This Privacy Statement applies to all Personal Data that Talpa Gaming processes when you use the following websites and/or mobile apps (“Gaming Websites”) as a visitor or customer:
- Governor of Poker
In this Privacy Statement, we provide additional information about the Personal Data we collect and use when you play our games and/or visit Gaming Websites or apps that are part of our gaming platform. We may also use your data to send you offers tailored to your interests and preferences. Finally, we will also inform you about the parties with whom we share your Personal Data, how long we retain it, and what rights you have with regard to the processing of this data.
This Privacy Statement consists of the following sections:
- Who we are
- The types of Personal Data we collect and how we collect it
- The purposes for which we use your data
- Sharing data with Third Parties
- Security and Retention
- International transfer of data
- Privacy requests, queries, and complaints
- Updates to this Privacy Statement
- Portal-specific information
1. Who we are
We are Talpa Azerion Gaming B.V. (also known as “Talpa Gaming”), a gaming company and joint venture between Talpa Network B.V and Azerion Holding B.V., with our registered office at Beechavenue 182, 1119 PX Schiphol-Rijk. Talpa Gaming is responsible (the controller) and – in exceptional cases – jointly responsible for the collection and use of your Personal Data described in this Privacy Statement.
Talpa Azerion Gaming B.V. (”Talpa Azerion Gaming B.V.”, ”we”, ”us” or ”our”) respects your privacy and recognizes the importance of providing a secure environment for your Personal Data. That is why we aim to provide you with clear and transparent information as to why and how we process your Personal Data .
2. The types of Personal Data we collect and how we collect it
When you access or play a game on one of our Gaming Websites, we may collect, use, store and transfer various kinds of Personal Data. The data we use depends on the purpose for which we process the data. We will only use your data for the as purposes described below in this section and in section 9 (Portal Specific Information) of this Privacy Statement.
In addition, we do not use all of the personal data you provide. The data we process may differ for each specific Gaming Website or app. For more information about the data that is processed via a particular Gaming Website or app, please see Section 9 of this Privacy Statement.
2.1 Basic Personal Data provided by you
When you access or play a game on our Gaming Websites, you may provide certain information to us, or receive a request to provide certain information to us, including:
- E-mail address
- Age verification: we offer an option to indicate whether you are younger than 18 years.
- Game ratings: we process rating information when you use the voting button on our Gaming Websites to rate games.
2.2 Special Categories of Personal Data
As a general principle, we do not process ‘Special Categories of Personal Data’, and do not ask you to provide such information. ‘Special Categories of Personal Data’ includes sensitive data such as race, ethnic origin, political opinions or philosophical beliefs, religion, trade union membership, sexual preferences or orientation, health data or criminal data.
2.3 Minors (under 18 years of age)
Visiting the Gaming Websites: Our Gaming Websites or apps allow visitors to play without registration (barring certain exceptions). When you play these games or Gaming Websites, no cookies other than essential cookies (as described below) are used when you indicate that you are under the age of 18.
When you first visit or play a game on one of our Gaming Websites, you will be shown a cookie notification and we will ask you to verify whether you are under 18 years of age. This age verification method will only be used to verify your age, and we do not store this information.
If you indicate that you are under 18 years of age, you will automatically be redirected to a separate Kids Domain and a single ”do not track” cookie will be placed on your device. No further cookies will be placed on your device, apart from essential cookies necessary to maintain the functional settings and performance of the website, i.e. to provide you the requested services and enable you to navigate the website and to make use of its functionalities. In this case, we may show you non-targeted advertisements, as we cannot show you targeted advertisements.
2.4 Personal Data we receive or generate from your use of our games or Gaming Websites
When you visit or play a game on our Gaming Websites, we may also process device-related data and information about your interactions with our games or Gaming Websites, including:
- Technical data: We collect information about your device and/or device settings for the purposes described below, and may combine this information across the different devices you use. The information we collect from these devices includes what type of device you use, online identifiers (your IP address), device IDs, game or website IDs, geolocation data (based on your IP address), and other technical data.
- Your usage: We collect information about how you use our Gaming Websites and/or games available on our Gaming Websites. This information includes your preferences, such as your interests in certain categories of games, the actions you take, and the time and duration of these actions. We also collect information about the websites that led you to our Gaming Website.
2.5 Personal Data we collect from other third parties
In certain cases, we will also obtain your Personal Data from third parties. We do so in full compliance with applicable data protection laws and regulations. Your Personal Data may be provided by the following third parties:
- Other third parties: We may also receive information about your approximate geolocation (the country in which you are located) from third parties (e.g. Google). We use this information to comply with our legal obligations regarding the processing of your Personal Data, to customize certain services to your location, and to prevent fraud or misuse.
2.6 Profiling activities
If you provide consent to do so via the cookie notification, we may use tracking mechanisms to track your Personal Data for profiling purposes. This allows us to display relevant content and tailor our services to your interests. For example, if you frequently play racing games, we might show you different racing/car games available on our Gaming Websites, or show you advertisements for cars or automobile accessories. You have the right to object to this type of data processing. You can also go to your privacy settings at any time to review and modify your choices regarding this type of data processing.
3. The purposes for which we use your data
Depending on the Gaming Website you are using and the privacy settings you have selected, we may process your Personal Data for the following purposes:
A. Provision and improvement of our games and services
- to allow you to play our games, including third-party games available on our Gaming Websites
- to facilitate content sharing on social networks
- to provide technical/customer support and respond to your requests
- to identify and correct any bugs/errors
- to gain insight into the popularity of our games
- to assess the quality of our services
- to understand and improve your online experience
- to aggregate financial reports in order to pay our business partners
B. Personalization of your gaming experience
- to remember your preferred (game) settings
- to display your favourite games
- to recommend games you might enjoy on the basis of your interests
- to display personalized advertisements
- to remember you the next time you visit one of our Gaming Websites
C. Marketing and analytics
- to include (targeted and non-targeted) advertising in our games or on our Gaming Websites
- to measure the effectiveness of advertising
- to send you marketing communications, inform your about new content, and provide in-game offers
D. Preventing fraud and illegal activities
- to detect fraudulent activities and illegal conduct within our games or on our Gaming Websites
- to provide you with customer support based on your questions, requests, or complaints
- to send you service emails, so that you can activate your account, for instance, or in case you forget your password
F. Compliance with our obligations on the following legal bases
We process your Personal Data, based on the following legal basis:
- Your consent: We process your Personal Data if you have granted consent to process data for a specific purpose. For example, when you first visit our Gaming Website, we ask for your consent to process data with reference to personalized advertising, analytics, profiling, social media and games from external publishers. We may also display contextual ‘just-in-time’ notifications and consent pop-ups to request your consent for additional data processing. You have the right to withdraw your consent at any time, for example by changing your privacy settings. Please note that this will not affect any processing carried out prior to the withdrawal of your consent.
- Performance of a contract: We process your Personal Data for the purpose of performing a contract to which you are a party. For example, to support the operation of our games or facilitate the provision of requested services.
- Compliance with legal obligations to which we are subject: We process your Personal Data in order to comply with legal obligations. For example, to respond to your requests related to your rights as a data subject and other obligations, such as informing you of any changes to this Privacy Statement.
- Legitimate interests: We may also process your Personal Data to the extent that such processing is necessary for our legitimate interests or those of third parties in the application of appropriate safeguards to protect your privacy. For example, we may process your Personal Data to improve the services we provide to you, to enhance your user experience, and ensure the proper functioning of our services.
4. Sharing data with Third Parties
We will not disclose your Personal Data to any party that is not authorized to process such data. To manage our services, we will share your Personal Data internally with members of the relevant departments and technical support staff involved in the gaming process, and in each case only if access to your Personal Data is necessary for the fulfilment of their professional tasks.
In addition, and only when necessary to fulfil the purposes mentioned above, we may disclose your Personal Data to the following recipients or categories of recipients or permit the following third parties to collect your Personal Data in connection with your use of our games or Gaming Websites:
- External service providers: We may share your Personal Data with external service providers who perform services on our behalf, like customer support service, IT services, hosting and content delivery services, web/social analytics services, data management services, data sharing services on social media, video hosting services, and user notification services. When we share your Personal Data with external service providers, we have appropriate agreements in place to ensure that your Personal Data is processed in compliance with applicable data protection laws.
- Third-party advertisers: With your consent, we may share your Personal Data with third-party advertisers or allow third-party advertisers to collect your Personal Data when you visit or play a game on our Gaming Website. If you indicate that you do not wish to receive any personalised advertisements at all, we will still show you advertisements but they may not reflect your interests, as those ads will be tailored to the content and not to the user. Please note that by clicking on a third-party advertisement, you may be redirected to the third-party advertiser’s environment, and we have no control over that environment.
- Social networks and related third-party platforms: If you wish to share certain content on social media, you will be asked to log in with your login credentials for the relevant social media platform. In this case, a link to the website you wish to share will be published on the relevant website/social network platform. In addition, the social media sharing service we use to enable you to share content on social networks may collect certain information, such as your IP address, geolocation data based on your IP address, the URL that leads to the website, the date and time you visited and used our Gaming Website, and whether you used the toolbar to share content.
- Law enforcement, government agencies, or judicial authority: We may disclose your Personal Data in response to lawful requests to public authorities, including law enforcement, government agencies, or the judiciary.
- Other third parties: We may also disclose your Personal Data in the event of any intended or initiated reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business or assets (including in any insolvency or similar proceedings).
By clicking here, you will see an overview of the third parties with whom we may share your Personal Data or who may share your Personal Data with us.
5. Security and Retention
5.1 How we protect your Personal Data
We have implemented appropriate technical and organizational security measures designed to protect your Personal Data against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We update and test our security standards on an ongoing basis. In addition, we take all reasonable measures to ensure that third parties to whom we transfer your Personal Data provide sufficient Personal Data protection.
5.2 How long will we store your Personal Data
We will not retain your Personal Data longer than necessary to fulfil the purposes for which the data was collected or to fulfil our legal obligations. We will subsequently delete or anonymize your Personal Data. Additional information on how long your Personal Data is stored by our service partners can be found in the respective third-party list available here.
6. International transfer of data
In general, your data is stored on servers within the European Union (EU) / the European Economic Area (EEA).
However, your data may also be shared outside the EU / EEA. Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here).
For the transfer of Personal Data from the EEA to countries not considered by the European Commission to provide an adequate level of protection, we have taken appropriate measures, such as standard contractual clauses adopted by the European Commission, to protect your Personal Data. You can obtain an overview of these measures by clicking here.
We are aware of the ruling of the EU Court of Justice of 16 July 2020 with implications for the transfer of Personal Data. We are currently investigating how best to absorb and adapt to the consequences of this ruling. Privacy is very important to us and we will take all reasonable measures to find an appropriate solution. Once we have developed an appropriate solution, we will inform you via this Privacy Statement.
7. Privacy requests, queries, and complaints
7.1 Your rights
To the extent permitted by applicable data protection laws and regulations, you have the following rights with respect to your Personal Data:
- T access the Personal Data we hold about you, including information such as the source and categories of data, the processing purposes, the recipients (or categories thereof), and the respective retention period.
- To request an update or correction of your Personal Data so that it is always accurate.
- To receive your Personal Data in a structured, commonly used and machine-readable format, including the right to transfer your Personal Data to another data controller.
- To request the deletion of your Personal Data if you believe that retention is no longer necessary for the purposes indicated above.
- To restrict the processing of your Personal Data in certain circumstances, for example, if you have contested the accuracy of your Personal Data, and for a period of time that is sufficient to allow us to verify its accuracy.
- To withdraw your consent at any time if your Personal Data is processed with your consent. Please note that this will not affect the lawfulness of data processing based on consent granted prior to its withdrawal.
- To object on specific grounds relating to your particular situation, in the event and to the extent that we process your Personal Data based on our legitimate interests. In that case, we will no longer process your Personal Data unless we have compelling legitimate grounds for processing that outweigh your interests, rights and freedoms, or within the framework of establishing, exercising or defending legal claims. You also have the right to object if we process your Personal Data for marketing purposes (including profiling). In that case, we will stop processing your Personal Data for marketing purposes.
7.2 Privacy Office
If you wish to exercise your rights, please send your request to the Talpa Gaming Privacy Office:
1119 PX Schiphol-Rijk
E-mail: [email protected]
Please specify in your request, insofar as possible, to which Personal Data your request relates and what right you wish to exercise, and provide evidence to demonstrate that you are the individual to whom the Personal Data relates. We aim to respond to your request within a period of one month.
7.3 Queries, comments, or complaints
If you have any questions, comments, or complaints about this Privacy Statement, please feel free to contact us. If you believe we have failed to comply with our obligations under applicable data protection laws and regulations, you have the right to lodge a complaint with the competent supervisory authority. In the Netherlands, the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) in The Hague is responsible for monitoring compliance with privacy regulations.
8. Updates to this Privacy Statement
We regularly review and update this Privacy Statement. If an important change is made that impacts the processing of your Personal Data, we will publish a notification to this effect on our Gaming Website.
This Privacy Statement was last updated on December 02, 2020.
9. Portal-specific information
In this part of our Privacy Statement, you will find specific information about the ways your Personal Data is processed for the games and Gaming Websites (with certain exceptions).
This section is supplementary to the general information on data processing as described above. Each topic - as listed below - will indicate the game and Gaming Website to which it applies by means of the following notations:
* Applicable to Spele, Funnygames, Bgames and Governor of Poker
** Applicable to Spele, Funnygames, Bgames
Hosting and content delivery (*): The portals are hosted by external companies providing web servers and web content. When you make a request, for example by clicking on a link on our platform, the information allowing this request to be made (e.g. device information and information regarding the requested content) will be sent to the external servers. This data is used to display the requested content more quickly. We process this data on the basis of our legitimate interest, to provide and improve our service and ensure its proper functioning.
Analytics (*): We use web analytics companies to understand how popular our games are to monitor traffic on the portals, for example following changes to the website. To do this, we process information about your device, retrieve data (including the URL of the current webpage and the website visited previously) and special event data (for example, if you share a link with your friends on the relevant social media platform). We may also process your full IP address to allow us to better understand how you use our games or our website, and to improve our games and websites. We process this information based on your consent, which you have provided via the consent pop-up displayed when you access the portals for the first time.
Social media (*): You can share content from the portals with your friends via social media by clicking on the social media share button and using your social media platform login credentials. Following your request, your IP address, device information, and information about the link you wish to share will be sent by the social media sharing service provider to the social media platform where the link will be published. We process this data based on your consent, which you can provide by selecting the option to share our website, or via the cookie notification pop-up.
Customer service (**): If you contact us for customer support by using our email address, an external customer service company will process your email address, the content of your request, information about your device, and your IP address so that they can provide you with support. Previous support requests that you have sent us may help us solve subsequent support requests. We process this data on the basis of our legitimate interest, to provide you with customer support, to improve our services, and to enable us to defend possible future legal claims.
Game distributors (**): On the portals, we offer games from third-party game distributors who may process your Personal Data. We will only show you third-party games on our Gaming Websites if you have given consent via the consent pop-up that is displayed when you first enter the portals. You will be able to choose from which third-party game distributor(s) you wish to play games, and which third-party game distributor(s) may accordingly process your Personal Data as described in their respective privacy policies. In such cases, as described above in section 4 of this Pivacy Statement, you will play the game in the virtual environment of the third-party game distributor, over which we have no control. The third-party game distributor processes your data when you play the games provided to us by that third-party, and they must obtain your valid consent where applicable. If you intend to play a game from a third-party distributor, you will be notified that this is a third-party distributor game. You can adjust your preferences at any time in your privacy settings.
Last games played (**): For your convenience, we will show you the last five games you have played. This information will be stored locally on your device and will be deleted when the browser cache is cleared manually or automatically. We process this information based on our legitimate interest to in making your user experience as pleasant as possible.
Advertising (**): On the portals, we show advertisements from different advertising companies. These advertisements can be personalized, but may also be non-personalized content-related ads. In order to display personalized advertisements, and only if you have given your consent, we share your Personal Data (your IP address, advertising identifiers, and information stating that you have provided consent for personalized ads) with third-party advertisers and advertising networks through our advertising platform provider. We also use this information to measure how effective these advertisements are. In our consent pop-up, which is displayed to you the first time you visit our Gaming Website, you can choose which advertiser(s) you would like to receive personalised advertisements from, or choose not to accept personalised advertisements at all. You can change your preferences at any time in your privacy settings. If you choose not to receive any personalised advertisements at all, we will still show you advertisements, but they may not reflect your interests as those advertisements will be tailored to the content and not to the user.
Video player (**): We use an ad-supported video player to provide you with walkthrough videos of our games. In order to show you the correct video, your request data, including your IP address, the URL you visited, and device information, is processed by the third-party video provider on the basis of our legitimate interests.
Data management platform (**): Based on your consent, we process your Personal Data to show you relevant games and advertisements based on information about the games you play on the portals. For this purpose, your device information, IP address and information about the category of games you have played are collected and sent to an external data management platform provider.
Rating function (**): You can rate games on the portals by means of a thumbs up or thumbs down icon. It is in our legitimate interest to provide our users an overview which games are most popular and best rated. When you click on a rating button, we will store the aggregated voting data based on the performance of a contract. The results of all submitted ratings are used to generate a score between 1 and 5 for each game, giving you an overview of the most popular and most highly rated games. In addition, a local text file is stored to prevent you from submitting multiple ratings for the same game. We store this data in your browser’s local storage, and we do not share this data with other partners.
Push notifications (**): We may show you push notifications on your device to inform you of new content and offers, if you have provided your consent to do so. For this purpose, we will process information about the page you visited, your IP address and your device information and share this information with a notification service company that assists us in making these notifications.
Third parties (**): If you click here, you will see an overview of the third parties with whom we may share your Personal Data, or who may share your Personal Data with us.