PRIVACY POLICY

GENERAL

This notice together with the General Terms and Conditions available on the site 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. By registering a Player Account with the Website you confirm your acceptance of this Privacy Policy. Please be advised that if you do not accept the terms outlined in this Privacy Policy and choose not to provide the necessary personal information, your access to certain features and services offered on this website may be limited.

Please note that this Privacy Policy constitutes an agreement between you and the Company. It is important to note that this Privacy Policy may be periodically updated and revised. While we will make reasonable efforts to inform you of any significant changes, we recommend that you review this Privacy Policy regularly to stay informed of our current practices regarding the collection, use, and protection of your personal information. Your continued use of the Website and/or its services will constitute your acceptance of the Privacy Policy.

www.NORTHCASINO.com values your integrity and privacy immensely and is committed to managing all your personal data in a transparent, fair and lawful manner. This privacy policy (together with the Terms & Conditions and the Cookie Policy) sets out the basis upon which www.NORTHCASINO.com collects, stores, and uses your personal data when you visit our website, as well as what your rights are, and how the law protects those rights according to the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation)

This website is solely intended for persons over the age of 18, and we do not knowingly collect data relating to persons under such age. If it becomes apparent to us that we have collected personal data relating to persons under the age of 18, due to reasons relating to abuse of our website, we do our best to ensure that such data is handled in accordance with applicable law.

About us

The website https://www.northcasino.com (“Casino”, “Website”, “Company”, “We”, “Us”, “Our”) is owned and operated by Hollycorn N.V., a company registered and established under the laws of Curaçao, with registration number 144359 and registered address at Scharlooweg 39, Willemstad, Curaçao. Hollycorn N.V. is licensed and regulated by the Curaçao Gaming Control Board (license no. OGL/2023/176/0095).

As a data controller, we have a legal obligation under gambling regulations to process personal data from players in order to allow them to participate in games and provide them with ancillary services.

When we mention “Company”, “Group”, “we”, “us” or “our” in this privacy notice, we are referring to the Hollycorn N.V.

We take your privacy seriously. For this reason we have appointed a data protection officer (“DPO”) whose responsibility is to oversee that the company is compliant with its legal obligations in respect of the processing of your personal data, and who is your contact point for any questions relating to this Privacy Policy. Should you have any queries about this policy, including any request to exercise your legal rights, and complaints about violation of your rights please contact our DPO using email dpo@hollycorngaming.com.

INFORMATION WE COLLECT

Information you provide us. It includes any of the information that you provide to us when filling in the forms on our account registration pages, as well as any other data that you further submit via the Website or email. It includes information you provide when you register to use our site, subscribe to our service, make deposits, bets or withdrawals on our site, participate in chat rooms, accept bonuses or other promotions available on our site, any due diligence documentation you share with us, including the source of wealth questionnaire and supporting documentation, and when you report a problem or make a complaint with us. The information you give us may include your name, username, address, date of birth, country of residence and nationality, identification number, e-mail address, and phone number, financial and credit card information, personal description, proof of identification, proof of address, proof of funds and photograph.

Technical information, that includes the Internet protocol (IP) address used to connect your computer to the Internet, 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), Information received from cookies. Please refer to our Cookie Notice for further details on the types of cookies in use.

Gameplay information. Games you played and duration on each game and page, page interaction information

Analytics information. In some cases we may 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.

Information we receive from other sources. This is information we receive about you if you use any of our websites or services operated by the Group.In the event that you use accounts on multiple sites operated by the Group we may collate information about you generated from each site in one data repository. Such data is important to us for statistical purposes, but also particularly relevant within the context of our Anti-Money Laundering and Responsible Gambling responsibilities as arising out of law.

During the course of delivering services to you, we are also working closely with third party data processors, joint or/and independent data controllers (including, for example, business partners, sub-contractors in technical, payment and delivery services as well as for delivery of marketing information (such as CRM Tool Providers, Email Marketing Partners, SMS Providers, Direct Mail Distributors and Outbound Call providers,) advertising networks and affiliate networks, analytics providers, due diligence intelligence companies, search information providers, credit reference agencies). This category includes information we receive from our Publishers, Advertisers and other Partners that we work with to help us deliver ads and personalized content to you and recognize you across browsers and devices. This may include pseudonymous advertiser identifiers that some Advertisers or other third-party ad platforms choose to share with us. Data processors process personal data according to our written instructions and their activities will be limited to those that are needed from them to assist us deliver the service to you.

HOW WE USE YOUR INFORMATION

We process the Personal Information we collect from you in order to deliver our services. In particular, we will use your data for the following purposes:

Information that you give to us:

a) to carry out our obligations arising from the terms and conditions entered into between you and us and to provide you with gaming services that you request from us, to accept your deposits and process your withdrawals, to carry out fraud management processes, to answer to any query or complaint that you may have as well as other ancillary matters related to the main services we are providing to you;

b) provided that you have granted consent to contact you with marketing information from the Group, to provide you with information about our services, bonuses schemes and promotions and information about the products and promotions of related sites operated by the Group or it’s brands;

c) to provide customized advertising on the site based on your interactions with the site or your Usage Data;

d) to notify you about changes to our service;

e) to meet obligations arising from Anti-Money Laundering Legislation and rules and regulations thereunder and all other laws that we may be subject to from time to time.

Information that we collect about you:

a) to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes. Such information will typically be collected through the use of Cookies. For more information on Cookies please refer to our Cookie Notice which also provides guidance on the manner in which Cookies may be disabled;

b) to contact you with marketing information, to provide you with information about services, bonuses schemes and promotions and information about the products and promotions, present or future, offered by the brand you registered or with marketing information about brand partners in case you have expressed your consent to receive such materials;

c) to contact you with marketing information, to provide you with information about services, bonuses schemes and promotions and information about the products and promotions, present or future, offered by the brand you registered or with marketing information about brand partners in case you have expressed your consent to receive such materials;

d) to assess your behavior and patterns through the site which will be used to help build a detailed customer profile on you, on different subject matters, including but not limited to:

• A register of bonus abusers may be created by the company and persons on this list may be excluded from any future promotions or even blocked from using the services of the Company. This includes analysis of other types of fraud and fraudulent behavior.
• We will also screen and monitor your transactions and behavior for reasons of responsible gambling, ensuring that your interaction with us remains fun and entertainment and not dangerous to you. We may assign a Responsible Gambling score to your account based on the information we collect and responsible gambling questionnaire, which may at times be provided to you to fill. As a result of our assessment you may be tagged as a ‘Problem Gambler’ or vulnerable to the risks of gambling addiction.
• As part of our commitment to prevent money laundering and terrorist financing, we may also analyze your personal data and compare it to third party data sources, build an AML profile on you and risk score your account based on the information you have provided to us and the information we have collected about you. We shall also keep a register of all high risk customers from an Anti-Money Laundering perspective.

 Please note that for these purposes we partially use profiling with the end decision performed by humans, however logic behind the profiling and information about it cannot be revealed since it would enable customers to bypass these control mechanisms aimed at the protection of Our business and compliance with legal obligations.

to improve our site 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 site safe and secure;

to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant promotions to you;

to make suggestions and recommendations to you about our products.

We also may collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

Information we receive from other sources: 

We will combine this information with information you give to us and information we collect about you. We will use this information and combined information for the purposes set out above (depending on the types of information we receive). Other sources include third party service providers of age verification tools, identity or address verification services, regulators or entities that keep central databases of problem gamblers, providers of PEP and Sanction searches, and other similar providers who we may contract with from time to time. We may also receive information about you collected from the other sites operated by the Group which helps us deliver a better service to you or to keep away bonus abusers, problem gamblers from our services.

Lawful Basis for Processing of Personal Data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. In regards to processing personal data based on a legal obligation, we refer to the provisions of the Anti-Money Laundering Directive (EU) 2015/849 of the European Parliament and the Council, and the Malta Gaming Act (Cap 583).

MARKETING COMMUNICATION

Unless you have elected not to receive promotional materials, we may use your Personal Information, including your email address and phone number, to send you marketing communications regarding products, services and promotions. This may include information about products and services from our business partners, such as casino game providers.

Whenever you decide to stop receiving such marketing and advertising material, you may opt out of this in your Player Account settings or by contacting our customer support at support@northcasino.com

Additionally, note that by accepting any contest prize or winnings from us, you consent to the use of your name and/or nickname for advertising and promotional purposes without additional compensation, except where prohibited by law.

OBTAINING PERSONAL INFORMATION

We shall not collect any Personal Information about you without your knowledge. We may, however, automatically collect certain data about you where you would have provided such information through the use of our services and through your interactions with us.

We may also lawfully receive certain Personal Information from online vendors and service providers, such as fraud prevention companies. In addition, we retain the right to engage the services of third-party providers to render technical support, so as to process your online transactions and source gaming content.

Please understand that we may be granted access to any information you may provide to such vendors, service providers and third-party e-commerce services. Rest assured that we will use and safeguard any Personal Information so obtained, as set out in this Policy. Any information that you provide will only be disclosed to third parties outside the Company in accordance with this Privacy Policy, and we shall take any necessary steps to ensure that our agreements with third-party service providers always protect your private information.

DATA RECIPIENTS

We may pass information that you have given us to other entities within our group of companies and to our business partners. These companies include our parent companies, their parent companies and all of the subsidiaries of these respective companies, as well as other companies with whom we carry out business and hold necessary agreements. Data processing of your information may be undertaken by the Company or by another entity in our group of companies, which may use a third party to fulfill such data processing needs.

Employees of the Company, more specifically Data Protection Officer, Money Laundering Officer, Payments & Anti-Fraud analysts, Customer Support agents, Customer Retention team members, VIP player managers as well as other selected employees, shall also have access to your Personal Information for the purpose of executing their duties and providing you with assistance.

Our employees who have access to, or are associated with the processing of the player’s personal information, have signed confidentiality agreements to respect the confidential nature of the player’s information pursuant to applicable gaming, data protection and privacy laws.

In order to provide you with an efficient service, we and/or our service providers might require transferring your personal data from one country to another in the European Union (EU) and European Free Trade Association (EFTA) regions and also to some data processors that may be based outside of the European Economic Area (EEA). Therefore, by browsing the Website and communicating electronically with us, you acknowledge and agree to our (or our suppliers or sub-contractors) processing of your data in these countries. We shall always use our best efforts to ensure that your information and data is treated securely and in accordance with this Privacy Policy.

RELEASING DATA TO THIRD PARTIES

We do not sell or rent your personal data to third parties.

We may disclose your personal information if required by law, regulation, or other legal subpoena or warrant. We may also disclose your personal information to a regulatory or law enforcement agency if we believe it to be necessary to protect the legitimate interests of the Company, its customers or any third party.

Personal data will only be disclosed to third parties in the following cases:

a) Where we are required to do so by law;

b) If the Website needs to share data with its payment processors to facilitate payment transactions in accordance with their privacy policies. (In particular, most banking card transactions are processed by Paysafe whose privacy policy applies to such transactions);

c) To comply with our legal and regulatory duties and responsibilities to the relevant licensing and regulatory authorities as well as all duties and responsibilities owed under any other applicable legislation and to any other applicable regulators in other jurisdictions;

d) When the Company believes that disclosure is necessary to protect the Company’s or the player’s safety, or the safety of others, investigate fraud, or respond to a government request;

e) If our marketing service providers require the data to carry out their tasks;

f) To any other third party with the player’s prior consent to do so.

We use third-party data processors to process limited personal data on our behalf. Such service providers support the Website, especially relating to hosting and operating the websites, marketing, analytics, improving the websites, and sending email newsletters. We shall ensure that the transfer of the Personal Data to the recipient is compliant with applicable Data Protection Legislation and that the same obligations are imposed on the processor as is imposed on us under the respective Services Agreement.

Our websites may also include social media features (e.g. “share” or “like” buttons). Such features are provided by third-party social media platforms such as Facebook. Where data is collected this way, its processing is governed by the privacy policy of the respective social media platforms.

In addition to the above, we may also release personal data if we acquire any new businesses. Should the Company undergo any changes to its structure such as a merger, acquisition by another company or a partial acquisition, it is most likely that our customers’ personal data will be included within the sale or transfer. We will, as part of our Policy, inform our players by email prior to affecting such transfer of personal data.

Please note our content may link to third party websites to provide relevant references. We are not responsible for such external content, which may contain separate privacy policies and data processing disclosures.

8. DATA RETENTION

As stated under our Terms and Conditions both you and the Casino can decide to have your Player Account closed at any time. Following closure of your account, we will retain your personal data on record for as long as required by law. This data shall only be used should it be required by competent authorities in cases of enquiries regarding financial and fiscal records, fraud, money laundering or investigations into any other illegal activity.

We may also keep anonymized derivatives of your data to improve our content and marketing communications where no automated decision making is involved.

You are to note that due to anti-money laundering regulations in licensed gaming jurisdictions in the European Union, we are obliged to retain personal data of players submitted during registration and any data passed on during the operative period of a Player Account for a minimum of five years from last player transaction or account closure. Therefore, requests for erasure prior to the lapse of this period cannot be entertained.

9. SECURITY OF YOUR DATA

We hereby acknowledge that in collecting and processing your Personal Information for the purposes of managing your Player Account, we are bound by strict legal provisions on the protection of personal data.

Consequently, we endeavour to protect your personal information and respect your privacy in accordance with best business practices and applicable regulations. Being committed to providing secure services to players, and we will take all reasonable precautions to ensure that all the data that you have submitted to us remains safe.

Right to withdraw consent. In cases where we rely on your consent for the processing of personal data, you have a right to withdraw your consent at any time.

Player Accounts can only be accessed with the player’s unique ID and password. You may also set up two-factor authentication (2FA) as additional protection from unauthorised use of your account. You are responsible for keeping your login information confidential and making sure it cannot be accessed by another person.

10. CONTACTING US

You may always contact us in regards to this Policy should you wish to:

a) Confirm the accuracy of the personal information we have collected about you;

b) Enquire about our use of your personal information;

c) Prohibit future use of your data for direct marketing purposes;

d) Update or rectify any information that you have provided us (in such cases you shall provide any evidence we may reasonably require to effect such changes). Note it is illegal to provide us with false information about you and it is your responsibility to ensure that we are always updated with your correct data.

We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, please contact the DPO at dpo@damacasino.com

In addition, as per Article 77 of the GDPR, you have the right to lodge a complaint related to your data processing to a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of an alleged infringement.

11. COOKIE POLICY

When you visit the Website, our system automatically collects information about your visit, such as your browser, IP address, and the referring website. This collection may be done in conjunction with our platform providers and partners. We may receive from them general demographic or usage data of our Website visitors. We do not use automatically collected information to identify you personally without receiving additional consent.

To collect the information in question we use cookies and similar tracking tools. Cookies are small text files that are stored on your computer or equipment when you visit our web pages. Some of the cookies are essential for the Website to operate; others improve your Website experience and help us deliver a better service. Below are the types of cookies we use and their purposes.

Required cookies: enable the navigation and basic functionality of the websites, e.g., access to member areas of the Website.

Functional cookies: allow us to analyse your website usage and your selections on the website (e.g. your session key, language, or region), so we can save these settings and offer you a more personalised experience.

Advertising cookies: allow us to gauge how effective our content marketing is. These cookies are provided by our partners to track website visits and new player registrations from advertising. We do not share your personal information (such as name or email) to affiliated partners except for site visit data collected directly by such Advertising Cookies. However your site visit data may be linked with other personal information collected through other sources by the providers. The latter external data processing is governed by the privacy notices and policies of these third-party providers.

In addition to the above, we use a number of third party service providers who also set cookies on this Website, in order to deliver the services that they are providing to us. Such services include, but are not limited to, helping us to improve your experience by tracking your activity on the Website, measuring the effectiveness of the Website and the effectiveness of our marketing campaigns.

Most online browsers automatically accept cookies. If you prefer, it is possible to block some or all cookies, or to delete cookies that have already been set by modifying your browser settings. However, we recommend that you do not block or delete your cookies as this may restrict your use of our Website.

12. NETENT GAMES

When you play casino games developed by NetEnt, NetEnt’s Privacy Policy also applies. This policy can be found here.