Privacy Policy

• Personal data and data controller
• Data that we collect from you
• How we use your personal data
• Who we can share your personal data with
• International transfers of personal data
• Storage of personal data
• Security
• Cookies
• Marketing communications and your choices
• Your rights
• How to contact us/our Data Protection Officer
• Changes to this policy

Personal data and data controller

ElectraWorks (Svenska) Limited is a company within the Entain Group, Swedish company registration number 502081-3662 and Swedish gaming license for commercial online gambling with no. 21Si1654. According to the provisions of the General Data Protection Regulation, ElectraWorks (Swedish) Limited is the data controller for the information collected and stored when someone uses our website www.ninjacasino.se and, where applicable, our mobile application. This Privacy Policy explains, among other things, what your collected personal data is used for and what rights you have and what obligations we have.

In this Privacy Policy the terms 'we', 'our' or 'us' include ElectraWorks (Swedish) Limited, other companies within the Entain Group and all Entain Group brands listed at (https://entaingroup.com/about/business-overview/our-brands/).

We are committed to protect your personal data securely when you use our services through our website and applicable mobile application, and it is an obligation we take very seriously. We apply strict and proven security procedures to protect your personal data. If you have concerns about how we process or protect your personal data, or would like to contact us about any part of this policy, you can contact us via the contact details on the last page of this Privacy Policy.

This Privacy Policy should be read in conjunction with our General Terms and Conditions, our Game Rules and other applicable terms and conditions for the services provided on our website.

Data that we collect from you

We collect data about you from the following sources:

• When you register an account with us
• When you visit our website or social media pages
• Through questionnaires that you fill out
• When you communicate with us (via email, letter, phone, via chat, including chat rooms or social media apps)
• When we analyse your interaction with us
• From our other group companies for internal reasons, mainly for business and operational purposes
• From public sources of information such as public records or social media posts
• From cookies and tracking devices on your devices where you have allowed them to be used
• From third-party databases to comply with our legal and judicial obligations
• From online sellers and service providers providing, for example, payment solutions, as well as from customer lists acquired from other parties

How we use your personal data

1.Provision of products or services

a.Typical personal data includes:

i.Your name, home or email address, phone number or online identity or other contact information you provide to us

ii.Your date of birth, gender

iii.Login details

iv.Information about game transactions and payment methods

b.Legal basis

i.Compliance with agreements

ii.Legal obligations

c.Further information

i.To comply with our obligations arising from agreements entered into between you and us and provide you with information, products and services that you request from us, including information about changes to our website, services or our terms and policies.

2.Customer service issues

a.Typical personal data includes:

i.Name, online identity, player ID

ii.Contact details

iii.Account notes and communications, call recordings

iv.Information about game transactions and payment methods

v.IP address, MAC address, device type, apps, location

b.Legal basis

i.Compliance with agreements

ii.Legitimate interests in player satisfaction, protection of our business and our customers in connection with responsible gambling

c.Further information

To provide customer service, answer your questions or handle your complaints or concerns.

3.Comply with our legal and lawful obligations

a.Typical personal data includes:

i.Name, online identity, player ID, contact information

ii.Games played, bets, winnings and losses, deposits and withdrawals, payment methods

iii.Online images of games and screenshots

iv.IP address, MAC address, device type, apps, location

b.Legal basis

i.Legal obligation

ii.Protect the vital interests of data subjects and others

iii.Carrying out a task that is carried out in the public interest

iv.Legitimate interests to protect our business, our staff and our customers

c.Further information

i.To comply with our lawful and legal obligations and obligations that include (but are not limited to) the Swedish Gambling Act, as well as liability for responsible gambling, money laundering, fraud and counter-terrorism laws. This may include electronic methods to identify you, for example through the use of cookies and images on online games.

4.Identity checks, age verification and ensuring responsible gambling and to maintain our duty of care

a.Typical personal data includes:

i.Name, online identity, player ID, contact information, date of birth and gender

ii.Login information, websites and visited web pages

iii.Information about game transactions and payment methods

iv.IP address, MAC address, device type, apps, location

v.Historical communications and account notes, call recordings

vi.Information about customer well-being

vii.National system list for voluntary suspension 'Game pause' ('Spelpaus')

viii.Pictures and selfies

b.Legal basis

i.Consent

ii.Compliance with agreements

iii.Legal obligation

iv.Protect the vital interests of data subjects and others

v.Carrying out a task which is carried out in the public interest and our customers' interests

c.Further information

i.To fulfil our responsibility for responsible gambling (such as registering players who are voluntarily suspended and where we believe a customer has a gambling problem).

ii.To check or validate your identity, age and protect your data.

iii.This may include electronic methods to identify you, such as using cookies.

5.Conduct surveys, competitions and promotions

a.Typical personal data includes:

i.Name or online identity

ii.Contact details, home address, email or phone number

iii.Contact preferences

iv.Responses to surveys, clicks on advertising, preferred products, your feedback

b.Legal basis

i.Consent

ii.Legitimate interests to understand our customers' opinions and encourage increased interaction with our customers

c.Further information

i.To invite you to participate in competitions, to provide us with feedback about your experiences, participate in promotions or to keep you informed about products and services that may be of interest to you.

ii.To measure or understand how effective our advertising to you and others is, and to provide relevant advertising to you.

iii.You can unsubscribe from receiving direct marketing communications at any time.

6.Lifestyle and demographic insight and profiling

a.Typical personal data includes:

i.Contact preferences

ii.Responses to surveys, clicks on advertising, preferred products, your feedback

iii.Interests and habits

Legal basis

i.Legal obligation

ii.Carrying out a task which is carried out in the public interest

iii.Legitimate interests

c.Further information

i.To create a profile of you, your preferences and your habits to better understand your interests and how you play.

7.Improve our services and ensure our systems are safe and up-to-date

a.Typical personal data includes:

i.Player ID

ii.Login information, websites and visited web pages

iii.Games played,

iv.IP address, MAC address, device type, apps, location

v.How to use mobile applications and websites

b.Legal basis

i.Legitimate interests to ensure that our communication with customers is appropriate, functioning and effective

c.Further information

i.To ensure that content from the Website is presented in the most effective way for you and your computer, maintain and improve our products and services, optimise business processes, ensure the integrity of our systems and manage our IT property, conduct quality assurance, support effective management of our staff, analyse the performance of the websites or promotions and provide content relevant to you.

8.Prevention and detection of crime, prevention of loss, protecting staff and customers

a.Typical personal data includes:

i.Name, online identity, player ID, contact information

ii.Login information, websites and visited web pages

iii.Games played, bets, winnings and losses, deposits and withdrawals, payment methods

iv.Online images of games and screenshots

v.IP address, MAC address, device type, apps, location

vi.Risk values, profile classifications

vii.Historical communication and account notes

viii.List of active applications and active processes when using our website, including access to files and location-related application apps

b.Legal basis

i.Carrying out a task which is carried out in the public interest

ii.Legitimate interests to protect our customers, businesses and workers.

c.Further information,/p>

i.To prevent or detect crimes, fraud, theft or loss directed against our company and our customers and prevent the use of improper practices on our websites or potential violation of our terms and conditions and applicable law.

ii.To protect our staff and other individuals from injury or loss.

iii.This may include monitoring online activity, electronic methods to identify you, for example through the use of cookies, your online transactions and payments.

Business sales, acquisitions and rights

a.Typical personal data includes:

i.Name, online identity, player ID, contact information

ii.Login information, websites and visited web pages

iii.Games played, bets, winnings and losses, deposits and withdrawals, payment methods

iv.IP address, MAC address, device type, apps, location

v.Risk values, profile classifications

vi.Historical communication and account notes

b.Legal basis

i.Legitimate interests in protecting and defending our business

c.Further information

i.To exercise or defend legal claims or to acquire or sell a company.

Much of the information we collect about you is required to comply with our legal obligations. However, when we ask for your consent to process your personal data, you do not need to provide it, although if you do not, you may not be able to use our services.

We may also store more sensitive personal data about you (often referred to as 'special categories of personal data') that may come directly from you, from other sources as described above, or from decisions we have made about you.

We may make some of these decisions or take actions to manage your account or meet our obligations using fully automated decisions. However, we will always provide you with contact details where you can ask for a review of the decision or receive additional information from us.

Who we can share your data with

We may need to share collected and stored personal data with other organisations to ensure that we comply with our statutory obligations or if we need support to meet your needs or our contractual obligations. We may also share information with other organisations if we believe it is consistent with the legitimate interests of the public, ours or yours. These other parties are usually:

• business partners, suppliers and subcontractors to fulfil a contract we enter into with them or you
• our partners if you have explicitly chosen not to receive marketing from us/third parties, you have been blocked or voluntarily suspended, in which case we may share removal lists with our partners to ensure that you do not receive unsolicited marketing
• companies within the Entain Group and third party providers and service providers for any of the purposes listed in the table above; third-party providers and service providers to the extent that they assist Entain Group with its legal/legal obligations, such as providers of money laundering, fraud, verification, etc.
• selected third parties so that they can contact you with information about the services they provide, when you have explicitly chosen/consented to your personal data being disclosed for these purposes
• analytics and search engine providers that help us improve and optimise our website and other selected third parties
• other third-party organisations that ask for, encourage, or collect online feedback and other views about your experiences with us to help us improve and optimise our services;
• Banks, credit card companies and relevant bodies that may share your information with third parties for the purpose of investigating and protecting against minors playing, fraudulent, criminal or suspicious activities or safer games (or other activities that we are committed to investigating and protecting against by law, regulation or guidance) or if we have reason to believe that you have participated in such activity
• our regulators, law enforcement or fraud prevention agencies, our legal advisors, courts, applicable independent court services and poker organisations and any other authorised body, for the purpose of investigating actual or suspected criminal activity, maintaining behavioural standards in poker or other regulatory or legal matters.

We may share your personal data with other companies within the Entain Group for marketing purposes. We will not share them with other companies or organisations unless you have explicitly consented to the disclosure of your personal data for these purposes.

We may also disclose your personal data to third parties in the following circumstances:

• in the event that we are considering selling or buying a business or assets, in which case we will disclose your personal data to potential sellers or buyers of such business or assets
• in the event of liquidation, merger or insolvency of any company within the Entain Group or in the event of the liquidation of a controller or other similar situation within the Entain Group
• if we, or essentially all of our assets, are acquired by a third party, in which case the personal data we hold about our customers will be one of the transferred assets
• to enforce or apply our Terms of Use to the website
• to protect our rights, property or security, or those of our staff, our customers or others. This includes the exchange of information with other companies and organisations for the security of staff and customers, crime prevention, fraud prevention and credit risk reduction;
• if we are required to disclose or share your personal data in order to comply with legal obligations or legal requirements, or otherwise to prevent or detect fraud or crime. If you have voluntarily suspended yourself from gambling, we may share this information with our regulators or other companies in our industry when we believe it is important to support your suspension.

Within Entain Group, we always work actively and purposefully to try to identify gambling addiction. In order to fulfil our obligations regarding the duty of care and to fully contribute to responsible gambling, we may disclose your personal data in the following circumstances:

• We may share your data with all companies and businesses within the Entain Group, and if necessary with other organisations to fulfil our commitments to our duty of care and responsible gaming.
• We have an obligation to identify at-risk players as early as possible and help them to stop gaming by placing certain restrictions on their accounts. These may include deposit limits, product limits, restriction of an account's ability to play certain products/during certain times/for certain periods. In order to comply with these obligations, we analyse the player's transactions and evaluate their behaviour or financial situation across our products and brands, which may lead us to make decisions about the player's accounts.
• We are also constantly looking for innovative ways to help players who may be heading into difficulties and identify them digitally. This means that we may use systems that identify customers (such as cookies on the player's devices or images that you send). We have also developed internal systems to understand your gambling in order to better communicate any risks related to your activity. We may also share or receive player data with other organisations that help evaluate risks or assess affordability by looking at how you interact with other gaming operators or help individuals directly.

In all these cases, you can rest assured that we take our obligations seriously to help our customers play responsibly while protecting your personal data. We will always ensure that we take the most appropriate measures and controls to protect your data.

Storage of your personal data

• Territory: All jurisdictions
• Typical retention period: 3 years
• Additional information: An extended retention period may apply on a case-by-case basis

• Territory: EU territories
• Typical retention period: 10 years (starting from the date you request your account to close or your account becomes inactive)
• Additional information: We will only continue to store personal data related to your account as permitted or required by data protection legislation (i) where we comply with a legal requirement under gambling or tax law to retain your data; and (ii) to exercise or defend our legal rights.
• If you sign up under the voluntary suspension system, while your voluntary suspension may be of a shorter duration, this will be registered and saved for longer as part of your customer profile.

The retention periods above may be extended if, for example, this is required to fulfil a specific legal obligation, investigate a crime, handle a claim or resolve a complaint.

International transfers of personal data

From time to time, service providers, companies within the Entain Group and other organisations with which we cooperate may be located outside the UK or the European Economic Area, in countries that do not have the same protection of personal data as countries within EU or EEA countries. However, we will always take all reasonable steps to ensure adequate protection to protect your personal data. We will also ensure that our service providers enter into personal data processing agreements with us to ensure that your personal data is processed in accordance with applicable data protection legislation. You can find more information about the mechanisms that we will use on the website below, but you can also contact us if you have specific questions regarding international transfers: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_sv.

Security

We take compliance with security regulations, standards, guidelines and privacy laws seriously and promote security measures that will maintain the confidentiality, integrity and availability of collected and stored personal data. We take reasonable organisational, technical and administrative measures to protect your personal data from unauthorised access, alteration, disclosure or destruction.

As a company, we have secure computer systems that are protected by firewalls, certified encrypted websites and we are certified according to ISO 27001:2013. We also take steps to ensure that all companies within the Entain Group and all partners and suppliers use adequate security levels throughout the business.

Where we have given you (or where you have chosen) a password that allows you access to certain parts of our website, you are responsible for keeping this password confidential and personal, i.e. you must not share your password with anyone else.

Unfortunately, the transmission of information over the internet is never completely secure. Although we will do our best to protect your personal data, we cannot fully guarantee the security of your data transmitted to our website; all transfers are at your own risk. Once we have received information about and from you, we will use strict procedures and security features to prevent unauthorised attempts to unlawfully access collected and stored personal data.

Cookies

We use cookies for various purposes, including making your experience of our website better. You will receive more information about our use of cookies in our Cookie Notice.

Marketing communications and your choices

When we first collect your personal data, we ask you to tell us how you want to receive information about our other products and services in the future. This will normally be done using tick boxes on forms or the website and you can unsubscribe at any time.

Unsubscribing in this context refers to several methods that you can use to avoid receiving unsolicited product or service information. This opportunity is usually associated with direct marketing campaigns such as telemarketing, email marketing or direct mail. Please note that unsubscribing will not prevent important customer correspondence, i.e. information that we believe you must receive, such as, but not limited to, communication regarding your gaming account.

If you do not wish to receive any offers, promotions, event information and tailored communications based on your account activity, you can request that you not be contacted by:

• using the unsubscribe option in all marketing communications that you receive
• changing your preferences in your account settings
• contacting our Customer Support.

We need as much of the following as possible to ensure that you do not receive additional unsolicited correspondence:

• Your full name
• Your account number or username
• How we contacted you, i.e. email, SMS or post
• The mobile phone number or email/postal address we used to contacted you
• The mobile phone number or email address that the message came from
• Date and time you were contacted
• A copy of the message you received (e.g. screenshot or forwarded email to our customer service)

Your rights

• You have the right to receive clear, transparent and easily understandable information about how we use your information and your rights. and you always have the right to access the personal data we have collected (stored) about you. You also have the right to demand that we correct incorrect personal data.