MOBILE INCORPORATED LIMITED ("MobInc", "we" or "us") with its registered office at Tower Gate Place, Tal-Qroqq Street, Msida, MSD 1703, Malta, is committed to protecting and respecting your privacy.
This policy (together with our Player Terms and Conditions and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
Information we collect from you
The information that we collect and process may include:
- Information you give us. This is information about you that you give us by filling in forms on our Site or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register for an Account and when you report a problem with our site. The information you give us may include your name, address, e-mail address and mobile phone number, date of birth, financial and credit card information, personal description and photographs.
- Information we collect about you. We may collect the following data about you when you visit the site or that we obtain from third parties:
- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your device's MAC address, IMSEI number and other device identification information, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling and clicks and mouse-overs), methods used to browse away from the page, and any email address used to contact customer services.
- information about your gambling activities through the Site, including a record of each gambling transaction, your session times, any financial limits you have set for your Account, any take-a-break or self-exclusion periods you have requested, game type
- information you provide to us in any correspondence and a record of any correspondence we have with you, such as emails or chats;
- to record telephone calls and retain communications to and from our Customer Services Department for training purposes to allow us to improve our customer services as well as for security purposes to allow us to identify persons in subsequent communications (legitimate interests).
Uses made of the information and legal basis for such use
We use information held about you in the following ways:
- as required by Mob Inc to enable our business and pursue our legitimate interests, in particular:
- to administer our Sites and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our Sites to ensure that content is presented in the most effective manner for you and for your computer;
- to allow you to participate in interactive features of our service, when you choose to do so;
- as part of our efforts to keep our Sites safe and secure;
- to detect, prevent and report fraud, money laundering, irregular betting and cheating;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; and
- to contact you with regard to your use of our Sites and, at our discretion, changes to any of our policies;
- for compliance with applicable laws, regulations, the conditions of our gambling licences and protection of our legal rights, including, but not limited to, use in connection with legal claims, compliance, regulatory or investigative purposes (including disclosure of such information in connection with legal process or litigation); and
- to develop a profile of your activities on our Sites in order to offer you targeted promotions and to analyse your use of our Sites, products and services so that we can identify customers that may be at risk of problem gambling. In addition, with your consent, we may send you direct marketing in relation to our relevant promotions, products and services, or other promotions, products and services provided by us, our Affiliates and carefully selected partners. Although these will only be sent where you have given your consent, or (where permissible) you have been given an opportunity to opt out, you will be able to opt out of electronic direct marketing by following the instructions in each communication you receive.
- to carry out our obligations arising from any contracts entered into between you and us, for example to provide you with gambling services. This may include verifying your identity, managing your Account and any funds in your Account and communicating with you;
Disclosure of your information
We may also share your personal information with:
- Companies Affiliated With Mob Inc ("Affiliates"), so that those Affiliates can: (i) assist us with fulfilling your requests or improving our products, content, services or advertising; and/or (ii) contact you about products, content, services or other offerings that may be of interest to you.
- When You Consent To Have Your Personal Data Shared or Otherwise Request That We Share Your Information. We may offer you the opportunity to consent to the sharing of your information with third parties, including for marketing purposes. Additionally, you may request, sometimes through your use of an interactive feature or third-party application, that we share personal data about you with a third party. If you consent or request to receive communications from third parties, you will need to communicate with them directly if you later decide that you no longer wish to receive their communications. Any information collected directly from or about you by such a third party is subject to its own privacy notice.
- Third-Party Service Providers Providing Services on Mob Inc's Behalf. We may from time to time employ third parties to perform functions on our behalf, and as a result we may also share your personal data with third party service providers that assist us with providing content, fulfilling your requests, improving our products, content, services or advertising, or otherwise performing services for Mob Inc. For example, we may share your information in order to host or operate the Sites and for data analysis purposes. The list of third-party service providers includes; Game providers, Payment services, Communications providers, Software providers (including platform), Identification and AML services providers, Marketing providers (including social media) and Security services.
- Business Transactions. We may share your personal data with other entities and advisors for internal reasons, primarily for business and operational purposes including any corporate reorganisation, restructuring or other corporate change or business advice. In addition, Mob Inc or any of its assets, including the Sites, may be sold, or other transactions may occur which result in your data being transferred to the purchaser of Mob Inc or its relevant assets.
- Legal Protections and Law Enforcement. We may transfer and disclose information, including your personal data, (including Usage Information and Device Identifier (including IP address)), to third parties: (i) to comply with legal obligations and the conditions of our gambling licences; (ii) at the request of governmental authorities conducting an investigation; (iii) to verify or enforce our Player Terms or other applicable policies; (iv) to respond to an emergency; or (iv) to otherwise protect the rights, property, safety or security of third parties, visitors to the Sites or the public. Such disclosures may be carried out without notice to you.
Where we store your personal data
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). Where information is transferred outside the EEA, and where this is to a country or entity that is not subject to an adequacy decision by the EU Commission, data is adequately protected by EU Commission approved standard contractual clauses, an appropriate Privacy Shield certification or a supplier's Processor Binding Corporate Rules. A copy of the relevant mechanism can be provided for your review using the contact details set out below.
How long do we keep your data?
Where you sign up for an Account with us on our Sites, we will keep your personal information and other data about your visits to our websites or applications for the length of any contractual relationship you have with us, and, to the extent permitted, after the end of that relationship for as long as necessary to perform the purposes set out in this notice. Laws may require us to hold certain information for specific periods. In other cases, we may retain data for an appropriate period after any relationship with you ends to protect us from legal claims, or to administer our business.
You may be entitled to ask us for a copy of your information, to correct it, erase or restrict its processing, or to ask us to transfer some of this information to other organisations. You may also have rights to object to some processing, such as profiling we perform for the purposes of direct marketing, customer analytics and responsible gambling analysis and, where we have asked for your consent to process your data, to withdraw this consent. These rights may be limited in some situations – for example, where we can demonstrate that we have a legal requirement to process your data. In some instances, this may mean that we are able to retain data even if you withdraw your consent.
Where we require personal data to comply with legal or contractual obligations, then provision of such data is mandatory: if such data is not provided, then we will not be able to manage our contractual relationship, or to meet obligations placed on us. In all other cases, provision of requested personal data is optional.
We hope that we can satisfy queries you may have about the way we process your data. If you have any concerns about how we process your data, or would like to opt out of marketing, you can get in touch at [email protected].
If you are not satisfied with how we have treated your personal data, or how we have responded to and/or handled any concern you have raised with us, please contact the applicable supervisory authority, being at present the Information Commissioner's Office (or ICO) at: https://ico.org.uk/global/contact-us/
Third Party Websites
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.