Privacy Policy

INTRODUCTION

Hacksaw Gaming is committed to respecting the privacy of everyone who uses our website www.hacksawgaming.com including its subpages (“Website”). If you wish to contact us about our privacy practices please feel free to do so by post or by email at [email protected].

Hacksaw Group shall include Hacksaw Gaming Ltd. and all its Subsidiary Companies that are part of the same group.

In this document we call the Hacksaw group of companies “Hacksaw Group”, or “us”/“we” and we call you (a visitor/user of our site) “you”.

This document explains how we collect, process and store personal data belonging to you. “Personal Data” means information about you which can be used, on its own or together with other information, to identify you as a person.

ROLES

References to “data controller”, “data subject”, “personal data”, “process”, “processed”, “processing” and in this Privacy Notice have the meanings set out in, and will be interpreted in accordance with applicable laws, including but not limited to the Data Protection Regulation (EU) 2016/679 and the Data Protection Act, Chapter 586 of the Laws of Malta and subsidiary legislation thereto, as may be amended from time to time.

Data controller: means the entity which alone or jointly with others determines the purposes and means of the processing of personal data. The Controller can ask another company to process the Personal Data on its behalf and as instructed by the Controller. That company then becomes a “Processor”.

Processing: means any operation or set of operations performed upon personal data or sets of personal data, whether or not by automated means, such as 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. A cloud service provider is generally considered a data processor processing data on behalf of the company (client) which determines the purposes and means of the processing of its customers’ personal data.

This Privacy Policy applies in the context of us being Data Controllers. The Operator is Controller for Personal Data collected through the Operator and in the games when you play them via an Operator (for example data you provide when you register as a player, transaction data). In those cases, the Operator’s privacy policy applies.

WHAT AND WHY

Personal data can only be processed if, and to the extent that, at least one legal basis for the processing listed below applies:

a) the data subject has consented to the processing;
b) it is necessary for the entry into, or performance of, a contract with the data subject or in order to take steps at your request prior to the entry into a contract;
c) it is necessary for compliance with a legal obligation under EU law or national law;
d) it is necessary in order to protect the vital interests of the data subject or of another natural person;
e) it is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and, or
f) it is necessary for the purposes of legitimate interests pursued by the data controller (or by a third party), except where the controller's interests are overridden by the interests, fundamental rights or freedoms of the affected data subjects. Legitimate interest includes anti-fraud measures, risk assessments, network security, personalisation and web-analytics, and customer support logs.

Specific areas include:

1. Information you provide when you fill in forms on our Website (example: job application forms, attendance confirmations, subscription to news emails etc.) for the purpose of managing our relationship with you, stored for five years.
2. Records of correspondence that we have with you necessary for the purposes of the legitimate interests pursued by us and emails will consequently be stored as long as we can claim lawfulness of such correspondence, unless such interests could be deemed overridden by your interests or fundamental rights and freedoms.
3. If you work for an Operator you may have access to our client area where we will save your work email, name, job telephone number and job title, the group company with which the operator has a contract, we generally hold this data for the duration of our contract with the Operator you work for.

As a result of legal obligations imposed on us, we typically retain personal data for up to ten (10) years from the closure of the file, unless we have a statutory obligation imposed on us to retain your data for a further period or a business need or require your personal data to exercise or defend legal claims.

In addition to the purposes listed above, we may always use your Personal Data as required by law and regulation (example: to maintain and protect the gaming licenses of the Hacksaw Group), in line with AML regulations.

RETENTION

We may retain your Personal Data after we have stopped providing services to you if it is necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes and/or prevent fraud or abuse. We may also keep anonymized derivatives of your data for business analytics purposes where no automated decision making is involved.

SHARING AND TRANSFER

We may share and/or your personal data with third party recipients who are:

• selected individuals within our Group, on a need-to-know basis;
• any service providers that may have access to your personal data in rendering us with their support services, including IT and accounting service providers; and
• third parties to whom disclosure may be required as a result of the relationship with you;
• third parties involved in the organisation of our events;
• any business partners to whom you may have requested that we transfer your personal data;
• third parties to whom disclosure may be required as a result of legal obligations imposed on us;
• when you have given your consent;
• as necessary in order to provide the Website (example: third-party internet service providers);
• as necessary in order to provide the games (example: third-party hosting providers);
• as necessary in order to communicate with you (example: third party email program providers);
• to carry out your instructions;
• in the circumstances where your data is on an anonymous and aggregated basis, meaning you could not be personally identified from it;
• as permitted by law or regulation;
• in order to comply with any legal obligation, in order to enforce or apply our terms and conditions or to protect the rights, property, or safety of Hacksaw or the Operators (example: third-party gaming regulators);
• in the event that there is a sale of the assets of Hacksaw or corporate restructuring, or as a result of a change of control of Hacksaw or one of its group companies, or in preparation of any of these events. Any third party to which Hacksaw’s assets are transferred will have the right to continue to use the Personal Data as set out in this document.

Except for these circumstances, we will not transfer or share your information to any third party.

Your Personal Data may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). The Personal Data may be hosted on servers outside EEA. Your Personal Data may be processed by staff operating outside the EEA who work for us, if at all, or for another company within the Hacksaw Group, or for one of our suppliers.

We will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this document when transferring the Data.

PROTECT

We have appropriate technical and physical safeguards to protect your Personal Data against accidental or unlawful destruction or loss, modifications, unauthorised use, disclosure or access, and all other unlawful forms of processing.

Since the internet is not a completely secure environment we can’t guarantee that information you transmit via our Website or Games will not be accessed, disclosed, altered or destroyed by breach of any of our safeguards or otherwise. We will of course follow applicable rules and processes for notifying you if this should happen.

Your personal data will not be used for any decision solely taken on the basis of automated decision making processes, including profiling, without human intervention. In the interest of transparency, note that we use systems which could profile you. Such systems are used by us exclusively to help us comply with legal obligations imposed on us as a result of anti-money laundering and combating the funding of terrorism legislation. As stated, no automated-decision will result from our use of such systems.

RIGHTS

• Right of access – you have the right to ascertain the personal data we hold about you and to receive a copy of such personal data;
• Right to complain – you have the right to lodge a complaint regarding the processing of your personal data with the supervisory authority for data protection matters. In Malta this is the Information and Data Protection Commissioner.
• Right to Erasure – in certain circumstances you may request that we delete the personal data that we hold about you;
• Right to Object – you have a right to object and request that we cease the processing of your personal data where we rely on our, or a third party’s legitimate interest for processing your personal data;
• Right to Portability – you may request that we provide you with certain personal data which you have provided to us in a structured, commonly used and machine-readable format. Where technically feasible, you may also request that we transmit such personal data to a third party controller indicated by you;
• Right to Rectification – you have the right to update or correct any inaccurate personal data which we hold about you;
• Right to Restriction – you have the right to request that we stop using your personal data in certain circumstances, including if you believe that we are unlawfully processing your personal data or the personal data that we hold about you is inaccurate;
• Right to withdraw your consent – where our processing is based on your consent, you have the right to withdraw your consent. Withdrawal of your consent shall not affect the lawfulness of the processing based on your consent prior to the withdrawal of your consent; and
• Right to be informed of the source – where the personal data we hold about you was not provided to us directly by you, you may also have the right to be informed of the source from which your personal data originates.

Please note that in terms of the applicable laws, your rights in relation to your personal data are not absolute.

CONTACT

If you have any questions, complaints or comments about this document or our use of Personal Data contact us by email at [email protected], post sent to the address indicated in the Company Details section below.

You can also complain to your local Data Protection Authority. Address: Level 2, Airways House, High Street, Sliema SLM 1549
Email: [email protected]
Website: https://idpc.org.mt/en/Pages/contact/complaints.aspx

COMPANY DETAILS

Hacksaw Gaming Ltd is incorporated in Malta bearing Company Registration number C84109 and having its registered address at 1st Floor, Suite 3, Central Business Centre, Mdina Road, Zebbug ZBG9015

We may update this Privacy Notice in our sole discretion including as result of a change in applicable law or processing activities. Any such changes will be communicated to you.

Last updated on 3rd October 2018