection Officer ("DPO") by emailing firstname.lastname@example.org.
The data controller for Personal Data is Paf Multibrand Ltd, company registered under the laws of Malta with registration number C 75805, and registered address in The Bastions Office No. 2, Triq Emvin Cremona, Floriana FRN 1281, Malta.
Version 1.0, dated 21 May 2019
B. WHAT IS A COOKIE?
Cookies are small text files containing minor amounts of information which are sent and stored on your device (desktop, smartphone or another device used to access our Website). These cookies are useful in order to allow us to distinguish you from other users by recognising your device. Further information about cookies can be found at www.allaboutcookies.org.
- Allow you to log into No Account Casino account;
- Allow you to choose your log in preferences;
- Collect and monitor information about the transactions you carry out on our Website;
- Prevent fraud; and
- Safeguard your privacy.
These cookies store information which allow us to remember your preferences, such as the preferred language; and to improve your experience, such as preventing the same message from showing twice.
These analytical cookies allow us to recognise our users, count the number of users, and to see how such users navigate around our Website. This helps us in improving the way in which our Website functions, in order for it to be user friendly and offer relevant information uniquely to the user. Such cookies allow us to also monitor the effectiveness of our adverts and information we display.
From time to time, we might use carefully selected third party tracking and/or analytical cookies in order to assist us in improving our Website and the services we offer you. Where third party links are provided on our Website, it is important to take note that such websites have their own privacy and cookie policies which will manage any information you may submit to them. These policies should be read before you decide to make use of any linked third part websites.
- Session Management
These are essential cookies which enable the proper use of our Website. Such cookies manage session information and enable users to navigate through our Website.
- Fraud Prevention
These cookies store information which helps us to stop and prevent fraudulent use of our Website.
- Tracking and Marketing
These cookies enable us to store information on how the users found and landed on our Website. As a result, we can appropriately remunerate our Affiliates. We use such information in order to measure the effectiveness of our marketing and to improve the relevance of advertising to you. Without these cookies, you will still be able to make use of our Website and its features; however, the displayed advertising will not be tailored according to your preferences. You can adjust the settings for these cookies on our site for data use.
Cookie declaration by Cookiebot:
Category: Necessary (1)
Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.
|JSESSIONID||noaccountcasino.com||Preserves users states across page requests.||HTTP||Session|
Category: Statistics (4)
Statistic cookies help website owners to understand how visitors interact with websites by collecting and reporting information anonymously.
|_ga||noaccountcasino.com||Registers a unique ID that is used to generate statistical data on how the visitor uses the website.||HTTP||2 years|
|_gat||noaccountcasino.com||Used by Google Analytics to throttle request rate||HTTP||1 day|
|_gid||noaccountcasino.com||Registers a unique ID that is used to generate statistical data on how the visitor uses the website.||HTTP||1 day|
|collect||Google-analytics.com||Used to send data to Google Analytics about the visitor's device and behaviour. Tracks the visitor across devices and marketing channels.||Pixel||Session|
Category: Marketing (49)
Marketing cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third party advertisers. You can adjust the settings for these cookies on our site for data use.
|_fbp||noaccountcasino.com||Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers.||HTTP||3 months|
|AA003||atdmt.com||Collects information on visitor behaviour on multiple websites. This information is used on the website, in order to optimise the relevance of advertisement.||HTTP||3 months|
|ads/ga-audiences||Google.com||Used by Google AdWords to re-engage visitors that are likely to convert to customers based on the visitor's online behaviour across websites.||Pixel||Session|
|AdServer/Pug||pubmatic.com||Sets a timestamp for when the visitor entered the website. This is used for analytical purposes on the website.||Pixel||Session|
|ATN||atdmt.com||Targets ads based on behavioural profiling and geographical location.||HTTP||2 years|
|audience||spotxchange.com||Used to determine whether the video-ads have been displayed correctly on the website. This is done to make video-ads more effective and ensure that the visitor is not shown the same ads more times than intended. The cookie also detects whether the visitor has any Do Not Track preferences.||HTTP||13 days|
|C||bidswitch.net||Regulates synchronisation of user identification and exchange of user data between various ad services.||HTTP||1 year|
|C||adform.net||Used to check if the user's browser supports cookies.||HTTP||30 days|
|cid||adform.net||Optimises ad display based on the user's movement combined and various advertiser bids for displaying user ads.||HTTP||2 months|
|CMID||casalemedia.com||Collects visitor data related to the user's visits to the website, such as the number of visits, average time spent on the website and what pages have been loaded, with the purpose of displaying targeted ads.||HTTP||1 year|
|CMPRO||casalemedia.com||Collects data on visitors behaviour from multiple websites, in order to present more relevant advertisement. This also allows the website to limit the number of times that the visitor is shown the same advertisement.||HTTP||3 months|
|CMPS||casalemedia.com||Collects visitor data related to the user's visits to the website, such as the number of visits, average time spent on the website and what pages have been loaded, with the purpose of displaying targeted ads.||HTTP||3 months|
|CMRUM3||casalemedia.com||Collects visitor data related to the user's visits to the website, such as the number of visits, average time spent on the website and what pages have been loaded, with the purpose of displaying targeted ads.||HTTP||1 year|
|fr||facebook.com||Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers.||HTTP||3 months|
|guid||de17a.com||Used to generate statistical data on what pages the user has visited and how often an ad click leads either to a purchase or other actions on the advertiser's website.||HTTP||539 days|
|i||openx.net||Registers anonymised user data, such as IP address, geographical location, visited websites, and what ads the user has clicked, with the purpose of optimising ad display based on the user's movement on websites that use the same ad network.||HTTP||1 year|
|IDE||doubleclick.net||Used by Google DoubleClick to register and report the website user's actions after viewing or clicking one of the advertiser's ads with the purpose of measuring||HTTP||1 year|
|KRTBCOOKIE_#||pubmatic.com||Registers a unique ID that identifies a user's device during return visits across websites that use the same ad network. The ID is used to allow targeted ads.||HTTP||29 days|
|psyn||smartclip.net||Used in content with video-advertisement. The cookie limits the number of times a visitor is shown the same advertisement-content. The cookie is also used to ensure relevance of the video-advertisement to the specific visitor.||HTTP||29 days|
|PUBMDCID||pubmatic.com||Registers a unique ID that identifies a user's device during return visits across websites that use the same ad network. The ID is used to allow targeted ads.||HTTP||3 months|
|PugT||pubmatic.com||Used to determine the number of times the cookies have been updated in the visitor's browser. Used to optimise the website's server efficiency.||HTTP||29 days|
|rum||casalemedia.com||Collects data related to the user's visits to the website, such as the number of visits, average time spent on the website and what pages have been loaded, with the purpose of displaying targeted ads.||Pixel||Session|
|serving/cookie/match||adform.net||Used to determine if the visitor should be presented to pop-up advertisement content on the website. This also allows the website to detect if an adblocker is present in the visitor's browser.||Pixel||Session|
|sync||smartclip.net||Collects data on visitors' behaviour and interaction. This is used to optimise the website and make advertisement on the website more relevant.||Pixel||Session|
|tap.php||rubiconproject.com||Registers data on visitor such as IP addresses, geographical location and advertisement interaction. This information is used to optimise the advertisement on the websites that make use of Rubicon Project-services.||Pixel||Session|
|test_cookie||doubleclick.net||Used to check if the user's browser supports cookies.||HTTP||1 day|
|tr||facebook.com||Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers.||Pixel||Session|
|tuuid||360yield.com||Collects unidentifiable data, which is sent to an unidentifiable receiver. The receiver's identity is kept secret by Perfect Privacy LLC.||HTTP||3 months|
|tuuid_lu||360yield.com||Collects a unique visitor ID, which allows Bidswitch.com to track the visitor across multiple websites. This allows Bidswitch to optimise advertisement relevance and ensure that the visitor does not see the same ads multiple times.||HTTP||3 months|
|Tuuid_||bidswitch.net||Collects a unique visitor ID, which allows Bidswitch.com to track the visitor across multiple websites. This allows Bidswitch to optimise advertisement relevance and ensure that the visitor does not see the same ads multiple times.||HTTP||1 year|
|uid||adform.net||Registers a unique ID that recognises the user's browser when visiting websites that use the same ad network. The purpose is to optimise display of ads based on the user's movements and various ad providers' bids for displaying user ads.||HTTP||2 months|
|ul_cb/match||360yield.com||Used to track visitors on multiple websites, in order to present relevant advertisement based on the visitor's preferences.||Pixel||Session|
|ul_cb/sync||bidswitch.net||Collects information on visitor behaviour on multiple websites. This information is used on the website, in order to optimise the relevance of advertisement.||Pixel||Session|
|umeh||360yield.com||Used to track visitors on multiple websites, in order to present relevant advertisement based on the visitor's preferences.||HTTP||3 months|
|UserMatch.ashx||atemda.com||Collects data about the user's visit to the website, such as which pages are read. The recorded data is used to target ads.||Pixel||Session|
|uuid||smartclip.net||This cookie is used to optimise ad relevance by collecting visitor data from multiple websites – this exchange of visitor data is normally provided by a third-party data-center or ad-exchange.||HTTP||29 days|
|Uuid2||adnxs.com||Registers a unique ID that identifies a returning user's device. The ID is used for targeted ads.||HTTP||3 months|
|w/1.0/sd||openx.net||Registers data on visitors such as IP addresses, geographical and advertisement interaction. This information is used to optimise the advertisement on websites that make use of OpenX.net services.||Pixel||Session|
Category: Unclassified (2)
Unclassified cookies are cookies that we are in the process of classifying, together with the providers of individual cookies.
D. MANAGING COOKIES
You can manage or delete any cookies which are already stored on your device or stop the cookies that keep track of your browsing patterns on our Website, you can do so by visiting your browser's privacy settings and delete and/or any existing cookies you may wish.
Please note if you delete our current cookies or disable our future cookies means that you may not be able to access certain areas or features of our Website. For instance, if you disable 'Session' cookies from your browser, you will not be able to log into your No Account Casino account.
E. TURNING OFF COOKIES VIA YOUR WEB BROWSER
For more information on how to disable cookies and/or alter your privacy settings, please visit www.allaboutcookies.org. Alternatively, you can also visit your browser’s ‘Help’ function for browser specific help.
You can find general information about cookies on most web browsers which also enables you to see what cookies are stored on your device, allows you to delete them (all or specifically), and allows you to block or allow cookies for all or specific websites. Usually, you will also have the option to turn off third party cookies separately. It is important to note that the settings offered by a browser or device often only apply to that particular browser or device where settings were set and/or altered.
Below are some links to some commonly used web browsers by users:
- Chrome: https://support.google.com/chrome/answer/95647?hl=en&p=cpn_cookies
- Firefox: https://support.mozilla.org/en-US/kb/clear-cookies-and-site-data-firefox
- Microsoft Edge: https://support.microsoft.com/en-us/help/4468242/microsoft-edge-browsing-data-and-privacy-microsoft-privacy
- Safari for Mac: https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac
- Opera: https://help.opera.com/en/latest/
Moreover, Google Analytics provides its own opt-out options: