Last revised: 24 April 2018
The Cityviews group companies, which includes all of the entities specified below under “The Group” section, including its affiliates (collectively, the "Cityviews"), offers online gambling services, such as Spin Palace, Ruby Fortune, Mummys Gold, Cabaret Club, Jackpot City, Riverbelle, Lucky Nugget, King Neptunes, Casino Epoca, Gaming Club and The Palace Group an online poker room – Spin Palace Poker, both through websites, mobile apps and other online properties (collectively, the “Services”).
Cityviews group includes the following companies:
We collect two types of information from our Users:
The first type of information is information that identifies or may reasonably identify an individual reasonable effort (“Personal Information”). Personal Information which is being gathered may consist of the following:
The second type of information is un-identified and non-identifiable information pertaining to a User(s), which may be made available or gathered via the User’s use of the Services (“Non-Personal Information”).
Non-Personal Information which is being collected consists of technical information and aggregated usage information, and may contain, among other things, the User’s operating system, type of browser, screen resolution, browser and keyboard language, the User’s ‘click-stream’ and activities on the Services, the period of time the User visited the Services and related time stamps, etc.
For avoidance of doubt, any Non-personal Information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection or linkage exists.
Types of Non-personal Information we collect from or about you:
Technical information: In order to enhance the functionality of the Services and to provide you with a better user experience, we collect technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time and the domain name of the website from which you linked to the Services; etc.).
Gameplay information: We record game play information including, amongst other things, your deposits, bets, bonuses, game session duration and your high scores. We may also share and publish such information through any of our Platforms.
Device and connection information: If you download the Software to your device, we may collect information from the particular device you are using, for security and fraud detection and prevention purposes. For example, we may gather information with regard to other software which is running simultaneously with the Software for detecting if you are using software which is associated with fraudulent activity (e.g. robots, malware, etc.) or checking if the connection you are using is via a VPN or proxy.
Analytics information: We collect information about your use of the Services, such as applications' usage, log files, user activity (e.g. pages viewed, the amount of time spent on particular pages, online browsing, clicks, actions, etc.), time stamps, alerts, etc. This information is collected for amongst other things troubleshooting errors and bugs as well as for research and analytics purposes about your use of the Services.
The Services are not designed or directed to persons under the age of 18 or persons under the age of legal consent with respect to the use of the Services of any jurisdiction, whichever is higher (“Legally of Age”). If you are not Legally of Age, you should not download or use the Services nor provide any Personal Information to us.
We reserve the right to access and verify any Personal Information collected from you. In the event that we become aware that a user who is not Legally of Age has shared any information, we may discard such information. If you have any reason to believe that a minor has shared any information with us, please contact us.
We We use your Personal Information for the purposes listed below:
The Group will use your Personal Information, such as your name, home address, email address, telephone number etc., ourselves or by using our third party subcontractors for the purpose of providing you with promotional materials, concerning the Services as well as products, services, websites and applications which relate to: (i) other companies within the Group; (ii) White Label Brands; or (iii) Group's business partners and affiliates (collectively: “Marketing Affiliates”), which we believe may interest you.
We may also share and disclose Personal Information with our Marketing Affiliates for the purpose of providing you different marketing offers, which we, or our Marketing Affiliates, believe are relevant for you. Our Marketing Affiliates may use this Personal Information for different marketing techniques, such as direct email, post, SMS and telephone marketing purposes.
You may update your marketing preferences at any time through Customer Services (where available). When you choose to download Software pursuant to our Services, notification software may also be downloaded onto your device. This allows us to send notifications to you about our Services directly to your device, for example to inform you about new features, updates, service communications, offers and promotions.
By downloading such Software, You consent to receiving notifications. If You would prefer not to receive these notifications, You will need to manually uninstall the notification software from your device (for example by clicking the "what's this" link on a notification you receive and following the 'how to remove' instructions", or by following the applicable "Settings" and "Notification Centre" uninstall instructions on Your Access Device).
You may at any time decline receiving further marketing offers from us or from our business partners and marketing affiliates by contacting us at to firstname.lastname@example.org. Please note that even if you unsubscribe from our marketing mailing list, we may continue to send you service-related updates and notifications.
We share Personal Information with any of the following recipients:
Since we operate globally, it may be necessary to transfer your Personal Information to countries outside the European Union. The data protection and other laws of these countries may not be as comprehensive as those in the European Union.
If you feel that your privacy was treated not in accordance with our policy, or if any person attempted to abuse the Services or acted in an inappropriate manner, please contact us directly at email@example.com.
When you visit or access our Services (for example when you visit our websites), we use (and authorize third parties to use) web beacons, cookies, pixels, scripts, tags and other technologies ("Tracking Technologies").
The Tracking Technologies allow us to automatically collect information about you and your online behavior, as well as your device (for example your computer or mobile device), for different purposes, such as in order to enhance your navigation on our Services, improve our Services’ performance and customize your experience on our Services. We also use this information to collect statistics about the usage of our Services, perform analytics, deliver content which is tailored to your interests and administer services to our Users, advertisers, publishers, customers and partners.
You should always review their privacy practices carefully before providing Personal Information to such third parties.
You are knowingly and voluntarily assuming all risks of using any third-party websites, services or applications. You agree that we shall have no liability whatsoever with respect to such third party sites and your usage of them.
If you have registered with an account through our Services, the Group will retain your Personal Information during the period your account is active. In addition, the Group will retain your Personal Data for additional periods, to enable the Group to meet its legal obligations under applicable laws or regulations, such as the applicable gambling regulations, Know-Your-Customer and Anti-Money Laundering regulations.
In addition, the Group may retain your Personal Information for longer periods, provided that retaining such information is necessary for the Group’s legitimate interests, such as fraud prevention and record keeping.
If for any reason you wish to delete your Personal Information, please send us an e-mail to firstname.lastname@example.org, and we will make reasonable efforts to address your request.
You may contact us at any time by email, and request:
Please note that these rights are not absolute and requests are subject to any applicable legal requirements, including gambling regulations and other legal and ethical reporting or document retention obligations. We may also rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion, in accordance with our internal policies.
We take great care in implementing and maintaining the security of the Services and your information. We have put in place appropriate physical and technological safeguards to help prevent unauthorized access, to maintain data security, and to use correctly the information we collect online. These safeguards vary based on the sensitivity of the information that we collect and store.
We employ industry standard procedures and controls to ensure the safety of our users’ information, such as:
Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse the Services, and we make no warranty, express, implied or otherwise, that we will prevent such access.
If you have any general questions about the Services or the information that we collect about you and how we use it, please contact us via email or via the form below.
We will make an effort to reply within a reasonable timeframe. Please feel free to reach out to us at any time. If you are unsatisfied with our response, you can reach out to the applicable data protection supervisory authority.
Revised at: March 28th 2018
When you visit or access our Services (such as websites or applications operated by us, or when you interact or engage with our content), we use (and authorize third parties to use) web beacons, cookies, pixel tags, scripts, tags, API and other tracking technologies ("Tracking Technologies").
The Tracking Technologies allow us to automatically collect information about you and your online behavior, as well as your device (for example your computer or mobile device), in order to enhance your navigation on our Services, improve our Services performance and customize your experience on our Services. We also use this information to collect statistics about the usage of our Services, perform analytics, deliver content which is tailored to your interests and administer services to our Users, advertisers, publishers, customers and partners.
We also allow third parties to collect information about you through Tracking Technologies.
What are cookies?
Cookies are small text files (composed only of letters and numbers) that a web server places on your computer or mobile device when you visit a webpage. When used, the cookie can help make our Services more user-friendly, for example by remembering your language preferences and settings. You can find more information about cookies at www.allaboutcookies.org.
We store Tracking Technologies when you visit or access our Services (for example when you are visiting our websites) – these are called "First Party Tracking Technologies". In addition, Tracking Technologies are stored by other third parties (for example our analytics service providers, business partners and advertisers) who run content on our Services – these are called "Third Party Tracking Technologies".
Both types of Tracking Technologies may be stored either for the duration of your visit on our Services or for repeat visits.
There are five main types of Tracking Technologies:
|Analytics Cookies||First party Tracking Technology||Performance Tracking Technologies
These Tracking Technologies are used to collect information regarding how you interact with the content on our Services, attribution purposes (for example, the referral URL), etc. We use the information to compile reports, calculate the revenues due to us and, help us improve the Services and to offer personalized products and content.
|Other cookies||First and Third party Tracking Technology||Strictly necessary Tracking Technologies
- these unlisted cookies might be in use on internal sections of the Services, in order to customize and simplify the user experience on the site by remembering choices you made and your log in credentials.
Please note that we do not recognize or respond to automated browser signals regarding Tracking Technologies, including "Do Not Track" requests. However, there are various ways in which you can manage and control your cookie settings. Please remember that, by deleting or blocking cookies, some of the features of the Services may not work properly or as effectively.
Most web browsers will provide you with some general information about cookies, enable you to see what cookies are stored on your device, allow you to delete them all or on an individual basis, and enable you to block or allow cookies for all websites or individually selected websites. You can also normally turn off third party cookies separately. Please note that the settings offered by a browser or device often only apply to that particular browser or device.
Information about cookies is usually found in the "Help" section of the web browser. Below are some links to some commonly used web browsers:
You can turn off certain third party targeting/advertising cookies by visiting the following link: Network Advertising Initiative.