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These terms and conditions and the documents referred to below (the “Terms”) apply to the use of the current website (the “Website”) and its related or connected services (collectively, the “Service”).
You should carefully review these Terms as they contain important information concerning your rights and obligations concerning the use of the Website and form a binding legal agreement between you – our customer (the “Customer”), and us. By using this Website and/or accessing the Service, you, whether you are a guest or a registered user with an account (“Account”), agree to be bound by these Terms, together with any amendments, which may be published from time to time. If you do not accept these Terms, you should refrain from accessing the Service and using the Website.
2. General Terms
We reserve the right to revise and amend the Terms (including any documents referred to and linked to below) at any time. You should visit this page periodically to review the Terms and Conditions. Amendments will be binding and effective immediately upon publication on this Website. If you object to any such changes, you must immediately stop using the Service. Your continued use of the Website following such publication will indicate your agreement to be bound by the Terms as amended. Any bets not settled prior to the changed Terms taking effect will be subject to the pre-existing Terms.
You acknowledge that at all times when accessing the Website and using the Service:
3.1. You are is over 18, or the legal age at which gambling, or gaming activities are allowed under the law or jurisdiction that applies to you. We reserve the right to request proof of age documents from you at any time.
3.2. You are of legal capacity and can enter into a binding legal agreement with us. You must not access the Website or utilize the Service if you are not of legal capacity.
3.3. You are a resident in a jurisdiction that allows gambling. You are not a resident of any country in which access to online gambling to its residents or to any person within such country is prohibited. It is your sole responsibility to ensure that your use of the service is legal.
3.4. You may not use a VPN, proxy or similar services or devices that mask or manipulate the identification of your real location.
3.5. You are the authorized user of the payment method you use.
3.6. You must make all payments to us in good faith and not attempt to reverse a payment made or take any action which will cause such payment to be reversed by a third party.
3.7. When placing bets you may lose some or all of your money deposited to the Service in accordance with these Terms and you will be fully responsible for that loss.
3.8. When placing bets you must not use any information obtained in breach of any legislation in force in the country in which you were when the bet was placed.
3.9. You are not acting on behalf of another party or for any commercial purposes, but solely on your own behalf as a private individual in a personal capacity.
3.10. You must not either attempt to manipulate any market or element within the Service in bad faith nor in a manner that adversely affects the integrity of the Service or us.
3.11. You must generally act in good faith in relation to us of the Service at all times and for all bets made using the Service.
3.12. You, or, if applicable, your employees, employers, agents, or family members, are not registered as an Affiliate in our Affiliate program.
4.1. You must not use the Service:
4.1.1. If you are under the age of 18 years (or below the age of majority as stipulated in the laws of the jurisdiction applicable to you) or if you are not legally able to enter into a binding legal agreement with us or you acting as an agent for, or otherwise on behalf, of a person under 18 years (or below the age of majority as stipulated in the laws of the jurisdiction applicable to you);
4.1.2. If you reside in a country in which access to online gambling to its residents or to any person within such country is prohibited.
4.1.3. If you are a resident of one of the following countries, or accessing the Website from one of the following countries:
4.1.4. To collect nicknames, e-mail addresses and/or other information of other Customers by any means (for example, by sending spam, other types of unsolicited emails or the unauthorised framing of, or linking to, the Service);
4.1.5. to disrupt or unduly affect or influence the activities of other Customers or the operation of the Service generally;
4.1.6. to promote unsolicited commercial advertisements, affiliate links, and other forms of solicitation which may be removed from the Service without notice;
4.1.7. in any way which, in our reasonable opinion, could be considered as an attempt to: (i) cheat the Service or another Customer using the Service; or (ii) collude with any other Customer using the Service in order to obtain a dishonest advantage;
4.1.8. to scrape our odds or violate any of our Intellectual Property Rights; or
4.1.9. for any unlawful activity whatsoever.
4.2. You cannot sell or transfer your account to third parties, nor can you acquire a player account from a third party.
4.3. You may not, in any manner, transfer funds between player accounts.
4.4. We may immediately terminate your Account upon written notice to you if you use the Service for unauthorised purposes. We may also take legal action against you for doing so in certain circumstances.
4.5. Employees of Company, its licensees, distributors, wholesalers, subsidiaries, advertising, promotional or other agencies, media partners, contractors, retailers and members of the immediate families of each are NOT allowed to use the Service for real money without prior consent from the Company Director or CEO. Should such activity be discovered, the account(s) will be immediately terminated and all bonuses/winnings will be forfeited.
You agree that at all times when using the Service:
5.1. We reserve the right to refuse to accept a registration application from any applicant at our sole discretion and without any obligation to communicate a specific reason.
5.2. Before using the Service, you must personally complete the registration form and read and accept these Terms. In order to start betting on the Service or withdraw your winnings, we may require you to become a verified Customer which includes passing certain checks. You may be required to provide a valid proof of identification and any other document as it may be deemed necessary. This includes but is not limited to, a picture ID (copy of passport, driver’s licence or national ID card) and a recent utility bill listing your name and address as proof of residence. We reserve the right to suspend wagering or restrict Account options on any Account until the required information is received. This procedure is done in accordance with the applicable gaming regulation and the anti-money laundering legal requirements. Additionally, you will need to fund your Service Account using the payment methods set out on the payment section of our Website.
5.3. You have to provide accurate contact information, inclusive of a valid email address (“Registered Email Address”), and update such information in the future to keep it accurate. It is your responsibility to keep your contact details up to date on your Account. Failure to do so may result in you failing to receive important Account related notifications and information from us, including changes we make to these Terms. We identify and communicate with our Customers via their Registered Email Address. It is the responsibility of the Customer to maintain an active and unique email account, to provide us with the correct email address and to advise Company of any changes in their email address. Each Customer is wholly responsible for maintaining the security of his Registered Email Address to prevent the use of his Registered Email Address by any third party. Company shall not be responsible for any damages or losses deemed or alleged to have resulted from communications between Company and the Customer using the Registered Email Address. Any Customer not having an email address reachable by Company will have his Account suspended until such an address is provided to us. We will immediately suspend your Account upon written notice to you to this effect if you intentionally provide false or inaccurate personal information. We may also take legal action against you for doing so in certain circumstances and/or contact the relevant authorities who may also take action against you.
5.4. You are only allowed to register one Account with the Service. Accounts are subject to immediate closure if it is found that you have multiple Accounts registered with us. This includes the use of representatives, relatives, associates, affiliates, related parties, connected persons and/or third parties operating on your behalf.
5.5. In order to ensure your financial worthiness and to confirm your identity, we may ask you to provide us with additional personal information, such as your name and surname, or use any third-party information providers we consider necessary. Should any additional personal information be obtained via third-party sources, we will inform you about the data obtained.
5.6. You must keep your password for the Service confidential. Provided that the Account information requested has been correctly supplied, we are entitled to assume that bets, deposits and withdrawals have been made by you. We advise you to change your password on a regular basis and never disclose it to any third party. It is your responsibility to protect your password and any failure to do so shall be at your sole risk and expense. You may log out of the Service at the end of each session. If you believe any of your Account information is being misused by a third party, or your Account has been hacked into, or your password has been discovered by a third party, you must notify us immediately. You must notify us if your Registered Email Address has been hacked into, we may, however, require you to provide additional information/ documentation so that we can verify your identity. We will immediately suspend your Account once we are aware of such an incident. In the meantime you are responsible for all activity on your Account including third party access, regardless of whether or not their access was authorised by you.
5.7. You must not at any time transmit any content or other information on the Service to another Customer or any other party by way of a screen capture (or other similar method), nor display any such information or content in a frame or in any other manner that is different from how it would appear if such Customer or third party had typed the URL for the Service into the browser line.
5.8. When registering, you will receive possibility to use all currencies available on the website. Those will be the currencies of your deposits, withdrawals and bets placed and matched into the Service as set out in these Terms. Some payment methods do not process in all currencies. In such cases a processing currency will be displayed, along with a conversion calculator available on the page.
5.9. We are under no obligation to open an Account for you and our website sign-up page is merely an invitation to treat. It is entirely within our sole discretion whether or not to proceed with the opening of an Account for you and, should we refuse to open an Account for you, we are under no obligation to provide you with a reason for the refusal.
5.10. Upon receipt of your application, we may be in touch to request further information and/ or documentation from you in order for us to comply with our regulatory and legal obligations.
6.1. Accounts could use several currencies, in this case all Account balances and transactions appear in the currency used for the transaction.
6.2. We do not give credit for the use of the Service.
6.3. We may close or suspend an Account if you are not or we reasonably believe that you are not complying with these Terms, or to ensure the integrity or fairness of the Service or if we have other reasonable grounds to do so. We may not always be able to give you prior notice. If we close or suspend your Account due to you not complying with these Terms, we may cancel and/or void any of your bets and withhold any money in your account (including the deposit).
6.4. We reserve the right to close or suspend any Account without prior notice and return all funds. Contractual obligations already matured will however be honoured.
6.5. We reserve the right to refuse, restrict, cancel or limit any wager at any time for whatever reason, including any bet perceived to be placed in a fraudulent manner in order to circumvent our betting limits and/ or our system regulations.
6.6. If any amount is mistakenly credited to your Account it remains our property and when we become aware of any such mistake, we shall notify you and the amount will be withdrawn from your Account.
6.7. If, for any reason, your Account goes overdrawn, you shall be in debt to us for the amount overdrawn.
6.8. You must inform us as soon as you become aware of any errors with respect to your Account.
6.9. Please remember that betting is purely for entertainment and pleasure and you should stop as soon as it stops being fun. Absolutely do not bet anything you can’t afford to lose. If you feel that you may have lost control of your gambling, we offer a self-exclusion option. Just send a message to our Customer Support Department using your Registered Email Address that you wish to SELF-EXCLUDE and this request will take effect within 24 hours from the moment of its receipt. In this case your account will be disabled until your further notice, and you won’t be able to login to it.
6.10. You cannot transfer, sell, or pledge Your Account to another person. This prohibition includes the transfer of any assets of value of any kind, including but not limited to ownership of accounts, winnings, deposits, bets, rights and/or claims in connection with these assets, legal, commercial or otherwise. The prohibition on said transfers also includes however is not limited to the encumbrance, pledging, assigning, usufruct, trading, brokering, hypothecation and/or gifting in cooperation with a fiduciary or any other third party, company, natural or legal individual, foundation and/or association in any way shape or form
6.11. Should you wish to close your account with us, please send an email from your Registered Email Address to our Customer Support Department via the links on the Website.
7.1. We will charge you a fee of €5 (or currency equivalent) per calendar month (Inactive Account Fee) if:
you have not logged into your Account or logged out from your Account, or used the Service, or made any bet in any section of the Service for twelve consecutive months or more (Account Activity);
and your Account is in credit.
7.2. You will be notified that we will start charging you the fees on the eleventh month of inactivity and you will always have the option to log in and withdraw your funds.
7.3. The Inactive Account Fee will be withdrawn from your Account on a monthly basis to the extent that your Account remains in credit and only for the period during which there remains no Account Activity after the initial twelve month period has passed. If the Inactive Account Fee is due to be withdrawn from your Account and the balance of your Account is less than €5 (or equivalent currency), the Inactive Account Fee shall comprise the remaining funds in your Account.
8.1. All deposits should be made from an account or payment system or credit card that is registered in your own name, and any deposits made in any other currency will be converted using the daily exchange rate obtained from oanda.com, or at our own bank’s or our payment processor’s prevailing rate of exchange following which your Account will be deposited accordingly. Note that some payment systems may apply additional currency exchange fees which will be deducted from the sum of your deposit.
8.2. Fees and charges may apply to customer deposits and withdrawals, which can be found on the Website. In most cases we absorb transaction fees for deposits to your playgram.justw.in Account. You are responsible for your own bank charges that you may incur due to depositing funds with us.
8.3. Company is not a financial institution and uses a third party electronic payment processors to process credit and debit card deposits; they are not processed directly by us. If you deposit funds by either a credit card or a debit card, your Account will only be credited if we receive an approval and authorisation code from the payment issuing institution. If your card issuer gives no such authorisation, your Account will not be credited with those funds.
8.4. You agree to fully pay any and all payments and charges due to us or to payment providers in connection with your use of the Service. You further agree not to make any charge-backs or renounce or cancel or otherwise reverse any of your deposits, and in any such event you will refund and compensate us for such unpaid deposits including any expenses incurred by us in the process of collecting your deposit, and you agree that any winnings from wagers utilising those charged back funds will be forfeited. You acknowledge and agree that your player account is not a bank account and is therefore not guaranteed, insured or otherwise protected by any deposit or banking insurance system or by any other similar insurance system of any other jurisdiction, including but not limited to your local jurisdiction. Furthermore, the player account does not bear interest on any of the funds held in it.
8.5. If you decide to accept any of our promotional or bonus offer by entering a bonus code during deposit, you agree to the Terms of Bonuses and terms of each specific bonus.
8.6. Funds originating from criminal and/or illegal and/or unauthorized activities must not be deposited with us.
8.7. If you deposit using your credit card, it is recommended that you retain a copy of Transaction Records and a copy of these Terms.
8.8. Internet Gambling may be illegal in the jurisdiction in which you are located; if so, you are not authorized to use your payment card to deposit on this site. It is your responsibility to know the laws concerning online gambling in your country of domicile.
9.1. You may withdraw any unutilized and cleared funds held in your player account by submitting a withdrawal request in accordance with our withdrawal conditions. The minimum withdrawal amount per transaction is € 10 (or equivalent in other currency) with the exception of an account closure in which case you may withdraw the full balance.
9.2. There are no withdrawal commissions if you roll over (wager) the deposit at least 1 time. Otherwise we are entitled to deduct a 8% fee with minimum sum of 4 euro (or equivalent in your account currency) in order to combat money laundering.
9.3. We reserve the right to request photo ID, address confirmation or perform additional verification procedures (request your selfie, arrange a verification call etc.) for the purpose of identity verification prior to granting any withdrawals from your Account. We also reserve our rights to perform identity verification at any time during the lifetime of your relationship with us.
9.4. All withdrawals must be made to the original debit, credit card, bank account, method of payment used to make the payment to your Account. We may, and always at our own discretion, allow you to withdraw to a payment method from which your original deposit did not originate. This will always be subject to additional security checks.
9.5. Should you wish to withdraw funds but your account is either inaccessible, dormant, locked or closed, please contact our Customer Service Department.
9.6 The maximum withdrawal amount per month is € 500,000.
9.7. Please note that we cannot guarantee successful processing of withdrawals or refunds in the event if you breach the Restricted use policy stated in Clauses 3.3 and 4.
10.1. You are fully responsible for paying all monies owed to us. You must make all payments to us in good faith and not attempt to reverse a payment made or take any action which will cause such payment to be reversed by a third party in order to avoid a liability legitimately incurred. You will reimburse us for any charge-backs, denial or reversal of payment you make and any loss suffered by us as a consequence thereof. We reserve the right to also impose an administration fee of €50, or currency equivalent per charge-back, denial or reversal of payment you make.
10.2. We reserve the right to use third party electronic payment processors and or merchant banks to process payments made by you and you agree to be bound by their terms and conditions providing they are made aware to you and those terms do not conflict with these Terms.
10.3. All transactions made on our site might be checked to prevent money laundering or terrorism financing activity. Suspicious transactions will be reported to the relevant authority.
11.1. In the event of an error or malfunction of our system or processes, all bets are rendered void. You are under an obligation to inform us immediately as soon as you become aware of any error with the Service. In the event of communication or system errors or bugs or viruses occurring in connection with the Service and/or payments made to you as a result of a defect or error in the Service, we will not be liable to you or to any third party for any direct or indirect costs, expenses, losses or claims arising or resulting from such errors, and we reserve the right to void all games/bets in question and take any other action to correct such errors.
11.2. We make every effort to ensure that we do not make errors in posting bookmaker lines. However, if as a result of human error or system problems a bet is accepted at an odd that is: materially different from those available in the general market at the time the bet was made; or clearly incorrect given the chance of the event occurring at the time the bet was made then we reserve the right to cancel or void that wager, or to cancel or void a wager made after an event has started.
11.3. We have the right to recover from you any amount overpaid and to adjust your Account to rectify any mistake. An example of such a mistake might be where a price is incorrect or where we enter a result of an event incorrectly. If there are insufficient funds in your Account, we may demand that you pay us the relevant outstanding amount relating to any erroneous bets or wagers. Accordingly, we reserve the right to cancel, reduce or delete any pending plays, whether placed with funds resulting from the error or not.
12.1. The winner of an event will be determined on the date of the event’s settlement, and we will not recognize protested or overturned decisions for wagering purposes.
12.2. All results posted shall be final after 72 hours and no queries will be entertained after that period of time. Within 72 hours after results are posted, we will only reset/correct the results due to human error, system error or mistakes made by the referring results source.
12.3. If a match result is overturned for any reason by the governing body of the match within the payout period then all money will be refunded.
12.4. If a draw occurs in a game where a draw option is offered all stakes on a team win or lose will be lost. If a draw option is not offered then everyone receives a refund in the outcome of a draw on the match. And if a draw option has not been made available, then extra time will count, if played.
12.5. If a result cannot be validated by us, for instance if the feed broadcasting the event is interrupted (and cannot be verified by another source) then at our election, the wagers on that event will be deemed invalid and wagers refunded.
12.6. Minimum and maximum wager amounts on all events will be determined by us and are subject to change without prior written notice. We also reserve the right to adjust limits on individual Accounts as well.
12.7. Customers are solely responsible for their own Account transactions. Once a transaction is complete, it cannot be changed. We do not take responsibility for missing or duplicate wagers made by the Customer and will not entertain discrepancy requests because a play is missing or duplicated. Customers may review their transactions in the My Account section of the site after each session to ensure all requested wagers were accepted.
12.8. A matchup will have action as long as the two teams are correct, and regardless of the League header in which it is placed on our Website.
12.9. The start dates and times displayed on the Website for eSport matches are an indication only and are not guaranteed to be correct. If a match is suspended or postponed, and not resumed within 72 hours from the actual scheduled start time, the match will have no action and wagers will be refunded. The exception being any wager on whether a team/player advances in a tournament, or wins the tournament, will have action regardless of a suspended or postponed match.
12.10. If an event is posted by us with an incorrect date, all wagers have action based on the date announced by the governing body.
12.11. If a team is using stand-ins, the result is still valid as it was the team’s choice to use the stand-ins.
12.12. Company reserves the right to remove events, markets and any other products from the Website.
12.13. In-depth explanation of our sports betting rules is on the separate page: SPORTS BETTING RULES
13.1. All communications and notices to be given under these Terms by you to us shall be sent using a Customer Support form on the Website.
13.2. All communications and notices to be given under these Terms by us to you shall, unless otherwise specified in these Terms, be either posted on the Website and/or sent to the Registered Email Address we hold on our system for the relevant Customer. The method of such communication shall be in our sole and exclusive discretion.
13.3. All communications and notices to be given under these Terms by either you or us shall be in writing in the English language and must be given to and from the Registered Email Address in your Account.
13.4. From time to time, we may contact you by email for the purpose of offering you information about betting, unique promotional offerings, and other information from playgram.justw.in. You agree to receive such emails when you agree to these Terms when registering at the Website. You can choose to opt out of receiving such promotional offerings from us at any time by submitting a request to the Customer Support.
We cannot be held liable for any failure or delay in providing the Service due to an event of Force Majeure which could reasonably be considered to be outside our control despite our execution of reasonable preventative measures such as: an act of God; trade or labour dispute; power cut; act, failure or omission of any government or authority; obstruction or failure of telecommunication services; or any other delay or failure caused by a third party, and we will not be liable for any resulting loss or damage that you may suffer. In such an event, we reserve the right to cancel or suspend the Service without incurring any liability.
15.1. TO THE EXTENT PERMITTED BY APPLICABLE LAW, WE WILL NOT COMPENSATE YOU FOR ANY REASONABLY FORESEEABLE LOSS OR DAMAGE (EITHER DIRECT OR INDIRECT) YOU MAY SUFFER IF WE FAIL TO CARRY OUT OUR OBLIGATIONS UNDER THESE TERMS UNLESS WE BREACH ANY DUTIES IMPOSED ON US BY LAW (INCLUDING IF WE CAUSE DEATH OR PERSONAL INJURY BY OUR NEGLIGENCE) IN WHICH CASE WE SHALL NOT BE LIABLE TO YOU IF THAT FAILURE IS ATTRIBUTED TO: (I) YOUR OWN FAULT; (II) A THIRD PARTY UNCONNECTED WITH OUR PERFORMANCE OF THESE TERMS (FOR INSTANCE PROBLEMS DUE TO COMMUNICATIONS NETWORK PERFORMANCE, CONGESTION, AND CONNECTIVITY OR THE PERFORMANCE OF YOUR COMPUTER EQUIPMENT); OR (III) ANY OTHER EVENTS WHICH NEITHER WE NOR OUR SUPPLIERS COULD HAVE FORESEEN OR FORESTALLED EVEN IF WE OR THEY HAD TAKEN REASONABLE CARE. AS THIS SERVICE IS FOR CONSUMER USE ONLY WE WILL NOT BE LIABLE FOR ANY BUSINESS LOSSES OF ANY KIND.
15.2. IN THE EVENT THAT WE ARE HELD LIABLE FOR ANY EVENT UNDER THESE TERMS, OUR TOTAL AGGREGATE LIABILITY TO YOU UNDER OR IN CONNECTION WITH THESE TERMS SHALL NOT EXCEED (A) THE VALUE OF THE BETS AND OR WAGERS YOU PLACED VIA YOUR ACCOUNT IN RESPECT OF THE RELEVANT BET/WAGER OR PRODUCT THAT GAVE RISE TO THE RELEVANT LIABILITY, OR (B) EUR €500 IN AGGREGATE, WHICHEVER IS LOWER.
15.3. WE STRONGLY RECOMMEND THAT YOU (I) TAKE CARE TO VERIFY THE SUITABILITY AND COMPATIBILITY OF THE SERVICE WITH YOUR OWN COMPUTER EQUIPMENT PRIOR TO USE; AND (II) TAKE REASONABLE PRECAUTIONS TO PROTECT YOURSELF AGAINST HARMFUL PROGRAMS OR DEVICES INCLUDING THROUGH INSTALLATION OF ANTI-VIRUS SOFTWARE.
16.1. If we suspect that you are or receive notification that you are currently under 18 years or were under 18 years (or below the age of majority as stipulated in the laws of the jurisdiction applicable to you) when you placed any bets through the Service your Account will be suspended (locked) to prevent you placing any further bets or making any withdrawals from your Account. We will then investigate the matter, including whether you have been betting as an agent for, or otherwise on behalf, of a person under 18 years (or below the age of majority as stipulated in the laws of the jurisdiction applicable to you). If having found that you: (a) are currently; (b) were under 18 years or below the majority age which applies to you at the relevant time; or (c) have been betting as an agent for or at the behest of a person under 18 years or below the majority age which applies:
all winnings currently or due to be credited to your Account will be retained;
all winnings gained from betting through the Service whilst under age must be paid to us on demand (if you fail to comply with this provision we will seek to recover all costs associated with recovery of such sums); and/or
any monies deposited in your Account which are not winnings will be returned to you OR retained until you turn 18 years old at our sole discretion. We reserve the right to deduct payment transaction fees from the amount to return, including transaction fees for deposits to your playgram.justw.in account which we covered.
16.2. This condition also applies to you if you are over the age of 18 years but you are placing your bets within a jurisdiction which specifies a higher age than 18 years for legal betting and you are below that legal minimum age in that jurisdiction.
16.3. In the event we suspect you are in breach of the provisions of this Clause or are attempting to rely on them for a fraudulent purpose, we reserve the right to take any action necessary in order to investigate the matter, including informing the relevant law enforcement agencies.
We will seek criminal and contractual sanctions against any Customer involved in fraud, dishonesty or criminal acts. We will withhold payment to any Customer where any of these are suspected. The Customer shall indemnify and shall be liable to pay to us on demand all costs, charges or losses sustained or incurred by us (including any direct, indirect or consequential losses, loss of profit, loss of business and loss of reputation) arising directly or indirectly from the Customer’s fraud, dishonesty or criminal act.
17.1. We reserve the right to confiscate any funds if any fraudulent activity or bonus abuse attempt is detected.
17.2. Using fraudulent game patterns to circumvent wagering of bonuses or take advantage of a certain game features is strictly forbidden and all winnings currently or due to be credited to your account will be retained.
17.2.1. Fraudulent game pattern can be defined as any pattern of bets that is unfair and it’s sole purpose is to circumvent the terms set by the casino and help you get unfair edge against the house. Fraudulent game pattern includes, but is not limited to:
– delaying game rounds in any game, including free spins and bonus features, to a later time when you have no wagering requirements;
– leaving large bets on the table, for example in blackjack, and returning to the game after bonus wagering has been completed;
– playing games with bonus money to build up in-game value, lose the bonus funds, and then cash out on the built-up value during real-money play;
– using strategies that take advantage of any software bug or failure.
18.1. Any unauthorised use of our name and logo may result in legal action being taken against you.
18.2. As between us and you, we are the sole owners of the rights in and to the Service, our technology, software and business systems (the “Systems”) as well as our odds.
you must not use your personal profile for your own commercial gain (such as selling your status update to an advertiser); and
when selecting a nickname for your Account we reserve the right to remove or reclaim it if we believe it appropriate.
18.3. You may not use our URL, trademarks, trade names and/or trade dress, logos (“Marks”) and/or our odds in connection with any product or service that is not ours, that in any manner is likely to cause confusion among Customers or in the public or that in any manner disparages us.
18.4. Except as expressly provided in these Terms, we and our licensors do not grant you any express or implied rights, license, title or interest in or to the Systems or the Marks and all such rights, license, title and interest specifically retained by us and our licensors. You agree not to use any automatic or manual device to monitor or copy web pages or content within the Service. Any unauthorized use or reproduction may result in legal action being taken against you.
19.1. Subject to these Terms and your compliance with them, we grant to you a non-exclusive, limited, non transferable and non sub-licensable license to access and use the Service for your personal non-commercial purposes only. Our license to you terminates if our agreement with you under these Terms ends.
19.2. Save in respect of your own content, you may not under any circumstances modify, publish, transmit, transfer, sell, reproduce, upload, post, distribute, perform, display, create derivative works from, or in any other manner exploit, the Service and/or any of the content thereon or the software contained therein, except as we expressly permit in these Terms or otherwise on the Website. No information or content on the Service or made available to you in connection with the Service may be modified or altered, merged with other data or published in any form including for example screen or database scraping and any other activity intended to collect, store, reorganise or manipulate such information or content.
19.3. Any non-compliance by you with this Clause may also be a violation of our or third parties’ intellectual property and other proprietary rights which may subject you to civil liability and/or criminal prosecution.
20.1. For your protection and protection of all our Customers, the posting of any content on the Service, as well as conduct in connection therewith and/or the Service, which is in any way unlawful, inappropriate or undesirable is strictly prohibited (“Prohibited Behaviour”).
20.2. If you engage in Prohibited Behaviour, or we determine in our sole discretion that you are engaging in Prohibited Behaviour, your Account and/or your access to or use of the Service may be terminated immediately without notice to you. Legal action may be taken against you by another Customer, other third party, enforcement authorities and/or us with respect to you having engaged in Prohibited Behaviour.
20.3. Prohibited Behaviour includes, but is not limited to, accessing or using the Service to:
The above list of Prohibited Behaviour is not exhaustive and may be modified by us at any time or from time to time. We reserve the right to investigate and to take all such actions as we in our sole discretion deem appropriate or necessary under the circumstances, including without limitation deleting the Customer’s posting(s) from the Service and/or terminating their Account, and take any action against any Customer or third party who directly or indirectly in, or knowingly permits any third party to directly or indirectly engage in Prohibited Behaviour, with or without notice to such Customer or third party.
The Service may contain links to third party websites that are not maintained by, or related to, us, and over which we have no control. Links to such websites are provided solely as a convenience to Customers, and are in no way investigated, monitored or checked for accuracy or completeness by us. Links to such websites do not imply any endorsement by us of, and/or any affiliation with, the linked websites or their content or their owner(s). We have no control over or responsibility for the availability nor their accuracy, completeness, accessibility and usefulness. Accordingly when accessing such websites we recommend that you should take the usual precautions when visiting a new website including reviewing their privacy policy and terms of use.
22.1. If you have any concerns or questions regarding these Terms you should contact our Customer Service Department via the links on the Website and use your Registered Email Address in all communication with us.
22.2. NOTWITHSTANDING THE FOREGOING, WE TAKE NO LIABILITY WHATSOEVER TO YOU OR TO ANY THIRD PARTY WHEN RESPONDING TO ANY COMPLAINT THAT WE RECEIVED OR TOOK ACTION IN CONNECTION THEREWITH.
22.3. If a Customer is not satisfied with how a bet has been settled then the Customer should provide details of their grievance to our Customer Service Department. We shall use our reasonable endeavours to respond to queries of this nature within a few days (and in any event we intend to respond to all such queries within 28 days of receipt).
22.4. Disputes must be lodged within three (3) days from the date the wager in question has been decided. No claims will be honoured after this period. The Customer is solely responsible for their Account transactions.
22.5. In the event of a dispute arising between you and us our Customer Service Department will attempt to reach an agreed solution. Should our Customer Service Department be unable to reach an agreed solution with you, the matter will be escalated to our management.
22.6. Should all efforts to resolve a dispute to the Customer’s satisfaction have failed, the Customer has the right to lodge a complaint with our licensing body Gaming Services Provider N.V.
Neither these Terms nor any of the rights or obligations hereunder may be assigned by you without the prior written consent of us, which consent will not be unreasonably withheld. We may, without your consent, assign all or any portion of our rights and obligations hereunder to any third party provided such third party is able to provide a service of substantially similar quality to the Service by posting written notice to this effect on the Service.
In the event that any provision of these Terms is deemed by any competent authority to be unenforceable or invalid, the relevant provision shall be modified to allow it to be enforced in line with the intention of the original text to the fullest extent permitted by applicable law. The validity and enforceability of the remaining provisions of these Terms shall not be affected.
Without limiting our other remedies, we may suspend or terminate your Account and refuse to continue to provide you with the Service, in either case without giving you prior notice, if, in our reasonable opinion, you breach any material term of these Terms. Notice of any such action taken will, however, be promptly provided to you.
26.1. Term of agreement. These Terms shall remain in full force and effect while you access or use the Service or are a Customer or visitor of the Website. These Terms will survive the termination of your Account for any reason.
26.2. Gender. Words importing the singular number shall include the plural and vice versa, words importing the masculine gender shall include the feminine and neuter genders and vice versa and words importing persons shall include individuals, partnerships, associations, trusts, unincorporated organisations and corporations.
26.3. Waiver. No waiver by us, whether by conduct or otherwise, of a breach or threatened breach by you of any term or condition of these Terms shall be effective against, or binding upon, us unless made in writing and duly signed by us, and, unless otherwise provided in the written waiver, shall be limited to the specific breach waived. The failure of us to enforce at any time any term or condition of these Terms shall not be construed to be a waiver of such provision or of the right of us to enforce such provision at any other time.
26.4. Acknowledgement. By hereafter accessing or using the Service, you acknowledge having read, understood and agreed to each and every paragraph of these Terms. As a result, you hereby irrevocably waive any future argument, claim, demand or proceeding to the contrary of anything contained in these Terms.
26.5. Language. In the event of there being a discrepancy between the English language version of these rules and any other language version, the English language version will be deemed to be correct.
26.6. Governing Law. These Terms are governed by the law in force in Curaçao.
26.7. Entire agreement. These Terms constitute the entire agreement between you and us with respect to your access to and use of the Service, and supersedes all other prior agreements and communications, whether oral or written with respect to the subject matter hereof.
For Deposits and Withdrawals.
AML Anti-Money-Laundering policy of Playgram.io.
Objective of the AML Policy:
We seek to offer the highest security to all of our users and customers on playgram.justw.in for that a three step account verification is done in order to insure the identity of our customers. The reason behind this is to prove that the details of
the person registered are correct and the deposit methods used are not stolen or being used by someone else, which is to create the general framework for the fight against money laundering. We also take into accord that depending on the nationality and origin, the way of payment and for withdrawing different safety measurements must be taken.
playgram.justw.in also puts reasonable measures in place to control and limit ML risk, including dedicating the appropriate means.
playgram.justw.in is committed to high standards of anti-money laundering (AML) according to the EU guidelines, compliance and requires management & employees to enforce these standards in preventing the use of its services for money laundering purposes.
The AML program of playgram.justw.in is designed to be compliant with :
EU : “Directive 2015/849 of the European Parliament and of The Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering”
EU : “Regulation 2015/847 on information accompanying transfers of funds”
EU : Various regulations imposing sanctions or restrictive measures against persons and embargo on certain goods and technology, including all dual-use goods
BE : “Law of 18 September 2017 on the prevention of money laundering limitation of the use of cash
Definition of money laundering
Money Laundering is understood as:
The conversion or transfer of property, especially money, knowing that such property is derived from criminal activity or from taking part in such activity, for the purpose of concealing or disguising the illegal origin of the property or of helping any person who is involved in the commission of such an activity to evade the legal consequences of that person’s or companies action;
The concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of, property, knowing that such property is derived from criminal activity or from an act of participation in such an activity;
The acquisition, possession or use of property, knowing, at the time of receipt, that such property was derived from criminal activity or from assisting in such an activity;
Participation in, association to commit, attempts to commit and aiding, abetting, facilitating and counselling the commission of any of the actions referred to in points before.
Money laundering shall be regarded as such even when the activities which generated the property to be laundered were carried out in the territory of another Member State or in that of a third country.
Organization of the AML for playgram.justw.in:
In accordance with the AML legislation, playgram.justw.in has appointed the “highest level” for the prevention of ML: The full management of MIBS NV are in charge.
Furthermore, an AMLCO (Anti Money Laundering Compliance Officer) is in charge of the enforcement of the AML policy and procedures within the System.
The AMLCO is placed under the direct responsibility of the general Management:
AML policy changes and implementation requirements:
Each major change of playgram.justw.in website AML policy is subject to be approval by the general management of MIBS NV and the Anti money laundering compliance officer.
Three step Verification:
Step one verification:
Step one verification must be done by every user and customer to withdraw. Regarding of the choice of payment, the amount of payment, the amount of withdraw, the choice of withdraw and nationality of the user/customer step one verification must be done first. Step one verification is a document that must be filled out by the user/customer himself. Following
information’s must be filled in: first name, second name, date of birth, country of usual residence, gender and full address.
Step two verification:
Step two verification must be done by every user which deposit over 2000 EUR (two thousand Euro) or withdraws any amount. Until step two verification is done the withdraw, tip or deposit will be hold. Step to verification will lead the user or customer to a subpage where he must send in his ID. The user/customer must make a picture of his ID. While a paperclip with a six-digit random generated number is next to his ID: Only an official ID may be used for ID verification, depending on the country the variety of accepted IDs may be different.
There will also be an electronic check if the filled in Data from the step one verification is correct. The electronic check will check via two different databanks to insure the giveninformation’s matches with the filled document and the name from the ID:
If the electronic test fails or is not possible the user/customer is required to send in a conformation of his current resident. A certificate of registration by the government or a similar document is required.
Step three verification:
Step three verification must be done by every user which deposit over 5000$ (five thousand Dollar) or withdraws over 5000$ (five thousand Dollar) or sends another user over 3000$ (three thousand Dollar) Until step three verification is done the withdraw, tip or deposit will be hold. For step 3 a user/customer will be asked for a source of wealth.
Customer identification and verification (KYC)
The formal identification of customers on entry into commercial relations is a vital element, both for the regulations relating to money laundering and for the KYC policy.
This identification relies on the following fundamental principles:
A copy of your passport, ID card or driving license, each shown alongside a handwritten note mentioning six random generated numbers. Also, a second picture with the face of the user/customer is required. The user/customer may blur out every information, besides date of birth, nationality, gender, first name, second name and the picture. To secure their privacy.
Please note that all four corners of the ID have to be visible in the same image and all details has to be clearly readable besides the named above. We might ask for all details if necessary.
An employee may do additional checks if necessary, based on the situation.
Proof of Address:
Proof of address will be done via to different electronic checks, which use two different databases. If an electronic test fails, the user/customer has the option to make a manually proof.
A recent utility bill sent to your registered address, issued within the last 3 months or an official document made by the government that proofs your state of residence.
To make the approval process as speedy as possible, please make sure the document is sent with a clear resolution where all four corners of the document is visible, and all text is readable.
For example: An electricity bill, water bill, bank statement or any governmental post addressed to you.
An employee may do additional checks if necessary, based on the situation.
Source of funds
If a player deposits over a five thousand euro there is a process of understandings the source of wealth (SOW)
Examples of SOW are:
Ownership of business
Employment
Inheritance
Investment
Family
It is critical that the origin and legitimacy of that wealth is clearly understood. If this is not possible an employee may ask for an additional document or prove.
The account will be frozen if the same user deposits either this amount in one go or multiple transactions which amount to this. An email will be sent to them manually to go through the above and an information on the website itself.
playgram.justw.in also asks for a bank wire/credit card to further insure the Identity of the user/customer. It also gives additional information about the financial situation of the user/customer.
Basic document for step one:
The basic document will be accessible via the setting page on playgram.justw.in. Every user has to fill out the following information:
First name
Second name
Nationality
Date of Birth
The document will be saved and created by an AI, an employee may do additional checks if necessary based on the situation.
Risk management:
In order to deal with the different risks and different states of wealth in different regions on the earth playgram.justw.in will categorize every nation in three different regions of risk.
Region one: Low risk:
For every nation from the region one the three-step verification is done as described earlier.
Region two: Medium risk:
For every nation from the region two the three-step verification will be done at lower deposit, withdraw and tip amounts. Step one will be done as usually. Step two will be done after depositing 1000$ (one thousand Dollars), withdrawing 1000$ (one thousand Dollars) or tipping another user/customer 500$ (five hundred Dollars.) Step three will be done after depositing 2500$ (two thousand five hundred Dollars), withdrawing 2500$ (two thousand five hundred Dollars) or tipping another user/customer 1000$ (one thousand Dollars). Also, users from a low risk region that change crypto currency in any other currency will be treated like user/customers from a medium risk region.
Region three: High risk:
Regions of high risks will be banned. High risk regions will be regularly updated to keep up with the changing environment of a fast-changing world.
Additional measurements.
In addition, an AI which is overseen by the AML compliance officer will look for any unusual behaviour and report it right away to a employee of playgram.justw.in.
According to a risk based few and general experience the human employees will recheck all checks which are done before by the AI or other employees and may redo or do additional checks according to the situation.
In addition, a data Scientist supported by modern, electronic, analytic systems will look for unusual behaviour like: Depositing and withdrawing without longer Betting sessions. Attempts to use a different Bank account to for Deposit and Withdraw, nationality changes, currency changes, behaviour and activity changes as well as checks, if an account is used by it´s original owner.
Also a User has to use the same method for Withdraw as he used for Deposit, for the amount of the initial Deposit to prevent any Money Laundering.
Enterprise-wide risk assessment
As part of its risk-based approach, playgram.justw.in has conducted an AML “Enterprise- wide risk assessment” (EWRA) to identify and understand risks specific to playgram.justw.in and its business lines. The AML risk policy is determined after identifying and documenting the risks inherent to its business lines such as the services the website offers. The Users to whom services are offered, transactions performed by these Users, delivery channels used by the bank, the geographic locations of the bank’s operations, customers and transactions and other qualitative and emerging risks.
The identification of AML risk categories is based on playgram.justw.in understanding of regulatory requirements, regulatory expectations and industry guidance. Additional safety measures are taken to take care of the additional risks the world wide web brings with it.
The EWRA is yearly reassessed.
Ongoing transaction monitoring
AML-Compliance ensures that an “ongoing transaction monitoring” is conducted to detect transactions which are unusual or suspicious compared to the customer profile.
This transaction monitoring is conducted on two levels:
1) The first Line of Control:
playgram.justw.in works solely with trusted Payment Service Providers whom all have effective AML policies in place as to prevent the large majority of suspicious deposits onto playgram.justw.in from taking place without proper execution of KYC procedures onto the potential customer.
2) The second Line of Control:
playgram.justw.in makes its network aware so that any contact with the customer or player or authorized representative must give rise to the exercise of due diligence on transactions on the account concerned. In particular these include:
• Requests for the execution of financial transactions on the account;
• Requests in relation to means of payment or services on the account;
Also, the three-step verification with adjusted risk management should provide all necessary information’s about all customers of playgram.justw.in at all time.
Also, all transaction must be overseen by employees over watched by the AML compliance officer who is over watched by the general management.
The specific transactions submitted to the customer support manager, possibly through their Compliance Manager must also be subject to due diligence.
Determination of the unusual nature of one or more transactions essentially depends on a subjective assessment, in relation to the knowledge of the customer (KYC), their financial behaviour and the transaction counterparty.
These checks will be done by an automated System, while an Employee crosschecks them for additional security.
The transactions observed on customer accounts for which it is difficult to gain a proper understanding of the lawful activities and origin of funds must therefore rapidly be considered atypical (as they are not directly justifiable).
Any playgram.justw.in staff member must inform the AML division of any atypical transactions which they observe and cannot attribute to a lawful activity or source of income known of the customer.
3) The third Line of Control:
As a last line of defence against AML playgram.justw.in will do manually checks on all suspicious and higher risk users in order to fully prevent money laundering.
If fraud or Money Laundering is found the authorities will be informed.
Reporting of Suspicious transactions on playgram.justw.in
In its internal procedures, playgram.justw.in describes in precise terms, for the attention of its staff members, when it is necessary to report and how to proceed with such reporting.
Reports of atypical transactions are analysed within the AML team in accordance with the precise methodology fully described in the internal procedures.
Depending on the result of this examination and on the basis of the information gathered, the AML team:
will decide whether it is necessary or not to send a report to the FIU, in accordance with the legal obligations provided in the Law of 18 September 2017;
will decide whether or not it is necessary to terminate the business relations with the customer.
Procedures
The AML rules, including minimum KYC standards will be translated into operational guidance or procedures that are available on the Intranet site of playgram.justw.in.
Record keeping
Records of data obtained for the purpose of identification must be kept for at least ten years after the business relationship has ended.
Records of all transaction data must be kept for at least ten years following the carrying-out of the transactions or the end of the business relationship.
These data will be safely, encrypted stored offline and online.
Training:
playgram.justw.in human employees will make manual controls on a risk based approve for which they get special training.
The training and awareness program is reflected by its usage:
A mandatory AML training program in accordance with the latest regulatory evolutions, for all in touch with finances
Academic AML learning sessions for all new employees
The content of this training program has to be established in accordance with the kind of business the trainees are working for and the posts they hold.
These sessions are given by an AML-specialist working in MIBS NV’s AML team.
Auditing
Internal audit regularly establishes missions and reports about AML activities.
Data Security:
All data given by any user/customer will be kept secure, will not be sold or given to anyone else. Only if forced by law, or to prevent money laundering data may be shared with the AML-authority of the affected state.
playgram.justw.in will follow all guidelines and rules of the data protection directive (officially Directive 95/46/EC)
Contact us:
If you have any questions about our AML and KYC Policy, please contact us:
By email: support@playgram.justw.in
We respect your privacy and are committed to protecting your personal data. This Privacy Notice will inform you how we look after your personal data when you visit this website, register for a Playgram Account, or if you provide personal data by any other means (for example, over the phone). It also covers our collection of personal data from third parties and publicly available sources such as social media platforms, data aggregators, and credit reference agencies. It sets out your privacy rights and how the law protects them.
We use cookies and similar technologies to collect personal data, browsing actions and patterns.
This Privacy Notice forms an integral part of the Player Terms and Conditions, and by accepting the Player Terms and Conditions, you also accept the terms of this Privacy Notice and the use of your personal data in accordance with this Privacy Notice. If you do not agree with the terms of this Privacy Notice, you should not use this website or otherwise provide us with your personal data.
This Privacy Notice aims to give you information on how we collect and process your personal data when you use this website.
This website is not intended for children, and we do not knowingly collect personal data relating to children.
It is important that you read this Privacy Notice together with any other privacy policy or fair processing policy that we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data.
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this Privacy Notice.
If you have any questions about this Privacy Notice, including any requests to exercise your rights in relation to personal data, you should contact our data privacy manager by email
You have the right to make complaints at any time to the relevant data protection and privacy regulator. We would, however, appreciate the chance to deal with your concerns before you approach the regulator, so we kindly request that you contact us in the first instance.
We keep this Privacy Notice under regular review. This version was last updated on the date at the bottom of this page.
It is important that the personal data that we hold about Players is accurate and current. We kindly request that you keep us informed if your personal data changes at any time whilst you have an account with us.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share personal data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website that you visit.
Personal data, or personal information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We collect personal information which you provide directly to us, such as when you register for a Playgram Account or when you contact customer services. We also collect information from publicly available sources or third parties such as social media platforms and data aggregators.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Photographs include passports and other photographic identification that are collected to verify your identity.
Contact Data includes a billing address, home address (if different to billing address), email address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about deposits and withdrawals from your Playgram Account and other details of services (e.g. casino games) that you have used on the Website.
Technical Data includes internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices Players use to access the Website.
Profile Data includes your usernames and passwords, our services that you have used, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use the Website and our products and services.
Marketing and Communications Data includes your preferences in relation to receiving marketing from us and third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal a your identity. For example, we may aggregate your Usage Data to calculate the percentage of our customers accessing a specific 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.
Where we need to collect personal data by law, or under the terms of a contract we have with you (for example, where it is required under our Player Terms and Conditions), and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the ability to place bets or wagers). In this case, we may have to cancel a product or service that you may be attempting to access, but we will notify you if this is the case at the time.
We use different methods to collect data from and about Players including through:
Direct interactions: you may give us your Identity, Contact and Financial Data by filling in forms on the Website or by corresponding with us by post, phone, email or otherwise.
Automated technologies or interactions: As you interact with our Website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see below in this Privacy Notice for further information on cookies.
Third parties or publicly available sources: We may also receive personal data about you from various third parties as set out below:
● analytics providers;
● advertising networks; and
● search information providers.
● providers of technical and payment services, such as payments solutions providers (PSPs) that facilitate deposits and withdrawals from Playgram Accounts.
● data brokers or aggregators.
We collect your personal information so that we can provide an excellent level of service and so that you can use the Website in an agile and secure way. Collecting personal data also allows us to offer you more customisation on the Website.
The table below explains when we collect your personal information, what we collect it for and why we use it.
| When information is processed | What information we ask for | How and why we use your information |
| When you register for a Playgram Account | Contact Data
Identity Data Financial Data Photographs |
We process this:
● to create and manage your account with us ● to communicate with you about your account We rely on performance of a contract as the lawful basis for collecting and using your personal information. |
| When we communicate with you about the management of your Playgram Account | Contact Data
Identity Data Financial Data Transaction Data Technical Data Profile Data Marketing & Communications Data |
We process this:
● to provide you with the best customised service ● to deal with queries and complaints We rely on performance of a contract as the lawful basis for collecting and using your personal information to manage your account. We rely on our legitimate interest of promoting our products and services. |
| When developing our understanding of our customers to improve our services and website. | Contact Data
Identity Data Transaction Data Technical Data Profile Data Usage Data Marketing & Communications Data |
We process this:
● to understand the behaviours and demographics of our customers ● to understand our customers needs and interests We rely on our legitimate interest of improving our business and services |
| When conducting marketing activity and determining what products, services and offers may be relevant to you | Contact Data
Identity Data Transaction Data Technical Data Profile Data Usage Data Marketing & Communications Data |
We rely on our legitimate interests of marketing our business, services and products
To the extent that we may have obtained your consent that is only consent to receive electronic marketing communications it does not change the legitimate interests basis we are relying on to conduct our marketing activity |
| Conducting our regulatory and compliance obligations | Contact Data
Identity Data Financial Data Transaction Data Technical Data Profile Data Usage Data |
We rely on our obligation to comply with a legal obligation to share information such as with regulators, insurers, or government agencies. This includes conducting anti-money laundering, KYC, anti-fraud checks we may be required to conduct under applicable laws |
You will receive marketing communications from us if either:
(i) you have a Playgram Account and have not opted out of receiving such marketing communications at the time we first collected your personal data or at any time since: or
(ii) If you are not a Playgram Account holder but have requested information from us or used Playgram services through the Website and you have opted in to receiving that marketing.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us or adjusting the marketing settings on the Website.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us for reasons other than marketing.
We may share your personal data with the parties set out below for the purposes set out above.
Internal third parties:
● Other of our group companies acting as joint controllers or processors who may provide services such as IT, HR, customer services and system administration services and who undertake leadership reporting.
External third parties:
● IT service and system administration providers.
● Third parties that licence key software to Playgram without which Playgram would not be able to provide services to you; for example, providers of casino games.
● Payment solutions providers to facilitate deposits and withdrawals from Playgram Accounts.
● Identity verification providers to prevent fraud.
● Third parties that facilitate the sending of marketing communications to you on our behalf.
● Professional advisers including lawyers, bankers, auditors and insurers that provide consultancy, banking, legal, insurance and accounting services to Playgram.
● Tax authorities, regulators, government agencies and other authorities that require reporting of processing activities in certain circumstances.
● Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with applicable law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process the personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances, you can ask us to delete your data; to do so, please see the section 14 below for further information.
Sometimes we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you may have the following rights under data protection laws in relation to your personal data:
● Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you.
● Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data that you provide to us.
● Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal or regulatory reasons which will be notified to you.
● Object to processing of your personal data where there is something about a your particular situation which makes you want to object to our processing as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
● Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
○ If you want us to establish the data’s accuracy.
○ Where our use of the data is unlawful but you do not want us to erase it.
○ Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
○ You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
● Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party they have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
If you wish to exercise any of the rights set out above, you should contact us, and we will confirm whether we are able to do so.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than one month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
